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Update
from the FBHVC on the new EU proposal for roadworthiness testing
See the
latest FBHVC newsletter. More
See the report
on the Octane magazine website. More
See our Information Gateway with links to articles on MOT tests
for classic cars of interest to MGV8 enthusiasts. More
The
FBHVC says "It
should be remembered that this is still just a proposal.
It has to have approval by each EU member country before it
is adopted. Some media commentary on this topic has tended
towards the 'we're doomed' end of the scale. It is
certainly a serious issue and FBHVC is treating it accordingly."
Posted: 121001
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Roadwortiness
testing: new proposal from the EY Commission
When the European Parliament Historic Vehicle Group
(EPHVG) met in May 2012, Szabolcs Schmidt the head
of the EC Road Safety Unit, mentioned that proposals
for revisions to the Roadworthiness Testing Directive,
following a 2010 consultation, were expected 'in
the summer'. In July 2012, |
the
European Commission published the detail which turned
out to be a proposal to replace the current Roadworthiness
Testing Directive (2009/40/EC) with a completely
new Regulation. The difference between a Directive
and a Regulation is that each Member State must
adopt a national law to implement a Directive
while a Regulation is binding in its entirety
and directly applicable in all Member States.
In its latest newsletter, the FBHVC says "it
was unfortunate that the editorial deadline for
the August FBHVC newsletter closed on 9th July and
this important item was issued four days later.
However, subsequently the Department for Transport
issued a 'Request for information circular' to assist
them in negotiations with the EU Commission. On
such an important matter we decided to issue a press
release on 23rd August to make our views widely
known and included on the mailing list were all
the member clubs for whom we have email addresses
as well as our press database."
The draft of the new Regulation has implications
for all motorists, not just historic vehicle owners.
Amongst other things, the draft includes requirements
to test all trailers (which in turn implies a registration
system) and requires tests to make reference to
a vehicle's original 'technical characteristics'.
The meaning of this expression is not defined.
Arrangements for vehicles of historic interest
National governments are granted the right to make
their own testing arrangements for 'vehicles of
historic interest'. A vehicle of historic interest
is then defined as one that:
> Was manufactured more than 30 years ago
> Is maintained by use of replacement parts which
reproduce the historic components of the vehicle
> Has not sustained any change in the technical
characteristics of its main components such as engine,
brakes, steering or suspension; and
> Has not been changed in its appearance.
FBHVC considers this definition to be unworkable
and completely unacceptable. FBHVC also rejects
the suggestion that Roadworthiness Testing should
relate to a vehicle's 'technical characteristics',
whatever the age of the vehicle. Modifications,
alterations and improvements are all part of the
history of motor vehicles and the older the vehicle,
the more likely it is that it will have been altered
at some stage. At present the basic tenet of a UK
MoT test is that it is one of mechanical fitness.
There is no database of original specifications
for UK vehicles, so testing to original 'technical
characteristics' is simply pie-in-the-sky.
Earlier this month, the Department for Transport
asked stakeholders for comment on the proposals.
FBHVC will be responding formally to this request
when further analysis of the detailed proposals
has been completed. FBHVC will be discussing the
implications of the proposal with the international
organisation, FIVA, and through them with the EPHVG
group as well as with the All Party Parliamentary
Historic Vehicle Group in the UK.
Avoiding
thehysteria and "we're doomed" mentality
It should be remembered that this is still just
a proposal. It has to have approval by each EU member
country before it is adopted. Some media commentary
on this topic has tended towards the 'we're doomed'
end of the scale. It is certainly a serious issue
and FBHVC is treating it accordingly.
FBHVC input to the DfT consultation
Since
the above was circulated the Federation has formally
replied to DfT's information request within the
short deadline allowed. We pointed out that the
proposed definition of a 'vehicle of historic interest'
is unworkable, explained why, and offered a suggestion
for a simpler two-stage definition of a vehicle
of historic interest that would not change the status
of any vehicle considered historic under the current
Roadworthiness Testing Directive. We also pointed
out that testing of trailers would require the establishment
of costly registration and testing systems for little
road safety benefit (it is understood that most
trailer related accidents occur as a result of tyre
failure) and objected to the notion, inherent in
the proposal, that conformity to original technical
characteristics has any bearing on roadworthiness.
We
anticipate a continuing dialogue with DfT as the
EU debate continues. Certainly the FIVA Legislation
Commission (of which I am a member) is unhappy with
the restricted nature of the definition of a 'vehicle
of historic interest' contained in the draft. |
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