nickwilliams

It looks like it's time to buy a new set of boots for the 90 - I'll be buying a set of five plus rims. I'm pretty much settled on a set of Khumo KL71 and the best deal I've found on line is at 4x4tyres.co.uk. Before I take the plunge and wave my credit card number in their direction, does anyone have any good or bad stories of trading experience with these people, or any other recommendations for suppliers? Thanks Nick.

I can confirm that the ones on this page work with a 300TDi. Nick.

First question is are you sure it's BSP? A lot of vehicle gauge fittings are NPT, not BSP. The two look very similar until you try to make a sealing joint using one of one and one of the other, at which point you find you need more than just PTFE tape, and by the time you've got it tight enough you've probably knackered the threads. I may have got a spare one I can lend you, but I'm in Denmark right now so I can't check. In any case, I'd certainly agree with VB that it would be six quid well spent to add one to your tool kit. Nick.

I've got some work commitments which mean I'm not going to have any time to spend on this over the next few days, although I should be able to forward the comments I made to the DfT to the Commission if I get a reply with the relevant e-mail addresses to send it to. I think we need to keep trying to get the mainstream media interested in this so if others could work on that, it would be helpful. Of the main broadsheet press, the Telegraph seems to have the most active motoring section, and the story might suit their agenda? Nick.

Hmm, I may need to take back some of what I said in my last post. I've just looked at the Commission proposal again and noticed that it's a proposal for a Commission Regulation, not for a Directive. Regulations take direct effect in EU Member States so there is no need for national legislation. This means that there won't be a Statutory Instrument. On some levels this is good since it means that the DfT can't gold plate the proposal, but it also means that we need to ensure that the submission I made to the DfT does actually get to the Commission. I've just e-mailed the Commission contact points to find out where best to send the comments. Nick.

Like I said, I'm not going to get into a debate on the politics of the EU on this forum - this is a technical forum for Landrovers; there are better places for political debate. However, with regard to the way in which this may pass into law, the procedure for Statutory Instruments is subject to parliamentary oversight and the measure will have to be debated if enough MP's question the proposed legislation when it is laid before Parliament. This is why it is important to make sure we get our concerns on the radar of our MPs. As I have already said, concerns about proposals for legislation will largely fall on deaf ears unless they are specific and are focussed on what has actually been proposed rather than hearsay. To that end, there is not a lot of point in making a big fuss with MPs right now - we need to wait until the SI (or a draft) is published and then complain about specific points in it. In the meanwhile, we need to continue to work on the civil servants who will actually draft the legislation. Nick.

I think this confirms that our problem is more to do with the DfT's interpretation of the EU proposals than with the proposals themselves. Whether this is incompetence or due to some hidden agenda is impossible to say, and largely irrelevant since in either case it means that it's the UK Members of Parliament we should be making our case to, not MEP's or UKIP. I've had no response from DfT. If I get time I'll try and chase them up today, unless someone else would like to volunteer to do it. Nick.

You need to be aware that there is a particular cultural issue with this in the UK, which is that a majority of UK citizens are against the idea of them having to carry any form of ID as part of normal daily life. One of the things the current government did when it came to power was to scrap a hugely expensive and overblown system which was intended to introduce ID cards in the face of stiff opposition from the general public. Furthermore, the UK has just spent a prodigious amount of money on a fully computerised MOT database, which makes paper MOT certificates pretty much superfluous. We are already required to carry various pieces of paper when travelling abroad and I don't suppose anyone will be too bothered about having to carry an MOT Certificate as well (although the fact that UK essentially no longer uses them may become a problem in due course). However, that's not the same as being required to carry one while travelling in the UK. Nick.

Hi David, Thanks for your reply. I can understand the frustration that you and your colleagues feel, but I remain of the view that your proposed action will do much more harm than good to your cause. I say 'your' rather than 'our' because I'm not a fervent user of green lanes - I have my own land which is why I have a Land Rover, and while I do occasionally use green lanes, mainly it is because I have a need for access to the land alongside them and so even if the lanes are subject to a TRO, I would still be legally entitled to travel along them. On the other hand, I am also a participant in a minority sport (potholing) and subject to some caveats which I will come to later, am firmly of the view that to be anti-off-roader would be hypocritical. Off roaders have a legal right to their fun, and that legal right should remain so long as it is not excessively to the detriment of other legitimate parties. To respond to your points directly, firstly I should point out that there are significant numbers of people who raise objections to the use of lanes by off-roaders who are not local, and your action will do nothing to change the views of these people. Most locals are not the walkers who make all the fuss. Secondly, and probably more relevant, the majority of local people are not vocal objectors to off-road users but they most assuredly will become so if you take action which starts to affect them directly. I am absolutely certain that the theory that by making life difficult for these people you will win them over to your cause is utterly misguided. You are going to make a great many more enemies than friends with this action. Thirdly, this proposal is tantamount to bullying. You are basically saying 'you've made our lives difficult so now we're going to make yours difficult'. This is no way to behave in an adult, civilised society. I am afraid I do not agree that you've tried everything else and this is now your only alternative - if this truly is the case then you have already lost your battle. Specifically with regard to School Lane in Great Hucklow, I am probably more familiar with what happens on the Lane at different times of day and year than any other individual - I am writing this message sat at my desk in the office at the bottom of the Lane and my family own property which borders on to it. My children go (or went) to the School which is half way up it. Notwithstanding all I have already said, I am of the view that School Lane is an archetypical example of a lane which should be closed to off-roaders and the TRF (and others) have made a significant error of judgement in trying to fight for it to remain open. It would have been much more sensible for them to accept early closure of School Lane in return for maintenance of Blackberry Lane which is longer, a much more interesting drive and (most significantly) sufficiently far away from any houses that its use by off roaders would not cause unreasonable disturbance. I cannot formally speak on behalf of the Parish Council but let's just say I would be surprised to discover that their view differed markedly from my own. I have personally seen groups of trail riders doing wheelies up School Lane past residents' houses at 8:00 am on a Sunday morning, and at other times forcing their way past infant children leaving school in the afternoons. Neither of these things are pleasant, and the latter is completely unacceptable on safety grounds if no other. I am forced to conclude that the only way to be sure that the lane is acceptably safe for my own and other children is to close the top part of Lane to all vehicles then that is a price worth paying. I have attended Parish Council meetings, first as an observer, and latterly as a Councillor, for over five years and the subject of off-road vehicles has come up at every single meeting I have been to. In that time there has never been an approach by the TRF or any other off-road user group to talk about the use of local lanes with the Council. Nor has there ever been any attempt to attend at the Village Gala to talk to people, or (as I suggested above) simply make yourselves available to explain your interests. On this basis, I am afraid I simply do not accept that you have done all you could do to win the hearts and minds of the locals. As regards your attendance at a PC meeting, I cannot say that you would necessarily have a comfortable time, but if you prepared the ground suitably in advance then you would, I think, be given the chance to put your case and you would at least gain some respect for making the attempt to communicate. The bigger issue, so far as Hucklow PC in particular is concerned at least, is that because of the safety issue I cannot see you changing the view of the Council over School Lane and so far as I am aware all the other lanes within the Parish are already subject to TROs so you would probably be wasting your time. However, the principle applies to all other PC's across the Peak and I don't think you can genuinely claim to have done all you can to communicate your case to the locals until you have at least attempted to speak to all of them (or at least those where there are lanes under threat). There is much else which could be said on this topic but it's late and I think I would only end up repeating myself. However, I will leave you with one final thought. I am absolutely convinced that the single most beneficial thing which off road users could do to help in their relationship with local people and other users of lanes would be to argue for and help to enforce a ban on vehicle noise which exceeds a nominal level. (I don't know what that number should be, but it needs to be comparable to a normal family car). Noise is the single greatest nuisance suffered by local people in particular, and bearing in mind that it is entirely possible to have a vehicle (motorcycle or 4x4) which is quiet (we do see some of them), it is specious to argue that the noise is somehow an essential part of the activity. Personally I like the roar of a well tuned multi-cylinder engine as much as the next petrol head, but even I could live without the racket from ten or twenty two stokes belting past my window, which happens here on a regular basis (by which I mean several times a day on many weekends). Anyway, it's been a long day, and now I'm off to bed. Cordially Nick. PS - for the avoidance of doubt, where I have referred to 'you' in the above, I do not necessarily mean you personally, of course!

OK, here is what I have sent: From: Nick Williams <nick.williams@address.deleted> Subject: Consultation on EU roadworthiness proposals Date: 6 September 2012 19:23:35 GMT+01:00 To: mark.heverin@dft.gsi.gov.uk Dear Mr Heverin, Consultation on EU roadworthiness proposals. The following comments are made on behalf of the LR4X4 forum, which represents a group of stakeholders who interests are primarily the maintenance and modification of old Land Rover vehicles. The group has somewhat more than 30,000 members. Please note that I would have used the Excel format reply for the consultation but I have been unable to do so due to software compatibility issues. I would be grateful if you would: - confirm receipt of this message; - confirm that these comments will be taken into account in your representations to the Commission; and - ensure that I am kept informed of any further developments on this issue. Please do not hesitate to contact me if you have any questions or if I can be of any further assistance. Regards Nick Williams <address details deleted> The Commission proposes to bring all trailers capable of more than 40kph into the scope of periodic testing. This includes all currently exempt trailers below 3,500 kg (including caravans). The proposal includes a very wide range of trailer and no evidence has been presented that all trailers present risks which would warrant the introduction of these measures. We would particularly draw attention to the following points: 1. There appears to be no justification for treating all trailers in the same way. It seems likely that the benefits of the proposal will be much lower for small trailers and those which only do low annual milage. 2. Poorly maintained or overloaded agricultural trailers clearly present a danger and it is nonsensical to exclude these if other trailers are to be subject to regular testing. 3. A requirement for trailers to be roadworthy does not necessarily imply that this can only be achieved by regular testing. Suitable enforcement of a general requirement for roadworthiness, including roadside examination of trailers, is likely to be a much more cost effective solution on a community-wide basis than requiring all trailer owners to pay for regular independent checks. While it may be beneficial to introduce inspections for heavy trailers or those subjected to high milage, it is difficult to conceive that the cost of the proposal is justified for small trailers, particularly if a registration system (which would presumably be required to make the proposal workable in practice) is introduced. We would argue that in its current form the proposal should be dropped entirely but failing this it should be modified to exclude all unbraked trailers under 750kg and any trailer or caravan rated at less than 3500 kg used for non-commercial purposes. The Commission proposes to bring motorcycles into scope of periodic testing. This is already done in GB but will become a requirement EU wide. It will add analysis of exhaust fumes. LR4x4 does not represent motorcycle users and so we have no comment to make on this proposal. The Commission proposes to introduce a definition for a roadworthiness test that components of the vehicle must comply with characteristics at the time of first registration. This may prevent most modifications to vehicles without further approval of the vehicle. (this will apply to many components and to all types of vehicle) LR4X4 members are particularly concerned by this proposal since we believe that if it is introduced in its current form it may be used to limit the scope of modifications which can be undertaken to road going vehicles after they have been first registered. It is not clear to us whether this is in fact what the Commission proposes, and we would be very concerned if it was. We would point out that there is a very considerable industry in the UK which supports after-market modifications to vehicles, and would urge DfT to ensure that this industry's interests are fully represented. We would also point out that the proposal to a large extent misses the point that it is perfectly possible to repair a vehicle with parts which retain the same characteristics as the original parts, but which nevertheless result in the vehicle being unsafe because the workmanship is poor. Furthermore, it is possible to change the manufacturer's original parts for others which provide a worthwhile enhancement to the safety of the vehicle, and as currently worded this proposal will make this practice impossible. The critical point is not whether the vehicle characteristics have been changed, it is whether the change results in an increase in the risks to the driver and other road users, and whether the tester has the competence to judge this matter correctly. While we accept that all modifications to road going vehicles must be safe, and that there may be circumstances where that safety should be independently verified, we are adamant that the principle of vehicle modifications being permitted must remain. We do not accept that it is necessary to introduce anything more stringent, expensive or frequent that the current UK's SVA/IVA/MOT test regime which we note already contains a system for identifying a threshold for vehicle modifications which require independent testing and approval. The proposal as currently worded is too blunt an instrument and too ambiguously worded. The Commission needs to re-think its approach in this regard. The Commission proposes to change the definition of an Historic Vehicle that may be exempt from periodic testing. This may allow vehicles older than 30 years to be exempt from testing providing the vehicle has been maintained in its original condition, including its appearance. We note that the UK already has plans to implement this and we believe that this it is sensible to exempt historic show vehicles from testing subject to certain conditions. However, our members do not consider their vehicles as historic and would not be eligible to apply this exemption so it must not be used as a basis for failing to address our concerns expressed in the previous point. The Commission proposes that all vehicles must be subject to periodic testing except historic vehicles, forces and emergency vehicles, agricultural vehicles limited to less than 40kph and specialist funfair/circus vehicles limited to 40kph. If safety is the primary concern then it does not make sense to exempt even the above vehicles, but any measures taken must be proportionate to the risk (based on scientifically gathered and publicly available evidence) and must not increase financial or other burdens on operators. The Commission proposes that new tests and testing equipment are introduced. The equipment details are contained in Annex V of the proposed Periodic Testing Regulation. New elements include testing of brake fluid, light intensity, shock absorber testers, changes to brake testing equipment and a number of others. There is insufficient time given for a detailed response to these proposals, but as a general principle, tests should only be introduced for which there are already commercially available test equipment from competitive sources. We would also observe that in many cases it is not necessary for expensive test equipment to be used in order to provide for a test requirement - a properly designed simple visual test will provide most of the safety benefits at minimal cost. The Commission proposes that all Member States make it compulsory for odometer distances to be shown on test certificates and that tampering with an odometer becomes an offence subject to a penalty. We agree with this proposal (which is already a requirement in the UK). The Commission proposes to introduce definitions of severity into test. Minor defects would result in a test failure but would not prevent a certificate being issued. (The vehicle owner is expected to correct the failure without needing to have it re-confirmed by the tester). We agree with this proposal. The Commission proposes that in the case where a vehicle has dangerous defects discovered at test, that the vehicle shall not be used on public roads and the registration of the vehicle must be withdrawn until the defects are rectified. We agree with this proposal (which is already a requirement in the UK). The Commission proposes new rules regarding the training of vehicle testers. This includes new areas of knowledge and compulsory annual retraining for all testers. (details are contained in Annex VI of the draft Periodic Testing Regulation). Clearly vehicle testers must be competent and their knowledge must be up-to-date, but we are concerned that a formal requirement for annual training will result in an unnecessary increase in costs. Most vocational training in the UK requires three or five yearly compulsory refreshers with intermediate training only required when necessary. A system with similar flexibility for vehicle inspectors should help to minimise the costs for all stakeholders. The Commission proposes that the drivers of a vehicle registered in a Member State shall keep on board the roadworthiness certificate corresponding to the latest roadworthiness test and the report of the last roadside inspection (if applicable). We do not agree with this proposal which is contrary to the widely held UK principle that private individuals should not be required to carry ID or other official papers as part of their normal daily activities. Our strongly held view is that the current UK system whereby the vehicle papers can be taken to a police station within a reasonable period of a correctly delivered request is adequate. We would also point out that the Commission proposal is entirely superfluous in the UK now that the MOT registration system is fully computerised and registration/MOT details are available to enforcement officers via fully portable data terminals. If the UK were to capitulate to this requirement then UK motorists would be fully entitled to question the recent investment in the systems required to implement ANPR, SORN and continuous insurance. The Commission proposes that when major or dangerous deficiencies have been found following a more detailed roadside inspection, Member States may require the payment of a fee. Our view is that this principle needs careful consideration. There is already a problem in the UK with the lack of control over the costs of vehicle recovery from public roads (e.g. motorways) and the lack of transparency in the relationship between vehicle recovery operators and the police. If the Commission proposal is used as an opportunity to introduce better transparency and fairer costs in this area then we will support it. However, as a principle, for any criminal or civil sanction (including a fine) to be applied, there must be a proper hearing with a meaningful right of appeal and the burden of proof must be on the authorities, not on the motorist. Any costs levied, including those which are classified as 'fees' rather than 'fines' must be transparently justifiable, consistent, reasonable and proportionate and should be subject to oversight by an independent regulator. The Commission proposes that all vehicle manufacturers will make available to test centres all technical data covered by the Certificate of Conformity. (As per annex I of the draft Periodic Testing Regulation). (Vehicle manufacturers includes makers of any non rail bourne motor vehicle or trailer). This is mainly a matter for vehicle manufacturers, but we would observe that 'all technical data covered by the certificate of conformity' is both unnecessary and unworkable in the context of an MOT examination. Testers do not need access to 'all' of the information associated with a vehicle type approval, they won't understand much of it, and the motorist should not be expected to pay the extra costs associated with making it available. The proposal also raises considerable potential issues of commercial confidentiality. We would suggest that the correct approach is the standardisation of information delivery, interfaces and systems rather than the mandatory provision of commercially sensitive information.

David, Just a note to say I will reply on these points in a few days, when I get time - responding to the DfT on the EU MOT proposals has a higher priority today. I understand you are reasonably local - I would be happy to meet to discuss this over a pint if you'd like. PM me your contact details if this is of interest. Nick.

Oh, one more thing! It would be useful to be able to state how many members (to the nearest 5% or so) LR4X4 has. Nick.

This is a REALLY bad idea. As a resident of Great Hucklow (and member of the Parish Council) I can tell you that the chances of this having the desired effect of 'recruiting the residents to our cause' are precisely nil. The only result this action will have is tiddle off the people who are not normally affected by off roaders so that they become virulent anti's as well. The idea that this kind of action will result in converting the view of the locals to favour trail bikes and off road enthusiasts, or that the local farming community will some how rise up in support of the cause is fanciful nonsense. In the International forum there is a thread about the potential for new rules on MOT's to outlaw modified vehicles from UK roads. People need to realise that there is a substantial constituency of people out there who would like to see non-professional use of off-road vehicles banned completely. Currently, there is no easy way the government could do this even if they wanted to (it would require primary legislation which would be far to difficult to frame without too many unacceptable side effects) but the new MOT requirements provide a perfect opportunity for a ban to be introduced by the back door, and the government can even shift the blame on to Europe. If you want to have a positive impact, don't send a load of vehicles with the express intention of making life difficult for people, send two or three well turned out vehicles with presentable, articulate and polite drivers and sit them in a prominent place in the village for a few hours so that the locals can come up and talk to you. Send representatives to parish council meetings. Give local people contact names and numbers where they can complain about problems and try to find ways of sorting them out. Find a way to control the idiots who drive too fast, in the wrong places and at the wrong time. TRF and other off road groups need to work A LOT harder at winning the hearts and minds of local people. Nick.

Can I take that as the 'OK' to contact DfT in the name of the forum, then? Nick.

I think this is a great idea but it would be good if someone else would take on this aspect. I'd start by trying to contact TG's producer, Andy Willman, rather than one of the presenters. I think it's less important for this to be done in the name of the forum BTW. Nick.

Sorry, I'm obviously being dim - what's the A&M section and which post are you referring to? I spent a few minutes looking for guidance in the 'LR4x4 Matters' forum but it did not leap out at me. Nick.

The reply was supposed to be in yesterday, but I don't think it's critical if we miss the deadline by 24 hours or so. But that's why I want to do this today if possible. Nick.

I think it would be good to get a response to the DfT today if we can (or, at least, this evening) so they have time to look at it before the end of the working week. Can the Mods let me know if they are willing for this to go in the name of the forum - if not I will send as being from a group of concerned individuals. Incidentally, how does one raise things such as this with the Mods? The 'Report' function for each post says it should only be used for reporting abuse, and not for contacting the mods for other matters. Nick.

The word used is 'fees' not 'fines' which implies that they are looking to promote a non-judicial charge to help offset the costs incurred by (in the UK) VOSA, police etc. This is a very dodgy area since the I suspect the whole point of defining these as 'fees' rather than 'fines' is that there is then no need to subject them to the checks and balances of a proper judicial process. In fact the Commission have a pretty good record of supporting the interests of consumers on this kind of thing (e.g. recent changes to the mobile phone roaming rates across Europe) but I hate to think how this will turn out once the grasping fingers of the police and the quasi civil-service agencies such as VOSA get involved. I think I could do with some better ideas for wording here. Any suggestions? Nick.

It's not clear from that page how often MOT testers currently have to do refresher/retraining, which was the point i was trying to get to since if they are currently not required to do annual re-training then requiring them to do so will add cost. Do you know how often refresher training is required under current MOT rules? Nick.

Useful comments, Matt, thanks a lot. Nick.

Not heard anything from a moderator yet - I was going to let this run until this afternoon before deciding what to do next. Got a day job to do as well! I've been thinking a bit more about the submission following the debate last night, and have come up with some new words for some of the sections. The new bits are shown in purple below. Further comments welcome. Nick. The Commission proposes to bring all trailers capable of more than 40kph into the scope of periodic testing. This includes all currently exempt trailers below 3,500 kg (including caravans). The proposal includes a very wide range of trailer. While it may be beneficial to introduce inspections for heavy trailers or those subjected to high milage, it is difficult to conceive that the cost of the proposal is justified for small trailers, particularly if a registration system (which would presumably be required to make the proposal workable in practice) is introduced. We would suggest that the proposal is modified to exclude all unbraked trailers under 750kg and any trailer or caravan rated at less than 3500 kg used for non-commercial purposes. The Commission proposes to introduce a definition for a roadworthiness test that components of the vehicle must comply with characteristics at the time of first registration. This may prevent most modifications to vehicles without further approval of the vehicle. (this will apply to many components and to all types of vehicle) LR4X4 members are particularly concerned by this proposal since we believe that if it is introduced in its current form it may be used to limit the scope of modifications which can be undertaken to road going vehicles after they have been first registered. It is not clear to us whether this is in fact what the Commission proposes, and we would be very concerned if it was. We would point out that there is a very considerable industry in the UK which supports after-market modifications to vehicles, and would urge DfT to ensure that this industry's interests are fully represented. While we accept that all modifications to road going vehicles must be safe, and that there may be circumstances where that safety should be independently verified, we are adamant that the principle of vehicle modifications being permitted must remain. We do not accept that it is necessary to introduce anything more stringent, expensive or frequent that the current UK's SVA/IVA/MOT test regime. We would also point out that the proposal to a large extent misses the point that it is perfectly possible to repair a vehicle with parts which retain the same characteristics as the original parts, but which nevertheless result in the vehicle being unsafe because the workmanship is poor. Furthermore, it is possible to change the manufacturer's original parts for others which provide a worthwhile enhancement to the safety of the vehicle, and as currently worded this proposal will make this practice impossible. The proposal is currently too blunt an instrument and too ambiguously worded. The Commission needs to re-think its approach in this regard. The Commission proposes that the drivers of a vehicle registered in a Member State shall keep on board the roadworthiness certificate corresponding to the latest roadworthiness test and the report of the last roadside inspection (if applicable). We do not agree with this proposal which is contrary to the widely held UK principle that private individuals should not be required to carry ID or other official papers as part of their normal daily activities. Our strongly held view is that the current UK system whereby the vehicle papers can be taken to a police station within a reasonable period of a correctly delivered request is adequate. We would also point out that the Commission proposal is entirely superfluous in the UK now that the MOT registration system is fully computerised. If the UK were to capitulate to this requirement then UK motorists would be fully entitled to question the recent investment in the computerisation systems required to implement SORN and continuous insurance.

That may well be true for the standard MOT stations which specialise in Euroboxes, but this forum is populated by people who would be able to make a reasonable judgement in such cases, so they do exist. I'm not convinced that insurance is a barrier - on two levels: one is that I make decisions on the safety of machinery for a living, and I don't have any problem getting insurance; the second is that it would be possible to word the legislation so that insurance for is primarily the responsibility of the vehicle owner, not the approval body - i.e. largely the situation we have already. Agree with that, although the aftermarket modification business (think of all those electricity/water/gas company wagons) may have similar interests to us. I'm not so sure. IVA (and, for that matter, WVA for trucks) do not necessarily require all this analysis, although I think you are right that we need to be vigilant to avoid these fears becoming a reality. Nick.

An interesting and useful contribution. How long ago was this? I think your message neatly sums up the dilemma - at one extreme you have Spain wanting to go through a ridiculous pantomime just for a spare wheel carrier, at the other extreme you have the UK which permits people to bugger about with their suspension or brakes pretty much willy nilly. In the long run, I think we'll end up with a situation which is much less polarised across the EU, somewhere in the middle. One point I'd make is that the IVA is a recognised type approval mechanism under the Whole Vehicle Type Approval Directive so there will always be a route by which a modified vehicle can be approved. Once it is approved then the MOT test (which is what this proposal is about) will be there to ensure that it remains safe. This proposal makes no change to the basic structure of that regime. However, I readily accept that we want to avoid the situation where simple modifications (and repairs) require any form of expensive independent check or approval. It seems to me that we will probably end up with a list of the modifications/repairs which should be permitted without any form of check, those that require a basic safety check (i.e. the equivalent of a current MOT) and those which require a more detailed check. Something like this: No checks required: - Change lightbulbs - Change any lubricant or fluid (except brake fluid) - Replace damaged cosmetic body parts - Add additional mirrors, lights - etc. Basic safety check: - Change brake components (including fluids) with like-for-like parts - Repair to chassis/bodywork requiring welding - Change seats/seat belts - Replace engine/gearbox with part with same (+/-10%) power/torque - Replace suspension components with like-for-like parts - etc Advanced safety check - Replace chassis - Replace engine with different power/torque - Replace brake/suspension components with non original spec. parts - etc. It might be in our interests to take the initiative and start work on this list. Nick.

This page is worth a look: http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/12/555&