Snagger Posted September 5, 2012 Share Posted September 5, 2012 Top Gear is a hugely popular programme across Europe and so has a fair bit of influence. Trying to get them onside shouldn't be hard - Clarkson and Hammond are both LR fans anyway and the whole team are mad about Range Rovers, and they frequently modify vehicles in all sorts of daft ways - so trying to get them to run a big piece on this might be a way of getting a lot of public awareness and support across the continent, and thus get the attention of the politicians. Quote Link to comment Share on other sites More sharing options...
discomikey Posted September 5, 2012 Share Posted September 5, 2012 sounds a good plan snagger. Quote Link to comment Share on other sites More sharing options...
Snagger Posted September 5, 2012 Share Posted September 5, 2012 Ultimately, it comes down to public opinion - MPs will block policy that will cost them elections. Look at the Heathrow third runway debate for a prime example - facts and logic aren't coming into it; it's all about public opinion and votes. Quote Link to comment Share on other sites More sharing options...
nickwilliams Posted September 6, 2012 Share Posted September 6, 2012 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. Quote Link to comment Share on other sites More sharing options...
Happyoldgit Posted September 6, 2012 Share Posted September 6, 2012 The report function will bring it to the attention of the mods for that section, if necessary they in turn are then able to flag it to the entire team. There is a post in the A&M section on this issue Quote Link to comment Share on other sites More sharing options...
zoltan Posted September 6, 2012 Share Posted September 6, 2012 Nick, To save time, can you word it such that the subject has been debated by a group of individuals on the LR4x4 Land Rover Internet Forum? Be terrible to miss the deadline because Mods couldn't agree on a policy quick enough. Once again, thank for taking the initiative on this and pressing on so quickly Quote Link to comment Share on other sites More sharing options...
nickwilliams Posted September 6, 2012 Share Posted September 6, 2012 Nick, To save time, can you word it such that the subject has been debated by a group of individuals on the LR4x4 Land Rover Internet Forum? Be terrible to miss the deadline because Mods couldn't agree on a policy quick enough. 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. Quote Link to comment Share on other sites More sharing options...
nickwilliams Posted September 6, 2012 Share Posted September 6, 2012 The report function will bring it to the attention of the mods for that section, if necessary they in turn are then able to flag it to the entire team. There is a post in the A&M section on this issue 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. Quote Link to comment Share on other sites More sharing options...
nickwilliams Posted September 6, 2012 Share Posted September 6, 2012 Top Gear is a hugely popular programme across Europe and so has a fair bit of influence. Trying to get them onside shouldn't be hard - Clarkson and Hammond are both LR fans anyway and the whole team are mad about Range Rovers, and they frequently modify vehicles in all sorts of daft ways - so trying to get them to run a big piece on this might be a way of getting a lot of public awareness and support across the continent, and thus get the attention of the politicians. 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. Quote Link to comment Share on other sites More sharing options...
Bowie69 Posted September 6, 2012 Share Posted September 6, 2012 A&M = Admin and Mods section Quote Link to comment Share on other sites More sharing options...
Happyoldgit Posted September 6, 2012 Share Posted September 6, 2012 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. To clarify - the A&M section is a separate area of LR4x4 which admins and mods [A&M's] are able to access in order to discuss forum issues and matters. This thread was flagged to us by way of a report yesterday and a discussion regarding it was subsequently instigated and underway in the A&M section. A&M's login and participate to the A&M section usually on a daily basis. Quote Link to comment Share on other sites More sharing options...
Happyoldgit Posted September 6, 2012 Share Posted September 6, 2012 Of those A&M's that have replied to date the response has been positive Quote Link to comment Share on other sites More sharing options...
nickwilliams Posted September 6, 2012 Share Posted September 6, 2012 Can I take that as the 'OK' to contact DfT in the name of the forum, then? Nick. Quote Link to comment Share on other sites More sharing options...
nickwilliams Posted September 6, 2012 Share Posted September 6, 2012 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. Quote Link to comment Share on other sites More sharing options...
Happyoldgit Posted September 6, 2012 Share Posted September 6, 2012 Can I take that as the 'OK' to contact DfT in the name of the forum, then? Nick. Yes indeed. Quote Link to comment Share on other sites More sharing options...
Happyoldgit Posted September 6, 2012 Share Posted September 6, 2012 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. You'll find some stats at the bottom of the index page Nick, according to those the total membership stands at 31,616. Quote Link to comment Share on other sites More sharing options...
nickwilliams Posted September 6, 2012 Share Posted September 6, 2012 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. Quote Link to comment Share on other sites More sharing options...
simonr Posted September 6, 2012 Share Posted September 6, 2012 Well done Nick - that's fantastic! Si Quote Link to comment Share on other sites More sharing options...
western Posted September 6, 2012 Share Posted September 6, 2012 read through as well, lets hope those in power take notice, great work Nick. Quote Link to comment Share on other sites More sharing options...
zoltan Posted September 6, 2012 Share Posted September 6, 2012 Yes, excellent work Nick! Thank you. Quote Link to comment Share on other sites More sharing options...
Happyoldgit Posted September 6, 2012 Share Posted September 6, 2012 Excellent! Thanks Nick. Quote Link to comment Share on other sites More sharing options...
steve b Posted September 6, 2012 Share Posted September 6, 2012 Thats great Nick , thanks for jumping in with no notice , a great job cheers Steveb Quote Link to comment Share on other sites More sharing options...
discomikey Posted September 6, 2012 Share Posted September 6, 2012 thanks nick, great job Quote Link to comment Share on other sites More sharing options...
TheRecklessEngineer Posted September 6, 2012 Share Posted September 6, 2012 That's awesome Nick. Thanks from me! Quote Link to comment Share on other sites More sharing options...
UdderlyOffroad Posted September 6, 2012 Share Posted September 6, 2012 Nice work Nick, sorry I didn't get back to you in time with feedback re your responses to my comments (work commitments+taking Mrs Udderly out for a much needed dinner+drinkies). Let's hope you get a response acknowledging your comments have been added Quote Link to comment Share on other sites More sharing options...
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