DVLA CONCERNS From Monty Goding

DVLA Concerns:

The All-Party Parliamentary Historic Vehicles Group Becomes Involved

I attended the AGM of the Federation recently and listened to their reports which gave reasons for the lack of progress with negotiations with the DVLA regarding non-acceptance of new bodies on cars with separate chassis. Privately I expressed my concerns to the lead officer and suggested that it was possibly time to start involving our MP’s. I was persuaded to wait a while before proceeding in that the Federation intended to have a Meeting with the Chairman of the All-Party Parliamentary Historic Vehicles Group but no date was given. I have heard no more from the FBHVC.

However, on receiving my copy of The Automobile for December, I was pleased to see a piece in the Editorial reporting a meeting between Sir Greg Knight MP, the Chairman of APHVG and the Transport Minister, John Hayes MP. The Automobile like me had been concerned that after an initial flurry of activity by the FBHVC, little progress had been made over the intervening months. I rang The Automobile and they very kindly sent me a copy of the press release from Sir Greg Knight. I reproduce it below in full but without the header and footer:-

8^th November 2016                     Release date: Immediate

DVLA Concerns: Sir Greg Knight Sees Transport Minister

The Chair of the All-Party Parliamentary Historic Vehicle Group, Sir Greg Knight MP has met the Transport Minister to discuss concerns about the new DVLA attitude and their procedures concerning historic vehicles.

Sir Greg had asked for the meeting to outline his disquiet about DVLA policy in respect of those vehicles that have been fitted with new parts, following complaints received from a number of historic vehicle owners around the country.

Following the meeting, Transport Minister John Hayes MP agreed to look into the matter and report back to Sir Greg.

Sir Greg said today: “Just because a historic vehicle has a number of replacement parts should not mean that it ceases to be historic. There is a distinction to be drawn between a brand new vehicle which is a replica of a historic car and a genuine historic vehicle which has been fitted with new parts to keep it on the road”.

“The Minister has promised to ask the DVLA to look again at any case where it is felt an injustice is done and I welcome this”, said Sir Greg.

The meeting organised by Sir Greg, was also attended by officers of the Federation of British Historic Vehicle Clubs.

Press Release ends.

I am extremely pleased that the whole issue has now been brought into the open and hope that this will quickly move on to a position where our Members who are restoring cars but using new bodies possibly different to that originally fitted, will be able to obtain an age-related number. We know that under current DVLA rules they cannot, and the DVLA have been immovable.

Monty Goding

21 November 2016

DVLA and Registration of Vehicles – by Monty Goding

Following the decision to close the DVLA local offices, the Head Office at Swansea has brought in more stringent rules governing the applications for retention of existing registrations and the provision of age-related numbers to those cars where there are no documents available.

It has been known within the Movement that there had been a number of cases where age related numbers had been issued to cars that were primarily constructed from new parts. More importantly the DVLA had established that in some cases this had been done with the full approval of the particular specialist Club.

The repercussions have been felt in a far wider community than those creating Evocations. For those not familiar with this word it is a description of a car constructed to represent a model other than that from which the parts for restoration arose. This usually means one of greater rarity and therefore value which could in the fullness of time be passed off as a genuine example.  It also refers to cars constructed from all new parts with the same object.

Within our Club Margaret has been carrying out work on the application for retention of registration numbers and for age related numbers for a number of years. She has set up very careful procedures with inspection by the Club of all vehicles and by virtue of being in possession of the original factory records she is able to satisfy most of the requirements of DVLA. However, the Club has recently run into some difficulty assisting a minority of our Members requiring age related numbers for cars where they have applied a new body to the rolling chassis which may be of a different design to that originally fitted.  We have been informed by DVLA that they cannot issue age related numbers to these vehicles although we believe this to be a change of policy.

This particular aspect of the DVLA work was considered outside that of the normal work of the Registrar and the Chairman asked me if I would assist. BNMC had asked to attend the conference at DVLA last September and was not invited. Since then DVLA have insisted that they are applying the same rules as before. They have also stated that they will only deal with these issues through the FBHVC.

I have in the past discussed this with the Chairman of the FBHVC and also the President of the VSCC where the building of specials is part of the culture. They had both told me that they had heard apocryphal tales of cars turned down by DVLA but had not seen clear evidence.  I therefore provided a full evidential file, as submitted to DVLA,  to both, of a car that had a full correct rolling chassis for a vintage Morris but with a professionally built two seater body in true vintage style (but not copying a famous car), that we had supported but which had been rejected.
I am grateful to have permission to report the following from the Committee Notes and The President’s Message (Tim Kneller) in the VSCC Newsletter.

VSCC Committee Notes:

The President had also received paperwork from the Chairman of the Bullnose Morris Club (sic) with regards to problems with DVLA registration and had a subsequent conversation where possible solutions were discussed.

VSCC President’s Message from Tim Kneller, who is also a BNMC member and owner:

In late May Dave Salmon (VSCC Chief Executive) and I met with David Whale the Chairman of the Federation of British Historic Vehicle Clubs. David gave a very candid report of recent progress.  He reported that following a lengthy delay after the departure of John Vale the Federation had now made contact with the new incumbent.  The Federation have spent considerable time in going back through past legislation to demonstrate that the DVLA’s position on cars with separate bodies and chassis is not correct.  This has been enhanced by their unearthing of the Ministry of Transport’s Handbook about taxation and registration of vehicles, which clearly states that a change of body on a car with a separate chassis does not constitute a change of identity.  This information has been compiled into a paper , which the Federation has submitted to DVLA, and they are currently awaiting a response.  The Federation have made the All Party Parliamentary Historic Vehicle Group aware. … It is Important that the VSCC (and BNMC) continue to support the FBHVC in their endeavours with the DVLA as this has the very best chance of a successful outcome…

I regret that BNMC have heard nothing direct from the FBHVC but I hope you will all find the above very encouraging and most welcome news.

Monty Goding

July 12 2016

Recent News From Federation of British Historic Vehicle Clubs – April 2016

UK Registration Matters by Bob Owen

As Ian explains in his section, progress on registration matters has currently stalled for lack of anyone ready to talk to us. We are awaiting confirmation of the new structure within DVLA before presenting our concerns in a clear, coherent and complete manner.

If we are not advised by DVLA of their new structure soon, we will clearly have to take a more pro-active approach, as all of our members affected by the current unsatisfactory position cannot be expected to wait forever for an outcome.

Our concerns, that our recognised position as stakeholder in respect of the V765 scheme and related matters has been undermined by the redesign of DVLA’s processes, remain valid, as we have had no explanation of the changes save that they represent existing and longstanding DVLA policy, which we believe to be incorrect and which we consider DVLA cannot prove.

We are in the course of preparing our formal approach for when we can restart. We have continued to work with the All Party Parliamentary Historic Vehicles Group and its Chairman, Sir Greg Knight, so we can all be ready to pull together when the time comes.

Meanwhile our advice to those affected to be patient must remain the best we can offer. We know this is not satisfactory but can see no way to improve the situation except what I have set out.

Asbestos

Two points only on this subject at the moment.

The first is to say that the Health and Safety Executive have advised that they would prefer to treat trailers on an individual basis. While this is disappointing, we have to recognise both that the types and varieties of trailers may be so wide as to defy easy definition, and that it may well be more difficult to identify the difference between historic trailers and those which are simply old.

That being the case, we would suggest the following if you do have a need to sell or hire out a genuine historic trailer which you have reason to believe might contain asbestos in its structure or components:

• It may well be best to take any steps you can to replace the asbestos components, e.g. brake shoes, and
• If the asbestos is not easily removable, or not removable without the potential of damage to the historic fabric of the trailer, do please contact us and we will try to help steer any necessary approvals through the HSE.Finally on asbestos, there have been some questions, so I shall restate the position simply. The exemption in the Certificate does not extend to spare parts. These cannot, if they contain asbestos, be sold. This has been the case for a number of years and has not changed.

DVLA  News from Ian Edmunds

It seems to be becoming a habit for me to start this piece by stating that I don’t have much to report and, although I appreciate it is not what you want to read, it is unfortunately the case again for this edition.
Towards the end of last year John Vale, who has held the post of Team Leader, Vehicle Registration Policy, at DVLA in Swansea for some years informed us that he was moving on to a new role within DVLA. Whilst we understand that the two admirable young ladies who are our normal points of first contact will remain in post there will be other changes within the group we have been working with. We have requested details of this new structure when it is finalised and also a meeting with John’s successor as soon as he (or she) is established. DVLA have agreed to both of these but up until now the time scale is unclear.
The practical result of this is that whilst I still can, and do, raise queries on individual cases, although perhaps with an extended response time from DVLA, it is clearly sensible to delay pursuing the broader issues until we are familiar with the changes in DVLA and have met the people concerned.

FBHVC are very aware that there is much disquiet in the historic vehicle community regarding many aspects of DVLA’s current activities. Thanks to the efforts of club officials and some individual members we believe we are adequately informed of these, but please keep the information coming. At the same time we would ask the clubs and their members to recognise two key points. Firstly it is the long established modus operandi of the Federation to work and lobby quietly to progress its objectives. Secondly it is only sensible in strategic terms to prioritise the issues and in particular the sterling efforts of the All Party Parliamentary Historic Vehicle Group should be concentrated on the most serious and intractable problems. Given that we are now aware of several re-bodied but otherwise acceptably original cars that DVLA are in effect preventing from being registered at all, I hope that you can understand that some other matters have to be temporarily put aside, but not, I assure you, forgotten.

One of the things which has been delayed by the staff changes is that a promised report back from DVLA on the issues regarding authenticity, which as you know have focussed on the Bugatti marque, has not occurred. FBHVC believes this exercise is still progressing, but we are currently totally unsighted as to what DVLA are doing on this subject. If we hear more, especially if what we hear is of general interest to our members, we will of course let you know through the Newsletter.

On a brighter note, we recently received a visit from two charming people from the DVLA Customer Insight Group. Their role is to collect and assess the views of customers about DVLA systems in general and the new digital systems in particular. We were able to explain some of the frustrations experienced by our members and to provide examples. We were actually asked for any suggestions about how the service might be improved. Two points must be made clear here, firstly this discussion was solely about systems, not policy, and secondly the role of this group is to report back. They cannot, themselves, instigate change. Nevertheless, an enjoyable and constructive couple of hours.

In closing I would like to emphasise that rumours currently circulating to the effect that DVLA are arbitrarily removing clubs from the V765/1 list are just that – rumours. DVLA have recently completed a routine housekeeping exercise of contacting all the clubs on the V765/1 list to confirm contact details etc. to ensure the list is accurate, nothing more. Similarly DVLA will continue to accept suitable dating evidence from any group they deem competent to provide it.

The National Historic Vehicle Survey 2016 – Urgent

The Federation of British Historic Vehicle Clubs, of which our club is a member, has announced the launch of the National Historic Vehicle Survey 2016. This important national survey is designed to identify the importance of the historic vehicle movement to the UK economy and the trends in historic vehicle ownership. The results will be used by the Federation of British Historic Vehicle Clubs to support their work on our behalf in representing the movement’s views to Parliament and to ensure we are able to enjoy the use of our vehicles on the roads for many years to come.

Members completing the survey can elect for complete anonymity or may choose to add their email address to the survey to become part of the Federation’s focus group to be consulted from time to time on issues important to the historic vehicle movement. The Federation have confirmed that no email addresses will be released to third parties. 

The survey is critical for the preservation of our historic vehicle interests and The Bullnose Morris Club is happy to give its full support. Please participate by completing the survey, It will help our Club.

To complete the survey click here http://tinyurl.com/zy3qyq2

On behalf of the FBHVC may I take this opportunity to thank you for your time and involvement in the survey. 

Yours sincerely

Garry Wright

Chairman – The Bullnose Morris Club

From the Club Registrar, Margaret Goding – 16th August 2015

In the late 1960s, when I began to work on the list of surviving Morris cars in the Jarman & Barraclough book, just for fun really, I could not have known at all where this would lead and how important the gathering of information on the surviving cars would be in the future.

First published in 1974, the little book ‘Early Morris Cars’ has provided information for Club Members. In subsequent editions, the format and content have been revised and expanded. A new updated edition for this year is in hand.

Over the years, many Club Members have restored cars enabling the Club to continue to uphold the tradition of keeping vintage Morris cars on the road and driving about all over the country. Quite a few of the cars had become separated from their original Registration Number, and part of my role has been to enable owners to regain that number or to be assigned an age-related Number by the DVLA. Our access to the original WRM and Morris Motors production records has been invaluable in supporting Club Members to obtain a Registration Number.

For their part, the DVLA policy on these matters has changed many times since the 1970s. However, the current DVLA situation is unique. Following the closure of local offices, the DVLA has total centralised control and the ability now to implement and impose many changes.

None of us in our Club could have guessed or known where this would lead. Prompted by the fact that some Marques of cherished cars have more listed in the Historic category than were originally produced by that manufacturer at the time, the DVLA has indicated it intends to review the Historic category status to a specific Marque, and even the possibility of extending this to all those vehicles accorded this status in the last 25 years. You need to read through the abstract we have provided on our website from the thought provoking articles in the current Newsletter of the Federation of British Historic Vehicle Clubs. It will help you to understand the next paragraph:

I have had a telephone call from a DVLA officer responsible for making the decision about an application I had submitted to the DVLA for a restored vehicle to be assigned an age-related Registration Mark. As a result I am now saying to you all: Anyone who is currently restoring or building or rebuilding a Morris manufactured before 1932 should take note that the DVLA has indicated that it is unlikely to agree to assign a Registration Mark to a vehicle which contains parts of modern manufacture, or a non-original body where new metal panels have been used, or a body which is not the same as the one originally sold by Morris Motors Ltd on that chassis frame. (Few cars were dispatched in the UK in chassis form, so I think we should concentrate on the UK bodied cars for the present).

When deciding whether to assign an age-related Registration Mark to a vehicle which has been restored, the DVLA has to place such a vehicle in one of two categories, either the ‘Reconstructed Classic’ or the ‘Built-up from period parts’.

A Reconstructed Classic must have the original body, or a body ‘genuine to the Morris marque’.

A Built-up vehicle would have to receive a Q plate and be put through the IVA vehicle test which a vintage Morris would not pass.

The DVLA says that each case is considered by the DVLA on its own merits.

I have worked hard over the past year to comply and fit in with the ‘new’ DVLA requirements for those of you trying to get an Age-related Number or the original one reinstated. Information on new requirements is not clearly set out. I am sure I am not alone in exploring the way forward. For the present, I would like to quantify the present situation and would urge anyone with a Morris restoration project in hand or stored for the future to write/email and tell me about it; please don’t phone or at this stage email me lots of photographs. Many of you have already done so, but please confirm the current situation.

FBHVC Newsletter   Nº 4-2015 

Article about the DVLA and investigations into Historic Status of vehicles 

Extract from letter sent by the DVLA to owners of a certain Marque: 

“3 July 2015 

I am writing to you as our records show you are the keeper of a ‘Historic’ vehicle. The Driver and Vehicle Licensing Agency (DVLA) has been made aware that the recorded date of manufacture for a number of vehicles may not be accurate. Initial investigations have confirmed that some historic vehicles have been built using replica/replacement parts of a mixture of period and new components and have therefore been incorrectly registered. A period manufacture date has been recorded in error and a registration number allocated based on this date. 

I hope you will appreciate DVLA has a legal responsibility to ensure that our records are accurate. This letter aims to provide you with advice and guidance on how DVLA will look to resolve this matter. DVLA require information about the provenance, construction and origin of your vehicle. You should provide as much information about your vehicle so that you can. This could include: 

• copies of receipts
• old documents such as logbooks
• copies of historical race sheets or reports
• recent/historical photographs
• copies of old sale advertisements
• extracts from books 

We also require information on the age and origin of major components your vehicle comprises of, such as chassis, engine, axles and steering assembly. You should also advise if the vehicle has been rebuilt, restored or entirely constructed in the last 25 years. The relevant Owners’ Club may be able to assist. The information should be sent to:

Vehicle Registration Policy

Strategy, Policy and Communications Directorate

D16, DVLA, Longview Road, Swansea SA6 7JL

Using this information, together with the documentation that was provided at first registration, we will assess whether a Historical classification is appropriate for your vehicle and if the date of manufacture is correct. If the vehicle has been recently built using a new or replica chassis, it is likely the DVLA record will be incorrect. You should be aware that we may contact the relevant Owners’ Club to help with our investigations. 

Once investigations are complete, we will write to you again explaining our conclusions. If any amendments are needed to the information DVLA hold on the vehicle record, these will be made and a new vehicle registration certificate issued. This could involve the issue of a different registration number. In addition, in some cases Individual Vehicle Approval may be required and/or a Q registration number may be appropriate. 

Please be aware that while these investigations are ongoing, applications to notify a change of vehicle keeper will not be processed.

Yours faithfully, John Vale, Team Leader, Vehicle Registration Policy”