Extract from the Federation of Historic Vehicle Clubs Newsletter - Issue 01/2011

(CCC Note :- All the text below, except that marked as 'CCC Note' (as here) is taken straight from the FBHVC newsletter)

LEGISLATION

FBHVC Discuss Key Issues with Transport Minister
On Tuesday 30 November senior members of the Federation of British Historic Vehicle Clubs accompanied by Rt Hon Greg Knight MP, the chairman of the All Party Parliamentary Historic Vehicle Group, attended a meeting with the Under-Secretary of State for Roads and Motoring, Mike Penning MP and two senior officials from DfT and DVLA.

The main issues raised by Greg Knight and the FBHVC were:

  • DVLA - The bureaucracy involved with correcting or substituting engine numbers on V5C documents. Similarly, making minor engine capacity changes on old vehicles, which are not taxed on emission levels.
  • DfT - Amending legislation to allow DVLA to mark V5Cs and computer records ‘non- transferable’ to enable current owners of historic vehicles to safeguard the permanent attachment of the registration to the original vehicle.
  • VOSA - The UK should be making full use of the concessions allowed in the EU Roadworthiness Directive for old vehicles. The impact of the planned substitution of government testing stations to ATFs especially relating to Class 5 tests. The inconsistency between braking requirements for classes 5 and 6.
  • Fuels - The proper labelling of petrol and diesel with a bio-fuel content. The provision of tested additives prior to the widespread introduction of petrol containing up to 10 per cent ethanol. What is the timescale for the publication of the commissioned reports relating to the impact of bio-fuel on historic vehicles?
  • Planning - What changes are envisaged for modern vehicles which could potentially adversely affect the old vehicle parc?

The Minister made it very clear at the outset that he is sympathetic to the old vehicle movement (being involved personally) and expressed his willingness to look at cutting out unnecessary regulation and bureaucracy where practical. He assured us that his officials would look into our concerns and report back.

Since the meeting the Minister has agreed in principle with the suggestion of exempting cars and smaller vehicles built on or before 31 December 1920 and PCVs built on or before 31 December 1940 from MoT testing. He has asked DfT officials to begin the process of consultation and making the necessary legislative changes. It is anticipated that these dates could be reviewed periodically and the introduction of a rolling date provision has not been ruled out. Public Service Vehicles will not be included in these concessions.

This measure is welcomed by the FBHVC as it will mitigate many of the problems experienced by the owners of vehicles in these categories at the annual test. We must emphasise that road-going vehicles must be maintained in full working order at all times and we must strive to ensure that our accident level does not rise from the present virtually zero position.


MoT testing stations
We have received a good response from member organisations to our request for details of MoT garages that understand our historic vehicles. We are still compiling the list at the time of going to press – we do understand that these requests take time to filter through clubs’ own newsletters and then to our office. Each of the garages is being invited to join the Federation as a trade supporter and a complete list of all them will shortly be on our website. We currently have over 60 names and would certainly welcome further additions to the list, especially those that understand motorcycles and commercial vehicles.


Speed limits for larger vehicles
Following responses to the Consultation on HGV and PCV motorway speed limits, the DfT have decided to drop any of the proposals.


Continuous Insurance Enforcement
There was a very comprehensive article in the last issue of the this newsletter about CIE, but since then there have been some very misleading reports in the press about the subject and consequently a large number of enquiries to our office. The truth is that vehicles must be insured if they are taxed for the road, or they must be subject to SORN and parked on private property. It is clearly not sensible for vehicles off the road to be required to be insured as has been printed in many press reports.


FUEL NEWS

The Federation has been monitoring the progress of The Motor Fuel (Composition and Content) and Merchant Shipping (Prevention of Air Pollution from Ships) (Amendment) Regulations 2010; Statutory Instrument 2010, No. 3035 that will increase the uptake of renewable fuels in the UK as part of the European campaign to slow climate change. In addition, air quality concerns have been responsible for progressive reductions in sulphur in heavier fuels such as diesel. The net outcome of these EU directives is the inclusion of bio-ethanol in petrol, and inclusion of components such as vegetable oils in diesel fuels, in addition to the reduction in sulphur content. We sent a representative to the Stakeholder meetings held at the Department for Transport last year and raised concerns about the increased biofuels content and the effect that it would have on historic vehicles. The DfT commissioned a report from QinetiQ which was eagerly awaited and finally published in the public domain in January.

Report Recommendations
The report is a weighty document of 54 pages and the Federation would like to thank all those members who submitted data which we passed to QinetiQ for inclusion.

The report found that:

  • The majority of vehicles 10 years old or older will not be compatible with E10 due to fuel system material incompatibility issues.
  • Carburettor vehicles and powered two wheelers will suffer problems due to material incompatibility, corrosion, and driveability issues.
  • Field experience has demonstrated that vehicles and petrol fuelled equipment fitted with glass fibre fuel tanks may suffer catastrophic failure due to the incompatibility of the glass fibre resin with petrol ethanol blends.
  • Based on vehicle age, approximately 8.6 million vehicles will be unable to run on E10… Based on average vehicle life of 13 years very approximately half these vehicles will still be in use when the proposed phase out of E5 takes place in 2013.

The report also has a recommendations section which makes interesting reading.

  • Vehicles ten years old or older, carburettored vehicles (including powered two wheelers) and first generation direct spark ignition vehicles should not be fuelled on E10 unless the manufacturer can state the vehicles are compatible with E10.
  • E5 should not be phased out in 2013, its widespread availability should continue for the foreseeable future.
  • Consideration should be given to maintaining a specification for E0 fuel for historic and vintage vehicles.

The Legislation
Again this is a lengthy document but we have included some of the important points below.

In parallel with increasing the maximum permitted ethanol content of petrol to 10% the Directive requires that Member States ensure that supplies of 5% ethanol content petrol are maintained until 2013. This is intended to support operation of older cars some of which are not compatible with 10% ethanol content. In practice we do not expect fuel suppliers to switch to 10% ethanol content in petrol until after 2013, but Member States are required to transpose this provision. The UK fuel supply infrastructure is currently only able to handle two grades of petrol, ‘Premium’ and ‘Super’ (the latter accounts for about 4% of petrol sales). In order to ensure widespread availability of 5% ethanol petrol, but minimise constraints on fuel suppliers, should they switch to 10% ethanol content petrol earlier than expected, the regulations require Super grade petrol sold at high throughput petrol stations prior to 2014 to contain no more than 5% ethanol.

The requirement for provision of information to consumers on the biofuel content of petrol is already implemented by regulation 3 of the Biofuel Labelling Regulations. This requires pumps dispensing petrol containing more than 5% bioethanol to be labelled ‘Not suitable for all vehicles: consult vehicle manufacturer before use’.

As the increases in ethanol and oxygen contents are permissive rather than mandatory, the provision of fuel to consumers would not necessarily change in the UK.

Vehicles sold in the UK and in EU markets have only recently (since around 2006) carried manufacturer's warranties covering use of petrol containing 10% ethanol. However, the Department is not aware of general vehicle operability or reliability problems being created on modern (closed loop control, electronically fuel injected) vehicles by running on ethanol content up to 10%. Direct injection petrol-engined vehicles manufactured prior to 2006 appear to be an exception to this and may not be compatible with petrol with more than 5% ethanol content. Older (pre-1993) vehicles are also unlikely to be compatible with petrol containing in excess of 5% ethanol without modifications, (rejetting of carburettors and changing of fuel hoses and seals) though these are a small and decreasing part of the fleet.

In order to support continued operation of these vehicles the Directive obliges Member States to ensure that suppliers continue to provide some petrol containing no more than 5% ethanol by volume (with corresponding 2.7% maximum oxygen content by mass) until at least 2013. This date is subject to review and potential extension. However, based on current projections bioethanol content of UK petrol is not expected to exceed 5% until 2015 at the earliest.

Summary and Recommendation
The Regulations will implement those elements of directive 2009/30/EC which specify new or revised requirements for fuel components which have an environmental impact. This will help reduce air pollutant and greenhouse gas emissions from road and off road transport.

The former objective will be achieved principally by the requirement to reduce the amount of sulphur in gas oil (‘red diesel’) supplied for non road mobile machinery and recreational craft to 10 parts per million (virtually ‘sulphur free’). The latter objective will be achieved by increasing the permitted levels of ethanol in petrol and of biofuel in diesel.

Sulphur-free fuel is required for the reliable operation of the emission control technology needed to meet the latest emission standards for non-road mobile machinery and tractors. This technology will bring significant reductions in emissions of NOx and particulates. These would not be realised however without the use of the new fuel because high levels of sulphur will poison the emission control system.

Increasing the permitted levels of ethanol in petrol is, in practice, a partial enabler to fuel suppliers for meeting the greenhouse gas targets for their fuels contained in Article 7a of the Directive and the transport biofuels targets in the Renewable Energy Directive, 2009/29/EC. These targets are being implemented by separate regulations. Provision is made in the Regulations for continuance of a supply of low ethanol petrol for older vehicles.

Most of the requirements are already met by fuel suppliers or are permissive and no additional costs are envisaged for these elements. Costs will be incurred however by gas oil suppliers and users as a result of the requirement for this fuel to be ‘sulphur free’. These are attributable mainly to increased costs for refining, for red dye marking facilities where road diesel is supplied instead of gas oil, the need in certain cases for users to provide separate storage facilities, and, where FAME is contained in the fuel supplied, the need for additional measures by users to minimise microbiological contamination risks. The Regulations have adopted the derogation available under the Directive for fuel intended for rail engines but has not been able to do so in respect of agricultural tractors because of the appearance of new, sulphur-intolerant, emissions control technologies in this sector from the beginning of 2011. The Regulations also allow minor contamination in the supply chain as permitted in the Directive. The Department has been engaged in close consultation with stakeholders to raise awareness of the need for precautionary measures so as to minimise the impact of the measure.

The SI is not just concerned with the biofuel; there are a number of other changes to fuel composition included in the legislation.

  • Reduction in leaded fuel sales volume (this still exceeds actual sales in the UK so is not thought to be too draconian).
  • Restriction of MMT (manganese-based lead replacement) octane booster additive use in pump fuel. This is not really a concern as it has never been used in the UK. It is the active ingredient in one of the products available under the approved FBHVC scheme for those that wish to use it.
  • Volatility will not be altered from existing levels (this was discussed at some length in the Stakeholder Meetings). Oil companies will be obliged to adjust volatility to compensate for the acknowledged adverse effect of adding ethanol, but only to bring the volatility of petrol-ethanol mixes back in line with the previous limit, so that in effect the vapour forming characteristics remain the same. The theory of this is sound, however there may be problems in practice.

Our conclusions
One area where there seems to have been a softening of attitude is in the life of E5; at the Stakeholder meetings the position was quite firm, E5 only until 2013 and then it would be phased out to be replaced by E10. The statement that E5 is likely to be around until at least 2015, backed up by the suggestion of provision of low ethanol (whatever that is) fuel for historic vehicles is a positive development and one in which we feel the FBHVC can claim to have made an impact.

For off-road diesel there were no real surprises, and there is lots of information about good housekeeping, blocked filters etc. However the report does indicate that some 50% of farm storage tanks may need to be replaced – at considerable expense.


EU LEGISLATION
(Extract from FIVA’s regular update provided by its lobbying service, EPPA)

Roadworthiness Testing – FIVA meets with European Commission to discuss options
Further to FIVA’s contribution to the European Commission’s consultation on a possible amendment to the 1996 Roadworthiness Testing Directive, Tiddo Brester (FIVA Legislation Commission chairman) and Andrew Turner of EPPA met in December with the DG Transport European Commission official responsible for the issue. During the meeting FIVA reiterated its view it would like the definition of a historic vehicle provided by the current directive (certain vehicles operated or used in exceptional conditions and vehicles which are never, or hardly ever, used on public highways, including vehicles of historic interest which were manufactured before 1 January 1960 or which are temporarily withdrawn from circulation) to be changed to reflect the terms of the FIVA definition. FIVA also reiterated that there is likely to be an increasing need for historic vehicles be to treated differently as testing will increasingly rely on highly sensitive automated machines; the increased lack of human intervention and reliance on equipment designed for modern vehicles may well lead to historic vehicles unfairly and unnecessarily failing tests - hence a greater need for historic vehicles – appropriated defined - be allowed to be treated differently to modern vehicles.

During the meeting, it became clear that:

  • the European Commission does intend to propose a new Directive (one of the options of the consultation was to do nothing);
  • DG Transport recognises the need for the need for special provision for historic vehicles in the Directive, but recognises that the definition in the current Directive is inappropriate;
  • DG Transport recognises FIVA’s definition includes all vehicles (i.e. cars, PTWs and commercial vehicles) and is inclined to favour changing the definition, specifically to introduce a rolling age;
  • A Commission proposal is expected after the first quarter.

FIVA will maintain contact with the Commission during the process to aim to ensure that the revised proposal continues to offer an exemption for historic vehicles and that the definition of a historic vehicle better mirrors the FIVA definition.


DVLA LIAISON

Dating letters
In the last Newsletter I explained about the revised DVLA definition of a Reconstructed Classic, and indicated that clubs will need to consider revising their standard ‘dating letter’ or ‘dating certificate’ to comply with that revised definition. On http://fbhvc.co.uk/downloads/ there is a sample template for a club to consider using as a new dating letter. This includes a check list of the documents it is suggested should be associated with an application to register a vehicle, and takes into account the requirements of Continuous Insurance Enforcement.

If the vehicle does not fit the criteria for DVLA to allocate an age-related number (e.g. it has a new body, or other major new components, excluding items subject to wear and tear like tyres or repaired components), then the dating letter template in that form is not applicable; DVLA could well allocate a Q plate.
When the application is made there must be a visible chassis/frame/car number on the actual vehicle, in the form of a number stamped directly on the vehicle, or/and stamped on a metal plate secured to the vehicle.

If the chassis/frame/car number is missing and unknown it is suggested that you contact the Federation for specific advice, prior to any application being made to register the vehicle.

The majority of the cases that I am asked to get involved with relate to the registration of a Reconstructed Classic, where the DVLA local office have offered a Q plate because of the inadequate or over-detailed information supplied to them.

The registration of Reconstructed Classics is looked after by the DVLA local office that is closest to the home address of the owner. There are 50 DVLA local offices, so it is not unexpected that there could be differences in the reaction to a dating letter. I have been told by a couple of clubs that they have been using the same format of dating letter for many years with an age-related number being allocated, but now that same format dating letter/certificate is leading to a ‘Q’ plate being offered.

When I look at these dating letter/certificates which were done under the previous definition of a reconstructed classic, my judgement of the dating letter/certificate is that it is slightly surprising that they ever produced an age-related number, when looking at the guidelines for dating letters/certificates contained in the V765/3 document which was issued to all V765 scheme signatories.

The DVLA requirement is for ‘confirmation of the year of manufacture’. One dating certificate only ‘suggested the year of manufacture’. Some local offices were happy to accept just the ‘suggestion’ of the year of manufacture, but for others this is not good enough. On the V5C the year of manufacture is what it says, so you need to confirm the year of manufacture. DVLA rely upon clubs decisive decisions.

Another dating certificate failed to define the year of manufacture, but had indicated the date of registration, although no evidence was produced for that statement, and could be due to a clerical mistake.

Some clubs are still producing hand-written dating letters, or are using a printed template with the relevant sections being filled in by hand. It does not give a very businesslike impression of the club if the clubs DVLA registered signatory does not have access to a word processor, or even a typewriter.

The DVLA V765 list is a list of club signatories registered with DVLA, predominately for use with the V765 scheme, i.e. claiming back an original number. There will be some DVLA local offices who will use this list to confirm the credibility of a club’s dating letter. If for some reason an age-related application is referred to DVLA Swansea, some key DVLA Swansea individuals will also take the same view. It is therefore logical that all club dating letters should be signed by the club’s V765 scheme registered signatory otherwise it might put a doubt in the mind of the DVLA local office regarding the credibility of the dating letter. It is reasonable that the club signatory will be familiar with the V765/3 guidelines, which includes dating letters. Other club officers may not be familiar with the contents of that document.

It is not unknown that an owner will attempt to alter a dating letter or V55/5 form. It is suggested that you make a photocopy of those documents, and the photographs of the vehicle and chassis/ frame and engine numbers for archive use. Rather than relying on storing this information on a computer, it is suggested that a back up is always made, or keep paper copies in a labelled folder.

Summary
To comply with the new definition of a Reconstructed Classic, you might wish to consider the use of the FBHVC dating letter template. See http://fbhvc.co.uk/downloads/ or contact the Federation’s Secretary for a copy.

  1. There must be a chassis/frame/car number on the actual vehicle, and if this is missing and unknown, then contact the Federation for advice.
  2. Any dating letter needs to focused and have a defined year of manufacture.
  3. A dating letter which is produced using a word processor (or typewriter) will give a more businesslike impression than a hand-written letter. Letters need to be dated and signed.
  4. To give additional credibility to the dating letter, it should be signed by the club’s registered V765 scheme signatory.
  5. The vehicle needs to have been inspected by the club. A sample vehicle inspection form is at http://fbhvc.co.uk/downloads/. Any inspection form should not be passed to DVLA, but some information from the completed form would be used on the dating letter.
  6. It is recommended that you fill out, or at least vet, the V55/5 form. The owner will need to sign and date page 2. It is suggested that copies should be kept of all documents and photographs.

Application of Rebuilt Vehicles Guidelines (INF26)
There has been some misunderstanding regarding how the various sections of INF26 are applied. The majority of INF26, including Section 2 (Rebuilt Vehicles), Section 3, (Altered Vehicles), Section 4 (Kit Built) and Section 5 (Kit Conversions) explains the criteria to retain an existing registration number on a vehicle already registered with DVLA.

If the vehicle is not registered with DVLA, and if insufficient evidence exists to reclaim an original registration number via the V765 scheme, then it is Section 6 (Reconstructed Classics) which applies in those cases.

With a chassis-based vehicle, this means that, for example, if a vehicle has a seriously deteriorated body, and insufficient evidence exists to make a V765 claim, it is suggested that the vehicle’s body is repaired sufficiently to obtain an MoT pass, and then register it under Section 6 (Reconstructed Classics). Once the vehicle is registered with DVLA, the retention of the age-related number would be governed by Sections 1 to 5, typically Section 2 (Rebuilt Vehicles) or Section 3 (Altered Vehicles). The installation of a new replacement body on an already registered chassis based vehicle should not affect the retention of the age-related number. If it has been declared that a new body had been installed prior to initial registration with DVLA this could mean that the vehicle would be ineligible for an age-related number (because of the new body) and a Q plate would be allocated.

In summary, register first, then restore.

DVLA Meeting
It is taking some time to collect the specific questions from the clubs who wish to take part in the meeting simply because of the deadlines for clubs’ newsletters. It is of course difficult to speculate on the size of meeting venue required without knowing how many delegates are likely to attend and we have now set a deadline of 18 February for submitting questions.

It should be remembered that DVLA personnel are not the policy makers; DVLA is the agency that carries out the DfT’s policy decisions.


TRADE AND SKILLS

A New Strategy
We have now modified our first trial questionnaire to allow more clubs and traders to take part. The new approach (via a web-based questionnaire for clubs and hopefully a number of one-to-one interviews with some traders) is summarised below and will be undertaken by a number of invited clubs and traders in the first instance.

We first need to identify whether there are endangered skills, procedures and documentation, parts and tools and tooling. Then we will use FIVA’s web-based questionnaire to gather the information. This will be a web-based questionnaire for clubs in each of FIVA’s member countries and we also intend to interview some of our member traders and museums who are known to undertake restoration work. Where possible automatic analysis of the questionnaire will be incorporated into the software.

The questionnaire was launched on 1 January 2011 with a closing date of 31 March and an initial analysis of responses is expected in April 2011. Some 50 clubs, encompassing the full range of historic vehicles, have been contacted and invited to take part. The full results across all FIVA’s member countries will be available ready for the FIVA General Assembly in November 2011.

Where it is discovered that there are endangered skills we then need to move on to identify how we reduce gaps between demand and supply. This could be done by forming partnerships with key professional associations but it will also be necessary to highlight the bigger picture to allow enthusiasts to continue to be able to repair, maintain, restore and drive our historic vehicles.

Professionals need to employ skilled craftsmen and ensure the availability of relevant skills, documentation, procedures, parts and tooling. Trainers need to provide trained and skilled craftsmen. National Federations need to quantify the contributions of our historic vehicle movement to the national economies.

In this country in order to maintain direction, momentum and to monitor progress we propose to hold a FIVA Trade and Skills seminar twice yearly.


HERITAGE

Heritage Open Days
Drive It Day is now firmly established as an effective means of demonstrating the wealth of fascinating historic vehicles, whether they are motor cars, motor cycles, steam, agricultural, commercial or ex-military, of all types and ages, that are kept in this country and highlighting the large numbers of people engaged in this interest.

In much the same vein the Federation is keen to link historic vehicles with the well-established heritage world that concentrates so much on historic houses and gardens. This arrangement has been very successful in other countries, particularly France, where it is seen to be of benefit in promoting both the vehicle movement and heritage properties. A historic vehicle display can be a means to enhance the property for a particular occasion.

FBHVC has a director with specific responsibility for heritage matters and, together with the recently appointed event co-ordinator, will be actively working to encourage the European practice of staging displays of appropriate historic vehicles at as many of Britain’s heritage venues as practical, particularly to augment any special events or Open Days.

These are days on which properties up and down the country that are normally closed to the public, or which normally charge an admission fee, are open to the public free of charge. Some are very small, others much larger. The scheme, co-ordinated by English Heritage, is intended to celebrate the wealth of our architectural and cultural heritage. These open days take place generally over a long weekend in September each year, the 2011 dates being the weekend of 10-11 September, but some sites will also be open on the preceding Thursday and Friday. More details can be found at: www.heritageopendays.org.uk

We are delighted to report that, following our approach to the National Trust, a number of property managers will be offering their locations for the display of historic vehicles.

FBHVC Heritage will be liaising with both of the above bodies, the individual venues and our member organisations with a view to maximising the mutual benefit and enjoyment of days out with historic vehicles at some of this country’s interesting and perhaps lesser known locations.

Full details of precisely which venues will be participating may not be known until April at the earliest. In the meantime, it would be helpful if member organisations interested in providing vehicles would pencil in the dates – September 8-11 – and advise Roy Dowding, Heritage Events Co-ordinator via the Secretary.


Transport Trust Awards
Entries are invited for the Transport Trust Restorations Awards; cash awards up to £5000 for high quality restoration projects that could be helped to earlier completion by a modest cash injection. More information is on the website: www.transporttrust.com

Nominations have also been requested for the Trust’s Preservationist of the Year, for Lifetime Achievement Awards and for the Young Preservationist of the Year.


CLUB NEWS

If you happen to be in the Drome region of France, the Citroen Car Club magazine recommends a visit to the ‘Citromuseum’ in Castellane www.citroencarclub.org.uk


DRIVE IT DAY, 17 APRIL 2011

We have been very busy already answering the question ‘when is Drive It Day 2011’. The event is usually held on the nearest Sunday to 23 April, which is the day was chosen six years ago to commemorate the 64 cars that set off from London on 23 April 1900 on the first day of the Thousand Mile Trial – an incredible undertaking and one which we believe deserves an annual celebration. This year the event will be a week earlier to take into account Easter Sunday on 24 April and we hope this will help to avoid the worst of the traffic congestion associated with the Easter break.

We have had so many requests to advertise DID events that we have made a dedicated page on our website events section for just this day. The same rules apply as for other events – member organisations may add details using their ID number and password issued last year.

The Royal Oak at Bishopstone in Wiltshire, a superb venue with a self-confessed classic car nut for a landlord, and with excellent food and beer, has once again indicated that they will be delighted to welcome all comers on the day and will be the focus of FBHVC activity.

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