Important information on DVLA proposals
DVLA HISTORIC VEHICLE EVENT
1. DVLA invited representatives of Classic Vehicle Clubs and Associations throughout UK to attend a Historic Vehicle Event at the DVLA RL Development Centre, Swansea, on 23 Sep 15. A7CA bid for a place for the Chairman but was unable to secure a place. However, Mike Ward of HA7C was successful and he was, therefore, invited to represent A7CA and its members.
2. As he was unable to get a place at the Briefing, the Chairman submitted four questions of which one was answered by DVLA; those questions were:
“What is the position as regards new bodies being mounted on a rebuilt/reassembled chassis made from refurbished original parts?
Does the body type have to be the same as the original type if replaced? In the past, it was often the case that vehicles would be re-bodied for another purpose – from saloon to estate car for example.
It used to be possible to buy a chassis from the Works and take it to your own favourite coachbuilder and have your own design of bespoke body fitted. In effect, this is what is happening with the new bodies. Is this acceptable? This was done by companies such as SS/Swallow, which became Jaguar. Also Gordon England did it in the 1920’s; these bodies are still being made to mount on period chassis.
What is the position with regard to “Specials”? These are built up from a collection of period parts suitably refurbished and repaired. Often these are then topped with a body built by the repairer – often in the style of his/her favourite vehicle. This is what Colin Chapman did which resulted in Lotus cars.”
MIKE WARD’S SUMMARY OF DISCUSSION
3. The meeting was opened by John Vale, team leader, Vehicle Registration Policy.
4. There were eighty delegates present and apologies were given for the remaining one hundred and fifty Club representatives whose applications for attendance had been unsuccessful. FBHVC were represented.
5. The meeting was broken down into three parts:
• Reconstructed Classics
• Form V765 Applications
• Authenticity of a Vehicle.
6. In DVLA terms, Reconstruction is the same as Rebuilding. Restoration is determined by all original parts being used. The Body and Chassis must both be original. Evidence of originality is paramount. A new chassis will attract an age related plate. Perishables, ie tyres etc do not count against losing an original registration.
7. The vehicle must be ‘complete’ when applying for registration on form V765 to retain its original registration number, not just a rolling chassis. An authorised Club representative must inspect the vehicle, not just see photographs. He or she must be the authorised signatory of the Club. The form must bear the Club’s stamp. A copy of an old style buff log book, authenticated by the Club, is accepted by DVLA. As much information as possible is the key to acceptance of a V765 application. A Dating certificate can be issued by the Club to aid the application. This should clearly state the VIN/Chassis/frame/car number. The date of manufacture must be quoted clearly without doubt. The Club must state what material has been used to date the vehicle, ie factory records. It must be specified if the Club has inspected the vehicle. If the Club Registrar’s records have been used, this must be stated. Authenticity by the Club must state that the vehicle has been built from original components.
8. General. DVLA receive an average of 2,822 applications per year using form V765. This is increasing year on year. There is a growing interest in vintage vehicles. This is why each application must be properly made out in order to avoid delay and disappointment.
9. Questions. All delegates had tendered questions prior to the event. Each name had been put into an envelope and drawn at random. There were about eight successful names drawn and their questions were heard. Mine was the eighth! I asked, on behalf of the A7CA, what was the position on ‘Specials’. It was said by the DVLA representative that it was ‘unlikely that an original registration would be retained, but each application would be considered individually’.
10. Record of Event. DVLA will be issuing notes of the meeting taking into account all the points raised by delegates.
Other Documents worth reading
11. Members were recommended to read the online report on the DVLA Briefing by The Vintage Hot Rod Association reproduced on their website [http://www.vhra.co.uk/VHRA/News/News.html] and printed below:
12. On 23rd September, the Vintage Hot Rod Association attended a meeting at DVLA headquarters to discuss matters arising from obtaining registrations for vehicles that are currently lacking in that department. This was in response to the recent news about certain marques receiving letters from the DVLA questioning their provenance. It was a chance for owners’ clubs and DVLA to communicate directly over any matters that may concern them.
13. The invitation to the meeting went out to everyone on the V765 list and also to all the member clubs of FBHVC. That was a total of around 600 clubs. DVLA received about 260 replies, which were whittled down to 80 clubs attending, 7 of which, rather disappointingly, didn’t bother to show up on the day.
14. There was an introduction from the head of the service, John Vale, who was very plain speaking and upfront about the way things work. He confirmed that essentially the rules haven’t changed, they are just being implemented properly now. He also commented on the letters sent to owners regarding their car’s provenance, confirming that not everyone will be receiving a letter; it had nothing to do with the latest EU directive and that they would be continuing to write to other owners if they felt there was just cause, such as an anomaly spotted on their records, or if something was brought to their attention from another source.
15. Next up was Julie Risley, a Service Designer for DVLA. A number of salient pieces of information were gleaned from her introduction. The first was that a large number of applications were rejected at the start of the centralisation of services but that has mostly been ironed out now. There are no proposed changes to the current service in the pipeline; if you have an appeal, they should be dealt with by a new person. No, they weren’t going to give out contact details, so you’re stuck with pressing keys on your phone; finally, if you have a chassis number and, if there are no legal implications, they should be able to look it up to see if a registration exists against it.
16. The last of the introductions was from Bob Owen, who was there with Rosie Pugh and Ian Edmonds from FBHVC. He said that FBHVC were there mostly as observers and that this was a chance for the clubs to ask questions, though, that said, they would step in if they thought it necessary. He also said that he would be speaking to Julie Risley about the service being provided, mostly to clarify what misunderstandings are still causing rejections. We were then sorted into smaller groups of 25-30 to listen to three different presentations.
Group 1: V765/Late Conversions. Hosted by Nicola Roberts, Donna Kennett & Karen Wing.
17. A V765 and Late Conversion application are very similar as they are to retain a known registration mark, but differ in one way. A Late Conversion means that, back in 1983 when DVLA got their first computers and transferred all currently registered vehicles to the system, there were quite a number of them languishing in sheds that weren’t road legal. The owners of those vehicles could register a Notice of Interest to retain the number should it ever get fixed up. This is the first thing the DVLA check for when they receive a V795 application. If there is a Notice of Interest, this means that the number will be transferable, unlike a regular V765 where the number isn’t. Last year, they received 2,822 V765 applications, of which 952 were rejected at the first call due to insufficient evidence linking the registration. Of those 2,822 applications, 292 had a Notice of Interest against them at the DVLA offices. For a V765 application to be successful, you need things like an original tax disc, old buff logbook, factory records, magazine features – anything that ties the chassis number to the registration.
Group 2: Reconstructed Classics. Hosted by Beverly Morgans, Lee Davies & Alison Williams.
18. Follow this link for the DVLA definition of a reconstructed classic: http://www.gov.uk/vehicle-registration/reconstructed-classic-vehicles. It will be a great help in understanding what follows. What they omit from that is that they will assign a DVLA unique 17 digit VIN rather than retain an original chassis number. Parts can be from any year as long as they are over 25 years old but the vehicle must retain true to the marque. We posed the question at the end of the event as part of the Q&A: “When does a vehicle stop being true to the marque?” citing early hot rods, cars made into commercials as part of the war effort and competition cars. The answer that came back, was that they couldn’t give a definitive answer, that it was left to the clubs to decide and that their answer was as clear as mud. We took the opportunity to push it a little further after the meeting was over and spoke to Beverly Morgans personally. It was explained that it was common for a V8 to replace a four cylinder engine and that the engine may be twenty years newer, but this was all so common at the time and before people were starting to restore Model A’s. She said that there was no issue with this, as long as it was using same make parts and that they were available back in the day. Best advice remains that you try to register things as close to stock as possible, just to save any potential trouble. There are a few flies in the ointment with this scheme, the first being that chassis do still have to remain largely stock and that aftermarket bodies can’t be used. The latter, however, is being looked into as they have had numerous requests, mostly from fabric or wood bodied car owners, so watch this space. There’s also the issue of them giving a VIN number, rather than using the original chassis number, and the car will be dated as its newest component. The flip to that is that, on the V5, it will state “built from parts”, but, on an age related plate, not a Q, so, should you change anything in the future, it would still be encompassed by the wording on the V5.
19. One final point: Beverly said that the reconstructed classic scheme was an attempt by the DVLA to keep cars on the road that fell outside all the other rules. They recognise the rarity of parts and cars and this allows a little mixing and matching to keep cars on the road in one form or another. It was refreshing to hear that they want to get historic vehicles back on the road, not keep them off.
Group 3: Age Related Registrations/Dating Certificates. Hosted by Sian James, Carla Richards & Leanne Chivers.
20. This is how most of the registrations that VHRA have assisted with have gone through. This isn’t very well explained in leaflets and, in fact, not at all on the DVLA website that we can tell. There is a mention of it in the back of a leaflet issued to clubs that issue dating certificates. It has links with the Reconstructed Classics scheme but also stands alone to some extent. This scheme is meant for complete original cars, rather than mixtures of parts, though they did say that, if just a few parts replaced, it wasn’t a problem. Clearly, this does blur lines but a little ambiguity is no bad thing sometimes. Much like the Reconstructed Classics, cars need to be complete, use original type parts, and submitted via a V55/5 application. If they believe that it falls into the Reconstructed category, it gets sent across; otherwise it will receive a period registration number and retain its original chassis number, essentially registering it as an original vehicle. In the Q&A that followed at the end of the group sessions, a few more questions, aside from mine that I mentioned earlier, were given good clear answers. The ones that mattered were:
a. Yes, a C&E386 can still be presented as long as it predates April 2013. After that it’s NOVA.
b. Cars are inspected at random and more likely to be checked out if a club hasn’t inspected them. This is currently contracted out to a Swiss company, SGS. It was said that all they look for is evidence of the vehicle not being a cut and shut and that the numbers match the application. They have no knowledge of makes and models, though it is assumed they do a little homework to make sure they know where relevant numbers should be.
21. So there you have it. Nothing is changing, but it does make it slightly clearer what is meant to be going on. For the VHRA part, we are going to carry on as we have been, and we had this confirmed whilst we were there. As always, we will talk owners through the pitfalls and problems of registering a vehicle. As previously mentioned, the best advice is to register a car whilst it’s original. For genuine, unregistered cars, we will continue to do all we can to help. It’s also worth noting that this has nothing to do with cars that are already registered. They are still covered by the 8 point system and can be modified accordingly including having replacement bodies fitted as well as parts from other marques.
22. Members will be aware that the President attended the DVLA Historic Vehicle Event last week and are no doubt keen for an update. We had been waiting for the DVLA notes to be sent out to Clubs before publishing any further information. However, it has now been over a week and so we have decided that it is more important to publish what follows than wait for the official report from DVLA – which will be published as soon as it arrives.
23. The event was very different from what had been expected, consisting of an introduction followed by three breakout sessions, with the attendees being split up into three groups, circulating between the sessions. The breakout sessions were based loosely around a presentation but all ended up in open forum question and answer sessions. Because of this, other delegates may have come away with slightly different interpretations of the deliberations. The presentations aimed to answer as many of the previously notified questions as possible.
24. There was an acceptance of the difference between a monocoque construction and vehicles with separate chassis and there appeared to be a revised interpretation of accepting new bodies on existing vehicles, either as like for like or bodies of an appropriate style, even if changing from a saloon to a tourer for example. On the other hand, a vehicle built from parts from different donor vehicles would require a Q plate if it had a new body. What was most encouraging was that DVLA are keen to work with the clubs to understand the issues. Useful contacts were made and follow up is possible and will be necessary, but this was a good start. I believe that there is no good reason not to re-commence participating in the V765 Scheme wherever we are the appropriate Club.
John Vale – Team Leader Vehicle Registration Policy
25. 80 clubs represented, with over 150 disappointed because of lack of space; John highlighted that the rules had not changed since the local offices closed but, being centralised required more consistency. He stressed that this has nothing to do with the European Roadworthiness Directive. The DVLA do not intend to write to all owners of historic vehicles, but will be writing to those owners where the Agency believe the records may be incorrect.
Julie Riseley – Service Designer
26. The higher number of rejections currently being experienced could be fixed by better communication. She stated that they want to understand the issues. Relationship management is seen as important, but there is no intention to give a single point of contact for any issue. It is the Agency’s policy that appeals should not be dealt with by the person who had made the original decision as had happened on some occasions. She asked that, if this happened, the matter should be reported to the Agency. The aim of DVLA is to reduce the burden on their customers (and, by definition, for themselves).
Bob Owen – FBHVC
27. Bob spoke in general terms about the Federation working with the DVLA.
Breakout Session on Dating Certificates
28. For vehicles without a logbook, information should be obtained from the manufacturer wherever possible. If it is not possible, the Agency will accept Dating Certificates from individuals who have specific knowledge or expertise. Dating evidence is only required when:
• The vehicle has not previously been registered in the UK, or
• The original registration number is unknown
29. DVLA ideally require the date to be exact, i.e. Day, Month and Year, and this must be definitive, not about, maybe, etc. The lack of exact dates, i.e. only a year, may be acceptable if it is shown that the exact date is not available and there would be no change during the year. The DVLA will always need to know the source of the date. Dating Certificates are not linked to V765. Dating Certificates only apply to a complete vehicle, not for parts or a vehicle in restoration. There was considerable discussion about this as it was argued that someone buying a rolling chassis may want to be sure that a period registration would be granted, which would be confirmed by having a Dating Certificate. John Vale accepted this was an issue that the Agency needed to look at. He also wanted to understand how long after that a complete vehicle might be available for inspection, i.e. wanting to know how long a Dating Certificate for an unassembled vehicle should be valid before the vehicle was completed. A figure of 5 years was suggested.
Breakout Session on V765 Scheme and Late Conversions
30. There were 2,376 applications under the V765 Scheme in 2014 and this number has been increasing over the past few years. Over 10% of these applications were for Registration Numbers for which an interest was registered before 1987 (so they have been restoration projects for 28 years!). Vehicles must always be inspected by the club unless they are pre-1987 ‘record of interest’ vehicles, which the DVLA will inspect. The club inspection does not have to be made by the signatory of the club, but the signatory must sign that the inspection has been completed by a suitable person.
31. The club must be satisfied with evidence linking the vehicle to the registration number. They must refuse applications outside their scope, e.g. where there is a relevant one make club. The Agency stressed that, if in doubt, the club should refuse the application and that they had an obligation in such circumstances to inform the DVLA. Some common questions were covered:
Q: Purchased a vehicle without documentation other than an old Tax Disc
A: A Tax Disc is not sufficient evidence, there must be additional clear evidence to link the vehicle to the registration number.
Q: Historic vehicles with a separate chassis may have had a change of body in the past that had not been notified.
A: The Agency would require evidence of the date of the change.
Q: What about where vehicles with a separate chassis have had a replacement body not like for like, e.g. a saloon body being replaced by a new tourer body.
A: In general, it should be a like for like change; however, if the replacement body was of a type (style) in keeping for the manufacturer for the year, this may be acceptable; however, DVLA would need as much evidence as possible and it would be on a case by case basis.
Q: What value does DVLA place on clubs’ recommendations?
A: A lot.
Breakout Session on Reconstructed Classics
32. This covers vehicles built up from parts, which is faithful reproduction with parts from more than one vehicle. A change of engine would not be deemed a reconstruction. A reconstructed Classic must be a true reflection of the marque constructed of components which are all over 25 years old. New components made to the original specification are not old, but are dated as the date of manufacture. Reconstructed Classics are given a registration appropriate to the newest component. For Reconstructed Classics, the body (even on cars with a separate chassis) is deemed a component, so a new body would result in Reconstructed Classic being given a Q plate, which would require the vehicle to be subjected to an IVA. DVLA have recognised this as being a particular issue to pre-war cars with separate chassis and body and have agreed to take it away and look at it. A Reconstructed Classic would be given a new VIN number (any original chassis number must be erased) and the log book would show that it was built from parts. DVLA did concede that it was difficult to draw the line between restoration and re-construction, but the underlying rule was that re-construction was for parts from different vehicles.
Question and Answer Session
33. DVLA are aiming to get consistency as soon as possible. They want feedback from the clubs and will try to give an indication when things will be done. If details are recorded incorrectly on a V5, these should be sent to DVLA with an explanation as to why it should be changed. In answer to the question: “What is DVLA’s attitude to Specials?” the response given was: “They could be a Reconstructed Classic, but if it has new components (including a new body) it must have a Q plate.”