Limited report wrongly ‘talked up’ by Government – to justify less frequent MOTs
Last year, in a move to gain motorists’ popularity, the Government planned a campaign to justify less frequent MOT Testing. As part of that they commissioned a very low budget piece of research from the Transport Research Laboratory (TRL) to find the ‘latest information’ about the link between defective vehicles and road deaths and injuries. They then ‘tagged on’ a request to project death and injury estimates from reduced frequency MOT Testing. This was probably to find something, anything, to challenge the Department for Transport's own projections in 2008 which suggested that over 400 more people would die annually should MOT Testing become two yearly instead of annually as it is now.
 |
TRL’s work duly indicated that far fewer people would, in fact, die from reduced MOT Testing. However, when interviewed by MOT Testing editor Jim Punter, the report’s lead author Richard Cuerden conceded that due to the limitations as what could be done with the low budget available, this methodology was limited and, as he said, “most likely underestimates the accident outcomes”.
He also emphasised that his report consistently predicted that less frequent MOTs would result in more road deaths and injuries – and a huge increase in MOT failure rates.
Since then the Government, in answers to Parliamentary Questions, in media statements and more recently in the impact assessment as to the effect of ending MOT Testing of Historic Vehicles, have only referred to the TRL report, failing to even mention their own DfT report from 2008, which predicted seriously greater fatalities and injuries from reduced MOT Testing frequency.
This is grossly irresponsible, and a grotesque distortion of the likely dangers attendant on any dilution of MOT Testing.
Classic Car MOT Testing
The Parliamentary Under Secretary of State for Transport (Mike Penning): The Department for Transport has today published a consultation on a proposal to exempt vehicles of historic interest (vehicles manufactured prior to 1 January 1960) in Great Britain (GB) from statutory MoT test, as allowed under Article 4(2) of the EU Directive 2009/40/EC.
The EU Directive of the European Parliament and of the Council, Chapter II, Exceptions, Article 4 states: “Member States may, after consulting the Commission, exclude from the scope of this Directive, or subject to special provisions, 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. Member States may, after consulting the Commission, set their own testing standards for vehicles considered to be of historic interest.”
Sections 45 to 48 of the Road Traffic Act 1988 provide the legislative basis for MoT testing. The purpose of the MoT test is to ensure that cars, other light vehicles (including some light goods vehicles), private buses and motorcycles over a prescribed age are checked at least once a year to see that they comply with key roadworthiness and environmental requirements in the Road Vehicle Construction and Use Regulations 1986 and the Road Vehicle Lighting Regulations 1989 (both as amended).
Whilst it is important to ensure that vehicles are safe to use on the highway, it is also important to ensure that regulations imposed are not excessive. Currently, both the age and the categories of vehicles requiring the MoT test in GB go further than the EU Directive on roadworthiness test 2009/40/EC, which only subjects post-1960 registered vehicles to a compulsory roadworthiness test and does not require motorcycles of any age to do a statutory roadworthiness test.
The Government believes that the proposed exemption will reduce regulatory burden on owners of historic vehicles, meet its Reducing Regulation agenda and the desire to remove unnecessary burdens. It will also bring the age of vehicles requiring the statutory MoT test in line with The Goods Vehicles (Plating and Testing) Regulations 1988, which already exempts unladen pre-1960 manufactured Heavy Goods Vehicles from the roadworthiness test.
Two-thirds of pre-1960 licensed vehicles (vehicles manufactured prior to 1 January 1960) are driven less than 500 miles each year. This is significantly less than the 9,000 miles driven on average by all licensed vehicles.
Whilst the pre-1960 licensed vehicles made up about 0.6% of the approximately 35.2m licensed vehicles in GB in 2010, they were involved in just 0.03% of road casualties and accidents.The pre-1960 licensed vehicles are largely well maintained by their owners. The initial MoT test failure rate for these vehicles in 2009 was less than 10%, whilst the initial MoT test failure rate for post-1960 licensed vehicles was over 30%.
The purpose of the consultation is to invite views on proposals to exempt vehicles of historic interest from the statutory MoT test in GB. In addition to no change, the consultation offers three options based on vehicle manufactured date, i.e. it seeks respondents’ views on whether the Government should exempt from the statutory MoT test, pre-1960, pre-1945 or pre-1920 manufactured vehicles.
The consultation also seeks respondents’ views (in all three options) on whether all vehicle categories and vehicles used for commercial purposes should be included in the exemption review.
The consultation will run until 26 January 2012. Copies of the Consultation Document have been placed on the Library of the House. Further copies are available on the DfT website at www.dft.gov.uk/consultations/dft-2011-27. Depending on comments received and the Department’s response, amendments may be made to regulations.
From the DfT website.
Support ProMOTe
The previous government's plans to decrease the frequency of the MOT were dropped following a comprehensive study which indicated that waiting an extra year before a car's first MOT Test, then Testing it every two years would result in hundreds of additional road deaths and thousands of injuries every year.
Click here to support the ProMOTe campaign
 |
| www.pro-mote.org.uk/ |
This government has revived the plan, ostensibly on the basis that it will save the hard-pressed motorist money (why not reduce the tax on fuel if that's the motive?).
Aside from causing road deaths and injuries, the repeated flip-flopping of the proposal is having a disastrous effect on those 20,000 businesses directly involved in carrying out the MOT. Halving the number of MOT Tests will push most of them over the brink in times when motorists are cutting back on servicing because of increasing fuel costs and squeezed incomes.
Why would an MOT garage invest in training and equipment when at the stroke of a pen the market they have equipped themselves to deal with might suddenly disappear?
This is an idiotic proposal – it's lose-lose all the way – no-one wins. No-one saves any money, road deaths and injuries increase, the roads become less safe, many thousands of businesses go to the wall, and in the interim, while the government dithers and prevaricates, the industry is in stasis.
The UK has the safest roads in the world, at the moment. Yet even as the EU is considering making MORE frequent vehice Testing compulsory, this government is proposing to change things for the worse.
Register your support for the ProMOTe campaign and get this ill-conceived nonsense stopped here.
Philip Hammond is thinking of changing the frequency of the MOT – does that mean the motorist will save money?
The MOT Test is subject to EC Directive, and all states in Europe must comply with a set minimum level of mechanical inspection – here in the UK we call it the MOT. At the present time in the UK, a normal motorist's vehicle must be MOT Tested once it reaches the age of three years, and then it must be MOT Tested every year after that – it is known technically as 3.1.1 Testing, being a description of the time periods involved.
In other states in Europe a less frequent level is imposed - for example, inspecting a car after it is four years old, then every two years after that (4.2.2 Testing) is carried out in France. The EC allows this because some states have not historically had any level of formal inspection at all, and a too harsh regime would impose a burden on the car drivers in those states.
The UK has the safest roads in the world, and this is probably due in some measure to the relatively frequent MOT inspection regime, which keeps dangerous cars off the road by ensuring that cars can not be road-taxed unless they have a valid MOT certificate.
It should be noted here that the initial failure rate of cars being MOT Tested is disturbingly high – approaching 40%!
There are moves in Europe to reduce the relatively high number of deaths and injuries on the roads caused by defective vehicles, and one of the measures being considered is to change the minimum frequency of testing to be more in line with that of the UK.
So why is Philip Hammond thinking about moving the frequency of the UK MOT Test in line with states in Europe which have less congested roads? He says it's to save the motorist money. But will it? Let's examine what is likely to happen.
If 4.2.2 Testing were to be introduced in the UK
Conscientious motorists would have a greater chance of being involved in a road accident due to another motorist neglecting to look after their vehicle correctly.
Conscientious motorists who decide to ‘look after’ their cars in a middle non-MOT year could still end up driving an unroadworthy car because a ‘service’ (for which there is no widely accepted specification) would not check the steering and suspension joints, the road springs, the headlamp aim, emissions, or the condition of the seatbelts.
Motorists who do nothing in the middle non-MOT year will end up paying much more money in maintenance over the two years between MOTs than in an annual regime due to the accumulation of related defects. For example – worn steering/suspension systems will result in accelerated tyre wear. A faulty O2 emission sensor could end up with a clogged catalytic converter requiring expensive replacement. Excessively worn disc pads, if undetected, would result in a damaged brake disc requiring replacement. Windscreen wipers excessively worn could cause permanent scratching of the windscreen resulting in premature replacement.
Cars without an MOT for nearly two years will have their ‘trade in’ value seriously eroded as expensive and extensive maintenance could be required.
In addition, if road accident rates increased, insurance premiums would be likely to rise. More expensive insurance premiums means more drivers dodging insurance or dodging servicing, probably both.
So think of it this way; while you might be saving up to £50 every other year on the cost of an MOT, would you feel safer in the knowlege that the car coming towards you at a junction might not have had its brakes serviced for up to two years?
We think probably not. So what on earth does Philip Hammond think he's playing at?
e-petition
Oppose the relaxation of vehicle testing (MoT) frequency - an ill-considered proposal from the DfT.
Responsible department: Department for Transport
The government should drop its proposals to reduce the frequency of MoT tests. Currently vehicles are tested when they reach the third anniversary of registration, and are then tested annually (so called 3-1-1). The government (DfT) has proposed a change to first test at four years and then retest every other year (4-2-2) and claim it would "reduce the burden on the motorist". It is hard to see what this burden is.
The maximum fee for a test is £54.85 and many test stations charge a great deal less. The test is a vital part of keeping the UK's cars safe, road-worthy and environmentally compliant. Any reduction in testing would lead to increased road casualties (deaths and serious injuries), increased pollution, and have employment consequences.
All of which has been supported by independent and reliable research. The system was reviewed in 2008 and seen to be appropriate and any relaxation in testing seen as unrealistic. Let's drop this ill-considered proposal! www.iaaf.co.uk
Sign the Petition
Protest against the proposed change in MOT Frequency
In our magazine MOT Testing, we recommended that MOT Testing Station owners, their staff and anybody else who has an interest in keeping our roads safe should strongly protest to their Members of Parliament not only about the serious road safety aspects of reducing the number of MOT Tests, but also about job losses and that the idea that reduced MOTs will save motorists money is a fallacy.
Information ‘kit’
In this website portal is an information kit to assist anybody wishing to protest against the Department for Transport’s proposals to reduce the frequency of MOT Testing. It contains:
• The latest MOT failure figures.
• The latest numbers for vehicles declared ‘Dangerous to Drive’ by MOT Testers for cars and light commercial vehicles (Class 4 MOTs), and heavier commercial vehicles (Class 7 MOTs).
• A framework letter of protest which can be used to send to your MP
• A link to discover the name and address of your MP.
• A copy of the extensive DfT’s 2008 report indicating that over 400 additional road deaths would result from changing to the first test after four years and every other year thereafter.
• The more recent short and more superficial Transport Research Laboratory report indicating less deaths/injuries.
If you feel strongly that the current MOT should be maintained, then protest to your MP, send letters to the editors of National Newspapers. Do not think that others are doing everything that needs to be done. People power is an essential element of modern protest.
Use these links and documents to protest you your MP – DO NOT WASTE TIME, THIS MUST NOT BE ALLOWED TO HAPPEN.
Who is my MP? Click here to find your MP
Template: Letter to MP
Document: Pass/Fail Figures
Document: 'Danger' Box Details
Document: MOT Evidence Base (previous comprehensive study showing higher road death figures)
Reasons for protesting against the change in frequency of MOT Tests
1. THE ROADS WILL BECOME LESS SAFE FOR ALL. All assessments, (including the TRL report) clearly state that any reduction in MOTs means more people will die on the roads. The Minister should be asked, “how many extra deaths is he prepared to accept to save motorists money?”, and “What would he have to say to those inevitable future victims and their families?”
2. IT WILL NOT SAVE THE MOTORIST ANY MONEY. Not having an MOT in the year between two yearly MOTs won’t save motorists money. Even a conscientious motorists having regular annual services will not be aware of defects arising in items not inspected during a service – steering and suspension joints, corrosion damage and emissions for example. Getting these checked and repaired will still need to be done. Moreover, if accidents increase, so will insurance premiums.
3. THE SURVEY WHICH SAYS THERE WILL ONLY BE 30 EXTRA ROAD DEATHS IS FLAWED. The TRL ‘cheap and cheerful’ report of itself suggesting perhaps more than 30 annual deaths from reduced MOTs, makes assumptions which are not valid and which significantly reduces death/injury projections – whereas the more extensive Department for Transport’s own November 2008 report projects hundreds of deaths from any such move.
4. THE EU IS MOVING TO GO THE OTHER WAY – TO MAKE ROADS SAFER. To improve road-safety the EU currently recommends member States to increase MOT frequency and expect to work towards that legislatively into the near future.
5. MANY THOUSANDS OF MOT BUSINESSES WILL FAIL – There will be a significant unemployment cost to the treasury. Currently about 100,000 or more people are directly dependent on MOT Testing and repairs.
6. THE UKs TOP ROAD SAFETY RECORD WILL BE REVERSED. Currently Britain’s roads are the safest worldwide of all OECD countries, and have the third greatest vehicle use. Reducing MOTs would inevitably endanger that creditable status.
7. INSURANCE PREMIUMS WILL RISE. With increased road accidents caused by more vehicle defects not repaired because there is no MOT in the middle year with two yearly MOTs, insurance premiums would inevitably rise even higher.
8. IT IS 'SOLVING' A PROBLEM WHICH DOESN'T EXIST. All opinion polls (including the Department for Transport’s own surveys) suggest that motorists like MOTs and do not feel it is an unnecessary burden.*
*AA poll, Motor Trade poll, and DfT MORI poll.
The Transport Committee has decided to undertake an inquiry into the Government’s strategic framework for road safety which was published in May 2011.
The Government’s vision for road safety is to ensure that Britain remains a world leader on road safety and that the relatively high risk of accidents amongst some groups, such as cyclists and children from deprived areas, is quickly reduced. The Committee will examine whether the strategic framework will fulfil this vision.
The issues which the Committee will examine are set out below:
• Whether the Government is right not to set road safety targets and whether its outcomes framework is appropriate
• How the decentralisation to local authorities of funding and the setting of priorities will work in practice and contribute towards fulfilling the Government’s vision
• Whether the Government is right to argue that, for the most part, the right legislative framework for road safety is in place, and, in particular, whether the Road Safety Act 2006 has fulfilled its objectives (see Post-Legislative Assessment of the Road Safety Act 2006, Cm 8141, published by the DfT, July 2011)
• Whether the measures set out in the action plan are workable and sufficient
• The relationship between the Government’s strategy and EU road safety initiatives.
Written evidence would be welcome on some or all of these issues and we would be grateful to receive written submissions by Monday 31 October.
Notes on the submission of written evidence
It assists the Committee if those submitting written evidence adhere to the following guidelines:
1. Written submissions should be as short as is consistent with conveying the relevant information. As a rough guide, it is usually helpful if they can be confined to six pages or less. Paragraphs should be numbered for ease of reference. A summary of the main points at the start of the submission is sometimes helpful.
2. Evidence should be submitted by e-mail to transev@parliament.uk in Word or Rich Text format, with as little use of colour and images as possible. If you wish to submit written evidence to the Committee in another format you must contact a member of staff to discuss this. The body of the e-mail should include a contact name, telephone number and postal address. It should be absolutely clear who the submission is from, particularly whether it is on behalf of an organisation or in the name of an individual.
3. Once accepted by the Committee, written evidence becomes the Committee’s property and it may decide to publish it or make other public use of it. If the Committee decides to accept your contribution as evidence we will email you formally accepting it as such. You may publicise or publish your submission yourself, once you receive the formal acceptance of your evidence to the Committee. When doing so, please indicate that it has been submitted to the Committee.
4. The Committee will usually publish the majority of written evidence that is received, but some submissions will be placed in the Parliamentary Archives for public inspection rather than being printed or published online. If you do not wish your submission to be made public, you must clearly say so, and should contact a member of staff to discuss this. Though the Committee is happy to receive copies of published material or correspondence sent to other parties, formal submissions of evidence should be original work produced for the Committee and not published elsewhere.
5. Committee staff are happy to give more detailed guidance on giving evidence to a select committee, or further advice on any aspect of the Committee’s work, by phone or e-mail.
Additional information on submitting evidence to a Select Committee is available online in the House of Commons Guide to Witnesses.