APPENDIX 23
Memorandum submitted by the Retail Motor
Industry Federation
VEHICLE AND
OPERATOR SERVICES
AGENCY (VOSA)
Passenger Car MOT Testing
VOSA should be an enforcement agency and leave
training to professional bodies.
Current requirement for refresher courses every
five years is insufficient.
The introduction of the computerised MOT system
has been beset by problems, numerous breakdowns in software, resulting
in loss of income. Compensation schemes for the industry have
been slow and difficult to quantify.
Commercial Vehicle Sale and Maintenance
There are problems with vehicle testing procedures.
Improvements to facilities, equipment and premises are in hand
but overdue and have resulted in higher fees.
There is a lack of consistency between test
stations and testers.
Existing regulations on permitted use of trade
plates by VOSA are ambiguous.
DRIVER AND
VEHICLE LICENSING
AGENCY (DVLA)
New programmes
The Driver and Vehicle Operator Group (DVO)
aimed at creating a virtual database of IT infrastructure across
agencies but efforts have concentrated on enhancing the level
of service for consumer rather than retail industry.
New regulations
There is a lack of consistency from DVLA offices
and ambiguous information is provided on new regulations.
The standard of service from Local Offices varies
significantly and must be addressed.
Registration marks
Should DVLA be both administering the transfer,
retention and sale of mark facilities and at same time selling
registration marks?
Registration marks costing
DVLA generates income for UK Government by selling
registration marks. It is questionable whether this provides the
best return for capital employed.
General comment
The Agencies carry out an essential and complex
transport function. There should be no cut back in investment
by DfT in these Agencies.
1. INTRODUCTION
This memorandum is submitted in response to
the Transport Select Committee's Press notice 17/2005-2006 dated
9 December 2005 on the Department for Transport's Executive Agencies.
The RMIF represents businesses concerned with
providing motor industry products and services and has more than
10,000 members throughout the UK. You will be aware that the annual
turnover of the UK retail motor industry is in excess of £70
billion and employs 600,000 people in 30,000 businesses. Annually
the industry raises £33 billion in tax revenue.
As a Trade Association the RMIF works very closely
with the Executive Agencies and what follows are some objective
comments on the following agencies;
(2) Vehicle and Operator Services
Agency
(3) Driver and Vehicle Licensing
Agency
2. VEHICLE AND
OPERATOR SERVICES
AGENCY (VOSA)
(a) Introduction
The Retail Motor Industry Federation (RMIF)
has two primary interfaces with VOSA. The first is in respect
of MOT testing for cars in terms of testing standards, policy,
administration, appeals, and future developments, and the second
is in relation to the commercial vehicle division of the RMIF,
and the regulatory regime that applies to this sector of the retail
trade.
(b) Passenger car MOT testing
The RMIF is of the opinion that some responsibilities
currently allocated to VOSA could be better carried out elsewhere.
For example the RMIF believes that VOSA should be primarily an
enforcement agency and leave the training side of testing to professional
bodies, as the Agency is commonly perceived to be judge, jury
and executioner in respect of the MOT system. The current requirement
for refresher courses every five years is insufficiently frequent.
Current training methods also leave much to be desired—potential
testers who fail an exam can purchase further training from VOSA,
but this is intended to calibrate skills rather than provide the
necessary retraining. VOSA maintain that potential testers should
be fully trained before attending courses.
In respect of performance, the introduction
of the computerised MOT system has regrettably been beset by problems.
As a result of being approximately three years behind schedule,
implementation has been rushed leading to frustration on the part
of the industry and the general testing stations. Equipment supplied
is of outdated technology and will need to be upgraded in the
near future. There have been numerous breakdowns in the software,
resulting in loss of income. The compensation scheme for the industry
has been slow and difficult to quantify.
The RMIF participates jointly with VOSA in several
working groups within CITA (the organisation that promotes standards
testing worldwide) and seek to foster a constructive, ongoing,
working relationship with VOSA. There has been a distinct improvement
over the last five or six years with regard to VOSA's attitude
towards the industry, which has been reinforced with the appointment
of a new Chief Executive.
(c) Commercial vehicle sale and maintenance
VOSA, understandably due to its role as an enforcement
agency, maintains its primary interface with the vehicle operators
and the organisations that represent them. However there are important
areas of their responsibilities that impact on the retail industry.
These relate primarily to annual testing which is undertaken by
VOSA either at VOSA Test Stations or at dealers ("Designated
Premises"), safety inspection processes, and trade plate
usage. As mentioned in the context of our comments on the MOT
system, VOSA is primarily an enforcement agency. There is arguably
a case for greater private sector investment in commercial vehicle
testing as happens in the car sector through the MOT scheme. This
would enable more flexibility in terms of longer working hours
and the more effective grouping of work to minimise downtime for
operators.
For many years the retail motor industry has
encountered problems with current vehicle testing procedures as
currently implemented. Improvements to facilities, equipment and
premises are in hand but are long overdue and have come at a price
in terms of significantly enhanced fees. There remains a serious
lack of consistency between test stations and testers. Although
VOSA and the RMIF have jointly collaborated to identify and address
key areas of concern, there still remain unexplained issues such
as the very high rate of headlamp alignment failure at test and
insufficient data available on failure types and trends.
The retail industry has a key role to perform
in road testing, taking vehicles and trailers to test, and collecting
and delivering both new and used vehicles. This function would
normally require the use of trade plates. Regrettably it has become
clear over the last few years that the interpretation of existing
regulations in respect of the permitted use of trade plates by
VOSA is ambiguous. The new Chief Executive at VOSA has responded
positively to our concerns, and VOSA and the RMIF have now set
up a new working group to examine this issue and others, which
are relevant to commercial vehicle distribution and servicing.
3. DRIVER AND
VEHICLE LICENSING
AGENCY (DVLA)
(a) Introduction
The RMIF has historically worked very closely
with the DVLA given the importance of the latters' processes and
practices for the retail trade, and the potential impact of any
changes on RMIF member businesses. An early example of successful
collaboration was the development of the automated first registration
and licensing system for new cars (AFRL) in the mid 90s. The RMIF
has continued to participate in a number of key working groups
with the DVLA and other industry partners, such as those involved
with crime reduction to meet the government's targets (VCRAT),
and those aimed at modernising the registration system and enhancing
the accuracy of the record (MVRIB). The DVLA maintains a twice-yearly
meeting with all trade associations to keep them informed of developments
(ILG meeting) and calls additional stakeholder meetings as appropriate.
(b) New programmes
The establishment of the Driver and Vehicle
Operator Group (DVO) aimed at creating a virtual database of the
IT infrastructure across the agencies has provided a major impetus
towards the development of online services but initial effort
appears to have been aimed more at enhancing the level of service
for the consumer rather than the retail industry.
It has been frustrating seeking to drive forward
key programmes such as tracking vehicles through the trade (TV3T)
over a long period of time because of the numerous changes of
staff within the DVLA project team. In fairness this has now been
recognised by the DVLA, and we have now seen the establishment
of a much more pro-active Motor Industries Services Team and good
progress is being made on TV3T. Likewise a team has now been established
to pull together and prioritise additional key trade requirements.(Vehicles
Programme Definition) with the aim of offering more support for
business and corporate customers.
(c) New regulations
While the RMIF has been generally supportive
of the objectives of the various new regulations introduced over
recent years (Statutory Off Road Notification, Continuous Registration
etc), our membership has at times suffered from a lack of consistency
in application from the various DVLA offices around the country
and divergent information being provided on how the new regulations
affect the trade. It has also been necessary to lobby for a more
pragmatic approach in those areas that introduce unnecessary and
excessive bureaucracy. The standard of service from Local Offices
has varied significantly for many years and needs to be addressed.
The closure of a significant number of the Local Offices in the
mid 90s clearly did not foresee the significant increase in workload
(we understand that DVLA headcount has risen by some 50% in five
years), and the routing of calls through a call centre has proved
extremely frustrating for the retail industry. More targeted communication
by the Agency at a time of rapid change is essential.
(d) Registration marks
Vehicle Registration Numbers or Marks are not
items of property in their own right. They are assigned, and may
be withdrawn by the Secretary of State for Transport as part of
the basic registration and licensing process, which is required
by law. The registration mark is a unique means of identifying
a vehicle, primarily for taxation and law enforcement processes.
It is assigned to the vehicle, rather than its keeper and, unless
it is transferred or retained, the registration mark normally
remains with the vehicle until it is broken-up, destroyed or sent
permanently out of the country.
An individual acquires entitlement to a registration
mark when he or she becomes the registered keeper of the vehicle
that carries the number. When the vehicle changes hands, entitlement
to its registration mark will automatically pass with the vehicle
to the new keeper unless use is made of the special facilities,
which have been designed to enable the motorist to acquire and
retain particular registration marks. These special facilities,
the Cherished Transfer, Retention and Sale of Marks schemes, are
administered by the DVLA. It is also these special facilities
that allow members of the CNDA to trade in vehicle registration
marks. The trading of vehicle registration marks is a growth industry,
thousands of motorists now display vehicle registration marks
that perhaps represent their initials or advertise their business
or profession.
DVLA administer the Cherished Transfer, Retention
and Sale of Marks schemes. As an Executive Agency it is correct
that DVLA should have this responsibility. However, since December
1989 DVLA has had its own sales scheme, looking to sell registration
marks to end-users. Today DVLA has three distinct sales brands;
DVLA Select, DVLA Classic Collections and DVLA Custom Marks. There
are perhaps questions over whether DVLA should be both administering
the transfer, retention and sale of mark facilities and at the
same time selling registration marks.
(e) Registration marks costing
DVLA generates income for the UK Government
by selling registration marks through its three sales schemes.
However, perhaps questions can be raised as to whether this generates
the best return for the capital employed. For example, DVLA spends
two million pounds each year on advertising, in order to drive
sales through their three sales schemes. An alternative might
be to operate as a wholesaler, selling registration numbers into
an existing and dynamic registration number industry, who would
then market to the end user. DVLA would raise the same income
for the UK government, yet without incurring the costs of raising
this income.
DVLA also have the need to administer the transfer,
retention and sale of mark facilities in the most efficient manner
possible. The staff of the DVLA Local Offices work extremely hard,
in difficult circumstances. However the administration of the
transfer, retention and sale of mark facilities needs review.
For example, a requirement of these facilities is that vehicles
involved, must be available for inspection. This is an understandable
requirement, however a number of CNDA members have reported incidents
where DVLA request inspections of the same vehicle many times
through the course of a year. For DVLA this is a waste of time,
money and resource.
DVLA local offices operate to a turnaround time
of seven working days for completing the administration of the
special facilities for transferring vehicle registration marks.
However, there is a particular problem with marks being transferred
into and out of Northern Ireland. CNDA members have numerous examples
of these transfers taking in excess of eight weeks to process.
(f) Conclusion
Since the DVLA became a trading fund in 2004
considerable discussion has taken place as to how the Agency can
fund its forward budget particularly to meet the requirements
of the 3rd EC Licence Directive. A number of new fees are under
consideration. Substantial sums are raised by the Treasury through
road taxes and the sale of number plates with only a relatively
small amount being reinvested in the industry infrastructure.
The DVLA has a direct influence on the trading
of vehicle registration marks, through administering the system
and by selling vehicle registration marks to the end user. Questions
can be raised as to this dual role. Additionally, questions can
be raised as to whether DVLA provides the taxpayer with the best
return for capital employed and provides an efficient and effective
service.
A distinction is drawn by the DVLA and Government
between fees and taxes but in the eyes of the consumer there is
little perceived difference. The motor industry in the UK has
always benefited from a transparent and fiscally easy system compared
with continental Europe, and it is important that this is protected.
In support of this we also note the intent of the EC Commission
to gradually abolish registration taxes across Europe.
The Agencies carry out an essential and complex
transport function. There should be no cut back in investment
by the DfT in these Agencies.
12 January 2006
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