Responding to the most critical questions

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Postal deadline circa 30th June. Online closing date - July 4th 2024

For those short of time, we feel that the following are the most important questions to answer.

The Call for Evidence is complex, requires expert background knowledge in many cases and runs to 19 pages, with 46 questions and 5 sections, but don’t worry, DVLA state that you should not feel obliged to answer all the questions.

The HCVA will be responding in substantial detail on behalf of its industry and owner/enthusiast members, which requires comprehensive and an in depth knowledge of all the background subjects and HCVA also has access to many recent cases, some of which will be introduced as evidence, so we’ve got this covered.

For the easiest and quickest response we recommend the Snap Survey option above. You don't need to answer all the questions, so you can just scroll through to the key ones we've suggested below.

Section 3 – Historic and Classic Vehicles

Q3.12: Do you think the (rebuilt vehicles) current guidance is still relevant?

HCVA's Answer Guideline:

The HCVA’s opinion is that the guidance is incorrect. There is no ‘fine line’ and the vehicle’s identity is not brought into question by rebuilding or altering it, or indeed drilling, cutting or welding (so repairing) a chassis or monocoque bodyshell, as DVLA are currently suggesting.

The degree of renovation required depends on the degree of degradation the original vehicle has suffered: this is part of the vehicle’s continuing history and DVLA should never remove an original registration or VIN ( chassis number) from a vehicle due to it being rebuilt.

Q3.14: To what extent should a vehicle be rebuilt before DVLA needs to be informed?

HCVA's Answer Guideline:

DVLA only needs to be informed where changes are made to affect the details recorded on the V5C, such as a change of colour, engine number, engine size, fuel type or body configuration.

Q and QNI registration numbers

Q3.37: Currently any modification to the chassis or monocoque (or frame for motorcycles) will result in a Q registration number being assigned to the vehicle. Do you agree with this policy?  

HCVA's Answer Guideline:

 HCVA selected: No

Modifications to the chassis/frame or monocoque of an existing authentic vehicle should not result in the removal of the vehicle’s identity.

Section 5 – Independent Advisory Groups

Q 5.1: Do you think that DVLA should explore the option of setting up independent advisory groups to support the registration process for historic vehicles?

HCVA's Answer Guideline:

HCVA have selected: YES

At present, DVLA are requesting our help and feedback in recognition that there is a problem affecting owners of Historic vehicles in the UK. They are currently referring to a policy written about 40 years ago and interpreting it (as confirmed within the Call for Evidence Guidance) to such a literal sense that drilling a hole in a floor , for safety reasons, to then fit seat belts or a roll cage, will result in an authentic original vehicle identity being made void and a Q plate, DVLA generated VIN and the need for an IVA test to be applied.

The process required to help the DVLA to be able to correct this position is via the Call for Evidence, which is the result of over three years of lobbying by the HCVA and associated organisations.

Therefore, DVLA should absolutely implement this option, using stakeholders represented in the HVUG as its basis and additional experts when deemed necessary.

DVLA themselves successfully defended, as upheld in the Court of Appeal (Seddon vs DVLA in 2019) that they do not have the the expertise on individual vehicle details that exists among specific vehicle restoration specialists and historical experts.

Q5.2 if you wish to put forward any evidence, suggestions or ideas not already mentioned around the registration process, please provide your thoughts around how these might work.

This question can be answered as simply as you wish. We include our response here just an an indication of the depth of potential topics that can be covered in this very open-ended question...

HCVA's Answer Guideline:

DVLA’s current categorisation of Historic vehicles as:

Historic & Classic Vehicles
Reconstructed Classic Vehicles
Rebuilt Vehicles
Restored Vehicles
Kit-built & Kit Converted Vehicles
Radically Altered Vehicles
Vehicles converted to electric propulsion

To many, this can be confusing and leads to incorrect allocation of cases. It is our recommendation that DVLA in future explores and considers potentially using the following categories only –

Historic Vehicles
Built-Up Classic Vehicles
Kit-built & Kit Converted Vehicles

HCVA also proposes considering the introduction of a new category of Continuation Vehicles for the recent innovation of continued-production historic-type vehicles built by the original manufacturer.

DVLA’s priority should be to keep vehicles registered, NOT change or withdraw registrations at will.

When assessing a claim to an original, currently lapsed, registration, DVLA should not insist on provision of a historic RF60 log book or old MoT certificate.

When assessing imported classics, DVLA should accept vehicle manufacturer records when issuing an age-related registration number.

When assessing imported classics, DVLA should be sensitive to the different use of terminology by foreign registration authorities.

DVLA should reintroduce the scheme allowing owners to obtain copies of past registration records for Historic vehicles.

DVLA’s current V894, V672/1 and inspection route, instigated without giving any justification, is onerous and is inconsistently applied and followed. 

Postal deadline circa 30th June. Online closing date - July 4th 2024