New RSA Consultation

Going Forward

The RSA is seeking the views of commercial vehicle owners about a wide ranging set of proposals aiming to radically overhaul the commercial vehicle testing regime in Ireland

A 56 page document, with a response date deadline this Friday 4th Nov.

http://www.rsa.ie/Documents/Vehicle%20Std%20Leg/Consultations/RSA%20CVR%20-%20Operator%20Consultation%20-%20Issued.pdf

-Chris-

Thread copied from C&T

Buffman

I had a quick scan through this, good few changes for HGV operators from what I can tell.

Most of us here who do the DOE will have LGV's, so I'll stick to them. The main proposed changes to the LGV DOE test I can see are:

-Yearly test based on the date of first registration, not the previous test date as is the case.

-A 'DOE' disc to be displayed, like the NCT disc.

-The CRW (Certificate and Disc) will be issued by a central office, not by your motor tax office, with a view to allowing online taxing for commercials.

-Cost is going to increase to around €102, and includes for test and CRW, and a 'road safety levy' whatever that's supposed to be?

I think that's it regarding LGV's, anyone spot anymore?

My opinions,

Yearly test:
Well, you're already required to do the test once the vehicle is over a year old, so no real change. It will probably be an issue for older vehicles where the dates may have slipped due to off road periods. It will affect fleet operators who buy in bulk at the same time, who'll find themselves having to stagger the tests by doing them early. Page 33 of the document is an interesting read with regard to test slippage.

Disc display:
I not a fan of cluttering up windscreens with discs, IMO we should only need 1 disc which should display everything. But this change will bring commercials in line with privates, so can't really complain I suppose.

Certificate of roadworthiness/online taxing:
I'd agree with this, it was always unnecessarily complicated having to get your test passed, and then pay again to have this changed into a CRW at the MTO, and then finally get taxed. About time they gave us the chance to tax online.

Cost:
'Road safety levy'? Another load of BS. It's a comparable test to the NCT, but will cost twice as much. You can test 2 identical vehicles, a private passenger version with NCT, and a commercial with DOE, yet the price of the DOE is significantly higher. This is the case as it stands and never made sense to me.

So, anyway, anybody with a LGV (Van/commercial jeep) or HGV/DOEable PSV should have a read of the document 'Going Forward' posted and get onto the RSA with their own views, before this Friday 4/11/11.

cvroperatorconsultation@rsa.ie

Slidey

I'll have a read of this later. It was brought up in the refresher course for DoE testing but I was busy counting threads in the carpet at the time..

CiniO

I'll have a look at the document later when I'll have a bit of time.



For quick now:

Buffman wrote: »

Yearly test:
Well, you're already required to do the test once the vehicle is over a year old, so no real change. It will probably be an issue for older vehicles where the dates may have slipped due to off road periods. It will affect fleet operators who buy in bulk at the same time, who'll find themselves having to stagger the tests by doing them early. Page 33 of the document is an interesting read with regard to test slippage.

I think it's complete utter nonsense.
Company I work for has 3 vehicles which fall under DOE regulations.
Due to seasonal nature of our business, all 3 of them are used regularly (everyday) March to November, and then pretty much being parked for December to February.
That 3 months is a perfect time to do all regular servicing and DOE test on all of them.
With proposed regulations we will be forced to do DOE test something in the middle of season, so we will need the vehicles off work for few days anyway, causing us to loose business.

Other thing are vehicles which travel abroad for long time.
Currently you can do DOE test anytime, and have it valid for a year, so physically a vehicle can stay abroad for the whole year and then come back to pass next DOE test.
Now vehicle will have to come back to Ireland in specified moment to do DOE test. Nonsense.
I remember there was some company in Ireland which send the whole fleet of it's tipper trucks to Poland to do work there on motorway building site.
It was a year contract. With proposed regulations it wouldn't be possible.

Slidey

CiniO wrote: »

I remember there was some company in Ireland which send the whole fleet of it's tipper trucks to Poland to do work there on motorway building site.
It was a year contract. With proposed regulations it wouldn't be possible.

Thats McGrane from Donegal I'd say.

I don't agree with having to test it on the registration anniv but I would support the new cert applying to one year from the expiry of the old one.

A lot of commercial vehicles are tested for a year, taxed for 9 months and then taxed for 12 while the cert is still valid

-Corkie-

Too many cowboy hauliers out there not compling with regulations and cutting rates on lads running legal.. A lot of dodgy doe testers around too especially around sligo.:pac:

Slidey

:eek:

Eric Cartman

yeah... the already above-nct priced test gets pricier ,

the part i dislike the most is the 'updated near real time' and 'live' talking about testing and its link to servers, im not a fan as the best part of the DOE was always 'everythings fine except...insert minor issue like a bulb being out..." and on your way you go

Buffman

CiniO wrote: »

Other thing are vehicles which travel abroad for long time.
Currently you can do DOE test anytime, and have it valid for a year, so physically a vehicle can stay abroad for the whole year and then come back to pass next DOE test.
Now vehicle will have to come back to Ireland in specified moment to do DOE test. Nonsense.

Yep, have to agree with you on that. I think, seeing as the RSA keep telling us that all these changes are due to EU regulations, you should be able to do the test in whatever EU country the vehicle happens to be in, to save shipping it home just for the test. Probably not a runner for loads of reasons, but would be a solution. The other countries would probably say if the vehicle is going to be there for a +1 year period, it should be re-registered locally.

CiniO wrote: »

I think it's complete utter nonsense.
Company I work for has 3 vehicles which fall under DOE regulations.
Due to seasonal nature of our business, all 3 of them are used regularly (everyday) March to November, and then pretty much being parked for December to February.
That 3 months is a perfect time to do all regular servicing and DOE test on all of them.
With proposed regulations we will be forced to do DOE test something in the middle of season, so we will need the vehicles off work for few days anyway, causing us to loose business.

I didn't mention it in my first post as I hadn't read it fully, but the RSA seem to have left it flexible enough for operators to change the due date by getting it tested early and for vehicles to be sold/sent abroad with a full year long test, so hopefully shouldn't effect your situation hopefully, apart for the extra cost of course. ((......?) is where I've fixed their typo's.)

It will be possible for an operator or dealer to offset the test due date of the vehicle from its (anniversary date?) by
presenting the (vehicle?) earlier for its test i.e. if an operator presents a vehicle that has a valid test
certificate at the time earlier than its anniversary date e.g. with a certificate that still has six
months before it expires they will be able to select this date as the expiry date of the
certificate on an ongoing basis as opposed to its initial registration date. This will enable
dealers to sell vehicles with 12 months certificates and operators to smooth demand across a
year if they purchase a large number of vehicles at the same time.

Fishtits

The RSA have done many good things, road casualties are decreasing etc.

But. I fear they are now at the stage where its gone to their heads, a hint of a power trip about all this?

Has their Terms of Reference ever been published?

The user/driver is a soft touch, IMHO they now need to take a strategic decision and turn the screw on the roads and get the relevant authorities to fess up & prepare plans to upgrade the tar and grit based roads that are the daily traverse of the majority. (Jeez, that sounds like a manifesto!)

Seriously, the RSA needs to broaden its approach to recognise our road safety problems in their entirety

CiniO

Buffman wrote: »

The other countries would probably say if the vehicle is going to be there for a +1 year period, it should be re-registered locally.

The only countries where there is really any pressure on re-registering it locally, are countries that charge a tax like VRT, and as well countries that charge motortax on every registered vehicle.
In other places, you can really drive on foreign plates for years, and no one cares. In many countries there isn't really any regulations limiting amount of time you can drive on foreign plates.

Anyway one is for sure. You can't test a vehicle in any other country apart from one it's registered in. I hope it will be changed soon enough by EU.

Going Forward

Fishtits wrote: »

The RSA have done many good things, road casualties are decreasing etc.

But. I fear they are now at the stage where its gone to their heads, a hint of a power trip about all this?

Has their Terms of Reference ever been published?

The user/driver is a soft touch, IMHO they now need to take a strategic decision and turn the screw on the roads and get the relevant authorities to fess up & prepare plans to upgrade the tar and grit based roads that are the daily traverse of the majority. (Jeez, that sounds like a manifesto!)

Seriously, the RSA needs to broaden its approach to recognise our road safety problems in their entirety

I would agree, and I think a major reason, is that with the welcome reduction in road fatalities, the RSA is now having to keep itself busy to justify its budget, and that means they are going to keep coming up with more rules and regulations and more paperwork for operators.

Going Forward

Didnt reply before cos i didnt get notification of the replies posted for some reason

Had anyone seen any newspaper ad for this consult beforehand, because I just happened to see it on their website one night whilst looking up mammy's licencing requirements for the Honda 50.

Bagenal

The "consultation" with regard to the introduction of the Drivers CPC was similar in my opinion i.e. no one heard of it until the date for submissions had passed. Certainly I didnt, the only reason I knew about the Drivers CPC was by reading UK truck magazines, at the time I worked where there were about 70 drivers & I reckon the vast majority of them had'nt heard about the CPC until I mentioned it. The reduction in fatalities on roads is welcome news and hopefully the numbers keep reducing but the RSA is not as good as it keeps telling everyone it is. They have a lot of work to do on the enforcement of tachograph regulations and Commercial Vehicle testing, they could take a leaf out of VOSA's book if they want to keep heaping praise on themselves.