Sunday 25 Aug 2019
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Letter to David Whale, Chairman of FBHVC from Simon Saint, Chairman of 2CVGB Ltd

Bob Owens article on the London ULEZ (Newsletter issue 2, 2019 page 4) contains comments which I think require explanation because they give the impression of having been made without any thought about their implications.

The self declared purpose of the Federation is to ‘uphold the freedom to use historic vehicles on the road’ and it does this by representing the interests of owners to politicians, officials and legislators. However Mr Owen now tells us that in representing those interests the Federation will be taking the view that historic vehicles ‘are no longer a means of transport as such’.

He goes on state that ‘the Federation cannot really support the use of vehicles claiming to be historic if they are in fact in daily use as transportation’.

I appreciate that these comments are made in the context of a discussion about the impact of ULEZs on older vehicles. However the comments to which I refer are introduced by the words ‘and there is one more difficult matter I need to address’ indicating that they are a statement of Federation policy not necessarily or solely related to the issue of ULEZs. As I read it they are general and unambiguous comments of the Federation’s approach to the definition of historic vehicles and the way in which the Federation thinks they should be used.

It seems to me that this is a redefinition of the Federation’s purpose, in which case how did it come about and how and by whom was the decision made. What is the argument in support of the view that a vehicle should no longer be considered a ‘means of transport’ because of its age and in any case what other purpose could a vehicle have than as a means of transport. Are we to accept a redefinition of the Federation’s purpose as to protect the freedom to use our vehicles on the road except when they are in daily use?

The creation of a category of ‘Historic Vehicle’ was a two edged sword. Clearly there are benefits for the owners of these vehicles. However the placing of a vehicle in that category distinguishes it from the majority of vehicles and it is only one step away from placing restrictions on such vehicles on the basis that they benefit from special privileges and should be treated differently. I could imagine a time when legislators took that view but I was not expecting it from the very organisation that exists to represent our interests.

If I have misunderstood Mr Owen then I apologies but I think it unlikely that I am the only person to have done so. At the very least the Federation should make a clear statement as to how these comments should be interpreted.

Letter to Simon Saint, Chairman of 2CVGB Ltd from David Whale, Chairman of FBHVC from 

Dear Simon,

Many thanks for your letter of today’s date. We very much recognise that Bob Owen’s comments in the last issue of Federation News caused a reaction and Bob has just finished writing a piece to explain in much more detail our perspective. We take the opportunity to share this with you in advance of publication in the next issue of Federation News and very much hope this will provide reassurance.

“A few words in the last edition of the FBHVC News seem to have created quite a storm.

So this might be a good time both to restate some of the Federation’s principles and to explain the environment in which we have to work, and the fine line we sometimes have to tread.

The Federation stands four-square behind its existing principles of protecting, to the full extent possible, the right of its members to use their historic vehicles, of all sorts, without restriction as to frequency or distance of travel on the highways of the United Kingdom.

In the United Kingdom we have been fortunate.

These rights of unrestricted use are not recognised in all countries.

What is more, our Government does not require a formal standard of what is a ‘historic’ vehicle, and again this is not always the case.

Our Government is content to rely on the age of the vehicle without setting more rules for a vehicle to qualify as ‘historic’. They consider that this approach does not create any measurable risk to safety, nor is there any obvious benefit to society, which would justify the effort and cost involved in setting rules. They have chosen a date of forty years old which, while not perhaps ideal, is one we have been able to work with as covering the interests of most of our members across all the types of historic vehicles we cover.

Even when working within EU constraints, on the extent to which they will exempt historic vehicles from MOT tests, our Government has chosen to apply an extremely light touch.

They have again applied a simple, and simply applied, rule of date of manufacture, (nearly but not exactly the same as for registration) with only the most limited of exceptions, though of course for some of our members, notably those whose area of interest is heavy goods vehicles, there are more onerous constraints.

Although there are attractions to the Federation of more strongly favouring the internationally recognised definition of thirty years to qualify as a historic vehicle, that international definition, as expressed by FIVA, does come with limitations as to originality and frequency of use. So while occasionally reminding our Government of the international standard, we tend to accept the current UK position as being a good compromise.

But the world around us is changing. In years gone by we did not have to justify our interest; it appealed to the general popularity of nostalgia and no one really considered it to have any downside.

But two very real issues, related but by no means the same, have come along and attained high importance and recognition in society in general, and particularly among younger people.

The first is climate change; there is now little or no doubt that it is real and potentially disastrous for the World.

It is gradually becoming recognised in the automotive industry that we may be at a point similar to the early 20th Century, when the end of the use of the horse and its replacement by the internal combustion engine happened much quicker than anyone expected. And now, unlike then, there are powerful reasons to proceed as fast as technology will permit from the internal combustion engine to electric power for vehicles. Our valued vehicles may surprisingly quickly become different in kind, rather than simply in state of development, when compared with current transport.

The need to control the speed of climate change led to Low Emission Zones (LEZs).

And the other is a greater understanding of air quality and its effects. The rapid advance of both air quality measurement techniques and of the science of epidemiology has meant that there is a much greater recognition about how the air we all breathe affects our health, both now and in the future. This is perhaps of more immediate effect to those directly affected. Thus we see the rapid development of Clean Air Zones (CAZs).

LEZs and CAZs are going to happen and both have increasingly general support. For various reasons, decisions on how they are to be set up are local. Differences can be quite major.

For instance, most LEZs and CAZs being set up do not affect motorcycles. There are extremely good reasons for this. But the London ULEZ does include motorcycles. Motorcycles which are in the ‘historic’ class are of course already excluded and can enter the ULEZ as they please without paying a charge.

There is a perfectly respectable campaign underway to have the use of motorcycles for commuting into London taken out of the ULEZ regulations. But it covers essentially all motorcycles over around 20 years old, and really has nothing to do with historic vehicles as such. We don’t oppose that campaign but it is not our fight.

Like the London ULEZ, the national Clean Air Framework which affects English local authorities requires them to exempt ‘historic’ class vehicles.  But the situation is more difficult elsewhere.

In Wales their consultation on a framework proposed only to exempt historic vehicles which were incapable of being modified to comply with emissions standards. The Federation protested that this could amount to cultural vandalism and now awaits the outcome of the Welsh consultation, which is, for some reason, delayed.

In Scotland there is a different problem. The Scottish Government framework proposal is not for charging zones, but for actual bans on use within Zones. While they are not unsympathetic to an exemption for historic vehicles, in view of the possible draconian effect of a ban we are attempting to get them to accept a thirty year cut-off for their historic exemption. We are in active discussion with the Scottish Government on the subject.

Which is where we get to the problem to which last month’s brief reference caused such a reaction.

The Federation always needs to make the best case possible for the interests of as many of its members as possible. We emphasise the increasing recognition of the cultural significance of our vehicles. And we are able, using our own extensive research, honestly to say that in general our members use their vehicles rarely and for very few miles for purposes related to their age and significance, and not simply as normal transport on a regular basis. This is a fact, not a projection. We can therefore argue with conviction that the privilege of an exemption will in fact be quite rarely exercised and have little or no effect on either air quality or greenhouse gas emissions.

We of course know a few of our members will wish to use their vehicles on a daily basis. On the basis of our research we consider that they are sufficiently few in number that they also cannot have any measurable overall effect on emissions.

So we would of course raise objections to any suggestion of the imposition of mileage limits. Up to now, none have ever been proposed. If they were, we would oppose them because the cost of policing such a limit to catch a very few unlucky users would vastly outweigh any benefits.

And lastly, there is perhaps the most difficult question. The responsibility of the Federation is to the historic vehicle community. That is emphatically to all historic vehicles. We value the rights of the owner of an Austin Allegro, or an Ariel Leader, or a Leyland Octopus, or a Bedford OB bus equally with those of a Rolls-Royce Phantom III.

We know that there are a significant number of vehicles considered by their owners to be ‘classics’ but which are simply not old enough to be considered historic, either by UK registration rules or by the international standard. The Federation is by no means opposed to the ownership of modern classics. We know they are cherished by their owners. We know many of these classics will become historic as the years go by. When they become thirty years old, they will fall within our remit.

Before then, they are not and cannot be the responsibility of the Federation. Arguments in favour of their use will only serve to dilute the simplicity of our message on historic vehicles. But we do not and will never argue against the use and ownership of modern classics. We will attempt as much as possible, to offer no public comment for or against their use.

We hope that the owners of newer classics will understand our dilemma and recognise that we have to do the best possible, using all the strongest arguments available to us, to serve the interests of our members.”

If you wish to raise any further points, please come back to me.

With kind regards,

David Whale

 

 

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