Draft for a letter to the RSA

peasant

Ok ...its come to the point where we as campervan/motorhome drivers have to DO SOMETHING about this DOE testing of our vehicles. The way it seems to be going right now is very messy.

The point of this thread is to pool our thoughts and make some reasonable suggestions to the RSA on how this test should be handled.

To summarise events so far:
1) The RSA wants campers to be tested - to that we have no objection, in principle

2) The NCT can't take most campers due to size restrictions, so we're about to get lumped in with commercial vehicles and the DOE test. - Now that's where the trouble starts: First of all ...some of our vehicles (not all of them) are based on commercial vehicles, but all of them are used as private vehicles and taxed as motor caravans. So there ought to be some breathing space in the implication of the DOE test.
For starters a test every two years would be fairerer ...no other private vehicle gets tested on an annual basis.

3) There needs to be clarification what exactly the DOE test entails and where that could conflict with normal, factory-standard motorhomes. It must not happen that something that left a motorhome factory a few years ago with EU type approval (and has possibly been tested in another EU country since) is all of a sudden deemed not roadworthy here only because something or other that is a typical motorhome feature does not meet DOE guidelines. If needs be, separate guidelines for motorhomes need to be worked out.

4) It can not be that the owner of the vehicle will be held responsible for providing documention about glazing (and whatever other components the RSA or DOE can come up with) in order to pass the test. As long as any component is a standard factory fit or standard aftermarket item that is used on motorhomes throughout the EU it has to be legal here as well without the burden of proof being on the owner. Some common sense needs to be applied here. This also should apply to home conversions. As longs as off the shelf motorhome components and accessories where used in the conversion these should be passable without problems.


ok ...now ...please add any constructive ideas / other points that you may have and we'll then put it all together and write to the RSA.

Please keep this thread clean, no off topic discussion ....focus


ohh ...and as an after-thought:
Those of you who are club members (any club) ...please invite your fellow members to put club rivalry aside for a bit and to participate in this discussion. It would be great if we could pool all resources and maybe speak with one voice on this issue. (If any club is already further down the road with this, I would have no problem with supporting their campaign either, if that would be more effective.)

Macspower

My letter to and from the RSA probably belongs here and feel free to pick and choose relevent bits... cross posted from DOE thread... Just my own thoughts on the subject..

My letter

Sent: 04 August 2009 12:05

Subject: Testing of Motorhomes and campers


Hi

Regarding the new proposed regulations about the testing of Motorhomes
and Campers.

Just to fill you in on the matter. I am a camper van owner now for
nearly 10 years and also recentyl purchased a motorhome and
I am well aware of the need for testing of all vehicles on the road but can I please bring a few matters to your attention..

Firstly as stated I am all on for testing as I personally know of some
campers and in particular conversions that should not be on the road.
But and it is a big BUT the test needs to be suitable for the purpose it
is intended... To make for safer motoring.


A DOE test for a camper with all the regulations of a Commercial Vehicle
is not a fair test for a motorhome.. It is not a commercial vehicle and
therefore should not and cannot be tested as one. These are leisure
vehicles and while some may have many similarities to commercial
vehicles they are a seperate category in their own right.... Leisure
Vehicles

In my opinion the following should be taken on board while designing a
test for these vehicles

1) The test can be carried out through the VTN as proposed

2) Due to the mileage ( I do on average 2000/3000 miles per year) an
annual test should not be required but instead one proportional to the
use... Every 2 years like the NCT or 3 years would be more appropriate.

Once every vehicle is tested once and it is deemed as roadworthy very
little is going to change in a year

3) For vehicles over 3.5 tonne (many are just over this) do you propose
that need to be treated like a commercial with a tacho and side marking
and weight plate, speed limiter etc?? Due to the purpose of the vehicle
I believe this is not necessary and completely complicates the situation
and the purpose of the test which is to have safe vehilces on our roads

4) On speaking to my local DOE centre they inform me that a certificate
of some sort is required for the window glass.. In my vehicle the
windows are stamped by the manufacturer and are made from some sort of
double glazed perspex. While I understand the need to make sure that the
windows are safe a cert is not the answer in my opinion.. I have seen
some conversions with ordinary "house" window glass and this should be
outlawed... Why not leave it to the test centre to determine if the
windows are safe or not?

5) Is there a proposal for some sort of inspection of the gas and
wiring? This is every bit as important for safety as the rest of the
test and to overlook it would be contrary to the purpose of the test...
ie SAFETY



In Summary... The test needs to be designed for the purpose which it is
intended... To keep unsafe vehicles off our raods.. Campers/Motorhomes
are not commercial vehicles and should not be tested as one but instead
have a custom test designed for the purpose and frequency to fair to the
use.. every 2/3 years.... If every 2 years is good enough for a car
doing 50k per year every 2 years should be good enough for a leisure
vehicle..


While we are a minority group and whatever you decide we will have to
live with all I ask for is a FAIR test for my vehicle designed for the
purpose and use it was intended for.

Kind regards,




response from RSA




Thank you for your submission and views. The RSA will be conducting a review of the testing regime for motor caravans and we shall include in the discussion the issues you have mentioned.

Briefly, the RSA is considering these vehicles as goods vehicles for testing purposes only. A goods vehicle does not mean a commercial vehicle.

The legislation for tachograph use provides for exemptions including one for "vehicles or combinations of vehicles with a maximum permissible mass not exceeding 7.5 tonnes used for the non-commercial carriage of goods." I believe most owners who might otherwise be liable for a tachograph can legitimately claim this exemption. Each VTN centre has copies of the form to be signed prior to the test.

The RSA has already issued a circular to the test centres providing a temporary exemption (pending the review) from the requirement for conspicuity markings.

Non-glass glazing must be to an automotive standard; therefore, if the material is marked as such (e.g. E-marked 43R signifying type approval to UNECE Regulation 43 for automotive glazing) it will not require further documentation. The burden of proof is on the owner to show that that the glazing meets automotive standards for the reason you mentioned. It is not the responsibility of the test centre to investigate the source and quality of the glazing.

Again, thank you for your views. They will be considered and discussed during the upcoming review of testing motor caravans.

Regards,

XXX

Engineer

Standards & Enforcement

RSA_Official

Clonfert House, Loughrea , Co Galway

peasant

The RSA will be conducting a review of the testing regime for motor caravans and we shall include in the discussion the issues you have mentioned.
....
Again, thank you for your views. They will be considered and discussed during the upcoming review of testing motor caravans.

I think we need to wrangle an invitation to this review out of the RSA.

Everybody else has lobby groups ..we need one too.

Irishgoatman

Hi,
These postings, by both Peasant and Macspower, appear to cover all issues. Well worded and to the point.
Well done.

chrisblack

Just a thought - if campers are DOE'd -does that mean a E50 VRT on import as with commercial vehicles???

Chris

peasant

copy of a post in the DOE for campers thread:

Ok ..maybe it needs to be spelled out more directly

This forum is a forum for all motorhome/campervan enthusiasts ...regardless which club they are or aren't affiliated with.

We all are very anxious about this whole DOE thingy and we all would like to be involved in decision making process and/or put our weight behind any initiatives that may be going.

It would be counterproductive however if we here cooked up our own little thingy, possibly sabotaging any developments that clubs may have initiated. (No point in 100 odd readers of this forum signing a petition for a DOE test with conditions attached if the clubs are near getting it struck off totally, for example)

I would therefore like to invite all clubs and club members (in as much as they can and in as much as it doesn't interfere with the ongoing dialogue with the RSA/DOE people) to share their thoughts and plans with us.

I would also like to invite all clubs and club members to use this forum (and this thread in particular) as a "neutral ground" for discussion of the issue, if that would be helpful/desirable.

peasant

MODEDIT

moved all the recent discussion posts to the DOE thread. I'd like to keep this thread for any suggestions for a letter that we may or my not write at some point