ACTO 150 gives you the RAFAC version.
A permit 19 has a weight limit attached IIRC. Maybe the bus was overweight and so they needed the full D1?
Iāve always thought that the āminibus liteā they advertise was going to fall foul of this.
The bus is over the weight limit but has a folding ranonjd the ability to remove seas for a wheel chair. The company who make it claim this covers the āspecialist equipmentā bit which gives you 4.25 tonnes, Iāve never been 100% convinced of that.
It was a light minibus tooā¦
Itās all a mess at the moment hopefully itās all sorted rapidly.
Notwithstanding some of the nuances in terms of what constitutes hire and reward, how Wings etc can say you must have a D1 to drive say an MPV, is just testes.
How many of us know people with ā7 seatersā, that they just drive, so why a squadron, if they could afford the insurance and other costs, couldnāt have 2 of these, which offers greater flexibiiity than a single 16 seater. Also parking etc is a lot easier.
No need for anything else licence wise. The licence problems make having an SOV more trouble than itās worth.
We got by with a 17-seat bus for years but it put an undue strain on the few members of staff with D1 licences (primarily people with āgrandfatherā rights) so we bought a 9 seat van last year that has probably had double the amount of use the big one has since.
When we dispose of the large one I think itās unlikely weāll buy another one that requires a D1.
FWIW my school moved from a fleet of lighter 17-seaters with S19 permits to a fleet of āfull sizeā Transit 17-seaters and required everyone to have D1 a couple of years back. The reason being that while the lighter vehicles might have a MAUM of 3.5t, we had no way to verify they were not overloaded making the whole operation illegal and dangerous; whereas itās harder to overload a āfull sizeā minibus with a higher MAUM.
I think that was the right decision (indeed I was consulted in the process and supported it) even though there is the attendant problem of D1 training - although Iām lucky enough to work in a school with the resources to fund our own D1 training rather than queue up for Leconfield.
Schools really need large minibuses given the need to move (if nothing else) sportsā teams around and do so on a regular basis. My school in the 70s had two minibuses which were used almost daily.
The majority of ATC SOVs stand around unused and rusting, so having vehicles that do not have specific licence needs will mean greater usage and if petrol, short journeys do not bring in the problems diesels can have with short journeys.
So basically a Permit 19 is an exemption from the to hold a PSV Operators Licence when providing transport for a charge and under specified conditions provides an exemption for the PCV part of the licence.
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There is much confusion, but as has been said Section 19 is an exemption from having an operators licence ( ie potential for hire & reward), but generally extends to a not for profit operation. But as parents do contribute towards annual camp, it could be argued that there is a charge made for transport. The issue is whether it is for profit or not, but this is not a charge which links to any ACO charity.
The driving licence requirement is not linked directly to the Section 19, but is geared to the size and type of vehicle, but because there are so many grey areas, you might get differing views from the constabularies. If you ask DVSA people a specific question, they will often say they dont know which is the easiest way to avoid being quoted and therefore any implied liability.
But letās face it if you have a D1 there are no worries either way.
Dont forget the minibus is purchased by the Civcom, is insured, taxed and maintained by the Civcom, and remains a Civcom asset, provided for the benefit of the Cadets to further their training. It is a civilian charity asset, as such it will never be a military asset, and therefore an FMT600 would never be required.
However an FMT 600 is required if you have to drive White or Green fleet vehicle, and most servicemen holders will have the full deck of licence qualifications; As MT management is outsourced and those providers (eg Babcock) hold an Operators licence, it is then debatable whether you could then legally drive any service MT vehicle legally on the highway if you dont hold a D1, if the vehicle comes within scope of the O Licence.
It is also then debatable whether the issue strays into other areas of say use of tachographs and Driver Qualification (CPC). As the RAFAC is not part of the military, and use of an MOD would not be for military purposes, there is unlikely to any exemptions, besides which any military deployment seems to require someone to be detailed to manage drivers hours.
The issue has grown since SOVs became popular,but as usual there is no definitive guidance,I suppose a bit like the DVSA inclination towards positive advice, do your best to further the aims and get left up the creak without a paddle (sorry I know we are not Sea Cadets)
although i agree a CFAV is not a military person, the use of tacho is not required when driving military vehicles
While at Leconsfield (yes i did the D1 course) we were told for the purposes and terms of use of the vehicle driven under a FMT600 ālicenceā the vehicle and driver are classes as āmilitaryā and thus exempt from needing a tacho - this includes the use of Phoenix/Clarity vehicles as these are classed as āwhite fleetā FMT600 vehicles for the period of use.
to drive a service vehicle requires a FMT600 that will then be annotated with that vehicleās license requirement to get that vehicle annotated on your FMT600 it must also be on your Driving Licence as a minimum, and typically requires a ācheck driveā with MT.
thus no one will be allowed to drive a service Minibus without holding a D1 - as it is not on their driving licence it will not then be included on their FMT600.
In answer to the topic - no a FMT600 is not required. In addition:
Our Sqn recently acquired a new Transit through the MOD scheme (39% disc on list price) and we applied to HQAC via accounts Form 82 for a Permit 19, having heard nothing, chased it only to be told that they werenāt issuing any more due to an investigation which I believe related to this communication from the DfT, Sharepoint notification followed the next dayā¦
This resulted in us applying directly to the Office of the Traffic Commissioner via this form for our Permits which cost Ā£11 per permit. We applied as it it was a condition from our insurers that a Section 19 was in place (KD Insurance brokers - very competitive and run by a previous member of RAFAC I believe (not sure if I can make recommendations on this forum!)) We received said permits some 3 weeks later.
Interestingly - Accounts Form 82 states weight limits (#7 in the notes section) but the Traffic Commissioners application does not, only seating (up to a maximum of 16 passenger seats before a large bus permit is required) this suggests Accounts Form 82 is out of date. Our SOV is a 17 seat transit and requires the driver to have a D1 licence to operate (weāve put people through Leconfield) in addition to the Permit 19 so that if necessary, running costs can be charged.
The other benefit of a Permit 19 is that it enables vehicles with a āplatedā weight of 3.5 tonnes (and up to 4.25 tonnes if adapted for reduce mobility as other users have mentioned) to be driven on a B cat licence if other conditions are met (held for 2 years, over 21, no direct payment received for driving duty - i.e. you are not employed as a driver). Our Transits plate is at 4.6 tonnes so that element of the Permit 19 benefit is obsolete but we still need one in place as otherwise a full operators licence would technically be required.
The same is true for schools - they technically require a Permit 19 to be in place to operate under the same conditions. The āgreyā area is unhelpful but my interpretation is that all SOVās should have a Permit 19 in place, those plated over 3.5 tonnes (or 4.25 tonnes if adapted for reduce mobility - again a grey area that Minibus Lite fits into) will require the driver to have a D1 licence in place.
Long post - apologies!
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Itās true. If adapted for the carriage of disabled persons you get an extra 750kg allowance on a car license. Doesnāt account for number of seats though:
No, itās essentially a private vehicle which anyone with a D1 can drive (subject to insurance of course).