Squadron Owned Vehicles

Adult Staff Execs
21

The reasoning behind my comment. All costs are a best guess…:

I’m assuming that any safety inspection will be to the same standard, if not better, than a Class V MOT. A quick google shows a price of about £60 for the MOT, so I would assume that a safety inspection would be a similar price, although it probably costs more, since MOT prices are fixed by the government. I’m guessing you can expect to pay around £100 ph per inspection.

The DVSA guide mentions inspection intervals of around 13 weeks between inspections. From what I can gather, we can extend that period*, so lets say an extra hundred pounds a year (if you can count the MOT as a safety inspection; £200 per year if not).

Ramps and lifts (if Fitted) also need to be inspected every 6 months by a competent person, and weight tested yearly. Lets put that at £100 for inspection and £100 for testing - £300 per year.

Best case - we’re expected to pay an additional £100 per year (£400 if your bus has ramps and lifts)

If we act in accordance with the Permit 19 conditions, it could end up a bit more expensive:

So every 13 weeks (minimum) = £400 extra per year, or £100 for a fresh inspection when you plan to take it out, if it’s laid up for any period of time.

Worse case, we’re looking at extra bills of £400 (£700 if you have ramps fitted) per year, per bus, before the MOT and servicing…

*If we wanted to make a case for extending the safety inspection times, I think it would need someone to become a Duty Holder, and who was prepared to stand up in court and state the reasons why the RAFAC have gone against DVSA guidance.

22

This assumes that nothing is found during an inspection that required work, which then adds P&L.

I imagine this regime is fine if it’s a public bus or MOD owned and serviced, as the former will be attracting fares etc and the second the public sector money pit. But for an ATC squadron with limited funds, adding just the cost of inspections, is already going to start to make it prohibitive, which if then attracts repair/replacement and labour costs, makes it more prohibitive. Then a CWC would need to potentially charge when it gets used, which would open a whole new can of worms, around hire and reward.

If this has been suggested by HQAC without some money chucked into the pot, then you have to wonder whose side are they on.

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23

I don’t think it’s been suggested by HQAC - probably just pointed out that they are apparently not complying with the conditions set by the Traffic Commissioner.

I’d assume that the ACF, SCC, Scouts, local youth club etc will all be in the same boat as us, if they use P19s?

The obvious answer would be to remove the S19 permit, and ensure all of our drivers were D1 drivers - I know what a PITA that would be for some units, but at least there is the option of Leconfield… To be fair, you could use money saved on the mandatory safety checks to privately fund D1 lessons locally…!

24

Maybe the question should be asked of similar groups and go down that route. How do schools operate?

I thought P19 was about whether it’s used for hire and reward, (which seems to be a major confused sticking point judging by some of the stuff on here) but something that carries fewer than 9 removes the D1 requirement. If not there are a lot of young mums driving on school runs in Landies and similar with paid for D1s.

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25

I don’t think that there’s anything stopping you from just getting extra MoTs, so the price won’t be any higher.

26

Permit 19 does more than just remove the requirement for a D1 however it’s also the exemption from having to get a full Public Service Vehicle Licence, getting rid of it could make matters far worse.

The cost of an extra service/MOT each year is nothing compared to the cost of paying for a D1 course.

27

My understanding is that PSV licences are for “for profit” organisations.

You don’t need a PSV licence, or a CPC for non commercial use of a minibus with a D1. In any case, the MOD is exempt from having to apply for one. I’d want to make sure we were legally classed as part of the MOD, though!

As far as I can tell, the only benefit of having a P19 is to allow us to drive a bus without having a D1?

A D1 is around £500 from a commercial provider - depending on whether we have to start paying for safety inspections, and how regularly, it may be the cheaper option in the long run.

28

Fingers crossed that that is the case. Although if it was that easy, surely commercial operators would be MOTing their vehicles on a monthly basis?

I’ve got a feeling most garages would refuse - why would a business accept job for £60, when they could charge more?

29

Unless garages offer a ‘safety check’ for less…

30

I’d like to hope so, but commercial vehicles attract commercial rates. Unless a bulk discount can be arranged nationally, I would expect to pay at least the hourly rate for a skilled commercial vehicle technician. And I doubt that that will be cheaper than an MOT… :pensive:

31

Indeed - I should have mentioned that we align the two - normally MOT first then Service which can rectify any MOT failures before retest.

32

Holding a D1 licence doesn’t negate the need for a P19, so the servicing schedule would still be retained - note it’s “recommended”.

P19 is used to except the need to operate under a Public Service Operator licence and is required in order for Charities/Schools/Youth groups to operate vehicles with up to 16 passenger seats ona “Not for Hire or Reward” basis. ACTO150 (currently being reviewed) previously required all SOV’s to have P19s in place as it was deemed cadets were being transported on a Hire + Reward basis (as they pay a subscription fee to be able to utilise the vehicle). That reasoning is currently being reviewed with the lawyers as far as I’m aware.

D1 category enables vehicles with a greater MAM than 3.5T/(4.25T adapted) to be operated - 17 Seat Transits for the last 10 years or so are good examples of such a vehicle, they used to plate in at 4.1T (unadapted) or 4.6T these days.

I believe that you are correct that effectively all such organisations (ACF, SCC, Scouts, local youth club) should technically operate under the same P19 requirements unless it has been decided that there members are not being transported for Hire and Reward in which case the criteria listed here (which many of non D1 drivers use) automatically apply.

33

A skilled technician can get an MoT done in about half an hour, and that includes checks on emissions, etc that wouldn’t be part of a safety check.

34

Schools should technically hold P19’s for their vehicles as without them they are judged to require to adhere to full PSV requirements. I ascertained that with a call to the DfT, during which I posed certain hypothetical questions. Note - a lot of schools don’t simply as they are unaware of the requirements / it’s pretty hard going to decipher some of this.

The chap on the other end of the line effectively said some educational establishments operate without one, get found to need one, claim ignorance and then operate the permit thereafter as the DfT has a record of them.

The organisation at the attached link provides vehicles for schools and has some useful info available, it is also currently lobbying for all Drivers of such vehicles to hold D1 licences.

35

Aside from mechanical safety, there is also the question of driver competence. One may have driven a car for some time but to hop into a minibus under the eligibility criteria provides little assurance of competence. That is where Driving awareness courses such as MiDAS come into play to familiarise individuals with driving a larger vehicle.

Post 97 D1 licence holders would have had to undergo full D1 training, medical, theory and practical elements and therefore are more competent. Being current is another issue, if it’s been a while since an individual has driving a minibus does that pose additional risk? Out parent MT desires at least annual use of certain vehicle types for their own assurance purposes and will arrange a ride around if it has been a while.

36

The background is that Air Command has raised concerns about the assurance of the safety of RAFAC personnel - to operate MOD vehicles there is a distinct process in place and the question is being asked where isn’t there the same in place for SOV’s.

This has lead to the engagement of the WO, to look at how we govern and assure SOVs to ensure that all Sqns work to the same guidelines using the same processes.

Please do add further thoughts to the thread :slight_smile:

37

The thing that makes it confusing is that HQAC are interpreting the DfT rules to say that by charging Subs you are operating for Hire & Reward yet the DfT guidance on exemptions specifically mentions youth groups as being exempt as long as transport from A to B isn’t their primary function. (It directly states Scouts but I can’t se any difference between them and us as we all charge a membership subscription.

38

The engagement of the WO, will be only to keep someone going in a job and then find he can exactly what he likes to bolster the position and HQAC won’t have the guts to tell him to wind this neck in, in the meantime creating another wad of admin, for squadrons with SOVs when the culture is supposed to be admin reduction. If not already, this will be a FTRS role, for a job that probably needs maximum three days a week, like all of the other FTRS in the ATC.

I’m intrigued as to why Air Command has now taken an interest, after decades of squadrons having vehicles? Like so many things recently I would suspect it’s to find jobs for people, in an RAF that is shrinking and the SqRt of sod all to do with safety, which has become a keyword to generate panic and jobs, where there wasn’t one. If there was a wide history of accidents due to poorly maintained/driven vehicles, fine, but this isn’t something that has ever been a ‘thing’. If it had HQAC would have produced reams of paperwork and so on to cover it.

If they don’t want ATC volunteers (sorry personnel alludes to being an employee) operating MOD vehicles, fine. But then they will need to find people to do it for camps and other times. Put too many things in the way and people vote with their feet and the only people that suffer are cadets. I’ve driven minibuses and cars on camp, but you know what, not having to do it wouldn’t be a hardship.

39

This is a Regular MT WO and SHE has been tasked to look into this for us, her email asking for our Risk Assessment for the Carriage of Cadets (sent to all WEXOs) indicates that she is on a tight timeline.

There is no indication that this will become a permanent posting at HQAC, although if it did it would probably be FTRS

40

The unanswered point is, why has Air Command now taken an interest?
What is their motive for taking an interest? I doubt it is altruistic.
We have seen more interest taken in the ATC by the wider RAF in the last 8/9 years than in the preceding 60, with no real benefit to us as an organisation or as individuals.

If you could think that at the end of this the answer would be “there’s no problems” fine. But I have a greater chance of winning both lotteries this week and getting to the moon by jumping on a trampoline, than this ending with “nothing to see here”.

I imagine this is odds on becoming a dossy FTRS job.