The three strands surrounding this issue are therefore:
Relevant and application of Permit 19 - DLS enquiry lodged WRT Hire or Reward status.
Mechanical Safety / Maintenance schedules of SOV’s
Qualification and competency of Drivers - which licencing requirements needed for which types of vehicle - how do decide if our people are “competent”.
The .gov guidance seems to indicate that the frequency is advisory, but proper safety checks must still be carried out.
As a permit holder you’re responsible for ensuring the safe operation of your vehicles, within the legal requirements and under a valid permit. You should ensure are that:
•Your vehicles satisfy the appropriate construction and use requirements and are maintained in a safe and roadworthy condition
Is the Sqn the holder, or is it HQAC? If it’s HQAC, it is their legal responsibility to ensure that every SOV is roadworthy. It then becomes more about HQACs tolerance of risk, than practical advice to SOV operators.
You just have to look at what is happening elsewhere to get an idea of their risk tolerance - 2FTS banning gliding outside of the organisation, unless ludicrous amounts of hoops are jumped through, for example.
My gut feeling is that HQAC will not tolerate any risk that any RAFAC SOVs will be involved in an accident where roadworthiness is a contributing factor. The only way to prevent that is to prescribe a mandatory regime of regular safety checks. Given that the DVSA have already issued clear guidance on levels expected of commercial operators, I would expect a similar regime, although I remain hopefully it will be more relaxed.
I think @Teflon comments regarding the hiring in of vehicles may prove to be the easiest way forward, but I would still expect extra admin every time a hire is made - in the same way we ask for copies of public liability certificates for PIPEs. I would expect to have to have to prove that the vehicle is insured, taxed, and roadworthy before we allow cadets to travel in a hire bus.
SOVs are going to become just moretrouble than they are worth in the future. What HQac need to do is negoiate a deal with the big private hire companies such as Enterprise and Hertz etc and all the indemnities will be there.
Agreed - I’ve assumed the permit holder to be the Sqn as that’s what’s been printed on the Permit itself - hence the checks outlined earlier in the thread that we conduct to provide some assurance of that.
Parent units have been engaged to see what could be offered, MT involvement in the maintenance side of things would be great financially but doesn’t reduce the burden of having to take a vehicle to a place for a time using up annual leave etc.
Regarding competency, a strand is being considered using suitably qualified individuals in the CFAV cadre to provide familiarisation training (once authorised) to new drivers - naturally provision of such an idea is dependent on there being suitably qualified CFAV’s in the area who are willing to act in this fashion.
Again hire seems viable - but personally prefer the ease of retaining an SOV that I could delay the sweep out till the next parade night and not incur additional hire charges - it also would dependent on proximity to hire depot as to how much effort returning the thing after use would be. Pretty sure the hire of any minibus requires a D1 licence (much like MT) which would knock out a good number of our drivers. However if grief of impending policy is greater than grief of hire operations then the latter will win out.
Unless (as Bob mentions) some large scale commercial engagement / central provision is going to be set up to ensure that vehicles are available for cadet events (again core vs non core activities will have to be considered here) - taking too hard a line on this topic will result in degradation of the cadet experience which is most unpalatable at this time.
We’ve hired minibuses and never been asked for anything. Mind you I’ve not made a thing of it.
One of the potential problems is, whenever mass travel is required, if it becomes another task, as you highlight reference gliding, it stops happening or happening as much as it did. People may not like this sentiment BUT as soon as something is made more arduous the default is not bother, which is a not restricted to the ATC.
The whole erring on the side of caution has probably caused more reductions in people doing things than anything else in the last 20 years.
So this thread got me thinking, as my perception of the Permit 19 is that it allowed me as a driver over 21 to drive the minibus without being qualified to do so (D1), having done some digging, this appears to be a common misconception.
I’ve found that the detail in Minibus Driving Licence Information explains it in the best detail.
The interesting point is that regardless of the licence held a Section 19 Permit is required to allow us as the organisation to make a charge for the use of the bus without a Passenger Carrying Vehicle.
It should be noted however, that volunteer minibus drivers who passed their car driving test after 1 January 1997 are restricted to drive minibuses which weigh no more that 3500kg gross vehicle weight. Section 19 permits have a life span of 5 years and must be renewed accordingly.
If no charge is made for the use of the bus at all, no permit is required. However, the word ‘charge’ covers more than just the payment of a fare. Any payment which directly or indirectly gives a person a right to be carried on the vehicle (the legal term for this is ‘Hire or Reward’) would require the operator to hold either a Section 19 Permit or PSV Operator’s Licence.
My bold.
To be carried on the vehicle, and a common insurance requirement, people need to be a member of the the organisation (RAFAC) for which all cadets pay a subscription, which based on the above would require a Section 19 Permit for all vehicles over 9 seats… even an MT Minibus or hire vehicle, luckily the permit is for the driving organisation, and not the vehicle
does that then imply that as an organisation we need only one permit held at HQAC and private SOV vehicles need not individual permits?
As I understand it, the vehicle needs to have a P19 disk displayed at all times. The disks can be moved from vehicle to vehicle, however.
Each vehicle needs to display the permit when it’s being driven, and until the issuing of Permit 19s was suspended by HQAC, they were the issuing body, while each squadron was recorded as an individual organisation…
Which brings into question use of the vehicle by another squadron, or by the wing for sport, as these users are NOT members of the organisation that holds the permit…
Perhaps each WHQ should have ~40 permits, enough for each squadron and then some so that the Wing becomes the organisation …
you cant as the registration number is on the permit for the vehicle
It can’t be given it’s not requested data on the Application for a standard or large bus permit you also wouldn’t then be able to use it on a hire vehicle…
thats a new form (May 18) they must of done away with the registration requirement as
it is completed on our permit
given this update coincides with HQAC pausing the issuing I wonder if there is an issue
This is my understanding as well - the vehicle must have a relevant permit displayed but as it is organisation specific it can be moved between vehicles.
The permits received we received form the Traffic commissioner have the Sqn’s name only. Use of permit in another squadron’s vehicle should be allowed as long as all other conditions are met as the vehicle is being supplied for the Sqn’s use. I tend to use Gov.Uk’s MOT + RFL Checker before borrowing another Sqn’s vehicle to ensure the minimum is in place - Insurance can be checked via askMID
Well that is really concerning for me…
We got ours via HQAC and it is clearly required to enter the registration number… so my worry is:
Is there different types of permits being issued and different requirements on the permit?
What actually constitutes a permit19 disc?
For those who wish to know about the Permit 19 scheme here are the FACTS as given to me by the DVLA this morning after our recent problems. Let me say my head is HURTING after this saga but we got a definitive answer from the DVLA legal side.
For driving a Minibus there are 2 basic categories of carriage
We as a youth group come under section 2- Commercial
Comercial vehicle drivers should be PSV drivers HOWEVER the permit 19 wavers this requirement if it meets the criteria. the criteria revolves around Hire and Reward and payment to the driver.
I was questioned and the information I gave they made the conclusion that even as a uniformed officer receiving pay, I am NOT employed as a driver and the cadets are not paying special membership or paying money for use of the minibus that would constitute hire and reward. There for we meet the criteria for receiving a permit 19.
the answer they felt I would still receive the same pay (and rate of) there for it was not an issue of paid employment as a driver
So the Permit 19 scheme, as I said is there to waiver the PSV License to carry under commercial requirements. the DVLA guidance is as follows;
If you wish to drive a Minibus with 16 seats or more, the driver has to have a D1 license and the Vehicle a Permit 19
If you have a standard B1 license then you can drive a minibus 3500Kg or under and no more that 15 seats. Again a Permit 19 is required.
Please note that BOTH vehicles require a Permit 19, without it the driver should be a PSV Licensed driver.
That is the guidance we received today from the DVLA Legal team,
I also asked regarding my concern about registration etc on the permits, but they said they had been alterations over the years and we may just have different versions but as long as it was in date then there is no problem.
I am inferring from this that even MOD/whitefleet/Calamity vehicles would require a P19 as the driver is likely to just hold a D1, not a PSV.
I would expect that in the same way the MOD self insure and therefore do not require to insure each vehicle, they are exempt from these rules, as they are from working time directive etc.
The exemption, would also remove the B1 exemption, hence the requirement for all to be D1…
But we all know about assumptions…
Just had this email? What do you think the game is? Our Minibus? Squadron Minibus ? where do think this is going?
Please can you let me know by return if you have a Squadron Mini Bus and if so how many. Please note it is most important that NIL RETUTRNS are reported. I have to gjve a 100 percent return across 3 wings to HQAC by Friday 22nd so please respond promptly stating which wing you belong t
