Call for evidence outcome

Heavy vehicle testing review: call for evidence

Updated 26 January 2024

Introduction and background

Vehicle testing

The annual test is an important part of the road safety system for heavy goods vehicles (HGVs) and public service vehicles (PSVs). While similar to the MOT tests for light vehicles, the annual test differs in that:

• there are appropriate changes reflecting the differences in vehicle type and size
• it’s conducted by staff of the Driver and Vehicle Standards Agency (DVSA), which is an agency of the Department for Transport (DfT)
• it supplements regular inspections and maintenance required for most heavy vehicles in connection with operator licensing

The basic delivery model has been in place since its introduction in the 1960s and was established and continued to be done in this way to reflect the safety risk these large vehicles can present. This model also ensures separation between responsibility for operation of the vehicle and the test itself.

However, during the past decade an important part of the delivery model has changed with most tests now delivered through privately owned authorised test facilities (ATFs), rather than government-managed test facilities. ATFs are typically operated by organisations involved in vehicle maintenance, such as dealerships, repair garages or vehicle users (operators or leasers).

Earned recognition

DVSA already has an approach to enable vehicle operators to demonstrate their high levels of compliance, which is called earned recognition (ER).

ER is a voluntary scheme for operators that can demonstrate the highest standards of maintenance systems and low annual test failure rates. Operators within ER can gain some commercial advantage by promoting their ER status to potential customers. DVSA also commits to not routinely stopping ER operator vehicles as part of its roadside enforcement activities.

We have information on the ER scheme and, in particular, the requirements to become an ER operator. Currently, the ER scheme covers around 10% of the commercial vehicle fleet via 115 operators. This is around 25,000 HGVs and 18,000 PSVs.

The heavy vehicle testing review (HVTR)

In March 2021, DfT published the heavy vehicle testing review (HVTR), which looked at how heavy vehicle testing is delivered in Great Britain (GB). Broadly speaking, the review found that the service did function as intended in providing independent assurance that the maintenance systems for both HGV and PSV operators ensure minimum standards are met.

However, it did make a number of recommendations for improvement. The full details of the HVTR and its recommendations are available at Heavy vehicle testing review: final report.

Since the HVTR was published, DfT and DVSA have worked towards implementing the recommendations, including engagement with key trade associations representing customers of the service. Changes implemented include:

• inviting applications of new ATFs (to improve choice for end customers)
• establishing service indicators, which help DVSA and trade bodies to identify how well the service is working and where it can be improved
• focusing on increasing the numbers of testing staff

DVSA has more recently focused on defining the path to improve how the whole process works from an ATF requesting DVSA testing to that being fulfilled. This includes both the process of how requests are made and the digital services behind that.

This call for evidence concerns a part of recommendation one of the HVTR, which is that longer-term service improvement should also include consideration of altered testing intervals for earned recognition operators, with an analysis of the road safety effect and whether this could be implemented practically.

This call for evidence expands on this recommendation by exploring options for whether the cost of testing can be reduced for those operators that demonstrate high levels of compliance while avoiding any negative impact on road safety or air quality.

This call for evidence

Despite the existing benefits of the DVSA ER scheme, there has been considerable feedback from its members and some trade bodies that ER members should have more flexibility in having to demonstrate high standards.

Changes to the annual test – or how it’s delivered – have been suggested, on the basis that this could be done without compromising safety because of the assurance that ER provides. This feedback was a significant part of informing the above recommendation of the HVTR. Further benefits to ER members could then have the effect of increasing take-up and, therefore, be compliant with safety rules.

Vehicle operation and maintenance is complex. If it were found appropriate to change the current approach for ER (or similar) operators, this would need to ensure that the benefit is available across road transport operators including of various sizes. The potential increase in ER applications also needs to be considered should any testing benefit be introduced.

Any change will need to maintain assurance on the safe operation of vehicles. That will mean considering whether the existing ER scheme does this well enough or needs changing, and/or whether other interventions are needed (reflecting that these vehicles are not generally stopped at the roadside).

We are now seeking evidence from all interested parties. The review will consider both potential short and longer-term changes.

We’re asking for the views of individuals, groups and organisations with specific interest in roadworthiness assurance. For example:

• vehicle operators, leasers and other users
• vehicle manufacturers and their dealerships
• organisations or individuals that maintain vehicles
• organisations where testing is done (ATFs)
• trade bodies representing those in the sectors
• motorists and other road users
• road safety organisations

While being a member of the European Union (EU), the UK was bound by EU law, which limited our ability to make changes to roadworthiness testing. Since the UK has left the EU, we have the ability to consider more varied options. However, an important consideration is that many UK-based heavy vehicles travel across Europe and we will need to ensure that any changes do not restrict their movement.

Options for changes to heavy vehicle testing (HGVs and PSVs)

Following consideration of the HVTR recommendation – including engagement with ER operators and trade bodies representing the HGV and PSV sectors – 3 main options were identified for those operators that could demonstrate high levels of compliance. They are:

• to increase the time between tests
• delegated testing
• reduced test content

In addition to these 3 options, DVSA is also considering options that would benefit operators that are simpler to implement, for example, through improved service provision.

The following section aims to briefly describe each of the options and set out benefits and considerations specific to them. These options are not considered to be government proposals. They are suggested options that require more understanding of their potential benefits or disbenefits.

For all options, careful consideration will be given to any potential impacts on road safety or air quality. These are outlined in the Risks section.

Further potential impacts of implementing these changes are discussed under the Other considerations section.

Option 1: Increasing the time between tests for ER operators

This would remove the requirement for ER operators to have their vehicles and trailers tested at the current 12 monthly intervals, extending the period to provide more flexibility. Initial consideration is that every other year (2 yearly) would be an appropriate frequency.

This option would require primary legislation and it could take considerable time to implement.

Vehicle operator benefits

This option is likely to benefit ER operators as there would be less downtime for vehicles needing to attend test appointments. There could also be savings in fuel and personnel time (if vehicles currently need to travel to an ATF that is not at the operator’s premises).

It may also free up DVSA testers who could potentially provide a more flexible service to other ATFs and/or across other services. Equally, there would also be some freeing up of ATF capacity that could improve the service offering as a whole for operators.

Practical considerations

For some operators this may not provide a significant benefit, for example:

• where an annual test is desirable (by, for example, insurers or as part of quality assurance of an outsourced maintenance provider)
• where it is still required annually (for example, as is likely for vehicles travelling outside of the country, further to the Interbus Agreement and the European Conference of Ministers of Transport haulage quota)

While there may be a positive impact on the service that ATFs are able to offer to operators – through a freeing of capacity – there may be a negative impact for some if volumes of work decrease to the extent that the viability of operation changes.

There are also some transitionary considerations with the potential that this change could cause a bi-annual peak and trough cycle, which may be inconvenient both for operators and ATFs.

Consideration will also need to be given to how to handle vehicles changing hands and whether it is right for the long test certificate to remain in those circumstances.

There will also be some practical changes to make to DVSA systems to ensure that vehicles or trailers that are being operated by an in-scope operator can be recognised and the certificate validity period adjusted accordingly. This may be challenging regarding trailers that change hands frequently – and in practical terms – may not have a clear operator.

Option 2: Delegated testing

This would involve allowing ER operators to test their own vehicles and trailers by default retaining existing frequency (annual from year 1). There is a consideration as to the extent to which those conducting the test would need to be able to demonstrate independence from those that are maintaining or repairing the vehicle.

A sub-option of delegated testing (option 2) could extend the delegation to allow the ER Operator to delegate that responsibility further, for example, to nominate a maintenance provider. However, such delegation would only apply to the testing of those vehicles from the ER operators.

This option could be implemented for PSVs via secondary legislation but would likely require primary legislation for HGVs.

Vehicle operator benefits

This option is likely to benefit ER operators as there would be less downtime for vehicles needing to await DVSA test appointments. During stakeholder discussions, this was identified as the key benefit of this option, allowing the timing of the test to be precisely in sync with the maintenance of vehicles.

As well as reduced downtime, there could also be savings in fuel and personnel time – if vehicles currently need to travel to an ATF that is not at the operator premises – as tests could be done elsewhere – although the same equipment as an ATF would be required for the test.

It would also free up DVSA testers which, assuming DVSA funding – and fee levels – allow, could provide a more flexible service to other ATFs and/or across other services.

Practical considerations

If only ER operators are delegated to – and the option does not allow further sub-delegation to maintenance providers – then this option may not provide benefits for those operators where maintenance is outsourced fully or partially.

This could mean, for example, that new vehicles that are maintained by manufacturers’ dealers for 3 years would need to be tested by DVSA, but after that could be tested by the operator. Such a regime could mean that operators do not see the benefits that they hope for and, in fact, could be counter-intuitive, as older vehicles present higher risks.

Should operators be allowed to sub-delegate to their maintenance providers, there will be some practical considerations about how this is done. This could be across multiple providers, mainly outsourced maintenance providers and, for example, dealerships, which may cover newer vehicles.

Practicalities will include considerations on how providers are nominated and whether they are still considered to be acting under the authority of the ER operator. There would also be a need to ensure systems are joined and that it is clear which vehicles could be tested by one of these organisations. This is so it’s obvious which vehicles – and trailers – were being operated by an ER Operator and who had authority to test them.

However, if delegated testing were implemented, consideration will need to be given to independence of testing from maintenance. This could simply be non-structurally, as it is with the car MOT – where there is a requirement within the guide that those testing vehicles should not be the person who has repaired it, or a more formal separation could be required, for example, some element of structural requirement in how the testing is delivered.

If this requirement is made too rigid, then the benefits of this option could be lost, but if too light, public confidence and road safety benefits of testing may be undermined.

There will also need to be consideration of the systems needed and approvals required for someone to be competent and assured as competent for delegated testing. It may be that, while they are not wholly appropriate, the requirements for MOT garages and their managers and testers to be authorised for light-vehicle testing provide some useful insight.

These are set out in detail at Set up an MOT test station: What you need to set up and start testing, but the main things to consider (in particular if ER operators are able to further sub-delegate) could be:

• suitability and repute of organisation
• training and qualification of managers
• training and qualification of testers
• procedures for withdrawal of delegation
• arrangements for ensuring quality of work

These are just examples with feedback required through this call to evidence. It is important to note that while there will be benefits to vehicle operators, there will also be costs in moving to this model.

In implementing any delegated testing option, it is assumed that DVSA will need to maintain the central record of test results as it currently does for heavy and light vehicles. This could be done through recording in a system similar to one used by MOT Testers for light vehicle MOTs.

Consideration will also need to be given to the extra testing capacity that industry will require. It may be that some businesses will have the spare capacity, but in other cases there may be a need to recruit.

As for option 1, there will also be some potential impact on ATFs and the provision for other operators.

Option 3: Reduced test content

This would involve reducing the content of the annual test for ER operators’ vehicles, such as removing some items that are covered in routine inspections or that can be shown to be effectively monitored by in-vehicle systems in the longer term.

However, the vehicle would still be required to be presented for assessment against the aspects that remain within the annual roadworthiness inspection, and existing in-use requirements for vehicle condition would remain across the whole range of items.

This would require some legislative change, which would impact implementation timescales.

Vehicle operator benefits

This option would present ER operators with shortened test times, which has the benefit of reducing vehicle downtime.

There also could be a reduced cost for these tests, albeit that may be minimal.

Practical considerations

Vehicles still need to be presented for annual roadworthiness inspections, so the benefit is likely to be minimal. When operators were asked about the desire for other options, most feedback received was about the arrangement of the test at a time that fits with maintenance, which has less to do with the time it takes to complete the test.

With this option, there is a risk of maintenance inspections and test preparation focusing on less content – although this is, perhaps, less of a risk than the greater freedoms offered in option 1 and option 2.

So far, including in the HVTR, feedback from operators is not that the content of the test itself is problematic. Therefore, it is likely that changes may be minor and would not materially affect test time in the short term.

However, looking ahead at the possibilities that vehicle condition monitoring systems may bring, it could mean the benefits become more significant. For example, an ER operator may operate vehicles that are able to monitor their own braking performance and may choose to make the data from that available to DVSA. If it can be shown that this data is robust and is acted upon, it is possible the vehicle would still require vehicle condition testing during the annual test.

Consideration would need to be given to whether this option would be compliant with other countries’ regimes, which could mean that it would not be an option for some UK-based operators managing vehicles overseas.

Option 4: Improved service provision

Option 1, option 2 and option 3 all propose significant change to the statutory basis of vehicle testing, aimed at reducing the burden on ER operators.

Option 4 proposes that DVSA could focus its service improvement efforts on those operators to minimise the testing burden, which would not require legislative changes. Such an initiative could, for example, include:

• complete or greater guarantee of requested ATF slots for ER operators (and potentially those providers nominated by them)
• full move away from tracking tester utilisation, offset by different fee arrangements
• full flexibility around days or hours worked to match maintenance requirements

Vehicle operator benefits

This option would mean ER operators have increased flexibility to get a test most suited to business need, which in principle should bring many of the benefits of the more complex options.

Practical considerations

While the theory of offering a preferential or better service to ER operators is in many respects a relatively straightforward change, it is heavily dependent upon DVSA being able to recruit testing staff across the country to enable this. DVSA has been increasing staff numbers in recent months, but this may prove challenging going forward.

There may be greater complexity associated with the other options, where ATFs used by ER operators are not their own.

There may also be a need to adjust the minimum fee set in ATF contracts to reflect the lower productivity – tests per assessor per day – that this option could result in. Although, it may be that ER operators using this type of service would still choose to fully utilise DVSA testers through conducting voluntary tests or similar.

The types of service set out in option 4 could:

• provide benefits for all vehicle operators and ATFs
• potentially not be limited to ER operators
• be the types of change that could be expected to follow the HVTR

Risks

Understanding risks

Any change to the vehicle testing regime has the potential to increase risk, particularly if there are fewer tests. It would be critical to ensure the rigour of the test is not compromised and is sufficiently comprehensive, as well as ensuring testers have sufficient independence.

Under the current regime, in-service data of vehicles stopped by DVSA shows that non-compliance rates found at the roadside increase significantly as time passes after the annual test. This indicates that some operators do not wholly meet their operator licence commitments of continuous preventative maintenance, because they may not be doing maintenance, or their providers are not delivering adequate service levels.

In addition, it is common practice for vehicle operators to choose to have one or more levels of pre-MOT prior to the formal annual test (MOT), alongside substantial test preparation. It can be assumed to – partially at least – account for the low fail rates seen in heavy vehicle testing compared to the light vehicle MOT – where vehicles are rarely prepared prior to an MOT.

It is necessary to ensure that any change to the testing regime for ER operators would not change maintenance standards. But there is a risk that it may and that over time standards could slip – even if records suggest they have not. This could be a difficult risk to monitor given DVSA may not have sight of the vehicles at any other time.

It will be essential to ensure that any changes made do not compromise safety and do not mean that one point of the year – which helps bring up safety standards – is assessed in less robust ways.

Views on the extent of this risk, and what can be done to mitigate it – against the options in this call for views – will therefore be critical in determining its value.

In considering road safety risks to changes in testing, it is crucial to account for the extent to which DVSA continues to maintain confidence in ER to maintain assurance that operators are compliant (see potential changes to ER for more).

It should also be noted we may consider any risk based on the number of vehicles within ER that will likely increase in the future, particularly if changes to testing for ER operators are implemented and are seen to be attractive.

Potential changes to ER

If changes were to be made to testing for ER operators, consideration would also need to be given as to whether the scheme itself should be changed to ensure that it is robust enough for the above options to provide sufficient assurance.

As an example, under the current ER scheme operators need to report key performance indicators (KPIs) on a 4-weekly basis. This can either be manually – where they don’t have electronic maintenance systems – or through third-party electronic maintenance system providers. There is a risk of a manipulation of data that shows where inspections have been carried out when they haven’t, where manual systems are used to report KPIs. It may be sensible to consider whether these requirements should be tightened if significant relaxation is planned around vehicle testing.

Furthermore, it has already been noted that:

• under option 1 and option 3, DVSA has less direct oversight of vehicle condition
• under option 2, DVSA has no direct oversight

Given the difficulties in achieving complete separation from the tester and those involved in vehicle maintenance or operation, it could be considered whether ER would need to be more robust than it currently is, for example with a more robust audit of systems. This change could negate some of the burden reduction benefits, so an appropriate balance would need to be identified.

It would be useful to understand views on the current scheme, and if there are changes that should or could be made to make ER more robust and mitigate any risks around roadworthiness. In gathering evidence for this potential change, it will be helpful to understand the benefits it may bring, but also to identify costs and the feasibility of implementation.

It is also possible that it will be necessary to legislate for the formal requirements of ER should changes to testing be made for ER operators (under options 1 to 3 or similar). This is because ER will need to be covered in the legislation which sets out the changes to the test. This could have implications for changing ER in the future, for example, in keeping it flexible to reflect changes in available technology.

Other considerations

Options beyond ER operators

The original reason for this call for evidence was around removing unnecessary burdens for ER operators. However, that is not to say that ER is the only or right way of determining that level of compliance – and by inference competence.

Vehicles operated by ER operators are not immune to failing annual tests – albeit that is less likely than non-ER operators’ vehicles – and equally, there are many highly competent vehicle operators that choose not to participate in ER.

It will be useful to understand if this is viewed as the best or only option and whether there are other ways that assurance of compliance could be determined.

It will also be valuable to understand if ER as it currently operates is seen as a fair and equitable scheme where any compliant vehicle operator – no matter their size or the nature of their business – has a reasonable prospect of being able to attain the necessary standard and join the scheme.

Consideration of operators that leave or are removed from ER

With any consideration of altered testing intervals or delivery models, thought must be given to what happens when an operator leaves or is removed from ER. For example, should the altered test remain valid?

This is important if the operator is removed, as that indicates they have failed to meet the continual demonstration of standards required to be in the scheme.

While the additional benefits any altered testing regime could deliver would need to be established as motivation to ensure they:

• remained in the scheme
• understand a clear process for those leaving the scheme
• know the test status of their vehicles

Identifying vehicles in scope

It is assumed that any change would apply to any vehicle or trailer operated by an ER operator as specified on their licence. While this may be reasonably straightforward for motor vehicles, it may be less easy for trailers as trailer ownership changes far more often and is not specified in the same way. This could mean it’s not possible to provide the same changes to testing for trailers.

In addition, ER does ask that PSVs are specified on the operator licence, but this is not always the case in practice.

It is also necessary to understand how fleet change programmes are likely to affect any of the changes made and if there are practical considerations around this.

Similarly, views on registration mark cherished transfers and how that could affect any approach would be helpful, too. For example, if vehicles change mark, will it still be possible to easily identify if they are in scope of the options considered through vehicle operating licensing and other systems?

It is noted that extensive vehicle and trailer test exemptions were issued during the pandemic, with exemptions of greater length issued to ER operators’ vehicles. In doing that, several administrative challenges were found in identifying the correct vehicles.

While some of these changes were particular to the circumstances created by the pandemic, lessons from this should help mitigate challenges of the necessary administrative changes.

Other impacts

For each completed test, there is a statutory test fee reflecting the cost of the test itself – known as tester time – as well as costs to DVSA of enforcing GB vehicles.

Implementing these changes to the testing regime – options 1 to 3 or similar –would be expected to reduce test fee income for DVSA, because there are fewer tests carried out per year. Or because they are shorter, as in the case of option 3.

While the cost of delivering testing could broadly be reduced in line with any reduction in test volume, this would not be desirable for enforcement. Costs of delivering testing would remain critical as none of these changes will improve the overall state of the fleet.

We will need to consider if structural changes in enforcement funding – or other fee changes – would need to be implemented with changes to testing for ER operators. Examples of new approaches could include:

• a fee for ER
• increases in ER test fees for those still requiring tests

How to respond

The consultation period began on 14 April 2023 and will run until 9 June 2023. Ensure that your response reaches us before the closing date.

To reply to the questions, see the Ways to respond section.

When responding, state whether you are responding as an individual or representing the views of an organisation.

If responding on behalf of a larger organisation, make it clear who the organisation represents and, where applicable, how the views of members were assembled.

If you need alternative formats of this document, such as Braille. large print or audio CD, contact freight@dft.gov.uk.

What happens next

We will aim to publish a summary of responses, including the next steps, within 3 months of the consultation closing on 9 June 2023. Paper copies will be available on request.

If you have questions about his consultation, write to:

Department for Transport
Roadworthiness
3rd Floor, Great Minster House
33 Horseferry Road
London
SW1P 4DR

Alternatively, email freight@dft.gov.uk.

Consultation questions

This list provides an overview of the questions we are asking. To respond to the questions, see the How to respond section.

1. Provide your name and email address.

2. Are you providing a response as an individual or on behalf of an organisation?

3. Are you an individual who maintains vehicles, a motorist or another type of user?

4. What best describes your organisation?

• an ER Vehicle operator
• a non-ER vehicle operator, leaser or other user
• a vehicle manufacturer or dealership
• an organisation or individual that maintains vehicles
• an organisation that provides testing (authorised test facilities)
• a trade body representing those in the sector
• a motorist or other road user
• a road safety organisation
• other type of organisation

5. If you are an operator, do you carry out your own maintenance or use a third-party maintenance provider? Or both?

6. Do you have your own authorised test facility (ATF)?

7. In your view, is the earned recognition scheme a fair system?

8. How can the earned recognition scheme be improved to ensure that it is a fair system, in your view?

Proposals

We are consulting on making potential improvements to heavy vehicle testing by altering the earned recognition (ER) scheme.

We have suggested 4 ways this scheme could be altered and are seeking your views on these options offered as well as any alternative approaches you may prefer to see implemented.

These options are:

• option 1: increasing time between tests
• option 2: implement delegated testing
• option 3: reduced test content
• option 4: improving service provision

Options for changes to heavy vehicle testing

9. Do you think that changes should be made to the testing regime for ER operators?

10. Why do you disagree with changes to the testing regime?

11. Why do you agree with changes to the testing regime?

12. If you are unsure about the options for changes to heavy vehicles testing, the remainder of this survey is about the considerations for implementation of these changes. Would you like to continue answering questions?

Option 1: Increase the time between tests for earned recognition

This would remove the requirement for ER operators to have their vehicles and trailers tested at the current 12 monthly intervals, extending the period to provide more flexibility. Initial consideration is that every other year (2 yearly) would be an appropriate frequency.

13. What advantages do you believe increasing the time between tests for ER would bring to an operator?

14. What disadvantages do you believe increasing the time between tests for ER would bring to an operator?

15. What impact do you think increasing the time between tests would have on authorised testing facility services (ATFs)?

16. What impact do you think increasing the time between tests would have to non-ER operators?

17. Are there other areas that may have an impact on increasing the time between tests?

18. Do you believe there are risks to road safety if increasing the time between tests option is implemented?

19. What are the risks of increasing the time between tests and how could these be mitigated?

Option 1: Increase the time between tests for Earned Recognition operators

20. What are the practical considerations when increasing the time between tests for vehicles changing operators?

21. What are the practical considerations when increasing the time between tests for correct recognition of vehicles and trailers?

22. What are the practical considerations when increasing the time between tests for transitionary measures?

23. What are the practical considerations when increasing the time between tests for other areas not covered?

24. How often do you believe tests should be retained?

25. What, if anything, would you like to change in option 1, which increases the time between tests for ER operators?

Option 2: Delegated testing for ER operators

We are proposing that this option would retain the existing year frequency testing requirement. There is a consideration as to the extent to which those conducting the tests would need to be able to demonstrate independence from those that are maintaining or repairing the vehicle, and how this would be archived.

26. In your view, should ER operators be able to sub-delegate testing to their own maintenance providers? If you said yes, why do you think that?

27. How should ER operators demonstrate independence of testing from vehicle maintenance and operation?

28. What advantages do you believe delegated testing would bring to an operator?

29. What disadvantages do you believe delegated testing would bring to an operator?

30. What impact do you think delegated testing would have on ATFs?

31. What impact do you think delegated testing would have on non-ER operators?

32. What impact do you think delegated testing would have on other areas?

33. Do you believe there are risks to road safety if delegated testing is implemented?

34. What are the risks of delegated testing and how could they be mitigated?

35. What are the practical considerations when delegating testing for approvals required for a person to be deemed competent for testing vehicles?

36. What are the practical considerations when delegating testing for approvals required for a person to be deemed competent for transitionary measures?

37. What are the practical considerations when delegating testing for approvals required for a person to be deemed competent for other practical considerations not covered?

38. Do you believe there will be challenges finding the additional tester capacity within the industry necessary to implement our delegated testing proposal?

39. What challenges do you think the additional tester capacity pose and what do you think the impact will be?

40. What would you like to change in option 2 for the delegated testing for ER operators?

Option 3: Reduced test content

Reduced test content would involve reducing the content of the annual test for ER operators’ vehicles. For example, by removing some of the items currently required in routine inspections or, in the longer term, that can be shown to be effectively monitored by in-vehicle systems.

The vehicle would still be required to be presented for assessment against any aspects that remain within the annual roadworthiness inspection and existing in-use requirements for vehicle condition would also remain across the whole range of items.

41. What advantages do you believe reduced test content would bring to an operator?

42. What disadvantages do you believe reduced test content would bring to an operator?

43. What impact do you think reduced test content would have on AFTs?

44. What impact do you think reduced test content would have on non-ER operators?

45. What impact do you think reduced test content would have on other areas?

46. Do you believe there are risks to road safety if reduced test content is implemented?

47. What are the risks of implementing reduced test content? How could they be mitigated?

48. What are the practical considerations of reduced test content for operation of vehicles abroad (compliance with other countries’ regulations)?

49. What are the practical considerations of reduced test content for operation of transitionary measures?

50. What are the practical considerations of reduced test content for operation of other practical considerations not covered?

51. What, if anything, would you like to change in option 3 in the streamlined test for ER operators?

Option 4: Improved service provision for ER operators

Improved service provision proposes that Driver and Vehicle Standards Agency (DVSA) focuses its service improvement efforts on ER operators to minimise other testing burdens beyond those mentioned in our other proposed options, and which would not require legislative changes to implement. Such initiatives could, for example, include:

• complete or greater guarantee of requested ATF slots for ER operators (and potentially those providers nominated by them)

• full move away from tracking tester utilisation, offset by different fee arrangements

• full flexibility around days or hours worked to match maintenance requirements

52. What advantages do you believe improved service provision would bring to an operator?

53. What disadvantages do you believe improved service provision would bring to an operator?

54.What impact do you think improved service provision would have on ATFs?

55. What impact do you think improved service provision would have on non-ER operators?

56. What impact do you think improved service provision would have on other areas?

57. Do you believe there are risks to road safety if improved service provision is implemented?

58. What are the road safety risks of improved service provision and how could they be mitigated?

59. What are the practical considerations of improved service provision for DVSA staffing levels?

60.What are the practical considerations of improved service provision for the potential adjustments to minimum fee levels currently set in ATF contracts?

61. What are the practical considerations of improved service provision for transitionary measures?

62. What are the practical considerations of improved service provision for other practical considerations not covered?

63. In your view, the greatest guarantee of requested AFT slots should apply to all operators or ER operators only? Outline your reasons why.

64. In your view, fully moving away from tracking tester ‘utilisation’, offset by different fee arrangements should apply to all operators or ER operators only? Outline your reasons why.

65. In your view, full flexibility around days and hours worked to match maintenance requirements should apply to all operators or ER operators only? Outline your reasons why.

66. What, if anything, would you like to change in option 4 the improved service provision?

67. Would you like any other additional changes to be made to the ER scheme?

68. Are there any other additional changes you’d like to make? Why?

Option preference

We are asking not only about the options you would like to have implemented but also about the order in which those options should be implemented (as it may be different from our own) and why.

Our options are:

• option 1: increase the time between tests for ER operators
• option 2: delegated testing for ER operators
• option 3: reduced test content for ER operators
• option 4: improved service provision for ER operators

69. With regards to the implementation of our 4 options, how many would you prefer to implement?

70. Which option would you like to be implemented?

71. If you selected 2 options, which 2 of the 4 options would you like to be implemented? You can outline which order you’d prefer your choice of options to be implemented.

72. If you selected 3 options, which 3 of the 4 options would you like to be implemented? You can outline which order you’d prefer your choice of options to be implemented.

73. If you selected 4 options, which order would you prefer them to be implemented in? The same as our proposed order or another order? You can outline which order you’d prefer your choice of options to be implemented.

Risks

74. In your view, are there risks to air quality for any of the options?

75. Which options do you think present air quality risks? You can outline what those risks are.

76. Are there any other risks we need to consider? If yes, what are the other risks we need to consider?

77. In your view, what changes need to be made to ensure public confidence in road safety controls if any of our options for vehicle testing were implemented for non-ER operators?

78. In your view, what changes need to be made to ensure public confidence in road safety controls if any of our options for vehicle testing were implemented for ER operators?

KPIs

We currently collect as part of the application for the ER scheme require applicants to supply key performance indicators (KPIs) on the areas of maintenance and driving activity.

79. We’d like to know your views on whether KPIs should only be sent electronically to us.

80. Do you agree or disagree that ER KPI data should only be supplied to us electronically?

81. Would you support any of our proposed option alterations being applied beyond ER operators to all heavy goods vehicles and public service vehicle operators instead?

Application beyond ER operators

82. Would you support all of the options being applied to all heavy goods vehicles and public service vehicle operators?

83. Would you support some of the options being applied to all heavy goods vehicles and public service vehicle operators?

Options to be implemented for all heavy goods vehicles and public service vehicle operators

84. Which option would you support to be applied to all heavy goods vehicles and public service operators? Option 1, 2, 3 or 4. Select the most appropriate option.

Changes applied

Driver and Vehicle Standards Agency (DVSA) currently commits to not routinely stopping ER operator vehicles as part of its roadside enforcement activities.

We will need to consider if a structural change in how enforcement is funded, or other fee changes, would need to be implemented with any change to testing for ER operators. Examples of new approaches could include a fee for ER or increases in test fees for those that still need tests.

85. How would you expect DVSA to determine compliance if any of these options were implemented?

Other considerations

86. In your view what barriers, if any, exist for smaller operators that may prevent them from joining the ER scheme?

87. What, if any, views do you have on the practical arrangements relating to these changes to testing for operators leaving the ER scheme?

88. What, if any, views do you have on the practical arrangements relating to these changes to testing for operators being removed from the ER scheme?

89. What views, if any, do you have on the practicalities of identifying vehicles that would be in scope of our changes to the heavy vehicle test?

90. Do you think different arrangements need to be made to ensure trailers are identified separately from heavy goods vehicles?

91. If you selected yes, why do you think different arrangements will be needed to ensure trailers are identified separately from heavy goods vehicles?

Funding for DVSA enforcement

Some of these options, if implemented, could affect funding for DVSA enforcement.

Currently, ER membership does not have an application fee amount.

92. How, in your view, do you think the loss of funding for DVSA enforcement might be mitigated?

93. Do you believe there should be an application fee for ER membership?

Fees

94. Do you believe there should be a fee charged for ER memberships? How much should the fee be (in GBP £)? Under £50, between £50 and £100, between £100 and £150 or more than £150?

Final comments

95. Do you have any further comments?

Freedom of information

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want the information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory code of practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this, it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances.

An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the department.

The department will process your personal data in accordance with the Data Protection Act (DPA) and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

Data protection

In this call for evidence, we ask for your name and email address, in case we need to contact you about your responses. You do not have to give us this personal information. but if you do provide it, we will use it only for the purpose of asking follow-up questions.

For organisations, we are in addition asking for a brief description of your organisation to better understand the relationship between your organisation’s work and the topic.

This call for evidence and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, the department will, under data protection law, be the controller for this information.

If responding to this call for evidence online, your personal data will be processed on behalf of the department by SmartSurvey, which runs the survey collection software.

Your name and email address will not be shared with any other third parties, but your responses and evidence may be shared with a third party for the purposes of analysis.

We will not use your name or other personal details that could identify you when we report the results of the call for evidence. Any information you provide will be kept securely and destroyed within 12 months of the closing date. Any information provided through the online questionnaire will be moved to our internal systems within 2 months of the call for evidence period end date.

Consultation principles

This consultation is being conducted in line with the government’s consultation principles.

If you have any comments about the consultation process, contact:

Consultation Co-ordinator
Department for Transport
Zone 1/29 Great Minster House
London
SW1P 4DR

Email: consultation@dft.gsi.gov.uk