Alec Quail
Driving Standards Agency, Policy Unit
The Axis Building
112 Upper Parliament Street
Nottingham
NG1 6LP
Thursday 27 June 2013
Dear Mr Quail,
DRIVER CPC CONSULTATION: Changes to the scope of exemptions to Driver Certificate of Professional Competence
I am writing on behalf of the Retail Motor Industry Federation (RMI) with regards to the above consultation.
The Retail Motor Industry Federation (RMI) is the only trade association in the UK that represents franchised car, van & truck dealers (via RMI National Franchised Dealer Association) as well as independent garage workshops (via RMI Independent Garage Association). Resultantly, many of the RMI’s members prepare a vast proportion of heavy goods vehicles for annual testing at both VOSA and ATF facilities.
The RMI and its members strongly support the proposals for revised exemptions outlined in your letter of the 7 June 2013. On many occasions we have communicated, to both VOSA and the Department for Transport, our desire to see such practical and cost effective driver CPC exemptions.
The proposals outlined in this consultation support the RMI’s view that it is not appropriate for technicians and mechanics to be required to hold a driver CPC in order to drive vehicles to and from their periodic roadworthiness tests, given that their main duties are the repair and maintenance of such vehicles. The inclusion under the driver CPC regulations would have been an unnecessary burden on retail garage businesses, a cost that would ultimately be passed on to consumers.
The proposed amendments below will reduce unnecessary cost and burden to both lease/hire businesses and commercial repair and maintenance workshops alike.
· Proposal 1: exempt drivers of a vehicle that is being driven with the permission of the vehicle operator or lessor (as appropriate) and where the following four additional conditions are also met:
o within 50 kilometres of the driver’s base;
o no goods or passengers are carried;
o the vehicle is not being used for ‘hire or reward’; and
o Driving such vehicles is not the driver’s principal activity.
· Proposal 2: exempt vehicles attending a VOSA test centre (including VOSA authorised testing facilities).
We look forward to receiving clarification of these amendments to the driver CPC.
Yours Sincerely,
Stephen Latham
Senior Operations Manager, RMI