Rotherhithe Tunnel

[Amarillo]

I only once cycled over Tower Bridge I did not like it. There seams to be a dip in the road near the kerb, also once on it no way off as barrier between road and pavement. I now push my bike on the pavement. Otherwise I like cycling in London. I feel saver than in Suffolk, other than in forest areas. Country roads have people driving fast and often passing is difficult. In London the ability to use dedicated ways and, river and canal side and parks is great. One of the reasons I brought a California was so I could take my bike to places I can cycle. I carry my bike inside, and I also have somewhere to change in to my cycle shorts.

Cycling in London is a real eye-opener. You get a whole different perspective of the city from a canal tow path, above a sewer or through one of the numerous parks. The Thames binds all the motor traffic free routes together, then south of the Thames the rivers Ravensbourne and and the Waterlink Way meanders south through Lewisham and Bromley; the River Wandle and the Wandle Way through Wandsworth and Croydon. To the north the River Lee slices through east London and into the Chilterns; the River Brent through Brent, Barnet, Ealing and Hounslow. All these rivers have cycleable motor traffic free routes either next to them or close by.

Perhaps one day we should have a Cali cycling meet at Abbey Wood.

 

[steven239]

Hi all, totally new but thought it might be worth updating this for any other readers.

I just received a Rotherhithe Tunnel fine of £130. The contravention code is "52G; failing to comply with prohibition on certain types of vehicle goods vehicles (sic) exceeding max gross weight indicated."

I have a SWB T28 that has been converted to a camper. The V5 describes 'Body Type' as 'Motor Caravan'; 'Taxation Class' as 'Light Goods Vehicle'; 'Revenue Weight' as '2800kg Gross', 'Mass in Service' as '1919' and 'Number of seats including driver' as '6'.

I'll make a representation based on the argument that I believed from the signage that it didn't include a SWB motorhome that falls within the height and width restrictions and also weight restriction based on it not being able to carry a commercial payload and the mass in service being compliant.

I'll also argue that the signage is unclear as the graphic used is a Luton style van which represents commercial goods vehicles. http://lruc.content.tfl.gov.uk/roth...-restriction-warnings-signage-location-v2.pdf

I'll see what they say. Any one had a similar unwelcome letter from TfL?

 

[WelshGas]

Hi all, totally new but thought it might be worth updating this for any other readers.

I just received a Rotherhithe Tunnel fine of £130. The contravention code is "52G; failing to comply with prohibition on certain types of vehicle goods vehicles (sic) exceeding max gross weight indicated."

I have a SWB T28 that has been converted to a camper. The V5 describes 'Body Type' as 'Motor Caravan'; 'Taxation Class' as 'Light Goods Vehicle'; 'Revenue Weight' as '2800kg Gross', 'Mass in Service' as '1919' and 'Number of seats including driver' as '6'.

I'll make a representation based on the argument that I believed from the signage that it didn't include a SWB motorhome that falls within the height and width restrictions and also weight restriction based on it not being able to carry a commercial payload and the mass in service being compliant.

I'll also argue that the signage is unclear as the graphic used is a Luton style van which represents commercial goods vehicles. http://lruc.content.tfl.gov.uk/roth...-restriction-warnings-signage-location-v2.pdf

I'll see what they say. Any one had a similar unwelcome letter from TfL?

This may be where the problem lies.
On your V5 there should be, I believe , Vehicle Type Approval N1, that means Commercial, whereas the California is M1, Diesel Car.

I don’t think the APNR cameras take account of Body Type, just Vehicle Type Approval.

I’m not sure how they deal with ‘Body Type ‘. You probably have to Appeal .

 

[Amarillo]

Hi all, totally new but thought it might be worth updating this for any other readers.

I just received a Rotherhithe Tunnel fine of £130. The contravention code is "52G; failing to comply with prohibition on certain types of vehicle goods vehicles (sic) exceeding max gross weight indicated."

I have a SWB T28 that has been converted to a camper. The V5 describes 'Body Type' as 'Motor Caravan'; 'Taxation Class' as 'Light Goods Vehicle'; 'Revenue Weight' as '2800kg Gross', 'Mass in Service' as '1919' and 'Number of seats including driver' as '6'.

I'll make a representation based on the argument that I believed from the signage that it didn't include a SWB motorhome that falls within the height and width restrictions and also weight restriction based on it not being able to carry a commercial payload and the mass in service being compliant.

I'll also argue that the signage is unclear as the graphic used is a Luton style van which represents commercial goods vehicles. http://lruc.content.tfl.gov.uk/roth...-restriction-warnings-signage-location-v2.pdf

I'll see what they say. Any one had a similar unwelcome letter from TfL?

I think you have a case to appeal - but your difficulty is the taxation class as a light goods vehicle suggests you are a commercial vehicle with a gross weight of over 2 tonnes.

Make the point that since the conversion you are no different in use from a VW California which would be registered as a passenger car, and your registration as a light goods vehicle is an anomaly.

 

[Collieboy]

One our works guys just got done both ways with a berlingo van.
It unladen weight is approx 1.7 tonnes so they must be using auto numberplate recognition to determine vehicle weight and working it on fully laden weight
An expensive days work! for some poor

 

[steven239]

Thanks all. Some good points that I'll include in my representation. I'll update this thread with Tfl's decision..

 

[steven239]

Hi all, just writing the representation now and I wonder if one of you could help me identify how the California differs from my T5 on the V5. I'll list the relevant points of my T5 that are found in section 4 of the V5 and if one of you is able to list the same for your California I would be extremely grateful.
D1. Make: VOLKSWAGEN
D2. Type: 7J0
D3. Model: TRANSPORTER T28 STARTLINE TDI
D5. Body Type: MOTOR CARAVAN
[X] Taxation Class: LIGHT GOODS VEHICLE
[Y] Revenue Weight: 2800KG GROSS
S.1 Number of seats, including driver: 6
J Vehicle category: N1
F1 Max. permissable mass (exc. m/c): 2800
G Mass in service: 1919

My argument will be that as the conversion is professionally fixed (I'll include conversion receipts as well as photos) and my T5 no longer has the ability to carry a load up to the max of 2800kg then it shouldn't be considered as a 'light goods vehicle' and it's weight should be considered just as a car (California) would with its kerb weight which I assume is the 'Mass in Service' of 1919 kg above, which falls below Tfl's Rotherhithe restrictions:

"
Weight restriction
Goods vehicles can't use Rotherhithe Tunnel if they have a gross vehicle weight of more than 2 tonnes.
Gross vehicle weight is the maximum weight that the vehicle is legally permitted to be loaded to. It is also called the Maximum Authorised Mass (MAM) or permissible maximum weight.

"

 

[WelshGas]

Hi all, just writing the representation now and I wonder if one of you could help me identify how the California differs from my T5 on the V5. I'll list the relevant points of my T5 that are found in section 4 of the V5 and if one of you is able to list the same for your California I would be extremely grateful.
D1. Make: VOLKSWAGEN
D2. Type: 7J0
D3. Model: TRANSPORTER T28 STARTLINE TDI
D5. Body Type: MOTOR CARAVAN
[X] Taxation Class: LIGHT GOODS VEHICLE
[Y] Revenue Weight: 2800KG GROSS
S.1 Number of seats, including driver: 6
J Vehicle category: N1
F1 Max. permissable mass (exc. m/c): 2800
G Mass in service: 1919

My argument will be that as the conversion is professionally fixed (I'll include conversion receipts as well as photos) and my T5 no longer has the ability to carry a load up to the max of 2800kg then it shouldn't be considered as a 'light goods vehicle' and it's weight should be considered just as a car (California) would with its kerb weight which I assume is the 'Mass in Service' of 1919 kg above, which falls below Tfl's Rotherhithe restrictions:

"
Weight restriction
Goods vehicles can't use Rotherhithe Tunnel if they have a gross vehicle weight of more than 2 tonnes.
Gross vehicle weight is the maximum weight that the vehicle is legally permitted to be loaded to. It is also called the Maximum Authorised Mass (MAM) or permissible maximum weight.

"

From DVLA. My California.

 

[WelshGas]

Hi all, just writing the representation now and I wonder if one of you could help me identify how the California differs from my T5 on the V5. I'll list the relevant points of my T5 that are found in section 4 of the V5 and if one of you is able to list the same for your California I would be extremely grateful.
D1. Make: VOLKSWAGEN
D2. Type: 7J0
D3. Model: TRANSPORTER T28 STARTLINE TDI
D5. Body Type: MOTOR CARAVAN
[X] Taxation Class: LIGHT GOODS VEHICLE
[Y] Revenue Weight: 2800KG GROSS
S.1 Number of seats, including driver: 6
J Vehicle category: N1
F1 Max. permissable mass (exc. m/c): 2800
G Mass in service: 1919

My argument will be that as the conversion is professionally fixed (I'll include conversion receipts as well as photos) and my T5 no longer has the ability to carry a load up to the max of 2800kg then it shouldn't be considered as a 'light goods vehicle' and it's weight should be considered just as a car (California) would with its kerb weight which I assume is the 'Mass in Service' of 1919 kg above, which falls below Tfl's Rotherhithe restrictions:

"
Weight restriction
Goods vehicles can't use Rotherhithe Tunnel if they have a gross vehicle weight of more than 2 tonnes.
Gross vehicle weight is the maximum weight that the vehicle is legally permitted to be loaded to. It is also called the Maximum Authorised Mass (MAM) or permissible maximum weight.

"

I would think you will be successful as the DVLA has accepted your Body Type change to Motor Caravan.

Apart from the VW California and the Mercedes Marco Polo virtually ALL other Campervan/Motorhome Vehicles are based on N1 Commercial Vehicles of one sort of another, whether self or professionally converted on new or 2nd hand Vehicles.
The only other exception to this is with some people carriers such as the Caravelle or similar.

 

[Amarillo]

My argument will be that as the conversion is professionally fixed (I'll include conversion receipts as well as photos) and my T5 no longer has the ability to carry a load up to the max of 2800kg then it shouldn't be considered as a 'light goods vehicle' and it's weight should be considered just as a car (California) would with its kerb weight which I assume is the 'Mass in Service' of 1919 kg above, which falls below Tfl's Rotherhithe restrictions:

I think that is the wrong argument. The weights are irrelevant as they apply to commercial vehicles.

Your argument should be that the body type needs to be considered in determining if your vehicle is a light goods vehicle, and that TfL have evidently failed to consider this. Provide copies of the conversion documents but make it clear that this is supplementary evidence only as the V5 clearly shows your conversion to be a motorhome not a light goods vehicle, and that you had gone to considerable effort to have the V5 changed to prevent the sort of misunderstanding TfL appear to have.

The 2800Kg maximum weight for your conversion still applies, but it doesn’t exceed the Rotherhithe Tunnel weight limit for non-commercial vehicles which is still 10 tonnes.

You still have the obstacle that the taxation class of your vehicle is "light goods vehicle", and TfL might argue that it is this which defines your van, not the body type. For that reason you might want to include an alternative reason for TfL to allow your representations: their signage with a Luton type van symbol made it unclear that light goods vehicles were included in the restrictions. This is a weak argument, and your hope in including this is that TfL would write back to say that while the penalty was correctly applied, they accept you were confused by their signage and in this one instance were cancelling the penalty.

 

[steven239]

That's interesting then that the revenue weight of the California is actually greater than my T5. I take your point, however, that foremost Tfl will focus more on the fact that it is an N1 classification. Rather hypocritical of them really as the main premise of the restrictions is to protect the ageing structure of the tunnel from excessive weights, but I appreciate that it is hard to enforce any other way. Having said that, however, I will keep my letter polite and make my point that the Body Type should be considered. I think I'm right in saying that it is impossible to change the Type from N1 to M1; I'll double check with a call to the DVLA tomorrow morning before I send the representation. If I'm correct then I have little choice but to rely on them checking the Body Type.

 

[WelshGas]

That's interesting then that the revenue weight of the California is actually greater than my T5. I take your point, however, that foremost Tfl will focus more on the fact that it is an N1 classification. Rather hypocritical of them really as the main premise of the restrictions is to protect the ageing structure of the tunnel from excessive weights, but I appreciate that it is hard to enforce any other way. Having said that, however, I will keep my letter polite and make my point that the Body Type should be considered. I think I'm right in saying that it is impossible to change the Type from N1 to M1; I'll double check with a call to the DVLA tomorrow morning before I send the representation. If I'm correct then I have little choice but to rely on them checking the Body Type.

The N1 or M1 Classification cannot be changed, only the Body Type. Best of Luck.
Let us know how you get on.

 

[steven239]

Thanks Welshgas. Yes I thought this was the case. But I'll have a chat tomorrow anyway just to see if they can make any suggestions that we may have missed. By the way, I also posed this question in the fantastic resource over at Pepipoo. Here's the link if anyone is interested in reading some interesting points and seeing my offending T5.

 

[steven239]

http://forums.pepipoo.com/index.php?showtopic=127470&st=0&gopid=1481110&#entry1481110

 

[Amarillo]

I think I'm right in saying that it is impossible to change the Type from N1 to M1

Yes, you are right, and this is significant in your appeal. To determine what type of vehicle you have TfL should have looked at your body type, and it is a legal requirement to have this changed on your V5 after a conversion to a campervan; in contrast the N1, M1 classification cannot be changed and therefore cannot be relied on to define the vehicle as it is now.

 

[Amarillo]

http://forums.pepipoo.com/index.php?showtopic=127470&st=0&gopid=1481110&#entry1481110

A significant point given is that changing the V5 body type to motorcaravan means you are subject to car speed limits; similarly car restrictions on use of the Rotherhithe tunnel apply, not goods vehicle restrictions.

 

[steven239]

I have just got off the phone with the DVLA. He confirmed that the Vehicle Category (N1 to M1) cannot be changed. The Taxation Class (Light Goods Vehicle) can be changed in some circumstances but not in the case of a camper conversion. The example he gave was were those with a Disability can change from LGV to Disability. He stressed that the purpose of changing Body Type to Motorcaravan, which he confirmed was a legal requirement, was to satisfy speed restriction differences and that 'Body Type' would be checked by enforcement agencies should that ever be in question, to confirm that I have the restrictions of a Motor Car rather than a Light Goods Vehicle.

I then went on to ask him the question that if a vehicle is reclassified as Body Type: Motor Caravan to legally allow it to travel as a Motor Car for the purposes of speed restrictions would that also infer that it should be regarded as a Motor Car for other restrictions that differentiate between Motor Cars and Light Goods Vehicles. That stumped him a little and that he was unsure.

His ultimate advice much the same as above is that I should first:
Approach Tfl with all the evidence of the conversion.
Explain my confusion given that I am bound by speed restrictions for a Motor Car and that I therefore believed that it was reasonable to assume that I would not be regarded as a Light Goods Vehicle as per the Rotherhithe restriction signage.

He did point out that it is typical of ANPR systems that exemptions can be made within these systems. So Tfl may be able to do this to avoid further PCNs being sent if they are satisfied that I should be exempt.

I'll write the representation to Tfl and update when I hear back.

 

[Amarillo]

I then went on to ask him the question that if a vehicle is reclassified as Body Type: Motor Caravan to legally allow it to travel as a Motor Car for the purposes of speed restrictions would that also infer that it should be regarded as a Motor Car for other restrictions that differentiate between Motor Cars and Light Goods Vehicles. That stumped him a little and that he was unsure.

You still have the obstacle that the taxation class of your vehicle is "light goods vehicle", and TfL might argue that it is this which defines your van, not the body type. For that reason you might want to include an alternative reason for TfL to allow your representations: their signage with a Luton type van symbol made it unclear that light goods vehicles were included in the restrictions. This is a weak argument, and your hope in including this is that TfL would write back to say that while the penalty was correctly applied, they accept you were confused by their signage and in this one instance were cancelling the penalty.

If you are mined to use this second reason as grounds for appeal, I think you can strengthen the argument somewhat.

=====
If I am wrong about my vehicle being a motor car for passage through the Rotherhithe Tunnel, it would be an extraordinary anomaly for TfL to define my vehicle by the taxation class alone and not in conjunction with the body type. The DVLA consider both the taxation class and the body type to determine that my vehicle is a motor car for highway restrictions, and the example they have given over the phone is for speed restrictions. If this extraordinary anomaly exists, there is no way that a reasonable person could work out the difference between the TfL and DVLA definitions of a light goods vehicle from TfL's signage or restriction notices, and in this one instance the PCN issued to me as the registered keeper should be cancelled and a warning issued instead.
=====

Your main emphasis should be to have TfL agree that the PCN was issued incorrectly as that will allow you and others to pass freely through the Rotherhithe Tunnel in a VW T5/T6 campervan conversion.

 

[steven239]

Hi all, rejection letter received:

 

[steven239]

The second paragraph ("You said ...to..... motor caravan conversion") is my representation letter stated back to me.

There doesn't seem like a lot of interest on their part to get involved in a debate which I presume is their general tactic.

The only significant couple of sentences seems to be where they say: "The restriction applies to all goods vehicles with a maximum gross weight that exceeds 2000kg. This includes and is not limited to Heavy Goods Vehicles, flats bed trucks, Lighter Good Vehicles, vans and pick ups whether carrying goods or not and irrespective of the vehicles use".

So again I suppose it comes down to whether or not an N1 that is now a Motor Caravan is legally a Light Goods Vehicle for road restrictions or not.

Interested to hear all and any thoughts.

Thanks all.

 

[Amarillo]

The second paragraph ("You said ...to..... motor caravan conversion") is my representation letter stated back to me.

There doesn't seem like a lot of interest on their part to get involved in a debate which I presume is their general tactic.

The only significant couple of sentences seems to be where they say: "The restriction applies to all goods vehicles with a maximum gross weight that exceeds 2000kg. This includes and is not limited to Heavy Goods Vehicles, flats bed trucks, Lighter Good Vehicles, vans and pick ups whether carrying goods or not and irrespective of the vehicles use".

So again I suppose it comes down to whether or not an N1 that is now a Motor Caravan is legally a Light Goods Vehicle for road restrictions or not.

Interested to hear all and any thoughts.

Thanks all.

My initial feeling is that they have not understood your argument.

It is not that you were not using the vehicle as a goods vehicle, but that it is now a motor caravan not a goods vehicle: its classification has been changed.

Had they said something like, "a motor caravan is still treated as a goods vehicle for the purpose of transit through the Rotherhithe Tunnel", and shown legislation to back that up, you then move to your second argument which is basically, "how would a reasonable person be expected to know that from your signage?" But they's said none of that and have just cut and pasted a load of garbage from the response to someone else's appeal that they were passing through the tunnel with an empty Ford Transit.

 

[larrylamb]

As the original post states, the weight limit is 2 tonnes.

http://lruc.content.tfl.gov.uk/rotherhithe-tunnel-restrictions-and-alternative-river-crossings.pdf

 

[WelshGas]

As the original post states, the weight limit is 2 tonnes.

http://lruc.content.tfl.gov.uk/rotherhithe-tunnel-restrictions-and-alternative-river-crossings.pdf

So a Range Rover is also banned as is a California?

 

[larrylamb]

So a Range Rover is also banned as is a California?

It's a bit ambiguous as one webpage says goods vehicles but the link I posted states all vehicles must comply which would include Range Rovers etc. My opinion is that a weight limit is purely that, why should it depend on vehicle type, it's about protecting an old tunnel. Wonder how many fines get issued and to what type of vehicle but I would n't risk it in a VW transporter, Cali or not.

 

[Amarillo]

It's a bit ambiguous as one webpage says goods vehicles but the link I posted states all vehicles must comply which would include Range Rovers etc. My opinion is that a weight limit is purely that, why should it depend on vehicle type, it's about protecting an old tunnel. Wonder how many fines get issued and to what type of vehicle but I would n't risk it in a VW transporter, Cali or not.

The weight limit a few weeks ago was 17 tons.

The new limit of 2 tons is for goods vehicles only.

The question on which this hinges is whether a goods vehicle converted to a motorhome is still a goods vehicle for traffic regulations because of the taxation class, or has the change in body type, required by law, changed it to something other than a goods vehicle for traffic regulations?