Rotherhithe Tunnel

I have written to TfL to try to clear up this ambiguity. This is their response:

Dear Mr Crispin
Thanks for your feedback form of 5 June about the restrictions for a campervan under the River Thames through the Rotherhithe Tunnel.
If a vehicle is registered as a commercial vehicle weighing more than 2T, or has dimensions greater than 2.0m in height or width it is prohibited. If it falls outside of those parameters, then it is not prohibited.
I trust this information is helpful and thanks again for contacting us. If there is anything else we can help you with, please reply to this email. Alternatively, you can call us on 0343 222 1234 and we'll be happy to help you.
Kind regards
Maria La Tegola
Customer Service Adviser

From that response I can see that a T5 or T6 campervan conversion would be banned, whereas a T5 or T6 California would be allowed. However, I think TfL may have it wrong as there is an anomaly between the way Highways England treat campervan conversions for speed limits etc, and the way TfL treat campervan conversions. If it were me, I would appeal the decision.
 
Reply sent to TfL
Dear Ms Le Tegola,
Just for clarity, can you please confirm that there exists an anomaly between the way Highways England treat campervan conversions which have had their registration documents amended to show the body type as “motor caravan” for highway restrictions such as speed limits, and the way TfL treat such vehicles for highway restrictions through the Rotherhithe Tunnel?
Can you also confirm that a VW T5 or T6 California with registration documents showing Body type “Motor Caravan” and Taxation class “Diesel car”, within the 2.0m height and width restriction, and with a Revenue Weight of 3000 Kg, would be permitted to transit the Rotherhithe Tunnel; whereas a VW T5 or T6 Transporter with registration documents altered showing Body type “Motor Caravan” and Taxation class “Light Goods Vehicle” (which cannot be altered), also within the 2.0m height and width restriction, and with a Revenue Weight of 3000 Kg, would NOT be permitted to transit the Rotherhithe Tunnel?
Finally, if the above is true, can you let me know how a layman would be able to find out that the way Highways England and TfL treat correctly registered campervan conversions for highway restrictions is different from each other?
Kind regards,
Tom Crispin
 
Maybe a trip to their offices with some example vehicles would help the bosses understand?
 
Maybe a trip to their offices with some example vehicles would help the bosses understand?
My query has been escalated.

Dear Mr Crispin
Thanks for your further email.
I've passed your correspondence to our Asset Investment team and I'll let you know an update as soon as I hear back from the team.
Thanks again for contacting us and please let me know if you need anything else.
Kind regards
Maria La Tegola
Customer Service Adviser

I do not know if I am on some sort of priority list with TfL, but I do find that I get informed responses from them when I press them on various issues.
 
So, I came across this thread from a Google search. I don't own a Cali (I wish!) But have just got a penalty charge notice sent through for my converted ford transit camper! Same situation as above, DVLA have it as camper, toll bridges it's classed as a car etc so I look forward to finding out what the outcome is here. Really reluctant to be £130 out of pocket :-(
 
So, I came across this thread from a Google search. I don't own a Cali (I wish!) But have just got a penalty charge notice sent through for my converted ford transit camper! Same situation as above, DVLA have it as camper, toll bridges it's classed as a car etc so I look forward to finding out what the outcome is here. Really reluctant to be £130 out of pocket :-(
What does it say on your V5?
 
So, I came across this thread from a Google search. I don't own a Cali (I wish!) But have just got a penalty charge notice sent through for my converted ford transit camper! Same situation as above, DVLA have it as camper, toll bridges it's classed as a car etc so I look forward to finding out what the outcome is here. Really reluctant to be £130 out of pocket :-(
On your V5 do you have taxation class "light goods vehicle", Body type "Motor Caravan"?
 
Hi all. Sorry I've not updated, especially after all the help, particularly from Amarillo, that has been posted since my last message. In short, I took my appeal to the adjudicator and have been waiting for a reply. Today I received a letter saying that it won't even be looked at until mid July, so I'll update as soon as I hear anything.
 
Btw some pertinent points made by a member of the Fightback Forum website, quoted below. These are very much aligned with the same points as Amarillo. Some of which I added to my representation to the adjudicator.

"In 2013, a reference to Commission Regulation (EU) No 678/2011 of 14 July 2011, replacing Annex II and amending Annexes IV, IX and XI to Directive 2007/46/EC of the European Parliament and of the Council establishing a framework for the approval of motor vehicles and their trailers, and of systems, components and separate technical units intended for such vehicles (Framework Directive), was added to a 2011 thread on the topic of the definition of "goods vehicle": http://forums.pepipoo.com/lofiversion/index.php/t62058.html


In Part A thereof, "Criteria for vehicle categorisation", section 1 specifies the classifications used for "purposes of European and national type-approval, as well as individual approval", as follows (in relevant part):

Category M Motor vehicles designed and constructed primarily for the carriage of persons and their luggage.

Category M1 Vehicles of category M, comprising not more than eight seating positions in addition to the driver’s seating position.

Category N Motor vehicles designed and constructed primarily for the carriage of goods.

Category N1 Vehicles of category N having a maximum mass not exceeding 3,5 tonnes.



In addition, a “Special purpose vehicle (SPV)” is a subcategory of these categories which is applied to vehicles of category M, N or O which have "specific technical features in order to perform a function which requires special arrangements and/or equipment."

One of the specified types of "Special purpose vehicle" is the "Motor caravan", which is defined as:

"A vehicle of category M with living accommodation space which contains the following equipment as a minimum: (a) seats and table; (b) sleeping accommodation which may be converted from the seats; © cooking facilities; (d) storage facilities. This equipment shall be rigidly fixed to the living compartment. However, the table may be designed to be easily removable."

This implies that a vehicle that is officially considered a "Motor caravan" must belong to category M (unless it had been mistakenly categorised), as there are no "Motor caravans" that do not belong to any category other than M.



In Part C thereof, "Definitions of types of bodywork", we find the following:

1. Vehicles belonging to category M1

AA Saloon a vehicle defined in term 3.1.1.1 of Standard ISO 3833:1977, fitted with at least four side windows.

AB Hatchback a saloon as defined in 1.1 with a hatch at the rear end of the vehicle.

AC Station wagon a vehicle defined in term 3.1.1.4 of Standard ISO 3833:1977.

AD Coupé a vehicle defined in term 3.1.1.5 of Standard ISO 3833:1977.

AE Convertible a vehicle defined in terms No 3.1.1.6 of Standard ISO 3833:1977. However a convertible may have no door.

AF Multi-purpose vehicle a vehicle other than AG and those mentioned in AA to AE intended for carrying persons and their luggage or occasionally goods, in a single compartment.

AG Truck station wagon a vehicle defined in terms No 3.1.1.4.1 of Standard ISO 3833:1977. However, the luggage compartment must be completely separated from the passenger compartment. In addition, the reference point of the driver’s seating position needs not to be at least at 750 mm above the surface supporting the vehicle.



Accordingly, a vehicle meeting the definition of "motor caravan" under the Regulation should be considered a vehicle of category M, with a body type of "multi-purpose vehicle", for European and UK type and individual approval purposes--which should be reflected in UK law. By implication, such a vehicle cannot also be a vehicle of category N, which is (obviously but, frustratingly, not explicitly) for goods vehicles.

But is TfL bound by this? EU Regulations are directly effective (they do not need to be transposed into UK law), at least so long as the European Communities Act 1972 remains law, so I would think so. Their letter has not bothered to argue the point; it simply says that "our records show that the [OP's caravan] is a [goods] vehicle," without explaining or even addressing the OP's evidence on that point. Nor has TfL referenced the information in "their records" or explained why they differ from those held by the DVLA. "
 
Hi all. Sorry I've not updated, especially after all the help, particularly from Amarillo, that has been posted since my last message. In short, I took my appeal to the adjudicator and have been waiting for a reply. Today I received a letter saying that it won't even be looked at until mid July, so I'll update as soon as I hear anything.
Thanks for the update. The more I think about this, the more I think TfL have made a mistake.

What possible justification would TfL have for treating a campervan conversion from a commercial vehicle as a goods vehicle while the DfT does not?
 
Bizarre reply from Transport for London.

Thanks for your further email.
I’ve been in communication with our enforcement policy and they have looked into the matter further for you. I'm sorry for the delay in replying.
As this matter is related to our policy on emissions, I've passed your correspondence to our Congestion Charging team who will reply to you directly shortly.
Thanks again for contacting us. If there is anything else we can help you with, please reply to this email. Alternatively, you can call us on 0343 222 1234 and we'll be happy to help you.
Kind regards
Maria La Tegola
Customer Service Adviser

Transport for London Customer Services
My query was asking if TfL have a different definition of a commercial vehicle for restrictions through the Rotherhithe Tunnel from the Department for Transport for highway restrictions, specifically in the case of campervans who have had their V5 amended, as legally required, to show the change.
 
Bizarre reply from Transport for London.

Thanks for your further email.
I’ve been in communication with our enforcement policy and they have looked into the matter further for you. I'm sorry for the delay in replying.
As this matter is related to our policy on emissions, I've passed your correspondence to our Congestion Charging team who will reply to you directly shortly.
Thanks again for contacting us. If there is anything else we can help you with, please reply to this email. Alternatively, you can call us on 0343 222 1234 and we'll be happy to help you.
Kind regards
Maria La Tegola
Customer Service Adviser
Transport for London Customer Services
My query was asking if TfL have a different definition of a commercial vehicle for restrictions through the Rotherhithe Tunnel from the Department for Transport for highway restrictions, specifically in the case of campervans who have had their V5 amended, as legally required, to show the change.
Stalling. They realise they have a problem. They hope you will go away. It could cost them money.

There are non-commercial vehicles that meet their requirements with worse emission standards so that statement is a red herring.

Keep at them.:thumb
 
Stalling. They realise they have a problem. They hope you will go away. It could cost them money.

There are non-commercial vehicles that meet their requirements with worse emission standards so that statement is a red herring.

Keep at them.:thumb
Emailed today:

Dear Ms La Tegola,
My query was asking if TfL have a different definition of a commercial vehicle for restrictions through the Rotherhithe Tunnel from the Department for Transport for highway restrictions, specifically in the case of campervans who have had their V5 amended, as legally required, to show the change.
This is not related to emissions, but TfL’s definition of a commercial vehicle.
Best regards,
 
Emailed today:

Dear Ms La Tegola,
My query was asking if TfL have a different definition of a commercial vehicle for restrictions through the Rotherhithe Tunnel from the Department for Transport for highway restrictions, specifically in the case of campervans who have had their V5 amended, as legally required, to show the change.
This is not related to emissions, but TfL’s definition of a commercial vehicle.
Best regards,
Go get them

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A barely coherent reply:

Thanks for your further email.
I understand your concerns.
The team that deals with enforcement issues will deal with your enquiry and reply to you directly as this matter relates to vehicles and permission through restrictions.
I have contacted them again and passed on your further correspondence and I trust they will contact you soon.
Thanks again for contacting me and please let me know if I can help you with anything else.
Kind regards
Maria La Tegola
Customer Service Adviser
I now wonder if in her previously reply a misspelled 'permissions' had auto-corrected to 'emissions'!!

We shall get an answer in the eventually.
 
I suspect they are calculating the cost of reimbursement by checking every PCN they have issued versus the revenue gained...
 
We've driven through the Rotherhithe tunnel numerous times in our California without problems, but doing so last week has brought us a Penalty Charge Notice. Is this restriction a new thing? I should think the last time we drove through the tunnel was December 2018 (signs were up saying no vans, and there was a police car watching at the tunnel entrance, but we had no problem).
I thought the issue this time might be that we had two bikes on the bike rack (which raises the height slightly over 2 metres, but looking at the Forum it seems to have happened to other people too.
However, as time is money for the self-employed (me) I'd rather pay the charge (or 50% of it, £65) than spend several hours disputing it. I'll be looking to see what other people find out though.
And in the future, bye bye Rotherhithe Tunnel!
 
We've driven through the Rotherhithe tunnel numerous times in our California without problems, but doing so last week has brought us a Penalty Charge Notice. Is this restriction a new thing? I should think the last time we drove through the tunnel was December 2018 (signs were up saying no vans, and there was a police car watching at the tunnel entrance, but we had no problem).
I thought the issue this time might be that we had two bikes on the bike rack (which raises the height slightly over 2 metres, but looking at the Forum it seems to have happened to other people too.
However, as time is money for the self-employed (me) I'd rather pay the charge (or 50% of it, £65) than spend several hours disputing it. I'll be looking to see what other people find out though.
And in the future, bye bye Rotherhithe Tunnel!
Do you still have the PCN? It should say why they claim you have contravened the restriction.
 
Thanks Amarillo/Tom.

It says:
Contravention description: Failing to comply with a prohibition on certain types of vehicle goods vehicles exceeding max gross weight indicated

Do you think this is a specific reason? I've noted it exactly as written, but there were two spaces between 'vehicle' and 'goods vehicles', nothing more given. (But posting this comment makes it autocorrect to a single space.)

I took this to be just a general wording of the rules, but if you think it's specific, then it probably would be worth attaching a copy of the vehicle registration certificate. I am just reluctant to spend a lot of time on it if it's unlikely to be successful.
 
Thanks Amarillo/Tom.

It says:
Contravention description: Failing to comply with a prohibition on certain types of vehicle goods vehicles exceeding max gross weight indicated

Do you think this is a specific reason? I've noted it exactly as written, but there were two spaces between 'vehicle' and 'goods vehicles', nothing more given. (But posting this comment makes it autocorrect to a single space.)

I took this to be just a general wording of the rules, but if you think it's specific, then it probably would be worth attaching a copy of the vehicle registration certificate. I am just reluctant to spend a lot of time on it if it's unlikely to be successful.
The alleged contravention appears to be exceeding the weight limit for a goods vehicle which is two tonnes.
As far as I am aware, the weight limit for cars is still 17 tonnes.

Depending on what it says on your V5, you should be able to successfully argue that your vehicle is not a goods vehicle.

My V5 describes my 2017 Beach as body type "MOTOR CARAVAN" and taxation class "DIESEL CAR".

If you have the same, I think that you'd be mad to hand over your hard-earned £65.

Photocopy your V5, highlight the taxation class and body type, and return the appeal form with the simple message, "My car is not a goods vehicle."

If your V5 has body type "MOTOR CARAVAN" and taxation class "LIGHT GOODS VEHICLE", you may well have more of a fight on your hands which I expect would ultimately be successful.

The contravention as stated is not height or width both of which are 2m for all vehicles.
 
Thank you. Ours is 'motor caravan' and 'private / light goods'.

Do you (or does anyone else) know, if I dispute the PCN but my claim is rejected, do I still have the opportunity to pay a 50% reduced charge within 14 days given that I'm unlikely to hear back within 14 days of the original notice? Or will I have to pay the full amount (£130) if it doesn't succeed, with no 50% option? Probably the latter, I should think.
 
Thank you. Ours is 'motor caravan' and 'private / light goods'.

Do you (or does anyone else) know, if I dispute the PCN but my claim is rejected, do I still have the opportunity to pay a 50% reduced charge within 14 days given that I'm unlikely to hear back within 14 days of the original notice? Or will I have to pay the full amount (£130) if it doesn't succeed, with no 50% option? Probably the latter, I should think.

My certainty on this is about 80%, so cannot be relied upon.

If you appeal, the number of days remaining for the discounted rate is frozen between your appeal being received and TfL informing you of their decision.
 
My certainty on this is about 80%, so cannot be relied upon.

If you appeal, the number of days remaining for the discounted rate is frozen between your appeal being received and TfL informing you of their decision.
Agree.
 
Let me tell you all as a Cali owner and a London Taxi Driver TfL are not only useless but secretive and have to be dragged kicking and screaming to even partially admit any error. Its not a political thing, they are set up to be beyond accountability and all mayors have failed to act.
A London Assembly report called them ‘woefully inadequate’, keep at them and never take no for an answer.
 
Thanks folks - I'll give it a go, largely because I'd like to be able to keep driving through the Rotherhithe tunnel. I'll post the results.
 
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