Rotherhithe Tunnel

[ejmoore]

That sounds good, but I can't find either N1 or M1 on our V5c - where should it appear?

 

[Barbara]

That sounds good, but I can't find either N1 or M1 on our V5c - where should it appear?

Look on the https://www.gov.uk/check-mot-status

Put in your registration and you will see if M1 or N1

 

[ejmoore]

Doesn't seem to be shown there either - am I missing something?

 

[andyinluton]

Do you not get something like this shown? Its the vehicle type approval bit that's important.

Vehicle details

Vehicle make: VOLKSWAGEN
Date of first registration: July 2014
Year of manufacture: 2014
Cylinder capacity (cc): 1968 cc
CO₂Emissions: 189 g/km
Fuel type: DIESEL
Euro Status: Not available
Export marker: No
Vehicle status: Tax not due
Vehicle colour: BLACK
Vehicle type approval: M1
Wheelplan: 2-AXLE-RIGID BODY
Revenue weight: 3000kg
Tax rates:

 

[ejmoore]

Thanks Andy. However, on ours it says 'not available'.
Maybe because ours is older - 2008?

 

[Amarillo]

Thanks Andy. However, on ours it says 'not available'.
Maybe because ours is older - 2008?

View attachment 48361

It seems you will need to rely on your California being a motor caravan and not a goods vehicle.

This website shows that a motor caravan is a category distinct from a goods vehicle, and that it is treated as a car for speed limits.

Speed limits

A limit of 30 miles per hour or 48 kilometres per hour usually applies to all traffic on all roads with street lighting

www.gov.uk

A document that was submitted by TfL in Steve’s appeal shows that “body type: motor caravan” should be considered when determining the vehicle category.

Your additional information should be something like this.

=====

Dear TfL,

Thank you for the opportunity to submit further information.

You appear to misunderstand my representations.

I do not argue that my motor caravan is under two tonnes, but that it is not subject to goods vehicle weight limits.

A motor caravan is a category of vehicle distinct from cars and goods vehicles as shown by this information from The Highway Code.

[insert table]

When determining the vehicle category TfL should consider the body type as evidenced by TfL’s own guidelines.

[insert advice from Steve’s appeal document: post 83 above]

In particular note paragraph 2 on page 5 “[ quote in full ]”.

Note on my V5c that my vehicle is of body type “motor caravan”.

If your officers would like to visually inspect my vehicle to confirm it is a motor caravan I am happy for you to do this.


Sent from my iPad using Tapatalk

 

[andyinluton]

Amarillo

That argument has already been lost.

EJMoore needs to find out whether the cali is N1 or M1, if its registered as N1 the appeal will loose for exactly the same reason as the previous case.

If its registered M1 an appeal should succeed as the only reason the the previous case lost at appeal was because the adjudicator decided that once a vehicle has been classified as a goods vehicle ( N1) it is always a goods vehicle, irrespective of body type.

If this cali has been registered as M1, it has never been a goods vehicle.

The Information will be on the V5 somewhere.

Having just checked the V5 for a 2007 mini On the top left of the first page under Vehicle Details its item J "vehicle Category"

 

[andyinluton]

Heres a scan of one of my V5s the circled bit is what you are looking for.

 

[ejmoore]

Thanks Tom & Andy, you are both being very helpful, thank you.
Unfortunately in our logbook, item J is again blank, see attached.

 

[Amarillo]

@steven239

I think I can see where both TfL and the adjudicator have erred in their findings.

In your post #83 above you show a letter from TfL redroutes setting out their position. The final paragraph on Page 4 declares as a “matter of fact” that the N1, N2 and N3 designation defines a goods vehicle and that M1, M2 and M3 designation defines a passenger vehicle.

This is incomplete. A motor caravan of under 3.05 tonnes unladen weight is a distinct category of vehicle. It will be M1 if built before first registration, and N1 if converted after first registration from a goods vehicle, but in both cases it will be neither a passenger vehicle or a goods vehicle, it will be a motor caravan. If the legal change of category from a goods vehicle to motor caravan is accepted by the Department for Transport this will show up on the amended V5c as body type “motor caravan”, and the vehicle subject to the same highway restrictions as a passenger car. The N1 designation cannot be changed.

On this basis, I think you can write to the adjudicator asking them to review their decision: they have relied on something as a “matter of fact” which is incomplete.

You will need to provide evidence, but the speed limits page from the Highway Code, and the guide to changing vehicle category from goods vehicle to motor caravan should suffice.

Tom

 

[Amarillo]

Thanks Tom & Andy, you are both being very helpful, thank you.
Unfortunately in our logbook, item J is again blank, see attached.

View attachment 48363

Body type “motor caravan” on your V5c should suffice in conjunction with TfL’s own guidelines published in @steven239 post #83 above, scanned page 5, paragraph 2; and the Highway Code vehicle category and speed limits page.

Your California is not subject to goods vehicles restrictions.

 

[Neuon2003]

@ejmoore
A vehicle's type approval is a matter of fact (Vehicle Approval) . Type approval does not change due to a description "motor caravan". Once an N1, always an N1 (until reinspected). What is modified by that description is the consequences. The most obvious are speed limits, MOT (Class 4 not 7), and parking.

Suggestions to support your representation:

1. Your vehicle is a factory converted camper van (model description) and not a third party conversion of a goods vehicle.You are aware that the VW California models are Type Approved as Class M1.

2. Based on the V5C, it does not establish the vehicle is a goods vehicle. The scan of your V5C shows that the vehicle has no recorded vehicle category and is exempt from a type approval number.

3. You have no means to establish (or suspect) that your vehicle was a goods vehicle (absence of V5C details) and in no other ordinary application is it regarded as a goods vehicle (speed, tax, MOT, parking restrictions).

4. It was reasonable for you to rely on the V5C that you do not have a goods vehicle as it is described as a motor caravan and subject to motor caravan conditions (e.g. speed limits, MOT testing, parking). The DVLA's criteria on appearance is to your benefit (see HERE). DVLA has a policy that "the body type will not be changed unless the exterior of the vehicle actually appears to be a motor home". DVLA do not describe converted commercial vans as a motor caravan.

As this is an evidence-based exercise, you will need to supply supporting evidence.

 

[Barbara]

Is the problem Taxation class - Private/Light goods mine is Diesel car. In the past cars were classed as Private/Light goods so it looks like the age of the van is why it says Private/Light goods. It does seem strange that newer Californians are OK and the older one is not. Good luck.

 

[ejmoore]

Ok, I've now written a response with plenty of evidence & pictures. Thanks very much to Tom, Andy & Barbara for your helpful advice.
I'm going to forget about it now & get on with some work (before we go on another campervanning trip that is). E

 

[andyinluton]

Ok, I've now written a response with plenty of evidence & pictures. Thanks very much to Tom, Andy & Barbara for your helpful advice.
I'm going to forget about it now & get on with some work (before we go on another campervanning trip that is). E

I was going to say have you tried asking DVLA whether its M1 or N1

 

[ejmoore]

I looked it up following the link that Barbara gave, but it didn't say M1 or N1, just 'not available'.
Do you think I should ring them up?

 

[andyinluton]

I looked it up following the link that Barbara gave, but it didn't say M1 or N1, just 'not available'.
Do you think I should ring them up?

Nothing to loose, apart from the cost of the phone call.

 

[Amarillo]

I’ve had a proper response from TfL about my query. They seem to be saying that an M1 motor caravan under 2m wide and under 2m high is allowed through the Rotherhithe Tunnel, but a similar N1 motor caravan is not.

==========

Transport for London TRANSPORT
FOR LONDON

Ref: 13678779

5 August 2019

Dear Mr Crispin

Thank you for your email of 22 July about the restrictions on entering the Rotherhithe Tunnel.

We appreciate the time you've taken to contact us. We're sorry for the earlier confusion over your previous emails to us.

We have a well-established business rule for the Ultra Low Emission Zone (ULEZ) that defines vehicles by the DVLA tax class.

The tax class is usually found on the V5C. If defined here as a goods vehicle, we can't apply an alternative view based on any changes made to the vehicle by the owner.

A goods vehicle is defined as a ‘motor vehicle or trailer constructed or adapted for use for the carriage or haulage of goods or burden’. Owners can alter vehicles after manufacture or simply not use the vehicle for its intended purpose. However, we still need to consider the vehicle based on how it was constructed. This is so we can deal as fairly and consistently with drivers as possible.

We can’t comment on Highways England or other authorities’ approaches to enforcement. However, we can confirm that a vehicle with a car tax class would be permitted (subject to the other size limits we also impose at Rotherhithe). However, a vehicle with a goods vehicle tax class (and in excess of 2T MGW) would not.

I trust the above information is helpful.

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

Andrew Clapham
Customer Service Adviser
Transport for London Customer Services

==========

My own feeling is that TfL have erred, and there needs to be a consistent definition of a goods vehicle and motor caravan throughout England. Scotland, Wales and NI may have different definitions for road signage, but it would be wrong for signage definitions to differ for different transport authorities within England.

Simply copying and pasting ULEZ definitions for a goods vehicle to apply to road signage restrictions through the Rotherhithe Tunnel is ridiculous.

 

[Amarillo]

Coincidentally, I spotted another goods vehicle weight restriction sign which does not include motor caravans as they are permitted in Hayling Beach car park.

Google Maps

Find local businesses, view maps and get driving directions in Google Maps.

goo.gl

 

[Amarillo]

A bit of information here which seems to support TfL’s view:

Van now a motorhome but still classed as N1

Hi everyone, This may be a little long winded as there is a response from the DVSA into my query regarding T5 converstions. I have recently done mine and sent all the evidence to DVLA for it to be re classified as a motor caravan, which they have done, however seeing that the vehicle was a van...

www.vwt4forum.co.uk

If the information is correct then N1 vehicles with a body type “motor caravan” are regarded as goods vehicles for speed restrictions. It is possible to have the N1 category reclassified as M1 but will require a new chassis number, and is probably not worth the effort.

=====

Thank you for your enquiry which has now been passed to me, due to its technical nature. This has caused an extended delay in you receiving a reply, for which I apologise. Your question is more involved than you might think, but I shall try to answer all the points raised to enable you to make an informed decision on the correct registration of such a vehicle. I shall therefore start by explaining the background to the situation regarding your vehicle. In October 2007, the European Type Approval scheme for cars known as European Community Whole Vehicle Type Approval (ECWVTA) was amended by the implementation of the Recast Framework Directive 2007/46/EC. Due to this legislation, ECWVTA will extend to cover other vehicle types for the first time. The directive details the mandatory implementation dates for all categories of vehicles affected, the first being M1 passenger cars from 29th April 2009, followed by buses, coaches, vans, trucks and some special purpose vehicles at key dates between 2009 and 2014. Motor Caravans (as Special Purpose Vehicles) have required IVA testing since 29th April 2012. The Directive provides the base European legislation for the approval of vehicles that are mass produced, built in small numbers or as individual vehicles, requiring them to meet specified safety and environmental standards before they can be used on the road. The IVA scheme is a pre-registration inspection for vehicles that have not been Type-Approved to British or European standards. Since 1st May 2009 there have been two levels of IVA; Basic and Normal. Basic IVA will be applied in cases where the number of affected vehicles is expected to be low and we can accept that the very demanding safety and environmental standards of Type Approval will not be undermined. The Normal IVA will be applied in all other cases, i.e. where the number of vehicles entering service warrants Type Approval or comparable standards for key environmental and safety items. Motor Caravans will require Basic IVA testing. However, despite what you have been previously advised, it is the DVLA that will decide if a vehicle requires IVA testing, not DVSA and as such it is probably a very good idea if you contact them again, to gain an understanding of the actual situation regarding your vehicle, should you still be concerned by this. The generic understanding currently provided by the DVLA is as follows : If a panel van is converted to a Motor Caravan post registration, then it does not require additional approval. However, it should be noted that even if the DVLA accept that the vehicle now meets the definition as a Motor Caravan, the vehicle class will not change on the V5 (registration document) only the vehicle description. If the vehicle was approved as an N1 Goods vehicle it will still be listed as an N1 Goods vehicle. As you have suggested, this will have an impact on such items as speed limits applied to the vehicle and the London Congestion charge. If the intention is to have the vehicle both viewed and described as a Motor Caravan, then it must be issued with a new chassis number by the DVLA and approved as an M1 passenger vehicle under the IVA scheme. With regard to proceeding with having an IVA examination of the vehicle, with the intention of having the vehicle category changed, I have provided further information regarding the IVA scheme, which can be found by following the links below: VEHICLE TYPE APPROVAL - https://www.gov.uk/vehicle-approval/...hicle-approval
IVA - https://www.gov.uk/vehicle-approval/...hicle-approval
(Includes links to the Model Report list on the VOSA site, list of Technical Services, the IVA Guide, Test Stations and POTFs) IVA MANUALS - https://www.gov.uk/vehicle-approval/...proval-manuals
IVA FORMS - https://www.gov.uk/vehicle-approval/...lication-forms
If any of the above links do not work, please copy and paste them into your web browser. While I appreciate that this is not the answer you had hoped for, I do hope that you have found this information to be of use. However, if you feel that I can be of further assistance in this matter, please do not hesitate to contact me. Best regards, Mark Mark Vickers Eng Tech MSOE MIRTE | Technical Officer IVA M1 N1 O1 Driver and Vehicle Standards Agency | Ellipse, Padley Road, Swansea, SA1 8AN Phone: 0300 123 9000

 

[ejmoore]

I've now had the answer from TfL to my representation: Notice of Rejection. Basically they don't want ANY heavy vehicles going through the tunnel, which is fair enough given its historic nature and physical limitations.

I don't intend to pursue this any further, and am glad to confirm that the 14-day half-price fine offer is still available.

TfL's letter is attached. Fair or not, I'm not bothered. But as a historic buildings specialist I can see the point of protecting the Rotherhithe tunnel, rather than continuing to use it on a technicality.

Thanks everyone for your help and advice.

 

[TripleBee]

Too bad it didn't work out.

I once took a small road in a forest in France to get to a certain place. It was the most direct way. The long way around would lead to more pollution, so I took that road. It had a sign that only vehicles less than 1000 kg could drive the road. I crossed 2 normal passenger cars, but none was less than 1000 kg. Luckily there were no camera's and weight bridges, otherwise I could have gotten a penalty too.
I guess the 1000 kg restriction was only for trying to discourage all other than passenger cars to take that forest road. On that moment I wasn't there driving in fuction of a campervan, but with 2 passengers.

If there are some restrictions that are legally bound to that road, then I wouldn't have taken it. Let's say a bridge that allows you to cross if less than 2000 kg, would be a tough one to decide for me.

The penalty is not that high, but it's high enough to try to get it dismissed.

 

[john mar]

Off topic. I was told the reason the tunnel has bends in it is because in the old days when a horse and cart would go through,if the horse saw the light at the end of the tunnel it would bolt,the bends stopped that ....I remember going through the tunnel in skip lorry's and you would have to pull your mirror in or hit another lorry,s mirror coming the other way.

 

[me..me..me]

Just for peoples information. I recently challenged a TfL PCN on Rotherhithe and had my PCN cancelled and they refunded the fee I paid. I am awaiting a written confirmation that TfL data base has been ammended.
Hopefully the draft below maybe of some help to others.
Maybe I was just lucky so no guarantees but good luck to anyone.........

 

[ejmoore]

Well done, and your letter is well-worded (and illustrated) and useful. However, I am not getting back into this one again! Heading out that way next week, and sorry not to go through the dear old Rotherhithe tunnel*, but I'll take another route.
* perhaps more 'grim old Rotherhithe Tunnel'