BSA Owners’ Club response to the DVLA Consultation Document on reducing Motorcycle Evasion of Vehicle Excise Duty (VED)

Q1 Are you prepared to allow your response or name to be quoted or made available to the public.

  Yes

  Q2 Should we adopt a ‘sticky licence’ system adhered to the ‘rear’ number plate.

A sticky licence perhaps, but to place it on the rear of the machine is probably the worst place on a motorcycle to stick it. The rear of the machine is subject to road spray, tar in hot weather and general grime and dirt. Therefore any licence would have to be capable of being pressure washed, solvent/cleaning fluid proof and be capable of being scrubbed without being damaged.

  I always thought that the VED disc on a motorcycle was to be displayed at the front on the nearside so it is clearly visible from the footway.

  Secondly if as you say the surrender of the licence is by a separate piece of paper how would the Police know that the machine showing a perfect licence disc know that the licence had not been surrendered. If the motorcyclist is then required to carry another piece of paper around to prove that the licence is still valid then I feel that this is an infringement of that person’s rights of being innocent until proved guilty. It also means that the sticky disc is irrelevant, as the police will still have to ask for proof of its validity whether or not a licence is shown.

  Thirdly, some guidance as to what is an acceptable degree of damage will have to be laid down very clearly otherwise Police and court time will taken up arguing on the validity of the licence. The only people to benefit from this wiil be the legal profession.

  Q3 Should we adopt a ‘sticky licence’ system adhered to a licence holder suitably placed on the rear of the motorcycle.

Unless it is sealed then the comments would be as above with regard to dirt and grime and the degree of acceptable damage. Would these licence holders be provided free?

  Q4 Should we use the number-plate as proof of licensing. (Laminate licensing details into the plate) and renew the number-plate on re-licensing.

  The most obvious problem with this is the fact of cost. Also would the Post Office have the facility to make up and laminate the number plate? If not you are imposing on the average motorcyclist an added cost and difficulty. Also the whole number plate could be transferred to another machine complete with a valid licence. Therefore in no way would this reduce tax evasion or theft. They would take the plate rather than the disc.

  Also would it make it difficult for the owner to take a bike to be tested when subject to the SORN and when a refund had been made. This is particularly relevant in rural areas where there could be a considerable distance to the MOT station and to the plate supplier.

  In addition which you alluded to in the document  is the historic motorcycle which has either a pressed aluminium number plate or the registration is painted direct on to the machine number plate. This is part of the structure of the machine and often contains the rear light.  Also the configuration and size of the number plate on the historic vehicle is different to modern machines being in the most part designed to take three letters and three digits. These are usually arranged vertically above each other and not in a line as on modern machines.

  Q5 Should all off-road motorcycles be registered?

  The Club does not condone the use of machines for criminal activity or creating a nuisance. However it must be said are these vehicles covered by the Road Traffic Acts? If not, does the DVLA have the legal power to require them to be registered?  If so what criteria would be used for registration. As far as I am aware there is no legal obligation to have any unique identifier on these types of off road machines.

  Also ex-road machines, which are used as field bikes etc., cause the majority of nuisance and therefore the registration would be irrelevant to these machines.

  As the enforcement of the nuisance is a police matter and do they have the capability of pursuing an unregistered off road machine across rough terrain?

  Q6 Do you have any suggestions or comments on the issues raised in this document.

  First I would like to have further information on the statement that 25% of motorcycles are unregistered. There may be very valid reasons why this is so. For instance did the survey take into account machines within the unlicensed category? Currently under a SORN? Records transferred to the DVLA when the computer was set up but have lain dormant since?

  If it was by road observation then did you take into account people not displaying a disc as they had it in their pocket?

  Second, both of the options place an extra burden on the motorcyclist and would be expensive to instigate. Who pays? Also would both options be available through the normal established network of Post Offices or would they only be available through the VRO’s, which are now few and far between.

  Thirdly, would other vulnerable road users be treated similarly? In particular open top cars, milk floats etc as their tax discs must also be vulnerable to theft as well as motorcycles?

  Fourthly, which taxation classes would this cover is it the Bicycle class or all motorcycles on the register as virtually all of the BSA Owners’ Club machines are eligible for the Historic classification. To exempt these would seem appropriate for the reasons stated above and also as they are zero rated then the loss of revenue to the DVLA would be minimal for the extra effort of instigating any of these proposals.

  As you state in the statistics 75% of motorcycles and probably more if you take into account those that are carrying their tax discs around, therefore is it equitable to have the vast majority to be punished for the minority. Also as there is a large theft of tax discs then would it not be sensible to bring this in for all road users and by doing this stemming the trade in stolen tax discs?

  On a further point I have e-mailed the contact point three times since May about where they obtained the statistics, requesting further clarification and informing them about our intention to place the response on our web site. I have yet to receive a response to these e-mails. In view of the lack of time I have decided to place our response onto the BSAOC web site.

Steve Foden BSAOC Librarian