Comment attributed to Barney Goffer, UK Product Manager at Teletrac Navman
Government consultation is currently underway and seeking views on its proposal to change the first MOT for new light vehicles, from three to four years after manufacture. In light of technological advancements such as hybrid, electric and self-drive vehicles, the Department for Transport (DfT) through this consultation, questions whether MOT tests need to adapt to be fit for the future.
The purpose of the MOT is to ensure we have vehicles that are safe to use on our increasingly busy roads. But my question is, how exactly does extending the time for the first MOT achieve this?
One area that we know causes MOT failure rates to increase - and the proposal itself states - is high mileage. The DfT’s 2016 consultation noted that while a three-year-old car does around 32,000 miles on average, vans do more than 70,000 miles. In 2021 the average mileage at year three, for class 4 vehicles was 25,379 and for class 7 (vans between 3 and 3.5 tonnes), it was 58,539.
Based on the 2021 figures, we’re looking at a difference of around 130 percent between the two classes of vehicle – a statistic that also demonstrates the likely difference in wear and tear too. By proposing to extend initial MOT tests by another 12 months, my concern is that a class 7 vehicle could therefore be less roadworthy, but remain on the roads until tested in its fourth year. This presents a worrying safety risk for both LCV drivers and road users at large.
In fact, the consultation estimates the increased risk of on-road collisions as a direct impact of moving MOTs from three- to four-year testing. It admits that it is reasonable to expect a vehicle to be more likely to fail its first MOT if the initial period of testing was extended. In data provided by the Driver and Vehicle Standards Agency (DVSA), it was also observed that for most of the vehicles in scope, the initial failure rate of vehicles increases with the vehicle age. For Class 4 vehicles in 2019, this rose from 14% for 3-year-old vehicles, to 16% for 4-year-old vehicles.
As a result of these failure rates, the proposal also calls out what the industry is up in arms about - that an increase in the number of vehicles operating with vehicle defects for a longer duration could lead to an increase in the number of vehicle defect-related collisions. To put this into perspective, in 2019 we saw around 1,455 casualties in collisions where a vehicle defect contributory factor was listed for the vehicles identified in scope of this proposal, 20 of which were fatal, 333 serious and 1,102 were slight, respectively.
The facts on the table make it very difficult to understand how a validation of any increases in road collisions can be considered, especially when the outcome directly links to the proposal. They talk about cost and environmental benefits as a result of the proposal, but roadworthiness and safety of vehicles must remain at the top of the agenda, with all other aspects considered secondary.
However, on the topic of environmental impact, the heavy focus on improving emissions in line with zero-emissions targets for new cars and vans in 2035 makes the move towards a four-year period for first MOTs feel like an odd one. Granted, new vehicles are going to produce much better emissions levels than older vehicles, but at what age do we consider new vehicles to be ‘old’ and less efficient?
As ICE vehicles continue to come under greater scrutiny as the push to EV becomes more prominent, it is vital that these vehicles operate as effectively as possible during the switch-over to EVs. Efforts to maintain a compliant fleet, support business continuity and become more environmentally friendly are futile, if we’re allowing ICE vehicles to run on the roads for 12 months longer before they’re proven roadworthy.
Overall, I think this proposal speaks for itself and there are just too many arguments against the changes proposed.”