Hello from ATFOA
It’s been some time since we last communicated with you. It’s not because we’ve been quiet, because we haven’t. Following our landmark victory in the house of Lords in the summer of 2020, where master tactician Lord Attlee (who was fighting in ATFOA’s corner) played a blinder and forced the government’s hand to hold a ‘Heavy Vehicle Testing Review.’ The ‘Review ‘ lasted a few months over regular online meetings with ATFOA and the other stakeholders participating. The Review has been in draft for a few weeks and has since been whizzed through Whitehall (to cleanse and ratify, no doubt) and we have now received a summary letter from Baroness Vere of DfT and the full report on the government’s website.
“Unlike the rest of us, DVSA and government still think the earth is flat when it comes to testing“
When the ‘Review’ was first announced we were ecstatic, we really thought we had won a victory for the instigation of a road map for delegated testing, but as soon as I had sat back down in my seat, an old cynical hack was on the phone teasing me that the process had been negotiated to keep us quiet and the ‘Review’ would be a whitewash.
Looking back, whitewash is perhaps the right description because DfT refused to include plausible alternatives, such as delegated testing, to be debated in the ‘Review’ process. This directive was hugely disappointing, as we all know that the only real solution for the inadequacy of DVSA’s delivery of testers to site would be to remove them from this historically painful responsibility. As the main attraction was ‘off the menu’ from the get go, the process, in our opinion, was no longer a ‘Review’ at all. It resembled a DVSA internal appraisal. DfT had given up the opportunity of the decade to take the small risk and steer their ship towards the edge of the earth in the hope of finding a land of great opportunity and benefit from a reliable, flexible, customer focussed, efficient alternative for the future of testing.
It’s not even much of a risk, it’s not like we’re the first to go over the edge. Government decided not to get physically involved with testing cars (class IV), now the industry does it. The arguments about HGV’s being heavier, therefore more dangerous doesn’t work when you consider the government has no consideration to get involved with testing planes, trains, large electromechanical plant, cranes, lifts and even generators so why are HGV’s treated different? It’s difficult to see their logic on this one and when you ask them they struggle to answer it.
Omitting delegated testing from The Heavy Vehicle Testing Review was like organising a panel to review the best football players of all time but not allowing them to discuss the merits of Pele. It makes the debate rather pointless unless you’re on the other side protecting something.
The Review in full
Those of you who have time to digest the detail, the report can be downloaded in full here.
“Yes, the industry will be paying for the improved service”
The Review in Summary
The contents of Baroness Vere’s letter gives us some insight into what to expect. It is likely that some change is coming, that said, the oil tanker that is the government hasn’t even given the order to turn the rudder yet so we are a good way off before we even think about changing course. There will need to be a public consultation to understand industry sentiment and how it reacts to increases in DVSA statutory testing fees to fund the extra testers required to deliver the flexibility and supply needed. Yes, the industry will be paying for the improved service despite DVSA already offloading their costs onto ATF’s and increasing fees at the onset of the ATF testing regime. In my opinion, knowing a little about how the government works, I would think it will be at least a year to 18 months before anything solid comes to fruition, that’s if COVID doesn’t rear its ugly head again.
Baroness Vere – “The review found that the testing system was not in crisis, but did identify a number of recommendations for future work, falling into six areas”
I am sure most ATF’s and stakeholders would disagree with the statement that the testing system is not in crisis. I would argue that it has been in crisis since NGT (Next Generation Testing) was introduced. That was when DVSA first restricted our supply of testers by up to 50% at some ATF’s. I personally lost 25% of tests. That was a crisis. That was when they removed overtime for testers and annual requests for tests so the flexibility we had was reduced. How can it not be in crisis when the whole industry can’t get a test on time due to exemptions that were invented, not because the haulage industry didn’t want to be tested or because of any COVID restrictions being in place – the rest of the industry, including DVSA enforcement, solved that problem at the onset of COVID and carried on to keep Britain moving, ATFOA presented DVSA with evidence of thousands of IRTE qualified private sector testers ready and willing with the capacity to start testing; exemptions were introduced to protect DVSA’s embarrassment of not being able to supply testers. That is by definition, a crisis.
|Recommendation||What this means||ATFOA Opinion||Would delegated testing deliver this recommendation?|
|Continued service improvement||DVSA is to continue to work to improve the service, ensuring that robust user feedback is used to develop any changes. Testing intervals for Earned Recognition operators should be considered further.||Nothing new here, the industry has been promised improvement for a decade. More often than not, improvement in service has been paid for by ATF’s. Unless DVSA can resist its protectionism or the public consultation results in funding for more testers, then expect no real improvement in service provision.|
|Slots for tests at Authorised Testing Facilities (ATFs)||The moratorium on new sites should be lifted in the near future and the effects of allowing testers to be booked further in advance should be examined.||Expect more ATF’s to open which will increase competition. This will diminish the demand for your test station. However, DVSA will have to massively increase their pool of testers before they can open more ATF’s and deliver the supply & flexibility they are promising. Historically DVSA tester availability has reduced year on year. ATFOA welcomes competition, however, in a normal free market, businesses control their supply lines and charges (amongst other things) to help counteract the effects of competition. The greatest inhibitor will be the challenge DVSA will have to resist their protectionism||YES|
|Booking of tests||More work is needed to make it easier for operators to book a test at an ATF.||Nothing new here. This issue was well known prior to the review. The testing regime is reliant upon DVSA delivering their resource efficiently, flexibly which has always been a challenge. DVSA online system may be the answer…||YES|
|Communications:||DVSA should work to reinvigorate stakeholder relationships and develop improved communications plans.||DVSA have promised this at every juncture, NGT was supposed to resolve communications, but it got worse. DVSA need to bring back local managers, not rely on the under resourced and distant network managers.||YES|
|Vehicle testing performance measures:||A more detailed set of measures that reflect the whole service (and user experiences in particular) should be developed.||User experience measurement is important, Up to now DVSA have focussed on internal measurements from their perspective. This data, such as capacity utilisation has been used to justify their protectionism.||YES|
|Tester capacity:||An increase in tester capacity (paid for through higher fees) should be considered, in order to provide greater capacity for users of the system. This would require public consultation.||Nothing new here. This issue was known prior to the review. NGT was supposed to deliver more testers, efficiency, choice and greater flexibility. The main problem though is a creaking 1970’s public body process not being able to respond to fluctuations in private sector supply and demand – coupled with DVSA protectionism restricting tester flow when the industry needs to ramp up. The important point here is that at last DVSA understand that they need to increase tester remuneration to attract their ever diminishing pool. So expect an increase in charges to fund more testers and more flexibility. Subject to a public enquiry.||YES|
It doesn’t take a lot to surmise that DVSA will not be steering a course towards delegated testing in the mid term, that’d be like sailing towards the edge of the world for them. Unlike the rest of us, DVSA and government still think the earth is flat when it comes to testing, their protectionism overrides any decision process that might see them lose control over their supply lines – so with these priorities coded into their DNA it’ll be a continued challenge for them to deliver any type of flexibility and efficiency that matches what the private sector can deliver.
A new hope
More recently, ATFOA were genuinely delighted to be approached by the incoming Chief Executive of the DVSA, Loveday Ryder, who was appointed to her new role on 1st January 2021. Loveday got in touch and took the time to listen to us so we had a great opportunity to communicate The ATF industry’s woes, thoughts and future requirements and expectations. Let’s hope Loveday is brave enough to buck the trend of her predecessors by looking at the perspective from all the industry stakeholders for a more balanced strategy, instead of protecting DVSA’s supply lines.
There is likely to be some industry probing over the next few months so DVSA can assess the sentiment before they implement some of the change management they will be proposing. Speaking broadly about what to expect, ATF members should start thinking about how they can benefit from increased competition and greater flexibility opportunities.
However, for the time being, expect much the same. Which leads me on to my next point….
What is much the same?
ATFOA want to record how our members are fairing as we are coming out of lockdown but still feeling the pain of the government imposed exemptions, so we are asking you to take part in this short survey. Please help us communicate your experience. Every complete survey adds to our voice.
Thank you for reading