Elephant-in-the-Room-animation-still970x546-720x405Elephant in The Room – Why are DVSA testers so special?

“is a metaphorical idiom in English for an important or enormous topic, problem, or risk that is obvious or that everyone knows about but no one mentions or wants to discuss because it makes at least some of them uncomfortable or is personally, socially, or politically embarrassing, controversial, inflammatory, or dangerous”

I have had tens, if not hundreds of conversations with many ATF’s and stakeholders since the decision was made to suspend testing completely. As an industry we have largely accepted the decision without question.

ATFOA are now challenging this Taboo subject: why is it that all other partners in the transport sector, including DVSA enforcement, can continue to operate in some capacity whilst following government guidelines on social distancing, when DVSA testers are treated differently and have suspended testing in its entirety?

If you look at the logic, the reasoning to suspend testing completely but allow for all other transport partners (including DVSA enforcement) to continue, is not just contentious, its flawed.

DVSA testers aren’t different at all to the rest of us. They operate in exactly the same spaces that the rest of the industry does. The ATF environment is mostly in the open, or at least in an open area, with only the tester operating in his own space. Workshops operate in this environment. I appreciate entering the cab may be an issue (but it’s not for the rest of us who follow government policy).

There could easily be a temporary variation introduced so DVSA do not need to enter the cab, or quite simply, the cab can be cleansed, like all other private sector workshop policies.

A few stakeholders had mentioned that the DVSA union representatives had a strong influence on the decision to suspend testing. If this is so, I’d like to hear the logic so the rest of the industry can understand why testing practice is treated different to driving, enforcement, workshops, delivery and loading practice etc, etc.

The private sector has developed its services and infrastructure around the supply and demand of customer requirement, it can instantly flex and continue to function to almost any situation – even COVID 19. Why can’t DVSA testers?

ATFOA have maintained that ATF’s have the experience, the skillset, the professionalism, the infrastructure, and the knowhow to mobilise tomorrow and start delegated testing, albeit temporarily. So, if DVSA continue to say they can’t do what the rest of the industry is doing, then we can do the testing for them.

There is never a stronger argument for delegated testing, based on what is happening right now; the transport industry is continuing to operate (albeit on a reduced capacity and obeying government guidelines) but DVSA testing is being treated differently and is suspended completely.

ATFOA will continue lobbying government and DVSA so they understand this: the longer nothing is done the bigger the problem grows. A decision is needed today

Letter to Grant Shapps – Secretary of State for Transport

Dear ATFOA member,

We have been inundated with members worried about their welfare and the future of testing. DVSA have not been able to respond to our proposals so we have turned our attention to Grant Shapps.

Please don’t hesitate to use our letter to Grant Shapps Secretary of State for Transport.

PDF – ATFOA Crisis letter to Grant Shapps

ATFOA Crisis letter to Grant Shapps

We ask that, if you make alterations then you do not use the ATFOA logo, thank you

Please show us your support and become a paying member

Titanic scenario – 3 month HGV MOT suspension

Dear ATF,

ATFOA are engaging with our stakeholders and DVSA on a range of measures as we need to start planning, now, to help mitigate against a range of problems that have only just started to materialise, for example;

Some hauliers schedule tests with ATF’s a year in advance, so when testing re-starts what happens to existing booked tests?

What tests take precedence? Existing or those vehicles that have been suspended.

The ATF capacity (and DVSA’s) will be overloaded when testing restarts, so at the end of the 3 months, how are we going to work through the back log?

DVSA struggle to supply the flexibility the market requires in ‘normal’ conditions so it will probably mean that suspended vehicles will need a further exemption (a compliance exemption) as slots won’t be available.

Even if DVSA offered an additional 3 month compliance exemption there would be double the workload so the reality would demand 6, 9 months or even 12 onths compliance exemption to help relieve the demand, unless DVSA consider other solutions.

Would DVSA consider ATF’s training their own staff to assist with the testing back log, even during a temporary period. If so, training needs to start now.

We should explore the practicality of extended testing times – to 24 hours


How might we utilise transparent compliance, such as, ‘earned recognition’ to reduce the temporary demand for testing.

We need to consider that some ATF’s will not survive their 3 month closure so it could be that testing capacity is further reduced.

I’d be happy for your input, please email atfoperators@gmail.com with any contribution.


Kind regards

Stephen Smith

Chairman

ATFO Association

M:07931 241 714

Is DVSA’s protectionism stagnating service levels for the end user?

I’ve had various conversations with DVSA, on behalf of members, who have had their testing allocations reduced.
There hasn’t been much in the way of a factual reasoning from DVSA, therefore, the industry generally concluded that they were caught short with the combination of opening over 550 ATF’s in quick succession at the same time a lot of DVSA testers left the service.
 
Since the big cull in testing quotas across the country, there are still ATF’s, waiting in vain, wanting to expand their operation to meet their original testing quota. There are  many other organisations who have already built fully functional testing bays awaiting DVSA to lift their restriction on new ATF’s.
DVSA maintain that
 
“ testing allocations are made on the basis of productivity. ATFs are invited to submit business cases to Network Business Managers when winning new contracts or experiencing increases in demand. Network Business Managers will consider all reasonable requests for additional allocations based on evidence.”
In many cases ATF’s delivering 85%-90% + had their testing allocations reduced by up to 50%. I personally had a 25% reduction despite circa 90% to 95% Capacity Utilisation (CU) and never received a factual explanation from DVSA. So their statement about productivity does not hold up.
That aside, there is a strong argument to suggest that the ‘productivity’ method DVSA employ reduces competition and quashes free market activity and therefore creates an ever decreasing testing environment. DVSA’s method is reactive rather than proactive. It protects their supply of testers because it significantly reduces flexibility on demand.
DVSA’s method (to submit a business plan) weighs too much on preserving the ‘norm’ and protecting DVSA from having to react to fluctuations of their ATF partners and their customers choice.
There is little weight, in the existing method, given to reward ATF’s who use a balanced risk approach by requesting more test slots as part of their business growth plans.
I would suggest to DVSA that continuing to employ these methods restricts speculation and competition. The incentive to succeed and offer a better service for your customers  is removed so the market just gets sluggish.
In free markets, a superior service is normally rewarded with more customers, so, high performing ATF’s requesting ‘proactive’ test allocation slots would get them be filled. Punitive measures for over capacity already exist, the ATF is punished with having to pay for slots not filled.
DVSA’s method turns normal competitive free enterprise on its head and treats all ATF’s the same, which is undemocratic and unfair.
The end customer experience is also negatively affected with DVSA’s method; Haulage operators who might otherwise move their ATF business to a better service offering, may not be able to, because its fleet size might mean there’s not enough volume to re-allocate a DVSA tester from one ATF to another to facilitate the move.
Of course you can argue, why all the talk about competition and speculation, as ATF’s are just testing vehicles, well, there should at least be some weight given to this argument because DVSA elected to partner with commercial enterprise where competition and service delivery balances the equation:
customer choice + service delivery satisfaction =  success
DVSA’s method appears to treat the customer as their commodity, where ATF’s have to ask permission to move them, this can’t be right. If that’s not the case then perhaps DVSA are using their ‘productivity’ method to preserve their supply lines because they don’t do flexible in the way free enterprise can. Either way it feels a bit arrogant and re-opens the conversation to privatise the industry.

ATF’s need a break not a diktat 

Since The ATF scheme was inaugurated in 2010-11 ATF’s have had to absorb a whole range of measures that have negatively impacted on our ability to operate a fair and efficient testing facility. To add to the misery, each time something else has been dumped on us by our DVSA partners we have not been remunerated for it.

Those of you mad crazy fools who jumped on board the ATF testing bandwagon in the early stages may remember the first fee consultation in 2011. How naive we were to think that our pit fee revenues would have been considered as part of the consultation process ….

It turned out that DVSA only managed to revise their own statutory fees but decided to leave their ATF partners fees out.

At that time, when I challenged him, I recall being caught out by a response from the previous head of The DVSA, Alistair Peoples, who quipped at one meeting I attended ‘it is not my responsibility to make ATF’s profitable’.

There was more than a hint of arrogance surrounding early DVSA decisions and it looks like the precedence had been set, especially if you consider the historic evidence since.

Time is money

In July 2014, DVSA revised some testing times on particular vehicle types. Some trailers increased from 20 to 25 minutes representing a 25% increase. So in real terms, if you were testing mainly trailers, this translated into a 25% reduction in ATF pit fee revenue in one fail swoop. Of course, ATF’s had no say in this decision, despite financing the ATF Testing scheme.

The methods used to measure the time it took to test led the industry to be somewhat bemused. DVSA management told the DVSA testers they were carrying out timing exercises so the testers knew they were going to be measured. From that point anyone could have forecast the results; it’s a widely known scientific rule that if the subject knows it’s being measured then the subject will react accordingly (more slowly in this case). ATFOA argued this point at the time and that ‘secret shopping’ measurements should have been used to gain real time records and experience of the ATF lane coal face, not laboratory re-enactments.

The timing exercise was critised by industry stakeholders for hardly being independent either, which cast further doubt over the results; The work was carried out by the Department for Transport’s own in-house analytical consultancy (IHAC).

More recently DVSA have announced, without consultation, that their ATF partners are to absorb yet more time and expense. This time round we have been told that ‘the setting up time’ is now to be carried out during our 420 ‘testing’ minutes.  The 420 minutes was contractually agreed to be utilised for testing, not ‘setting up time’.

ATFOA have yet to receive any feedback from ATF’s on this latest burden yet, but we have to again, question the arrogance of DVSA’s decision making that appears to assume that their partners can afford to utilise time that we’ve paid for testing to do their job. 

Furthermore it has been assumed by DVSA management that DVSA staff can be assisted by the ATF personnel ensuring that the necessary equipment and associated facility checks have been completed – but at whose expense?

To truly understand the point we’re making; One should consider what DVSA’s reaction would be if the ATF community decided to shorten test times of trailers, asked their staff to make our tea and then pay ourselves a bonus – all without consulting them. 

ATF’s were left out of the fee consultation in 2011, have absorbed increased test times (2014) and, more recently, absorbed ‘setting up checks’, during allocated testing time. If this isn’t challenging enough we should remind DVSA would have absorbed 9 years of inflationary pressure by 2020.

Inflationary pressures at the Bank of England average rate of 2.9%, would mean that if ATF test fees were reviewed annually (as originally stated) the £55 cap would now be £69.28.

Meaning ATF’s will be losing £14 per test because ATF’s have been left out, again.

On a normal test day, that’s loss of £141. If you’re testing 5 days a week that’s a £714 loss or £3000 per month.

Coupled with large reductions in testing allocations, these factors are hitting hard on The ATF community so ATFOA will be looking to DVSA to support their partners by reviewing the pit fee cap to help alleviate the financial challenges we are facing.

If the figures don’t alarm you, then perhaps we should listen to latest pattern of reports.

It transpires that some ATF’s are struggling to remain viable so they are looking for additional revenue to help sustain their ATF investment. Some ATF’s, we hear, are making it a mandatory charge to present third party vehicles for testing (instead of allowing the option for third parties to present themselves). Some haulage operators who have contacted us have quoted £120 mandatory presentation charge on top of the pit fee.

Whilst The ATFOA does not condone this practice, as presenting a vehicle for testing should be an option rather than mandatory, we fully understand the compromise some operators are having to make to support ailing test figures.

ATF’s exist in an environment where our partners:

  • Change the goal posts at will
  • Can afford to reward their staff £500 bonus 
  • Struggle to deliver a flexible supply of testers

So is it time that ATFOA ask for some more?

ATFOA believe it is.

One has to argue that a re-calibration of the pit fee is well over due. A consultation should be on the table to alleviate the challenges ATF’s have inherited.

Letter of the month

Having had several reservation requests declined I was advised by the DVSA ATF testers manager to make short term booking requests for days close to the declined ones, I put a request in, giving what I thought was a sensible lead time of 4 weeks.

A week later the short term booking request was declined as it was “too far ahead”, DVSA can only take short term requests that are no more than two weeks ahead.

This makes the short term booking request facility unusable for the following reason: If you were to put in a request for a test day in two weeks’ time, wait a week to hear from the DVSA,  that would leave you a week to organise a day’s testing, IMPOSSIBLE !

It appears DVSA are manipulating the short term requests so they can report ATF’s are not using the short term booking request facility.

 Have you had anyone else with similar stories ?

Many thanks

Allan Balsdon

Managing Director

Balsdons Vehicle Services

Do you have any correspondence, experience or opinion you wish to share? Please write in to atfoa@atfoa.co.uk

Kind regards  

Stephen Smith

 

The inherent problems with restricted testing

The ATFOA Board have been busy.

Following on from the formation of the Stakeholder Group in late 2017 we’ve continued our dialogue with DVSA and attended various round table meetings.

Our mission remains the same: to continue to work towards improving the ATF testing environment for our members and their customers.

The present innate testing environment is not of our making, yet we, as ATF owners, have to deal with the consequences of a restrictive market.

The reduced pool of testers has led to DVSA restricting ATF from testing to their previous capacity. It is common place to hear that many ATF’s have had their test allocation reduced by up to 40%. The financial impact has resulted in lost revenue and redundancies within the ATF community.

So, it was quite a surprise to discover the existence of an internal DVSA email that appears to extol the virtues of their success by awarding a bonus to DVSA staff.

Except from DVSA email

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

“By way of our thanks, you will receive a £500 reward to be paid in April, for you to spend as you wish.”

<<<<<<<<<<<<<<<<<<<<<<<<<<<<

Members have found the timing of a bonus for DVSA staff I’ll conceived considering DVSA have engineered a crisis whereby ATF’s have had their testing slots reduced; partly because DVSA have not been able to respond successfully to the supply and demand of ATF’s testing requirements, and partly because DVSA hadn’t forecast the impact to demand for testers by allowing over 550 ATF’s to open in such a short time.

ATF’s have had to make workers redundant and we would estimate hundreds of thousands in lost revenue for each ATF when you take into account the revenue received from pre MOT and preventative maintenance work etc.

It should be stated that there is no issue, in principle, for rewarding DVSA staff at the coalface for their hard work, but by comparison, there has been no recompense for hard working ATF’s who have had to bear the brunt of DVSA’s handling of the scheme.

ATF’s have absorbed administrative, real estate and management costs, as part of this partnership. Front desk ATF staff have had to bear the brunt of angry customers when DVSA testers were not turning up, on a daily basis.

The email continues

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

“Despite significant challenges, 2018 / 19 has been outstanding year for us in vehicles services, with all zones in excess of honouring 99.7% of all confirmed reservations at ATFs, comfortably exceeding our business plan target of 98%. This success is all down to your hard work, effort and commitment in delivering the best service possible on the frontline.”

<<<<<<<<<<<<<<<<<<<<<<<<<<<

It has been argued that DVSA’s statistics in the email are synthetic nonsense; One has to question how DVSA can rejoice their ‘honouring of confirmed reservations’ when they are also responsible for restricting the test allocations.

The statistics do little to help understand the real narrative. To rejoice honouring of tests is almost 100% when the tests have been restricted is a falsehood, it’s nonsensical. It’s like a third world shop keeper rejoicing that he’s sold all his bread from the shelves when the regime only delivered 1 loaf that day with 300 people queuing up outside.

When one entity controls both elements of supply and demand, the testing environment in this country will continue to suffer because it will always struggle to adjust to customer requirements and free market movements. The controlling entity will tend to preserve itself rather than allow the free market to flourish.

ATFOA – latest opinion.

DVSA are convinced that they can continue to recruit themselves out of the tester shortage, however, I understand the challenges of recruitment, first hand. I believe the struggle before them will not improve, however it can be mitigated by initiating ATFOA’s proposals.
 
The Earned Recognition project is exciting, especially as DVSA 5 year strategy – Section 2.2 – states that DVSA would  “look into the case for allowing exemplary commercial vehicle operators to test their own vehicles if they share their testing data with us”.  
 
As ATFOA’s proposals offer a plausible and practical opportunity to allow exemplary operators to test their own vehicles without any legislative change we are disappointed with DVSA’s lacklustre response to a solution that may help to reduce the effects of their tester supply problem.
 
Additionally, In the 5 year strategy – Section 6.2 Motoring services strategy – it says “As part of that strategy, we’ve committed to things such as: looking at the case for having more of our services (for example, large vehicle testing) provided by partner organisations.” 
 
I believe, an ‘all industry’ drive to help push ATFOA proposals over the line might just stop DVSA re-think the problem and prompt them into being more enthusiastic at progressing our proposals.
 
As no legislative change is required to test your own PSV, we are arguing that it would only take a little bit of ‘will’ from DVSA to realise that a carefully planned pilot scheme might just result in a successful plan being established to instantly resolve the tester crisis. We calculate up to 40 testers will be released to free up the other ATF’s being inhibited by the lack of testers. 
 
DVSA’s single minded plan to recruit themselves out of this crisis is extremely challenging because, amongst other things, DVSA tester pay grade is markedly low and the new contract is unfavourable for workers to consider joining.
 
Additionally, NGT has added to ATF woes; NGT has delivered the opposite to what was promised. 
 
Instead of flexibility, ATF’s have rigidity in a number of processes. 
 
  • Requesting future testing slots is more difficult, we used to be able to book a year in advance to help plan our fleets – now we are limited to just 3 months. Large fleet operators are finding it more difficult to spread the impact of bulk purchases because they are no longer guaranteed dates in the future. This is especially an issue now that test wait times are unto 6 weeks.

  •  Short term extra test requests are almost impossible. Previously, when ‘over time’ existed, the testers had an incentive to stay behind and test a few more axles.

  •  DVSA enforcement officers are no longer allowed to cover for testers’ absences’ so ATF’s often have no choice but to close for the day.

DVSA ‘Clearing House Concept’ Survey

In our January meeting with DVSA we discussed the “Clearing House Concept”.

DVSA conducted a survey in December 2017 to get ATF input into the idea of setting up a central system to advertise any spare or short notice available test slots to customers. 

ATFOA invites its members and industry stakeholders to take the survey.

DVSA are leaving it open so you can have your say

http://www.smartsurvey.co.uk/s/ATFBookingslotsFeb18/