HAS THE LOW VOLUME VEHICLE SYSTEM FAILED?

The Low Volume Vehicle System has failed in the following:-

The LVVTA have failed to develop and maintain LVV Standards- SEE- ORS Submission2
The LVVTA are failing to maintain an acceptable standard of safety of vehicles modified. LVVTA DANGERS- THE FACTS
I understand that another Coroners report is pending, concerning a fatality resulting from the failure of an LVV Certified trike.

QUESTIONABLE OPERATION OF THE LVVTA

Here are two examples of the sort of questions that do need to be asked and answered before a way forward for the LVV System can be found:

QUESTION 1 How can the NZ Transport agency justify allowing the LVVTA to make Certification judgements?
The LVVTA have a contract for ‘Desktop Auditing’ to ensure LVV Certifiers are meeting the LVV Standards, however the LVVTA appear to be making Certification decisions under this guise.
We can see no provision in any legislation authorizing NZTA to allow this.

QUESTION 2 On what basis does the LVVTA assume that their knowledge is superior to that of the LVV Certifiers? None of the LVVTA Staff are LVV Certifiers, and do not even meet the requirements for many categories. Yet experienced LVV Certifiers have their judgement questioned, are required to accept the judgement of the LVVTA, and are reported to NZTA for ‘incorrect’ decisions. Several recent incidents have proven that the judgement of the LVVTA can be seriously wrong.

CONSEQUENCES
The LVV system is failing to retain the skilled Certifiers
on which integrity and safety of the system depends- such as-

( Names removed by request )

LVVTA are now slanderering these ex-Certifiers, calling them ‘Rogue Certifiers’ and ‘safety risks’ instead of recognizing them as outstanding, highly regarded Certifiers whose experience is a major loss to the system.

THE LOW VOLUME VEHICLE SYSTEM HAS LOST THE ABILITY TO CARRY OUT HIGHER LEVEL CERTIFICATIONS, BECAUSE

A ….. LVV STANDARDS COVER ONLY VERY BASIC MODIFICATIONS.
B ….. THE SKILLED AND QUALIFIED CERTIFIERS HAVE LEFT THE SYSTEM, REPLACED BY ‘HOBBYIST’ CERTIFIERS.

The LVV system is reverting to just a low-level ‘hobby car’ certification system.

Emergency appointments of Certifiers from a ‘Hot-Rod’ background lacks credibility, because:-
1…..’hot rod’ experience in no way qualifies a LVV Certifier to deal with the range and complexities of modern automotive engineering.
2…..a Certifier who is beholden to the LVVTA lacks the independence required by the deed of appointment.

The LVV system is failing to meet the needs of vehicle modifiers– the number of Certifications is falling whilst the number of vehicles and the number of mods needing LVV Certification are rising-

1…….Abandoned Certifications We receive continuous enquiries for LVV Certification, from all over New Zealand.
We give out the phone numbers of other Certifiers, we even contact them ourselves on behalf of customers.
In the end, we are left with sheaves of job-sheets, for vehicles which WILL NEVER BE LVV CERTIFIED

2……Modified cars exported- We are aware of many modified and scratch-built vehicles EXPORTED to avoid the LVV system in NZ

3……Modifiers leaving the business- We are aware of PROFESSIONAL MODIFIERS (many with export business) who have CLOSED THEIR BUSINESSES or moved out of NZ.

U Drive Mobility are one recent example of this- now building in France

4…..Avoidance of LVV System Motor-home builders IN NEW ZEALAND switching to Certification to ADR Second Stage system, to avoid the costs, delays, and irregularities of the New Zealand LVV system. Private modifiers are being forced to drive vehicles without LVV Certification

5……Soaring costs-
The LVVTA levy, has increased, with more increases anticipated, as legal and insurance costs start to bite.
LVV Certifiers have increased their charges to cover time they now require to process Certifications.
In Auckland the total cost to the customer for LVV Certification has increased by an average of 25% in June 2014.

This means that to LVV Certify say, a set of wheel spacers, or adjustable platform suspension struts, will now cost the vehicle owner $550 to $650, which could exceed the cost of the modification.

If NZTA loses faith in the LVV System, (Quite likely)
it is possible that:

1 … Minor Modifications: TSD agents, or WOF agents be authorized to pass a range of minor modifications

2 … Self- Certification: Professional Modification businesses (seat installers, motor-home builders etc) be accredited to Self-Certify

3 ….Hobby cars and Hot-rods– (a very small part of the LVV picture) could be left out in the cold, are unable to be driven on the road.

4 …. The LVVTA and LVV Certification plates become history.

IS THIS THE FUTURE WE WANT?

How about some clear thinking about the LVV System of the future?

1 Trust the Certifiers to do the job they are appointed to do. Cut LVVTA out of the Certification process. Allow Certifiers to make their own plates, or use a Certifier appointed Plate printing contractor.

2 Introduce proper “Certifier Training”, conducted ‘on line’ and on the job, by Certifiers or Industry Professionals, (not by the LVVTA) and allow proper technical debate to occur.

3 Allow Certifiers to Certify to proven International Standards if they choose, instead of faulty LVVTA Standards.

4 Form a Certifier controlled “Standards Committee” to develop and change LVV Standards, instructing LVVTA to print and distribute.

5 Simplify Certifier Categories to say “Mechanic based Certifier” (able to do most certifications) and “Engineer Certifier” for situations where the skills of an Engineer are required. Allow “Engineer Certifiers” to consult to “Mechanic Certifiers” when required.