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| Representation with reference to MoRTH Notification of 12.12.2019 on Vintage Cars
This is a representation to the Ministry of Road Transport and Highways (MoRTH), New Delhi, with reference to their draft notification no. RT/16017/2/2018-T dated 12.12.2019 for " Vintage Cars". The letter drafted by my friend Advocate Anand Parchure, an enthusiast, with the Sl. No. 8 added by me can be edited by individuals as desired as it will be in their respective names. The notification classifies all categories of two and four wheelers as "vintages" that are to undergo fitness tests once every 10 years by paying Rs 20,000=00 for the fitness test. Three wheelers and buses/ trucks with private registrations are not covered. Also a two wheeler owner cannot be equated with a four wheeler owner like for example a Lambretta 48 owner and a Rolls Royce owner both are to pay Rs 20,000=00 for the 10 year fitness. our representation takes care of such and other anomalies.
You may please send it to director-morth@gmail.com and jspb-morth@gov.in. Another email id (official) of the Director, MoRTH, New Delhi, is:- piyush.jain70@gov.in Also please follow it up by sending it to the postal address by Registered Post so as to reach them by 11/01/2020 (within one month wef 12.12.2019 as notified) Quote:
To,
The Joint Secretary,
Ministry of Transport and Highways,
Transport Bhavan,
1, Parliament Street,
New Delhi- 110001.
Dated
Subject: Suggestions/objections to the proposed amendment to the Central Motor Vehicle Rules,1989.
Sir,
I am a vintage motor vehicle enthusiast and having come across the notification dated 12.12.2019, proposing formulation of an order to be called as “The Regulation of Vintage Motor Vehicles Order 2019”, wish to register my objections/suggestions as under :
At the outset I appreciate the concern of the Ministry to regulate and prescribe guidelines for registration and effective utilization of vintage vehicles, which would also ensure protection of planet earth and prevention of pollution. It is however submitted that in order to achieve the said objective the said order is definitely laudable and however there is need to consider the following suggestions:
1. The proposed order fails to recognize privately registered trucks, buses, six wheelers and 3 wheelers. At the same time it completely ignores motorbikes, scooters and mopeds.
2. The order completely prohibits use of each vehicle on road on regular basis. It overlooks the fact that unless the vehicles are regularly used, they will not be kept in order and in operable condition. Restricting its use only on specified occasions would render the said vehicles useless and would expose the owner of such vehicles to harassment by R.T.O and Traffic Police.
3. The suggestion to appoint Vintage Motor State Committee is apparently superfluous and would empower them to act as super regulatory authority over and above the R.T.O authorities. This would give them unbridled, unchannelized and arbitrary powers to reject the registration of vehicles at their whims and fancies.
4. Assuming though not admitting that constitution of such committee is necessary, the Local Vintage Association should be given adequate representation excluding other private individuals from the said committee.
5. In so far as fitness test by such committee is concerned, they may be directed to consider that the vehicle is maintained in its basic/ original structure and modifications that may be necessary to make the vehicle operable may be ignored. The procedures to obtain a valid fitness certificate from the Motor Vehicles Department under extant laws needs to adhered to for future fitness tests. Since it is required, the spare parts of vintage vehicles are not available in India and procuring such parts (if available with manufacturer) from outside India would entail payment of astronomical duties. The said aspect therefore deserves consideration and relaxation.
6. The proposed requirement of having display of registration in a particular manner as suggested under the order is unworkable, particularly where such series are already allocated. Instead, the vintage vehicles can be allowed to maintain their original registration numbers but with a different colour combination. Use of different colour combination would make such vehicles distinctly notable and would make the registration procedure simple.
7. The registration fees prescribed to the tune of Rs 20,000 as blanket fee is also illusory and unworkable and also not pragmatic. The fee structure for a 10 year fitness can be as under:
Sr. No Amount of fees (in Rs.) Type of vehicles
1. 4,000 Trucks and Buses.
2. 3,000 Cars.
3. 1,500 Three wheelers.
4. 1,000 Two wheelers.
8. In this context, I am to also refer to the note from Mr Gautam Sen, Vice President, FIVA, Paris, (copy attached) dated 20/12/2019 also widely circulated in the media, who has expressed his concern over the neglect and apathy for the 15-50 year old motor vehicles in India by the officialdom and vintage elite alike. In many countries in Europe and in civilised western countries including the U.S., a 30 plus year old motor vehicle is regarded as “historic”. Those manufactured within our country are truly historic as industrial milestones, but we are generally apathetic towards the mass produced Indian motor vehicles. We fully concur with Mr Gautam Sen’s views when he says “In the United Kingdom, the population of historic vehicles, which are more than 30 years old, is 1.2 million, and is valued at £17.8 Billion (Rs 167,000 Crores)! Even if the worth of the historic vehicles in India is not a fraction of that, just imagine the opportunity lost cost of the 975,000 vehicles, which may get destroyed over the next few years? Most European countries, as well as the US (which has an estimated 25 million historic vehicles in the country) and several other nations recognise the importance and value of the world’s industrial history, and the fact that to keep these vehicles “alive” they need to be driven, even if occasionally. It is important for us as a nation to learn from them, and not from China, which has systematically destroyed its history at every level.”
I would hence like to add that by preserving the older motor vehicles that are 30 plus years old, not only are we creating a new class to add to our national wealth, but are also preserving our industrial history.
The proposed suggestions are made with a holistic approach and ensuring that rules and regulations are made in such a manner that the historic vehicles are preserved and heritage is nurtured.
I do hope and trust that the above suggestions would be taken into consideration in proper perspective to solely aim at the real essence of your notification dated 12.12.2019 for preserving our industrial heritage on wheels.
Yours faithfully
( N A M E )
Address
|
The draft notification is also appended for reference. Vintage vehicle draft notification 12.12.2019.pdf
Also quoted is a note from Mr Gautam Sen, Vice President, FIVA, Paris, France, dated 20/12/2019 , who has given his comments on the above notification:- Quote:
For enthusiasts of historic vehicles, the recent letter from the Ministry of Road Transport and Highways has spelled good tidings. Of course, the letter raises more questions than answers them, but at least the thinking in the government seems to be heading in the right direction. The fact that there are more than a billion automobiles on Planet Earth, contributing to almost 75 percent of carbon monoxide emissions, is a piece of data, which cannot be denied. In congested cities, automobiles could contribute to over half the emission in certain cases, and this is reflected in the fact that Indian cities are some of the most polluted in the world.
Most of the major cities of the world are instituting the concept of Low Emission Zones (LEZs) for their cities to bring down pollution and improve the deteriorating health situation of its citizens. This is brought about by restricting the use of vehicles, more specifically, the older ones, as they pollute more. For instance, Paris does not allow vehicles older than 20 years to ply in the city during peak hours – from 8am to 8pm during the five working days of the week.
Initially the plan was to ban the use of all vehicles above the age of 20 entirely, through the week. The Fédération Française des Véhicules d’Epoque (FFVE), which is the federation that unites all the clubs (979 of them), museums (46) and professionals (354) in France, as well as the enthusiasts (some 250,000 of them, owning over 800,000 vehicles), with the help of FIVA, approached the mayor of Paris. The mayor was also made aware of the fact that UNESCO had recognized FIVA as a non-governmental partner. After detailed discussions and representations, she was convinced that the ban should be, at most restricted to 12 hours (8am-8pm) per day, for the five working days of the week, when traffic is at its maximum.
The mayor of Paris, as well as most government authorities in Europe recognise that automobiles above the age of 30 years cannot be one, which is in use extensively, and thus realise that the extent to which historic vehicles pollute is indeed minuscule. At the same time, there are restrictions to vehicular age of commercial use automobiles: for instance, taxis in Paris cannot be more than seven years old. (Though the figure for Paris have never been computed, it may be worth noting that the population of the commercial use vehicles in Beijing used to be three percent, but contributed to 38 percent of vehicular pollution in that city. By electrifying this fleet, Beijing has been able to address its pollution problems markedly.)
FIVA and the historic vehicle movement in Europe realise that with LEZs cropping up everywhere, what would happen to vehicles between 20 and 30 years of age (all the cars between 1990 and 2000, for instance)? Many will migrate to the countryside. Otherwise, people will keep them in storage and use occasionally during weekends or out of the city. The German federation ADAC has managed to get a different classification and recognition for the 20-30 years-old vehicles as Youngtimers.
The 15-50 years gap in the Indian system – as proposed by the ministry – will be terrible for all historic vehicles in the 30-50 years lot, and a significant chunk of India’s historic vehicles are amongst them. Of course, when the phrase historic vehicles is used, it implies all vehicles which are more than 30 years of age, and by that definition would include all the early Maruti 800s, the Hindustan Contessas, the Standard 2000s, as well as Kinetic Hondas and Yamaha RX100s. In Europe, much greater importance has been for the vehicles manufactured within the country – these are the vehicles, which are truly historic for the country. Unfortunately, many of the elitist enthusiasts in India tend to dismiss our own history.
Though figures are not available it has been estimated that around 20 million vehicles are more than 15 years old, in India. Of these, it may not be amiss to assume that, at best, only five percent are more than 30 years of age, which would still be as many as a million cars and two-wheelers (the latter perhaps representing more than three quarters of the total). Yet the numbers for the total fleet, which is more than 50 years of age, probably falls to just 25,000, at most. Which would mean that as many as 975,000 vehicles are in peril.
It may be worth noting that in the United Kingdom, the population of historic vehicles, which are more than 30 years old, is 1.2 million, and is valued at £17.8 Billion (Rs 167,000 Crores)! Even if the worth of the historic vehicles in India is not a fraction of that, just imagine the opportunity lost cost of the 975,000 vehicles, which may get destroyed over the next few years? Most European countries, as well as the US (which has an estimated 25 million historic vehicles in the country) and several other nations recognise the importance and value of the world’s industrial history, and the fact that to keep these vehicles “alive” they need to be driven, even if occasionally. It is important for us as a nation to learn from them, and not from China, which has systematically destroyed its history at every level (something that they recognise today, even if it is too late for certain aspects).
The most important learning from Europe and the US is that to discuss, present and convince government and authorities, it is important to have one voice, one set of criteria and standards, one cohesive story to tell and explain, instead of a set of diverse, often contradictory, objectives and points of view. It is also important that the representation made to the government reflect the desires of every enthusiast, and not just that of a handful of the bigger collectors, as this hobby mustn’t be seen to be the exclusive preserve of the wealthiest. FIVA’s past president Patrick Rollet had just three historic vehicles. Tiddo Bresters, the new president has one better – he has four of them, but all are VW Beetles.
As of the time of writing this, we are still the world’s biggest democracy. A democratic representation of the wishes of the enthusiasts, with a democratic process followed in heeding and deciding on the rules and regulations of the use of historic vehicles may go a long way in bringing about an intelligent and sensible solution to preserving our motoring heritage. At the same time, address the serious issues of emission and the wellbeing of all Indian citizens.
- Gautam Sen |
Last edited by anjan_c2007 : 31st December 2019 at 21:23.
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31st December 2019, 21:13
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