I received this from a friend. The ***SUMMARY FROM MYSELF*** is apparently from a person at Lovells.
***STATEMENT FROM LOVELLS AUTOMOTIVE SYSTEMS 22/08/2018 8:43AM***
On the 21st August 2018, the QLD Government over turned QLD TMR’s decision to release new vehicle modification codes (LS11 and LS15), which were due for release to the industry on the 4th September 2018. Changes in these Modification codes included the banning of Towing Capacity Upgrades on in-service vehicles, banning of axle capacity increases on in-service vehicles, banning of GVM Upgrades on in-service vehicles which had previously been upgraded by another jurisdiction/State and/or brand and banning of GVM Upgrades on in-service vehicles which had previously had active SSM Approvals, which are no longer manufactured (eg. Nissan Patrol Y61 and Toyota Hilux KUN125/126).
The Government will now not introduce planned regulation changes on 4 September, but is not backing down from its position of re-instating GCM (Gross Combined Mass) revision on in-service vehicles.
While GCM revision is still legally available on brand new vehicles in QLD (and all States) and legal/recognised on in-service vehicles for all other States except NT, towing upgrades will remain of virtually no use in QLD because the Government will not allow an increase in the GCM (combined weight of the vehicle and its trailer).
Despite the Premier’s assurances on the morning of 21st August that the Government would absolutely reject any changes that disadvantage Queensland drivers, they are already enforcing a disadvantage.
TMR QLD have advised that their stance on GCM revision will be discussed and reviewed in due course.
Meantime, at a Federal level, Lovells wish to confirm the following which was uploaded to the RVCS website (Federal Dept of Transport and Infrastructure) on 3rd August 2018.
Of note in this, which is listed at the following (infrastructure.gov.au/…/rvcu-2018-August-issue-3.as…)
Administrator's Circular 0-4-6 (Issue 4 June 2018) Administrator's Circular 0-4-6 (Certification of vehicles which have undergone a second stage of manufacture) was amended in June 2018 following industry consultation. The circular was amended to include arrangements for Second Stage Manufacture (SSM) Light Vehicles that have been subject to a Gross Vehicle Mass (GVM) upgrade under Clause 10—and formalise current business practice for GVM upgrades to light vehicles.
• The guidance provided by the Circular 0-4-6 applies to NA (GVM up to 3.5 tonnes) and NB1 (GVM over 3.5 tonnes and up to 4.5 tonnes) category vehicles.
• The revised circular only applies to new applications and new amendments to existing Identification Plate Approvals (IPAs).
• The Circular will not affect the existing IPAs held by the second stage manufacturers. Existing IPA holders can continue to supply (to the market) vehicles covered by the approved Road Vehicle Descriptors (RVDs). This includes vehicles where the approved RVD has variants that exceed the first stage manufacturer's Gross Combination Mass (GCM) rating or Rated Towing Capacity or Maximum Braked Towing Mass rating. The second stage manufacturers need to ensure that the current approved RVDs refer to the current approved RVDs for the first stage manufacturer.
• The option of GCM or towing capacity upgrade may be available to consumers in some state and territory jurisdictions, after the vehicle is supplied to the market.
In conclusion, we confirm that there is no change to existing SSM Approvals. Any vehicles (as stated in current SSM Approvals and as noted on current RVDs) can still be plated with GVM Upgrades and Towing Capacity Upgrades (BTC upgrades) under the approved RVD. Thus Lovells SSM Approved kits can continue to be supplied.
The implementation of Administrator’s Circular 0-4-6 is effective for all future IPA Approvals. That is, any SSM Approvals applied for beyond the current valid and active SSM Approvals.
Lovells GVM/GCM/Towing Capacity or variants of these modifications remain 100% legal in all States and Territories for all vehicles in service/previously modified.
Lovells GVM/GCM/Towing Capacity or variants of these modifications remain 100% legal in all States and Territories for all vehicles when modified prior to first registration (Federal Compliance).
Lovells GVM/GCM/Towing Capacity or variants of these modifications remain 100% legal in all States and Territories, other than Queensland and NT, for all vehicles when modified after first registration/in service vehicles (State Compliance). State based GCM modifications are governed by the State Authority and their individual Type Approvals or Modification Codes.
Lovells GVM/GCM/Towing modifications have always been legal and we have always strived to ensure compliance with the Federal, State and Territory Regulators.
The whole point of GVM/GCM/towing upgrades is to ensure the ongoing compliance and safety of vehicles and occupants when carrying/towing heavy loads and thus ensuring the safety of other road users.
Despite false reports in some forums and competitor press releases, safety is not an issue. SSM Approval holders can attest to and advise categorically that there is no evidence of any safety issues, accidents or fatalities due to or related to any GVM/GCM/Towing Upgrade.
• PRE REGO there is no change in plating vehicles with GVM & Towing Upgrades. GCM as defined by the SSM manufacturer • POST REGO vehicles can be plated with GVM upgrade. The Towing and GCM upgrade would be supported and approved via State Authorities and state based signatories.
• The implementation of 0-4-6 is for all future SSM approvals
***SUMMARY FROM MYSELF***
The GCM and BTC upgrades have been brought into the market because 1. A vehicle will exceed its GVM with the ball mass of a large towing apparatus added – and/or 2. The GCM of a vehicle will be exceeded because not all vehicles GCM are calculated with GVM+BTC – and/or 3. The axle capacities of a vehicle will be exceeded with the ball mass of a large towing apparatus added. Additionally, another key reason why the towing upgrade was brought into the market is due to caravan manufactures producing a caravan that has (for example) an ATM of 3500kg but its tare weight may be up to 3400kg or often above the issued ATM itself – which is a huge problem for a vehicle rated to 3500kg towing capacity. The fact is vehicles have been legally impractical (from a payload point of view) since vehicles existed, we can all agree that the older generation willingly knew and towed illegally because that is the way that it has always been.
Times have changed, society is much more focused on safety, and insurance companies will always look for a way out of paying out a claim (as they should). Now people seem to be aware of this issue due to the publicity around it – which is fair enough people want to be legal. Everyone seems to have forgotten about the most significant loser out of this is the end-user. The retired generation, tax paying citizen with their dream car and caravan that want to be legal. These people want their $100,000 motor vehicle and $100,000 caravan to be legal which now solely due to TMR is not possible.
We are aware of many members of the public that have placed orders for 3.5tonne towing apparatuses and/or 4.0tonne towing apparatus with the intent of utilising their current vehicle to tow these applications. These individuals have purchased their new caravan builds based on the fact that the Lovells GVM, GCM and BTC upgrades exist and now as a result are unable to tow legally or locate a replacement vehicle that can tow legally. This will cause huge financial hardship for the people affected by this which clearly is directly caused by TMR QLD.
We also can’t imagine the impact to the tourism industry in Queensland when this group of people from other states who may not completely understand the impacts of the proposed legislation and possibly start avoiding Queensland as a destination.
The list of problematic vehicles is across the board. To name just a few of the more commonly known vehicles – VW Amarok V6, Isuzu D-Max, Holden Colorado, Ford Everest, Mitsubishi Pajero, Nissan Navara, Mitsubishi Triton, Toyota Hilux, Toyota Prado, Toyota Landcruiser 76, 78 & 79 series. All of these vehicles state a maximum towing capacity of xxxx kg, however when attempting to use all of this towing capacity the vehicles GVM and/or GCM and/or axle capacities will be exceeded.
The SSM accepts full liability and responsibility for all these modifications carried out and there is no evidence of an incident or fatality due to these upgrades.
TMR QLD has been speaking of universalising State Legislation for over 20 years. The fact TMR are not allowing GCM upgrades post-registartion contradict practices in most other States and Territories where GCM upgrades are able to be carried out post-registration. They appear to be in direct contradiction to the Federal Government’s VSB14, which exists solely to allow GVM/GCM/towing upgrades to be undertaken safely.