Consultation on charges for the removal, storage and disposal of vehicles

As previously stated, the fairest for all parties Would be a Scenario based system.

Perhaps this approach is not ideal for everyone, however this is a proven method used in England and in the main works well. It is however important to emphasise the matrix used in England has not been subject to any form of review and therefor the rates charged are the same today as they were in 2008 when it was introduced. Had it seen at the very least a 3% annual increase the rate today would be £201.59. The SPA proposals must attract an annual review, both for its charge out rate and its operating performance. It’s also important to consider when the Scenario charging was rejected in Scotland back in 2011 it was working on a rate of £150.00 basic charge (as was in England at the time) If this was subject to review it would have been £163.91 The SPA proposed rate should be £202.00 and not the proposed £190.00

If dealing with a fatality then other factors should be considered, mainly the considerable time the operator has to spent at scene, so an hourly charge should be factored in. Also, there are times where a vehicle might be off road by some considerable distance, these cases should again factor an allowance for additional time spent dealing with the incident.

It is often the case that different displaced loads have to be dealt with in different ways, for example Refrigerated Truck on its side with Swinging or Hanging Beef, a very expensive load and something that requires considerable care and effort to ensure the load is still fit for human consumption once the job is finished. A second example, a Milk Tanker with its load spilling into the water table, a huge problem for the water board and public health authorities, the cost to contain the load is very expensive and a cost re-charging arrangement is required.

The list is endless, and the statute must allow for the operator to negotiate these very special and avoidable charges, no matter who eventually payes the bill.

The SPA Description of Significant Damage appears reasonable.

We have an in-depth scenario-based system using the same category selection as your annex E, we have reviewed the matrix against experience within the UK and applied the necessary APR Increases, there is no function to upload a document, we hope you can apply the obvious column index’s or please email a request and we will happily provide this separately.

We have an in depth scenario based system using the same category selection as your annex E, we have reviewed the matrix against experience within the UK and applied the necessary APR Increases, there is no function to upload a document, we hope you can apply the obvious column index’s or please email a request and we will happily provide this separately on the registered email Address.

1 2 3 4 5
£202.00 N/A N/A N/A N/A
£202.00 £335.00 £470.00 £470.00 N/A
£403.00 £873.00 £2,688.00 £4,032.00 N/A
£470.00 £873.00 £4,032.00 £6,048.00 YES
£335.00 £505.00 £1,344.00 £2,016.00 YES
£335.00 £505.00 £2,015.00 £2,687.00 YES
£470.00 £1,142.00 £4,032.00 . £6,048.00 YES
£470.00 £1,142.00 £6,048.00 £8,064.00 YES

Parking & Storage

£14.00 £28.00 £3.00 £41.00 £47.00

The Scenario charging table should be used for all cases, where the scenarios are impractical, for example an overturned fuel tanker, where the fuel must be pumped off first and very specialist equipment used, a special agreement with the insurer or customer paying the bill should be allowed as part of the statute.

Statutory charges are exactly that, a charge to perform a role as stated by statute, any administration cost borne by the administrator should not be part of the statutory charge. The cost of the managing agent should be kept separate. The admin cost associated to the dispatching process should then be a separate contractual arrangement with the recovery agent, this cost should be capped to stop abuse of the system by the managing agent. The cost associated to the statistical function, a requirement the SPA needs should be paid by the SPA and not the recovery operator. This could be as simple as a set management fee, say £30.00 split 2/3 recovery operator to pay and 1/3 SPA = £20 R/O and £10 SPA.

As the subject of Statutory Charges is now being tackled, it is important the finer detail of the statute is applied properly, this means the correct handling of VAT and the payment of Statutory fees into the SPA fund, and the operator being paid for every job according to specific scenario. The recovery operator should then Invoice the SPA and then be paid directly by the SPA.

As the subject of Statutory Charges is now being tackled, it is important the finer detail of the statute is applied properly, this means the correct handling of VAT and the payment of Statutory fees into the SPA fund, and the operator being paid for every job according to specific scenario. The recovery operator should then Invoice the SPA and then be paid directly by the SPA.

This is a very good point and lessons learnt so the SPA does not fall fowl of the same problems. A distinct lack of knowledge of the police officer dealing with any specific incident. The need for an officer to invoke his powers of removal is abused on a daily basis, the same applies within the SPA and is part of the reason this consultation is necessary. A vehicle removal should only be classed as a statutory removal when the vehicle is of interest to the police, or it is causing an obstruction, possibly in a dangerous place. Outside of this and the removal should be classed as an owner’s request and the owner should be at liberty to find his own recovery operator to carry out the recovery. It is often the case in both England – Wales and Scotland where the owner makes his own arrangements, the recovery vehicle arrives on scene only for the Police to turn them away and unnecessarily use his powers of removal.

Secondly and a point raised answering other questions is review process, England & Wales we promised an annual review, this has never been done correctly and as a result the scenario rates are now ten years out of date and a huge hurdle to overcome bringing them back in line.