If it is already registered with the DVLA and has been issued with a registration number and, you do not intend to use it for ‘hire and reward’, then probably not. However, if you want to use your limousine for private hire, rather than just for weddings, then in all likelihood, your local licensing authority will insist that the vehicle has an SVA. In fact, it does not just stop there, but this will be covered later. If you have yet to buy a stretched limousine, then the best advice that can be offered is to ensure that it already has an SVA, if on the other hand you already have limousine that does not have an SVA and, you want to register the vehicle for private hire, then you need to consider arranging for a voluntary SVA.
In the past, it was possible to register a stretched limousine without the need for an SVA, simply by registering the vehicle as a 10 seat limousine. This is no longer possible. Now as a consequence of the amendments contained in the Road Safety Act 2006, from 1st January 2008, all stretched limousines that are to be used for hire and reward, will have to either be registered with the local authority for Private Hire or be registered as a Public Service Vehicle, which also requires the owner to have obtained a Public Service Operators Licence. Limousine companies operating within
Section 53 of the Road Safety Act 2006 introduced an amendment to section 75(1) of the Local Government (Miscellaneous Provisions) Act 1976, covering hackney carriages and private hire vehicles in England and Wales (excluding London which is covered separately), whereby paragraph (b) was omitted. It was this paragraph that originally allowed limousine operators to operate without a Private Hire Vehicle licence or Public Service Operators licence. Because the
Whether or not a vehicle has an SVA has gained significance because most local authorities will not register a limousine unless or until it has an SVA. If you already own the vehicle, then fortunately, you can apply for a retrospective SVA, known as a ‘voluntary SVA’. However, it is possible that you may have to complete some additional conversion work before the limousine will be accepted for an SVA and the best advice here is to go to a specialist.
Another issue that will come into play if you wish to apply for a voluntary SVA is whether or not the vehicle was built by a coachbuilder, who was approved, at the time of manufacture, by the vehicle manufacturer. The most popular limousine is the Ford Lincoln and this should have been built by a coachbuilder that was as authorized QVM (Lincoln Qualified Vehicle Modifier) coachbuilder. Another limousine, very rare in the UK is the Cadillac; they have their own programme CMC (Cadillac Master Coachbuilder). Provided the limousine was built by an approved QVM or CMC coachbuilder, then as SVA should not be particularly difficult. However, it should be remembered, that as with any test, no two examiners are likely to have the same opinion of each and every issue. Compliance, therefore, will always be fraught with inconsistencies.
It should be noted, that whilst some of the latest Chrysler 300 stretched limousines have an SVA, many do not and because the manufacturer has not approved the vehicle to be stretched, it has no comparable programme to the QVM and CMC. This does not exclude it from obtaining an SVA, nor does the fact that a limousine was stretched by a non-approved QVM or CMC coachbuilder; however, it does make it much more difficult. This is because VOSA will insist that a great deal of technical information is provided, some of which may be available from the coachbuilder, but the majority will not be available and if you have to provide the data yourself, there is a very real chance that the cost would exceed the value of the vehicle.
The safest bet, if you intend to apply for a Private Hire Vehicle Licence, is to ensure that you only buy a limousine with an SVA and if this option is not available, then at the very least, don’t but a vehicle that has not been built by a QVM or CMC coachbuilder. If you already own the vehicle, then you need to talk to a specialist or the NCLA (National Limousine & Chauffeur Association), who may be able to offer advice or assistance.
If you haven’t purchased a limousine at this time and it is your intention to Licence the Vehicle for Private Hire, then the best advice is to be guided by your local licensing authority. With over 400 separate authorities across the country, interpretation of the rules varies and some may be more lenient than others. If you disagree with their interpretation, you are entitled to appeal, but this process can be time consuming.
Most, but not all, local authorities will not approve under any circumstances a Hummer, Excursion or Navigator even if these have been issued with an SVA (unlikely) or have undergone and passed the Schedule 6 conversions. If you intend top operate of buy one of these vehicles, then it would probably be more appropriate to apply for a Public Service Operators Licence and register the vehicles as Public Service vehicles, however, it must be borne in mind, that to carry more than 8 passengers, the vehicle must have a COIF (Certificate of Initial Fitness). Whilst not impossible, there are very few vehicles that have achieved this status and those that have will have a price attached to them that directly reflects the considerable investment that is required to achieve this certification.
The information herein is provided in good faith, rules and regulations can and do change, as with all advice, you should complete your own research and satisfy yourself that you have all of the facts before making any decision. The author of this article accepts no responsibility for any errors or omissions contained in this article. For the most up to date information, readers are urged to make contact with the National Limousine & Chauffeur Association or contact any of the bodies referred to in this article.
Cars for Stars Limited is the largest limousine franchise network in the UK providing start-up assistance, support and advice for franchisees.
