Written evidence from Fourdot Affinity Ltd (GMA0008)

 

 

Overview

Fourdot is a new (2012) British start-up company founded to innovate the manufacturing and design of UK vehicle licence plates with sales made exclusively on-line.  As a regulated product we have interacted with the DVLA and other Government Agencies.  Until recently our attempted interaction with the DVLA requesting licence plate Proof-of-Entitlement compliance improvements was fruitless.

 

In January 2014 a much delayed review of the BS AU145 technical standard appeared to be coupled with a fundamental review of the DVLA Registered Numberplate Supplier regime, with overall responsibility formally centralised with the DVLA.  Since this change substantive DVLA interaction with Fourdot has begun, with the first signs being encouraging.   

 

As new market entrants and first-time users of the BS AU145d standard we became very concerned at its inadequacy and the way it was being reviewed for the first time since 1998.  To date we have failed to establish who is responsible for scoping and controlling the BSI review.  Unless such reviews are assigned to whoever is responsible for the UK number plate regime, now the DVLA, it is our opinion that many number plates products will not, over the normal life expectancy of the plates, be suitable for reliable ANPR imaging.  This reduces Police ANPR forensic effectiveness and risks Vehicle Excise Duty (VED) compliance in a paperless environment.  From what we have learnt the present interaction process with the BSI is not working in the interests of either the consumer or the enforcement authorities.  Instead it serves vested commercial interests.

 

 

 

A summary of Fourdot’s requests to the DVLA:

 

  1. To make validated, on-line purchasing of vehicle registration plates possible without the customer mailing original documents, by using on-line access to DVLA Keeper data.

 

  1. To make on-line supply more secure and respectable in the eyes of the public by operating a zero-tolerance approach to the supply of miss-spaced plates, known as Showplates, and deterring customer purchase from unregistered cross border suppliers.

 

  1. To increase the longevity of ANPR visible plates by raising quality and production standards.  This will require the introduction of more demanding qualifying standards for manufacturers wishing to be authorised to supply.

 

  1. To fundamentally review the control, constitution and transparency of the BS AU 145 review panel and then re-specify the scope of the current review.

 

Issues Background

 

  1. Secure, validated on-line plate purchase

 

Consumers are discouraged from on-line plate purchasing as, officially, the originals of a Proof of Entitlement and Identification documents has to be provided by mail, with the attendant risks and temporary loss of, usually, a driving licence.  Unofficially some DVLA registered on-line suppliers have been accepting scans of these documents by email for years.

 

An on-line DVLA query using the Vehicle Registration Mark (VRM) will validate a match between the Registered Keeper and their address, when compared with the Customer’s name and despatch address.  The on-line purchaser information provides an automatic ID audit trail.

 

Such simplification of the customer experience, with a 24 hour lead time, should stimulate higher quality, more competitive manufacturing companies, supplying nationally.

 

Recommendation 1.  Request the DVLA to expedite the introduction of on-line validation for all qualifying and registered suppliers.

 

  1. Industry Image Improvement – Deterring Miss-spaced Plate Suppliers

 

Miss-spaced plates (hereon after called Showplates) are not innocent fun.  By changing the character groupings, or syntax, ANPR software can fail to determine either the UK or Schengen zone Country in which a vehicle is registered, as required by the Home Office ANPR NASP standard.  This either leads to a discarded ANPR misread or wasted police time pursuing an innocent UK motorist.  Miss-spaced plates can also encourage strategically placed black fixings, deliberately intended to change the registered character for another character.  Obviously this results in ANPR misreads or the penalising of an innocent motorist. 

 

Knowledge that Showplates cause misreads coupled with unchallenged easy supply from both within and outside the UK is of great assistance to those who wish to escape detection.

 

Recommendation 2.  The DVLA should strengthen its relationship with currently some 39,000 active registered number plate ‘manufacturers’ by replacing its once-off £40 registration fee with a Licence Agreement.  One of the terms should explicitly prohibit the manufacturer from producing any number plate product showing the VRM in a non-compliant form to BS AU 145.

 

  1. Improving plate quality to reduce long term ANPR misreads.

 

An inadequate BS AU 145 standard combined with products designed for ‘casual’ assembly by thousands of motor traders, results in plates that can delaminate, stain and lose retro-reflectiveness over time. The result is eventual ANPR impairment.  The police lack the resources to challenge the owners of such plates so it is obviously better to solve the problem at source.

 

The concept of convenience with just-in-time plate assembly has resulted in some 39,000 registered suppliers.  Using component sets from just 8-9 major UK suppliers, many workshops produce a few pairs of plates a week using low cost equipment and an employee who is ‘free’ at the time.  Components carelessly laminated one or two millimetres askew will result in long term water ingress.  Micro scale, part time ‘manufacture’ as an adjunct to trading motor vehicles cannot achieve the same quality control of a dedicated plate manufacturing business providing a product warranty.

 

Controlling ‘unauthorised’ assembly in, for example, small second-hand car dealerships is difficult to say the least.  Legal record keeping will, in all probability, never be checked through lack of DVLA or Police resources.

 

Cloaking a vehicles identity has never been more ‘useful’ to criminals and tax evaders. The current ease of plate supply via ‘back street’ enterprises needs to be stopped.

 

Recommendation 3. The DVLA should phase out the registration of mass, local component assemblers by adding conditions to a new Manufacturers Licence Agreement (proposed in Recommendation 2 above) along the following lines:

 

  1. Quality standard ISO 9001 certification must be achieved within 12 months of initial Licensing.
  2. Plate manufacture must be the principal business of a British limited company and represent more than 50% of annual turnover. The minimum share capital should be £10,000.
  3. A minimum annualised supply level (to be specified) of plates must be achieved within 24 months of Licensing.
  4. Plate entitlement validation must be carried out on-line by DVLA query.
  5. Plate manufacture, against a specific VIN number, should be recorded in a data format suitable for upload to the DVLA as required.
  6. A Manufacturers BS AU 145 compliance certificate showing the Vehicle Registration Mark should be issued with each pair of plates.
  7. All plates to be guaranteed against delamination and water ingress for a minimum of 3 years.

 

  1. Inadequate BS AU 145 standard (current revision d)

 

AU 145 covers the physical characteristics of licence plates including reflectivity, accelerated weathering and graphical content/presentation. 

 

The current review, which has been running for two years, has a secret brief, has secret panel membership, is funded with public money and, in our opinion, is non-compliant with BS 0, the British Standards Institute’s own standard of conduct.  Government supervision is unknown.

 

As a new, fresh and serious user of the AU 145 standard, our offer to serve on the panel was refused on the basis that ‘The Trade’ would be consulted on the draft. ‘The Trade’ we define as the 39,000 registered Suppliers.

 

We do know, as one of them, that ‘The Trade’ at large was not consulted on the withdrawal of BS AU 145 testing by BSI in November 2012.  With no other accredited testing authority in the UK for AU 145 the bald facts are that anyone challenging the construction of a plate on the grounds of physical non-compliance with AU 145 will have to pass the plate between several specialist testing houses and part with around £20,000.  BSI advised us that BS AU 145d (and therefore any revisions) is now a self-certification exercise.

 

‘The Trade’ that were consulted on the cessation of testing were the members of The British Numberplate Manufacturers Association or the BNMA.  The same BNMA that advised that they would only help us or consider us for membership if we could prove that we were manufacturing 300,000 pairs of plates per annum.  Clearly this is not a conventional Trade Association which would be expected to assist new entrants and encourage shared knowledge and innovation.  With only their 7 or 8 manufacturing members meeting the membership criteria BNMA is a ‘specialised’ kind of Association.  It is the only body that the Government, to date, has listened to and, by unofficial account, two of their members are the only Trade Representatives on the AU 145 review panel.  One of these individuals is believed to be the Group Managing Director of Rennicks, the largest importer of retro-reflective film to the UK.  The second largest film supplier, being 3M, employs the Chairperson of the Panel, who also sits on other BSI panels.  3M also own a major UK ANPR camera manufacturer.  This situation is not new – please see

http://www.publications.parliament.uk/pa/cm201213/cmhansrd/cm130131/debtext/130131-0003.htm#13013134000003 being the adjournment debate on vehicle registration marks on 31st January 2013.

 

There is nothing surprising or unacceptable about an organisation such as BNMA.  However its member’s exclusive ‘Trade’ domination of the BS AU 145 panel risks distorted conclusions caused by their vested interests.  It is already rumoured to be leading to additional reflective film marking obligations as part of the current AU 145 review. These changes would be entirely unnecessary in a DVLA revised manufacturing licensing regime and simply work to tighten their control of the market.  The situation is not conducive to producing the best possible product for consumers or law enforcement agencies alike.

 

Recommendation 4.  The DVLA should be given formal control of an expanded and revised BS AU 145 review brief in conjunction with the ACPO ANPR and Roads Policing Leads. The review should include:

 

  1. Front of plate protection capable of withstanding modern pressure washers and stone chip penetration.  (Current thin-film front-laminated plate systems which are claimed to meet BS AU 145d, are prone to such problems.)
  2. Front of plate plastic specifications improved to cover long term UV effects reducing retro-reflectivity.
  3. The testing regime.  The tests should be re-written to use commercially available test equipment and concentrate on the importance issues of reflectance and water penetration.  By mandating a 3 year warranty, manufacturers should automatically be incentivised to self-test prior to self-certification.  Standardised ANPR read testing should be added.
  4. Supplier/Manufacturer Identification.  This can be simplified to just the DVLA Manufacturer Number.  Under the above proposals separately identifying the Motor Trader within the statutory area of the plate is unnecessary as the Manufacturer would carry the responsibility for all aspects of the plate, including entitlement verification.  Motor Trader advertising can continue to be separately displayed outside the statutory area and often on a plate extension.
  5. Methods of fixing and their positioning.

 

Recommendation 5.  The DVLA should be given executive approval of the AU 145 panel representatives, and panel constitution.  This should include: 

 

  1. Publication of the brief, its scope, panel members and timetable.
  2. The appointment of an independent Chairman with no vested interests.
  3. Inclusion of:
    1. At least two front-line police officers responsible for ANPR forensics and Roads Policing.
    2. Two ANPR system experts.
    3. At least one on-line Trade manufacturer supplier.
    4. At least one non BNMA manufacturer supplier.
    5. A standards testing expert.
    6. A DVLA representative

 

 

 

 

 

 

 

 

 

 

Concluding Statement

 

We make the above observations having come fresh to the vehicle licence plate market two years ago.  Our conclusions result from trying to use and test with the BS AU 145d standard, consulting with ANPR suppliers, consulting with front line ANPR and Roads Police Officers, studying the University of Hertfordshire’s research, study and selection of materials, study of relevant law and an average understanding of human nature.

 

We are proposing, and offering to subject ourselves to, increased regulatory control in order to be part of a bigger change in encouraging the public to respect the value and importance of their licence plates and to encourage our raison d’etre of better looking, longer lasting plates on the road.  Enhancing our cars through better quality plates with desirable additional imagery outside of the statutory area was the reason we founded the company.  Our innovation and the improvement to the core functionality of a licence plate – “to be remembered”  - can be seen at www.fourdot.co.uk from early March 2014.

 

Ian Southern

Managing Director

February 24th 2014

 

 

 

 

 

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