Open Letter to WHOM IT MAY CONCERN

On 8th Dec 2020 I wrote to the Rt Hon Grant Shapps MP (Secretarary of State for Transport), the Department of Transport itself and to the DVSA. The DVSA have kindly responded via email but, eight weeks on, my correspondence to Rt Hon Grant Shapps and the DfT hasn't even been acknowledged, let alone replied to.

I can only assume they don't take the A-Frame towing of cars seriously.

Below is My letter.

08 December 2020

Open letter to

Rt Hon Grant Shapps MP

DVSA

DfT

and other interested parties.

Ref: A-Frame Towing.

Dear Sirs,

I previously wrote (20.10.2020) to both the DfT and the DVSA regarding the issues surrounding A-Frames but to date, have received no response.

As a retired trailer and towbar manufacturer and a past director of the National Trailer and Towing association (NTTA), I have been aware of a major inconsistency regarding the regulation of towed and towing vehicles for over 30 years.

‘A’ frames are most commonly used in the leisure field, predominantly by Motorhomers to tow their ‘city cars’ behind them. Currently, there are in the region of 300,000 Motorhomes/Campers on UK Roads, well over a 1/3rd of which are equipped to tow cars, or ‘Toads’ as some of the users choose to refer to them.

There is an issue that this sector of the vehicle market is almost entirely unregulated and that over 75% of new product is still using outdated and incompatible technology, based purely on cost.

My concerns fall into two main categories, 1. Safety. 2. The legal/legislative aspect and the non regulation,

The current view of the DoT, according to https://www.gov.uk/government/publications/a-frames-and-dollies/a-frames-and-dollies is that a car on an ‘A’ frame (a Toad) is classed temporarily, as a trailer. Only the UK accept that a car adapted for towing is classed as a trailer although the page referred to does state that a car/A-Frame combination must meet the technical requirements for trailers when used on British roads. This is a farcical situation when a trailer has to be capable of being auto-reversed yet no car/A-Frame combination using Inertia coupling technology can be. The systems are simply incompatible.

Additionally, the page refers to the Road Vehicles (C&U) regs 1986, SI1986/1078 (as

amended) and specific regulations therein, the Road Vehicles Lighting Regs 1989, SI1989/1796 (as amended),plus European Directive 71/320EC. Added to the list should be:

European Directive 94/20EC

European Directive 98/12EC

The Vienna Convention on Road Traffic, 8.12.68

and Regulation No 13 of the Economic Commission for Europe of the United Nations (UN/ECE) — Uniform provisions concerning the approval of vehicles of categories M, N and O with regard to braking [2016/194] in particular para 5.2.2.2

The.gov Guidance page clearly states “Since 1st October 1988 Inertia braking systems have been required to allow a trailer to be reversed by the towing vehicle without imposing a sustained braking drag. Devices used to fulfil this requirement must engage and disengage automatically. This applies to A-Frames that employ inertia over-run technology”. That quite simply is impossible to achieve as trailers have a dedicated auto-reverse mechanism built into each brake assembly and no car does. On the subject of brakes, most systems are relying on the vehicle’s service brake system with a ‘dead pedal’ connection where the vehicle’s servo is inoperative resulting in poor efficiency and, in the event of an emergency breakaway, all are relying on the car’s hydraulic braking system to park the car. NONE are utilising a fully mechanical, locked, parking brake.

The page goes on to say that “the A-frame itself is neither a vehicle nor a trailer, and is therefore outside the scope of type approval.”, however, a Tow-Bar is neither a vehicle nor a trailer either but has been subject to type approval since 1st August 1998. What is the logic that dictates that towing equipment fitted to the rear has to be ‘TYPE-APPROVED’ yet towing equipment fitted to the front doesn’t and is outside regulation?

Since 2012, all trailers on U.K. roads are required to be type approved but no car/‘A’ frame combination (Toad) is, nor can it be under the trailer regulations. Not one single vehicle manufacturer has mounting points they consider suitable for A-Frame towing.

The 25th May 2007 saw the outlawing of non type approved Bull Bars on the grounds of safety regarding pedestrians yet Towing A-Frames have as much potential for injury/death to a pedestrian and are unregulated. To attach an A-Frame to a car, a number of suppliers are undertaking a major alteration to the front of the towed vehicle by removing and discarding the crash/impact beam that the car was tested and approved with and replacing it with a heavy fabrication that is permanently fitted. Of the suppliers that don’t discard the crash/impact beam, they are modifying and reinforcing the original to accommodate the necessary additional mounting points and the increased stresses imposed by A-Frame towing.

These potentially have an effect on the crumple zones built into the car and even airbag deployment, with the knock on effect of risk to driver and passengers when the vehicle is used in ‘normal’ mode.

Moreover, a large number of these have projections from the front in the form of mounting points which are potentially hazardous to pedestrians involved in any accident.

Without any guidance or regulation to go by, the converters who are adapting vehicles for this purpose are using their own judgement as to what is acceptable. In many cases, the fabrication being attached to the front of the vehicle is at least as dangerous as a bull bar and certainly more dangerous than a tow-bar.

There is no sense whatsoever that Tow-Bars, Bull Bars etc. fitted to vehicles have to be type approved but ‘A’ frames have no such requirement for ‘e’ markings and more importantly, nor do their attachment brackets, which are permanently fixed to the car.

I would argue that removing the original crash/impact beam and replacing it with a much stronger welded fabrication amounts to the car being a ‘Radically Altered Vehicle’ as it affects the basic chassis construction. As such, it should be subject to a Vehicle Inspection Report and possibly re-registration. This is already successfully undertaken in New Zealand by the lvvta.org.nz

As recent correspondence with vehicle manufactures shows, there is not one single car manufacturer that has approved mounting points for these brackets. Of 15 letters written to leading manufacturers, after more than 4 months, 8 still have not responded.

In date order, the others are summarised here.

• 1.Vauxhall: I can advise that we do not have any mounting points for an A-Frame on any of our vehicle range.

• 2. Fiat (FCA): Any faults or issues relating to the fitment of an A-Frame would possibly render our manufacturers warranty void.

• 3. Honda: unable to advise, refer to dealer.

• 4. Hyundai: None of our vehicles are suitable to be towed on an A-Frame.

• 5. Toyota: we cannot recommend the use of an A-Frame with any of our vehicles.

• 6. Skoda: we are unable to advise.

• 7. Ford: refer to dealer.

A poll currently running among users of A-Frames suggests that the most popular cars to convert are Mercedes-Smart, Peugeot and Citroen yet to date, none of these have commented.

Under current legislation, the ONLY truly legal way to transport a vehicle is on a trailer, however, a properly constructed, tested and approved A-Frame has the potential to provide a safer, more stable way of vehicle transportation, bearing in mind it is quite a bit lighter than a trailer/car combination and also has a lower centre of gravity. For the end user it has the added advantage of being easier to store and arguably requires less skill/training. Far from trying to have A-Frames banned, what I hope to see, eventually, is a fully legal one that can be used with confidence.

, If ‘Toads’ were reclassified as such rather than, temporarily, as a trailer, the A-Frame manufacturers would be able to comply with RELEVANT legislation, rather than trying to conform to something unfit for purpose. Equally, there would no need for any to attempt to pull the wool over the eyes of the consumer, selectively quoting bits of legislation they think suits their purpose and confusing the end user into believing their product is ‘FULLY LEGAL’ as they all claim!

I look forward to your response.

Yours sincerely

A E Maris

A Guide to A-Frame towing your car...

What is A-frame towing? It’s a way of transporting your car, with all 4 wheels on the ground as an alternative to using a transporter trailer. Effectively, you add an ‘A’ shaped drawbar frame to the front of the vehicle, via a permanently mounted base plate, replicating a trailer.

The car with A-frame attached is variously referred to as a ‘towed vehicle’, a ‘TOAD’, ‘flat towing’ and in the USA even ‘dinghy towing’.

A good percentage of Motorhome owners like the idea, and convenience, of being able to take their ‘city car’ with them, so what’s the best way to go about it?

The A-frame itself is not usually vehicle specific. It can, theoretically, be swapped between vehicles however, as no small car on the U.K. market is designed to be ‘flat towed’, all will require some modification to attach the A-frame. This may be a modification of the crash protection beam to add a 2nd towing eye or, in many cases, removing the crash protection beam altogether to facilitate the addition of a vehicle specific base plate or mounting plate. Some of these are unsightly and can have dangerous projections. It needs to be said that a fabrication such as illustrated, WILL affect the crumple zones and possibly airbag deployment in the event of an accident.... It’s also necessary to add an additional wiring loom to operate the required road lights including, since 2012, reversing light(s). Currently in the U.K. , an A-framed towed car is treated as a trailer and has to comply with all the relevant trailer legislation (more on that later!). Using a trailer lighting board is NOT legal!

Before you take the plunge, you need to check:

1. firstly, your driving licence entitlements. You MUST have sufficient entitlement to drive an M1 class vehicle (passenger car) PLUS a braked trailer equivalent to your Toad's MGW. Usually, that would be category B+E on your licence. If the Motorhome exceeds 3,500kgs MGW, you would need category C1+E.

NOTE: Driving licence categories are based on PLATED vehicle weights, not the ACTUAL weight at any given time.

2. secondly, your Motorhome MUST have the available towing capacity to handle the extra load of a braked trailer. This can be checked on the Motorhome VIN plate (see my blog at https://spinner28.wixsite.com/tonys-towing-trivia/post/weights-vin-plates

3. Is your car suitable to be ‘flat-towed’? If your car is an automatic, 4x4, or has a limited slip diff it’s unlikely to be suitable. There is risk of damaging the transmission. Most semi-automatics are also unsuitable (check with VEHICLE manufacturers, not the A-frame supplier). All fully electric cars are unsuitable as are most hybrids (damage to electric motors) check with VEHICLE manufacturer not the A-frame supplier.

OKAY! so you think you’re good to go? As a ‘towed car’ is classed as a trailer and all cars have brakes fitted, it falls into the trailer category ‘02’. Essentially, with all trailers fitted with brakes, they have to work on all wheels, be fully operational and comply with trailer legislation. It is totally illegal to use an unbraked A-frame, or a ‘Car Dolly’ for transportation. They are limited to recovery operations.

There are a number of A-frame suppliers in the U.K. but essentially their product falls into one of two categories. Traditional, inertia (overrun) couplings, designed for trailers, have been used on A-frames since the 1980s and still are but, more recently, there has been a significant increase in alternative, electronic braked systems. So which to choose? Do your research! While I have a list of A-frame suppliers/manufacturers in the U.K. I’m not here to promote one over another so I’ll refrain from mentioning any. Before deciding WHO to choose, decide which system might suit you best. The obvious considerations are: Budget, Convenience, Weight, Storage/handle-ability, Ease of use and Braking system but you may well have your own, or even different, priorities.

OPTION 1 is the traditional inertia(overrun) braked system. If you are familiar with caravans or braked trailers, you should already know how to use them.

By their nature, they are heavy and bulky. Typically 20kgs+, up to 30kgs if including a jockey wheel!

They rely on a Bowden cable from a brake pivot on the coupling at one end, while the other end fits to the existing ‘dead’ (no servo assist) brake pedal of the car. The Bowden cable requires a quick release fitting to allow the A-frame to be detached.

Regular maintenance is essential to ensure continued smooth operation. The biggest risk is damage or wear to the Bowden Cable (and possible incorrect adjustment) causing significant brake drag and overheating.

Auto-reverse, inertia braked couplings are fundamentally incompatible with standard car brakes and therefore, cannot be auto-reversed. They also fall outside rhe UNECE regulation 13 which only allows them on centre axle trailers.

On the plus side, this option usually has a significant cost advantage over option 2.

OPTION 2 is a lightweight unbraked frame coupled with an electronic activated braking system. They still operate on the brake pedal but this can be power or servo assisted. They can also be auto-reversed.

Typically weighing only 8, 9 or 10kgs, they are easier to handle and store, usually folding up to fit quite neatly in the boot of the towed car when not in use.

As braking is activated electronically, there is little user intervention required but initial installation can be technical. The A-frame itself may require less maintenance yet, as with both options, regular inspections of the attachment points to the car should be carried out.

The down side of these options is cost, often being more expensive than a transporter trailer.

Unlike with inertia couplings, there is no mechanical parking brake in the event of an emergency breakaway.

Braking effect is dependent on an adequate 12volt supply and some systems draw up to 10.8amps. Once the battery depletes, there is no braking!

DRIVING. The A-frame needs to be correctly fitted to the towbar of the towing vehicle, including the attachment of either a breakaway cable or a secondary coupling. (Another blog? 🤔) and the towing electrics connected. Once set up, the towed car then needs to be set in neutral, the handbrake fully off and the ignition key set to the ‘aux’ position ensuring the steering lock isn’t on. Some installers recommend pumping the footbrake several times to depressurise the braking system. Going forwards is pretty straightforward (though remember when cornering, the car will track inside the path of the towing vehicle). A few vehicles can suffer ‘wheel shimmy’ or the ‘death wobble’ as some call it.... BE AWARE!.

It’s a requirement of trailer regs that the outfit has to be reversible without the driver (or anyone else) intervening, that is, auto-reversing. The fact is though that reversing a ‘TOAD’ is significantly more challenging than reversing a trailer. This is due to the steering geometry of the car which has a tendency to react more like a supermarket trolley when in reverse! Due to the castor effect, considerable damage can be done to steering, suspension and tyres if you persist. Inertia/overrun couplings are also incompatible with non-autoreverse car brakes. My advice, if you need to reverse, is to simply uncouple the two, reverse independently and then recouple.

OTHER OPTIONS?

You do not have to A-frame! A trailer may be easier and can be used for other things (provided you can store it). You can abandon the towing idea altogether and hire a car at your destination (may be more cost effective if only using occasionally) or you can cut costs dramatically with local transport and/or keep fit on ‘shank’s pony’ or a pushbike!

LEGALITY…

The legal position of A-framing is contentious, to say the least. In the UK., the view of the DfT is that an A-framed towed car should be treated as a trailer and comply with trailer regs, however, they also say "the A-frame itself is neither a vehicle nor a trailer, and is therefore outside the scope of type approval." yet on the same DfT advice page, they say all trailers need to be type approved! https://www.gov.uk/government/publications/a-frames-and-dollies/a-frames-and-dollies

Confusion reigns and the result is that A-framing is tolerated. unfortunately, it also means that without any controls, ANYONE can manufacture and fit their own A-frame.

Europe is a different story altogether. While France currently tends to ignore UK plated Motorhomes with A-Frames, they are illegal in French Law. Spain and Germany take a rather more stern view and UK users have been stopped and issued with fines. It's a popular misconception that if a 'vehicle' is accepted on UK roads it has to be accepted on European roads. NOT SO!

There are literally, reams of pages of legislation encompassing UK Construction & Use regulations, EU regulations and UNECE regulations. I shall, hopefully cover this topic in more detail in a future blog.

REMEMBER! The ONLY guaranteed legal way of transporting a car behind a Motorhome, anywhere in Europe, is to have it on a Type Approved trailer.

Unravelling ‘S’ and ‘D’ values.

Most towing equipment introduced since 1998 should be type approved and have a plate or sticker showing:

• The Manufacturer

• The country of Type Approval (eg E11)

• The part number

• The Eu standard (typically A50-X)

• The ‘S’ Value

• the ‘D’ Value.

As users, the 2 most important bits of information are the ‘S’ value and the ‘D’ value.

The ‘S’ value is straightforward. Simply, it is the maximum vertical load (nose-weight) that can be imposed on it. It’s measured and shown in kilograms and typically might be between 50 -150 Kgs. Higher values are permissible on certain equipment but, for the purposes of this blog, it’s restricted to regular use such as a Motorhome owner or a car/van driver towing his/her Cat01 or Cat02 trailer on a standard 50mm tow-ball. (Trailer category info is for another blog).

The ‘D’ value is a little more complex. Towing equipment isn’t generally rated by a finite value (i.e. 1500kgs) but by a ‘D’ value calculation. The capacity of the towing equipment will vary, dictated by the GVW (Gross Vehicle Weight) or MAM (Maximum Authorised Mass) of the towing vehicle. As the vehicle’s GVW or MAM goes up, it’s towing capacity will go down if the ‘D’ value is fixed.

‘D’ value of the towing equipment needs to be at least high enough to accommodate the vehicle’s maximum towing capacity as calculated from the VIN plate.

Here we have the VIN plate from a Vauxhall Vivaro Van.

The info on the VIN plate shows a towing limit of

exactly 2 tonnes (fully laden) . That is the Gross

Vehicle weight (1st weight displayed) deducted

from the Gross Train Weight (2nd weight

displayed).

To be compliant, the ‘D’ value of the towing

equipment needs to accommodate both the van’s

GVW (MAM) and it’s maximum towing limit.

So How Do We check it’s Adequate?

Use the calculation:

D value = 9.81 x (towing vehicle’s GVW x Trailer’s MAM) / (towing vehicle GVW + Trailer’s MAM)

In this case, 9.81 x(3.03(tonnes)

x 2(tonnes)) / (3.03(tonnes) + 2(tonnes)) = 11.82 D value.

As the tow-bar is plated at a D value of 12.02, it’s a

perfect match! :)

NOTE! It is ILLEGAL to exceed ANY of the weights on the VIN plate, or the towing equipment’s nose-weight (in this case 85Kgs.)