https://www.gov.uk/government/consultations/road-vehicles-improving-air-quality-and-safety
https://www.facebook.com/groups/128498247234680/permalink/1601235803294243/
[Edited on 3/2/18 by craigdiver]
This is concerning...
https://www.gov.uk/government/consultations/road-vehicles-improving-air-quality-and-safety
https://www.facebook.com/groups/128498247234680/permalink/1601235803294243/
[Edited on 3/2/18 by craigdiver]
Not nice - but I sort-of understand what they're saying, and I must admit that I half expected it. They're currently putting huge pressure
on manufacturers and car buyers to go for the lowest emission options, but letting kit builders get away with installing ancient engines that get
nowhere close to the current standards.
Note that I'm saying this as the owner of a Locost with a 1970's Ford crossflow engine...
Really, really hope that if this proposal is passed (quite likely) they are fair enough to give us builders part way through their builds a couple of
years to get it finished off and through IVA.
Our kitcar builders opinions are being voiced through some of the larger kitcar/sportscar manufacturers such as westfield - will they fight the corner
for the complete self-builder (build chassis from scratch) or will they jump at the opportunity to stop self-builds to increase their own sales?
I hate this sort of pointless regulation - is forcing a couple of hundred cars off the road going to save any polar bears? 
I’m not surprised by this they where always going to tighten up the regulations kitcars will still pass this with modern engines I think everyone should remember how lucky we are to be able to build cars in this country!
its not clear to me from the wording if this is retrospective in its application - i effing well hope not having recently iva’d/registered a crossflow
on dcoes
going forwards id assume old engines and carbs are up against it
quote:
Originally posted by Christof
its not clear to me from the wording if this is retrospective in its application - i effing well hope not having recently iva’d/registered a crossflow on dcoes
going forwards id assume old engines and carbs are up against it
This a result of the blanket adoption of EU law to align UK law prior to Brexit.
Point 10 below needs to be addressed urgently and I suggest that argument is discussed urgently and not at length or we will simply miss the deadline
for response.
One of the big problems with the latest engines is the complexity of the ECU and the built in security systems that require sight of dashboards,
antilock brake sensors and a whole lot more that stops us from recycling cars that would just be scrapped.
There is a big conversation to be had and we don’t have much time.
10 Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT
standards according to the age of their engine?
The consultation period begins on Friday 2 February 2018 and runs until Friday 2 March 2018. Please ensure that your response reaches us before the
closing date. If you would like further copies of this consultation document, it can be found at https:// www.gov.uk/dft#consultations or you can
contact us using the details below if you need alternative formats (Braille, audio CD, etc.).
Please send consultation responses to: Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
LONDON SW1P 4DR
Email to: ivs.consult@dft.gsi.gov.uk
great work snapper,
Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?
Ok not 100% sure how this effects me but it doesn't sound too good!!!
My build will certainly NOT be IVA'd this year ... I am putting together a 2.0 Pinto for it with ZX9R bike carbs
With the above changes is there any chance of my car passing the IVA emissions test or should I just throw it in the sea now !!!!!!
quote:
Originally posted by craigdiver
great work snapper,
Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?
The proposal is for your cars emission requirements to not be engine age specific but to match that of the mot requirements at time of
registration.
In a nutshell you’ll need a catalytic convertor, fuel injection and a very well setup ECU with emissions in mind.
quote:
Originally posted by PorkChop
quote:
Originally posted by craigdiver
great work snapper,
Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?
What precisely are you objecting to?
It reads like this will apply to all kit cars, whether registered already or not. I hope not but if so, in my case that would mean meeting 2006 MOT
standards, not 1991.
It will put a lot of cars off the road if this is the case.
quote:
Originally posted by SJ
It reads like this will apply to all kit cars, whether registered already or not. I hope not but if so, in my case that would mean meeting 2006 MOT standards, not 1991.
It will put a lot of cars off the road if this is the case.
quote:
Originally posted by snapper
In a nutshell you’ll need a catalytic convertor, fuel injection and a very well setup ECU with emissions in mind.
Next step sealed Ecus & registered tuners. Mot pass map & circuit/track maps.
A full section in that doc about penalties for using emissions "defeat devices" e.g. VW/Audi ecu mods, but presume also the prolific use of
decat pipes & welded up dpfs.
And if there is any added requirement for meeting EU4/5/6 standards cars might be required to have OBD ports & thus CANBus looms, etc..
[Edited on 4/2/18 by MattD]
quote:
Originally posted by SJ
It reads like this will apply to all kit cars, whether registered already or not. I hope not but if so, in my case that would mean meeting 2006 MOT standards, not 1991.
It will put a lot of cars off the road if this is the case.
LETS PUT SOME PETSOECTIVE ON THIS
This is a consultation document
We have the opportunity to comment
It is a proposal and with any change in motoring Law is not retrospective in the same way that emissions requirement is not retrospective for older
cars
Personally for me at the moment this isn't a problem as mine is registered and running the standard Ford ECU with a CAT but obviously those that
are in the process of building with an older engine this is a concern.
Would a zetec running say an Omex/Emerald ECU and a CAT meet the emission standards easily enough or would even that struggle?
I guess most cars running a carb would struggle.
I can see the point of the change, but will be writing with the following objections/comment. Of course I am entirely motivated by the fact that I
don't want this to come in before I get my car finished - as I am fully intending to use a 1985 Ford Pinto engine running carbs, which I assume
won't meet modern emission standards. But, incase, I have decided to try and get my car to IVA as soon as possible now!!!
1 - At best a change like this should have a reasonable lead time - say 24 months - because many people build kit cars over a reasonably long period
of time - and many will have begun such projects expecting to use an engine which, under the new rules will not be allowable.
2- The actual impact from an environmental point of view of implementing this change will be minimal. Of the relatively small number of kit cars which
are being built and used on the road, many already have engine which can meet modern emissions standards.
3 - Once registered many kit cars are used for a relatively small amount of miles each year (evidenced by the fact that many kit cars are insured on
limited mileage policies), and therefore even those with engines tested to older standards will make little environmental impact in real terms.
4- If it is deemed necessary to implement this change, a reasonably long lead time to implementation should be considered acceptable because of 2) and
3) above.
Does this proposed change impact at all on the use of bike engines, especially on Morgan-like trike builds? I'd like to build one of those
next...
I agree with the above ... I too am in the middle of a Pinto build ... would cost me a fortune to switch now !!!!
a 24 month grace period sounds fair ... would also give me the kick up the arse to get it finished :-)
Does the proposal means Euro6 or later emission? Or do they just want post '92 engines to be used in future IVA submissions?
CCK Kempten managed to get a Zetec Blacktop to Euro6 for German legistations, but I recon that it wouldn't be an easy thing to do.
Surely some ex-VAG engineers are willing to offer some support if all this go through?
quote:
Originally posted by ettore bugatti
Does the proposal means Euro6 or later emission? Or do they just want post '92 engines to be used in future IVA submissions?
quote:
Originally posted by PorkChop
quote:
Originally posted by ettore bugatti
Does the proposal means Euro6 or later emission? Or do they just want post '92 engines to be used in future IVA submissions?
No, it does not; it tells you this in section 4.10.
You can fit any engine if you can get it to meet the limits.
quote:
To pass the Basic Emissions Test, the following requirements must be met:
Fast idle test (2500 - 3000rpm):
CO <= 0.2%;
HC <= 200ppm;
Lambda between 0.97 and 1.03.
Idle test (450 - 1500rpm):
CO <= 0.3%.
I have commented saying pretty much the same - I suggest everyone does the same. I also pointed out that we are 'recycling' engines that
had they been left in the donor vehicle, would be required t meet a lower standard.
I'm not sure whether my 1.25 Zetec Se (1995) will pass - I have deleted the oil breather recirculation gubbins....
quote:
Originally posted by gremlin1234
quote:
Originally posted by PorkChop
quote:
Originally posted by ettore bugatti
Does the proposal means Euro6 or later emission? Or do they just want post '92 engines to be used in future IVA submissions?
No, it does not; it tells you this in section 4.10.
You can fit any engine if you can get it to meet the limits.
as far as I can tell the proposed limits will be the current MOT limits (and after 20 May '18 mot changes too)
quote:because its important to know that its not changing. and what the limits will actually be.
Originally posted by PorkChop
Unless there is something I've missed, a change in the emissions limits is not part of the proposed MOT changes, so why are you bringing it up?
quote:
Originally posted by gremlin1234
quote:because its important to know that its not changing. and what the limits will actually be.
Originally posted by PorkChop
Unless there is something I've missed, a change in the emissions limits is not part of the proposed MOT changes, so why are you bringing it up?
apologies, I might have been clearer had I written:
...current MOT limits (and these don't change with the 20 May 2018 updates )
rather than
...current MOT limits (and after 20 May '18 mot changes too)
Assuming this goes through, when would it be applied. I’m nearly ready for IVA on carbs
quote:
Originally posted by mikeb
Assuming this goes through, when would it be applied. I’m nearly ready for IVA on carbs
IVA paperwork going in this week!
page 15 secn 4.6
quote:
4.6 We are proposing to apply the new WLTP cycle for vehicles approved via IVA
with effect for vehicles whose manufacture is completed on or after 1 July 2018.
This earlier (than NSSTA) date for IVA is to encourage manufacturers to
transition to the new cycle as soon as possible.
quote:
Originally posted by gremlin1234
page 15 secn 4.6
quote:
4.6 We are proposing to apply the new WLTP cycle for vehicles approved via IVA
with effect for vehicles whose manufacture is completed on or after 1 July 2018.
This earlier (than NSSTA) date for IVA is to encourage manufacturers to
transition to the new cycle as soon as possible.
quote:
Originally posted by gremlin1234
page 15 secn 4.6
quote:
4.6 We are proposing to apply the new WLTP cycle for vehicles approved via IVA
with effect for vehicles whose manufacture is completed on or after 1 July 2018.
This earlier (than NSSTA) date for IVA is to encourage manufacturers to
transition to the new cycle as soon as possible.
It seems to me that there are two key issues for us.
Point 1
If we are forced to use the latest emissions standards in force at the time of IVA, then this may be very difficult.
It will probably force us to use new or nearly new engines.
Imagine a situation where one of us starts to build a car using a nearly new engine that meets current standards. Three years later, the car is ready
for IVA but by that time, the standards may well have moved on.
I would suggest that ideally, there should be no change and that the emissions standards appropriate to the engine should be applied. Failing that,
enforcing an older standard would allow us to have at least a chance of getting hold of suitable engines.
we shouldn't be required to comply with the latest standards - that seems impractical.
Point 2
The short implementation timescale would be very unfair.
I would suggest a MINIMUM of 2 years for a significant change along these lines.
This forum has 13,000+ registered members, should we submit a group response?
I think as other have said;
a) Give us time to finish our current builds - at least 24 months.
b) ????
c).......
Now i'm confused ...... I have an MK Indy using a 1983 Ford Pinto, which was SVA'd and registered in 2009. Therefore under the new MOT will I have to pass the emissions criteria for 2009?
They'll not give any consideration to cars currently being built - anyone could claim that and get away for the next 2 years, and they don't
have time to assess each on merit.
I think we need to not knee-jerk at this, however I think you not only need a modern engine, but most of the emissions ancillaries and control
electronics, which makes it borderline impossible in this kind of vehicle. If the IVA updates with current MOT requirements, what we have today as a
pass criteria (isn't THAT hard to hit) may become really hard.
At what stage do you start needing charcoal canisters, full evap recirc systems, OEM-level tuning, cats with pre and post wideband etc..
They've recently started the 40 year rolling MOT exemption due to the small number of cars and high level of enthusiast care - this flies in the
face of that logic.
I'm in two minds.
[Edited on 5/2/18 by coyoteboy]
It's not consideration to cars being built, it's a straightforward delay of at least two years that's needed.
It is not reasonable to apply such a change with short notice (5 months is very short notice).
I also agree, requiring compliance with the moving target of current MOT standards is getting towards impossible.
We should be requesting either sticking with current engine based standards or require compliance with older standards.
quote:
Originally posted by andyace
I agree with the above ... I too am in the middle of a Pinto build ... would cost me a fortune to switch now !!!!
a 24 month grace period sounds fair ... would also give me the kick up the arse to get it finished :-)
quote:
Originally posted by theduck
quote:
Originally posted by andyace
I agree with the above ... I too am in the middle of a Pinto build ... would cost me a fortune to switch now !!!!
a 24 month grace period sounds fair ... would also give me the kick up the arse to get it finished :-)
Have you got that motor in yet?!
Think I'll hold off spending £200 on bearings, rod bolts, rings and a timing chain for my xflow then. Plenty of other jobs to do in the
meantime.
Hopefully they'll give some notice as I've already spent 100s on this engine...
quote:
Originally posted by theduck
quote:
Originally posted by andyace
I agree with the above ... I too am in the middle of a Pinto build ... would cost me a fortune to switch now !!!!
a 24 month grace period sounds fair ... would also give me the kick up the arse to get it finished :-)
Have you got that motor in yet?!
You know where I am if you need me!
These rules will not be retrospective, however there is one change to the emissions requirements in regard to the draft mot manual as below;
**
Vehicles first used before 1 September 2002 fitted with a different engine must be tested to the requirements of whichever is older, the engine or the
vehicle. For example; a 1995 car fitted with a 1991 engine (of whatever make), must be tested to 1991 standards for emission purposes. The onus is on
the vehicle presenter to prove engine age.
Vehicles first used on or after 1 September 2002 fitted with a different engine must to tested to the requirements relating to the age of the
vehicle.
**
This second paragraph indicates that an engine change in a 01/09/2002> vehicle will fall under different rules to present.
With a Q plate or where the emissions are stated on the V5 this isn't a major problem, but an engine swap or original non cat engine without the
preceeding criteria it will default to a full cat test requirement.
I have emailed the DVSA regarding the lack of emission limits being present on a proportion of V5 logbooks, and whether it is feasable to formally
accept the MAC certificate type code as proof of emissions limits for a vehicle and state this in the mot manual (at present it is only a draft and
changes can be made).
This would simplify things for those who have incomplete V5 details, as the DVLA are slower than treacle in dealing with these things.
Dave
quote:
Originally posted by JonBowden
Point 1
If we are forced to use the latest emissions standards in force at the time of IVA, then this may be very difficult.
It will probably force us to use new or nearly new engines.
Imagine a situation where one of us starts to build a car using a nearly new engine that meets current standards. Three years later, the car is ready for IVA but by that time, the standards may well have moved on.
I would suggest that ideally, there should be no change and that the emissions standards appropriate to the engine should be applied. Failing that, enforcing an older standard would allow us to have at least a chance of getting hold of suitable engines.
we shouldn't be required to comply with the latest standards - that seems impractical.
I think the confusion is over the limits....
Cars undergoing IVA will have to meet the current MOT emissions NOT production emissions.
At the moment, it ‘shouldn’t’ cause issues for any car with fuel injection, an ECU and a CAT........it’s mainly those who have not yet passed IVA who
are using carbs that will be affected.....probably
quote:
Originally posted by nelmo
I hate this sort of pointless regulation - is forcing a couple of hundred cars off the road going to save any polar bears?
quote:
Originally posted by scootz
quote:
Originally posted by nelmo
I hate this sort of pointless regulation - is forcing a couple of hundred cars off the road going to save any polar bears?
I hate this sort of pointless post.
We are living on a dying planet, and every little helps... even if it miffs big kids at play!
The universe does not revolve around me, myself, or I.
So we have to get with the emissions programme!? So what! Deal with it!
quote:
Originally posted by PorkChop
I think this is being blown out of proportion a bit and people are getting confused; the people that really need to worry about this is those fitting 80s or earlier engines. As I said earlier, the DfT seems to have made the assumption that if you have a Euro 1 or later engine, then you have the hardware to meet the 2002 MOT limits. This is an assumption I can understand, a big enough cat with enough precious metal, enough temperature and not running rich should be enough to oxidise enough CO and HC to meet the limits.
To put it in perspective, I have a very early, pre Euro 1 MX5 engine (which does have a cat and EFi). I'm not overly concerned about the proposals, it's just the exhaust line will need a bit of thought.
Just in case anyone does have an opinion that they want to give feedback to the legislators about you can do so at
https://www.gov.uk/government/consultations/road-vehicles-improving-air-quality-and-safety
but if you try to give online feedback you will be expected to give feedback with reasons on EVERY proposal
If you wish to comment on the issues about kit cars at IVA having to conform to whatever standards exist at that time you can do so by email or by
post at the details below. The question in the consultation document comes in section 4 and is question 10.
Email to:
ivs.consult@dft.gsi.gov.uk
Write to:
Robert Lloyd-Smith
Zone 1/33,
Great Minster House
33 Horseferry Road,
London,
SW1P 4DR
quote:
Originally posted by mikeb
IVA paperwork going in this week!
I helped a mate get a Murtaya kit mechanically ready just in time for the SVA cut off date before IVA came in... it had no trim & no lights, but
the engine ran (badly), and the brakes worked.
It failed obviously, but we were purely there so that it was tested under the SVA rules.
We had a long "to do list", and 6 months to retest, which it passed still under the SVA criteria. (It would have passed IVA anyway, but mate
was unnecsessarily worried).
How VOSA intend to implement the 2018 changes I dont know, but would expect similar.
did mine at Norwich a few months back
dont think there was a particularly long lead time, but assume your application has been approved and referred across to them already
doubt they would mind a few questions, but also doubt they are on the cutting edge of rule changes
webbed feet and all that (just kidding, love east anglia!)
quote:
Originally posted by Christof
assume your application has been approved and referred across to them already
my memory isn't great so I've looked back - you'll need to fill in the IVA 1C, amateur build declaration, photos/invoices/letter re
engine age etc which can be done online and pay your £450. the only snag on mine was proof of purchase i.e to guard against stolen cars. That's a
bit tricky when you buy an incomplete project with old parts etc from another individual rather than a manufacturer, so had to show bank statement
showing payment plus a signed 'sale receipt' etc
there were a handful of emails probably took 3 weeks for the (dvsa?) process, then similar lead time for test day (vosn?).
once passed, then you have to send it all off to dvla -dvla vin application letter and garage stamped proof of vin on chassis, v55/5 application form,
v627/1 built up vehicle report (ie can i have an age related reg please), registration fee (circa £200) first tax fee £250, iva cert, photos (again!),
utility copies for proof of add etc
Throw in the transporter hire and that's £1000.
My objection is that we are paying civil servants many hundreds of thousands to administer this rule change that will, in the grand scheme of things, have a minuscule effect on worldwide emissions. How about the emission system from agricultural vehicles? There are many more of those than kit cars. How about power station emissions? Having been to China who are building coal fired power stations at a huge rate, I fail to see how a few hundred (at most)less Pinto engines on carbs will do anything! Save the money and get the civil servants doing something more useful!!!!!!
quote:
Originally posted by JC
My objection is that we are paying civil servants many hundreds of thousands to administer this rule change...
quote:
Originally posted by Sam_68
quote:
Originally posted by JC
My objection is that we are paying civil servants many hundreds of thousands to administer this rule change...
Be careful what you wish for. By far the cheapest and easiest option from an administrative point of view is to stop pandering to the whims of a few eccentric enthusiasts and ban home-built vehicles altogether.
quote:
Originally posted by JC
How about the emission system from agricultural vehicles? There are many more of those than kit cars...
Ok so preparing for the worst (or best as we save the planet) .... assuming my 2.0 pinto with zx9r bike carbs won't pass emissions, what's
my cheapest option (relative term) to get an engine which does meet current emissions
Assuming I buy a brand new Zetec 2 litre blacktop whats the cheapest option to get it to pass emissions?? Can I use my ZX9r carbs on it and still pass
emissions or do I HAVE to go injection ... I have a type 9 .... would I need a cat ... ? I'm an old school engine person and don't have the
knowledge (yet) of newer engines.
A new zetec will cost me £1100 ish, how much will it cost above this to get the cheapest passable engine ??
Would appreciate some input from my knowledgeable members, thanks
quote:
Originally posted by JC
My objection is that we are paying civil servants many hundreds of thousands to administer this rule change that will, in the grand scheme of things, have a minuscule effect on worldwide emissions. How about the emission system from agricultural vehicles? There are many more of those than kit cars. How about power station emissions? Having been to China who are building coal fired power stations at a huge rate, I fail to see how a few hundred (at most)less Pinto engines on carbs will do anything! Save the money and get the civil servants doing something more useful!!!!!!
Ok - As one of the people directly affected by this "proposed" (we all know it has already been decided) change, I'm also going to ask
the collective's opinion on this please:-
I was planning to go through IVA with a 1989 2.0 EFI Pinto running stock ECU.
Would this motor stand a chance of meeting current mot emissions regs with a CAT or is my motor due to join the forthcoming tidalwave of pinto's
soon to appear on Ebay?
Cheers
Tony
quote:
Originally posted by Edwardo
Ok - As one of the people directly affected by this "proposed" (we all know it has already been decided) change, I'm also going to ask the collective's opinion on this please:-
I was planning to go through IVA with a 1989 2.0 EFI Pinto running stock ECU.
Would this motor stand a chance of meeting current mot emissions regs with a CAT or is my motor due to join the forthcoming tidalwave of pinto's soon to appear on Ebay?
Cheers
Tony
Not much hope of my pre xflow passing. As to those who believe that a) we should think our selves lucky that we are privileged to be able to build kit cars and b) that this change to reduce kit car emissions will make any difference to levels of pollution are I imagine the owners of cars already which meet the limits proposed and are true optimists. Not all kit cars are built as or intended to be fast modern lotus 7 clones. Some of us like to build replicas of older cars Jag ss's, xk's,D and C types,Cobra's, Lotus Elevens even replica's of Lotus 6's and early Lotus 7's etc. Even on this site there is a thread running currently extolling the virtues of older type narrow wheeled cars Yes there are fewer of us but that means total emisions from these cars comes to a total of sodd all of a percentage of total traffic emisions. Many of you won't be affected by these changes and if you aren't directly affected then why bother objecting. Of course those of us who are affected not only won't feel lucky to be able to be able to build cars that we don't want but also won't be involved with the kit car hobby when the next proposals do affect your cars and you need support to be able build the cars you want. Either all those who's hobby is self building the cars they want stick together or very soon the right to build our own car will be taken from all of us.
quote:
Originally posted by minibull As to those who believe that a) we should think our selves lucky that we are privileged to be able to build kit cars and b) that this change to reduce kit car emissions will make any difference to levels of pollution are I imagine the owners of cars already which meet the limits proposed and are true optimists.
quote:
quote:
Originally posted by JC
How about the emission system from agricultural vehicles? There are many more of those than kit cars...
We need to eat. And as an island nation, we need to be able to maintain an ability to produce our own food.
We don't need to build kit-cars.
quote:
Originally posted by SJ
yep, we'll only need to keep a couple of billion kit cars off the road to off set one of the coal fired power stations being built!
The main thing that concerns me is the "tested to current MoT limits" - now, currently the MoT manual states " vehicles after 2002 but
not on the annex" (obviously no kitcar will be on the annex) - nut then for ANY current vehicle which is listed on the annex "as stated in
the annex" - without having a copy of the annex I think those figures are actually slightly less onerous. HOWEVER surely vehicles complying with
Euro 6 & above must have to meet higher requirements at manufacture - is there any intention to introduce tougher limits at MoT, so far as I am
aware there is nothing in the consultation about such possible changes.
Further the thing everyone is raving about re air pollution is NOxes, so is it likely that a NOx measurement is to be introduced to the MoT? If not
then it makes the whole emission testing fiasco all the more ridiculous.
A NOx test would be a total game changer, it's not impossible to get a 30 year old engine to meet the emissions requirements (not saying
it's easy, saying it's possible) for the purpose of the IVA test as it is at 2 specific RPM areas, both of which correspond to very low
throttle openings - I get our ZZR1400 engines thro' for instance which were never intended to pass such emission tests - the chance of them ever
actually meeting those emission standards whilst on the road is a whole different conversation. But for NOxes so far as I'm aware it's
largely withing the actual engine design & original intended management system, so not something you could easily play with afterwards
So if this is agreed as is, & if MoT limits change, you could be suddenly & swiftly shafted with little or no notice, I feel therefore that
this is to be resisted as best we can & the best way is for us to make our no.'s (albeit small) felt
As has already been said, if you attempt to object online you have to go thro' every single Q on the form when it is only a specific area we are
interested in commenting on, I would suggest therefore that EVERYONE writes to
Robert Lloyd-Smith
Zone 1/33,
Great Minster House
33 Horseferry Road,
London,
SW1P 4DR
Clearly stating their objections, ie that given the small no. of vehicles affected compared with worldwide emissions this legislation will have almost
zero effect, however on those small no. of kitcars/specials, which are using recycled engines which would otherwise generate more scrap, the costs
& amount of work this would inflict on the owners/builders would be entirely unfair & would be likely to reduce or eliminate one of our unique
UK cottage industries & many of the parts & component suppliers that deal in these markets - something along those lines, please don't
digress into anything about retrospective legislation for cars already registered, it does NOT apply to those vehicles
Let's present a united front
Some info. on the Complete Kitcar magazine website here
quote:
Originally posted by mattf
Some info. on the Complete Kitcar magazine website here
quote:
Originally posted by Sam_68
quote:
Originally posted by mattf
Some info. on the Complete Kitcar magazine website here
OK... so that seems clear enough:
1) There is no effect on cars that have already been registered.
2) Cars that are registered once the change has been implemented will simply have to meet the MOT test requirement for post-1992 vehicles (which effectively means fuel injection and a catalyst).
Is anyone losing any sleep over those requirements?
quote:
Originally posted by Sam_68
2) Cars that are registered once the change has been implemented will simply have to meet the MOT test requirement for post-1992 vehicles (which effectively means fuel injection and a catalyst).
quote:
Originally posted by loggyboy
As i read the gov document its not Post 92 regs, its current Mot regulations, meaning a CAT test (post 2002)
quote:
erm yes me, if it goes through then I need to scrap the Pinto unit and parts I have bought over the years and spend tons more on an engine which will pass emissions which will be significantly more expensive.
While I'm not against the proposal I feel it's a bit unfair on those part way through a build. I'd be happy for it to be in force from 2020
Perhaps I am being a bit cynical or mischievous, but this proposal, if implemented, may cause the value of Pinto engines to plummet and the value of Dutton V5s to rocket...
quote:
Originally posted by softfeet
Perhaps I am being a bit cynical or mischievous, but this proposal, if implemented, may cause the value of Pinto engines to plummett...
I think you are all somewhat missing the point, at least to a certain extent - "compliance with the MoT standard at the time of registration will
be required" - is a very "wooly" description & means you are agreeing to have your vehicle tested to whatever standard is in force
at the time of completion of the build - I see plenty of builds on here that have taken 10 years or more, what on earth the MoT regs are likely to be
in 10 years, god only knows.
Also, just because it doesn't affect you personally "I've got my car IVA'd & registered, I'm alright Jack" is not a
reason to allow others to get their plans trashed due to bureaucracy, the guys saying they have Pinto engines or similar - these certainly could be
made to pass current MoT regs, possibly even with carbs, but certainly not without a lot of faffing & tinkering
As I said b4, let's stick together on this & get some letters in to
Robert Lloyd-Smith
Zone 1/33,
Great Minster House
33 Horseferry Road,
London,
SW1P 4DR
As for "Still fuel injection and a catalyst still ought to be able to meet the requirements on pretty much any non-prehistoric engine?" -
yes, but if you'd just laid out ££££'s for a set of twin webbers or similar, I think you'd have every right to feel a bit miffed. Also,
if you have swapped cams, valves, had head work done then you may have a fair bit of retuning to do to get a car to pass. Remember very few people run
the stock air plenum & management so it's never going to be straightforward
At best we want existing regulations to continue & at worst a 2 or 4 year "breathing space" to allow builds to be finished
quote:
Originally posted by andyace
Ok so preparing for the worst (or best as we save the planet) .... assuming my 2.0 pinto with zx9r bike carbs won't pass emissions, what's my cheapest option (relative term) to get an engine which does meet current emissions
Assuming I buy a brand new Zetec 2 litre blacktop whats the cheapest option to get it to pass emissions?? Can I use my ZX9r carbs on it and still pass emissions or do I HAVE to go injection ... I have a type 9 .... would I need a cat ... ? I'm an old school engine person and don't have the knowledge (yet) of newer engines.
A new zetec will cost me £1100 ish, how much will it cost above this to get the cheapest passable engine ??
Would appreciate some input from my knowledgeable members, thanks
quote:
Originally posted by russbost...we want existing regulations to continue...
quote:
Originally posted by Sam_68
quote:
Originally posted by russbost...we want existing regulations to continue...
You don't speak for all of us, Russ.
Some of us have seen the writing on the wall. Emissions are going to continue to be driven down on mainstream cars, like it or not. The planet is dying and governments have got to be seen to at least try to do something about it.
The further out of step individually built vehicles become with mainstream legislation, the sooner they'll be banned outright.
Meeting current MOT standard (whatever that happens to be at the time) isn't all that stringent - it means that cars we're newly registering are allowed to be as dirty as the worst mainstream production cars of similar age that would be tolerated before being removed from the roads as being unfit and unroadworthy. It's really not that unreasonable a requirement, when you think about it.
By all means argue for a reasonable transition period, but I have no problem with being asked to comply with minimum levels of roadworthyness for cars of equivalent age in the longer term.
quote:
Originally posted by russbost
...so why not ask for the continued status quo?
quote:
Originally posted by Sam_68
quote:
Originally posted by russbost
...so why not ask for the continued status quo?
Because "we" don't want it. It's a bad idea, for the long-term health of the industry.
Evolve or die...
quote:
Originally posted by Sam_68
The further out of step individually built vehicles become with mainstream legislation, the sooner they'll be banned outright.
Anybody fancy writing a book on how to build one of these for £250?
Fred
quote:
Originally posted by jps
quote:
Originally posted by Sam_68
The further out of step individually built vehicles become with mainstream legislation, the sooner they'll be banned outright.
Yeah - Like they've banned traction engines and steam trains and steam cars... Oh no, because they have negligible impact in the grand scheme of things, they haven't have they!!!
Instead of forum members agreeing and disagreeing on various points of the proposed I.V.A changes, if they could put that energy into writing to the
person mentioned in the consultation document, Robert Lloyd-Smith , it may help us all, I have spent the afternoon composing a letter/email,
see it below, some may care to copy it word for word if that is easier for them , others may wish to add or subtract points, But if we all send
something in it may just help. Not only us, but others in the future.
Email; ivs.consult@dft.gsi.gov.uk
Robert Lloyd-Smith
Zone 1/33
Great Minster house
33 Horseferry road
London SW1P 4DR
Date
Ref; Road Vehicles improving air quality and safety consultation.
Dear Sir,
With regards to the above mentioned document, I do understand the need to review, and if necessary, update vehicle
safety and pollution specifications from time to time, however, I must object to question 4.10 regarding kit car emissions.
The proposal, if it were implemented, would have a major impact on a great many individuals who have spent hard earned money and many
hours, in some cases years, constructing vehicles , as yet unfinished, using recycled engines and other components that would otherwise have gone for
scrap, subsequently creating pollution in the process.
It will also have a dramatic impact on the U.K. specialist and kit car manufactures and there suppliers, whilst not a large industry
compared to major motor manufacturers, it is unique to the U.K. keeping a lot of people, a great number of which have specialist skills, fully
employed.
The introduction of the S.V.A. test, then the I.V.A. test has insured all vehicles are built to a safe standard, a fact borne out by the
low insurance premiums these cars command.
On a day to day basis, there are very few kit cars or classic cars used on the roads, most are reserved for days out or weekends, it is
not uncommon for these vehicles to have limited mileage insurance of only 2000 or 3000 miles a year, with the vast majority not covering 1000 a
year.
The emissions impact of such a small number of vehicles, doing very low annual mileage really doesn't warrant the very heavy handed
controls being considered, I strongly request this element of the proposed new legislation be dropped.
Yours Faithfully.
Well there's the letter if you want to copy it,please do, but whatever you do, please, please write something, please don't be
complacent and not do anything, if this legislation goes through, its one more nail in the coffin so to speak, and it will just make it harder and
harder for people to build individual road cars in the future
Thanks.
[Edited on 9/2/18 by clive7883]
[Edited on 9/2/18 by clive7883]
[Edited on 9/2/18 by clive7883]
[Edited on 9/2/18 by clive7883]
What Clive said ^^^, let's stop bickering & get some letters sent!
quote:
Originally posted by craigdiver
quote:
Originally posted by PorkChop
I think this is being blown out of proportion a bit and people are getting confused; the people that really need to worry about this is those fitting 80s or earlier engines. As I said earlier, the DfT seems to have made the assumption that if you have a Euro 1 or later engine, then you have the hardware to meet the 2002 MOT limits. This is an assumption I can understand, a big enough cat with enough precious metal, enough temperature and not running rich should be enough to oxidise enough CO and HC to meet the limits.
To put it in perspective, I have a very early, pre Euro 1 MX5 engine (which does have a cat and EFi). I'm not overly concerned about the proposals, it's just the exhaust line will need a bit of thought.
This is great info PorkChop - just to be crystal clear, you mention the need to meet Euro 1 for MOT, does this also apply to cars going through IVA? (you need to be able to pass 2002 MOT limits to pass IVA emissions test?)
One point that seems to be getting missed here. The mot limits are not set in stone. They can and will only be made more stringent and then we have an
ever moving set of goalposts. This is the big issue. What happens if you spend £xxx getting your engine to meet current standards only for them to
tighten up mot regs and your back to square one.
Send a letter/email. I don't think it will change the dft's mind as they are a complete bureaucratic nightmare devoid of all common
sense.
But we have to try!
quote:
Originally posted by russbost
What Clive said ^^^, let's stop bickering & get some letters sent!
quote:
Originally posted by sdh2903
One point that seems to be getting missed here. The mot limits are not set in stone. They can and will only be made more stringent and then we have an ever moving set of goalposts. This is the big issue. What happens if you spend £xxx getting your engine to meet current standards only for them to tighten up mot regs and your back to square one.
Send a letter/email. I don't think it will change the dft's mind as they are a complete bureaucratic nightmare devoid of all common sense.
But we have to try!
But by that point your already in with the masses and won't have any say as a collective community.
I can see you have differing views as everyone will. Yes this isn't a massive step now. But this is the thin end of the wedge.
quote:
Originally posted by sdh2903
...this is the thin end of the wedge.
quote:
Originally posted by PorkChop
quote:
Originally posted by russbost
What Clive said ^^^, let's stop bickering & get some letters sent!
Why? I disagree that it is something that needs objecting to. Bear in mind this directly affects me and my build.
quote:
Originally posted by russbost
"The thin end of the wedge was when we rolled over and accepted SVA without a fight, back in 1998." - Really? Disagree entirely, I thought pretty much everyone agreed that overall SVA was a good thing...
quote:
Originally posted by mattf
Some info. on the Complete Kitcar magazine website here
Done my bit and sent an e-mail with my concerns tonight. It potentially affects me running a 4age on webers. Car is almost finished too
@Sam_68 "Congratulations, though - you've obviously got the system that you wanted: nannied to the point where even the most trivial risk is
removed... including environmental risk." - Where do you come up with this cr*p from Sam? we certainly don't have a system that I like nor
wanted, as I pointed out had you bothered to read my post, SVA was one thing, IVA quite another & obviously I want a total nanny system,
that's why I designed such a boring middle of the road car!
To get back to NOT bickering & the important item that's actually in hand, there is a very important paragraph in that complete kitcar link
above which reads "Peter Bailey, of Chesil Motor Company has spoken to Mike Lowe who told him: “…if the consensus of the opinion is that this
will kill the British kit car industry, we are very much open to listening and asking Ministers if we can remove this proposal from the package of
proposals.” so it at least sounds as tho' the people in control MIGHT listen to sensible arguments; think about some of the ramifications of
this, would a Cobra with a modern fuel injected quiet, tame V8 be the same as one with a bucket sized carb on a big block old school V8? Obviously
not, same goes for stuff like Ford GT 40's, D type, SS100 etc etc ALL the old school replica's would either disappear or turn into toned
down versions much more like a modern car & quite losing the spirit of the original.
If you read the piece from Complete Kitcar there is much in there concerning engine choice & the reasons for it (I assume Chesil incidentally are
still using the old VW lump, was that ever available with injection, management & a CAT?), it warrants reading & the points raised therein are
precisely the sort of thing we should be pointing out to the powers concerned
As I've already said, if you agree with the proposals, fine, do nothing, that's your choice, but if you disagree then please write in &
try to send something original rather than just a copied template from someone else
quote:
Originally posted by russbost there is a very important paragraph in that complete kitcar link above which reads "Peter Bailey, of Chesil Motor Company has spoken to Mike Lowe who told him: “…if the consensus of the opinion is that this will kill the British kit car industry, we are very much open to listening and asking Ministers if we can remove this proposal from the package of proposals.”
Whoops - double post...
[Edited on 12/2/18 by jps]
quote:
Originally posted by russbostWhere do you come up with this cr*p from Sam?
quote:
I thought pretty much everyone agreed that overall SVA was a good thing, made a LOT of people clean up their act. IVA, however was a different matter, where else but in a government department could you think that an increase in charges of over 700% for a test that had barely changed could possibly be reasonable
quote:
Originally posted by jps
I suspect that it'll help a lot if there is representation from manufacturers about this change, I can imagine ministers more interested in changing policy if they think business will suffer. Is there anything this community could do to raise this issue with kit manufacturers, etc?
quote:
Originally posted by Sam_68
quote:
Originally posted by russbostWhere do you come up with this cr*p from Sam?
Why, directly from yourself, Russ:
quote:
I thought pretty much everyone agreed that overall SVA was a good thing, made a LOT of people clean up their act. IVA, however was a different matter, where else but in a government department could you think that an increase in charges of over 700% for a test that had barely changed could possibly be reasonable
On the one hand, you are saying that (apart from the cost) IVA is virtually identical to SVA, which 'everyone agreed' was a good thing. On the other, you are now saying that we have a system that you neither like nor wanted.
Which is it - you seem confused?
quote:
Originally posted by russbost
As usual, the pedant pulls individual sentences apart rather than looking at what's actually been said
quote:
Originally posted by russbost
I am hardly surprised that the Niche Vehicle Network haven't taken any notice as they are primarily manufacturers of brand new vehicles using modern technology such as carbon fibre, hybrid & electric motors, they are hardly likely to be interested in something affecting old technology are they? (please don't bother to answer that)
No you not think that the cliff edge proposed in the consultation is the main issue, disadvantage for those who are currently building.
There is not enough time for those people to change to a newer engine and the cost would be high.
Those who are building must respond to the consultation and I would hope those who have been lucky enough to have already completed theirs would
support the others not so luck especially if you have a Pinto engine for instance because you would have failed.
Let’s start a list of who has responded
1.me
This info is from the thread on Pistonheads
"I have now had confirmation via the assistant to my local MP that the new rules - if they come into force - will not be retrospective. They will
apply to cars registered later in 2018 at a date to be confirmed. Anyone building a car with an engine that won’t comply with current emissions
legislation needs to get it registered and IVA’d as soon as possible as a contingency against Government madness...."
To add to the list Paul started
Let’s start a list of who has responded
1.Snapper
2.Russbost
I would add, that if you are concerned about these proposals, but can't find time/be bothered to write in yourself, you can ask Adam Wilkins at
Complete Kitcar to add your name to the group submission they are making - adam@performancepublishing.co.uk
I've sent an email with my concerns even though I think my 1997 BMW engined Rush should pass when I get to test stage.
I think the manner in which they are planning to rush through the changes is entirely unfair to builders that have already started with an engine that
will struggle to pass the proposed new limits on emissions. I suggested (being as they love paperwork) that new builders embarking on a project from
the proposed date of the new limits download and complete a declaration to DVSA that ties them to the new legislation going forward. Existing builders
could complete a declaration that ties them to a completion date two years (or something) from the proposed date.
I understand that the government have to take action on air quality and kit builders can't be exempt from that but introducing changes that are
fair, proportionate and give an appropriate lead time for projects to be completed is surely the way forward.
On a side note I thought I saw on the document that the Niche Vehicle Network was on the list of consultees. I mentioned them in my email as I suspect
they are more concerned with the shifting of turnkey cars rather than kit builders and therefore could offer false representation in my opinion.
Chris
quote:
Originally posted by russbost
This info is from the thread on Pistonheads
"I have now had confirmation via the assistant to my local MP that the new rules - if they come into force - will not be retrospective. They will apply to cars registered later in 2018 at a date to be confirmed. Anyone building a car with an engine that won’t comply with current emissions legislation needs to get it registered and IVA’d as soon as possible as a contingency against Government madness...."
To add to the list Paul started
Let’s start a list of who has responded
1.Snapper
2.Russbost
I would add, that if you are concerned about these proposals, but can't find time/be bothered to write in yourself, you can ask Adam Wilkins at Complete Kitcar to add your name to the group submission they are making - adam@performancepublishing.co.uk
I have replied via an email, also sent a hard copy by post, a friend has also responded by post,
so that's 2 more..
Everyone should be responding online to the consultation and asking for Cars that go via BIVA to be exempt. Otherwise even cats and fuel injection may
not get you through as time goes on and the standards become even harder. remember they are going to be linked it to emissions rules at the test
date I.e. Therefore Amateur biulds will find this harder and harder as time goes on
so please respond to the consultation ask for BIVA exemption
[Edited on 18/2/18 by Hoylegj]
I've responded, if the proposals go ahead my build stops
For the attention of
Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
London SW1P 4DR
Dear Sirs,
proposal document called ‘Road Vehicles – Improving air quality and safety’.
The following are my response to sections 4.10 - 4.13 of the above document, and Questions 8 and 10
Q8. Do you agree with the introduction of WLTP in IVA, for light vehicles built after 1 July 2018? Answer: No
Q10. Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to
MOT standards according to the age of their engine? Answer: No
I am building, and have been for many years a Ronart W152, and whilst it is not a strict replica, it is a homage to the golden era of British motor
racing, as it is on lines of a1950 grand prix car. As such there is a need to have an earlier style engine to retain the character and style of the
car. It has been designed for jaguar XJ6 series 1,2 or 3, 4.2 litre straight 6 engine with period triple carburettors, Such an engine arrangement
would be impossible to meet the current mot and proposed emission criteria controls. The build commenced having only after the engine obtain the
historic age verification to allow emissions to be tested on an age related basis.
It could be said that the alternative would be to modify the chassis, mechanics, rear axle, electrics and body panels to accommodate a more modern
engine. As well as incurring unimaginable expense, such a change would detract from the vehicle, the whole design, the original character of the car,
and therefore its sale-ability. As it would no longer reflect the period the car is paying homage to. the car not been worth a fraction on the current
market resale price in excess of £40,000.
If an alternative solution is not possible as a modern jaguar straight 6 cylinder engine and axle are not available, and if they were would it
increase the build cost astronomically, and as explained above have detrimental effect on the resale values?
I Would there be existing builder who after expending many hundreds if not thousands of hours and personal expense into the build would effectively
have a project that would be uneconomical to continue as my projected build completion date is may years beyond the proposed implementation date.
On a wider view
Small scale manufacturers of specialist and kit cars do not form a big industry, but are unique within Europe and in fact in the world, having
produced thousands of specialist cars over the last 50 years, and have become established as the world centre for this type of car.
The introduction of SVA and then IVA allowed the kit car industry to produce vehicles to a recognized safe standard – a fact borne out by the low
insurance premiums that we as owners enjoy.
The introduction of the proposal would be the death of yet another small industry, and one that is unique in this country. It is another sign of the
Government not supporting small industries and removing the possibility of home build engineers, Rather favouring mass production and requiring
everyone to be the same.- not good.
It is important to economic growth that this industry to continues both for manufactures, the supply chain suppliers and the builders , but these
current proposals could be, and many are sure will be the death of many small firms. This is not an excessive expectation, but a reality. As many have
individually explained, it is the proposed change to MoT emissions standards for kit cars that would be very damaging to our cars… the older style of
engines perhaps being vital to the core appeal of the model, and/or the potential costs of fitting compliant engines being so expensive as to cause
sales to fall to unsustainable levels.
Many builders and manufactures have small workshops and not a vast workforce, but all have many times that number indirectly employed who have
specialist skills and rely on our continued, and regular, work.
The proposal could be seen as a personal vendetta to the kit car industry and the builders as, if the old engines are in classic cars and the cars are
restored, the proposals don’t apply. But if we refurbish the old engines and these are done to the same standard as applied by the classic car owner,
for use in a kit car ,they do apply and have to meet current mot emission standards.
As you will notice, on a day-to-day basis there are very few classic cars on the roads and even less Kit cars, all often reserved for special
occasions, days out and perhaps limited touring during the summer months.
It is not uncommon for these cars to have limited mileage insurance, typically 2000-6000 miles per year, with many not covering more than 1000 miles
annually. The emissions impact by this small ‘fleet’ of cars is also tiny and does not warrant the heavy-handed controls that are being considered.
I hope that you now have a better picture of our industry and its precarious position if this legislation became enacted.
I strongly request that this part of the proposed new legislation be dropped.
Regards
The way I read it as the years pass the rules for emissions will get tighter. By that time all cars will be electric or hydrogen. If we have to make.out builds meet those standards we will struggle to build anything. Your choice, respond to the consultation or not. Personally I enjoy this hobby/sport and have responded to try and keep options open for others that follow us
Just had a reply to my email...
"Thank you for your recent response to our consultation on Road vehicles - Improving air quality and safety.
I can confirm that we have received your comments and that your response will be carefully considered as part of the consultation".
The results of the consultation will be published alongside the consultation documents, at:
https://www.gov.uk/government/consultations/road-vehicles-improving-air-quality-and-safety
Yours sincerely
Robert Lloyd Smith
Mr Robert Lloyd Smith | International Vehicle Standards, Department for Transport
If the proposals are adopted;
1. Kits that use donors made in the last 25 years will not be affected.
2. Kit cars that are currently registered will not be affected if the proposals are adopted.
3. New car MOT standards as ref in the proposal means BET (basic emission test). To comply a CAT will be needed.
4. The majority of kits manufactured today use post 1995 engines and therefore comply with BET.
5. Kits currently under construction with carbs may struggle to pass but with a CAT it may be possible.
6. Kits that use engines over 25 years old may struggle to pass but with a CAT it may be possible.
7. Currently a kit with a post 1995 engine goes through a far more strict test than one with a 60's engine but that may change.
"3. New car MOT standards as ref in the proposal means BET (basic emission test). To comply a CAT will be needed." - yes, but what will MoT
emission standards be in, say, 3 years time - no one knows, agree to this at your peril!
Well, they haven't changed for almost 16 years, when OBD / Euro 3 came in, beginning in 2000. Some food for thought and for people to draw their own conclusions - the Euro standard has just entered it's sixth iteration since then (Euro 3, 4, 5, 5b, 6b, 6c and recently 6d Temp).
Well, if it hasn't changed in 16 years it obviously isn't going to is it? No, wait, by 2040 (supposedly) ALL new cars will be electric, so
what MoT regs do you think we'll have then? Is it not feasible (likely perhaps) that we may have changes a long way b4 that? Why take a
chance?
& it still doesn't change the position for the poor sod with a several 1000 £££'s worth of carb'ed V8 sitting in his garage &
no way of finishing the car b4 June - wake up & smell the roses!
I can't believe people are being so lax about this, if this goes through, it will be the start of the end for kit cars, hot rods and even modified road cars, re mapping etc will all eventually be affected !!!
I'm not sure that many people are being "lax" about it. I know many that have emailed to make their point. I also know some people are
in agreement with the proposed changes going forward. I think the real issue lies in the timescale in which any changes are due to be made,
that's the unfair bit as I see it. My car will probably be alright ('97 BMW 2.8 with EFI and CAT) come IVA day but I emailed to make the
point on behalf of other people that are building using carbs, no cats etc.
Personally I think it won't happen but that's just my opinion and I'm usually wrong.
MOT emissions are changing on 20th May.
The new rules will allow kit cars built based on donors up to 25 years old to pass.
Those with older engines or carbs will need a CAT and then they may pass.
The levels to achieve are quoted below from the new MOT manual.
"The emissions limits to be met are specified for both the fast and normal idle tests.
At fast idle, CO must be at or less than 0.2%, HC at or less than 200 parts per million
(ppm), and the lambda value(1) must be between 0.97 and 1.03. At normal idle, CO
must be at or less than 0.3%."
Not me - I was writing to the magazines (those being the days before internet was in such commonplace use) saying exactly that it was the thin
end of the wedge, for exactly the reasons that have transpired... that it would give an easy mechanism by which the Regs could be progressively
tightened and made more obstructive, without the ability for effective resistance, to the point where the industry ceased to be viable.
We were sold a dummy, with SVA - the ultimate outcome was inevitable.
To be fair, my concerns were based mainly on the similar system for homebuilt aircraft, where the UK has a delightfully Catch-22 situation that
you're not allowed to build a design unless it has proven successful over so many flight hours, but you're not allowed to fly a prototype to
gain those hours - leaving us only able to pick up designs second-hand from other countries.
I firmly believe that you can't have a progressive and innovative engineering industry without some risk, and there was never any evidence
that kit or self-built cars were particularly dangerous - just the opposite, from the insurance figures; they were always a very good risk.
Congratulations, though - you've obviously got the system that you wanted: nannied to the point where even the most trivial risk is
removed... including environmental risk.
quote:
Originally posted by chillis
...the reality is if the SVA had been opposed with any degree of vigour then kit cars would have been banned there and then.
...Individual and individualised transport has had its day sooner or later we all have to accept that
quote:
Originally posted by Hoylegj
Everyone should be responding online to the consultation and asking for Cars that go via BIVA to be exempt. Otherwise even cats and fuel injection may not get you through as time goes on and the standards become even harder. remember they are going to be linked it to emissions rules at the test date I.e. Therefore Amateur biulds will find this harder and harder as time goes on
so please respond to the consultation ask for BIVA exemption
[Edited on 18/2/18 by Hoylegj]
quote:
Originally posted by stig mills
MOT emissions are changing on 20th May.
The new rules will allow kit cars built based on donors up to 25 years old to pass.
Those with older engines or carbs will need a CAT and then they may pass.
The levels to achieve are quoted below from the new MOT manual.
"The emissions limits to be met are specified for both the fast and normal idle tests.
At fast idle, CO must be at or less than 0.2%, HC at or less than 200 parts per million
(ppm), and the lambda value(1) must be between 0.97 and 1.03. At normal idle, CO
must be at or less than 0.3%."
quote:
Originally posted by russbost
...what are the MoT limits going to be in 2020, 2022 etc - the point is we don't know
Well, as usual Sam you are obviously 100% right as I've never, ever known you to be wrong about anything, I suggest you should write in & tell the powers that be what a marvellous idea it all is. They'll be able to put your reply on a pile all of it's own - where it belongs!
quote:
Originally posted by russbost
Well, as usual Sam you are obviously 100% right as I've never, ever known you to be wrong about anything, I suggest you should write in & tell the powers that be what a marvellous idea it all is. They'll be able to put your reply on a pile all of it's own - where it belongs!
The issue is those in the middle of the build process, they will be hugely disadvantaged and it specifically those people I would like he collective
to consider and support them even if it just to give a longer period for them to complete their builds
I cannot see why you could not help your fellow builders!
quote:
Originally posted by snapper
The issue is those in the middle of the build process, they will be hugely disadvantaged and it specifically those people I would like he collective to consider and support them even if it just to give a longer period for them to complete their builds
I cannot see why you could not help your fellow builders!
quote:
Originally posted by snapper
The issue is those in the middle of the build process, they will be hugely disadvantaged and it specifically those people I would like he collective to consider and support them even if it just to give a longer period for them to complete their builds
I cannot see why you could not help your fellow builders!
"Originally posted by snapper
The issue is those in the middle of the build process, they will be hugely disadvantaged and it specifically those people I would like he collective
to consider and support them even if it just to give a longer period for them to complete their builds
I cannot see why you could not help your fellow builders!"
Sam "I don't think anyone disputes that, or would fail to support transitional arrangements"
Sam "We're getting away lightly with the offer of MOT limits as the testing criteria, so grab it while you can!"
Sam "and I already have; once in a private capacity, once as a member of the NVN" in response to "I suggest you should write in &
tell the powers that be what a marvellous idea it all is"
Sam "resistance to what amounts to a very mild rationalisation of the Regs in the form of these latest changes will merely prod the sleeping
monster of central Government into realising we're simply not worth the trouble any more, for a relative handful of oily-fingered eccentrics, and
the plug will be pulled on IVA, period."
Make your mind up Sam - you can't have all of the above statements as being correct! & by your own previous comments & apparent support
which you claim to have written in about, you clearly do NOT support any transitional arrangements. Good Grief - you surely cannot possibly have got
something wrong????? No doubt you will be able to put me straight as to exactly how the contradictory statements, all from yourself & one swiftly
followed by another are in fact not contradictory at all, but in fact compliment one another perfectly!
Also I'd like to see some evidence for "The MOT emissions test will never be a particularity strict standard"
& I'm now really annoyed with myself as I've responded & let you drag the post totally off topic again, I can only hope that people
find our bickering sufficiently entertaining to get more people reading the thread! I'm sure they are capable of making their own minds up as to
what will or will not help the industry
quote:
Originally posted by russbost
Make your mind up Sam - you can't have all of the above statements as being correct!
quote:
Originally posted by russbost...you clearly do NOT support any transitional arrangements
quote:
Originally posted by Sam_68
...Certainly agree that a period of grace would be nice, but if we don't get it, life goes on...
quote:
Originally posted by Sam_68
...By all means argue for a reasonable transition period, but I have no problem with being asked to comply with minimum levels of roadworthyness for cars of equivalent age in the longer term.
Sam, you say you've written in to support the proposed legislation, yet you say you support the bulk of the rest of us in saying that, AT
MINIMUM, we should have a transition period, if you can't see that those 2 statements appear totally contrary, then I can only suggest you go to
Specsavers. "will merely prod the sleeping monster of central Government into realising we're simply not worth the trouble" would
certainly appear to be a direct suggestion for the rest of us NOT to raise objections
You've said several times that I don't represent the rest of LCB or indeed the industry on objecting to this - I have never suggested so far
that I was or am representing anything or anybody other than myself, however, it would appear from response both here & elsewhere that my views
are much more in line with most others than yours are, you appear to take a contrary view to just about everyone
I am not as you suggest in a "blue funk" about anything, I just think that agreeing, without any sort of opposition, to legislation that we
actually have no way of knowing what it will be in a few years time, is just plain daft. I am really pretty unconcerned at the legislation with regard
to it's direct affect on me, but do not see that as a reason to not support others
Having just had the AGM at Essex Kitcar Club, I CAN unequivocally say, that I have the support of everyone who attended the AGM (& several who
sent apologies for absence) & that there was not one single person who dissented. We will most certainly be putting the club name behind the bulk
objection that Adam at CKC is putting in.
Perhaps you could explain how you think I'm reading one thing & interpreting another?
Maybe it's time you took a holiday Sam, I think you need one! I would imagine the bulk of LCB members would hope it's a long one to
somewhere where there's no internet connection ...............
Now for anyone still reading, you still have around 6 days to get an objection to these heavy handed & ill advised proposals, I would remind
everyone again that you can reply online, apparently not quite as hard as I thought, people have said all irrelevant Q's can be ignored or simply
answer no to them, or write in, as many of us have to
Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
London SW1P 4DR
This issue is being discussed on many internet forums, as you might guess.
I have noticed this on the UK Cobra Club Forum. See post number 164 on page 17.
http://www.cobraclub.com/forum/showthread.php?t=59824&page=17
Response from DfT:
"The proposal was to bring this into force at the same time as the rest of the regulation, likely to be 1 September 2018. However due to the
volumes of comments received, many of which advocate a postponement of say 2 years, we will need to re-consider this. In fact the whole element of the
proposal which affects kit cars is likely to come under scrutiny given the vast volumes of negative comment, so it may be removed altogether."
NTDWM, I am just a lurker over on the Cobra Forum.
quote:
Originally posted by russbost
Sam, you say you've written in to support the proposed legislation, yet you say you support the bulk of the rest of us in saying that, AT MINIMUM, we should have a transition period, if you can't see that those 2 statements appear totally contrary, then I can only suggest you go to Specsavers.
Ah, so we're down to name calling now!
You are truly unbelievable, I'm the Troll??? Really, I suppose coming from the Arch Troll among Trolls I should take that as a compliment! Remind
me, how many forums is it you've been banned from?
What I said, if you read slowly and carefully, using you finger to follow the words, if necessary, is:
"you support the bulk of the rest of us in saying that, AT MINIMUM, we should have a transition period" the phrase "AT MINIMUM"
refers NOT to anything you've said, but to what the bulk of people on this thread have said - or is your understanding of English so poor that
that is completely beyond you?
I would love to see the response you've sent in to the consultation as apparently it both supports the proposals as they are & yet also
supports a transitional period (which most certainly is contrary to the proposals)
Anyway, back to the thread, & back on topic, I think the response from Softfeet found on the Cobra forum:-
"The proposal was to bring this into force at the same time as the rest of the regulation, likely to be 1 September 2018. However due to the
volumes of comments received, many of which advocate a postponement of say 2 years, we will need to re-consider this. In fact the whole element of the
proposal which affects kit cars is likely to come under scrutiny given the vast volumes of negative comment, so it may be removed altogether."
is really encouraging as it would definitely imply that the powers that be are actually listening & do take notice of both the volume of
objections & what they are objecting to, I would strongly encourage anyone that has any objection to the proposals as they stand to get a response
in to the consultation b4 the cut off date of Mar 2nd
quote:
Originally posted by russbost
Remind me, how many forums is it you've been banned from?
quote:
Originally posted by russbost
"AT MINIMUM" refers NOT to anything you've said, but to what the bulk of people on this thread have said - or is your understanding of English so poor that that is completely beyond you?
quote:
Originally posted by russbost
I would love to see the response you've sent in to the consultation as apparently it both supports the proposals as they are & yet also supports a transitional period (which most certainly is contrary to the proposals)
quote:
Originally posted by Sam_68
...Certainly agree that a period of grace would be nice, but if we don't get it, life goes on...
Jesus guys. Get a room for f**k sake.
quote:
Originally posted by softfeet
This issue is being discussed on many internet forums, as you might guess.
I have noticed this on the UK Cobra Club Forum. See post number 164 on page 17.
http://www.cobraclub.com/forum/showthread.php?t=59824&page=17
Response from DfT:
"The proposal was to bring this into force at the same time as the rest of the regulation, likely to be 1 September 2018. However due to the volumes of comments received, many of which advocate a postponement of say 2 years, we will need to re-consider this. In fact the whole element of the proposal which affects kit cars is likely to come under scrutiny given the vast volumes of negative comment, so it may be removed altogether."
NTDWM, I am just a lurker over on the Cobra Forum.
Ive logged on for the first time in ages to see what all the fuss was about the emissions regulations
it appears that the Locostbuilders forum is alive and well, and Ive not contributed for 86 months
and by the time I reached the end of the comments
I had an understanding of the new rules and had already sent my online reply in regarding some grace period for the older carb engine builds still in
progress (my dads) - thanks
i bought the carbs for his engine in 2004....
so we are technically 14 years and counting.
donor Mk11 escort shell was thrown in a skip that's how long ago it was
the chassis was finished about 10 years ago
what we need is something like crowd building
I have driven it in the street and we have all the remaining parts, so its just time and moving boxes of washing powder/random boxes stored on top of
the car.
it will be a barn find before long
i agree new builds should move with the times, like everything really, its called progress, but, to change the rules during peoples builds is a bit of
double standards. Major projects in the UK are not affected by standards changes mid way through as the costs would go up. Id already expect the DFT
to know that, maybe not.
what they have done now is potentially put a spike the IVA booking process system that maybe wasnt all that efficent anyway by the sounds of it. so
our first application will be even slower....
does anyone go down to the restoration club in washington on here?
that was the ony place i did any work on classic cars as you always had a deadline to meet on the hire of the facilitys/bay
maybe thats an option..
thanks
IC
quote:
Originally posted by ianclark1275
... to change the rules during peoples builds is a bit of double standards. Major projects in the UK are not affected by standards changes mid way through as the costs would go up. Id already expect the DFT to know that, maybe not.
I'll still go with the fact that we have a decent chance of either removing or, at minimum, amending the proposals; as posted above:-
"The proposal was to bring this into force at the same time as the rest of the regulation, likely to be 1 September 2018. However due to the
volumes of comments received, many of which advocate a postponement of say 2 years, we will need to re-consider this. In fact the whole element of the
proposal which affects kit cars is likely to come under scrutiny given the vast volumes of negative comment, so it may be removed altogether."
Note, it says VAST volumes of NEGATIVE comments, PLEASE keep them going in guys we still have a few days, encourage any local clubs you are members of
to also add their concerns, the more individual objections the more likely this is to be squashed
Ok, it's still only going to be a stay of execution as they are intent on outlawing diesels by 2030 & petrol by 2040, but we might as well
enjoy our vehicles as long as we are able to
I'll post the address again as I'm sure many people haven't read the whole thread
Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
London SW1P 4DR
My response to him mailed today, guaranteed delivery for tomorrow. I appreciate my centiment won't match everyones here, particually those who
want to build the simplest car possible. Biggest thing for me is they've made consessions for the vehicle converter people but none for kits.
Dear Robert LloydSmith
Road Vehicles: Improving air quality and safety
I am writing to raise questions about the draft report that proposes changes to the emissions testing for IVA and submit a formal objection to the
neglect these proposals appear to show to the kit car industry in comparison to multstage build based SMEs and vintage/classic rebuilds.
The report proposes an exemption for multistage build SMEs acknowledging the cost implications of these changes with receipts proving vehicle
purchase before the implementation date. There is however no similar exemption for kit car builders whose projects are typically on far longer time
scales and on tighter budgets.
The kit car industry has been a development ground for many well known originally British manufacturers who started off as kit car manufacturers such
as TVR, Lotus, and Ginetta. Without significant safe guarding the industry is likely to suffer significantly, directly effecting a large number of
supporting SMEs over the country and the death of the industry would have negligible difference to total UK emissions.
In direct relation to the text of the document it does not clearly address the four different routes to vehicle registration for the builders:
1. All parts new, heading for a new registration. This does allow for a number of major components to be reused if they are fully refurbished.
2. If enough parts are reused from the original vehicle then an age related registration is granted.
3. If too few of the parts come from a single donor then a Q plate is issued.
I believe the MOT testing to be related to the age of the registration plate number (when there is not a specific entry in the MOT guide book) whereas
new MOT regulations relating to emissions do not tend to be retrospectively applied to a generation of vehicles to the point where they’d be forced
off the road. So current MOT standards could be interpreted as the MOT tests that the donor vehicle would have been subjected to if still on the
road.
The proposal seems to focus on the use of older engines (perhaps targeting carburettor and / or pre catalytic converter) but is ambiguous to what is
actually meant by “date of registration” in relation to age related registrations.
In addition, “We are proposing that for kit cars, compliance with the MOT emissions standards current at the date of registration will be required”
leaves amateur builders in an impossible situation where we are needing to double guess what the government is going to do over the period of time it
would take to go from design to IVA test. This proposal itself demonstrated the short time scale between proposals being released to the general
public and the proposals being implemented. Few kit car builds fit within a year!
It does appear that the kit car industry is being unfairly targeted here in comparison to the vintage rebuild or multistage build industries. The
comparatively small number of vehicles within this market would suggest that directly targeting this section is not going to result in an
insignificant change in the total UK emissions.
While I personally believe that the days for carburettors on new builds has past and kit car builders should consider moving over to more modern EFI
engines, forcing ambiguous changes on us like this and in such as short time frame without offering similar concessions as offered to other sub
sections is wholly inappropriate.
Perhaps vehicle excise duty is a far fairer way to tackle this issue?
[Edited on 28/2/18 by WesBrooks]
Spot the obvious mistake! Four routes mentioned. I was going to discuss the use the same registration route if you bypassed the IVA by keeping the
same chassis, but scrubbed around it as since it doesn't need an IVA I thought it would confuse matters. Alas forgot to chamge four to three!
Cock up #2. Following sentence should have been significant rather than insignificant:
The comparatively small number of vehicles within this market would suggest that directly targeting this section is not going to result in an
insignificant change in the total UK emissions.
Any how, not posting here for a grammatical review, merely sharing what I've sent in. Writing letters like this aren't easy when you've
a ten month old intent on slapping your keyboard!
[Edited on 28/2/18 by WesBrooks]
As I mentioned in my post further up the thread, my issue is slightly different in that my business does not chiefly build "kit cars" as
such, but we rebuild and radically modify road cars, to the extent that some are then actually NEW vehicles with all-new parts. These regulation
changes could have the effect of meaning that because these are not technically "kit cars" then they would have to go through the full WLTP
process.....forget tricky MOT's and multi stage cats, thats easy!! The difficult bit would be funding the potential millions of pounds worth of
data acquisition and testing needed to get the WLTP data.
As I stated to Dft in my response, what we ALL need is a clarification of what constitutes a "kit car" and I pushed for this categorisation
to mean any vehicle currently eligible for BIVA rather than full IVA.
Hopefully this will be the end result
Then hopefully the rules regarding that category will remain as they are.
Problems I was trying to address:
Pace of change.
Lack of clarity.
Inconsistent approach.
No delay in implemtation or concessions for active projects.
Like others have said I think kit cars are being hammered as it's an easy, low fruit target.
The opportunity to respond on this closes TOMORROW - 11:45 PM. You can email to ivs.consult@dft.gsi.gov.uk
Reading other peoples responses that they then posted on here helped me to write what I sent in by email. So here's my response incase it helps
anyone else.
"I am writing in response to the consultation on the proposed changes contained within 'Road vehicles: improving air quality and
safety'.
On the whole I would comment that I am very supportive of efforts to improve the environment and to reduce the environmental impact of motor
vehicles.
I would like to make specific comment on, and object to, the proposed changes which would apply to 'kit cars' which are subject to the IVA
process - specifically that referenced at 4.11 / Question 10 in the consultation document - which would remove the possibility that vehicles presented
at IVA can have their emissions standards tested against emissions standards relevant to the year of manufacture of the engine.
I have been building a 'kit car' over a period of several years, as is often the case with this hobby. It is a replica of the Lotus 7 and,
as such I am building the car using a relatively low powered petrol engine, running on carburettors, to maintain the character and style of the car on
which it is based. Such an engine arrangement would be impossible to meet the current MOT and proposed emission criteria controls. In building my car
I am effectively recycling many parts of the 1985 Ford Sierra that I purchased as the 'donor car', which would include reusing the engine
from that vehicle in it's original form. The consultation document does not clearly specify a timescale for implementation for the changes, but
once implemented the change would most likely mean that it would not be possible for me to pass the IVA test. It would appear from the timescales for
other changes that are defined in the document that I could expect this change to be implemented within only a few months, which would not give me
enough time to complete my build and present my car for IVA before the change.
I'm well aware that I am not the only person who would be affected by the change in this way and would note that, although a relatively niche
hobby, as well as this change being felt at the individual 'builder' level there is a sizeable UK sector which supports amateur car
building, both in terms of 'kit' providers, but also many small businesses which provide parts or components (bespoke manifolds for
example). This proposed change, especially if introduced quickly, may have some immediate impact on wider industy, such as redundancy of stock or
products, but may also undermine longer term confidence in the customers who often enter into building of 'kit cars' with the expectation
they may take many months if not years to complete their project. They may be far less willing to do so if there is experience of significant
regulatory change being implemented at short notice.
I also note that these changes will remove the potential to 'recycle' engines from older vehicles (as I am) but will not have any form of
retrospective application. I think this is correct, as the document notes, the number of older vehicles are reducing on an ongoing basis and even in
the production of 'kit cars' many engines are being utilised which will meet the proposed standards. However this highlights the point that,
in real terms, the longer term environmental impact of these proposed changes is likely to be insignificant. 'Kit cars', most of which are
run at low annual mileages in any event, are less and less likely to be built with 'older engines' into the future. It is also worth
considering that the proposal may simply mean that car enthusiasts who wish to use vehicles with 'older' engines may simply restore/maintain
'older' vehicles rather than recycle them into 'kit cars', nullifying the presumed intention to remove older engines from use.
I therefore object to the proposal on several basis:
The proposed change would disproportionately affect vehicle enthusiasts who wish to recycle 'older' engines into 'kit-cars',
in comparison to any motorist who is simply using an older vehicle or who runs a 'classic car'. This is inconsistent and 'kit-car'
applications should remain allowable as should remain the case for any other 'older' vehicle.
The environmental impact of this change is likely to be minimal, despite significant potential for personal and industry impact.
The change will remove the possibility for 'replica' kit cars which reproduce 'classic' cars (such as those built by
http://www.suffolksportscars.com/) to be produced, which will be a disappointing removal of an accessible way for some of the general public to own
and enjoy vehicles which are otherwise the domain only of the very wealthy.
I appreciate that there will be a variety of views on this subject and many responses to the consultation. I would therefore request that, if the
final decision is that the change to which I object is to implemented, the timescale for implementation should be deferred for at least 2 years to
allow completion of current projects and a period of adjustment for the wider industry."
Anyone know how long it'll take to analyse our responses?
I have £200 of xflow bearings or an old Mondeo to buy
The governments guidance on consultation principles states
I. Consultation should facilitate scrutiny
Publish any response on the same page on gov.uk as the original consultation, and ensure it is clear when the government has responded to the
consultation. Explain the responses that have been received from consultees and how these have informed the policy. State how many responses have been
received.
J. Government responses to consultations should be published in a timely fashion
Publish responses within 12 weeks of the consultation or provide an explanation why this is not possible. Where consultation concerns a statutory
instrument publish responses before or at the same time as the instrument is laid, except in exceptional circumstances. Allow appropriate time between
closing the consultation and implementing policy or legislation.
I have a Locost Xflow ready for IVA application, what is the chance of getting it tested before April, assuming it goes through. How long does it take on average to get a test date. Surely it would be April 2019 to change?
quote:
Originally posted by Kevin
I have a Locost Xflow ready for IVA application, what is the chance of getting it tested before April, assuming it goes through. How long does it take on average to get a test date. Surely it would be April 2019 to change?