NS Dev
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| posted on 22/2/18 at 02:35 PM |
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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]
Exactly this!! While the consultation refers to "kit cars" in several places. These are not defined in the rest of the IVA system and thus
are not a defined entity. While with my "locostbuilders" hat on I know that world is ok as it is exempt from WLTP, with my business (car
building in general not necessarily kits) hat on, much of my work could end up not exempt, and that would be a game changing business terminating
concept!
I have written in for clarification and to point out that the exemption from WLTP needs to be for all BIVA vehicles
Retro RWD is the way forward...........automotive fabrication, car restoration, sheetmetal work, engine conversion
retro car restoration and tuning
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russbost
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| posted on 22/2/18 at 03:18 PM |
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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%."
Yes, but Stuart, what are the MoT limits going to be in 2020, 2022 etc - the point is we don't know, so, agree with the proposals as they stand
& you are agreeing to rules you know nothing of!
I no longer run Furore Products or Furore Cars Ltd, but would still highly recommend them for Acewell dashes, projector headlights, dominator
headlights, indicators, mirrors etc, best prices in the UK! Take a look at http://www.furoreproducts.co.uk/ or find more parts on Ebay, user names
furoreltd & furoreproducts, discounts available for LCB users.
Don't forget Stainless Steel Braided brake hoses, made to your exact requirements in any of around 16 colours.
http://shop.ebay.co.uk/furoreproducts/m.html?_dmd=1&_ipg=50&_sop=12&_rdc=1
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NOTE:This user is registered as a LocostBuilders trader and may offer commercial services to other users
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Sam_68
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| posted on 22/2/18 at 04:03 PM |
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quote:
Originally posted by russbost
...what are the MoT limits going to be in 2020, 2022 etc - the point is we don't know
But it's a safe bet that they will not be so strict as to cause anything that's not ridiculously dirty by the standards of the day
to fail.
As Stuart has pointed out, the MOT criteria for 'current' vehicles are easily complied with by anything with fuel injection and a
catalyst.
The MOT emissions test will never be a particularity strict standard, compared to that set by emissions testing for type approval - its purpose
is to identify vehicles that have fallen into such a poor state that they need to be removed from the roads, so its level will always be set such that
only vehicles that are considered completely intolerable and unroadworthy will be failed.
If you enjoy paranoid scaremongering and speculation about what might happen, you need to go to the Niche Vehicle Network symposium and listen
to the talk of bringing in proper low-volume testing of emissions so that smaller manufacturers can 'benefit' from the normal CO2-related
taxation classes. It would 'only' cost circa £7000 per vehicle type, and a lot of the smaller manufacturers are enthusiastic about the
idea, because the low weight of their products actually makes them capable of gaining very attractive tax banding.
No, we don't know what might happen in 2022... but if we resist a rationalisation of the Regs now, it could just as easily be a proper test for
CO2 banding of everything in a couple of years, when it becomes obvious how far out of step the kit car market has become with the mainstream.
Needless to say, that really would screw self-building - to an almost Australian level of cost and difficulty.
We're getting away lightly with the offer of MOT limits as the testing criteria, so grab it while you can!
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russbost
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| posted on 22/2/18 at 05:56 PM |
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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!
I no longer run Furore Products or Furore Cars Ltd, but would still highly recommend them for Acewell dashes, projector headlights, dominator
headlights, indicators, mirrors etc, best prices in the UK! Take a look at http://www.furoreproducts.co.uk/ or find more parts on Ebay, user names
furoreltd & furoreproducts, discounts available for LCB users.
Don't forget Stainless Steel Braided brake hoses, made to your exact requirements in any of around 16 colours.
http://shop.ebay.co.uk/furoreproducts/m.html?_dmd=1&_ipg=50&_sop=12&_rdc=1
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NOTE:This user is registered as a LocostBuilders trader and may offer commercial services to other users
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Sam_68
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| posted on 22/2/18 at 06:28 PM |
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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!
Why thank you, Russ - and I already have; once in a private capacity, once as a member of the NVN. 
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snapper
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| posted on 23/2/18 at 04:58 PM |
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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!
I eat to survive
I drink to forget
I breath to pi55 my ex wife off (and now my ex partner)
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joneh
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| posted on 23/2/18 at 05:28 PM |
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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!
That's me. Halfway through refurbing my xflow with twin 40s. 
[Edited on 23/2/18 by joneh]
[Edited on 23/2/18 by joneh]
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Sam_68
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| posted on 23/2/18 at 06:02 PM |
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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!
I don't think anyone disputes that, or would fail to support transitional arrangements.
That could be as simple as registering your 'in progress' build with the DVLA, giving them details of the type of car you are building
(assigning it a chassis number), the engine it is fitted with, and the reason you need an exemption. You could then take as long as you like with the
build, and when it comes to IVA it would be tested under the old rules.
I am certain that the handful of manufacturers whose products are genuinely reliant on archaic engines (Chesil and Suffolk Sports Cars are the two
that immediately spring to mind) will be seeking similar transitional arrangements to give them time to redevelop their products for more modern
engines
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russbost
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| posted on 23/2/18 at 06:47 PM |
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"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
I no longer run Furore Products or Furore Cars Ltd, but would still highly recommend them for Acewell dashes, projector headlights, dominator
headlights, indicators, mirrors etc, best prices in the UK! Take a look at http://www.furoreproducts.co.uk/ or find more parts on Ebay, user names
furoreltd & furoreproducts, discounts available for LCB users.
Don't forget Stainless Steel Braided brake hoses, made to your exact requirements in any of around 16 colours.
http://shop.ebay.co.uk/furoreproducts/m.html?_dmd=1&_ipg=50&_sop=12&_rdc=1
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NOTE:This user is registered as a LocostBuilders trader and may offer commercial services to other users
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Sam_68
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| posted on 23/2/18 at 07:39 PM |
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quote:
Originally posted by russbost
Make your mind up Sam - you can't have all of the above statements as being correct!
Yes I can. Which of the statements you've quoted are in any way mutually exclusive?
The responses I've sent say that I think the proposed change is an excellent idea, going forward, but that it would be beneficial to have
transitional arrangements for those individuals who already have a build in progress, and for those companies whose standard products are currently
dependent on archaic engines.
It really is very simple.
There's really no need to get your knickers in a twist - we've even seen poor old Mistrale put his project (into which I'm assuming
he has committed many hundreds of hours) up for sale because of this nonsensical scaremongering, when there was really no need to do so.
I am genuinely interested to know how you get to:
quote:
Originally posted by russbost...you clearly do NOT support any transitional arrangements
From:
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.
As with the proposed legislation itself, you seem to be reading one thing, but then interpreting it as something completely different, and
unnecessarily working yourself into a blue funk in the process.
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russbost
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| posted on 24/2/18 at 10:28 AM |
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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
I no longer run Furore Products or Furore Cars Ltd, but would still highly recommend them for Acewell dashes, projector headlights, dominator
headlights, indicators, mirrors etc, best prices in the UK! Take a look at http://www.furoreproducts.co.uk/ or find more parts on Ebay, user names
furoreltd & furoreproducts, discounts available for LCB users.
Don't forget Stainless Steel Braided brake hoses, made to your exact requirements in any of around 16 colours.
http://shop.ebay.co.uk/furoreproducts/m.html?_dmd=1&_ipg=50&_sop=12&_rdc=1
|
NOTE:This user is registered as a LocostBuilders trader and may offer commercial services to other users
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softfeet
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| posted on 24/2/18 at 12:10 PM |
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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.
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Sam_68
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| posted on 24/2/18 at 02:56 PM |
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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.
Russ, the source of your confusion, as I have said, is that your eyes are reading one thing, and your brain is interpreting another.
YOU have introduced the words 'AT MINIMUM' (in capital letters, no less!). At no time have I used those words or said any such thing.
IF YOU MUST CONTINUE TROLLING, PLEASE DO SO WITHOUT FABRICATING WORDS THAT I HAVE NEVER USED.
What I said, if you read slowly and carefully, using you finger to follow the words, if necessary, is:
"I don't think anyone...would fail to support transitional arrangements"
"a period of grace would be nice, but if we don't get it, life goes on.."
"By all means argue for a reasonable transition period..."
None of those statements suggests that I will only support the legislation if AT MINIMUM there is a transition period.
Supporting those who wish to argue for such an amendment is not the same as being unwilling to accept the legislation without it, except, perhaps to
your twisted and irrational logic.
Indeed, I would have thought the second of my quotes above makes it pretty clear even to the most argumentative and obtuse of village idiots that if
no transitional period is offered, then I would be pretty relaxed about accepting that outcome.
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russbost
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| posted on 24/2/18 at 05:58 PM |
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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
I no longer run Furore Products or Furore Cars Ltd, but would still highly recommend them for Acewell dashes, projector headlights, dominator
headlights, indicators, mirrors etc, best prices in the UK! Take a look at http://www.furoreproducts.co.uk/ or find more parts on Ebay, user names
furoreltd & furoreproducts, discounts available for LCB users.
Don't forget Stainless Steel Braided brake hoses, made to your exact requirements in any of around 16 colours.
http://shop.ebay.co.uk/furoreproducts/m.html?_dmd=1&_ipg=50&_sop=12&_rdc=1
|
NOTE:This user is registered as a LocostBuilders trader and may offer commercial services to other users
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Sam_68
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| posted on 24/2/18 at 06:37 PM |
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quote:
Originally posted by russbost
Remind me, how many forums is it you've been banned from?
Erm... none? I left PistonHeads back in, ooh, about 2013, of my own volition. If conclusion-jumping was an Olympic sport, you'd be gold medal
material.
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?
I suggest you go back and read each and every post on this thread. There's nothing wrong with my English, but I think you'll find your
statistical skills need a little work. Either that, or we're back to what Russthinks was said, after he's added a few WORDS IN
CAPITAL LETTERS in his own head.
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)
I didn't keep a copy, I'm afraid, but it was pretty much exactly, word for word, what I said above: that "I think the proposed
change is an excellent idea, going forward, but that it would be beneficial to have transitional arrangements for those individuals who already have a
build in progress, and for those companies whose standard products are currently dependent on archaic engines."
There was a bit more about why I think it's a good idea (it removes the encouragement for individual builders to use old, high-emissions
engines as a 'dodge' to make MOT tests and performance tuning easier; it sets a regime that's in line with acceptable standards of
performance for other newly registered cars, without being too stringent or requiring too complex or costly a testing process, it maintains the social
acceptability of the industry in the eyes of those who see overall emissions reduction as a global priority), but nothing that changed the basic gist
of the above.
If you're not a Troll, then the only assumption I can make is that you're somewhere on the autistic spectrum (and that's not
intended as an insult, merely a statement of fact). Do you really see everything anyone says in such black-and-white terms? Can you not get you
head around the idea that:
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...
Means NEITHER
"...you clearly do NOT support any transitional arrangements"
NOR
"We shall fight them on the beaches, we shall fight them the consultation process and at the IVA test centre. We shall fight them in the
corridors of the Department of Transport, and the House of Commons. We shall NEVER surrender!"
It means that normal, ordinary people, who don't live on Planet Russ, are capable of saying, "yeah, a period of grace sounds like a good
idea - why not let's suggest it and see if they're willing to be flexible on that point?".
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sdh2903
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| posted on 24/2/18 at 07:49 PM |
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Jesus guys. Get a room for f**k sake.
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Edwardo
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| posted on 24/2/18 at 08:25 PM |
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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.
Thanks for posting this softfeet - This is a positive development!
Postponement would be great - but fingers crossed they do remove it altogether! 
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ianclark1275
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| posted on 27/2/18 at 01:07 AM |
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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
measure twice, cut once, scrap it, start again.
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Sam_68
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| posted on 27/2/18 at 07:50 AM |
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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.
It's not a difficult problem for them to fix, though, if they want to.
The Building Regulations are typically updated every 2 or 3 years, and nobody gets in a tizzy about it, for the simple reason that anything that has
passed the basic design stage continues to be built to the old regs.
It's a bit different, because with buildings (at least complicated ones) you need to get plans approved before you start to build, so
you've some evidence of a design approval date... but all it would take with IVA is that builders of ongoing projects register with their IVA
test centre now, providing some evidence of their build (the same receipts for major components that they'll need when applying for a
registration, maybe), and they could then continue to build to the old regs for as long as it takes.
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russbost
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| posted on 27/2/18 at 09:01 AM |
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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
I no longer run Furore Products or Furore Cars Ltd, but would still highly recommend them for Acewell dashes, projector headlights, dominator
headlights, indicators, mirrors etc, best prices in the UK! Take a look at http://www.furoreproducts.co.uk/ or find more parts on Ebay, user names
furoreltd & furoreproducts, discounts available for LCB users.
Don't forget Stainless Steel Braided brake hoses, made to your exact requirements in any of around 16 colours.
http://shop.ebay.co.uk/furoreproducts/m.html?_dmd=1&_ipg=50&_sop=12&_rdc=1
|
NOTE:This user is registered as a LocostBuilders trader and may offer commercial services to other users
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WesBrooks
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| posted on 27/2/18 at 02:33 PM |
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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]
http://doctrucker.wordpress.com
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WesBrooks
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| posted on 27/2/18 at 03:46 PM |
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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]
http://doctrucker.wordpress.com
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NS Dev
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| posted on 28/2/18 at 10:59 AM |
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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.
Retro RWD is the way forward...........automotive fabrication, car restoration, sheetmetal work, engine conversion
retro car restoration and tuning
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WesBrooks
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| posted on 28/2/18 at 11:12 AM |
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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.
http://doctrucker.wordpress.com
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jps
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| posted on 1/3/18 at 12:25 PM |
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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."
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