Consultation on changing emissions standards for kit cars

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agnoraan
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Re: Consultation on changing emissions standards for kit cars

Post by agnoraan »

simonjrwinter wrote: Tue Feb 06, 2018 8:17 am Surely this will decimate the kit car industry? All new builders will have to fit brand new (or almost new) engines in their cars to stand any chance of passing emissions tests. Gone will be the days of the 302 and the Rover v8! A 2018 build car will need to pass 2018 emissions tests.......
Simon
Unless there is an amnesty of a few years to complete current builds.

I saw this on another forum and it seems quite succinct and to the point. Maybe we could use soome of these points in our replies to the consultatation?

FAO Consultation Co-ordinator

I would like to voice my dismay at the inconsiderate proposed changes that are trying to be rushed through from consultation to policy.

Whilst I agree with the sentiment, the speed and the actual changes I believe will have a drastic effect to the classic kit car market. This industry tries very hard to recreate as kit that is as close as possible to the original car.

In order to meet current MOT requirements as you are proposing would mean the inclusion of fuel injection and more importantly a Catalytic Convertor. This would be extremely difficult on these older designs.

Classic Kit projects like these are undertaken by smaller numbers compared to the general kit car market, These builders who undertake these projects invest large sums of money into these projects and the kit car market and I would like you to consider the following points:-

1. A change like this must have a reasonable lead time of something like 24 months because many people build kit cars over a reasonably long period of time. Many builders will have begun their projects expecting to use an certain period engine (most likely already purchased at considerable expense) which under the new rules will not be allowable.

2. The actual impact and benefit 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 an engine which can meet modern emissions standards.

3. Once these cars have been IVA tested and registered the majority of them 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 the existing 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 has to be considered acceptable because of Items 2 and 3 above.

5. On these style of cars I feel a more lenient stage of emissions based on the above would be more considerate. That would be to legislate with fuel injection but avoid the requirement for a Catalytic convertor as this would have a drastic effect both visually and give big problems with heat dissipation on what are generally enclosed exhaust systems.

6. This change in legislation would have a serious impact on the classic kit car market which is trying to reproduce a replica as close to the original as possible. The impact of these proposals could destroy businesses and many jobs.


I trust you will consider the true impact these changes will make on the kit car economy rather than just the limited emissions which you seem to be following as a blanket strategy.

Personally this proposal will financially affect me should it go through as proposed to the tune of several thousand pounds. Considering the state of the economy, the weak value of sterling affecting materials costs and inflation, the uncertainty around Brexit and where we will sit in the European marketplace in a couple of years time, I really do not think you need to be targeting the kit car market for the minute improvement that may be achieved.

I look forward to your response to my e mail accordingly.
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Re: Consultation on changing emissions standards for kit cars

Post by simonjrwinter »

And send it to...

mailto:ivs.consult@dft.gsi.gov.uk


Simon
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Re: Consultation on changing emissions standards for kit cars

Post by amulheirn »

agnoraan wrote: Tue Feb 06, 2018 8:24 am
I saw this on another forum and it seems quite succinct and to the point. Maybe we could use soome of these points in our replies to the consultatation?
Thanks for this Nige - it sums it up quite well. I will definitely be replying, and might use this as the basis, but write my own words so it doesn't look like I'm jumping on someone else's bandwagon.

Cheers,
Andy
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Re: Consultation on changing emissions standards for kit cars

Post by nikbj68 »

Doesn't matter about the wording, it's the volume of replies that will help!
Actually, it does matter about the wording...we should be petitioning for this proposal to be dropped, not deferred.
This is worse for the future of the Replica Industry as a whole than the VHI stuff!
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Re: Consultation on changing emissions standards for kit cars

Post by nikbj68 »

Suggested response:

Re: Road Vehicles, Improving air quality and safety Consultation.
Section 4.11 & 4.12

In response to Question 10.
Implementation of this regulation would have an immeasurably small beneficial impact on air quality or pollution due to the comparatively low number of vehicles being presented for IVA test, and their subsequent use on the road, but would have a significant impact on a large number of small businesses and individual vehicle builders who would not be able to create satisfactorily accurate replicas or restore historic vehicles.
The entire "Kit Car" and Classic Car restoration industries are worth many millions of pounds to the UK economy, but could suffer massive downturns in revenue and employment as a result of this amendment, which would have no quantifiable improvement to air quality at all.
I/we petition you to cancel the proposed amendments 4.11 & 4.12 in their entirety.
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Re: Consultation on changing emissions standards for kit cars

Post by amulheirn »

Good words Nick. Just had a message from Complete Kit Car saying they’ve been on to the DfT about this. There’s a chance the kit car part could be dropped but we need to get involved and write letters responding in a similar way to how you suggest above.
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Re: Consultation on changing emissions standards for kit cars

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25 million cars averaging 11,000 miles per annum (only cars, not vans, lorries, buses, motorbikes) on the road, how many are kit, component or altered classics? 10- 20,000? Averaging 1-2000 miles per annum? These remain unaffected by the proposed amendment. And how many per year will be added to that total? A few hundred AT MOST?
Net reduction in polluting vehicles going on the road, per annum, 0.001%!
:evil:
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Re: Consultation on changing emissions standards for kit cars

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I want to use a lot of swears...
There are SO MANY bigger fish to fry first!
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Re: Consultation on changing emissions standards for kit cars

Post by nikbj68 »

...AND I'm not even building a car that would be affected!
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Re: Consultation on changing emissions standards for kit cars

Post by agnoraan »

It's important not to emphasise the small amount of mileage these cars do, as the limited mileage proposals are still "waiting in the wings". We dont want that to become law and drag us into that either.
Nige
Last edited by agnoraan on Tue Feb 06, 2018 5:21 pm, edited 1 time in total.
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