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 »

Andy, the reason a lot of the consultation focuses on diesels is because this was brought about initially by the VW scandal, but the alternative car market has been dragged into it.

The most important thing when replying is not to let emotions get in the way, or to form the basis of the response. The government aren't concerned about things such as what happened at manufacturing stage, or how it affects an extremely small minority of kit car owners or manufacturers . They aren't saying you can't have a kit car, theyre saying that they should use energy efficient engines, that can pass current emission standards. It is of no concern to them that the engine in a replica isn't the same as an original. They see the bigger picture of eliminating cars from our roads, that pollute the atmosphere.

The important issue to US here is that many people take years to build a car, so engines that would have already been bought at the earlier stages of the project are no longer viable. Older engines cannot be made to comply with current emmissions standards

. More importantly is that this latest consultation is only being run for a month, ie trying to slip it in through the back door, before it can be opposed. TIME IS OF THE ESSENCE!

Initially we need to get the consultation to be run as per normal through government channels, which normally takes a couple of years. Priority is to get a stay of execution and get the consultation deferred for as long as possible. Then there's more time to get everyone on board to stop it being passed as law.

The template responses, that are relevant, succinct and to the point being prepared by the aforementioned action group will be ready soon for all to use to fight this. The group already have people contacting the DFT, VOSA, Government bodies, magazines, motoring media, manufacturers etc etc, but we need to kick up a sh**storm to bring this to the attention to as many people that can make a change as possible
Nige
Last edited by agnoraan on Thu Feb 08, 2018 10:13 am, edited 1 time in total.
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Re: Consultation on changing emissions standards for kit cars

Post by nikbj68 »

Good points all.
The cars this proposal would prevent are but a handful of sand on the vast desert of pollution.
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Re: Consultation on changing emissions standards for kit cars

Post by agnoraan »

I found this on another forum,(RHOCAR Forum) some of which might be of use for those who want to reply to the consultation now.


I write in response to the DFT proposal to improve Air Quality and Safety. Whilst broadly agreeing with the proposals contained within the document, as a kit car owner and builder I am concerned that the application of these new rules will have a negative impact on other kit builders and the kit car industry as a whole.

The consultation document raises 2 key question specifically aimed at kit cars:

8 Do you agree with the introduction of WLTP in IVA, for light vehicles built after 1 July 2018?

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?

For anyone with a knowledge of the current regulations and a genuine interest in the UK kit car industry, the answer to both these questions has to be an emphatic NO.

WLTP testing as part of IVA would be impossible. It would be too complicated and time consuming to be performed as part of what is already a lengthy and expensive process and it would be unreasonable to expect an amateur individual to subject a vehicle to the same test as a major manufacturer. Successful completion of the test would depend not only on the type of engines and emission controls but also other aerodynamic devices fitted to the vehicle. Even if it was possible to fit a WLTP friendly engine to a kit car, it would be impossible to get satisfactory results given that the visual style of kit cars generally gives no consideration to improving their aerodynamic (and emissions) performance. For many kit car owners and builders, having a vehicle that is visually different from most other cars on the road is a major cornerstone of their interest.

Requiring kit cars to meet the latest MOT standards would also present a number of problems. In recent years, the kit, restored and modified car industry has seen the increased use of technology in the area of fuel and emissions control. Sophisticated electronic control units (ECU’s) are now available that allow a level of control that even major manufacturers would not have had 20 years ago. This has been a huge step forwards but as amateur builders we still lag some way behind when benchmarked again current regulations. This is partly because an older design of engine, even when fitted with a sophisticated ECU, will still struggle to meet the existing regulations. As the test standards continue to rise, the design of engines must follow and it simply isn’t possible for kit builders to use a brand-new latest design engine.

The current MOT standard for kits which bases emissions standards on engine age works well. Whilst I agree that there is a wider chose of modern engine available to builder, not all of these may be suitable. This may be because they don’t physically fit, or they don’t have suitable transmissions available. The vast majority of modern cars are front wheel drive and their transmission cannot be adapted to kit cars, most of which are rear wheel drive, meaning many builders are forced to look at older, rarer and consequently more expensive alternatives.

Many kit car builders want cars with a period feel to them. Being forced to use a more modern engine isn’t really an option for them and using an older engine, possibly coupled with a modern ECU allows them to retain a period feel but still give some consideration to emissions which in most cases, will be far better that what the original manufacturer ever thought possible. Retaining the existing MOT standards is the best way to ensure that kit cars maintain sensible emissions without forcing them in to using complicated, expensive and potentially unsuitable current engines. The number of kit cars on the road is a very small percentage of overall vehicle and is also very likely less than the number of classic vehicles that are designated MOT exempt and therefore have not emissions requirement. If a blanket exemption can be applied to classic vehicles, then why can’t a more sensible approach be taken for kit cars.

The current IVA and MOT regulations weren’t popular amongst kit car builders when there were introduced but they are now widely understood and accepted. Further changes to regulations that seem to offer very little real benefit would only have a negative impact on kit builders and the kit car industry as a whole.

The UK kit car industry is probably unique in the breadth of products that it offers and is widely regarded in Europe and further afield. It has managed to survive despite new legislation which has at times, done everything it can to make things difficult and I think it is vital it’s given every possible opportunity to continue to do so."


Nige
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Re: Consultation on changing emissions standards for kit cars

Post by Migge »

Nige,

You have PM
Special customized BRA289
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Re: Consultation on changing emissions standards for kit cars

Post by peterc »

I am sure that most replica and kit cars built over the last 20 years will not have an ECU and in some cases not even the space to locate it. Also the point made about old design engines just not being able to meet the new emissions levels even if fitted with an ECU is extremely valid. Also locating a catalytic convertor in a fibreglass car would not be practical.

Going back to the original comments they would need a three year feed in period to placate those mid build and absolutely no retrospective changes due to the need to re design the engine internals if indeed it were possible on an old style unit.
Engine design has changed significantly over the last 20 years to meet the continual tightening regulations and major manufacturers have spent billions to achieve it. Pre 2000 engines just wouldn’t cope without major redesign / replacement.

As Nige has noted we need to be factual and non emotional. The law makers don’t understand the industry and don’t really care. They want to be seen to be improving air quality regardless of the cost to others.

It would be good to read the additional comments from Nige when it is available but we all need to create our own version and issue it before the end of the month.
Peter C
Last edited by peterc on Fri Feb 09, 2018 7:21 am, edited 1 time in total.
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Re: Consultation on changing emissions standards for kit cars

Post by nikbj68 »

peterc wrote: Thu Feb 08, 2018 2:56 pm...The law makers... want to be seen to be improving air quality regardless of the cost to others...
Peter C
That’s the main point. Challenge them to quantify the improvement that stopping a couple of hundred cars a year* would have on air quality. My guess...0.0000000001% of all pollution!
We’re guilty until proven innocent here... it’s contrary to the basis of the British system of law!!!!
DROP ITEMS 4.6, 4.11 & 4.12 NOW!

*Many of the 5,000 or so vehicles presented for IVA will have compliant emissions systems, only a comparatively small percentage will be similar to ‘our’ types of vehicles.
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Re: Consultation on changing emissions standards for kit cars

Post by agnoraan »

This has some very good points and explains exactly what the Government want in response to the consultation. Please share this with EVERYONE!!

From Complete Kit Car magazine:-

https://completekitcar.co.uk/2018/02/07 ... nges-mean/

What the proposed MoT changes mean

The Department for Transport (DfT) has recently released a new propasal document called ‘Road Vehicles – Improving air quality and safety’. While this is primarily aimed at stopping a repeat of the dieselgate problems from large scale manufacturers, there is a section relating to MoT standards for newly registered kit cars.

These can be found at section 4.10 to 4.13, reproduced here:

4.10 Kit cars and reconstructed classic cars undergoing IVA will not be required to meet WLTP, given that at present they are not required to meet NEDC or the latest EU standards. Instead they are tested to age-appropriate MOT standards, on the basis of the date of manufacture or first use of the engine.

4.11 We are proposing that for kit cars, compliance with the MOT emissions standards current at the date of registration will be required, despite the use of an older engine. In other words the current relaxation for emissions according to the age of the engine will no longer apply.

4.12 Reconstructed (restored) classic cars undergoing IVA will not be required to meet the latest MOT standards, as long as the appearance of the vehicle is broadly unchanged and the engine is of the same capacity as that supplied with the vehicle when it was new.

4.13 When new vehicles were first required to be fitted with catalytic converters around 1992 (Euro 1 emissions standard), kit car makers typically used older engines which were not fitted with catalytic converters, hence the justification for age-appropriate testing of emissions based on date of engine manufacture or first use. The majority of the fleet is now vehicles up to 25 years old whose engines are fitted with catalytic converters, providing plenty of choice to the kit car builder.

A link to the full document can be found HERE.

While the wording is potentially ambiguous, Peter Bailey of the Chesil Motor Company has now had clarification from Mike Lowe, Acting Head of Branch, Regulation, International Vehicle Standards. Mike Lowe says: “The change proposed is to treat kit cars as having a new engine and thus subjected to the MOT standards applicable to new vehicles (once they reach 3 years old). This is a test with a vehicle idling (for petrol).”

Our understanding is that this would mean all newly registered kit cars would have to meet the requirements for production cars registered from 1992 onwards, this being a Basic Emissions Test (BET) requiring a catalytic converter.

The period for consultation is short, ending on Friday 2 March.

Feedback from manufacturers tells us that for some kit cars this is not a problem as they already meet the requirements, while for others it is. We are also aware that this may be an issue to a number of builders who are mid-way through a build and committed to an engine choice.

Clearly it is important that manufacturers, traders and private owners who would be affected by these proposals, should respond as soon as possible, outlining their concerns.

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.”

Peter has put together the following guidelines for how you might like to structure any written response. Please feel free to use these guidelines, or do your own thing. Over to Peter…

As you are now hopefully aware, there is new legislation in the pipeline that could greatly affect our industry. I for one would not be here at Chesil if these proposals were introduced, as we fit air-cooled engines (that have no real alternative) and would be very difficult to get to pass the proposed emissions… but on top of that, it is not what our customers want.



It does seem, having spoken to the DfT just now, that if there is sufficient pressure and clear, genuine reasons why this part of the legislation could be ‘catastrophic’ to our industry, there is a fair chance it could be removed from the proposals, but it is up to all of us to respond!



I am suggesting that all manufacturers write, giving their own individual case, and also that we all collectively send a response from the industry as a whole.



Below are some suggestions as to the content of your response:

1. Does your vehicle, particularly if it is a replica, need to have an earlier style engine to retain the character of your car? If so, explain why this is so important, and how difficult it would be to implement emission controls.

2. Would fitting a more modern engine detract from the original character of the car, and therefore its saleability? Would customers be put off buying it? Explain why.

3. If an alternative could be fitted, would it increase the build cost, which too could be detrimental to sales? Give a realistic indication of cost increase, perhaps as a percentage.

4. Would there be existing customers who could get ‘caught out’ by this legislation as their build completion would be beyond the implementation date? Give an example and perhaps how many customers you have in this situation.

5. If this legislation were implemented, could it possibly affect your business sufficiently that you might have to ‘close your doors’? If so, give good sound reasons why.

Responses should be sent to…

ivs.consult@dft.gsi.gov.uk or

Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
London SW1P 4DR

Below is Peter’s proposal for a group response from manufacturers/traders. If you are happy to have your name and company added to this list, we are happy to collate them here and send it on your behalf. To be included, please email adam@performancepublishing.co.uk BEFORE Wednesday 28 February.

A Collective Response – from kit car manufacturers and traders

As small scale manufacturers of specialist and kit cars, we would like to collectively respond to the proposed legislation, in particular regarding to the changes to the emissions requirement.

We are not a big industry, but we 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 our industry to produce vehicles to a recognised safe standard – a fact borne out by the low insurance premiums that our vehicle owners enjoy.

We would very much like our industry to continue, but these current proposals could be catastrophic to some, and many we are sure would have to close. 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 of us have small workshops and not a vast workforce, but we all have many times that number indirectly employed who have specialist skills and rely on our continued, and regular, work.

As you will notice, on a day-to-day basis there are very few classic cars on the roads, 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.

We all hope that you now have a better picture of our industry and its precarious position if this legislation became enacted.

We strongly request that this part of the proposed new legislation be dropped.

The following companies and individuals have agreed to their names being added to this letter…

Clubs and individual owners

Complete Kit Car has had contact from a number of clubs expressing concern at the proposals. Hopefully the information we have provided above will clarify the situation. We understand some clubs will be more impacted by the proposals than others, and may wish to make their own representation to the contact details listed above.

ADAMRWILKINS
FEBRUARY 7, 2018

Hope this helps
Cheers....NIge
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Re: Consultation on changing emissions standards for kit cars

Post by kenv »

Morning all,
Just read a post on Facebook on this and checked this site. Thanks to all for comments. I've spent a lot of money restoring a 6 cylinder period engine for my Ace and not halfway through the build, so a little vexed by this Government proposal!
Just off to read all the above to formulate an email to them, for what good it will do!!!!****
Regards
Ken
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Re: Consultation on changing emissions standards for kit cars

Post by peterc »

I have had to read many contract specs in my time but crikey this is heavy reading. I was losing will to live before the end and will need to re read to ensure we haven’t missed something.
As John says we certainly need to answer questions 8 & 10 on Page 31 with an emphatic NO.
All comments gratefully received. I suggest cutting and pasting all the good bits into a document of your own and then adding your own touches rather than carte Blanche copying.
One problem is that as individuals we are not in a position to put costs forward in £M of how it will affect the industry.

Nige - when do you think you will get the extra comments that we made need to include.
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Re: Consultation on changing emissions standards for kit cars

Post by amulheirn »

I wrote a freedom of information request to the DfT today to ask the questions I mentioned a few posts back. I think if we can get number for 'amateur-built' cars per annum versus mass-produced cars per annum it might highlight how small an effect it will have. The document is mainly driven by the diesel issues as far as I can see.
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