VERY IMPORTANT PLEASE READ Consultation responses.

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agnoraan
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VERY IMPORTANT PLEASE READ Consultation responses.

Post by agnoraan »

As mentioned in my previous post re the latest legislation for the requirements of Kit cars, kit built and modified cars to meet current emissions standards, please find the information from the aforementioned action group below. Please remember, the letters are templates. You are all free to edit them to suit your needs before sending. The templates were created to help people who are not confident at writing their own letters, but by the same token giving everyone the correct, valid information to help get this consultation removed. ie so that we're all on the same page with valid, coherent information.

I know that there's a lot to read through, but this, if passed will affect us all and is likely to be the end of the kit car industry as we know it. It's vitaly important that you send off letters, emails etc and fill in the consultation stating that you do not accept what is being proposed. I've also listed here a lot of the stuff that you'll find on the Action Groups Facebook page, as I know that not everyone uses Facebook.

Also there are some things to be mindful of when replying. It would not be wise to say for example, that the kit cars only do a very limited mileage per annum, so should be exempt from this due to that fact. The limited mileage proposals for VHI's have not gone away. By saying we don't cover much mileage could be detrimental, as the Government would see our cars as being inconsequential in the larger scheme of things. ie not important and not worth trying to appease the kit car industry.

If this legislation is not passed as law, it could play into the governments hands to limit the mileage per annum on kit cars, based on the limited mileage quoted by ourselves. By the same token, saying that it would affect "X" amount of people, does not really hold water either. This legislation is about controling the amount of emissions produced per annum. The loss of our hobbies and the loss of a very small percentage of people employed in this industry would be of no concern to the Government, in comparison to trying to get the emissions down to a controlable level, hence the onward march, backed by world Governments, for electric cars. We are but a small thorn in their sides.

The action group are already contacting the DFT, Government departments, local Governments, motoring media and magazines. The more responses to this, the more likely it would be to get the legislation thrown out before it goes to Parliament.


From the action group:-
/www.facebook.com/groups/148944219148084 ... &ref=notif

You must complete the Government Survey

http://www.smartsurvey.co.uk/s/road-emissions/



Consultation Document:
https://l.facebook.com/l.php?u=https%3A ... rdoU5hoJWt

Survey to complete
http://www.smartsurvey.co.uk/s/road-emissions/


Look in the files and see the Bulletpoint list for pointers:
https://www.facebook.com/groups/1489442 ... 045729668/

BULLET POINTS these are factual and non emotional

Bullet points to pick, select from and tailor to target i.e. MP or 'Consultation' replies.
• NOT a consultation but a Notice of Intent
• No time for due process
• No actual time to consult only to take initial opinions
• List of Consultees doesn’t contain any to do with kit car / kit altered / radically altered.
• Should be separate consultation for BIVA
• SVA took 4 years to formulate.
• 2 years to transfer SVA to IVA.
• Despite some time limited exemptions being granted no mention in official rules that the rules can be changed without notice or
even that they were considered time limited
• Many build decisions taken that THESE were the rules and wouldn’t change overnight.
• Kit cars. kit altered, radically altered being made to pay for OEM cheating.
• Lack of understanding by Consultation authors on what type of vehicle uses BIVA and of DVLA rules for retaining original identity
(See recent Cobra court case).
• BIVA is a UK only spec and does not HAVE to be recognised abroad.
• This is being driven by our Government NOT EU
• Will kill a multi-million pound industry stone dead. No time to bring these figures to the table.
• Shared suppliers / manufacturers with VHI that will affect ability to be competitive with less market share.
• Vehicle builds currently underway cannot be altered within the proposed time frame.
• Doesn’t simply require an engine change but a redesign to create a safe package.
• OEM cannot meet TODAY’s spec without cheating so how can we?
• We cannot simply band aid something to make it work as much is in internal engine design.
• Vehicles from 1995 onwards not chosen for donors as most are FWD and unsuitable for kit use.
• Most 1995 onwards contain PAT systems (Passive Anti-Theft) that prevent engine being started without ALL systems from cars i.e. Airbags, ABS, blown bulb warning etc.
• Existing aftermarket ECUs not sophisticated enough run to levels required.
• FWD engines require costly adaptations to be used longitudinally
• Purchase of new engine IF it can be made suitable would cost about £3000 for 4 cylinder and £7000 for v8 WITHOUT any peripherals.
• With Kit altered the market focuses on single donor builds where FWD does not meet criteria.
• Radically Altered vehicles are based on modifying EXISTING vehicles so the engine is already in use and is NOT an addition to polluting vehicles.
• It is considered that VHI usage of old visual smoke only vehicles is acceptable and they don’t even require an MOT let alone an Amateur Built Compliance test
• Someone inadvertently caught with a non 8 point compliant vehicle due to limitations advising of existing V5C document and DVLA’s lack of dissemination of rules may as well crush the vehicle than try to comply.
• This is ultimate recycling keeping parts in use rather than causing major pollution with new car production.
• Huge cost difference in kit cars and kit altered cars where a required engine swap may cost more than kit.
• Despite advertising and TV shows a kit car / kit altered / radically altered is NOT achieved over a period of a month.
• Many projects take 5-10 years to build due to additional outlays and time restraints.
• Some kits will not be able to use alternative engines as the very nature of the style is based on a long ago used technology.
• Reconstructed Classics do NOT use BIVA, unless they become Radically Altered Vehicles and they then won’t pass without rebuild.




In addition there are THREE template letters for you to choose from. You are free to edit any letter as you choose and send to your Local MP and/or members of the DfT.

The letters are in the Files section:
https://www.facebook.com/groups/148944219148084/files/

Letter template A

Dear Sir,

I write in response to the DFT proposal "Road vehicles - Improving air quality and safety". Whilst broadly agreeing with the proposals contained within the document, as a kit/modified car owner and builder I am concerned that the application of these new rules will have a negative impact on other kit/modified builders and the kit car industry as a whole.

The consultation document raises two key questions specifically aimed at kit cars:

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

Question 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 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. Electronic control units (ECU’s) are now available for some engines, but are not compatible with all. This has been a huge step forward but as amateur builders we still lag some way behind when benchmarked against 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 choice of modern engine available to the 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 transmissions cannot be easily adapted to kit cars, most of which are rear wheel drive, meaning many builders are forced to look at older designs that are able to be adapted the vehicles they choose to build.

Many kit car/radically altered vehicle builders want cars with a period feel to them. Being forced to use a more modern engine is not really an option for them and using an older engine is in keeping with the whole ethos of the vehicle being built (would you for instance want a replica E Type Jaguar with a Honda engine?)

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 impossible to use (due to the complexities of the modern ECU’s with their anti tamper software) current engines. The number of kit cars on the road is a very small percentage of overall vehicle numbers and is also very likely less than the number of Classic vehicles that are designated MOT exempt and therefore have no emissions requirement. If a blanket exemption can be applied to Classic vehicles, then I question why a more sensible and realistic approach cannot be taken for kit cars/radically altered vehicles?

The current IVA and MOT regulations weren’t popular amongst kit car/radically altered vehicle builders when they 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 vehicle builders and the kit car/modified car industry as a whole.

The UK kit/modified car industry is probably unique in the breadth of products that it offers and is widely regarded in Europe and further afield. The annual MoT 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 that it’s given every possible opportunity to continue to do so.

Some other facts to consider that are taken from the 2016 survey of the Federation of British Historic Vehicle Clubs. Whilst these figures are not 100% directly affected by the new proposals, the new proposals – if implemented, would have a significant impact upon them with resultant job losses and reduction of GDP.

• £662 million income from overseas enthusiasts
• 34,900 jobs in the historic (only - even more if adding in customising/hot rodding/kit car etc.) car industry.
• 6 out of 10 businesses that are worried the new regulations will cause problems for them in future trading.
• £2.05 Billion spent annually on associated items
• £262 million spent annually by traders
• £5.5 Billion spent annually in total by historic owners




Yours faithfully,


*NOTE
If addressing the letter to a person “Dear Mr Brown”, end the letter “Yours sincerely”.

Letter template B

Re: Road vehicles - Improving air quality and safety

I write in respect of the above so-called “consultation” in which respondents have been given just twenty-eight days to read and digest the document and formulate an informed response.

From reading the document it appears to be more a statement of intent than a consultation. It’s patently a decisive intention to make it impossible for builders of some categories of individual vehicle to be able to comply with the ever-changing rules.

The requirement for such vehicles to comply with the emission levels at the time of registration is severely restraining. In most cases catalytic converters and OEM ECU’s would need to be installed to achieve such standards. But from previous rulings these builders are not allowed to use airbags or ABS systems on safety grounds. However if you attempt to use an OEM ECU and unplug various safety systems such as airbags and ABS, there is every likelihood that the ECU would disable the vehicle, probably ending up with the vehicle running – if it would actually start – in limp-mode at best.

Hence the use of such systems on an engine that was never designed to use, or even had such systems installed in the first place, makes no sense at all.

Most kit and radically altered amateur built vehicles utilise mainly old, reconditioned parts. They choose rear wheel drive as a preferred option, as this is in keeping with the tradition of the older vehicle, however even these donor parts are becoming increasingly rare. This layout provides easy build options and simplicity, with each main component being a distinct separate entity, i.e. engine, gearbox, prop-shaft, rear axle, front axle and steering. Only basic electrics are usually employed to fulfil the minimum needs of the vehicle, with the only nod to electronics – if there is one – being the use of electronic ignition. The addition of this has the added benefit of improving the efficiency of the system without adding anything too complex. Complexity is what most builders are trying to get away from, they seek a simple to work on and simple to use vehicle that they are happy to drive anywhere, knowing they have the ability to repair it at the roadside themselves, with basic tools if necessary. Not having to rely on needing a PC to plug into it to tell them what might be wrong with it!

To legislate that older engines need to achieve the emission values operating on the date of first registration to such exacting standards is – frankly – amazing. It’s like putting a CD on your old Hi-Fi turntable and expecting it to play it!

The suggestion that there are more suitable modern engines with ECU’s available for builders to use is wholly unrealistic. Most modern vehicles are front wheel drive units with integral gearboxes, differentials and drive shafts, also by disabling the airbag and ABS circuits of the ECU’s of such vehicles to comply with existing rulings, the units would be rendered virtually useless, as pointed out earlier.

To put realistic, achievable requirements in place relative to the age of the engine, the fuel delivery system and ignition system employed in any vehicle build would be much fairer, and at least give the builder the chance to comply.

It appears that the individual is being directly punished – and punished very harshly – for the misdemeanours of OEM constructors who have knowingly cheated the system. If even they find it impossible to comply, how on earth do you expect an individual to be able to do it?

The individual builder has no intention or desire to cheat in any way; they simply wish to build and use their own self-built, completely individual vehicle, surely not too much to ask?

Under the guise of a consultation we get a document that sets out to tell us what we can and can’t do and which determines a set of rules that are actually impossible to comply with. On top of that the timescale in which this ill-conceived idea, that obviously has little or no understanding of the technology and technicalities involved to achieve the strict requirements is being implemented, with no interested parties from relevant companies and organisations being consulted directly, makes it obvious that it’s virtually a foregone conclusion and the intention is simply to wipe all such vehicles off the road in one very foul swoop.

Not only will this action wipe the vehicles and the considerable revenue they raise out, it will destroy at a stroke a large number of companies supplying parts and services to such vehicle builders, resulting in the loss of revenue on an even larger scale and doubtless creating loss of income and probably unemployment for a considerable number of those that will be directly affected.

As my MP I ask that you make representation on my behalf about this dreadful disregard for my freedom to be able to build a car if I so wish. By implementing the contents of this document many thousands of individuals across the length and breadth of the UK, not just the hundreds in your constituency, will be profoundly affected and disgusted by the outcome.

Letter template C

Senders name and address here
Date

Dear (name of MP/transport secretary)
I am writing to you to request your help in stopping a proposal within the ‘Proposed changes to emission standards for new vehicles using national schemes’ https://www.gov.uk/government/consultat ... and-safety

Within this document they wish to make all vehicles undergoing IVA (Individual Vehicle Approval) to be compliant with the year of registration (2018 onwards) rather that the current status quo of complying with the date of engine manufacture.
I am horrified that the “consultation” is only 4 weeks and has none of the affected businesses/people as consultees, is this how modern democracy works now?
The current system is fair and workable; the proposed changes are only brought about by the “Deiselgate” fiasco – as actually outlined in the proposal. If implemented then 98% of current and future ‘home built’ cars would end up as total scrap as it is far beyond the home builder to meet the current day emissions levels. There is no level of ‘avoidance’ by the home builder, they are just trying to build their ‘dream’ car whether it is a replica E type Jaguar or a ‘radically altered vehicle’ such as a 1930’s car fitted with more modern underpinnings such as ‘Hot Rods’ as they are termed today. All of the current builds in peoples garages will be rendered unregistrable if this proposal goes through without the IVA exemption being kept.
There are many reasons why modern engines are not suitable for these projects, whether it is because of the simple aesthetics (who wants a front wheel drive Honda engine in an E type Jaguar replica???) to the more complicated engineering issues of front wheel drive engines not being compatible with rear wheel drive projects.
Lastly, modern engines come with modern ECU’s to control them – which are designed by the manufacturers to not be removed and put in other applications – resulting in non-running or poor running of the engine, so meeting modern emissions levels with modern engines is not a viable proposition even if it were a preferred option to the home builder.
I have attached a document showing the relevant parts of the proposal with our arguments highlighted in red for your perusal and I hope you will campaign on our behalf to have the sections 4.6, 4.7, 4.10, 4.11 and 4.13 dropped.

I look forward to your response.

Yours Sincerely,


The list for all MP's and DfT members are in the posts below. Don't forget all the shadow members, they will be more receptive as they can oppose the govt rulings which is their job

People in DfT for letters
Head of DfT - Chris Grayling
chris.grayling.mp@parliament.uk

Other members of DfT
https://www.gov.uk/government/organisat ... -transport

Postal Address for DfT:
Department for Transport, Great Minster House, 33 Horseferry Road , London, SW1P 4DR

List of MP's for letters
http://www.parliament.uk/mps-lords-and-offices/mps/


Please try to spread this to as many people that you can, we only have a few weeks to respond before it goes before the Government to be passed as law.
Cheers..NIge
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