DVLA consultation on historic & modified cars
Discussion
Sharing this which came up on the TR Register forum. Appears the boffins in DVLA could be looking to make some major changes, especially if you look at the sections on "Historic and Classic Vehicles", "Kit-Cars" and "Vehicles converted to Electric" to name but a few things PHers should be aware of.
Nice of them to allow Joe Public to submit feedback, but will it make a difference?
https://www.gov.uk/government/calls-for-evidence/r...
Touch paper lit!
Nice of them to allow Joe Public to submit feedback, but will it make a difference?
https://www.gov.uk/government/calls-for-evidence/r...
Touch paper lit!
Hmm, will have to have a think about this, broadly I think the system works well, but there are some gaps.
I recall the thread from the chap who EV converted a classic Mini, and merely drilling some mounting holes was counted as "altering the monocoque", affecting the registration/identity, and he wasn't even allowed to just repair the holes or replace the panel to avoid it.
Things like that shouldn't happen.
I recall the thread from the chap who EV converted a classic Mini, and merely drilling some mounting holes was counted as "altering the monocoque", affecting the registration/identity, and he wasn't even allowed to just repair the holes or replace the panel to avoid it.
Things like that shouldn't happen.
There's a lot to go through there, will have to have a proper look when I have some time.
As said above, things like drilling a hole to run a wire should not result in a vehicle being deemed as radically altered, in the same way that welding a couple of brackets to the chassis to mount a radiator shouldn't also.
Good to see they note that there is work to do regarding the EV conversions of classics too.
As said above, things like drilling a hole to run a wire should not result in a vehicle being deemed as radically altered, in the same way that welding a couple of brackets to the chassis to mount a radiator shouldn't also.
Good to see they note that there is work to do regarding the EV conversions of classics too.
A Mini without an IC engine is radically altered, end of.
That it took a hole in a bulkhead to tip the balance is perhaps a sign that the current situation is not ideal?
I flipped through the survey, some interesting bits in there about 'replica' and 'remanufactured' etc.
A lot of different aspects being addressed?
I think there is a big can of worms here.
What's right and what's wrong with the current position?
What 'modified' vehicles should and should not be allowed?
What should be allowed to be passed off as 'historic'?
Should anyone be forced to bear the stigma of a Q plate? Why does the general public need to know your car is a fake, sorry replica?
Personally I see a dsitinction between modifying a vehicle for your own use, vs selling vehicles which are less safe than mainstream.
That it took a hole in a bulkhead to tip the balance is perhaps a sign that the current situation is not ideal?
I flipped through the survey, some interesting bits in there about 'replica' and 'remanufactured' etc.
A lot of different aspects being addressed?
I think there is a big can of worms here.
What's right and what's wrong with the current position?
What 'modified' vehicles should and should not be allowed?
What should be allowed to be passed off as 'historic'?
Should anyone be forced to bear the stigma of a Q plate? Why does the general public need to know your car is a fake, sorry replica?
Personally I see a dsitinction between modifying a vehicle for your own use, vs selling vehicles which are less safe than mainstream.
The TR Register has heard its membership and sent the following to all members from the FBHVC . I fully suspect other car groups are as well(or I sure as heck hope others are):
This is an urgent call-to-action!
You may be aware of the 9 May Government announcement of a wide-ranging consultation about the registration of historic vehicles https://www.fbhvc.co.uk/news/article/dft-and-dvla-...
In total, the consultation asks 50 questions in 12 subject headings. It covers all historic vehicles - not solely cars - of all types, and are all represented within the Federation.
Please find attached a Press Release (in Word and PDF) explaining how the Federation has set out its provisional position on each of the areas and is calling for your feedback in an online questionnaire.
We are seeking your club’s and your members’ feedback, along with that from our wider supporter membership and community.
This will help shape the Federation’s formal response to the consultation, on a topic of great importance that affects the entire movement.
The consultation offers FBHVC member clubs the opportunity to shape the creation and evolution of policies to preserve our ability to restore, register, and use historic vehicles efficiently and fairly for tomorrow’s roads.
We strongly encourage you to share this information – and importantly the link https://evidence.fbhvc.co.uk/ – with all your members and wider historic vehicle friends (such as through social media).
The more people who respond to us the better, as this will ensure that our collective voices will carry considerable weight.
It’s taken a very long time - and a huge amount of extremely hard work by our dedicated team - to get to this position, as we battled on your behalf.
Now, it’s over to you!
The MT will be formulating the club's formal response to the Federation position. It will be hugely supportive of the FBHVC but we need to go through it in detail to see if we can add anything of substance. In the meantime, please click on the link: https://evidence.fbhvc.co.uk/ and respond to the questionnaire yourselves. It is far better for the classic car community to respond via the FBHVC rather that direct to the DVLA. We have a greater voice when we act together.
A cynic could say that the government's actions to open up the call for evidence to the public is that it did not like the response it had already received from the industry bodies, so it may be an attempt to divide (and conquer) the community. We need to stick together, please support the FBHVC.
This message will be going out to all our members asap.
Many thanks
This is an urgent call-to-action!
You may be aware of the 9 May Government announcement of a wide-ranging consultation about the registration of historic vehicles https://www.fbhvc.co.uk/news/article/dft-and-dvla-...
In total, the consultation asks 50 questions in 12 subject headings. It covers all historic vehicles - not solely cars - of all types, and are all represented within the Federation.
Please find attached a Press Release (in Word and PDF) explaining how the Federation has set out its provisional position on each of the areas and is calling for your feedback in an online questionnaire.
We are seeking your club’s and your members’ feedback, along with that from our wider supporter membership and community.
This will help shape the Federation’s formal response to the consultation, on a topic of great importance that affects the entire movement.
The consultation offers FBHVC member clubs the opportunity to shape the creation and evolution of policies to preserve our ability to restore, register, and use historic vehicles efficiently and fairly for tomorrow’s roads.
We strongly encourage you to share this information – and importantly the link https://evidence.fbhvc.co.uk/ – with all your members and wider historic vehicle friends (such as through social media).
The more people who respond to us the better, as this will ensure that our collective voices will carry considerable weight.
It’s taken a very long time - and a huge amount of extremely hard work by our dedicated team - to get to this position, as we battled on your behalf.
Now, it’s over to you!
The MT will be formulating the club's formal response to the Federation position. It will be hugely supportive of the FBHVC but we need to go through it in detail to see if we can add anything of substance. In the meantime, please click on the link: https://evidence.fbhvc.co.uk/ and respond to the questionnaire yourselves. It is far better for the classic car community to respond via the FBHVC rather that direct to the DVLA. We have a greater voice when we act together.
A cynic could say that the government's actions to open up the call for evidence to the public is that it did not like the response it had already received from the industry bodies, so it may be an attempt to divide (and conquer) the community. We need to stick together, please support the FBHVC.
This message will be going out to all our members asap.
Many thanks
OutInTheShed said:
A Mini without an IC engine is radically altered, end of.
That it took a hole in a bulkhead to tip the balance is perhaps a sign that the current situation is not ideal?
It's not "end of". That's only your opinion. Why should changing from a 998 A-Series to an electric motor cause the car to lose it's identity, when changing to a 1275, fitting a 16v BMW bike head and EFI doesn't? Especially at a time when EVs are very much in favour.That it took a hole in a bulkhead to tip the balance is perhaps a sign that the current situation is not ideal?
I will agree that the current situation is not ideal, but over zealous bureaucracy is not the answer to it.
Completely changing the nature of the power plant, or vastly increasing the power is a significant change and should be properly engineered and subject to some sort of testing.
These conversions are completely separate from maintaining a historic or classic vehicle .
Lumping the two concepts in together is very risky, We could end up the kind of testing that's appropriate for a car that's doubled its power, increased its weight and completely changed its weight distribution, applied to someone upgrading the brakes on a 50HP Morris Minor.
Or we could have people selling conversions for road use which are essentially unsafe.
Or we could end up with the privileges which are currently afforded to old vehicles being withdrawn.
There's a whole other strand of discussion about vehile 'identity', ranging from the 'Trigger's Broom' bangers through to reproductions built around the chassis number plate, through to downright fakes of desirable model variants.
There may also be a few genuienly historic rare cars which may be lost to 'conversion'. Generally I don't think this is too much of a problem, there are plenty of examples of most 'classics' around, and quite likely less people actually wanting to own many of them. But in 20 years time people may look back at some of these conversions as vandalism similar to the excesses of 'customs' in the 70s.
These conversions are completely separate from maintaining a historic or classic vehicle .
Lumping the two concepts in together is very risky, We could end up the kind of testing that's appropriate for a car that's doubled its power, increased its weight and completely changed its weight distribution, applied to someone upgrading the brakes on a 50HP Morris Minor.
Or we could have people selling conversions for road use which are essentially unsafe.
Or we could end up with the privileges which are currently afforded to old vehicles being withdrawn.
There's a whole other strand of discussion about vehile 'identity', ranging from the 'Trigger's Broom' bangers through to reproductions built around the chassis number plate, through to downright fakes of desirable model variants.
There may also be a few genuienly historic rare cars which may be lost to 'conversion'. Generally I don't think this is too much of a problem, there are plenty of examples of most 'classics' around, and quite likely less people actually wanting to own many of them. But in 20 years time people may look back at some of these conversions as vandalism similar to the excesses of 'customs' in the 70s.
It's good to see this put out to the public and it will be interesting to see what is made of it. Some amount of pragmatism makes sense but also ensuring that the resulting vehicle (classic or modified) retains the relevant safety engineering is also a high priority.
Realistically even the current rules allow you to go fairly wild without needing to IVA a vehicle, the key sticking point being modifying the chassis. A drilled hole can impact the performance of structural elements and/or crumple zones so allow them in none structural areas only makes sense. With the current laws one could argue the vast majority of vehicles with a tracker need an IVA as many of these boxes are drilled and self tappered into the monocoque!
Something along the lones of retaining standard hard points for engine and subframe mountings but allowing modification of none structural areas only would make sense but guidance would be requried on what constitues none structural. EV conversions are more tricky as you've got to carry several hundred KGs of mass in a position and with a mounting system that is crash suitable - of course the argument with older vehicles / classics is that they weren't crash suitable anyway
Realistically even the current rules allow you to go fairly wild without needing to IVA a vehicle, the key sticking point being modifying the chassis. A drilled hole can impact the performance of structural elements and/or crumple zones so allow them in none structural areas only makes sense. With the current laws one could argue the vast majority of vehicles with a tracker need an IVA as many of these boxes are drilled and self tappered into the monocoque!
Something along the lones of retaining standard hard points for engine and subframe mountings but allowing modification of none structural areas only would make sense but guidance would be requried on what constitues none structural. EV conversions are more tricky as you've got to carry several hundred KGs of mass in a position and with a mounting system that is crash suitable - of course the argument with older vehicles / classics is that they weren't crash suitable anyway
poppopbangbang said:
It's good to see this put out to the public and it will be interesting to see what is made of it. Some amount of pragmatism makes sense but also ensuring that the resulting vehicle (classic or modified) retains the relevant safety engineering is also a high priority.
Realistically even the current rules allow you to go fairly wild without needing to IVA a vehicle, the key sticking point being modifying the chassis. A drilled hole can impact the performance of structural elements and/or crumple zones so allow them in none structural areas only makes sense. With the current laws one could argue the vast majority of vehicles with a tracker need an IVA as many of these boxes are drilled and self tappered into the monocoque!
Something along the lones of retaining standard hard points for engine and subframe mountings but allowing modification of none structural areas only would make sense but guidance would be requried on what constitues none structural.
I agree. One of the issues I have with the current setup is that it's a little light on specific detail, so when I write up my response, I'm going to include some suggestions of that ilk.Realistically even the current rules allow you to go fairly wild without needing to IVA a vehicle, the key sticking point being modifying the chassis. A drilled hole can impact the performance of structural elements and/or crumple zones so allow them in none structural areas only makes sense. With the current laws one could argue the vast majority of vehicles with a tracker need an IVA as many of these boxes are drilled and self tappered into the monocoque!
Something along the lones of retaining standard hard points for engine and subframe mountings but allowing modification of none structural areas only would make sense but guidance would be requried on what constitues none structural.
Unless things have changed, I don't think there's an avenue to treat it like planning permission - drawing up or otherwise laying out what you intend and how, having a discussion with the (supposed?) experts at their end, and getting a signed off agreement, that yes, this is definitely A-ok to proceed.
Being able to do that (and yes, you'd have to pay for it) would help a lot in making sure things were being done correctly.
It feels like the current procedure involves a fair amount of "if we don't like it after you've done it, sorry, that was your only chance, car's dead now", which is ridiculous, as with that Mini EV.
Don't like the holes? OK, let him weld them up or replace the panel, as he could if they were rust holes, or give him an avenue to have someone who knows their s
t sign off on it being OK and not a structural issue.InitialDave said:
I agree. One of the issues I have with the current setup is that it's a little light on specific detail, so when I write up my response, I'm going to include some suggestions of that ilk.
Unless things have changed, I don't think there's an avenue to treat it like planning permission - drawing up or otherwise laying out what you intend and how, having a discussion with the (supposed?) experts at their end, and getting a signed off agreement, that yes, this is definitely A-ok to proceed.
Being able to do that (and yes, you'd have to pay for it) would help a lot in making sure things were being done correctly.
It feels like the current procedure involves a fair amount of "if we don't like it after you've done it, sorry, that was your only chance, car's dead now", which is ridiculous, as with that Mini EV.
Don't like the holes? OK, let him weld them up or replace the panel, as he could if they were rust holes, or give him an avenue to have someone who knows their st sign off on it being OK and not a structural issue.
That Mini is a really interesting one, even as a standard car it would never pass a current IVA so if we take the emotive elements out of it then the case is really should there be a path for inspection of classics that need it i.e. support in the current IVA which grandfathers in things like external door hinges etc. Regardless clearer guidance would also have helped out the poor chap who built it in avoiding ending up in that position, if it was absolutely clear that it would need an IVA then I suspect it would have never been built. Unless things have changed, I don't think there's an avenue to treat it like planning permission - drawing up or otherwise laying out what you intend and how, having a discussion with the (supposed?) experts at their end, and getting a signed off agreement, that yes, this is definitely A-ok to proceed.
Being able to do that (and yes, you'd have to pay for it) would help a lot in making sure things were being done correctly.
It feels like the current procedure involves a fair amount of "if we don't like it after you've done it, sorry, that was your only chance, car's dead now", which is ridiculous, as with that Mini EV.
Don't like the holes? OK, let him weld them up or replace the panel, as he could if they were rust holes, or give him an avenue to have someone who knows their s
t sign off on it being OK and not a structural issue.In terms of signing off battery packs etc. it gets a bit complicated - partly in the mounting system and partly in the approval of the HV battery system (Reg 100 etc.). There is already support for electrical safety via the CEC 100.01 test but there is nothing yet around mounting system etc. Many seem to think you can just change it on the log book and off you go but this isn't (and never has been) the case. It will be interesting to see what the eventual solution/DVSA offering is as it's a complex subject and those wishing to home build something likely don't have access to the kind of FEA stuff requried to engineer in the requried strengths - perhaps some sort of minimum mounting system spec would make the most sense based on battery mass.
This does of course open up a can of worms as several EV converters have been told time and time again that the cars need an IVA and have ignored this, I suspect the chap with the Mini won't be the last person to end up in this position unfortunately.
There is already a path to recieve professional advice on legality of conversion etc. but this is catered for via other businesses and usually targetted at low volume OEMs, niche manufacturers etc. To assess something properly and do all the grunt work around it isn't a low cost excercise though so realistically isn't viable for most home builders. Adding £10K cost to your MX5 engine swap to be confident it will emit, meet regs and be safe just isn't on most peoples must haves list.
I've always look at meeting the regulations, retaining homologation and getting the vehicle to emit etc. as part of the challenge. The days of "still a 1.3 on the log book mate" are long gone! Classics are a bit different and arguably an approach of "do what you want" within a performance tolerance of the original car would be a sensible approach.
InitialDave said:
I agree. One of the issues I have with the current setup is that it's a little light on specific detail, so when I write up my response, I'm going to include some suggestions of that ilk.
Unless things have changed, I don't think there's an avenue to treat it like planning permission - drawing up or otherwise laying out what you intend and how, having a discussion with the (supposed?) experts at their end, and getting a signed off agreement, that yes, this is definitely A-ok to proceed.
Being able to do that (and yes, you'd have to pay for it) would help a lot in making sure things were being done correctly.
It feels like the current procedure involves a fair amount of "if we don't like it after you've done it, sorry, that was your only chance, car's dead now", which is ridiculous, as with that Mini EV.
Don't like the holes? OK, let him weld them up or replace the panel, as he could if they were rust holes, or give him an avenue to have someone who knows their st sign off on it being OK and not a structural issue.
But that Mini EV can get an IVA and be issued with a Q plate?Unless things have changed, I don't think there's an avenue to treat it like planning permission - drawing up or otherwise laying out what you intend and how, having a discussion with the (supposed?) experts at their end, and getting a signed off agreement, that yes, this is definitely A-ok to proceed.
Being able to do that (and yes, you'd have to pay for it) would help a lot in making sure things were being done correctly.
It feels like the current procedure involves a fair amount of "if we don't like it after you've done it, sorry, that was your only chance, car's dead now", which is ridiculous, as with that Mini EV.
Don't like the holes? OK, let him weld them up or replace the panel, as he could if they were rust holes, or give him an avenue to have someone who knows their s
t sign off on it being OK and not a structural issue.So what's all the whining about? Just the 'stigma' of a Q plate, or pretending the car is something it's not?
Maybe if Q plate cars were allowed to have pre 63 style vanity plates some people would be happy?
poppopbangbang said:
I've always look at meeting the regulations, retaining homologation and getting the vehicle to emit etc. as part of the challenge.
Oh, I'm fine with that, I just feel that digging out exactly what those regulations say can and can't be done isn't that simple.Nominally, they do, kind of, but the real nitty gritty stuff is seemingly absent, and that's where I feel it can be improved.
E.g. explicitly stating that to move a crossmember on a chassis a few inches or drill a hole for a mounting bracket is fine as long as it doesn't compromise the safety of the structure.
And then it gets into "well, who gets to say that?"
At which point, how do people who actually really do know their stuff swerve being subject to a "computer says no" opinion from officialdom?
OutInTheShed said:
But that Mini EV can get an IVA and be issued with a Q plate?
So what's all the whining about? Just the 'stigma' of a Q plate, or pretending the car is something it's not?
Maybe if Q plate cars were allowed to have pre 63 style vanity plates some people would be happy?
Yes, the stigma of a Q plate and losing the identity of the vehicle, it may not matter to you, but it does to some. You may think that it serves them right for messing around with a classic, which is fine, but stuff like that in the context of this survey could have unintended consequences for things you do like.So what's all the whining about? Just the 'stigma' of a Q plate, or pretending the car is something it's not?
Maybe if Q plate cars were allowed to have pre 63 style vanity plates some people would be happy?
I'll be blunt, I can see you don't like EV conversions, but this is not the time to grind that particular axe and mess up the freedoms car enthusiasts currently enjoy across the board, as this country is better than many in that regard.
InitialDave said:
Yes, the stigma of a Q plate and losing the identity of the vehicle, it may not matter to you, but it does to some. You may think that it serves them right for messing around with a classic, which is fine, but stuff like that in the context of this survey could have unintended consequences for things you do like.
I'll be blunt, I can see you don't like EV conversions, but this is not the time to grind that particular axe and mess up the freedoms car enthusiasts currently enjoy across the board, as this country is better than many in that regard.
I have no problem with EV conversions, just with people pretending it's still 'the same car' and getting precious about reg numbers and all that.I'll be blunt, I can see you don't like EV conversions, but this is not the time to grind that particular axe and mess up the freedoms car enthusiasts currently enjoy across the board, as this country is better than many in that regard.
There's really no issue with messing with 'classic minis' because they made far too many of them in the first place.
In this particular case, a lot of people are getting upset on behalf of the owners of a car who don't actually seem to give a toss about using it on the road anyway.
There's also a limit to what we should be sharing the roads with.
If some cowboy enginieering firm can shoehorn an EV drivetrain into some old car designed for a fraction of the power, with no testing, no meaningful development and then sell it to some hipster who's only ever known run of the mills Nissan school run cars.
It seems entirely right to me that significantly altered cars should have some sort of credible check before going on the road, more so if the are being sold to 'civilians'. Exactly what that check should be is another question, maybe stick some part worn tyres on it and let my idiot brother in law rag it around the south circular in the rain?
I think it will be yoghurt-weaving EV conversion firms buggering it up for everyone else, not the other way around.
OutInTheShed said:
But that Mini EV can get an IVA and be issued with a Q plate?
It can't, or rather can't in its current form. IVA has specific requirements around vehicle structure for pedistrian safety etc. Things like the external door hinges on an original Mini fail IVA regulations (and fail hard!). So in order to pass an IVA you'd need to significantly change the vehicle to comply. This is really what the argument is about, if the vehicle was like that when it left the factory should that feature be grandfathered in from a regs perspective even if it has to comply with the remaining regulations. This way you could IVA it with all the modifications you wanted but the physical structure could remain as per originally produced.poppopbangbang said:
It can't, or rather can't in its current form. IVA has specific requirements around vehicle structure for pedistrian safety etc. Things like the external door hinges on an original Mini fail IVA regulations (and fail hard!). So in order to pass an IVA you'd need to significantly change the vehicle to comply. This is really what the argument is about, if the vehicle was like that when it left the factory should that feature be grandfathered in from a regs perspective even if it has to comply with the remaining regulations. This way you could IVA it with all the modifications you wanted but the physical structure could remain as per originally produced.
So you might have to change the hinges or fair them in.These rules are there to reduce injuries to pedestrians etc.
If people start kicking back against a sensible level of safety in what is effectively a car rebuilt from the ground up with marginal 'old' content, then people might decide they don't want dangerous old cars in our cities at all.
You start to open a can of worms about cars which might be in intense daily use, as opposed to old cars which average a couple of thousand miles a year in favourable conditions.
OutInTheShed said:
So you might have to change the hinges or fair them in.
These rules are there to reduce injuries to pedestrians etc.
Well the thing is, they aren't... at least not for all the classics operating completely legally on the road today. They are still road legal because their homologation/registration is grand fathered in i.e. if once road legal then always road legal. IVA has no support for this due to the Part 16 regulations around minimum radiuses etc. The question being posed is really simple and at a high level isn't even about EVs conversions etc. it's a question of do you allow exemption for originally road legal elements on classic and historic vehicles. These rules are there to reduce injuries to pedestrians etc.
The remainder regarding rebuilt and radically modified can be dealt with pretty easily by either allowing modification to none structural elements of the monocoque as dictated by a set of guidelines or retaining the rules as they are. The latter isn't terrible as you can still do a massive amount of stuff within those rules and the path to requiring an IVA is already pretty sensible, from my perspective requiring IVA on anything signficantly modified is very sensible and if the IVA regulations were written in a way which supported existing vehicles (historic and classics included) I think people would be much keener to IVA once built as as sign off, which in turn ensures these vehicles are as safe as they ever were in modern traffic.
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