New emissions for kit cars consultation
Discussion
Equus said:
That's debatable, but the justification is quite clear: as it says in the consultation document, the current system has the effect of encouraging kit car manufacturers and builders to use older engines as a 'dodge' to make compliance with IVA easier. This change removes that encouragement.
I can't think of any kit manufacturers using it as a dodge - The classic replica brigade deserve old engines. Out of the LSIS brigade, most offer brand new engines etc and no one offers Pinto etc. as a default!Having re-checked the proposals for May, it appears that modifications to emissions equipment only apply to Diesel engines, so folks like me who have removed EGR etc. will be OK for now.
I have a much better plan for HMG than this proposal. Last week one of my flights was cancelled. I would have emitted many TONNES of CO2 etc. on that flight, but these were saved. I propose to offset these saved emissions against the emissions from every kit car built from today. That should keep the industry, which emits GRAMMES of CO2 etc, going for around 30-40 years!
Mistrale said:
Having re-checked the proposals for May, it appears that modifications to emissions equipment only apply to Diesel engines, so folks like me who have removed EGR etc. will be OK for now.
I honestly don't think you need have worried, anyway: the key word is modifications to emissions equipment. It has to be fitted as part of an original, type-approved specification in the first place, before you can breach any rules by removing it.Kit cars and individually-build vehicles have no 'standard' specification to deviate from. The only thing they will have to comply with is the emissions limits.
The reason for failure is "Emission control equipment fitted by the manufacturer missing, obviously modified or obviously defective". With a kit car, you are the manufacturer. It says nothing about 'the donor engine manufacturer'.
Think about it: if your interpretation was correct, someone fitting a cat, mapped ignition and fuel injection to a Crossflow or Beetle engine to make it pass the emissions test would then automatically fall foul of the 'modifications' rule because they'd removed the caburettor and distributor. It would be a Catch-22 situation.
Equus said:
I honestly don't think you need have worried, anyway: the key word is modifications to emissions equipment. It has to be fitted as part of an original, type-approved specification in the first place, before you can breach any rules by removing it.
Kit cars and individually-build vehicles have no 'standard' specification to deviate from. The only thing they will have to comply with is the emissions limits.
The reason for failure is "Emission control equipment fitted by the manufacturer missing, obviously modified or obviously defective". With a kit car, you are the manufacturer. It says nothing about 'the donor engine manufacturer'.
Think about it: if your interpretation was correct, someone fitting a cat, mapped ignition and fuel injection to a Crossflow or Beetle engine to make it pass the emissions test would then automatically fall foul of the 'modifications' rule because they'd removed the caburettor and distributor. It would be a Catch-22 situation.
I'm not an expert and I doubt anyone else is either. Kit cars and individually-build vehicles have no 'standard' specification to deviate from. The only thing they will have to comply with is the emissions limits.
The reason for failure is "Emission control equipment fitted by the manufacturer missing, obviously modified or obviously defective". With a kit car, you are the manufacturer. It says nothing about 'the donor engine manufacturer'.
Think about it: if your interpretation was correct, someone fitting a cat, mapped ignition and fuel injection to a Crossflow or Beetle engine to make it pass the emissions test would then automatically fall foul of the 'modifications' rule because they'd removed the caburettor and distributor. It would be a Catch-22 situation.
Edited by Kccv23highliftcam on Saturday 24th February 09:30
[quote=mikeveal]Who's responded then? And how did you respond?
1. mikeveal - completed online consultation.[/quote
I responded by letter, but I have some encouraging news for everyone (well nearly everyone, not Equus perhaps), it would appear that a LOT of people have raised objections, this comes from one of the Cobra forums
"I emailed the Department of Transport to try and get some indication of when the proposed legislation with regard to kit cars would come into force if it was passed. The response I received is below:
"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."
So far from it being the case that responding is a waste of time & would serve no purpose, it would seem that the powers that be ARE listening both to the volume & the nature of the objections, please keep reponses going in, cut-off date is March 2nd.
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
1. mikeveal - completed online consultation.[/quote
I responded by letter, but I have some encouraging news for everyone (well nearly everyone, not Equus perhaps), it would appear that a LOT of people have raised objections, this comes from one of the Cobra forums
"I emailed the Department of Transport to try and get some indication of when the proposed legislation with regard to kit cars would come into force if it was passed. The response I received is below:
"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."
So far from it being the case that responding is a waste of time & would serve no purpose, it would seem that the powers that be ARE listening both to the volume & the nature of the objections, please keep reponses going in, cut-off date is March 2nd.
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
RussBost said:
I responded by letter, but I have some encouraging news for everyone (well nearly everyone, not Equus perhaps)
there’s always one...RussBost said:
it would appear that a LOT of people have raised objections, this comes from one of the Cobra forums
"I emailed the Department of Transport to try and get some indication of when the proposed legislation with regard to kit cars would come into force if it was passed. The response I received is below:
"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."
So far from it being the case that responding is a waste of time & would serve no purpose, it would seem that the powers that be ARE listening both to the volume & the nature of the objections, please keep reponses going in, cut-off date is March 2nd.
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
If this turns out to be correct and I really hope it does it will be a huge weight off of my mind at least."I emailed the Department of Transport to try and get some indication of when the proposed legislation with regard to kit cars would come into force if it was passed. The response I received is below:
"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."
So far from it being the case that responding is a waste of time & would serve no purpose, it would seem that the powers that be ARE listening both to the volume & the nature of the objections, please keep reponses going in, cut-off date is March 2nd.
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
Edited by Hoonigan on Sunday 25th February 06:22
MKnight702 said:
I've responded as well.
I expect it will have precisely zero impact. The "green" blanket has been thrown over this proposal and how dare anyone question it or try to pull the blanket off.
I disagree, it’s looking like the response to this is having the exact effect we would like it to, see post 166 in the attached photo:I expect it will have precisely zero impact. The "green" blanket has been thrown over this proposal and how dare anyone question it or try to pull the blanket off.
We'll see.
But the risk is that if they don't implement the current proposal, it potentially worsens the scenario when they do eventually get round to doing something.
It's inconceivable that with the mainstream move to LZEV, low volume cars will be left forever in a situation where they can be registered with whatever dirty old engines their builders see fit. Next time around might be under a very left wing Labour Government, with different ideas about private transport and the environment. We simply don't know.
Another part of the consultation, which the kit car community has either failed to pick up on or chosen to ignore, asks whether the UK industry wishes to remain in alignment with EU legislation. Most of the manufacturers I know have answered 'yes' to this, as they don't want two separate testing and type approval regimes (with twice the cost) for their products... so there may end up being a basic legislative conflict to be resolved, anyway.
The problem seems to be that the average kit-car builder can't see past the end of their nose in terms of immediate impact and selfish interests.
But the risk is that if they don't implement the current proposal, it potentially worsens the scenario when they do eventually get round to doing something.
It's inconceivable that with the mainstream move to LZEV, low volume cars will be left forever in a situation where they can be registered with whatever dirty old engines their builders see fit. Next time around might be under a very left wing Labour Government, with different ideas about private transport and the environment. We simply don't know.
Another part of the consultation, which the kit car community has either failed to pick up on or chosen to ignore, asks whether the UK industry wishes to remain in alignment with EU legislation. Most of the manufacturers I know have answered 'yes' to this, as they don't want two separate testing and type approval regimes (with twice the cost) for their products... so there may end up being a basic legislative conflict to be resolved, anyway.
The problem seems to be that the average kit-car builder can't see past the end of their nose in terms of immediate impact and selfish interests.
Equus said:
We'll see.
But the risk is that if they don't implement the current proposal, it potentially worsens the impact when they do eventually get round to doing something.
It's inconceivable that with the mainstream move to LZEV, low volume cars will be left forever in a situation where they can be registered with whatever dirty old engines their builders like. Next time around might be under a very left wing Labour Government, with different ideas about private transport and the environment.
Another part of the consultation, which the kit car community has either failed to pick up on or chosen to ignore, asks whether the UK industry wishes to remain in alignment with EU legislation. Most of the manufacturers I know have answered 'yes' to this, as they don't want two separate testing and type approval regimes (with twice the cost) for their products... so there may end up being a basic legislative conflict to be resolved, anyway.
The problem seems to be that the average kit-car builder can't see past the end of their nose in terms of immediate impact and selfish interests.
I did say I was out, but I've risen to it again.......... The extra emissions will probably amount to less than the emissions from smokers' cigarettes and/or vapes But the risk is that if they don't implement the current proposal, it potentially worsens the impact when they do eventually get round to doing something.
It's inconceivable that with the mainstream move to LZEV, low volume cars will be left forever in a situation where they can be registered with whatever dirty old engines their builders like. Next time around might be under a very left wing Labour Government, with different ideas about private transport and the environment.
Another part of the consultation, which the kit car community has either failed to pick up on or chosen to ignore, asks whether the UK industry wishes to remain in alignment with EU legislation. Most of the manufacturers I know have answered 'yes' to this, as they don't want two separate testing and type approval regimes (with twice the cost) for their products... so there may end up being a basic legislative conflict to be resolved, anyway.
The problem seems to be that the average kit-car builder can't see past the end of their nose in terms of immediate impact and selfish interests.
. I have to ask Equus are you a kit car enthusiast?Fastpedeller said:
I did say I was out, but I've risen to it again.......... The extra emissions will probably amount to less than the emissions from smokers' cigarettes and/or vapes .
And that has any legislative relevance at all, because?.Fastpedeller said:
I have to ask Equus are you a kit car enthusiast?
Yes. A very long standing one (second car I ever bought was a Westfield, back in the late '80's, and I've owned many since then).But I also have some understanding from my day job about how legislation works, and I'm trying to take a longer-term view.
Equus said:
Fastpedeller said:
I did say I was out, but I've risen to it again.......... The extra emissions will probably amount to less than the emissions from smokers' cigarettes and/or vapes .
And that has any legislative relevance at all, because?.Oh I bit again! I should stop doing it
Fastpedeller said:
Because if the government were really interested in reducing emissions, there are 'better' targets...
And I ask again, that has any relevance, because?I didn't think that there was anyone left, naive enough to think that the Government has any interest in anything beyond making sure that they remain the Government.
They have agendas that they need to be seen to be trying to do something about, that's all.
I personally do subscribe to the 'every little helps' ethos of trying to save our planet, but don't confuse that with the political realities of framing legislation, either way.
Equus said:
They have agendas that they need to be seen to be trying to do something about, that's all.
Perhaps they should do the emissions test on the combustion engine in all the hybrid cars then, rather than a few kit cars do a few hundred miles a year then.Equus said:
I personally do subscribe to the 'every little helps' ethos of trying to save our planet, but don't confuse that with the political realities of framing legislation, either way.
Errr, no you don’t, you drive a big polluting car and don’t careEquus said:
You're quite right; it doesn't bother me all that much - I'll be long gone before the situation becomes critical.
richardab1967 said:
Perhaps they should do the emissions test on the combustion engine in all the hybrid cars then, rather than a few kit cars do a few hundred miles a year then.
Perhaps they should. Why don't you suggest it to them - I'm sure they'll be waiting on your pontifications with bated breath.
richardab1967 said:
Errr, no you don’t, you drive a big polluting car and don’t care
Big, yes.Polluting?
...I'm not the one worrying about whether my Nazi-Wagon is capable of passing a basic MOT emissions test, am I?
Which rather puts it in perspective how dirty a car will need to be, to fail the proposed test.
richardab1967 said:
Equus said:
Polluting?
Your own words.....Equus said:
but if I choose to run a polluting car (which I do), I pay the punitive road tax and fuel duty without complaint
Yes, one of my cars is a large SUV (one of my others runs on LPG, so is very clean indeed). Neither is the cleanest car available on the market.
...but even the worst is still easily compliant with the emissions standards that you're wetting your panties over, and it's still more fuel efficient than your lightweight sportscar will be IF you manage to get it registered with its prehistoric engine.
Equus,
If you have a serious point to make, then perhaps you should resist the temptation to belittle other posters with petty jibes - or perhaps that is your own method of illiciting a response.
If you have a serious point to make, then perhaps you should resist the temptation to belittle other posters with petty jibes - or perhaps that is your own method of illiciting a response.
Equus said:
Nope, you're not missing anything: the industry is f
ked.
SVA was the thin end of the wedge, and IVA was somebody hitting the wedge with a bloody great lumphammer.
It is ironic that on one hand (thread) you are bemoaning the effect of SVA/IVA yet on this one you are championing a piece of legislation that will remove another dozen or so models from the UK kit car scene.ked. SVA was the thin end of the wedge, and IVA was somebody hitting the wedge with a bloody great lumphammer.
Mistrale said:
It is ironic that on one hand (thread) you are bemoaning the effect of SVA/IVA yet on this one you are championing a piece of legislation that will remove another dozen or so models from the UK kit car scene.
Go back and read my very first post on this thread.It is the very fact that we accepted SVA/IVA with barely a murmur that means it now makes sense to bend with the wind a bit on this issue.
Pre-SVA, we actually had an industry big enough to carry a little bit of clout, politically. Now we do not.
There are two big areas of IVA that can be used to very easily kill what's left of individual self-building.
Emissions is one of them; we're getting off lightly with a test that's simply linked to the MOT. One alternative is a cut-down version of the emissions cycle testing that major manufacturers go through. A lot of the larger kit car manufacturers and specialists would actually welcome this, as it would allow their products to pay CO2-related road tax bands, and since they're very light, they can be made to perform quite well over the test cycle. There have been companies lobbying this at the annual Niche Vehicle Network symposiums, quoting costs of circa £7K, from memory.
The other is structural safety. The Australians (whose regs are otherwise modelled largely on our own) already have a system whereby you need to meet a beam and torsion strength test for any chassis, and you have to have a Consultant Engineer supervising each and every build. They actually have quite a vibrant 'clubby' (the term they use for a Locaterfield) community despite this, but if the cost of passing a BET is scaring UK builders, they'd have an aneurysm if they had to face the implementation of a Supervising Engineer, or destructive impact testing of a chassis (which is the other option). Again, the bigger manufacturers are not necessarily against the idea; it gives them exclusivity in the market by weeding out the smaller players, and it gives assurances to safety-conscious customers.
The larger kit manufacturers also have a vested interest in any legislation that enforces or encourages standard specifications on products, as it makes their stockholding easier, and encourages builders to buy more components via the manufacturer instead of sourcing themselves, so don't expect the 'big guns' of our tiny industry to be fighting too hard on your behalf, either.
As I've said, it's inconceivable that we'll not be asked to keep in step with emissions legislation in some shape or form, as the mainstream market progresses to LZEV, and I have no doubt that safety will soon float to the top of the agenda again, too. So if we're given relatively painless options that allow us to stave off the inevitable for another few years, common sense says that we should take them...
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