New emissions for kit cars consultation
Discussion
Frankthered said:
Mistrale said:
It appears fairly clear.
When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
With respect I don't think it is clear. I agree that the idea is to prevent people building kits and using older engines just to avoid needing a Cat and allow them to keep their carbs. (Does anybody do that any more?)When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
What about a single donor kit, though? If I were insane enough to buy that Ginetta G26 that's been on eBay and happened to find a 20k mile Cortina with rapidly decomposing bodywork, I could build the G26 and apply for an age related plate. My direct experience of this is that the date of first registration stated on the V5 is the same as the donor and is unrelated to the date of IVA.
Intuitively, I would suggest that the few cars left of this ilk would fit better into the description included in 4.12 (reconstructed classic) rather than 4.11, other than the bit about the appearance being broadly unchanged.
Complete Kit Car have just posted on their FB page this is a part of it.....
..........................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.
..........................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.
Fastpedeller said:
Frankthered said:
Mistrale said:
It appears fairly clear.
When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
With respect I don't think it is clear. I agree that the idea is to prevent people building kits and using older engines just to avoid needing a Cat and allow them to keep their carbs. (Does anybody do that any more?)When you complete IVA, that counts as date of registration. Your build has to comply with MOT rules in place on that day.
A build based on MX5 etc., as long as it has a Cat etc. 'should' pass. A build based on a carb'd Pinto won't.
This proposal is a sledgehammer crack a non-existent nut, given the number of kits on the road and the mileage that they drive...
What about a single donor kit, though? If I were insane enough to buy that Ginetta G26 that's been on eBay and happened to find a 20k mile Cortina with rapidly decomposing bodywork, I could build the G26 and apply for an age related plate. My direct experience of this is that the date of first registration stated on the V5 is the same as the donor and is unrelated to the date of IVA.
Intuitively, I would suggest that the few cars left of this ilk would fit better into the description included in 4.12 (reconstructed classic) rather than 4.11, other than the bit about the appearance being broadly unchanged.
Fastpedaller's Quantum; SVA 2009, date of first registration, 2009. (Presumably with a note to state the specific emissions requirements for the car)
Frankthered's Minari; IVA 2011, date of first registration, 1987. No note required as it's treated as any 1987 car.
Different day at the DVLA, different result. What date of first registration would the G26 get, I'm buggered if I know, although in that particular case, it wouldn't be a massive hardship to fit a later engine with a cat to pass the MOT emissions test as I am inferring from everybody's replies that this is all that would be required.
It does make me suspect that whoever wrote this doesn't really understand kit cars, so there is probably some room for manoeuvre within the proposal.
Not sure where all the comments about the legislation being retroactive are coming from - have I missed something?
Frankthered said:
This is what I'm talking about:
Fastpedaller's Quantum; SVA 2009, date of first registration, 2009. (Presumably with a note to state the specific emissions requirements for the car)
Frankthered's Minari; IVA 2011, date of first registration, 1987. No note required as it's treated as any 1987 car.
Different day at the DVLA, different result. What date of first registration would the G26 get, I'm buggered if I know, although in that particular case, it wouldn't be a massive hardship to fit a later engine with a cat to pass the MOT emissions test as I am inferring from everybody's replies that this is all that would be required.
It does make me suspect that whoever wrote this doesn't really understand kit cars, so there is probably some room for manoeuvre within the proposal.
Not sure where all the comments about the legislation being retroactive are coming from - have I missed something?
The quantum has a note saying %CO 3.5 ; HC 0.12. For some reason the MOT guy has problems relating this to his equipment, and asks "what year do I test it at?" so I say 1987, but he uses 1992. Fastpedaller's Quantum; SVA 2009, date of first registration, 2009. (Presumably with a note to state the specific emissions requirements for the car)
Frankthered's Minari; IVA 2011, date of first registration, 1987. No note required as it's treated as any 1987 car.
Different day at the DVLA, different result. What date of first registration would the G26 get, I'm buggered if I know, although in that particular case, it wouldn't be a massive hardship to fit a later engine with a cat to pass the MOT emissions test as I am inferring from everybody's replies that this is all that would be required.
It does make me suspect that whoever wrote this doesn't really understand kit cars, so there is probably some room for manoeuvre within the proposal.
Not sure where all the comments about the legislation being retroactive are coming from - have I missed something?
I think the concern about it being retrospective is because the wording is poor. It doesn't state specifically that it's all new IVA vehicles
re section 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.”
As an aside I'm not surprised at this latest move, it's about par for the course for regulators who think they'll either save the planet or line their own pockets by introducing rules which make little sense - Their insistence on heading down the route of hybrid or electric is an example of not looking at the whole picture..... we'll make cars that look cleaner but use a lot more energy during their production than will ever be 'repaid' with economy, and we've already said that the county will have a 30% electricity shortfall within the next 20 years, but hey ho!
Frankthered said:
Not sure where all the comments about the legislation being retroactive are coming from - have I missed something?
At first I thought they were retrospective, now I am not so sure. I think it is all about MOT time and the ambiguity of what they have said.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.
I suppose strictly speaking my car will comply with the 2017 registration date emission standards as my V5 states
Special note 2.
2 SVA/IVA CERT ISSUED 13 06 2017 EMISSIONS - VISUAL TEST ONLY
But is this what they mean, or do they mean my visual test no longer applies at MOT time.
Regards
Nick
Edited by Nick Brough on Thursday 8th February 22:58
The way I read it, if the ruling comes into force your MOT emission test will be the emission in force when your car was registered and that the ‘visual’ test would no longer apply.
There are a lot of people out there who read it as it will not be applied retrospectively but no one can give a definitive answer.
There are a lot of people out there who read it as it will not be applied retrospectively but no one can give a definitive answer.
I have now had confirmation via the assistant to my local MP that the new rules - if they come into force - will not be retrospective. They will apply to cars registered later in 2018 at a date to be confirmed. Anyone building a car with an engine that won’t comply with current emissions legislation needs to get it registered and IVA’d as soon as possible as a contingency against Government madness....
Is there a good source of information of the various emissions requirements for the different years, e.g. I have a Ford Pinto in my Westfield that I registered in 1992. Where can I find what the emissions were back then?
I can see this all being a lot of agro. In the past I have had to educate my various MOT testers as to what is required.
It's a bit easier now with the internet but I have had the odd awkward moment pre internet in the testers garage as he has chatted on the phone to someone from the ministry about whether he should pass it. It always got through in the end and they were all fairly gracious with me being correct. Once we established what was needed I tried to stay with that garage every year unless I moved away.
I can see this all being a lot of agro. In the past I have had to educate my various MOT testers as to what is required.
It's a bit easier now with the internet but I have had the odd awkward moment pre internet in the testers garage as he has chatted on the phone to someone from the ministry about whether he should pass it. It always got through in the end and they were all fairly gracious with me being correct. Once we established what was needed I tried to stay with that garage every year unless I moved away.
Tempest_5 said:
Is there a good source of information of the various emissions requirements for the different years...?
Fill ya boots (page 12, specifically)Equus said:
Tempest_5 said:
Is there a good source of information of the various emissions requirements for the different years...?
Fill ya boots (page 12, specifically)The following types of vehicle will be considered as first used before 1 August 1975
(Visual Test):
• wankel rotary engined vehicles first used before 1 August 1987.
• All kit-cars and amateur built vehicles first used before 1 August 1998.
and
• For vehicles first used before 1 August 1975 a visual test will be applied.
• For vehicles first used on or after 1 August 1975 a metered test will be applied.
So does my '76 'first registered' kit car only need a visual test? At MOT the tester has always used the metered test for 1976 car
Fastpedeller said:
So does my '76 'first registered' kit car only need a visual test? At MOT the tester has always used the metered test for 1976 car
My understanding is that the visual smoke test only applies to kit cars if they are on a Q-plate (ie. indeterminate year of manufacture), but admittedly that's not what it says.
BobE said:
I have now had confirmation via the assistant to my local MP that the new rules - if they come into force - will not be retrospective. They will apply to cars registered later in 2018 at a date to be confirmed. Anyone building a car with an engine that won’t comply with current emissions legislation needs to get it registered and IVA’d as soon as possible as a contingency against Government madness....
I see a lot of people posting....Any of you taken the time to write a response to the consultation?
I have!
If you want your voice heard you should reply to the consultation and at the very least ask for a transition period of 4 years which is the average time builders take to complete a self build.
My main argument was that the current engine age related emissions requirement was working and given more time would meet the consultations requirement.
I also mentioned kit replicas and how they would be wiped out but that manufacturers could still build continuation models
PaulKemp said:
BobE said:
I have now had confirmation via the assistant to my local MP that the new rules - if they come into force - will not be retrospective. They will apply to cars registered later in 2018 at a date to be confirmed. Anyone building a car with an engine that won’t comply with current emissions legislation needs to get it registered and IVA’d as soon as possible as a contingency against Government madness....
I see a lot of people posting....Any of you taken the time to write a response to the consultation?
I have!
If you want your voice heard you should reply to the consultation and at the very least ask for a transition period of 4 years which is the average time builders take to complete a self build.
My main argument was that the current engine age related emissions requirement was working and given more time would meet the consultations requirement.
I also mentioned kit replicas and how they would be wiped out but that manufacturers could still build continuation models
Equus said:
Fastpedeller said:
So does my '76 'first registered' kit car only need a visual test? At MOT the tester has always used the metered test for 1976 car
My understanding is that the visual smoke test only applies to kit cars if they are on a Q-plate (ie. indeterminate year of manufacture), but admittedly that's not what it says.For others with existing kitcars have a look on the front page of the V5. In the notes section mine states when in passed SVA and also states 'visual smoke'.
Steve
Steve_D said:
Equus said:
Fastpedeller said:
So does my '76 'first registered' kit car only need a visual test? At MOT the tester has always used the metered test for 1976 car
My understanding is that the visual smoke test only applies to kit cars if they are on a Q-plate (ie. indeterminate year of manufacture), but admittedly that's not what it says.For others with existing kitcars have a look on the front page of the V5. In the notes section mine states when in passed SVA and also states 'visual smoke'.
Steve
And back on subject.....
This is not about your cars currently registered
This about every one building and the cliff edge proposal for newly IVA’d cars Sept 2018 t comply with the post 1995 MOT emissions.
So all those with a registered car please send a response to the consultation and let’s hear from those currently building and those hoping to build in the future
RESPOND TO THE CONSULTATION OR LOOSE AFORDABLE KIT CARS
This is not about your cars currently registered
This about every one building and the cliff edge proposal for newly IVA’d cars Sept 2018 t comply with the post 1995 MOT emissions.
So all those with a registered car please send a response to the consultation and let’s hear from those currently building and those hoping to build in the future
RESPOND TO THE CONSULTATION OR LOOSE AFORDABLE KIT CARS
"...BUT, I will say that for the vast majority of projects, I don't personally think the proposed rule change would be that onerous" - rather depends what vehicles you are talking about - how easy do you think it would be to get a Cobra with a carb'ed V8 thro' the test, or a GT40, Ultima etc. If you want such a vehicle with a modern fuel injected & catalysed engine it can obviously be done, but would it have anything like the same visual or audio effect as the original? I don't think so, same goes for any "traditional" replica, SS100, C or D type etc.
If you are talking about a 7 clone with modern MX5 donor then sure, it's no big deal, but what about the guys who started a build 4, 5 or more years back with an engine that will, under these proposals, be useless. What if you've just forked out a small fortune for a pair of 40 or 45 Webbers or similar for your project, you're now faced with needing to sell them at a loss & start over ......
I would also point out that we would be agreeing to cars being tested to the MoT standards "applicable at time of test/registration", ie test the car in 2020, comply with 2020 emission standards - WHATEVER THEY ARE. We have no way of knowing if MoT standards are due a change or not, but they've not changed for around 16 years & in that time we've gone from Euro 3 to Euro 6. Nobody seems to have twigged the fact that we would be agreeing to a test with moving goalposts!
The current air pollution concern is all about NOxes, hence the "witch hunt" for diesels, how long b4 we get a NOx test at MoT time - now that would be a total gamechanger, I doubt any engine much b4 2012 would meet any modern Euro 6 style legislation re NOxes,
At an absolute minimum we need an extension of several years for people to get existing builds finished, but for goodness sake people, if you DO object then get a letter in quickly, (the online service is hopeless, you need to answer ALL questions, not just the stuff about 4.10, 4.11) we have only till the start of March to reply to this.
Address to write to in case you've missed it is:-
Robert Lloyd-Smith
Zone 1/33,
Great Minster House
33 Horseferry Road,
London,
SW1P 4DR
My reply went off yesterday, how about yours???
If you are talking about a 7 clone with modern MX5 donor then sure, it's no big deal, but what about the guys who started a build 4, 5 or more years back with an engine that will, under these proposals, be useless. What if you've just forked out a small fortune for a pair of 40 or 45 Webbers or similar for your project, you're now faced with needing to sell them at a loss & start over ......
I would also point out that we would be agreeing to cars being tested to the MoT standards "applicable at time of test/registration", ie test the car in 2020, comply with 2020 emission standards - WHATEVER THEY ARE. We have no way of knowing if MoT standards are due a change or not, but they've not changed for around 16 years & in that time we've gone from Euro 3 to Euro 6. Nobody seems to have twigged the fact that we would be agreeing to a test with moving goalposts!
The current air pollution concern is all about NOxes, hence the "witch hunt" for diesels, how long b4 we get a NOx test at MoT time - now that would be a total gamechanger, I doubt any engine much b4 2012 would meet any modern Euro 6 style legislation re NOxes,
At an absolute minimum we need an extension of several years for people to get existing builds finished, but for goodness sake people, if you DO object then get a letter in quickly, (the online service is hopeless, you need to answer ALL questions, not just the stuff about 4.10, 4.11) we have only till the start of March to reply to this.
Address to write to in case you've missed it is:-
Robert Lloyd-Smith
Zone 1/33,
Great Minster House
33 Horseferry Road,
London,
SW1P 4DR
My reply went off yesterday, how about yours???
I agree with what you've said Russ, but we need to be clear (and the proposal document isn't) as to what is meant by 'emissions at test date'
My understanding is that it's the IVA test date, not the MOT test date. As an example, get a car through IVA in 2018, and the MOT levels in place for 2108 will be noted on the V5C, and these will be the levels that the car has to comply with. Maybe I'm wrong? Whatever our interpretation, it is indeed important that we send email or similar response before 2nd March!
My understanding is that it's the IVA test date, not the MOT test date. As an example, get a car through IVA in 2018, and the MOT levels in place for 2108 will be noted on the V5C, and these will be the levels that the car has to comply with. Maybe I'm wrong? Whatever our interpretation, it is indeed important that we send email or similar response before 2nd March!
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