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Old 13th February 2018, 11:24
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Default Proposed response

I'm still working on my response but here it is the draft so far...
(I make no apology for plagiarising some bits from other forums which i have weaved together.)

Please review and let me know your thoughts and comments.......


Objection to Paragraphs 4.10 – 4.13 in the Road vehicles Improving air quality and safety- Feb 2018 consultation.

Paragraph 4.1
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.


The wording of this paragraph is ambiguous and it is not clear if this clause applies retrospectively to all kit cars currently registered. If this is a retrospective requirement then many thousands of kit cars will be scrapped as it would not be technically possible to make them all compliant.


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?


I strongly oppose this part of your proposal.

The environmental impact caused by kit cars using engines that do not meet the current MOT emission standards is insignificant due to their limited number and limited annual mileage. This appears to be confirmed by your own cost/benefit analysis in Appendix A, (page 6).

Once registered, many kit cars are used for a relatively low mileage each year (evidenced by the fact that many kit cars are insured on limited mileage policies), and therefore even those cars tested to the standards applicable to their engine’s age will make very little environmental impact in real terms.

Of the relatively small number of kit cars which are being built and used on the road, many already have engines which meet current MOT emissions standards. However, certain types of kitcars/replicas are designed to use older style engines that are not technically designed to meet current MOT emissions standards. The companies producing these kits and cars will become untenable and will likely go out of business. The impact on these businesses and jobs appears to be omitted from Appendix A.

The insignificant improvement in air quality from this proposal does not justify the cost of implementation nor the business impact of this change.

Many kit cars are built as a hobby over long period of time, sometimes up to 10 years, and can be a significant individual investment so any changes such as these should be introduced over a 3-5 year timeframe to allow builders time to adjust their plans and not be left with cars that cannot be registered.

But, the kit car / classic car industry is not just a hobby for many and provides employment for 1000's. In the post Brexit world the UK's micro industries must be encouraged and not legislated out of existence.
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