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  #21  
Old 13th February 2018, 09:44
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Quote:
Originally Posted by Mitchelkitman View Post
A measured response is indeed likely to be more effective than an emotive response - but anything is possibly better than no response
Maybe a good approach is to use the 'politicians' speak and keep parameters loose enough whilst getting the point across eg. A change of engine for an individual's car may involve so many associated parts that the extra cost will be beyond the budget. eg2. A change of engine for a manufacturer may not be possible either mechanically or economically (for instance a suitably compact engine with ancilliaries such as exhaust manifold in a safe place may not exist) rendering the Companies loss of market and employees jobs. I'm basing my response mainly on the extra environmental impact of manufacturing compared to the emissions the donor car engine would generate through being driven a low annual mileage - I accept this is unquantified, but may strike the right chord. I'm sure others will give many good reasons.
I like this approach, its similar but different to my argument. I think a variety of objections should help the cause.
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  #22  
Old 13th February 2018, 09:50
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Default BIVA facebook page

I'm still working on my letter.
I found the bulletin points and some draft letters useful in this facebook group.
https://www.facebook.com/groups/1489...oved&ref=notif

Neil
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  #23  
Old 13th February 2018, 10:04
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Quote:
Originally Posted by Paul L View Post
Peterux & Mitchelkitman - Agreed about providing a measured response and I'm still working on mine.

I found this useful link.
https://www.smmt.co.uk/industry-topi...sions/testing/

Which should help defeat the DfT's claim that BIVA builders now have 25 years of 'modern' engines to pick from.

As the table shows that only a Euro 5 petrol engine (or newer) would pass Euro 6 standards and nothing other than a Euro 6 diesel engine could be used.

Cheers, Paul.
Paul, you may be right in your interpretation because the wording in the proposal is so ambiguous but my reading is that they want 'kitcars' to comply with the current MOT emissions standards which are quite different to the Euro standards for new cars.
The section 4.10 states
"Kit cars undergoing IVA will not be required to meet WLTP, given that at present they are not required to meet NEDC or the latest EU standards. Instead they are tested to age-appropriate MOT standards, on the basis of the date of manufacture or first use of the engine
But 4.11 says...
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.

Fuel injected engines with a CAT should be able to meet the MOT standard but older engines on carbs may not.
The problem is that they can then tighten the MOT standard whenever they like in the future!!
Mr Towed has always been good at interpreting regulations so it would be nice to see him weighing in. Porsche Speedsters are one club that could be severely impacted.

Thanks for your support and taking the trouble to respond,

cheers,

Peter
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  #24  
Old 13th February 2018, 10:24
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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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  #25  
Old 18th February 2018, 19:55
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You can respond to the proposal by completing the online feedback here...

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

Not sure why but, the Question 10 on kitcars in the proposal becomes question 15 in the survey.

I have just completed my feedback and for sections I was not interested in, I just typed 'Not reviewed'. For the Kitcar question I cut and pasted my response above in the box.

It's an easy and a relatively quick way of providing feedback.
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  #26  
Old 21st February 2018, 14:56
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If the proposals are adopted;

1. Kits that use donors made in the last 25 years will not be affected.

2. Kit cars that are currently registered will not be affected if the proposals are adopted.

3. New car MOT standards as ref in the proposal means BET (basic emission test). To comply a CAT will be needed.

4. The majority of kits manufactured today use post 1995 engines and therefore comply with BET.

5. Kits currently under construction with carbs may struggle to pass but with a CAT it may be possible.

6. Kits that use engines over 25 years old may struggle to pass but with a CAT it may be possible.

7. Currently a kit with a post 1995 engine goes through a far more strict test than one with a 60's engine but that may change.
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  #27  
Old 22nd February 2018, 08:10
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Peterux - Thanks for the vote of confidence in my ability to pick the bones out of the legal side of things, but then I was doing that for a living until last year.

I've stayed out of this debate so far as I'd always vowed not to build a car that needed IVA due to the significant extra expense and bizarre regulations that you have to comply with. I mean, rounded instrument bezels? What is that all about? If your face hits the rev counter in your Caterfield Se7en then you've got more to worry about than a cut chin.

But, I have to say I do have some concerns over these changes as they could represent a slippery slope towards retrospective regulation of existing cars or be applied to re-bodied classics that I do like to build.

I haven't yet read through all the proposals, but from what I've seen so far I think the focus should be on two areas:

1 - Clarification of what the changes actually mean for our hobby and some specialist businesses (anyone building turn-key DBR2's, SS100's or C Types in the £50k to £120k bracket, for example);

2 - Ensure that the legislators are made aware of how little impact our impractical, sunny days and holidays, limited mileage cars have on the environment, especially inner city air quality which is the hot textured tofu du jour.

As such, I would avoid any kind of rant in response and also any phrases suggesting that thousands of cars will be affected. That may well be counter-productive, giving ammunition to whoever dreamt up these changes.

Instead, a FOI subject access request could be made to DVLA to establish how many specialist cars are registered in the UK, and how many miles are driven in them each year as recorded on their MOT returns. That could then be presented as proof that introducing such legislation is a waste of taxpayers' money as the benefits would clearly be minimal when compared to the costs involved.

In fact, given that our cars are 99% petrol powered and it's now universally accepted that diesels do most of the damage to inner city air quality, I wouldn't be surprised if the particulate, CO2 and Nitrogen Oxides output of our entire hobby's cars each year is less than that of a single London Black cab, which counts as environmentally 'friendly' public transport.

I'll have a read of the proposals later and get back on here if I think I can contribute anything useful to the debate.
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  #28  
Old 22nd February 2018, 09:02
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Quote:
Originally Posted by Mister Towed View Post


As such, I would avoid any kind of rant in response and also any phrases suggesting that thousands of cars will be affected. That may well be counter-productive, giving ammunition to whoever dreamt up these changes.

Instead, a FOI subject access request could be made to DVLA to establish how many specialist cars are registered in the UK, and how many miles are driven in them each year as recorded on their MOT returns. That could then be presented as proof that introducing such legislation is a waste of taxpayers' money as the benefits would clearly be minimal when compared to the costs involved.
Hi Towed
As Peterux has already stated the authors of the proposal actually included their own estimate of the number of cars whose emissions would be improved.
It is 523 (Appendix A, Section 3, item 1)and when compared with a total of 37.5 million vehicles registered with the DVLA (https://www.gov.uk/government/upload...march-2017.pdf) it represents a 0.0014% improvement!

If you use an average figure of 3000 miles per year for kit car annual mileage then that represents 0.0005% of the 323.7 billion miles driven on Britain's roads in 2016 (https://www.racfoundation.org/motori...s/mobility#a25)

Personally I don't think such a pitiful improvement is worth anyone at Realm, Suffolk, Chesil etc losing their job.


Neil

P.S. I've just sent in my response to the Consultation questions...must admit I couldn't help myself when I reached question Q45. What are your views on our analysis of costs and benefits? Give supporting evidence wherever possible: My views included "a waste of time for the projected benefits which would not be tolerated in my former employment".

Last edited by NeilF355; 22nd February 2018 at 19:43.. Reason: Post script
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  #29  
Old 23rd February 2018, 21:06
NigelB NigelB is offline
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There's a loooonnnnggg post about this on the UK Cobra Club Forum

http://www.cobraclub.com/forum/showt...=59824&page=17

Page 17 is the key page. It looks like there may be a rethink going on.

Fingers crossed. But everyone with an interest needs to write in with their concerns.

Nigel
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  #30  
Old 25th February 2018, 13:21
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Well, I've finally finished the survey and certainly tried my best to build a case for kit cars, hot rods and non-VHI classic cars that are/will be covered by BIVA.

Cheers, Paul.
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  #31  
Old 28th February 2018, 10:09
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Just two days left to respond. ...
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  #32  
Old 15th March 2018, 08:25
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I can't see this helping. ....
http://www.bbc.co.uk/news/uk-politics-43405684

The civil servants will be under pressure to tighten emissions even more :-(
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  #33  
Old 15th March 2018, 16:18
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Only one way to tackle this - Bicycles for short journeys and electric trains for long journeys!
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  #34  
Old 21st April 2018, 07:24
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I picked this news item from a classic car publication.....

http://historicvehicles.org.uk/hvg3.php

Maybe all those letters and emails did have some effect?
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  #35  
Old 1st May 2018, 11:17
Mitchelkitman Mitchelkitman is online now
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This has appeared today on the Complete Kit Car magazine facebook page.....

We've just received a call from the Department for Transport confirming that they will not proceed with the part of the emissions regulation proposals that affected kit cars. There were over 2000 responses to the consultation.
A Department for Transport spokesperson said:
“The UK’s specialist vehicle industry is thriving – it creates jobs and gives enjoyment to many, with products exported all over the world.
“We are grateful to the over 2000 kit and replica car enthusiasts, manufacturers and suppliers who took part in this consultation. Following their responses, we have decided that there will be no changes to the current MOT–style testing of kit car emissions.”

Our comments did something! Well done everyone.
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  #36  
Old 1st May 2018, 11:23
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The proposed changes have been dropped.

This is from Complete Kit Car magazine's facebook page:

We've just received a call from the Department for Transport confirming that they will not proceed with the part of the emissions regulation proposals that affected kit cars. There were over 2000 responses to the consultation.

A Department for Transport spokesperson said:

“The UK’s specialist vehicle industry is thriving – it creates jobs and gives enjoyment to many, with products exported all over the world.

“We are grateful to the over 2000 kit and replica car enthusiasts, manufacturers and suppliers who took part in this consultation. Following their responses, we have decided that there will be no changes to the current MOT–style testing of kit car emissions.”
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  #37  
Old 1st May 2018, 16:04
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Quote:
Originally Posted by softfeet View Post
The proposed changes have been dropped.

This is from Complete Kit Car magazine's facebook page:

We've just received a call from the Department for Transport confirming that they will not proceed with the part of the emissions regulation proposals that affected kit cars. There were over 2000 responses to the consultation.

A Department for Transport spokesperson said:

“The UK’s specialist vehicle industry is thriving – it creates jobs and gives enjoyment to many, with products exported all over the world.

“We are grateful to the over 2000 kit and replica car enthusiasts, manufacturers and suppliers who took part in this consultation. Following their responses, we have decided that there will be no changes to the current MOT–style testing of kit car emissions.”
Excellent news!! Power to the people
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  #38  
Old 28th May 2018, 21:32
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Still no official update on the consultation....

https://www.gov.uk/government/consul...ity-and-safety

Less than 4 weeks to review and reply to the consultation.....3 months+ to analyse!!
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  #39  
Old 8th June 2018, 10:26
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Official consultation response now published in full online. No changes to existing BIVA arrangements for kit cars, so all good news. Just needs them to sort out the MOT confusion now (introduced in the changes on the 20th May).

John
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  #40  
Old 11th June 2018, 19:43
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This is a great result and for once shows the power of collective lobbying.

If you read the whole report you get the gist how they were overwhelmed by, email, letters and responses to the questionnaire from the kit car community.

For anyone not wishing to read the whole report here is the important summary from Jesse Norman MP.

Our proposal to implement stricter emissions rules for kit cars was a minor part of the package. But it raised serious concerns among kit car enthusiasts, and attracted the vast majority of the 2340 responses received. There were numerous objections, pointing out among other things the importance and value of the UK’s specialist vehicle industry. We have reflected on these concerns and have decided not to proceed with this aspect of the proposal.



And in the relevant section....

2.39 Respondents argued fitting catalytic converters and more modern engines to kit cars would lead to negligible positive impact on the environment, given the low proportion of kit cars in the fleet, the low average mileages travelled and low proportion of travel in urban areas. On the other hand respondents cited the expected enormous negative impact on the industry, with concerns around harming authenticity, increasing cost, packaging difficulties and technical issues with using modern engines with immobilisers designed for a specific application.
2.40 In addition, a lot of respondents argued that a change of this nature could not be made quickly but would require suitable notice, because the timeline for constructing a kit car can be extensive, up to ten years and several respondents had experience of a longer period. Constructors really valued the current ability to purchase an engine of a given build date and be confident that when the vehicle was finally complete it would still be assessed against age-appropriate standards.
2.41 The potential harmful impact of the proposed changes on the industry supporting amateur builders was mentioned, with respondents pointing out that the kit car sector was part of a larger UK specialist car industry which was world leading and a source of exports.


Well done everyone who took the trouble to respond!!
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