Are you madabout kit cars      
 "We've Got Kit Cars Covered" Information about Madabout-Kitcars.com Contact Madabout-Kitcars.com         Home of UK kit cars - madabout-kitcars.com Various kit car write ups All the latest kit car news Kit car related and general discussion

Search
Manufacturers
Kit Cars
Kit Car Data sheets
Picture Gallery
SVA Knowledgebase
Clubs & Communities
Build cost estimator
Kit cars for sale
Knowledge Base 
KitcarUSA.com
Classic-Kitcars.com
 

Go Back   Madabout Kitcars Forum > Mad Build Area > General Build Chat

General Build Chat Area for general build chat, questions, tips, tricks and progress

Reply
 
Thread Tools Display Modes
  #21  
Old 13th February 2018, 10:44
peterux's Avatar
peterux peterux is offline
Senior Member
Enthusiast
 
Join Date: Mar 2005
Posts: 2,707
peterux is on a distinguished road
Default

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.
Reply With Quote
  #22  
Old 13th February 2018, 10:50
NeilF355's Avatar
NeilF355 NeilF355 is offline
Senior Member
 
Join Date: Sep 2011
Location: Teesdale
Posts: 130
NeilF355 is on a distinguished road
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
Reply With Quote
  #23  
Old 13th February 2018, 11:04
peterux's Avatar
peterux peterux is offline
Senior Member
Enthusiast
 
Join Date: Mar 2005
Posts: 2,707
peterux is on a distinguished road
Default

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
Reply With Quote
  #24  
Old 13th February 2018, 11:24
peterux's Avatar
peterux peterux is offline
Senior Member
Enthusiast
 
Join Date: Mar 2005
Posts: 2,707
peterux is on a distinguished road
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.
Reply With Quote
  #25  
Old 18th February 2018, 20:55
peterux's Avatar
peterux peterux is offline
Senior Member
Enthusiast
 
Join Date: Mar 2005
Posts: 2,707
peterux is on a distinguished road
Default

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.
Reply With Quote
Reply


Currently Active Users Viewing This Thread: 2 (0 members and 2 guests)
 
Thread Tools
Display Modes

Posting Rules
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts

BB code is On
Smilies are On
[IMG] code is On
HTML code is Off

Forum Jump


All times are GMT +0. The time now is 19:28.

copyright © madabout-kitcars.com 2000-2018
terms and conditions | privacy policy