BIVA Builds - Engine Rules
 

Spotted this on Rods 'n' Sods:

http://www.rodsnsods.co.uk/forum/lic...vy-shit-530026

Basically there is a new DfT consultation on making any engine in a car getting IVA'd meet current emission standards.

Whereas, currently, you can fit an old V8 and meet the emissions standards of the time of the engine.
( For some this is a simple smoke test. )

If you think this will effect you, or others you know, please pass it on and respond to the DfT.

Cheers, Paul. :)

Disaster!!!!!
 

Paul,

thanks for raising this issue.

This could have a devastating effect on the traditional kitcar industry. The way I read it anyone building a car that needs an IVA will probably have to fit a new'ish engine fitted with a CAT to meet the current MOT emissions standard.(Or spends hundreds of pounds trying to get an old engine to meet the current MOT regs if at all possible)

I think the requirements and implementation time-frame are both completely unreasonable!! (The feedback timescales are also unreasonable).

Whilst we should all be looking after the environment, the impact on the world of a very few kitcars is infinitesimal.

Time to do battle....:fencing:

P.S. I have written to Adam Wilkins (Complete Kitcar) and Steve Hole (Totalkitcar) to see if they can drum up some industry support to lobby.

This proposal is also being discussed on Locost Builders forum.

http://http://www.locostbuilders.co.uk/viewthread.php?tid=211596&page=1

It is a lively and amusing debate!

It seems that there will be a quite a lot of replies to the consultation.

Thanks, softfeet.
I have updated my post above now I have calmed down a bit!
The proposal is that at the IVA you have to meet the current MOT requirements for emissions (which could of course change at any time in the future!).
So you'll need to build with a new'sh engine that has a properly working CAT and an ECU set up to meet the MOT test. So no good try to use an old engine on carbs with no CAT so this will exclude old V8's and Ford pinto's etc.

I still think it's unreasonable and ineffective to force the small number of builders down this route for very little impact on the environment.

Similar lively debate on Pistonheads kitcar forum....

https://www.pistonheads.com/gassing/...f=30&t=1722937

I'm confused
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”

Yet the consultation question 10 asks

"Are you content to require kit cars submitted for IVA to meet the latest MOT standards, thereby removing the current rule that kit cars are IVA tested to MOT standards according to engine age?"


Also
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.”

If you've already passed IVA with a pre 92 engine (and had the non cat limits applied at the IVA test) because your date first registered will be post 2000 will you have the cat limits applied to your car at it's next MOT???????

Agreed, It's a very poorly worded document and open to interpretation.

4.10 is the good news, but.....
4.11 is a tightening of the regulations for older engines.
You are right to point out that 4.11 does not say 'when submitted for IVA' so could imply that this is a retrospective action on existing cars, although from the question I think they mean when submitted for IVA.

Perhaps an additional complaint is that its not possible to comment because the proposal is not clearly described.

I've had another read through the proposals and you are correct - they apply to NEW vehicles submitted for IVA.

It puts my current build in jeopardy as it has a pre 1992 Alfa v6 engine which I doubt very much can be brought up to 2018 emissions standards and I have no real chance of completing it before the July this year implementation of these proposals. :doh:

The implication is there (as the title says new vehicles), but
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.
Can be read either way - or am I just being too anxious?

Will this also affect the VED charges on the vehicle as they are based on emissions

What do they mean by 'kit car'? A valid question, as the GOV.uk site has 'kit-built vehicles' and 'kit-converted vehicles'. I guess it doesn't include body kits, as these (hopefully) aren't subject to IVA, but could a name change bring about a new registration date?

There is some very helpful information on this subject here:

https://completekitcar.co.uk/2018/02...-changes-mean/

Thanks for posting this link.
I wrote to Adam Wilkins yesterday, after I saw Paul's post, and he said they were looking into it but didn't point me to this page?
It's good to see that some manufacturers are taking up the battle, but I think as many individuals as possible should complain.
Clearly it is important that manufacturers, traders and private owners who would be affected by these proposals, should respond as soon as possible, outlining their concerns.

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

Because the wording is so ambiguous anyone who thinks this is wrong should object.:boink:

Buried deep in the DfT document in the Appendix A (page 6) is the following extract....

In the areas under consideration in this package of measures, it is considered that safety and the environment can be improved, at modest cost, by increasing the current level of requirements in domestic approval schemes, to approach more closely the level of the EU requirements. The areas under
consideration where this applies include:
1) improvements to tailpipe emissions (to an estimated 523 vehicles), which should improve air quality,

Tailpipe emissions in a total of 523 vehicles!!

For convenience I’ve copied some of the information and contact details over from Rods ‘n’ Sods.

Details of the Government’s consultation are here:
https://www.gov.uk/government/consul...ity-and-safety

I’m not on Facebook, so I hope this link to suggested reply templates works:
https://www.facebook.com/groups/148944219148084/

Another sample response is here:
http://www.blanfordpersians.co.uk/Le...20schemes.docx

It has also been suggested that you copy your responses to the following:

Minister for Roads, Local Transport and Devolution
Email - jesse.norman@dft.gsi.gov.uk
Use the subject line Transport Enquiry.

Shadow Minister for Transport.
Email - info@andymcdonaldmp.org

Replies to be submitted before 2nd March 2018.

Mitchelkitman – You are correct & I’ve now fixed my previous post, thanks.

I’ve also posted a correction on Rods ‘n’ Sods where I’d copied that date across from. :rolleyes:

Finally…

In my, admittedly limited, experience, there is still some confusion in the DVLA about the difference between a ‘traditional’ kit car (E.g. Caterham, Westfield, Ultima, etc.) and body kits (E.g. Tribute SWB 250, MX250, etc. ) and rebodies (E.g. Sammios, Miglias, Formosas, etc.).

So, hopefully, these are not affected by this, but I’m still planning to reply on behalf of traditional kits.

Cheers, Paul. :)

I think we all should - even anyone not directly affected. If we get the kit car proposals dropped, it will surely strengthen any future case against changes (be what they may).

Paul,
many thanks for posting these links and I'd like to support yours and Mitchelkitman's suggestion that everyone responds whether they are affected or not.

However, I have read the proposed response and can't help feeling it won't be an effective way of changing the DfT's mind. I can understand that emotions are running high (my own blood boiled when I first read it!!) but a letter with inaccuracies and exagerated claims may just be tossed in the bin.

Statements such as "it will render all current builds as scrap and will potentially kill a multi-billion industry stone dead." are incorrect.
Also, the Code of Practise for Consultations is an old document that has been superseded. A quick google search will find the latest version of the governments guidelines(2016) that does not require 12 weeks.

I am genuinely concerned that letters like these will dismissed out of hand and not counted as valid objections.

I'm working on an alternative response for others to copy or plagiarise as they see fit.
I will post it on here when I'm happy with it.

cheers, Peter

A measured response is indeed likely to be more effective than an emotive response - but anything is possibly better than no response :yell:
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.

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. :)