BIVA Builds - Engine Rules

Paul L · #1 7th February 2018, 06:16

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.

peterux · #2 7th February 2018, 07:48

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....

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.

softfeet · #3 7th February 2018, 09:02

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.

peterux · #4 7th February 2018, 10:11

Quote:

Originally Posted by softfeet

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.

peterux · #5 7th February 2018, 10:18

Similar lively debate on Pistonheads kitcar forum....

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

NeilF355 · #6 7th February 2018, 10:44

Quote:

Originally Posted by peterux

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!).

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???????

peterux · #7 7th February 2018, 11:32

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.

Phaeton · #8 8th February 2018, 13:09

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

Mitchelkitman · #9 8th February 2018, 13:20

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?

softfeet · #10 8th February 2018, 15:45

There is some very helpful information on this subject here:

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

peterux · #11 8th February 2018, 18:33

Quote:

Originally Posted by softfeet

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.

peterux · #12 8th February 2018, 19:28

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!!

Mister Towed · #13 22nd February 2018, 08:10

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.

NeilF355 · #14 22nd February 2018, 09:02

Quote:

Originally Posted by Mister Towed

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".