Just sent this:
Dear Sir or Madam,
I write to express my concerns about the proposed measures for kit cars contained in the current DfT consultation ‘Road vehicles; Improving air quality and safety’.
My main concern is that the proposals could damage and possibly severely damage the kit car industry. The consequences of this could be job losses and small business closures; not only affecting kit car manufacturers but also the small industry that serves to provide materials and services to kit car builders and to assist the enthusiasts in this sector in keeping their niche vehicles on the road. The number of vehicles in this sector is very small, they are predominantly very lightweight and, in general, they cover very low mileages per annum (on limited mileage specialist insurance policies). A large percentage of them are already built to meet modern emission standards. It therefore seems very heavy handed to risk such potentially damaging effects on this very small sector when it will have infinitesimal effect on the overall aims of the legislation.
There is an even larger risk to the classic kit car and replicas market. This niche industry is a small fraction of the already small kit car market and attempts to manufacture replica vehicles that are as closely as possible to the original in both form and design. This obviously includes (and needs to continue to include) the use of period engines; both for aesthetic reasons and also because many modern engines and environmental aids just would not fit.
Another concern is the proposed time scales of this legislation. Some kit car builds are complex and can take up to three to five years. There should therefore be an exceptional transition period of at least 36 months for this sector.
Once again, the damage to this small industry which provides to a niche, but thriving enthusiasts sector is likely to be totally incommensurate with the infinitesimal effect such measures will have on the overall aims of the legislation. A blanket strategy is simply not appropriate here. I would therefore respectfully suggest that the kit car proposals in section 4 of the consultation document should be seriously reconsidered. At the very least, a Regulatory Impact Assessment should be carried out before any changes are made to kit car legislation. This should seek to ensure that any such changes and consequent commercial damage are commensurate with the (detailed) environmental benefits.
Finally, I would appreciate your acknowledgement that my response has been received and will be duly considered.