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jeff oakley

Latest IVA emissions proposal

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I received the same response yesterday but today had another e mail with slightly different response today which is slightly encouraging 

Thank you for your comments. I have been asked to respond.

 

We will be considering all responses received. The proposal on kit cars has attracted a very high volume of comments so we will give careful consideration whether to delay this element of the proposal, or remove it altogether.

 

Mike Lowe  | Regulation, International Vehicle Standards, Department for Transport
1/29 - 1/33 GMH | 

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One of the members on the UK Cobra Club Forums post copied as below

Hi All

I emailed the Department of Transport to try and get some indication of when the proposed legislation with regard to kit cars would come into force if it was passed. The response I received is below:

"The proposal was to bring this into force at the same time as the rest of the regulation, likely to be 1 September 2018. However due to the volumes of comments received, many of which advocate a postponement of say 2 years, we will need to re-consider this. In fact the whole element of the proposal which affects kit cars is likely to come under scrutiny given the vast volumes of negative comment, so it may be removed altogether."

It would appear from this comment that they are taking notice of all the responses that have been made. Things may be looking up.
 

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Let's await official confirmation before celebrating this...

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Sounds like the rallying cry has mobilised a lot of people, that's great, hopefully good news on its way.

I started drafting a response a couple of weeks ago, it is quite long but I work in a related area so I wanted to utilise my experience with these matters and also incorporate lots of the good points people here have made... I have been a bit tied up with work but just got it finished and sent it in, there's still one more week to go. Below if anyone wants to use anything from it:

FAO Consultation Co-ordinator

I am writing with reference to the recent DfT paper titled "Road Vehicles - Improving Air Quality and Safety" published for comment in February 2018. In particular, as a kit car owner, I wish to comment on the proposals for kit cars found in Section 4.

I recognise DfT's mission to improve air quality and limit pollutant & CO2 emissions. However the proposals for kit cars in 4.10 to 4.13 will do next to nothing to achieve these policy objectives, whilst simultaneously damaging individuals and businesses.

As noted in 4.10, kit cars are not subject to the same emissions requirements as production vehicles. This is for a number of reasons:

1. Compliance with NEDC or WLTP typically requires an extensive test programme involving more than one test vehicle which have accumulated several thousand miles, which is clearly not feasible for an IVA

2. Kit cars make up a miniscule proportion of total vehicle registrations in the UK each year

3. As typically niche, replica or sports cars, the average annual mileage of kit cars is extremely low compared to regular vehicles, evidenced by the fact that most kit cars are insured on limited mileage policies and in turn most kit car owners also own another vehicle used for commuting or regular journeys

4. Of the already small number of annual kit car registrations, it is a similarly small subset of kits which use older engines, for example pre 1992, typically for replicas of classic vehicles. 

Considering the above, the impact of kit cars, including those with older engines, on fleet emissions and air quality is negligible and this has to be the basis for any discussion about regulation of them as an industry.

The proposed change in 4.11 to remove age-based testing and instead impose current emissions limits on IVA tests will completely eliminate replica classic vehicles as an industry, with no benefit to the policy objective. Jobs and small businesses will likely be lost as a direct result of this change. 

The proposal paper suggests in 4.13 that enough time has elapsed since the introduction of catalytic converters to allow sufficient choice of engines to use for such projects. However, this completely defeats the point of a classic replica and also ignores the fact that it is often not possible to simply swap a newer engine into a classic chassis. For example, with the shift from rockers to overhead cams, engines are now much taller and in many cases simply do not fit inside smaller classic vehicles.

Additionally while the law allows classic cars to be driven on public roads, this change would prohibit the same engine being used in another chassis, even though it would produce the same emissions.

The provisions for reconstruction and restoration in 4.12 are also subjective and poorly defined, and there have been some high profile cases of similar criteria being used unfairly to remove "historic" status from classic cars which have had some necessary number of parts replaced to keep them running.

Even without the above considerations, the lead time for the proposed changes is far too short as many owners of classic or replica kits will be partway through a build. Due to the proposed implementation dates, these builders will be unable to test or register their vehicle in 6 months' time. Large volume manufacturers have several years' notice of significant regulatory changes as well as distinct new type and all registration deadlines, plus end of series derogations, to ensure stock built prior to the introduction of the new requirements can be registered, as is recognised in your proposal paper in Section 6. 

I hope you will consider the true impact of these proposed changes on the kit car industry and recognise the negligible impact that they would have on the objective of the proposal paper.

I look forward to your response.

Yours sincerely,

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If they have decided to reconsider that is a great thing. What still grates with me is that they deliberately slipped this out in the most low key way to deliberately avoid the sort of level of objections it has obviously raised. 

Had there not been people on the ball who spotted this, it would have slipped through. At the moment I would bet they will still plough on but might concede a two or three year period of grace to get them of the hook with cars in the building phase. Hopefully I am wrong but the environmental lobby is very well organised, very well funded and as a result they get the ear of governments at the EU level easily.

I have been involved with projects involving the EU to secure open access to allow independent garages to continue working on all vehicles. The OE manufacturers have full time lobbyists and have thrown millions at getting their way, in comparison the whole aftermarket of the EU could get just one part time. That is what we are up against when things like this happen, those who have used the VW case as a stick to beat the EU have made a lot of ground with demanding ever lower levels of emissions.

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