Major IVA change

[supaimpy]

http://www.nsra.org.uk/2018/02/action-required-dft-improving-air-quality-and-safety-consultation/

sums it all up

[mad_pete]

“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.”  That’s the section.

[Snagger]

On 23/02/2018 at 4:23 AM, mad_pete said:

Just latest mot standards. That’s not that hard to pass is it ? Must have some mot savvy people here. What’s the latest rules on emissions to pass mot ?

You're missing the point.  At the moment, a kit car or amateur build car has to pass the MoT standard appropriate to the age of the engine.  Under this proposal, new kit or amateur built cars would have to pass Eu6 MoT standards.  Now, that's tricky for us but doesn't sound devastating if you plan a new build using a Eu6 engine and exhaust, but if you have an older vehicle with a few mods that doesn't currently need IVA, but that later needs another mod for some reason (like PAS or auto box because you're to old or disabled to continue with the original) and you car now needs IVA, you'll be screwed.

[Snagger]

Pete, look at 4.11:

 

Kit cars

4.10 Kit cars and reconstructed classic 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.

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.

4.12 Reconstructed (restored) classic cars undergoing IVA will not be required to meet the latest MOT standards, as long as the appearance of the vehicle is broadly unchanged and the engine is of the same capacity as that supplied with the vehicle when it was new.

4.13 When new vehicles were first required to be fitted with catalytic converters around 1992 (Euro 1 emissions standard), kit car makers typically used older engines which were not fitted with catalytic converters, hence the justification for age-appropriate testing of emissions based on date of engine manufacture or first use. The majority of the fleet is now vehicles up to 25 years old whose engines are fitted with catalytic converters, providing plenty of choice to the kit car builder.

[Snagger]

Miketomcat, you're OK - look at section 4.7.  I'm hoping that it also covers cars already in service that are modified beyond the DVLA points restriction and become subject to IVA (allaying my concerns a couple of posts above)

Multi-stage build

4.7 Where a vehicle converter is in possession of an incomplete vehicle or chassis built prior to 1 September 2018 (or 1 July 2018 in the case of IVA) and issued by the manufacturer with an Emissions approval and an Incomplete or Complete Certificate of Conformity, the converter will be permitted to carry out a conversion or addition of bodywork after that date without having to upgrade the engine to WLTP, as this would be prohibitively expensive, as long as he maintains the existing emissions control system in good working order.

4.8 More generally, we are proposing that where a converter modifies a massproduced vehicle which complies with WLTP, he will in principle be required to retain WLTP compliance by maintaining the emissions control system in good working order. Increases in unladen weight due to additional bodywork, for example, and modifications to the frontal area of a vehicle or changes to aerodynamics will be permitted.

4.9 We are also proposing that where a converter changes a vehicle category, for example a van converted to a minibus, the compliance required will be that applicable to the base vehicle on the date of its completion and prior to the conversion, because to require anything else would be disproportionately costly for the SMEs involved in such conversions.

[mad_pete]

51 minutes ago, Snagger said:

You're missing the point.  At the moment, a kit car or amateur build car has to pass the MoT standard appropriate to the age of the engine.  Under this proposal, new kit or amateur built cars would have to pass Eu6 MoT standards.  Now, that's tricky for us but doesn't sound devastating if you plan a new build using a Eu6 engine and exhaust, but if you have an older vehicle with a few mods that doesn't currently need IVA, but that later needs another mod for some reason (like PAS or auto box because you're to old or disabled to continue with the original) and you car now needs IVA, you'll be screwed.

I’m looking to clarify the point rather than missing it. The text says MOT it does not mention EU6. I don’t think EU6 is the same as the MOT current pass standard.  And that’s my question is it the same? Sure it’s a higher than older car standard but a bet you a cup of tea the tests aren’t the same. I reckon a 10 year old engine in good condition and cats will pass current MOT emissions test and I’m asking people who know the details on the standards to confirm. 

[Snagger]

Quote

 

If you take the chapter as a whole, it's pretty clear that the proposal means that all new built cars, including IVA, will have to be Eu6 compliant, and the text specifically talks about removing the exemption of having an engine age related standard.  MoT emissions standards are variable, dependant on age, so this makes the proposal pretty clear, Pete.

[Daan]

It may pass an MOT, but that Is irrelevant, as it won't pass an IVA. Thing is that a lot of people try to wiggle out of IVA as they think it is too much hassle. These rules are only going to increase this. It would mean you need to buy a new LS engine or a Ford TDCI with all the after treatment equipment if you want your build to pass IVA. So the good old days of buying bits for cheap to build your home grown special would change a bit. You still can modify existing cars, so although it will not be ideal, it also is not the end of our hobby I think.

 

Daan

[mad_pete]

The Mot is the only standard I see in that section. I do not see EU6 anywhere so please paste the section that has it. 

Actually not to worry. My reading is it’s current MOT pass only, others see it as EU6 required. I think it is poor the document is not clear on this point. I’m fine to leave it there. 

[Bowie69]

Yep, Pete, I know I read it, but now can't find it again!

As you say, very poorly worded and needs much greater clarification, either way it will affect us negatively.

[miketomcat]

2 hours ago, Snagger said:

Miketomcat, you're OK - look at section 4.7.  I'm hoping that it also covers cars already in service that are modified beyond the DVLA points restriction and become subject to IVA (allaying my concerns a couple of posts above)

Multi-stage build

4.7 Where a vehicle converter is in possession of an incomplete vehicle or chassis built prior to 1 September 2018 (or 1 July 2018 in the case of IVA) and issued by the manufacturer with an Emissions approval and an Incomplete or Complete Certificate of Conformity, the converter will be permitted to carry out a conversion or addition of bodywork after that date without having to upgrade the engine to WLTP, as this would be prohibitively expensive, as long as he maintains the existing emissions control system in good working order.

4.8 More generally, we are proposing that where a converter modifies a massproduced vehicle which complies with WLTP, he will in principle be required to retain WLTP compliance by maintaining the emissions control system in good working order. Increases in unladen weight due to additional bodywork, for example, and modifications to the frontal area of a vehicle or changes to aerodynamics will be permitted.

4.9 We are also proposing that where a converter changes a vehicle category, for example a van converted to a minibus, the compliance required will be that applicable to the base vehicle on the date of its completion and prior to the conversion, because to require anything else would be disproportionately costly for the SMEs involved in such conversions.

Nope still screwed as no kit car has a certificate of conformity that' why they need an IVA.

Mike

[Snagger]

I understood that to be that the donor vehicle has conformity, so the certificate would be LR and already dealt with by VCA.

 

As always, these legal documents are full of traps and vague terms.

[miketomcat]

My chassis isn't land rover though it's foers.

Mike

[Bowie69]

Twas what I thought, hence my comment above about it being essentially a new vehicle.

[MECCANO]

I presume this applies to any chassis modifications. For example, foley doing a 3rd axle extension, even if the rest of the vehicle is original.

[miketomcat]

My understanding is it used to be altering the wheel base was a fail. But brackets, out riggers even front and back mods weren't a problem. However with IVA this was changed to any modifications to the chassis became a fail. You can add by bolting or welding to the chassis from what I can make out and repairs are fine but if you "cut" the chassis to mod it then that's a fail.

Mike

[Daan]

I wrote this letter to my local MP (it is largely copied from the link in my first post):

 

Dear Madam,
I am writing to you to bring your attention to the Governments “Road Vehicles Improving Air quality and Safety’ consultation.


https://www.gov.uk/government/consul...ity-and-safety


I am very concerned about the section containing Kit Cars, Page 16, 4.10 - 4.13. In this section it is proposed that all cars going through Individual Vehicle Approval (IVA) would have to comply with current new car emission laws. IVA is a “Super MOT” that a kit or modified car has to pass to be registered or re-registered. Some kit cars and vehicles such as conversions for the disabled are based on new cars, so compliance would not be a problem, but modified classics would never pass these emission laws.


The technology in a modern engine with computers controlling emissions is out of reach of the average person building a modified classic or kit car, even the manufacturers have been caught cheating. At the moment emissions checks carried out at the IVA test are based on the current MOT limits and are determined by the age of the engine and not the car. This is a fair way to determine compliance and does not need to change.


There are people all over the country Being employed in the business of building and modifying cars. A considerable amount of money is invested in these projects and many people earn a living in this industry. If these proposals are implemented it will kill a multi million pound industry dead, part suppliers, craftsmen, magazines, car shows and charity donations to name a few affected areas.


I feel with a relatively short consultation time of 2nd February - 2nd March 2018 and an implication date in July this year, that this is not a consultation but a notice of intent. There is no time for due process and no time to consult, only to take initial opinions.
There is obviously a lack of understanding by consultation authors on what type of vehicle uses IVA and of the DVLA rules for obtaining original vehicle identity.


The recent EU Road Worthiness Testing Directive due to be implemented this May, directs “substantially changed” vehicles towards IVA. If this proposal goes through, IVA will not be an option for these vehicles.


The “Kit Car” section of this proposal needs to be dropped as it is totally unusable.


I hope I have given you some insight into the situation and I urge you to take this up with the relevant Minister as soon as possible, or a whole way of life for many people will be lost forever.


Yours faithfully,

 

Daan Schreuders

 

I think if everyone on here write a similar letter to their local MP, we might get some leverage against these proposals.

 

Daan

 

 

[Bowie69]

Daan, thank you, I have blatantly copied and modded for my own use and sent it off to my local MP.

Ta again,

 

 

Peter.

[gav-]

I just wondered is there any way of finding out the progress of this change?? 

As in if it will be approved or not? 

I have been putting off getting my vehicle iva’d For years now - not been a priority and now I am thinking I need to rush to get it tested? Would like to find out if it’s likely??

 

[GW8IZR]

has anyone had any response from their elected member? I wrote to my AM two weeks ago and have not even had a response.

The bad weather has probably taken priority but that hasn't changed the end date.

Paul

[Snagger]

 I got the following responses:

Thank you for contacting me about the Department for Transport's consultation on improving air quality and safety.  I note the concerns you raise and I hope that you have responded to the consultation.
 
Given the recent VW dieselgate scandal, and the strong imperative to improve air quality, I understand Ministers are investigating what more can be done. As a part of this, the consultation seeks views on new penalties for vehicle manufacturers supplying vehicles fitted with defeat devices and proposals to implement various safety and environmental rules.
 
I can assure you that I want to see the UK retain a thriving car industry. This means supporting both the construction and development of new models as well as the restoration of classic cars and the building of new kit cars.
 
As the consultation is still ongoing, I would encourage you to respond directly to it to make your views known.  As I am sure you can appreciate, I am not able to pre-empt the results of the consultation but it is important that informed views such as your own are considered by the Government as part of its plans to improve air quality.
 
Thank you again for taking the time to contact me.

 

Kind regards

And, after informing him that I had completed the survey and clarified a few points:

 

Thank you for your further email.  I appreciate your further points and have taken them up directly with the Department of Transport.

 

As soon as I receive a reply from the Transport Minister I will write to you again.

 

Kind regards

[Bowie69]

Great!

No response from mine yet though.

[GW8IZR]

That is a fair response - I'll advise if my AM answers my latest 'prod'

[ejparrott]

Waste of time addressing the Rugby MP, he's spineless, he'll only do what head office tells him to do, never challenges anything

[WesBrooks]

Multistage builds are commercial things like coach building or motor caravans. Doesn't apply to amateurs, although just incase it does I have sent a letter to the dvla ask for permission to transfer a vin or get a new one for my custom D1 chassis as a vague time stamp on top of receipt of the body.

Modern car emissions are not tested to the same level as needed for a class of engine to pass one of the euro standards. This is demonstrated by the imminent changes to the MOT that tighten the emissions testing for recent cars but doesn't exceed or match the performance required to achieve a euro level of performance.

I think the main loop hole they are trying to close is building an otherwise new kit car and being free to drop in a pre 94 lump to avoid the need for cat and potentially use carbs rathet than EFI.

The proposals are vague, and probably purposely so. If they had successfully  got a regulation change approved with vague wording it leaves them free to tighten it later!

What is not clear to me is date of registration. When modifying a car you keep the current registration if you reuse enough of the donor and don't mod the chassis. These projects are not effected by this change. You do however have the option to target an age related plate, new registration, or Q plate. I'd argue that the age related should be tested to the same standards as the donor. Q plate and new registration for kits or significantly modified vehicles are at real risk here even with my proposed  interpretation.

I have also raised the point in my objection letter that the changes will have an insignificant effect to the total uk emissions. I bet total annual number of amateur BIVA'ed vehicles compared to new registrations of type apprived vehicles is probably single digit or fractional percentage levels, and annual mileage in these is also likely to be less as these are often second vehicles.

 

Edited March 5, 2018 by WesBrooks