Major IVA change

[WesBrooks]

Here's my letter. Alas with two cock ups which I'll post next!

Dear Robert Lloyd­Smith

Road Vehicles: Improving air quality and safety

I am writing to raise questions about the draft report that proposes changes to the emissions testing for IVA and submit a formal objection to the neglect these proposals appear to show to the kit car industry in comparison to mult­stage build based SMEs and vintage/classic rebuilds.

The report proposes an exemption for multi­stage build SMEs acknowledging the cost implications of these changes with receipts proving vehicle purchase before the implementation date. There is however no similar exemption for kit car builders whose projects are typically on far longer time scales and on tighter budgets.

The kit car industry has been a development ground for many well known originally British manufacturers who started off as kit car manufacturers such as TVR, Lotus, and Ginetta. Without significant safe guarding the industry is likely to suffer significantly, directly effecting a large number of supporting SMEs over the country and the death of the industry would have negligible difference to total UK emissions.

In direct relation to the text of the document it does not clearly address the four different routes to vehicle registration for the builders:

1. All parts new, heading for a new registration. This does allow for a number of major components to be re­used if they are fully refurbished.
2. If enough parts are re­used from the original vehicle then an age related registration is granted.
3. If too few of the parts come from a single donor then a Q plate is issued.

I believe the MOT testing to be related to the age of the registration plate number (when there is not a specific entry in the MOT guide book) whereas new MOT regulations relating to emissions do not tend to be retrospectively applied to a generation of vehicles to the point where they’d be forced off the road. So current MOT standards could be interpreted as the MOT tests that the donor vehicle would have been subjected to if still on the road.

The proposal seems to focus on the use of older engines (perhaps targeting carburettor and / or pre catalytic converter) but is ambiguous to what is actually meant by “date of registration” in relation to age related registrations.

In addition, “We are proposing that for kit cars, compliance with the MOT emissions standards current at the date of registration will be required” leaves amateur builders in an impossible situation where we are needing to double guess what the government is going to do over the period of time it would take to go from design to IVA test. This proposal itself demonstrated the short time scale between proposals being released to the general public and the proposals being implemented. Few kit car builds fit within a year!

It does appear that the kit car industry is being unfairly targeted here in comparison to the vintage rebuild or multi­stage build industries. The comparatively small number of vehicles within this market would suggest that directly targeting this section is not going to result in an insignificant change in the total UK emissions.

While I personally believe that the days for carburettors on new builds has past and kit car builders should consider moving over to more modern EFI engines, forcing ambiguous changes on us like this and in such as short time frame without offering similar concessions as offered to other sub­ sections is wholly inappropriate.

Perhaps vehicle excise duty is a far fairer way to tackle this issue?

 

[WesBrooks]

Four routes mentioned. I was going to discuss the use the same registration route if you bypassed the IVA by keeping the same chassis, but scrubbed around it as since it doesn't need an IVA I thought it would confuse matters. Alas forgot to change four to three!

Cock up #2. Following sentence should have been significant rather than insignificant:
The comparatively small number of vehicles within this market would suggest that directly targeting this section is not going to result in an insignificant change in the total UK emissions.

Any how, not posting here for a grammatical review, merely sharing what I've sent in. Writing letters like this aren't easy when you've a ten month old intent on slapping your keyboard!

 

[GW8IZR]

So I have now received a reply from my AM and an explanation of why he didn't react to my first mail, Its quite a thoughtful and interesting response and I need to read it a few times and reply to him before commenting here. A fair bit of it revolves around appropriate representation for none devolved issues which are outwith the scope of this discussion.

He has passed on my concerns to the relevant people within the Welsh assy and has asked if anyone else has raised the issue. In particular did the Assy have input to the consultation or are we just to take the fallout!

A question he asked is along the lines of 'have the representing body of the kit car and vehicle modifiers formally responded and if so what was the response.

First - I don't know if there is a recognised representing body?

Second - If there was such a response, does anyone know if it was in the public domain?

Finally - the more I think about it, I'm not sure the kit car manufacturers are on the same wavelength as those of us that individually build and modify cars to our own design, after all what would they gain from users wanting too much variety from the norm? far better if everyone just builds Caterham spec 1, 2 or 3 and pays accordingly.Especially if they offer to supply an engine that meets the emission requirements .

 

In my letter I did add a couple of points one targetting rural (farm vehicles) where the changes might suddenly make what is a 'reuse recycled' approach unviable and also the point that most modified and kit cars are not daily drivers with limited use and as such their impact on the environment is negligible compared to a business vehicle.

So thats where I'm up to.

 

 

[supaimpy]

Biggest hit I can see is make a chassis mod or other mods that take you below 8pts so that you need an IVA , then even if your engine is the original , you are very unlikely to meet the emissions as a new vehicle, so bobtail = chassis mods =IVA , std engine from say 1983 and unlikely to pass new vehicle standards ,

Kit Cars- not sure there is a national body , NRSA - will cover Hot rodders concerns and I guess realistically they are the closest group to any LR 4 x 4 modifier, Classic Car's will be the domain of FBHVC .

[Snagger]

I can see why the authorities would want new kit cars or new projects of modified vehicles, which are for all intents and purposed new build vehicles using second hand parts ,to be compliant.  The problem is that there are two unfair applications of the approach - the amateur builder who has already embarked on a project that will fall foul because of the time taken, like Mike, and the older vehicles which are modified over years of use and are in no way new build and more "Trigger's broom" affairs where a lot of the VIN scoring points have already been lost and any further mods will push them into IVA territory and this new scheme.  I'm sure quite a lot of us on this forum are close to that position, where a single further mod to make the vehicle easier, safer or more efficient (altruistic mods, not performance, in other words) would result in these punitive measures.

 

Paul, your observations about the kit car industry are very interesting, and could be right on the money - it could indeed be an opportunity to streamline their production because of more limited chassis variations (due to limitations on the choice of engines), and a revenue stream supplying compliant engines.  Easy for them, and not to big a deal for new project starters if they can still find sufficiently high performance engines that fit the vehicle.

[WesBrooks]

Classic car owners have it easy as they aren't effected unless they are doing significant mods.

As hinted to in my letter if enough points to keep old reg or age related then testing should be the same as a vehicle of the same reg.

I think Q plates and new reg kits are going to find it difficult to avoid tighter testing and old engine loop hole is likely to be closed.

[GW8IZR]

2 hours ago, WesBrooks said:

As hinted to in my letter if enough points to keep old reg or age related then testing should be the same as a vehicle of the same reg.

I think Q plates and new reg kits are going to find it difficult to avoid tighter testing and old engine loop hole is likely to be closed.

 

3 hours ago, Snagger said:

the older vehicles which are modified over years of use and are in no way new build and more "Trigger's broom" affairs where a lot of the VIN scoring points have already been lost and any further mods will push them into IVA territory and this new scheme.  I'm sure quite a lot of us on this forum are close to that position, where a single further mod to make the vehicle easier, safer or more efficient (altruistic mods, not performance, in other words) would result in these punitive measures.

 

Exactly this! I'm right on the edge with my 90, one more change and the many thousands of pounds spent and hundreds of hours rebuilding will be gone.

(caveat) Unless there was an amnesty for existing vehicles that meet the criteria today ( not going to happen ) or a suitable engine found and conversion developed to allow an IVA pass.

Even if a suitable engine was identified I wonder if I have the heart to 'start again' only to be caught with some other new rule further down the line - on a car that pollutes the environment for circa 600 miles a year.

[GW8IZR]

This was part of the reply I sent clarifying my two biggest concerns, not sure if its clear enough as part of the problem is 'we' kind of understand the impact so we try to explain it from our narrow mind set.

(quote)

If the changes from the consultation are implemented two groups of enthusiasts will be caught out unfairly.

Existing projects coming to fruition this year:

Those that started a project that has taken several years to complete will have designed the vehicle based on current rules. At this stage significant financial investment and build hours  will have been spent. The choice of engine is critical to the design. Typically an engine is chosen based on fit, power and economy. The engine very often comes from an older car which is recycled. If the project comes to fruition later this year that older engine will no longer meet the new requirements and as such is lost. Remember even VW fail to meet the current requirements without being very creative and they have far greater resources available to them than a home 'kit builder'

Existing cars that meet the requirements today but may need future modification:

A car which is perfectly legal today as it meets the DVSA 'points' system to retain its identity. Any future modification however small may mean the vehicle loses its identity which means it should go for an IVA test. If that test changes as per the implementation of the consultation the vehicle would need to meet the current emissions standard.

Even with the standard engine that the manufacturer previously fitted that would be impossible.

Its easiest to give an example, take a Land Rover which was made in 1985 fitted with a diesel (or petrol) engine - the owner gets a little older and decides to make changes to make his older car easer to use and keep on the road. Maybe fitting power steering or an automatic gearbox. Due to previous changes and alterations the changes push it over the edge of losing its identity and forces IVA. Thats fine those are the rules. As the modified car is built to the same condition and specification of a vehicle that LR themselves made and sold so it should pass easily - apart now from engine emissions which is impossible to achieve.  That car becomes scrap yet an unmodified vehicle which hasn't been restored can continue to be used ad infinitum.

Existing IVA is a challenge to pass and ensures the vehicle submitted is in perfect condition, it ensures that emissions are as reasonable as possible given the state of the art when the vehicle was built - those of us that modify and alter cars respect that and accept those rules. The proposed rule changes make it impossible to comply.

An unrestored vehicle is far less likely to be kept as well maintained and in as safe a condition as for example my LR which does 600 miles a year and is kept inside in case it rains!

[Snagger]

The stupid thing is that they're pushing for electrification of cars as if that doesn't have environmental issues (digging up the roads to lay all the cabling for recharging points is going to cause traffic jams and more emissions, for a start!).  The secondary effect of this legislation will be that more builders and modifiers hide their alterations, which will open a legal and insurance can of worms.  They'd be fuelling an underground movement of illegal ownership and operation.

[WesBrooks]

Yeah. My bighest problem with the regulations around current crop of electric cars is there is no incentive to get something with limited power, or better efficiency. Efficiency is just as much an issue with electric as IC, it's just the emissions are remote.

I'd love to do an electric project but need to get my head around the thermal management issues for the battery pack. Heat loss from the battery pack being another efficiency issue as well as safety.

[Daan]

6 hours ago, Snagger said:

The secondary effect of this legislation will be that more builders and modifiers hide their alterations, which will open a legal and insurance can of worms.  They'd be fuelling an underground movement of illegal ownership and operation.

While this is true, a good 90 percent does this already. So no change there.

[GW8IZR]

a locked door only stops an honest person.

[honitonhobbit]

On 25/02/2018 at 9:02 AM, MECCANO said:

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.

Foley have been exempt form legaiity for years

[Gazzar]

I have read a lot of this thread. I think I understand.

 

What needs doing?  MP letter writing? 

 

Happy to help, but the easier it is for me to do, the more time I can spend welding.

G.

[Snagger]

You can write to your MP, but the consultation survey is already closed.

[Snagger]

Got this reply today:

"Dear Mr Boylen,

 Further to our previous correspondence I now enclose a copy of the reply I have received from the Transport Minister, Jo Johnson MP.

 Your additional comments will be considered by officials as part of the consultation process and we now must wait for the outcome.

 Thank you again for your contact.

 Kind regards..."

 

and the enclosed reply from Jo Johnson (transcribed from the headed email PDF because I didn't want my address disclosed):

"Dear Alistair,

Thank you for your letter of 28 February 2018, enclosing correspondence from your constituent, Nick Boylen of ...., about the Government's consultation on road vehicles: improving air quality and safety.

 

I can confirm that the Department has received Mr Boylen's comments ans his response will be considered as part of the consultation.

The results of the consultation will be published alongside the consultation documents at:

https://www.gov.uk/government/consultations/road-vehicles-improving-air-quality-and-safety

(signed) Jo Johnson"

 

So, the system works, and hopefully many others have received similar responses that will get a sympathetic outcome.

[GW8IZR]

So coincidentally my AM replied yesterday confirming that both of my 'letters' had been received and passed on appropriately, to quote part of the reply ' I will ensure that my team pass on any relevant information to you following our enquiries to Welsh Government & my Westminster colleagues.'

As its not devolved legislation  I can't ask for more than that and it does confirm that the process of representation works.

Now whether there is any influence on the outcome remains to be seen, where departments wave the 'environmental' flag it always feels a bit like peeing into a gale.

 

[Snagger]

Anyone heard any informed rumours about which way this is heading, yet?

 

[Bowie69]

Nothing here....

[FridgeFreezer]

I wouldn't be surprised if nothing happens at all until after the dust has settled from Brexit.

[GW8IZR]

7 hours ago, FridgeFreezer said:

I wouldn't be surprised if nothing happens at all until after the dust has settled from Brexit.

 

Or any other political dust that might be happening ........

[LiftedDisco]

Whilst if you follow the link to the consultation, it tells you that responses to the consultation are still being considered...

 

Interestingly, the IVA requirements were in ‘draft’ form until 9th April with a new version then available for download from 10th April.

 

I would (cynically) suggest that the plans were already well developed and the post-10th April IVA regs are now those in force until the next upheaval...

[gav-]

I have read through the new Iva manual. 

Anyone know if a 3.5l v8 with mega squirt would pass?? 

[FridgeFreezer]

On 21/04/2018 at 12:45 PM, gav- said:

Anyone know if a 3.5l v8 with mega squirt would pass?? 

I'd guess it depends how you tune it, in theory you should be able to get the emissions down as low as can be, although it they require a cat you'll never get through without one as the cat knocks some of the numbers down massively.

[Snagger]

Good news, everyone - we won!  IVA vehicles will be exempted from the changes.  They agreed that the environmental benefits of including IVA vehicles would be immeasurably small but the damage to many businesses devastating and the economy significant.