Bobtailing a Discovery - What requires an SVA?

[Tetsu0san]

Evening all.

My understanding on doing a bobtail conversion is that if you changed the chassis in any way it would require an SVA test. So basically if you were going chop the rear off the back of the chassis you would need to have an SVA test done on your vehicle.

Anyway, I was browsing the fleabay tonight and a link took me to a site who will do the conversions for you and one of their pages talks about the legality of the conversion. On the page http://www.bobtail4x...on-legislation/ it states:

Conversion Legislation

Below is our understanding of the legislative issues if the vehicle is subject to a conversion and to also be used for road use following conversion.

Because the vehicles have not had the following changes there is no requirement for a SVA (Single Vehicle Approval by VOSA / DVLA).

• Wheel base not altered
  
• Not changed any suspension (leaf to spring)
  
• Not changed axles
  
• Not changed transmission
  
• Not changed engine
  
• Not changed the brakes or the power of the vehicle
  
• Original vehicles identity is intact
  

VOSA seem fairly clear with there opinions as long as no suspension (leaf to spring) or axle or braking mounts have changed then changes are classed as cosmetic.

I have to draw your attention to the 'our understanding' bit. Surely that sounds like a little bit of a grey area with this conversion. Don't get me wrong, I am not having any sort of go at these people at all, I just wanted to know if my understanding of what requires an SVA is right or wrong. I am just about to purchase another Discovery project and I was thinking of bobtailing it, so I just wanted some views.

[Steve Hiatt]

I read this site a few weeks ago.

It's in black & white on the DVLA website, alter the chassis and you need an IVA.

However, I've read all the legislation I can find and can not find any specific Law making this the case. IMHO you could reasonably argue that bobtailing a LR does not change it's identity or radically alter the vehicle and therefore it shouldn't need an IVA.

I hope someone who is planning or has a bobtail pushes the DVLA to quote the Law they are applying in their guidelines.

[Bowie69]

It is definitely required, will dig up the legislation tomorrow for you. That Ebay add is talking a crock of....

[scube]

My understanding was as long as you do not alter the wheel base you can get away with it.

chopping a bit of the front or rear is okay.

Will be interesting to see what Bowie69 comes up with

[Hybrid_From_Hell]

Nope

Chopping the chassis overhang front and or rear - is an immeadiate SVA / IVA requirement

the end

nige

[Bowie69]

Here's a link:

http://www.direct.go...hicle/DG_191068

The relevant bit is:

Registering a radically altered vehicle

Registration of radically altered vehicles includes vehicles, which are altered from their original specification, but are not kit conversions. Find out what you need to register your vehicle and how you can keep the original registration number.

Getting a vehicle registration number

When issuing a registration number for a radically altered vehicle the Driver and Vehicle licensing Agency (DVLA) use a points system.

To keep the original registration number your vehicle must have eight or more points. This must include the original or new and unmodified chassis, monocoque bodyshell or frame.

Your vehicle will need Individual Vehicle Approval (IVA), Single Vehicle Approval (SVA) or Motorcycle Single Vehicle Approval (MSVA) if:

it has less than eight points

it has a second hand or altered chassis, monocoque bodyshell or frame

there is evidence that two vehicles have been welded together to form one (eg ‘cut and shut’)

If your vehicle passes you will be able to register your vehicle and will be given a ‘Q’ registration number.

That is pretty clear cut if you ask me.

BUT, don't be scared about it, it's a bit like an extended MOT test, others have been through this in the forum, and I will be soon, the IVA Inspection Manual is your friend -downloadable from Business Link website.

[Hybrid_From_Hell]

http://webarchive.nationalarchives.gov.uk/+/www.direct.gov.uk/en/Motoring/BuyingAndSellingAVehicle/RegisteringAVehicle/DG_4022486

If you are rebuilding or radically altering a vehicle, or building a vehicle from a kit, it'll need to meet certain criteria before the vehicle is registered. The Driver and Vehicle Licensing Agency (DVLA) local office will assign the original or an appropriate registration mark on the evidence provided.

http://webarchive.nationalarchives.gov.uk/+/www.direct.gov.uk/en/Motoring/BuyingAndSellingAVehicle/RegisteringAVehicle/DG_10014199

The vehicle must score eight or more points to retain the original registration mark. If less than eight points are scored or a second-hand or modified chassis or altered monocoque bodyshell is used an Individual Vehicle Approval (IVA), enhanced single vehicle approval (ESVA), single vehicle approval (SVA) or motorcycle single vehicle approval (MSVA) certificate will be required to register the vehicle. A 'Q' prefix registration number will be allocated.

Scoring components

The following values will be allocated to the major components used:

• chassis or body shell (body and chassis as one unit - monocoque ie direct replacement from the manufacturer) (original or new) = 5 points
  
• suspension = 2 points
  
• axles = 2 points
  
• transmission = 2 points
  
• steering assembly = 2 points
  
• engine = 1 point
  

Where there is evidence that two vehicles have been welded together to form one (ie 'cut and shut') a 'Q' mark will be allocated, IVA, ESVA, SVA or MSVA will be required.

Nige

[Bowie69]

Oh, and on 'bobtail4x4', they are quoting SVA specifications, which is VERY out of date, 3 years or so, and at that point you couldn't even re-reg a bobtail, it would have to be destroyed -search on here for the bishtail).

[Bowie69]

Oi Nige, back your box, and next time use current page links

[Chicken Drumstick]

Here's a link:

http://www.direct.go...hicle/DG_191068

The relevant bit is:

That is pretty clear cut if you ask me.

BUT, don't be scared about it, it's a bit like an extended MOT test, others have been through this in the forum, and I will be soon, the IVA Inspection Manual is your friend -downloadable from Business Link website.

Thing is though, it's not clear cut at all and guidelines don't mean it's actual legislation.

The main point of note is the title "Radically altered". There is no definition for this, personally I'd argue that an otherwise non altered Disco but bob tailed isn't that radical at all. It reality it has had less affect on vehicle ability and safety than swapping a Series III from a hard top to a full tilt.

So if it 'isn't radically altered', then none of the following conditions such as chassis welding would apply at all.

You could also argue that replacing the rear cross member on a Defender is just as 'radical' in terms of the work involved, yet as a repair this would need no inspection what so ever.

[Steve Hiatt]

With respect chaps you're not quoting legislation, you're quoting the DVLA's guidelines based on their interpretation of the law.

Try http://www.legislation.gov.uk/uksi/2002/2742/contents/made

Whilst their guidelines are clear, reams and reams of legislation cannot be boiled down to a couple of paragraphs without exception. I haven't found anywhere in the legislation or subsequent amendments that says by removing a non structural/ non essential part of the chassis is a de facto IVA.

[daveturnbull]

Didn't bishbosh on here come a little unstuck on this one? I seem to recall reading that the VOSA wouldn't let him use his very nicely built bobtail range rover as it didn't fit into any of the categories they had dreampt up.

Edit: more reading here: http://forums.lr4x4.com/index.php?showtopic=24048&view=findpost&p=255923&hl=bishtail&fromsearch=1

Edited March 2, 2012 by daveturnbull

[zardos]

What gets me is that they only talk about issuing a registration number in their guidelines, what they don't talk about in their guideline is how the original vehicle lost it's current registration. It is not as though it is normal for a car to be issued a new registration number every year.

[Bowie69]

OK, from their legislations... bear in mind this took a while to get a clear meaning from:

6.—(1) A vehicle is an amateur built vehicle if—

(a) the vehicle was—

(i) constructed or assembled or

(ii) having previously been registered under the 1994 Act, structurally modified,

for the personal use of a person ® who is a relevant individual, and

(b) the whole, or a substantial part, of the construction, assembly or modification was

carried out—

(i) by R,

(ii) by one or more relevant individuals acting on behalf, and under the direction, of R,

or

(iii) by R and one or more relevant individuals acting on behalf, and under the direction,

of R.

(2) For the purposes of this paragraph, a relevant individual in relation to a motor vehicle is an

individual who does not, at any time during the period when the construction or assembly of the

vehicle was being carried out, carry on a business in the course of which motor vehicles are

normally constructed, assembled or modified.

So we know what an amatuer built vehicle is legally defined as.

More to come...

[Bowie69]

Didn't bishbosh on here come a little unstuck on this one? I seem to recall reading that the VOSA wouldn't let him use his very nicely built bobtail range rover as it didn't fit into any of the categories they had dreampt up.

Edit: more reading here: http://forums.lr4x4....il&fromsearch=1

Yes, however that was under SVA regulations, and not IVA. Under SVA it would have needed to comply with MODERN safety standards and airbags etc.... i.e. no way to pass. IVA is less restrictive than IVA in this area.

[Deej]

If we assume that an IVA is required, there is the next question of which category of IVA the vehicle falls into. From the IVA Information Guideline document:

3.1 What are ‘Basic’ and ‘Normal’ IVA?

‘Basic’ and ‘Normal’ IVA refer to the level of inspection carried out on a vehicle and apply to the

following two vehicle categories ONLY : • Passenger cars - M1 • Light goods vehicles - N1

Both Basic and Normal IVA inspections take place at selected Testing Stations which are operated by the Vehicle and Operator Services Agency (VOSA). However, these inspections can also be conducted by VOSA examiners at ‘Privately Owned Test Facilities’ (POTFs) if certain conditions are met. A POTF is a privately owned and operated site where VOSA examiners conduct IVA testing. Please refer to Annex 4 on page 53 for a list of ‘VOSA IVA test stations and Privately Owned Test Facilities’.

In all cases, IVA (whether Basic or Normal) is only required for passenger cars and light goods vehicles less than 10 years old, which require first licensing and registration in the United Kingdom.

Basic IVA

Basic IVA is only applicable to the following classes of vehicles. Please refer to Annex 2 on page 49 for definitions of these vehicles (excluding left hand drive) :

1. Personal imports

2. Amateur built vehicles (kit cars)

3. Rebuilt vehicles

4. Very low volume production vehicles

5. Ambulances (ambulances are only ‘M’ category)

6. Motor caravans (motor caravans are only ‘M’ category)

7. Hearses (hearses are only ‘M’ category)

8. Armoured vehicles (armoured vehicles can be ‘M’ or ‘N’ categories)

9. Left hand drive vehicles

10. A vehicle manufactured using parts of a registered vehicle

Any vehicle not being one of the above classes will be subject to a ‘Normal’ IVA inspection.

Although the same items are inspected as in type approval, they are not inspected in the same way.

The examiner will, in the case of certain items, conduct an engineering assessment. This check will be in the form of either a visual inspection or a simple test on the vehicle to ensure, as far as practicable, that it complies with the regulations.

The inspection will be limited to parts of the vehicle which can be easily seen without the vehicle having to be dismantled. However, the presenter may be asked to open lockable compartments and remove engine covers, inspection/access panels, trims or carpeting. This is to allow access to items subject to inspection. In addition, as vehicles are inspected individually, the tests are not destructive or damaging to the vehicle in any way.

An Individual Approval Certificate (IAC) is issued when the examiner is satisfied that the vehicle would meet the requirements of the regulations, in the main being in relation to the design and construction of the vehicle. This is as opposed to an MoT, which is concerned about the condition of the vehicle, although with regards to IVA, a vehicle in poor condition may make it impossible to assess whether some construction requirements are met.

Where an item is found to be defective to the extent that it presents a potential danger when the vehicle is used, this may also result in the refusal to issue an Individual Approval Certificate.

Normal IVA

Normal IVA applies to M1 passenger cars and N1 light goods vehicles ONLY that are not defined by one of the categories listed subject to Basic IVA. This includes mass produced vehicles that are imported on a commercial basis. These vehicles will have to meet the Basic IVA requirements as well

as additional safety, environmental and security aspects. These include brakes, crash safety, seat belt

installation and anchorages, exhaust emissions (including CO2), noise and silencers and anti-theft protection. For these additional requirements, the European standard (or in some cases non-EU standards considered to be comparable) for that aspect of the vehicle and appropriate to the age of the vehicle, will have to be met.

For the Normal IVA element of the inspection, the items (other than seat belts) cannot be tested by VOSA because special facilities are required. For such items, you will have to provide additional documentary evidence to demonstrate that your vehicle complies with the ‘Type Approval’ standards required of mass produced cars in Europe. Your vehicle will be checked to ensure it aligns to the documentation provided as evidence of compliance when it is presented at the VOSA test station for

the remainder of the inspection.

Compliance with Normal IVA may be demonstrated by one or more of the methods listed in Section 5

on page 14.

The definition of 'Amateur Built'

(1) A vehicle is an amateur built vehicle if :

(a) the vehicle was :

(i) constructed or assembled, or

(ii) having previously been registered under the 1994 Act, structurally modified for the

personal use of a person (‘R’) who is a relevant individual, and (b) the whole, or a substantial part, of the construction, assembly or modification was carried out :

(i) by ‘R’, or

(ii) by one or more relevant individuals acting on behalf of, and under the direction of, ‘R’, or

(iii) by ‘R’ and one or more relevant individuals acting on behalf of, and under the direction of, ‘R’.

(2) For the purposes of this paragraph, a relevant individual in relation to a motor vehicle is an individual

who does not, at any time during the period when the construction or assembly of the vehicle is

being carried out, carry on a business in the course of which motor vehicles are normally constructed,

assembled or modified.

I would hope that a bobtailed vehicle would fall into the above category, otherwise it would be subjected to the much more stringent 'normal' IVA test which I imagine would be impossible to pass due to the more modern 'type approval' tests.

Dave

[Deej]

Link to IVA Information Guide:

http://www.businesslink.gov.uk/Transport_files/IVA_Information_Guide.pdf

[Steve Hiatt]

So we know what an amatuer built vehicle is legally defined as.

More to come...

Bear in mind that that is the classification when presented for IVA, not the initial requirement for an IVA.

From what I can tell the DVLA are saying a bobtail requires an IVA because modifying the chassis in any way loses the vehicles identity. It's got nothing to do with roadworthyness or competence of the conversion, bizarrely.

This leads me to ask what legislation can be applied to say chopping 12" off the back of a Discovery stops it being the vehicle it was originally registered as?

[Bowie69]

I would hope that a bobtailed vehicle would fall into the above category, otherwise it would be subjected to the much more stringent 'normal' IVA test which I imagine would be impossible to pass due to the more modern 'type approval' tests.

Yes, it does, I have had this confirmed in writing from the IVA helpline.

[Deej]

Yes, it does, I have had this confirmed in writing from the IVA helpline.

That's good to hear. Also apologies for somewhat duplicating the information you posted.

[Les Brock]

When you "bobtail " etc etc ** cut/chop or radically alter ie fill in what you have done here ** you deviate from the original vehicle type approval which is therfore void, therefore an IVA is required to ensure it comples with the construction and use regulations - IIRC it was the SVA when I did mine

[Steve Hiatt]

I remember your posts at the time, Les.

At that time there was disparity between different DVLA offices, IIRC there was a thread at the same sort of time about a chap who got his 100" Landy registered by just dealing with his local DVLA office,

Anyway, Whole Vehicle Type Approval didn't become Law for new vehicles in the UK until 2009 so wouldn't apply to most vehicles being bobtailed. They don't seem to be applying the component Type Approval as their guidelines suggest you could change to portals, without chassis modification, and not need an IVA. You could fit a big block Chevy and gearbox and they still wouldn't want an IVA.

[Hybrid_From_Hell]

Makes a mockery of matey chaps bobtailing website eh

Nige

[Jon W]

Ok to open a tin of worms it says, your ok on a new chassis. So technically if someone produced a chassis of the right length for a bobtail then you could use the normal registration. I know if defeats the point of using a rotten old discovery. Or could someone technically start a business "building new chassis's" and use those (i.e. clean and paint them up or galvanise them when the right length so they look like new) as what is there to say whether a chassis is new or not in the DVLA's eyes.

Jon

[Bowie69]

Haven't had any more time to look at this, but REALLY, why are you trying to avoid it? Isn't the fact that it says on one of the governments websites that 'you need an IVA if....' good enough for you?