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Road Vehicles, improving air quality and safety-Gov.UK

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  • #16
    Re: Road Vehicles, improving air quality and safety-Gov.UK

    FWIW I completed the survey. These are my responses:

    Kit cars: emissions standards for national schemes

    Q16. Do you agree with requiring kit cars submitted for IVA to meet the latest MOT standards, thereby removing the rule that kit cars are IVA tested to MOT standards according to engine age?

    No
    Your reasons are?

    It takes a many years to construct a kit car. My own project was purchased in July 2000 to suit an engine built in January 1989. I had anticipated getting it registered in the next couple of years.

    The consultation document states:
    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.

    This is untrue as compliance with the MOT emissions standards current at the date of registration is required. The majority of engines that are 25 years old certainly will not meet current standards. The current emissions standards were published 20 August 2014 and updated 1 February 2018. Engines that meet those specs would need to be manufactured very recently.

    Fitting a new engine to a kit car is unlikely to be completed before the emissions standards are revised. The need to meet current emissions would effectively kill the kit car industry.

    While it is true that older engines are more polluting, kit cars are unlikely to complete many miles in a year, often less than 1,000. While I support the need for new cars to meet more stringent emissions targets the use of recycled engines should be treated in a similar way to reconstructed (restored) classic cars. The appearance of the vehicle should not be a factor in emissions requirement.

    The consultation document recognises in paragraph 4.7; where a vehicle converter is in possession of an incomplete vehicle or chassis the converter will be permitted to carry out a conversion without having to upgrade the engine, as this would be prohibitively expensive. I think this is a farer approach for kit cars.

    Final comments
    I do not think a four week consultation period is sufficient for people to react. Many builders of kit and modified cars are retired engineers.

    I am a member of a kit car owners club. According to government guidelines as voluntary body and representative group affected by the policy we should have been consulted.

    Finally
    Perhaps I should also have mentioned that modern engines are integrated into running gear and security systems. This makes them impractical for transplanting into a different chassis.

    Paul

    Comment


    • #17
      Re: Road Vehicles, improving air quality and safety-Gov.UK

      Originally posted by dave_clutterbuck View Post
      That's how I read it, my Hunter is 1997 due to older engine it is not currently subject to emissions test.
      It will be subject to 1997 emission test level, I presume I may need a catayltic converter then or I may be OK if it passes
      At the last MOT mine was emission tested as a non catalyst vehicle, it passed OK
      Your Hunter was a new car in 1997 and was designed to pass the then current regs. Those still stand and every year it should have been tested at those levels. I have the same car it has the 2.3 injected Ford engine with Cat it passes with ease the emissions on the MOT so should yours Dave. I have as an ex garage owner followed emission stuff over the last few years, and can see real problems on the horizon as electric vehicles become the norm and ICE vehicles become dinosaurs, I dont think those days are faraway

      Comment


      • #18
        Re: Road Vehicles, improving air quality and safety-Gov.UK

        Originally posted by milliemarlin View Post
        My engine is a ford V6 cologne first installed in a car January 1989. No chance of passing a modern emissions test.
        Paul,
        don't give up hope yet. Even if the new proposal is adopted, because your engine is pre-1992 it would be required to meet the MOT Basic Emissions Test. If the engine is in good condition and properly tuned, the addition of a catalytic converter in the exhaust should enable it to pass.
        Thankfully, there has been a lot of response from clubs, individuals and kit-car manufacturers so hopefully this part of the proposal will be dropped.
        I think your response is very good.
        Just today left if anyone else wants to object.....

        Comment


        • #19
          Re: Road Vehicles, improving air quality and safety-Gov.UK

          For information I have responded, as chairman, to the consultation on behalf of the MOC. I'll put the text of the letter up a bit later.
          Regards, Geoff

          Comment


          • #20
            Re: Road Vehicles, improving air quality and safety-Gov.UK

            It’s interesting that according to the document, the U.K. has led the way in creating the EU Europe wide legislation.
            With Brexit on the horizon that demands the the UK can pick and chose the legislation that it adopts, is this one that might be dropped?
            Could the German car makers have to tighten regulations under UK pressure, but ultimately continue to sell sub standard goods to the UK.
            It’s rather like accepting US food standards, much lower than the EU, post Brexit.

            But would it not be best if Europe wide (continental) legislation prevented VW/Audi or any other motor manufacturer from circumventing regulations.

            My personal opinion of the debacle is different. VW/Audi designed a system to pass a test. I would use an analogy, school children are taught to pass a test, that could impact their future lives. But they are only taught to pass the test, not a broader education that might help in their later life.

            Either way I welcome the legislation even if a few people are negatively impacted.
            MOC member since 05/97
            1984 Marlin Roadster SWB.
            1800TC, Unleaded ported head, stage 2 cam. Ford Type 9 gearbox, Dolomite Sprint rear axle fitted with MGF disc brakes.
            Three core radiator, Renault Clio vented front discs.
            The reasonable man adapts himself to the world; the unreasonable one persists in trying to adapt the world to himself. Therefore all progress depends on the unreasonable man.

            Loads of Marlin Reference can be found documents here or there.

            Comment


            • #21
              Re: Road Vehicles, improving air quality and safety-Gov.UK

              Originally posted by peterboat View Post
              Your Hunter was a new car in 1997 and was designed to pass the then current regs. Those still stand and every year it should have been tested at those levels. I have the same car it has the 2.3 injected Ford engine with Cat it passes with ease the emissions on the MOT so should yours Dave. I have as an ex garage owner followed emission stuff over the last few years, and can see real problems on the horizon as electric vehicles become the norm and ICE vehicles become dinosaurs, I dont think those days are faraway
              Hi Peter at present "For emissions purposes only, kit cars and amateur built vehicles first used before 1 August 1998 are to be considered first used before 1 August 1975. First used after 1 August 1998 should be tested to the limits stated on V5" given to me by MOT tester from MOT Inspection manual.
              Looks like this will be superseded very soon, meaning I will need a Cat to pass MOT emissions as it will not qualify for Non Catalyst emission test
              Presumably if it is possible to pass the emissions test without a Cat I will not need to have one

              Comment


              • #22
                Re: Road Vehicles, improving air quality and safety-Gov.UK

                Originally posted by stevejgreen View Post
                It’s interesting that according to the document, the U.K. has led the way in creating the EU Europe wide legislation.
                With Brexit on the horizon that demands the the UK can pick and chose the legislation that it adopts, is this one that might be dropped?
                Could the German car makers have to tighten regulations under UK pressure, but ultimately continue to sell sub standard goods to the UK.
                It’s rather like accepting US food standards, much lower than the EU, post Brexit.

                But would it not be best if Europe wide (continental) legislation prevented VW/Audi or any other motor manufacturer from circumventing regulations.

                My personal opinion of the debacle is different. VW/Audi designed a system to pass a test. I would use an analogy, school children are taught to pass a test, that could impact their future lives. But they are only taught to pass the test, not a broader education that might help in their later life.

                Either way I welcome the legislation even if a few people are negatively impacted.
                I agree with you! For me the quicker we have electric cars the better I have daughters and grand kids, and all diesels are causing poor air quality regardless of what euro they equipped to fiddle! To many times when I owned my garage I saw DPFs removed and saw ad blue defeats fitted who do they think they kidding not us in the garage business that is for sure

                Comment


                • #23
                  Re: Road Vehicles, improving air quality and safety-Gov.UK

                  Worried!

                  Brum was registered in 2012 after the DVLA inspected her and issued her with an H suffix reg.
                  I assume this was because the original Alfa donor was also an H reg.
                  My MOT inspector has only ever given her a 1970 emission test.
                  I assume if this goes ahead that she will be subject to a 2012 test.

                  Doomed

                  Stumbling around in the dark
                  Marina based SWB roadster
                  Alfa Romeo 1750 with 5 speed box

                  Comment


                  • #24
                    Re: Road Vehicles, improving air quality and safety-Gov.UK

                    Have I read this wrong then?

                    When I saw this and read through it a few weeks back I concluded it only impacted kit cars that still had to go through IVA, so if a car was presented for IVA after this is implemented, it would have to meet emmision limits in force at the date of the IVA test.

                    Vehicles already registerested would continue to be MOT tested for emmisions as per the current regulations, date of first reg if a factory built kit car or date of first reg or age of engine whichever oldest for amatuar built kit cars, as per the existing MOT guidance.

                    Have I misread this, I can't see how they can apply current emmision limits to kit cars retrospectively unless they applied the same requirement to all existing registered cars. There are lots of non kit cars on the road that do not and never could meet current emmision standards.

                    John

                    Comment


                    • #25
                      Re: Road Vehicles, improving air quality and safety-Gov.UK

                      Cabrioman, as far as I'm aware this would only apply to kits yet to go through IVA, as you say. The emission requirements for existing cars are unchanged. I believe there have been a large number of submissions from kit manufacturers and clubs to the consultation, the deadline of which was 2nd March. All we can do now is wait and see.

                      Comment


                      • #26
                        Re: Road Vehicles, improving air quality and safety-Gov.UK

                        This is the relevant paragraph:
                        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.

                        There is nothing to indicate that currently registered kit cars will retain their relaxation. So it looks like Millie will fail her MOT in the future.

                        Comment


                        • #27
                          Re: Road Vehicles, improving air quality and safety-Gov.UK

                          But the opening paragraph heading is for New Cars “4. Proposed changes to emissions standards for new vehicles using national schemes”

                          I can’t see how they can do it retrospectivly unless it was accross the board of all currently registered vehicles not just kit cars

                          Any how Looks like there is potentially a rethink on the cards...



                          Scroll down for responce from DOT

                          John
                          Last edited by cabrioman; 03-03-18, 12:41 PM.

                          Comment


                          • #28
                            Re: Road Vehicles, improving air quality and safety-Gov.UK

                            A little extra information about Millie.

                            Millie was first registered in 2005 constructed from 1989 Sierra. Her licence plate is age related (F registration). Coincidentally I replaced the engine with 2005 Focus engine. I had the engine tuned on a rolling road, at some expense, to be as green as possible. Initially the new engine passed the 2005 emission test “better than a new car”. For some reason the engine has drifted out of tune and currently does not pass the 2005 test. This does not matter as she only needs to pass the 1989 test. This causes confusion with some testers. I could perhaps replace her cat and get her to pass the 2005 test. I might have to get her retuned to pass. Whatever; it’s going to cost me.

                            But based on the document as presented she could never pass with her original 1989 engine.

                            Some people with cars older cars may be able to argue that they are a classic.
                            Paul

                            Comment


                            • #29
                              Re: Road Vehicles, improving air quality and safety-Gov.UK

                              If Millie does have to pass the 2005 emissions test I jolly well hope they reduce my Vehicle Excise Duty (VED) to match.
                              Paul

                              Comment


                              • #30
                                Re: Road Vehicles, improving air quality and safety-Gov.UK

                                Originally posted by cabrioman View Post
                                But the opening paragraph heading is for New Cars “4. Proposed changes to emissions standards for new vehicles using national schemes”

                                I can’t see how they can do it retrospectivly unless it was accross the board of all currently registered vehicles not just kit cars

                                Any how Looks like there is potentially a rethink on the cards...



                                Scroll down for responce from DOT

                                John
                                Good point. I hope that is what is intended. Although the sentence under 4.13 “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.” Only makes sense if it applies to previously registered cars.

                                This is the post from Rob P in the other forum:
                                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.

                                Rob


                                Let’s hope they really are listening.

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