ACTION REQUIRED! DfT – Improving Air Quality and Safety Consultation

***DfT – Road Vehicles Improving Air Quality and Safety – Consultation Responses***

– URGENT ACTION REQUIRED BY ALL NSRA MEMBERS & MOTORING ENTHUSIASTS – This consultation closes on Friday 2nd March!

In this document on page 16, 4.10 to 4.13 it is proposed that all vehicles going through IVA from this July will have to conform to new car emissions limits. In short, this will kill any chance of a Hot Rod or kit car passing. The current rules takes the age of the engine to determine the emissions limit. If you are building, thinking of building or relying on getting your modified car through IVA, this legislation will put a stop to it. We all need to act fast to stop this or a whole way of life for many people will be lost forever.

To help, you need to create awareness to this consultation to all effected people. Everyone needs to reply to the consultation and say NO to the Kit Car section. You need to write or email your MP to express your thoughts against this proposal and reply to the online consultation. We have drafted some letters to use and some points to raise while replying to the consultation, feel free to copy them or use parts to write your own letter.


RESPONSE 1 – An individual’s response to consultation: –

Below is the Air Quality Consultation Document link, and all links for individuals to respond to it. The main bulk is a guideline for your individual consultation response if you need it, covering why their document is totally unworkable and the points they need to consider before implementation.

This consultation closes on Friday 2nd March!

DfT -Road Vehicles Improving Air Quality and Safety – Consultation

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

DfT -Road Vehicles Improving Air Quality and Safety – Consultation Response

http://www.smartsurvey.co.uk/s/road-emissions/

Answer Question 10 as NO, detailing reasons why as below

The notified list does not contain any clubs to do with kit cars which will be majorly impacted but the Road Safety Markings Association have? This does not seem to be a “consultation” but a “notice of intent” because of its timescale.

As much as the major companies would wish us to renew our car every 3-5 years, kit cars and particularly radically built vehicles mostly reuse second hand parts, by recycling like this it is far more environmentally friendly than buying new parts off the shelf which creates pollution in manufacture.

The timescale given in your document is completely unworkable as many hobbyists (even some kit car companies) take years to complete a project.

Mentioned in 4.7 is that vehicle convertors can carry outworks and it would be prohibitively expensive to upgrade the engine, as long as he maintains the existing emissions on the engine, should this not also apply directly to kit cars if not more so due to expense?

In 7.8 the car or van categorisation, it is stated that you are taking a “common sense” approach if you cannot determine the prime function of a vehicle. Why is a similar approach not being used for a person building a classic style kit car and their engine choice?

4.10

Reconstructed classic cars do not require IVA?

The sensible route is for the installed engine to have an age appropriate emission test as it currently is now. Which is the same as all the classic and historic vehicles currently on the road with the same engines.

This is the only sensible and workable legislation to have.

4.11

Most kit cars are built to a style of decades past(Caterham, Cobra), which by definition includes the drivetrain, this stops this stone dead.

Kit cars based on a VW Beetle with an original engine will never ever pass the proposed emission tests, so again this stops stone dead.

This also unworkable as the emission level limits will only ever get tighter which means if you are taking a number of years to build you will permanently be “chasing your tail” to meet the “current” level in place at the time of test.

4.12

Reconstructed classic cars do not require IVA?

Define a “broadly unchanged” appearance, as early separate chassis cars when coach built were vastly different on the same chassis, which is the basis for a vehicles identity.

Engine capacity, is that within type or as the individual vehicle left the factory?

4.13

A 25 year old engine as suggested will not meet current emission levels

The cost of using an engine from the last 25 years which does meet current emission levels will be out of reach for many due to cost and a lack of understanding of ECU’s, we are engineers not computer programmers.

Many more modern engines with ECU’s will not function without being in their original chassis or without the airbag and ABS systems in place, which cannot be in place for a BIVA test. There are no workable alternative ECU’s available.

Consultation Replies to :-

Email to: ivs.consult@dft.gsi.gov.uk

Or post to:-

Robert Lloyd-Smith
Zone 1/33,Great Minster House
33 Horseferry Road
LONDON
SW1P 4DR

Also, extra responses can be forwarded to :-

Head of DfT – Chris Grayling

pocorrespondence@dft.gsi.gov.uk

Other members of DfT

https://www.gov.uk/g…/organisations/department-for-transport

Postal Address for DfT :-

Department for Transport, Great Minster House, 33 Horseferry Road, London, SW1P4DR


and please use this NSRA CONSULTATION RESPONSE 2 for a draft letter to use to write to your MP:

Dear Sir/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/consultations/road-vehicles-improving-air-quality-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 building cars in their garages. They have considerable time and money invested in their projects. 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,

….