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With
reference to the recommendations raised by The Consultation
on Review of Inspection Procedures of the Driver and Vehicle
Licensing Agency (DVLA) and Driver and Licensing Northern Ireland
( DVLNI) of April 2004 we feel that points have been raised
and people /businesses affected that would have not felt a need
to input into the original document. As such we feel that further
consultation should take place and almost certainly a Regulatory
Impact Assessment will be required based on the points raised
in our response document.
It
appears that the far reaching effects and impact upon businesses
have not been considered as the whole car modifying scene consists
of somewhere in the region of 1-2,000,000 people with a minimum
annual turnover of approx £2000,000,000 in parts alone.
This figure is based on a very conservative £2000 pa spend
by 1,000,000 people and this disregards any costs for labour,
insurance, VAT, import duties etc.
There
is also a large vehicle import market both directly by businesses
and, more and more in this computer age by individuals themselves,
from vehicles to parts to restore and modify. There are also
the businesses involved in shipping these items to be considered.
Our
initial figures are based on the audited circulation of related
magazines and these show sales of £98,000,000 per annum
for all Automotive based magazines with half of those relating
to the Modified market. Total monthly magazine sales are just
under 1,800,000 and the marketing divisions always work on the
basis that at least 2 people read every copy sold.
We,
as car modifiers, feel that our hobby, and history, is greatly
misunderstood by many. Also that most have no idea of our background,
history or depth of feeling involved.
In
order to access what changes would prove beneficial it is first
important to understand the continuing changes in automotive
design and what is considered by most enthusiasts to constitute
the root ‘core' of a vehicle.
.
Photo
1 Chassis and body construction method.
The
first vehicles produced from the beginning of last century up
to, mainly, 1960 constituted a chassis onto which a body was
bolted followed by the propulsion units of engine, gear box,
axles and then steering components.
From
approximately 1960 most manufacturers changed to a new system
of monocoque, where the body is welded permanently to what would
have been the old chassis and the propulsion units bolted directly
to this bodyshell.
Photo
2 showing underneath of rear wheel drive monococque welded body
/ chassis unit.
During
the next 20 years, following the huge success of the Mini, most
manufacturers turned away from the rear wheel drive through
a separate axle towards the front wheel drive car, where the
engine/gearbox/steering and driving axles became one large linked
component fitted on a subframe to the monococque.
Photo
3 Complete FWD subframe assembly of engine/ gearbox/steering/
front suspension.
Car
modifiers use predominantly RWD (rear wheel drive) cars as they
are regarded more as ‘drivers' cars and allow a greater flexibility
in design modification.
Many
will not understand the need to modify cars at all. This is
something that has always happened from the start of motoring.
A lot of revered marques such as MG and Bentley, evolved from
the pastime of building ‘specials'. During the late ‘50's the
hobby evolved into placing bodies made from glass fibre onto
readily available Ford Popular chassis. From these humble beginnings
came the fledgling kit car industry and more revered marques
such as Lotus and TVR. In short, this practice has allowed many
great engineers and designers to develop hands on experience
that has benefited car safety and industry in general.
We
understand the concerns raised over safety and can see why,
on first uninformed glance, that these vehicles may appear dangerous.
Huge engines placed into bodies designed for a miniscule power
output. However, all is not as it would first appear and great
steps are taken to ensure the strength, and safety of the components
used.
Imagine
installing a large v8 engine into this early body design …….
…..
To make this
But
without realizing the depth and strength of engineering under
the skin may look like this 
The
insurance industry always known for its caution, even see these
cars as ‘good' risks. Seem strange?? Probably until you see
the risk assessments proving that they have realized how well
engineered these cars are and that the drivers take huge pride
in their machinery and driving standards. The accident statistics
speak for themselves, there are far less accidents involving
‘modified' cars than for standard vehicles. Like for like claims
run in the 6-8% bracket compared to mainstream 45-50%! Mainstream
OEM motors are often skimped on as maintenance costs can be
extortionate, but worse still is the family ‘2 nd ' car , used
purely for a shopping trip or school run, and only maintained
when they stop working or something falls off. The motoring
enthusiast is always checking his car and ensuring it is maintained
at the very highest level.
Previously
we have spoken of car modifiers in general, but now we'll come
to the “Street Rodding” side of the hobby. Car modifiers in
general tend to stick together with others that have similar
interests. Our side of the hobby traces its roots, in the UK,
back to the late 1950's and then a huge boom in the 1970's.
Many of our vehicles have a longer history of being modified
that they do as standard cars. They are often works in continual
progress with items being changed as newer, safer or stronger
components become available from recycling yards or the huge
aftermarket.
These
components are not fitted straight from the yard, but rather
overhauled and upgraded to modern safety levels. Many components
are purchased purpose built items from the huge aftermarket
supplies worth some £ 2000,000,000 p.a .The perception
that huge engines are put into low specification base models
could not be further from the truth. This is where the retention
of an ‘unmodified' chassis/semi monocoque becomes a problem
as these need to be strengthened to cope with the new loads
imposed on them.
It
is difficult to judge where the ‘essence' of a car lies but
surely the general consensus would be that it is what it resembles,
i.e. the bodyshell/chassis body is the heart of the motor.
If
you look at this picture of a car broken down into it's main
components which part would the general public point to and
identify as ‘the car ‘?
Surely
the item in the background??
The
bulk of the components lumped together in the foreground would
be recognized by most , including the police, as non dated or
vehicle linked service items with only the engine normally carrying
any form of identification number. In the case of engine reconditioning
or ‘swapping' the same engine could serve in two or more cars
in its lifetime.
Reconstructed
classics claim to use all period parts and indeed the Police
feel that this is a prerequisite of the class continuing. We
find this hard to comprehend as it is highly unlikely that any
genuine, period parts would still be in serviceable condition.
For instance would a vehicle still carry its original brake
linings, brake hoses, steering joints and various other service
items?
If
you were to look into the car park it is very unlikely that
a 5 year old car would carry the same components that were OEM
when it left the factory. By the time they are 10 years old
it is likely that that a large percentage of the car is not
as it left the factory. It would probably have had an engine/gearbox/back
axle change along with many body panels due to accident damage.
Should these vehicles' identity be called into question also?
From
the above it must start to become clearer that any car's identity
is constantly changing and difficult to define if you consider
the ‘underpinnings' as part of the identity. However the vehicle's
visual representation remains constant during the same time.
This very point has been proven in the High Court re the famous
case of ‘Old number 1' Bentley and this will be dealt with again
later on in this document.
The
vehicles chosen for modification are usually 20 years, or more,
old. Whilst the engineering and propulsion components are upgraded
it is usually impossible to modify the items that would fail
SVA as they were not an initial design characteristic of the
vehicle. They cannot be compared with kit cars that are purpose
designed to pass the SVA. We feel that our cars should be built
to certain laid down standards and, on the ‘Street Rodding'
side, we have started to compile our minimum specification to
which we would adhere. When SVA was first proposed we supported
the idea of a super MOT. Unfortunately the SVA had to become
all things to many interests and a lot of our input was sadly
lost.
As
the recent consultation document did not raise the matter of
inspection of ALL modified vehicles there is a vast number of
enthusiasts whose views have not been taken into account. Whilst
we attempt to address the “Street Rodding” fraternity's concerns
with the current recommendations we are also campaigning to
make the other enthusiasts aware of the possibly damaging changes
that are being discussed currently.
To
put this into perspective the kit car industry currently has
two national magazines on sale, the ‘Street Rodding' side has
three, and there are something like 30 dealing with modifications
to other old vehicles.
We
have already submitted proposals for a Street Rod Class of registration.
However in the light of recommendations raised, and concerns
voiced, we have revised and amended this to become a reconstructed
/ modified class. This would encompass the needs of the Reconstructed
Classic class and expand to accommodate
the needs of the modified car enthusiast in a straightforward
and clear manner. This would provide an easily administrated
class and provide the necessary consumer protection by annotating
the V5C with details.
The
safety inspection of these vehicles could be dealt with either
by an engineers report from an engineer endorsed by the governing
body or owners club. Alternatively this could be done through
the SVA testing stations but in a manner that takes into account
the original design date of the base vehicle. That is to say
that the SVA is not a suitable test as most cars have not been
designed to pass but that many safety aspects that form part
of the SVA could be checked. The reasons for non SVA compliance
of early vehicles will be examined later in this document. It
is felt that most that wish these vehicles to comply with the
SVA do not have an understanding of the SVA test itself.
Car
modifiers are as concerned as any about safety, maybe more than
most, and would not object to testing, with a reasonable cost,
that was appropriate to their vehicles.
We'd
now like to offer our opinions on the various recommendations
raised that are pertinent to car modifiers.
Recommendations
arising from consultation document.
6)
Radically Altered Vehicles
Recommendations
To
consider when a vehicle ceases to be the original vehicle.
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As
mentioned earlier in this document the general consensus would
be that the identity changes when the vehicle ceases to resemble
its description on the registration document. Cosmetic changes
that do not alter the general silhouette would not affect its
identity and neither would ‘under the body' mechanical changes.
Many of the original OEM parts fitted at the point of manufacture
would have changed as they have worn out and been replaced with
reconditioned exchange or aftermarket pattern replacement parts.
The
case for the mechanical components having no real contribution
to the vehicles identity are proved in the court case relating
to the well known Bentley ‘Old number 1 ‘.
This
famous case :-
HUBBARD
vs. MIDDLEBRIDGE SCIMITAR LIMITED
IN
THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
Royal Courts of Justice, London.
No. 90/MJ/2474 - 27th July 1990
Before: MR. JUSTICE OTTON
QUOTE:
Thus the expert evidence is all one way. It confirms that as
with any other racing car the parts in the car were continually
being
changed. Such changes were made either because the parts were
worn or because the specification of the car needed
upgrading. Accordingly, the car evolved over a period of time
as a continuous entity and can still properly be regarded as
the
present legitimate manifestation of Old Number One. As Mr. Guppy
put it, "A racing car is a continual development around
a
theme and depending upon its history might contain a greater
or lesser proportion of its original parts without jeopardizing
its
perceived authenticity". END OF QUOTE.
Please
bear in mind that whilst this is referred to as a ‘racing car'
this is in fact a road legal and registered vehicle.
Full
transcript available at http://www.gomog.com/articles/no1judgement.html
To
consider whether vehicles that have been radically altered from
their original specification require type approval. This may
involve changes in legislation.
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As
stated previously those Radically
Altered Vehicles that retain the essence of the original design
would not pass SVA as these design criteria were not established
at the time of their design and production. . We fail to see
how vehicles designed between 20- 70 years ago could be asked
to pass a test designed for modern vehicles. After all original
Classics are allowed on the road with no additional testing
and most of their basic safety items remain inferior to current
specifications. That is not to say that their systems are inadequate
just that there have been huge advances in vehicle safety systems.
The modifier incorporates these into his classic based vehicle
thus enhancing safety but many still feel that this CAUSES a
safety concern?
There
is no objection from modifiers to a safety inspection merely
to what is an appropriate form. It is possible that this may
take the form of an engineers report from someone well versed
in the style of vehicle being presented and authorized by the
relevant organizing body or owners club. It is also possible
that this test could be carried out at an SVA station but it
should NOT be a full SVA test but rather one where exemptions
have been made based on the initial design date of the vehicle.
The
following 3 interior photos showed standard interiors that would
not pass the test due to the radii requirements of switchgear,
method of construction of steering wheels, or even the method
of speedometer readings. These are however perfectly standard
period interiors and meet the legislation at the time of construction.
Photo,
Mk2 Consul interior
Photo
Ford RS Escort interior (above ) Ford Popular( below)
The
exteriors of these vehicles would not comply with SVA, falling
foul of lack of E marked lighting, spring back mirrors, side
repeater lights, hinge projections on early cars, radii of exterior
components much of this even within the shapes of the original
body panels.
For
instance the Ford RS Escort a popular car for modifications,
pictured below, would even fail on the shape of the original
wheel arch .
These
Land Rovers even fall foul of current Construction and Usage
in standard form.
That
the registration document be annotated to indicate the vehicle
has been customized.
We
feel this is a good step for both the car modifier, given that
it gives established status and also for the consumer as the
non standard nature of the vehicle would be noted. It is however
worth pointing out that it would be most unlikely that someone
would ‘accidentally' purchase a modified vehicle. We feel that
the term ‘Modified' would cover a wider range and be more indicative
of the true nature of the vehicle.
To
consider checking the make /model details at the MOT test.
During
the early days of customising and kit car building it was not
unusual for even DVLA inspected vehicles to retain the donor
vehicle details ( make/model ) even when the appearance of the
vehicle had radically changed. Some provisions must be made
for some form of ‘Grandfather Rights'.
Also
many modified cars have a longer history as a modified car than
they do as a standard car but the ‘under the skin' changes that
have been gradual and not so significant as to have been annotated
on the registration document. These have been used regularly
and legally for many years but may fall foul of what are essentially
retrospective changes.
Consideration
must also be given to how long a change may be in position before
it is considered to form part of the vehicles identity in its
own right. IE If the car is 20 years old and the modified component
has been in place for 10 of those surely it should start to
be considered as part of the ‘original' vehicle?
9)
Reconstructed Classics
To
consider whether the category of Reconstructed Classics should
be retained.
We
feel that the category should be retained and actually expanded
to provide the basis for a Reconstructed / Modified registration
class that could address many of the concerns voiced by the
Police and others. Referring back to the argument as to what
forms a vehicle's identity
if the propulsion components are disregarded the need for genuine
pre 73 components is no longer necessary. In fact by sticking
to that criteria many of the Classics already on our roads but
not registered under this class would fall foul of proposed
changes.
We
feel that our further proposals over the next few pages would
be helpful in making this a more easily accessible and understandable
registration class and one where safety checks could be carried
out under the terms offered up in the Radically Altered Vehicles
class.
As
has been previously stated the SVA is not a suitable test for
those vehicles that would fall into this category and hopefully
the previous few illustrations would show the reasons why. It
is felt that the ramifications of the SVA test, and its inappropriateness
for all classes mentioned in this document, is being overlooked
by those proposing it's use.
Further
explanations can be made available if required.
Photo.
A modified 1936 Ford ,originally customized in 1952 and recently
restored and updated. We also value our alternative automotive
history .
MODIFIED
/ RECONSTRUCTED REGISTRATION CLASS
____________________________________________________
•
There will be a one off fee payable for registration in this
class
•
All vehicles will conform to Construction and Usage relative
to the date of manufacture as shown on the V5C
•
To provide consumer protection the V5C would be annotated
to show the vehicle was “ modified and/or reconstructed from
a mixture of new and old components “
•
All vehicles will undertake a safety inspection to ensure
the quality of the workmanship. This may take the form of
an engineers report from an owners club / governing body approved
engineer who would be conversant with the modifications in
question.
•
Alternatively the test may take place at SVA premises using
a modified SVA test with exclusions relative to the date of
first manufacture of the base vehicle.
•
Cherished transfers would be allowed to these vehicles as
consumer protection is already dealt with by the annotation
of the registration document.
CRITERIA
1)
Any
vehicle using an ORIGINAL body together with ORIGINAL, or MODIFIED
ORIGINAL chassis, with all other components of a style produced
prior to January 1973, or components of which the first model
was produced prior to January 1973, shall be taken to have the
date of manufacture of the first year of production of that
body style or, if documents relating to the original registration
are available, the actual year of manufacture.
1a)
The vehicle would be entitled to Historic Vehicle Classification
and issued with an age related registration, if no other mark
was already relevant
2)
Any
vehicle using an ORIGINAL body together with a NEW REPLACEMENT
OR REPLICA chassis, with all other components of a style produced
prior to January 1973, or components of which the first model
was produced prior to January 1973, shall be taken to have the
date of manufacture of the first year of production of that
body style or, if documents relating to the original registration
are available, the actual year of manufacture.
2a)
The vehicle would be entitled to Historic Vehicle Classification
and issued with an age related registration, if no other mark
was already relevant.
3)
Any
vehicle using a NEW REPLACEMENT REPLICA body together with an
ORIGINAL or MODIFIED ORIGINAL chassis, with all other components
of a style produced prior to January 1973, or components of
which the first model was produced prior to January 1973, shall
be taken to have the date of manufacture of the first year of
production of that body style or, if documents relating to the
original registration are available, the actual year of manufacture.
3a)
The vehicle would be entitled to Historic Vehicle Classification
and issued with an age related registration, if no other mark
was already relevant.
4)
Any
vehicle using an original body, manufactured after 1973, but
with a NEW REPLACEMENT chassis, or MODIFIED ORIGINAL CHASSIS
/ MONOCOCQUE with contemporary and/or newer propulsion components
shall have the date of manufacture shown as the first year of
manufacture of that body style unless there is documentation
to prove the actual year of manufacture.
4a)
The vehicle would NOT be entitled to Historic vehicle classification
and would be issued with an age related registration relevant
to its presumed date of manufacture, unless documentation can
be shown to prove date of manufacture of the bodyshell.
Moncocque
construction.
5)
Any vehicle using an ORIGINAL or REPLACEMENT or REPLICA TO OEM
STANDARD moncocque bodyshell with all other components of a
style produced prior to January 1973, or components of which
the first model was produced prior to January 1973, shall be
taken to have the date of manufacture of the first year of production
of that body style or, if documents relating to the original
registration are available, the actual year of manufacture.
5a)
The vehicle would be entitled to Historic Vehicle Classification
and issued with an age related registration, if no other mark
was already relevant
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