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Thread: DfT - Road Vehicles Improving Air Quality and Safety - Consultation Response

  1. #1
    NSRA member Pike's Avatar
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    DfT - Road Vehicles Improving Air Quality and Safety - Consultation Response

    Below is the Air Quality Consultation Document link, and all links to respond to it as well, the main bulk is a guideline for your 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
    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
    33Horseferry 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
    Last edited by Pike; 13-02-18 at 08:47 PM.
    Pike

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  2. #2
    NSRA member kapri's Avatar
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    Don't forget that replying to the Consultation document is THE most important bit if you are short of time.
    Galations 6:7

  3. #3
    Good to see both classic car weekly and classic car buyer newspapers have front page headlines this week.
    Input from NSRA in article and links to consultation document, so hopefully more will respond.

    I'm going to Race Retro at Stoneleigh this weekend so will being asking some of the traders what they have done.
    .

  4. #4
    NSRA Committee Hannah's Avatar
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    Quote Originally Posted by 33 Plymouth View Post
    Good to see both classic car weekly and classic car buyer newspapers have front page headlines this week.
    Input from NSRA in article and links to consultation document, so hopefully more will respond.

    I'm going to Race Retro at Stoneleigh this weekend so will being asking some of the traders what they have done.
    .
    Andy, are you able to send me a photo or a scan of the article? Cheers

    Sent from my SM-G930F using NSRA mobile app

  5. #5

  6. #6
    Sorry Hannah I did not buy them just had a quick look at them in Asda.
    .

  7. #7
    I have filled in the answers to these "proposals" but find that Q10 and Q15 appear to be asking the same thing. What am I missing? Q15 seemed more appropriate despite Pike's post at the top of this thread
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  8. #8
    Is it question 15 for the kit car, as opposed to question 10?
    We do not stop PLAYING because we grow old,
    we grow old because we stop PLAYING!

  9. #9
    Quote Originally Posted by Doctor View Post
    Is it question 15 for the kit car, as opposed to question 10?
    It took me a while to work out all the different number combinations in this consultation farce. Why can't they use the same question numbers for the document PDF and the respond links.

    To answer question 10 about kit cars in the document booklet PDF you have to answer question 15 if you use the respond online link.

    but if you use the next link down - complete a response form. The kit car question / answer is 16 !!!

    I used the respond online link and question 15 about kit cars.

    .

  10. #10
    Don't know if it helps, but having responded to it online, there is a question right at the end about your view on their cost benefit analysis. I responded by saying it was flawed as they had not taken into account the impact on the classic, modified and kit car industry, worth in excess of £5.5 billion.

    Every little helps.....

    Gerry

  11. #11
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    I’ve just had a letter forwarded to me by my MP, from Jo Johnson, Minister of State and Minister for London, thanking me for my correspondence and my views of the consultation.


    Jo is one of the people I wrote to about it all a few weeks ago. Glad to see that some of them do actually hear and acknowledge what we minions have to say.
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    Monogamy is essentially much the same thing.

  12. #12
    NSRA member Jimbob's Avatar
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    Just received this from my MP.Name:  20180312_120827.jpg
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Size:  29.6 KB

    Sent from my SM-J320FN using NSRA mobile app
    It's only original once...... But you can rod it as many times as you like!

  13. #13
    At least some of the MPs are doing their job I didn't hear anything back from my local mp
    does anyone no when we're likely to no the outcome of the consultation?

    luke

  14. #14
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    Likewise Luke,
    Stuff all back from my MP, not even an acknowledgement of receipt............

  15. #15
    Pleasantly surprised to receive a reply from my MP yesterday and he had obviously actually read my letter (that was based on the NSRA draft) and added a personal note.

    Unfortunately I can't seem to be able to post the reply on here at the moment
    Rome wasn't burned in a night

  16. #16
    Dear Steven Knight



    Thank you for contacting me about the Department for Transport's consultation on improving air quality and safety.

    Given the recent VW dieselgate scandal and the strong imperative to improve air quality, I understand Ministers are investigating what more can be done. As a part of this, the consultation seeks views on new penalties for vehicle manufacturers supplying vehicles fitted with defeat devices and proposals to implement various safety and environmental rules.

    I note the concerns that you have about the consultation. I can assure you that I want to see the UK retain a thriving car industry. This means supporting both the construction and development of new models as well as the restoration of classic cars and the building of new kit cars.

    The consultation has now closed and the Government is analysing the feedback. As I am sure you can appreciate, I am not able to pre-empt the results of the consultation.

    Thank you again for taking the time to contact me.

    Yours sincerely,

    Jeremy Quin



    Jeremy Quin

    Member of Parliament for Horsham

    House of Commons

    Quote Originally Posted by Graham Thompson View Post
    Pleasantly surprised to receive a reply from my MP yesterday and he had obviously actually read my letter (that was based on the NSRA draft) and added a personal note.

    Unfortunately I can't seem to be able to post the reply on here at the moment
    This is the reply I received today

  17. #17
    Quote Originally Posted by Steveknight View Post
    Given the recent VW dieselgate scandal and the strong imperative to improve air quality, I understand Ministers are investigating what more can be done. As a part of this, the consultation seeks views on new penalties for vehicle manufacturers supplying vehicles fitted with defeat devices and proposals to implement various safety and environmental rules.
    Too right there should be new penalties for vehicle manufacturers supplying vehicles fitted with defeat devices (that question got a big fat YES).. Thanks a lot VW Group!! "here's another nice mess you've gotten us into!" Theres millions of vehicles worldwide from the worlds largest motor manufacturer emitting fourty times the amount of poisonous NOX thats permitted by the US Gov and who does our Government want to pick on?.. UK kit car manufacturers!!.. (because obviously targeting a few kit cars is going to make a huge difference to air guality!).. you just couldnt make it up. And, no, in case anyone thinks it, im definitely no eco-warrior.
    I take it youve all heard about VW+BMW +Mercedes Monkeygate as well? What is it with these people and gas chambers?.. old habits die hard.

    Quote Originally Posted by Steveknight View Post
    The consultation has now closed and the Government is analysing the feedback. As I am sure you can appreciate, I am not able to pre-empt the results of the consultation.
    And so we wait (and rant a little bit).

  18. #18
    Quote Originally Posted by Graham Thompson View Post
    Pleasantly surprised to receive a reply from my MP yesterday and he had obviously actually read my letter (that was based on the NSRA draft) and added a personal note.

    Unfortunately I can't seem to be able to post the reply on here at the moment


    Finally managed to upload it. As stated above a better than expected reply. I wonder if Chris Graying will bother..... I copied the letter to him in the first instance.

    Name:  img001.jpg
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    Rome wasn't burned in a night

  19. #19
    As usual, heard nothing from my local MP, Tom Brake (Lib Dem) but not likely to either as he's fighting to stay in office come May due to their current incinerator scandal near me!!
    MisteR Tee
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  20. #20
    NSRA member Captain Scarlet's Avatar
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    I have had two,a standard letter which must be from taking part in the survey from Robert Lloyd Smith ,and one from my Conservative MP Amanda Milling,photo below.

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