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New Emissions Proposals For Kit Cars


Snapperpaul
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There's only 2 questions that really apply to kit builders:

 

 

8 Do you agree with the introduction of WLTP in IVA, for light vehicles built after 1 July 2018?

 

10 Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT standards according to the age of their engine?

 

Most right minded people who understand the current regulation would answer NO to both questions so if this is you, why not let them know and give them a short explanation why and let this chap know

 

Robert Lloyd-Smith

Zone 1/33,

Great Minster House

33 Horseferry Road

LONDON

SW1P 4DR

 

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

 

making your views know takes let time than it took me to post this and if no-one offer a counter view, they'll assume no-one's interested.

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It does state in contact details to inform them if your representing as an idividual or a body.

 

Perhaps we have a committee member that could represent our views as a club.

 

Doesnt have to be that person doing the work, just forwarding our "the club" views, maybe a point to bring up at Stoneleigh for discussion.

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Hi emptyat - I think this is the part that was causing a little confusion. Although it's in a 'proposal document' - 4.10 is actually just reiterating how it stands with the 'current' system.

 

4.11 goes on to detail what they are proposing to change it to. As it states - when they register your car, it must comply with current mot emission standards which means it must have been tested at that level at IVA.

 

Snapper - I think everybody totally understands that it couldn't possibly be applied retrospectively. As you rightly say - motoring changes of this magnitude never are. :)

 

Thanks for that I get it now!

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Here's my effort:

 

"Dear Sir,

 

I write in response to the DFT proposal to improve Air Quality and Safety. Whilst broadly agreeing with the proposals contained within the document, as a kit car owner and builder I am concerned that the application of these new rules will have a negative impact on other kit builders and the kit car industry as a whole.

 

The consultation document raises 2 key question specifically aimed at kit cars:

 

8 Do you agree with the introduction of WLTP in IVA, for light vehicles built after 1 July 2018?

 

10 Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT standards according to the age of their engine?

 

For anyone with a knowledge of the current regulations and a genuine interest in the UK kit car industry, the answer to both these questions has to be an emphatic NO.

 

WLTP testing as part of IVA would be impossible. It would be too complicated and time consuming to be performed as part of what is already a lengthy and expensive process and it would be unreasonable to expect an amateur individual to subject a vehicle to the same test as a major manufacturer. Successful completion of the test would depend not only on the type of engines and emission controls but also other aerodynamic devices fitted to the vehicle. Even if it was possible to fit a WLTP friendly engine to a kit car, it would be impossible to get satisfactory results given that the visual style of kit cars generally gives no consideration to improving their aerodynamic (and emissions) performance. For many kit car owners and builders, having a vehicle that is visually different from most other cars on the road is a major cornerstone of their interest.

 

Requiring kit cars to meet the latest MOT standards would also present a number of problems. In recent years, the kit, restored and modified car industry has seen the increased use of technology in the area of fuel and emissions control. Sophisticated electronic control units (ECU’s) are now available that allow a level of control that even major manufacturers would not have had 20 years ago. This has been a huge step forwards but as amateur builders we still lag some way behind when benchmarked again current regulations. This is partly because an older design of engine, even when fitted with a sophisticated ECU, will still struggle to meet the existing regulations. As the test standards continue to rise, the design of engines must follow and it simply isn’t possible for kit builders to use a brand-new latest design engine.

 

The current MOT standard for kits which bases emissions standards on engine age works well. Whilst I agree that there is a wider chose of modern engine available to builder, not all of these may be suitable. This may be because they don’t physically fit, or they don’t have suitable transmissions available. The vast majority of modern cars are front wheel drive and their transmission cannot be adapted to kit cars, most of which are rear wheel drive, meaning many builders are forced to look at older, rarer and consequently more expensive alternatives.

 

Many kit car builders want cars with a period feel to them. Being forced to use a more modern engine isn’t really an option for them and using an older engine, possibly coupled with a modern ECU allows them to retain a period feel but still give some consideration to emissions which in most cases, will be far better that what the original manufacturer ever thought possible. Retaining the existing MOT standards is the best way to ensure that kit cars maintain sensible emissions without forcing them in to using complicated, expensive and potentially unsuitable current engines. The number of kit cars on the road is a very small percentage of overall vehicle and is also very likely less than the number of classic vehicles that are designated MOT exempt and therefore have not emissions requirement. If a blanket exemption can be applied to classic vehicles, then why can’t a more sensible approach be taken for kit cars.

 

The current IVA and MOT regulations weren’t popular amongst kit car builders when there were introduced but they are now widely understood and accepted. Further changes to regulations that seem to offer very little real benefit would only have a negative impact on kit builders and the kit car industry as a whole.

 

The UK kit car industry is probably unique in the breadth of products that it offers and is widely regarded in Europe and further afield. It has managed to survive despite new legislation which has at times, done everything it can to make things difficult and I think it is vital it’s given every possible opportunity to continue to do so."

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edit: beat me to it ^^^ :)

 

As an aside, I'm curious as to how workable this is going to be at IVA :)

 

If emmissions are all rated at grams per kilometre, then they will have to run your car in controlled circumstances on a rolling road while measuring the emmissions. They will need to accurately measure distance, which they have thanks to their calibrated rollers, but obviously this will take time and additional training at the test centres to perform. And in order for it to be 'fair', presumably it has to be to the same test standards as any normal production car (and we all know how fair they play :) )....

 

In short, I would imagine this will be a cost nightmare to accurately implement at an IVA test station. Just seems fair easier to do what they do now, and either prove age of engine and test against known standards or otherwise just mandate compliance with Euro IV/V accordingly. Trying to measure an emmissions level in g/km seems a large amount of effort to implement for such a small volume of cars hitting the road. But, hey ho, they've got to spend our taxes one way or another I s'pose :-/

Edited by brumster
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Stoneleigh will be too late, if you have a view it needs to be known now.

 

This is a 4 page thread of chat that will have no effect on the outcome. The DFT proposal is a stupid idea with no merit and they need to be told, either by post or email. It's as easy to send them an e-mail as it is to stick a post on here and if people have a view, I can't see why they wouldn't want the DFT to hear it.

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The proposal is sound to me on the basis of people staring out building a new kit. I don't see why anyone should need to, or even would want to, install an engine so old that it can't meet some basic emmissions standards (assuming the current limits are acceptable).

 

Having said that, I agree that the volume of kit cars going through the process just seems to make the proposal a bit of a pointless exercise that burns political effort and money for no real advantage. I mean, seriously, why go through all this effort for what must be a handful of cars each year in relation to the total number of cars on the road.

 

So I'd say it's a waste of time, not on the premise of it's intentions - I think they are sound - but the practicalities of implementing it and the effort<->reward just seems foolish.

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Richy,

 

Very much simmilar to my draft i was intending to cut n paste to here.

 

I agree that we could all do something to work towards the cleaner air but im very mindfull of the practicality of a home builder achieving such modern standards while maintaining cost effectiveness.

 

In health and saftey speak, its just not practicable.

 

If your letter needs us to agree to your response as a view then im a plus one.

 

Very well constructed. Better than mine i may add.

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I don't think it's necessary to agree my response. What people need to do is put their view in their own words. All they need is to be told whether you agree or disagree with the 2 questions and then give some reasons why. It'll be judged on the subject content, not the grammar.

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I think If I was forced to meet the current emissions standard's then I would want a brand new current registration number rather than an age related plate.

 

I can understand what they are trying to do but it just seems like a silly idea that won't work and just crush the kit car industry.

 

Sending my response today.

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  • 1 year later...

Lifting an old topic, but what happened with this proposal in the end? I can't find anything relevant on the DVSA web site (but might have missed it).

I'm toying with the idea of building a bike engined car for some track day action, but if these emissions changes come into force, I think it might be difficult to get through emissions.

OTOH, maybe a bike engined car would automatically end up on a Q plate, which sounds like a get-out-clause?

 

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The IVA standard was revised in April 2018 with regard to metered emissions. The emissions look to be broadly in line with current MOT regulations and are based on engine age. Going for a Q plate won't necessarily help you at IVA. 

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Thanks for replying :)

 

I think I found the right document now:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/738819/individual-vehicle-approval-inspection-manual-passenger-vehicles.pdf

So, as you say, it looks like the 'effective age' is basically engine age:

 

Quote

Metered Emissions 02B Revision: 8 Date: 03/04/201812of 14

The “effective date” used to determine the criteria applicable is -the date of manufacture of the vehicle, except for an “Amateur Built” vehicle, a “Vehicle manufactured using parts of a registered vehicle” or a “Rebuilt vehicle” it shall be 1 January immediately preceding the date of manufacture of the vehicle’s engine if this is earlier.

That obviously makes a lot of sense for a car, and IMO a good move, all things considered.

 

I'm guessing that for a Bike engined car, the same criteria would apply, and thus it'd fall into the default limits:

Quote

Fast Idle:(2500 to 3000rpm)

CO <= 0.3% (1st Sept 02 onwardsCO<= 0.2%)

HC <= 200ppm

Lambda between0.97 and 1.03

Idle: (450 to 1500rpm)

CO <=0.5%

(1st Sept 02 onwardsCO <= 0.3%)

 

Need to do some more research on what bike engines clear those (unless I've got myself confused with the rules).

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1 hour ago, Henrik said:

Lifting an old topic, but what happened with this proposal in the end? I can't find anything relevant on the DVSA web site (but might have missed it)

 

It was canned - they got over 2000 complaints about it which I think is maybe the official limit when it doesn't go further? Either way, it was canned... (there was a short news item in the Spring club magazine about it).

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