See here
https://www.pistonheads.com/gassing/top ... &t=1722937
Can I suggest as many of us as possible email in our objections, as if more modern emissions tests are required, the A series will struggle.
I will certainly not be spending any money on my A series for a while, until the results of the proposal and consultation are published....
Potentially the end of the A series Eleven build....
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biggles
- Posts: 316
- Joined: Tue Apr 10, 2012 8:10 am
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Simon Marks
- Posts: 66
- Joined: Sun Mar 29, 2015 2:05 pm
Re: Potentially the end of the A series Eleven build....
Hi, Simon,
I have already e-mailed - see below:
"I have become aware of some consultations regarding vehicle MOT / IVA regulations that would have an adverse effect on my hobby (building and enjoying replica kit cars) and the industry that employs many people manufacturing the kits for sale.
Road vehicles: improving air quality and safety
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.
I understand that this is hoped for implementation in July this year. This will impact:
Kit cars currently in build - it is not unusual for builds to take place over several years and an engine purchase is an early part of the process. If an older engine is in someone's car that cannot be finished before this July, the car will not be able to be submitted for IVA. An unfair cost for such people that could be removed by delayed implementation of any such rules for kits / engines already purchased.
Replica type kits (such as classic Jaguar / Lotus / Porsche replicas) which have been designed round older engine designs and chassis of which may well not safely be able to accommodate catalytic converters (and the associated heat generated by these components). This could see people with cars in build not being able to complete their cars, negating their investments in time and money) and the manufacturers seeing revenue streams removed, quite possibly threatening their existence.
The numbers of kit built cars is small compared to mass produced vehicles, so the impact on overall emissions of any easing of implementation / regulations would be small - but the loss to each individual car builder and supplier could be many thousands of pounds.
The wording of this point threatens kit cars already IVA / SVA tested and legally on the road with older engines. It suggests that for all such vehicles, "the emission standards current at the rate of registration will be required". It is not usual for new regulations to remove older vehicles. Unless clarification that this rule is to be for newly IVA certificated vehicles only, the older cars will not be able to pass MOTs with more owners seeing their vehicles dreadfully devalued.
Britain has a long heritage of self built cars, some of which have led to the formation of very famous and valuable companies such as Jaguar, Lotus and McLaren. Could the above points please be considered and not overlooked in an apparent haste to push through this legislation?"
I'll probably be addressing a similar e-mail to my MP in the near future.
I have already e-mailed - see below:
"I have become aware of some consultations regarding vehicle MOT / IVA regulations that would have an adverse effect on my hobby (building and enjoying replica kit cars) and the industry that employs many people manufacturing the kits for sale.
Road vehicles: improving air quality and safety
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.
I understand that this is hoped for implementation in July this year. This will impact:
Kit cars currently in build - it is not unusual for builds to take place over several years and an engine purchase is an early part of the process. If an older engine is in someone's car that cannot be finished before this July, the car will not be able to be submitted for IVA. An unfair cost for such people that could be removed by delayed implementation of any such rules for kits / engines already purchased.
Replica type kits (such as classic Jaguar / Lotus / Porsche replicas) which have been designed round older engine designs and chassis of which may well not safely be able to accommodate catalytic converters (and the associated heat generated by these components). This could see people with cars in build not being able to complete their cars, negating their investments in time and money) and the manufacturers seeing revenue streams removed, quite possibly threatening their existence.
The numbers of kit built cars is small compared to mass produced vehicles, so the impact on overall emissions of any easing of implementation / regulations would be small - but the loss to each individual car builder and supplier could be many thousands of pounds.
The wording of this point threatens kit cars already IVA / SVA tested and legally on the road with older engines. It suggests that for all such vehicles, "the emission standards current at the rate of registration will be required". It is not usual for new regulations to remove older vehicles. Unless clarification that this rule is to be for newly IVA certificated vehicles only, the older cars will not be able to pass MOTs with more owners seeing their vehicles dreadfully devalued.
Britain has a long heritage of self built cars, some of which have led to the formation of very famous and valuable companies such as Jaguar, Lotus and McLaren. Could the above points please be considered and not overlooked in an apparent haste to push through this legislation?"
I'll probably be addressing a similar e-mail to my MP in the near future.
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jonclancy
- Posts: 943
- Joined: Tue Nov 01, 2011 9:30 pm
Re: Potentially the end of the A series Eleven build....
Just drafting a response to the consultation address and copying to my MP, James Gray.
Just because some corporate criminals decided to defraud their customers and hoodwink the authorities shouldn’t mean we get the splintery bat!
In any case, it isn’t really consistant legislation where our classic and specialist cars are concerned. No MOT required for some old jalopy nowadays, but won’t be able to enjoy motoring in a replica build with period and new parts.
This proposal, in consideration with the DVLA rules, is neither consistent nor coherent.
Just because some corporate criminals decided to defraud their customers and hoodwink the authorities shouldn’t mean we get the splintery bat!
In any case, it isn’t really consistant legislation where our classic and specialist cars are concerned. No MOT required for some old jalopy nowadays, but won’t be able to enjoy motoring in a replica build with period and new parts.
This proposal, in consideration with the DVLA rules, is neither consistent nor coherent.
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jonclancy
- Posts: 943
- Joined: Tue Nov 01, 2011 9:30 pm
Re: Potentially the end of the A series Eleven build....
Copied from PH
Complete Kit Car have just posted on their FB page this is a part of it.....
..........................Peter Bailey, of Chesil Motor Company has spoken to Mike Lowe who told him: “…if the consensus of the opinion is that this will kill the British kit car industry, we are very much open to listening and asking Ministers if we can remove this proposal from the package of proposals.”
Peter has put together the following guidelines for how you might like to structure any written response. Please feel free to use these guidelines, or do your own thing. Over to Peter…
As you are now hopefully aware, there is new legislation in the pipeline that could greatly affect our industry. I for one would not be here at Chesil if these proposals were introduced, as we fit air-cooled engines (that have no real alternative) and would be very difficult to get to pass the proposed emissions… but on top of that, it is not what our customers want.
It does seem, having spoken to the DfT just now, that if there is sufficient pressure and clear, genuine reasons why this part of the legislation could be ‘catastrophic’ to our industry, there is a fair chance it could be removed from the proposals, but it is up to all of us to respond!
I am suggesting that all manufacturers write, giving their own individual case, and also that we all collectively send a response from the industry as a whole.
Below are some suggestions as to the content of your response:
1. Does your vehicle, particularly if it is a replica, need to have an earlier style engine to retain the character of your car? If so, explain why this is so important, and how difficult it would be to implement emission controls.
2. Would fitting a more modern engine detract from the original character of the car, and therefore its saleability? Would customers be put off buying it? Explain why.
3. If an alternative could be fitted, would it increase the build cost, which too could be detrimental to sales? Give a realistic indication of cost increase, perhaps as a percentage.
4. Would there be existing customers who could get ‘caught out’ by this legislation as their build completion would be beyond the implementation date? Give an example and perhaps how many customers you have in this situation.
5. If this legislation were implemented, could it possibly affect your business sufficiently that you might have to ‘close your doors’? If so, give good sound reasons why.
Responses should be sent to…
ivs.consult@dft.gsi.gov.uk or
Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
London SW1P 4DR
Below is Peter’s proposal for a group response from manufacturers/traders. If you are happy to have your name and company added to this list, we are happy to collate them here and send it on your behalf. To be included, please email adam@performancepublishing.co.uk BEFORE Wednesday 28 February.
A Collective Response – from kit car manufacturers and traders
As small scale manufacturers of specialist and kit cars, we would like to collectively respond to the proposed legislation, in particular regarding to the changes to the emissions requirement.
We are not a big industry, but we are unique within Europe and in fact in the world, having produced thousands of specialist cars over the last 50 years, and have become established as the world centre for this type of car.
The introduction of SVA and then IVA allowed our industry to produce vehicles to a recognised safe standard – a fact borne out by the low insurance premiums that our vehicle owners enjoy.
We would very much like our industry to continue, but these current proposals could be catastrophic to some, and many we are sure would have to close. This is not an excessive expectation, but a reality. As many have individually explained, it is the proposed change to MoT emissions standards for kit cars that would be very damaging to our cars… the older style of engines perhaps being vital to the core appeal of the model, and/or the potential costs of fitting compliant engines being so expensive as to cause sales to fall to unsustainable levels.
Many of us have small workshops and not a vast workforce, but we all have many times that number indirectly employed who have specialist skills and rely on our continued, and regular, work.
As you will notice, on a day-to-day basis there are very few classic cars on the roads, often reserved for special occasions, days out and perhaps limited touring during the summer months. It is not uncommon for these cars to have limited mileage insurance, typically 2000-6000 miles per year, with many not covering more than 1000 miles annually. The emissions impact by this small ‘fleet’ of cars is also tiny and does not warrant the heavy-handed controls that are being considered.
We all hope that you now have a better picture of our industry and its precarious position if this legislation became enacted.
We strongly request that this part of the proposed new legislation be dropped.
The following companies and individuals have agreed to their names being added to this letter…
Clubs and individual owners
Complete Kit Car has had contact from a number of clubs expressing concern at the proposals. Hopefully the information we have provided above will clarify the situation. We understand some clubs will be more impacted by the proposals than others, and may wish to make their own representation to the contact details listed above.
Complete Kit Car have just posted on their FB page this is a part of it.....
..........................Peter Bailey, of Chesil Motor Company has spoken to Mike Lowe who told him: “…if the consensus of the opinion is that this will kill the British kit car industry, we are very much open to listening and asking Ministers if we can remove this proposal from the package of proposals.”
Peter has put together the following guidelines for how you might like to structure any written response. Please feel free to use these guidelines, or do your own thing. Over to Peter…
As you are now hopefully aware, there is new legislation in the pipeline that could greatly affect our industry. I for one would not be here at Chesil if these proposals were introduced, as we fit air-cooled engines (that have no real alternative) and would be very difficult to get to pass the proposed emissions… but on top of that, it is not what our customers want.
It does seem, having spoken to the DfT just now, that if there is sufficient pressure and clear, genuine reasons why this part of the legislation could be ‘catastrophic’ to our industry, there is a fair chance it could be removed from the proposals, but it is up to all of us to respond!
I am suggesting that all manufacturers write, giving their own individual case, and also that we all collectively send a response from the industry as a whole.
Below are some suggestions as to the content of your response:
1. Does your vehicle, particularly if it is a replica, need to have an earlier style engine to retain the character of your car? If so, explain why this is so important, and how difficult it would be to implement emission controls.
2. Would fitting a more modern engine detract from the original character of the car, and therefore its saleability? Would customers be put off buying it? Explain why.
3. If an alternative could be fitted, would it increase the build cost, which too could be detrimental to sales? Give a realistic indication of cost increase, perhaps as a percentage.
4. Would there be existing customers who could get ‘caught out’ by this legislation as their build completion would be beyond the implementation date? Give an example and perhaps how many customers you have in this situation.
5. If this legislation were implemented, could it possibly affect your business sufficiently that you might have to ‘close your doors’? If so, give good sound reasons why.
Responses should be sent to…
ivs.consult@dft.gsi.gov.uk or
Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
London SW1P 4DR
Below is Peter’s proposal for a group response from manufacturers/traders. If you are happy to have your name and company added to this list, we are happy to collate them here and send it on your behalf. To be included, please email adam@performancepublishing.co.uk BEFORE Wednesday 28 February.
A Collective Response – from kit car manufacturers and traders
As small scale manufacturers of specialist and kit cars, we would like to collectively respond to the proposed legislation, in particular regarding to the changes to the emissions requirement.
We are not a big industry, but we are unique within Europe and in fact in the world, having produced thousands of specialist cars over the last 50 years, and have become established as the world centre for this type of car.
The introduction of SVA and then IVA allowed our industry to produce vehicles to a recognised safe standard – a fact borne out by the low insurance premiums that our vehicle owners enjoy.
We would very much like our industry to continue, but these current proposals could be catastrophic to some, and many we are sure would have to close. This is not an excessive expectation, but a reality. As many have individually explained, it is the proposed change to MoT emissions standards for kit cars that would be very damaging to our cars… the older style of engines perhaps being vital to the core appeal of the model, and/or the potential costs of fitting compliant engines being so expensive as to cause sales to fall to unsustainable levels.
Many of us have small workshops and not a vast workforce, but we all have many times that number indirectly employed who have specialist skills and rely on our continued, and regular, work.
As you will notice, on a day-to-day basis there are very few classic cars on the roads, often reserved for special occasions, days out and perhaps limited touring during the summer months. It is not uncommon for these cars to have limited mileage insurance, typically 2000-6000 miles per year, with many not covering more than 1000 miles annually. The emissions impact by this small ‘fleet’ of cars is also tiny and does not warrant the heavy-handed controls that are being considered.
We all hope that you now have a better picture of our industry and its precarious position if this legislation became enacted.
We strongly request that this part of the proposed new legislation be dropped.
The following companies and individuals have agreed to their names being added to this letter…
Clubs and individual owners
Complete Kit Car has had contact from a number of clubs expressing concern at the proposals. Hopefully the information we have provided above will clarify the situation. We understand some clubs will be more impacted by the proposals than others, and may wish to make their own representation to the contact details listed above.
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biggles
- Posts: 316
- Joined: Tue Apr 10, 2012 8:10 am
Re: Potentially the end of the A series Eleven build....
Good points there. I’ll be adding to those as follows:
1/ it is completely false to assume that any older engine can just be replaced by a newer, emissions compliant version, or that any post 1992 catalysed engine can conform to the most modern emissions standards. Over the last 25 years or so the typical car engine has changed dramatically in terms of engine architecture and also has many attached components to tune the emissions. The major effect has been an increase in height, and also to have engine bays crammed with components. These packaging problems are minor to a large manufacturer, at the design stage, with a large development budget, but would be too difficult and/or expensive for self builders or small firms to overcome when adapting modern engines to fit what are often small, more sporty home constructed cars.
2/ The legislation proposed is inconsistent with DVLA's interpretation of a kit converted vehicle in that DVLA allows a car built largely from components taken from one vehicle to retain the age related identity and registration from that vehicle. Therefore if DVLA is satisfied that an older car has in a nutshell been rebuilt into another form via a kit conversion, why should that car now have to conform to updated emissions requirements that it was never designed to fulfill.
3/ A side effect of effectively banning kit conversions of older vehicles would be that prospective builders of older style cars will just restore a classic car and use it rather than building a replica or hotrod from it. For example older Rovers, Jaguars, MGs, Minis and such which are popular 'donor' vehicles but also are classics in their own right, would remain extant in original form. Therefore the same engines would still be on the road producing the same emissions. However in many cases, these would be older 'historic cars', and therefore subject to no MOT testing at all, whereas if these same engines found their way, via an IVA test, into a kitcar or hotrod, an annual MOT test would at least police basic emissions standards.
4/ It cannot be stressed enough that we are talking here about small numbers of very well looked after, largely petrol powered, well maintained cars, that are by and large used for occasional recreational driving in non built up areas. Effectively banning all older style kitcars from the road on emissions grounds is a sledgehammer to crack an almost non existent nut and will produce no measurable improvement in emissions, and drive a lot of small firms out of business.
Cheers all, Tim
1/ it is completely false to assume that any older engine can just be replaced by a newer, emissions compliant version, or that any post 1992 catalysed engine can conform to the most modern emissions standards. Over the last 25 years or so the typical car engine has changed dramatically in terms of engine architecture and also has many attached components to tune the emissions. The major effect has been an increase in height, and also to have engine bays crammed with components. These packaging problems are minor to a large manufacturer, at the design stage, with a large development budget, but would be too difficult and/or expensive for self builders or small firms to overcome when adapting modern engines to fit what are often small, more sporty home constructed cars.
2/ The legislation proposed is inconsistent with DVLA's interpretation of a kit converted vehicle in that DVLA allows a car built largely from components taken from one vehicle to retain the age related identity and registration from that vehicle. Therefore if DVLA is satisfied that an older car has in a nutshell been rebuilt into another form via a kit conversion, why should that car now have to conform to updated emissions requirements that it was never designed to fulfill.
3/ A side effect of effectively banning kit conversions of older vehicles would be that prospective builders of older style cars will just restore a classic car and use it rather than building a replica or hotrod from it. For example older Rovers, Jaguars, MGs, Minis and such which are popular 'donor' vehicles but also are classics in their own right, would remain extant in original form. Therefore the same engines would still be on the road producing the same emissions. However in many cases, these would be older 'historic cars', and therefore subject to no MOT testing at all, whereas if these same engines found their way, via an IVA test, into a kitcar or hotrod, an annual MOT test would at least police basic emissions standards.
4/ It cannot be stressed enough that we are talking here about small numbers of very well looked after, largely petrol powered, well maintained cars, that are by and large used for occasional recreational driving in non built up areas. Effectively banning all older style kitcars from the road on emissions grounds is a sledgehammer to crack an almost non existent nut and will produce no measurable improvement in emissions, and drive a lot of small firms out of business.
Cheers all, Tim
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Simon Marks
- Posts: 66
- Joined: Sun Mar 29, 2015 2:05 pm
Re: Potentially the end of the A series Eleven build....
I've filled in the survey that is mentioned in the "Consultation" Document - http://www.smartsurvey.co.uk/s/road-emissions/ The important questions for us with existing cars threatened by the imposition of "date of registration" emissions tests is Question 15. "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?"
I've replied as follows:
"I have built and finished a car in 2016 that is based around a 1973 vehicle. It has passed its IVA and is on the road for between 1,000 and 2,000 miles each year. It would not be easy to re-engine (modern twin cam engines are much taller than the engine in my car so will not fit below the bonnet). There would also be the problem of where to safely site a catalytic converter. The engine that I remove would be severely devalued so the total cost to me would be in excess of £5,000. Of course, if I was not able to find a satisfactory solution, what value would my current £25,000 + car retain? Very little, I suggest.
I believe that legislating existing vehicles off the road is without precedent and I strongly disagree with starting now! Such kit cars are not common and the contribution to the overall emissions burden of the national fleet is tiny"
I'm holding off writing to my MP for a few days to incorporate all the good points that are coming out with almost every post.
Simon
PS - Aplogies for calling you Simon, Tim - a case of pilot confusion, I'm afraid
Simon
I've replied as follows:
"I have built and finished a car in 2016 that is based around a 1973 vehicle. It has passed its IVA and is on the road for between 1,000 and 2,000 miles each year. It would not be easy to re-engine (modern twin cam engines are much taller than the engine in my car so will not fit below the bonnet). There would also be the problem of where to safely site a catalytic converter. The engine that I remove would be severely devalued so the total cost to me would be in excess of £5,000. Of course, if I was not able to find a satisfactory solution, what value would my current £25,000 + car retain? Very little, I suggest.
I believe that legislating existing vehicles off the road is without precedent and I strongly disagree with starting now! Such kit cars are not common and the contribution to the overall emissions burden of the national fleet is tiny"
I'm holding off writing to my MP for a few days to incorporate all the good points that are coming out with almost every post.
Simon
PS - Aplogies for calling you Simon, Tim - a case of pilot confusion, I'm afraid
Simon
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biggles
- Posts: 316
- Joined: Tue Apr 10, 2012 8:10 am
Re: Potentially the end of the A series Eleven build....
No worries,Simon!
It needs pointing out that that you don’t have to fill out the questionnaire and respond to the whole body of proposed legislation. You can just email your comments about section 4 (our relevant section) to the email address quoted above, ivs.consult@dft.gsi.gov.uk
Cheers all, Tim
It needs pointing out that that you don’t have to fill out the questionnaire and respond to the whole body of proposed legislation. You can just email your comments about section 4 (our relevant section) to the email address quoted above, ivs.consult@dft.gsi.gov.uk
Cheers all, Tim
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biggles
- Posts: 316
- Joined: Tue Apr 10, 2012 8:10 am
Re: Potentially the end of the A series Eleven build....
Anyone had any response/any developments?
I wrote to John Bercow (the Speaker of the House) who is my MP. He is writing to the Transport Secretary to address my points, apparently. Whether anything meaningful comes back is another matter but we can but try!
I wrote to John Bercow (the Speaker of the House) who is my MP. He is writing to the Transport Secretary to address my points, apparently. Whether anything meaningful comes back is another matter but we can but try!
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jonclancy
- Posts: 943
- Joined: Tue Nov 01, 2011 9:30 pm
Re: Potentially the end of the A series Eleven build....
I wrote to Robert Lloyd-Smith of the DfT, and my MP (James Gray).
Mr Gray wrote back to me today. He stated he supported a thriving UK car industry, including new, cleaner and safer cars, and the restoration of classic cars and building of new kit cars. He kindly included a link to the survey.
Although he did not mention classic replicas specifically (though I did so in my letter), his view appeared supportive, though he stated he could not preempt the outcome of the consultation.
Guess I'll have to wait until the Summer to see if I can use my A series from my Midget in my Project X...
Mr Gray wrote back to me today. He stated he supported a thriving UK car industry, including new, cleaner and safer cars, and the restoration of classic cars and building of new kit cars. He kindly included a link to the survey.
Although he did not mention classic replicas specifically (though I did so in my letter), his view appeared supportive, though he stated he could not preempt the outcome of the consultation.
Guess I'll have to wait until the Summer to see if I can use my A series from my Midget in my Project X...
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biggles
- Posts: 316
- Joined: Tue Apr 10, 2012 8:10 am
Re: Potentially the end of the A series Eleven build....
Complete Kitcar magazine's Facebook page is reporting that the emissions change for kitcars has been dropped. Hopefully it is business as usual in the classic replica world!
Hope those of you going to Stoneleigh have a good weekend. I’m working worse luck....
Hope those of you going to Stoneleigh have a good weekend. I’m working worse luck....