This is a read-only archive of the old Madabout Kitcars forum. New posts and replies are no longer possible, but every thread is still here to browse and read.
Not sure why but, the Question 10 on kitcars in the proposal becomes question 15 in the survey.
I have just completed my feedback and for sections I was not interested in, I just typed 'Not reviewed'. For the Kitcar question I cut and pasted my response above in the box.
It's an easy and a relatively quick way of providing feedback.
Peterux - Thanks for the vote of confidence in my ability to pick the bones out of the legal side of things, but then I was doing that for a living until last year.
I've stayed out of this debate so far as I'd always vowed not to build a car that needed IVA due to the significant extra expense and bizarre regulations that you have to comply with. I mean, rounded instrument bezels? What is that all about? If your face hits the rev counter in your Caterfield Se7en then you've got more to worry about than a cut chin.
But, I have to say I do have some concerns over these changes as they could represent a slippery slope towards retrospective regulation of existing cars or be applied to re-bodied classics that I do like to build.
I haven't yet read through all the proposals, but from what I've seen so far I think the focus should be on two areas:
1 - Clarification of what the changes actually mean for our hobby and some specialist businesses (anyone building turn-key DBR2's, SS100's or C Types in the £50k to £120k bracket, for example);
2 - Ensure that the legislators are made aware of how little impact our impractical, sunny days and holidays, limited mileage cars have on the environment, especially inner city air quality which is the hot textured tofu du jour.
As such, I would avoid any kind of rant in response and also any phrases suggesting that thousands of cars will be affected. That may well be counter-productive, giving ammunition to whoever dreamt up these changes.
Instead, a FOI subject access request could be made to DVLA to establish how many specialist cars are registered in the UK, and how many miles are driven in them each year as recorded on their MOT returns. That could then be presented as proof that introducing such legislation is a waste of taxpayers' money as the benefits would clearly be minimal when compared to the costs involved.
In fact, given that our cars are 99% petrol powered and it's now universally accepted that diesels do most of the damage to inner city air quality, I wouldn't be surprised if the particulate, CO2 and Nitrogen Oxides output of our entire hobby's cars each year is less than that of a single London Black cab, which counts as environmentally 'friendly' public transport.
I'll have a read of the proposals later and get back on here if I think I can contribute anything useful to the debate.
As such, I would avoid any kind of rant in response and also any phrases suggesting that thousands of cars will be affected. That may well be counter-productive, giving ammunition to whoever dreamt up these changes.
Instead, a FOI subject access request could be made to DVLA to establish how many specialist cars are registered in the UK, and how many miles are driven in them each year as recorded on their MOT returns. That could then be presented as proof that introducing such legislation is a waste of taxpayers' money as the benefits would clearly be minimal when compared to the costs involved.
If you use an average figure of 3000 miles per year for kit car annual mileage then that represents 0.0005% of the 323.7 billion miles driven on Britain's roads in 2016 (https://www.racfoundation.org/motoring-faqs/mobility#a25)
Personally I don't think such a pitiful improvement is worth anyone at Realm, Suffolk, Chesil etc losing their job.
Neil
P.S. I've just sent in my response to the Consultation questions...must admit I couldn't help myself when I reached question [COLOR="black"]Q45. What are your views on our analysis of costs and benefits? Give supporting evidence wherever possible:[/COLOR] My views included "a waste of time for the projected benefits which would not be tolerated in my former employment".
Well, I've finally finished the survey and certainly tried my best to build a case for kit cars, hot rods and non-VHI classic cars that are/will be covered by BIVA.
This has appeared today on the Complete Kit Car magazine facebook page.....
We've just received a call from the Department for Transport confirming that they will not proceed with the part of the emissions regulation proposals that affected kit cars. There were over 2000 responses to the consultation.
A Department for Transport spokesperson said:
“The UK’s specialist vehicle industry is thriving – it creates jobs and gives enjoyment to many, with products exported all over the world.
“We are grateful to the over 2000 kit and replica car enthusiasts, manufacturers and suppliers who took part in this consultation. Following their responses, we have decided that there will be no changes to the current MOT–style testing of kit car emissions.”
This is from Complete Kit Car magazine's facebook page:
We've just received a call from the Department for Transport confirming that they will not proceed with the part of the emissions regulation proposals that affected kit cars. There were over 2000 responses to the consultation.
A Department for Transport spokesperson said:
“The UK’s specialist vehicle industry is thriving – it creates jobs and gives enjoyment to many, with products exported all over the world.
“We are grateful to the over 2000 kit and replica car enthusiasts, manufacturers and suppliers who took part in this consultation. Following their responses, we have decided that there will be no changes to the current MOT–style testing of kit car emissions.”
This is from Complete Kit Car magazine's facebook page:
We've just received a call from the Department for Transport confirming that they will not proceed with the part of the emissions regulation proposals that affected kit cars. There were over 2000 responses to the consultation.
A Department for Transport spokesperson said:
“The UK’s specialist vehicle industry is thriving – it creates jobs and gives enjoyment to many, with products exported all over the world.
“We are grateful to the over 2000 kit and replica car enthusiasts, manufacturers and suppliers who took part in this consultation. Following their responses, we have decided that there will be no changes to the current MOT–style testing of kit car emissions.”
Official consultation response now published in full online. No changes to existing BIVA arrangements for kit cars, so all good news. Just needs them to sort out the MOT confusion now (introduced in the changes on the 20th May).
This is a great result and for once shows the power of collective lobbying.
If you read the whole report you get the gist how they were overwhelmed by, email, letters and responses to the questionnaire from the kit car community.
For anyone not wishing to read the whole report here is the important summary from Jesse Norman MP.
Our proposal to implement stricter emissions rules for kit cars was a minor part of the package. But it raised serious concerns among kit car enthusiasts, and attracted the vast majority of the 2340 responses received. There were numerous objections, pointing out among other things the importance and value of the UK’s specialist vehicle industry. We have reflected on these concerns and have decided not to proceed with this aspect of the proposal.
And in the relevant section....
2.39 Respondents argued fitting catalytic converters and more modern engines to kit cars would lead to negligible positive impact on the environment, given the low proportion of kit cars in the fleet, the low average mileages travelled and low proportion of travel in urban areas. On the other hand respondents cited the expected enormous negative impact on the industry, with concerns around harming authenticity, increasing cost, packaging difficulties and technical issues with using modern engines with immobilisers designed for a specific application.
2.40 In addition, a lot of respondents argued that a change of this nature could not be made quickly but would require suitable notice, because the timeline for constructing a kit car can be extensive, up to ten years and several respondents had experience of a longer period. Constructors really valued the current ability to purchase an engine of a given build date and be confident that when the vehicle was finally complete it would still be assessed against age-appropriate standards.
2.41 The potential harmful impact of the proposed changes on the industry supporting amateur builders was mentioned, with respondents pointing out that the kit car sector was part of a larger UK specialist car industry which was world leading and a source of exports.
Well done everyone who took the trouble to respond!! eace: