Pike
11-02-18, 09:22 PM
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 (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 (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
(pocorrespondence@dft.gsi.gov.uk)
Other members of DfT
https://www.gov.uk/g…/organisations/department-for-transport
(https://www.gov.uk/government/organisations/department-for-transport)
Postal Address for DfT :-
Department for Transport, Great Minster House, 33 Horseferry Road, London, SW1P4DR
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 (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 (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
(pocorrespondence@dft.gsi.gov.uk)
Other members of DfT
https://www.gov.uk/g…/organisations/department-for-transport
(https://www.gov.uk/government/organisations/department-for-transport)
Postal Address for DfT :-
Department for Transport, Great Minster House, 33 Horseferry Road, London, SW1P4DR