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Re: Road Vehicles, improving air quality and safety-Gov.UK
FWIW I completed the survey. These are my responses:
Kit cars: emissions standards for national schemes
Q16. 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?
No
Your reasons are?
It takes a many years to construct a kit car. My own project was purchased in July 2000 to suit an engine built in January 1989. I had anticipated getting it registered in the next couple of years.
The consultation document states:
The majority of the fleet is now vehicles up to 25 years old whose engines are fitted with catalytic converters, providing plenty of choice to the kit car builder.
This is untrue as compliance with the MOT emissions standards current at the date of registration is required. The majority of engines that are 25 years old certainly will not meet current standards. The current emissions standards were published 20 August 2014 and updated 1 February 2018. Engines that meet those specs would need to be manufactured very recently.
Fitting a new engine to a kit car is unlikely to be completed before the emissions standards are revised. The need to meet current emissions would effectively kill the kit car industry.
While it is true that older engines are more polluting, kit cars are unlikely to complete many miles in a year, often less than 1,000. While I support the need for new cars to meet more stringent emissions targets the use of recycled engines should be treated in a similar way to reconstructed (restored) classic cars. The appearance of the vehicle should not be a factor in emissions requirement.
The consultation document recognises in paragraph 4.7; where a vehicle converter is in possession of an incomplete vehicle or chassis the converter will be permitted to carry out a conversion without having to upgrade the engine, as this would be prohibitively expensive. I think this is a farer approach for kit cars.
Final comments
I do not think a four week consultation period is sufficient for people to react. Many builders of kit and modified cars are retired engineers.
I am a member of a kit car owners club. According to government guidelines as voluntary body and representative group affected by the policy we should have been consulted.
Finally
Perhaps I should also have mentioned that modern engines are integrated into running gear and security systems. This makes them impractical for transplanting into a different chassis.
Paul
FWIW I completed the survey. These are my responses:
Kit cars: emissions standards for national schemes
Q16. 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?
No
Your reasons are?
It takes a many years to construct a kit car. My own project was purchased in July 2000 to suit an engine built in January 1989. I had anticipated getting it registered in the next couple of years.
The consultation document states:
The majority of the fleet is now vehicles up to 25 years old whose engines are fitted with catalytic converters, providing plenty of choice to the kit car builder.
This is untrue as compliance with the MOT emissions standards current at the date of registration is required. The majority of engines that are 25 years old certainly will not meet current standards. The current emissions standards were published 20 August 2014 and updated 1 February 2018. Engines that meet those specs would need to be manufactured very recently.
Fitting a new engine to a kit car is unlikely to be completed before the emissions standards are revised. The need to meet current emissions would effectively kill the kit car industry.
While it is true that older engines are more polluting, kit cars are unlikely to complete many miles in a year, often less than 1,000. While I support the need for new cars to meet more stringent emissions targets the use of recycled engines should be treated in a similar way to reconstructed (restored) classic cars. The appearance of the vehicle should not be a factor in emissions requirement.
The consultation document recognises in paragraph 4.7; where a vehicle converter is in possession of an incomplete vehicle or chassis the converter will be permitted to carry out a conversion without having to upgrade the engine, as this would be prohibitively expensive. I think this is a farer approach for kit cars.
Final comments
I do not think a four week consultation period is sufficient for people to react. Many builders of kit and modified cars are retired engineers.
I am a member of a kit car owners club. According to government guidelines as voluntary body and representative group affected by the policy we should have been consulted.
Finally
Perhaps I should also have mentioned that modern engines are integrated into running gear and security systems. This makes them impractical for transplanting into a different chassis.
Paul
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