New MOT emissions regs for kit cars
Discussion
Hi all,
I've just read this article(www.totalkitcar.com/tkc_article_252.shtml) that is talking about a tightening of the rules regarding MOT for kits.
I'm not totally up to speed on what some of it means - does anybody have any idea what it might mean for the car I'm building (R1 engined Fury)? My plan has been to get a new reg for it, and I know I'll have to put a cat in for SVA. Does this mean that I'll now have to do the Elise trick of sticking the cat back in for every MOT as well?
Cheers,
Will
I've just read this article(www.totalkitcar.com/tkc_article_252.shtml) that is talking about a tightening of the rules regarding MOT for kits.
I'm not totally up to speed on what some of it means - does anybody have any idea what it might mean for the car I'm building (R1 engined Fury)? My plan has been to get a new reg for it, and I know I'll have to put a cat in for SVA. Does this mean that I'll now have to do the Elise trick of sticking the cat back in for every MOT as well?
Cheers,
Will
It doesn't bode well at all!
As I understand it, the MOT tester will look at the number plate and take that as the year of manufacture unless he has reason to believe otherwise (like a very old private plate). This means that everyone who got a "new" registration for their kit since 1998 will get lumbered with a catalyst emissions test for the rest of the vehicle's life. If I was in that position, I might consider getting a cheap "private" plate from just before 1998!) If the car was SVA'd after 1998 and was on an "age-related" plate, you should also be OK for a non-cat test for whatever age the number plate suggests the vehicle is. In case of doubt, the onus will be on the PRESENTER to prove the age of the engine. A copy of the Minister's Approval Certificate will do this (the emissions category is part of the code on the certificate). Failing that, I guess a copy fo the V5 from the donor car the engine came out of would be a good bet if the engine number is still clearly visible.
My biggest fear is that they will "wise up" to the age of the car not necessarily being the age of the number plate sooner or later. Once the MOT stations get computerised, the VIN number (or chassis number) will tell the tester exactly when the car was SVA'd and what emissions test it had to pass at the time. Whent that day comes, life really will get difficult!
As I understand it, the MOT tester will look at the number plate and take that as the year of manufacture unless he has reason to believe otherwise (like a very old private plate). This means that everyone who got a "new" registration for their kit since 1998 will get lumbered with a catalyst emissions test for the rest of the vehicle's life. If I was in that position, I might consider getting a cheap "private" plate from just before 1998!) If the car was SVA'd after 1998 and was on an "age-related" plate, you should also be OK for a non-cat test for whatever age the number plate suggests the vehicle is. In case of doubt, the onus will be on the PRESENTER to prove the age of the engine. A copy of the Minister's Approval Certificate will do this (the emissions category is part of the code on the certificate). Failing that, I guess a copy fo the V5 from the donor car the engine came out of would be a good bet if the engine number is still clearly visible.
My biggest fear is that they will "wise up" to the age of the car not necessarily being the age of the number plate sooner or later. Once the MOT stations get computerised, the VIN number (or chassis number) will tell the tester exactly when the car was SVA'd and what emissions test it had to pass at the time. Whent that day comes, life really will get difficult!
do the sva testers go be the age of the engine or the donor car then? cos im planning on transplanting an bike engine into my donor (hopefully just on paper rather than actually putting the engine in the car) so i can have an age related plate. the engine is 1997 and the car will be late 80's early 90's ish, so if they go by the engine i may need a cat, but the engine doesnt have one in the first place so i may be ok either way. this is confusing. 
yep if your engine is post-Aug-95 then you have to pass the full emissions test. the chances are that you will have to fit a cat in order to achieve the required level. this is not beyond the realms of possibility - you can rent-a-cat.
but if you are just transplanting an engine into a donor, then you won't be re-registering, and won't be taking the SVA test, you can just change the engine number at DVLA. or am I missing something?
moomin
but if you are just transplanting an engine into a donor, then you won't be re-registering, and won't be taking the SVA test, you can just change the engine number at DVLA. or am I missing something?
moomin
Well Moomin, if I might answer a question with a question:
Why shouldn't they????
I mean, you're not going to come out with the environmental argument are you?
Kit cars are probably about as green as cars get. They do very few miles, they generally don't do those miles in city centres, they are largely built out of re-cycled components, and usually built by hand rather than on an automated line AND there's very few of them!
True, many of them have whopping great engines but they generally don't weigh much and their largest single emission is likely to be CO2 - which won't be too dissimilar (per mile) to a similarly powered brand new car with a cat.
As far as the engine age vs car age issue goes, I'm not sure about this. I think anyone intending to "swap" a donor engine on paper runs the risk of being caught. When the DVLA get an amended V5 showing a different engine number / capacity, they might ask the local Vehicle Registration Office to inspect it to make sure the new engine details are correct. This is very common if the capacity has gone down taking the donor into a different road tax band. Lots of people are currently trying this "scam" on ordinary cars (nothing to do with kits) to get themselves cheaper road tax.
Why shouldn't they????
I mean, you're not going to come out with the environmental argument are you?
Kit cars are probably about as green as cars get. They do very few miles, they generally don't do those miles in city centres, they are largely built out of re-cycled components, and usually built by hand rather than on an automated line AND there's very few of them!
True, many of them have whopping great engines but they generally don't weigh much and their largest single emission is likely to be CO2 - which won't be too dissimilar (per mile) to a similarly powered brand new car with a cat.
As far as the engine age vs car age issue goes, I'm not sure about this. I think anyone intending to "swap" a donor engine on paper runs the risk of being caught. When the DVLA get an amended V5 showing a different engine number / capacity, they might ask the local Vehicle Registration Office to inspect it to make sure the new engine details are correct. This is very common if the capacity has gone down taking the donor into a different road tax band. Lots of people are currently trying this "scam" on ordinary cars (nothing to do with kits) to get themselves cheaper road tax.
Hi Doy.
I totally agree with the points you make, but wonder why should it be any different to if I owned say a Lotus Elise as a second car? That would have meet the emissions regs appropriate for the age of it's engine, but similarly might only do a few thousand miles per year. It is also probably more efficient (yes in the environmental sense - since that is what the test is all about) than your average kit car engine.
Sure I would like not to have to do the test as much as the next person, but I am not going to stress myself about it too much. At the end of the day, as long as we (as kit car builders/owners) are clear on what the rules are, then it is not such a big problem.
What I don't like is the inconsistency, and am slightly dubious about the application of new rules retrospectively.
Moomin
Edited to make better use of English language.
>> Edited by moomin on Saturday 5th April 13:25
I totally agree with the points you make, but wonder why should it be any different to if I owned say a Lotus Elise as a second car? That would have meet the emissions regs appropriate for the age of it's engine, but similarly might only do a few thousand miles per year. It is also probably more efficient (yes in the environmental sense - since that is what the test is all about) than your average kit car engine.
Sure I would like not to have to do the test as much as the next person, but I am not going to stress myself about it too much. At the end of the day, as long as we (as kit car builders/owners) are clear on what the rules are, then it is not such a big problem.
What I don't like is the inconsistency, and am slightly dubious about the application of new rules retrospectively.
Moomin
Edited to make better use of English language.
>> Edited by moomin on Saturday 5th April 13:25
Hi Moomin,
Actually, "Doy" was me but I forgot I was on someone else's computer when I wrote it!
I think the difference is that Lotus or TVR could claim to have more resources than a kit car company. Ford and Vauxhall, in turn, would have more resources than Lotus or TVR. The whole "Approval" system is stacked against the smaller guy. It costs the best part of half a million quid to get EC Whole VEhicle Type Approval. That's what it would cost Ford and that's what it would cost TVR (but it wouldn't hurt Ford as much!) The "carrot" for doing this is that you can sell as many cars as you like in any EC Member State once you've got it. UK Low Volume Type Approval only costs about £50k per model and has reduced requirements. Obviously this would be attractive so the authorities make sure you can't sell as many cars because otherwise everybody would do it and then we really would give the environment a severe kicking! As such this scheme is limited to 500 cars per year and you can only sell them in the EC country that granted the approval (although others can choose to accept the cars if they want). Finally you get SVA which costs £200 PER VEHICLE and has reduced requirements again. The idea is that if you're going to make more than about 250 cars a year it becomes financially viable to get UK Low Volume Type Approval anyway but the sums aren't quite that simple. (You're limited to 200 per year in any case).
I think it's very imortant that we keep this ladder because otherwise, we wouldn't have the CHOICE of whether to buy a kit or an Elise At present, if someone wants to minimise their "environmental footprint" and / or enjoy higher occupant protection, they buy a car with full EC approvals. If they're not as bothered, they can buy a low volume car or even a kit car. Britain has few industries it can still be proud of but motorsport is something we're very good at. I believe that a lot of this is because we have a permissive legislative system that allows people to get involved at minimal cost so they get "bitten by the bug". You don't suppose Trevor Wilkinsn or Colin Chapman or Jem Marsh would have built up their businesses if they'd only had the option of full EC type approval do you?
Yes, the tailpipe emissions of a kit car will be worse than those of a Low Volume Type Approved car which, in turn may be worse than those of a fully EC approved car but NOT BY VERY MUCH!!!! I can't remember exactly but an EC-approved car must produce less than 2.3 grammes of Carbon Monoxide per kilometre whereas it's 2.2 grammes per kilometre for a Low Volume Type Approved car. This makes it sound like the Low Volume scheme is tougher but cars in this scheme get an extra 30 seconds of warm-up time before the sampling process is started whereas the EC approved cars need to do it from cold. Also, the EC-approved cars need to emit less than 0.2g/km of unburned hydrocarbons and less than 0.15g/km of oxides of nitrogen whereas a Low volume car is allowed to produce 0.5g/km of both these pollutants added together. You can't directly compare SVA emissions limits because they're done in a very different way but suffice it to say, few SVA cars can pass a type approval emissions test but all type approved cars can pass an SVA test!
The point I'm trying to make (somewhat too lengthily!)is that in real terms there's stuff-all difference in damage to the environment if you step back and look at the "bigger picture". I mean what's the point of saying you can only emit 0.2grammes of unburned fuel per kilometre when every time you fill the car up at a petrol station you spill several hundred kilometres worth of petrol on the forecourt? 0.2 grammes isn't very big!
Mr. rep in his Mondeo might do 50,000 miles a year and Mr. enthusiast in his kit might do 5000.
Finally, I completely agree with your feelings on the necessity for clear legislation. I think that there are big problems with a lot of UK legislation but, again, looking at the bigger picture, we have a very good road death rate compared to other EC countries and we seem to be doing a reasonable job of getting out national emissions down under the Kyoto agreement so if it ain't broke - don't fix it!
The restrospective legislation bit isn't actually the case. The legislation has, for some years now, required cars to meet appropriate "in-service" emissions limits but the Vehicle Inspectorate (or "VOSA" as they now call themselves) never actually applied it to kit cars - they allowed them to do a "visible smoke" emissions test regardless of what they did in their SVA test. What has happened now isn't a change in the legislation, it's the VI waking up and realising they weren't doing it right for some time!
Actually, "Doy" was me but I forgot I was on someone else's computer when I wrote it!
I think the difference is that Lotus or TVR could claim to have more resources than a kit car company. Ford and Vauxhall, in turn, would have more resources than Lotus or TVR. The whole "Approval" system is stacked against the smaller guy. It costs the best part of half a million quid to get EC Whole VEhicle Type Approval. That's what it would cost Ford and that's what it would cost TVR (but it wouldn't hurt Ford as much!) The "carrot" for doing this is that you can sell as many cars as you like in any EC Member State once you've got it. UK Low Volume Type Approval only costs about £50k per model and has reduced requirements. Obviously this would be attractive so the authorities make sure you can't sell as many cars because otherwise everybody would do it and then we really would give the environment a severe kicking! As such this scheme is limited to 500 cars per year and you can only sell them in the EC country that granted the approval (although others can choose to accept the cars if they want). Finally you get SVA which costs £200 PER VEHICLE and has reduced requirements again. The idea is that if you're going to make more than about 250 cars a year it becomes financially viable to get UK Low Volume Type Approval anyway but the sums aren't quite that simple. (You're limited to 200 per year in any case).
I think it's very imortant that we keep this ladder because otherwise, we wouldn't have the CHOICE of whether to buy a kit or an Elise At present, if someone wants to minimise their "environmental footprint" and / or enjoy higher occupant protection, they buy a car with full EC approvals. If they're not as bothered, they can buy a low volume car or even a kit car. Britain has few industries it can still be proud of but motorsport is something we're very good at. I believe that a lot of this is because we have a permissive legislative system that allows people to get involved at minimal cost so they get "bitten by the bug". You don't suppose Trevor Wilkinsn or Colin Chapman or Jem Marsh would have built up their businesses if they'd only had the option of full EC type approval do you?
Yes, the tailpipe emissions of a kit car will be worse than those of a Low Volume Type Approved car which, in turn may be worse than those of a fully EC approved car but NOT BY VERY MUCH!!!! I can't remember exactly but an EC-approved car must produce less than 2.3 grammes of Carbon Monoxide per kilometre whereas it's 2.2 grammes per kilometre for a Low Volume Type Approved car. This makes it sound like the Low Volume scheme is tougher but cars in this scheme get an extra 30 seconds of warm-up time before the sampling process is started whereas the EC approved cars need to do it from cold. Also, the EC-approved cars need to emit less than 0.2g/km of unburned hydrocarbons and less than 0.15g/km of oxides of nitrogen whereas a Low volume car is allowed to produce 0.5g/km of both these pollutants added together. You can't directly compare SVA emissions limits because they're done in a very different way but suffice it to say, few SVA cars can pass a type approval emissions test but all type approved cars can pass an SVA test!
The point I'm trying to make (somewhat too lengthily!)is that in real terms there's stuff-all difference in damage to the environment if you step back and look at the "bigger picture". I mean what's the point of saying you can only emit 0.2grammes of unburned fuel per kilometre when every time you fill the car up at a petrol station you spill several hundred kilometres worth of petrol on the forecourt? 0.2 grammes isn't very big!
Mr. rep in his Mondeo might do 50,000 miles a year and Mr. enthusiast in his kit might do 5000.
Finally, I completely agree with your feelings on the necessity for clear legislation. I think that there are big problems with a lot of UK legislation but, again, looking at the bigger picture, we have a very good road death rate compared to other EC countries and we seem to be doing a reasonable job of getting out national emissions down under the Kyoto agreement so if it ain't broke - don't fix it!
The restrospective legislation bit isn't actually the case. The legislation has, for some years now, required cars to meet appropriate "in-service" emissions limits but the Vehicle Inspectorate (or "VOSA" as they now call themselves) never actually applied it to kit cars - they allowed them to do a "visible smoke" emissions test regardless of what they did in their SVA test. What has happened now isn't a change in the legislation, it's the VI waking up and realising they weren't doing it right for some time!
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