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Author: Subject: proposed changes to emissions testing for IVA
craigdiver

posted on 3/2/18 at 06:02 PM Reply With Quote
proposed changes to emissions testing for IVA

This is concerning...

https://www.gov.uk/government/consultations/road-vehicles-improving-air-quality-and-safety

https://www.facebook.com/groups/128498247234680/permalink/1601235803294243/



[Edited on 3/2/18 by craigdiver]





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David Jenkins

posted on 3/2/18 at 06:20 PM Reply With Quote
Not nice - but I sort-of understand what they're saying, and I must admit that I half expected it. They're currently putting huge pressure on manufacturers and car buyers to go for the lowest emission options, but letting kit builders get away with installing ancient engines that get nowhere close to the current standards.

Note that I'm saying this as the owner of a Locost with a 1970's Ford crossflow engine...





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craigdiver

posted on 3/2/18 at 06:52 PM Reply With Quote
Really, really hope that if this proposal is passed (quite likely) they are fair enough to give us builders part way through their builds a couple of years to get it finished off and through IVA.

Our kitcar builders opinions are being voiced through some of the larger kitcar/sportscar manufacturers such as westfield - will they fight the corner for the complete self-builder (build chassis from scratch) or will they jump at the opportunity to stop self-builds to increase their own sales?





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nelmo

posted on 3/2/18 at 07:23 PM Reply With Quote
I hate this sort of pointless regulation - is forcing a couple of hundred cars off the road going to save any polar bears?





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ian locostzx9rc2

posted on 3/2/18 at 07:38 PM Reply With Quote
I’m not surprised by this they where always going to tighten up the regulations kitcars will still pass this with modern engines I think everyone should remember how lucky we are to be able to build cars in this country!
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Christof

posted on 3/2/18 at 07:56 PM Reply With Quote
its not clear to me from the wording if this is retrospective in its application - i effing well hope not having recently iva’d/registered a crossflow on dcoes

going forwards id assume old engines and carbs are up against it

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craigdiver

posted on 3/2/18 at 09:37 PM Reply With Quote
quote:
Originally posted by Christof
its not clear to me from the wording if this is retrospective in its application - i effing well hope not having recently iva’d/registered a crossflow on dcoes

going forwards id assume old engines and carbs are up against it


It is vague and appears to be open to interpretation which is concerning.





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snapper

posted on 3/2/18 at 09:47 PM Reply With Quote
This a result of the blanket adoption of EU law to align UK law prior to Brexit.

Point 10 below needs to be addressed urgently and I suggest that argument is discussed urgently and not at length or we will simply miss the deadline for response.
One of the big problems with the latest engines is the complexity of the ECU and the built in security systems that require sight of dashboards, antilock brake sensors and a whole lot more that stops us from recycling cars that would just be scrapped.
There is a big conversation to be had and we don’t have much time.

10 Are you content with our proposal to require kit cars to meet the latest MOT standards, removing the current rule where vehicles are tested to MOT standards according to the age of their engine?

The consultation period begins on Friday 2 February 2018 and runs until Friday 2 March 2018. Please ensure that your response reaches us before the closing date. If you would like further copies of this consultation document, it can be found at https:// www.gov.uk/dft#consultations or you can contact us using the details below if you need alternative formats (Braille, audio CD, etc.).

Please send consultation responses to: Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
LONDON SW1P 4DR
Email to: ivs.consult@dft.gsi.gov.uk





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craigdiver

posted on 3/2/18 at 10:09 PM Reply With Quote
great work snapper,

Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?





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andyace

posted on 3/2/18 at 11:20 PM Reply With Quote
Ok not 100% sure how this effects me but it doesn't sound too good!!!

My build will certainly NOT be IVA'd this year ... I am putting together a 2.0 Pinto for it with ZX9R bike carbs

With the above changes is there any chance of my car passing the IVA emissions test or should I just throw it in the sea now !!!!!!

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PorkChop

posted on 3/2/18 at 11:58 PM Reply With Quote
quote:
Originally posted by craigdiver
great work snapper,

Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?


What precisely are you objecting to?

The whole document is talking about new IVA tests, so unless there is something I've missed, retrospective application to vehicles that already have an IVA pass doesn't seem valid.

As far as I can tell, if you have a post September 2002 engine, then this proposal makes no difference whatsoever, as you are already required to meet the most stringent MOT standard during IVA.

What I think they're proposing in effect is the removal of the CAT 1 test from the IVA and make passing the BET test (which is the first emissions test you go through) mandatory.

What seems to have been assumed by the DfT in section 4.13 is that for any powertrain that meets at least Euro 1 standards (i.e. August 1992 on), then it can meet the September 2002 MOT standards.

NB: this assumes that the registration date is not in the past. Contrary which has been posted on that FB group, this is not necessarily restricted to brand new 67 / 18 registrations. There are age related and Q plated kits with registration dates that are the same time as their IVA / registration dates.

[Edited on 4/2/18 by PorkChop]

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snapper

posted on 4/2/18 at 08:50 AM Reply With Quote
The proposal is for your cars emission requirements to not be engine age specific but to match that of the mot requirements at time of registration.
In a nutshell you’ll need a catalytic convertor, fuel injection and a very well setup ECU with emissions in mind.





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craigdiver

posted on 4/2/18 at 09:08 AM Reply With Quote
quote:
Originally posted by PorkChop
quote:
Originally posted by craigdiver
great work snapper,

Is anyone here prepared to draft a letter we could all use as a template to lodge our objections to this?


What precisely are you objecting to?


I would be objecting to its immediate implementation if it is passed. Your summary of the proposed changes is excellent (thank you) and I shouldn’t have too many issues with this (year 2000 BMW engine with cat), however, many other builders are mid-way through their builds using engine setups that are unlikely to pass these stringent emissions tests. If it is passed I would be wanting a few years before the new emissions limits come into force.





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SJ

posted on 4/2/18 at 09:11 AM Reply With Quote
It reads like this will apply to all kit cars, whether registered already or not. I hope not but if so, in my case that would mean meeting 2006 MOT standards, not 1991.

It will put a lot of cars off the road if this is the case.

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PorkChop

posted on 4/2/18 at 10:29 AM Reply With Quote
quote:
Originally posted by SJ
It reads like this will apply to all kit cars, whether registered already or not. I hope not but if so, in my case that would mean meeting 2006 MOT standards, not 1991.

It will put a lot of cars off the road if this is the case.


I honestly don't think this is the case. The proposals talk about vehicles undergoing IVA.

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PorkChop

posted on 4/2/18 at 10:46 AM Reply With Quote
quote:
Originally posted by snapper
In a nutshell you’ll need a catalytic convertor, fuel injection and a very well setup ECU with emissions in mind.


It is more than just this - even if you have a post August 1995 to pre September 2002 engine (and hence most likely have a catalyst and EFi fitted already), your targets also change with this proposal.

[Edited on 4/2/18 by PorkChop]

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MattD

posted on 4/2/18 at 11:43 AM Reply With Quote
Next step sealed Ecus & registered tuners. Mot pass map & circuit/track maps.

A full section in that doc about penalties for using emissions "defeat devices" e.g. VW/Audi ecu mods, but presume also the prolific use of decat pipes & welded up dpfs.

And if there is any added requirement for meeting EU4/5/6 standards cars might be required to have OBD ports & thus CANBus looms, etc..

[Edited on 4/2/18 by MattD]

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snapper

posted on 4/2/18 at 01:05 PM Reply With Quote
quote:
Originally posted by SJ
It reads like this will apply to all kit cars, whether registered already or not. I hope not but if so, in my case that would mean meeting 2006 MOT standards, not 1991.

It will put a lot of cars off the road if this is the case.


No it does not say that FFS

It will apply to vehicles at registration after IVA

Both my kit cars have particular emissions requirements on their V5’s which stand and will continue to

Please please read the section properly





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snapper

posted on 4/2/18 at 01:09 PM Reply With Quote
LETS PUT SOME PETSOECTIVE ON THIS

This is a consultation document
We have the opportunity to comment
It is a proposal and with any change in motoring Law is not retrospective in the same way that emissions requirement is not retrospective for older cars





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tims31

posted on 4/2/18 at 03:00 PM Reply With Quote
Personally for me at the moment this isn't a problem as mine is registered and running the standard Ford ECU with a CAT but obviously those that are in the process of building with an older engine this is a concern.

Would a zetec running say an Omex/Emerald ECU and a CAT meet the emission standards easily enough or would even that struggle?

I guess most cars running a carb would struggle.





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jps

posted on 4/2/18 at 03:55 PM Reply With Quote
I can see the point of the change, but will be writing with the following objections/comment. Of course I am entirely motivated by the fact that I don't want this to come in before I get my car finished - as I am fully intending to use a 1985 Ford Pinto engine running carbs, which I assume won't meet modern emission standards. But, incase, I have decided to try and get my car to IVA as soon as possible now!!!

1 - At best a change like this should have a reasonable lead time - say 24 months - because many people build kit cars over a reasonably long period of time - and many will have begun such projects expecting to use an engine which, under the new rules will not be allowable.
2- The actual impact from an environmental point of view of implementing this change will be minimal. Of the relatively small number of kit cars which are being built and used on the road, many already have engine which can meet modern emissions standards.
3 - Once registered many kit cars are used for a relatively small amount of miles each year (evidenced by the fact that many kit cars are insured on limited mileage policies), and therefore even those with engines tested to older standards will make little environmental impact in real terms.
4- If it is deemed necessary to implement this change, a reasonably long lead time to implementation should be considered acceptable because of 2) and 3) above.

Does this proposed change impact at all on the use of bike engines, especially on Morgan-like trike builds? I'd like to build one of those next...

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andyace

posted on 4/2/18 at 04:33 PM Reply With Quote
I agree with the above ... I too am in the middle of a Pinto build ... would cost me a fortune to switch now !!!!

a 24 month grace period sounds fair ... would also give me the kick up the arse to get it finished :-)

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ettore bugatti

posted on 4/2/18 at 04:42 PM Reply With Quote
Does the proposal means Euro6 or later emission? Or do they just want post '92 engines to be used in future IVA submissions?

CCK Kempten managed to get a Zetec Blacktop to Euro6 for German legistations, but I recon that it wouldn't be an easy thing to do.

Surely some ex-VAG engineers are willing to offer some support if all this go through?

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PorkChop

posted on 4/2/18 at 06:02 PM Reply With Quote
quote:
Originally posted by ettore bugatti
Does the proposal means Euro6 or later emission? Or do they just want post '92 engines to be used in future IVA submissions?


No, it does not; it tells you this in section 4.10.

You can fit any engine if you can get it to meet the limits.

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gremlin1234

posted on 4/2/18 at 06:21 PM Reply With Quote
quote:
Originally posted by PorkChop
quote:
Originally posted by ettore bugatti
Does the proposal means Euro6 or later emission? Or do they just want post '92 engines to be used in future IVA submissions?


No, it does not; it tells you this in section 4.10.

You can fit any engine if you can get it to meet the limits.

as far as I can tell the proposed limits will be the current MOT limits (and after 20 May '18 mot changes too)
quote:

To pass the Basic Emissions Test, the following requirements must be met:
Fast idle test (2500 - 3000rpm):
CO <= 0.2%;
HC <= 200ppm;
Lambda between 0.97 and 1.03.
Idle test (450 - 1500rpm):
CO <= 0.3%.


link for Mays MOT changes
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/671818/mot-inspection-manual-for-classes-3-4-5-and-7-from-20-may-20 18-draft.pdf

edit: make link work, and readablity

[Edited on 4/2/18 by gremlin1234]

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