What the proposed MoT changes mean

The Department for Transport (DfT) has recently released a new propasal document called ‘Road Vehicles – Improving air quality and safety’. While this is primarily aimed at stopping a repeat of the dieselgate problems from large scale manufacturers, there is a section relating to MoT standards for newly registered kit cars.

These can be found at section 4.10 to 4.13, reproduced here:

4.10  Kit cars and reconstructed classic cars undergoing IVA will not be required to meet WLTP, given that at present they are not required to meet NEDC or the latest EU standards. Instead they are tested to age-appropriate MOT standards, on the basis of the date of manufacture or first use of the engine.

4.11  We are proposing that for kit cars, compliance with the MOT emissions standards current at the date of registration will be required, despite the use of an older engine. In other words the current relaxation for emissions according to the age of the engine will no longer apply.

4.12  Reconstructed (restored) classic cars undergoing IVA will not be required to meet the latest MOT standards, as long as the appearance of the vehicle is broadly unchanged and the engine is of the same capacity as that supplied with the vehicle when it was new.

4.13  When new vehicles were first required to be fitted with catalytic converters around 1992 (Euro 1 emissions standard), kit car makers typically used older engines which were not fitted with catalytic converters, hence the justification for age-appropriate testing of emissions based on date of engine manufacture or first use. 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.

A link to the full document can be found HERE.

While the wording is potentially ambiguous, Peter Bailey of the Chesil Motor Company has now had clarification from Mike Lowe, Acting Head of Branch, Regulation, International Vehicle Standards. Mike Lowe says: “The change proposed is to treat kit cars as having a new engine and thus subjected to the MOT standards applicable to new vehicles (once they reach 3 years old). This is a test with a vehicle idling (for petrol).”

Our understanding is that this would mean all newly registered kit cars would have to meet the requirements for production cars registered from 1992 onwards, this being a Basic Emissions Test (BET) requiring a catalytic converter.

The period for consultation is short, ending on Friday 2 March.

Feedback from manufacturers tells us that for some kit cars this is not a problem as they already meet the requirements, while for others it is. We are also aware that this may be an issue to a number of builders who are mid-way through a build and committed to an engine choice.

Clearly it is important that manufacturers, traders and private owners who would be affected by these proposals, should respond as soon as possible, outlining their concerns.

Peter Bailey, of Chesil Motor Company has spoken to Mike Lowe who told him: “…if the consensus of the opinion is that this will kill the British kit car industry, we are very much open to listening and asking Ministers if we can remove this proposal from the package of proposals.”

Peter has put together the following guidelines for how you might like to structure any written response. Please feel free to use these guidelines, or do your own thing. Over to Peter…

As you are now hopefully aware, there is new legislation in the pipeline that could greatly affect our industry. I for one would not be here at Chesil if these proposals were introduced, as we fit air-cooled engines (that have no real alternative) and would be very difficult to get to pass the proposed emissions… but on top of that, it is not what our customers want.

 

It does seem, having spoken to the DfT just now, that if there is sufficient pressure and clear, genuine reasons why this part of the legislation could be ‘catastrophic’ to our industry, there is a fair chance it could be removed from the proposals, but it is up to all of us to respond!

 

I am suggesting that all manufacturers write, giving their own individual case, and also that we all collectively send a response from the industry as a whole.

 

Below are some suggestions as to the content of your response:

1. Does your vehicle, particularly if it is a replica, need to have an earlier style engine to retain the character of your car? If so, explain why this is so important, and how difficult it would be to implement emission controls.

2. Would fitting a more modern engine detract from the original character of the car, and therefore its saleability? Would customers be put off buying it? Explain why.

3. If an alternative could be fitted, would it increase the build cost, which too could be detrimental to sales? Give a realistic indication of cost increase, perhaps as a percentage.

4. Would there be existing customers who could get ‘caught out’ by this legislation as their build completion would be beyond the implementation date? Give an example and perhaps how many customers you have in this situation.

5. If this legislation were implemented, could it possibly affect your business sufficiently that you might have to ‘close your doors’? If so, give good sound reasons why.

Responses should be sent to…

Robert Lloyd-Smith
Zone 1/33, Great Minster House
33 Horseferry Road
London SW1P 4DR

Below is Peter’s proposal for a group response from manufacturers/traders. If you are happy to have your name and company added to this list, we are happy to collate them here and send it on your behalf. To be included, please email adam@performancepublishing.co.uk BEFORE Wednesday 28 February.

A Collective Response – from kit car manufacturers and traders

As small scale manufacturers of specialist and kit cars, we would like to collectively respond to the proposed legislation, in particular regarding to the changes to the emissions requirement.

We are not a big industry, but we are unique within Europe and in fact in the world, having produced thousands of specialist cars over the last 50 years, and have become established as the world centre for this type of car.

The introduction of SVA and then IVA allowed our industry to produce vehicles to a recognised safe standard – a fact borne out by the low insurance premiums that our vehicle owners enjoy.

We would very much like our industry to continue, but these current proposals could be catastrophic to some, and many we are sure would have to close. This is not an excessive expectation, but a reality. As many have individually explained, it is the proposed change to MoT emissions standards for kit cars that would be very damaging to our cars… the older style of engines perhaps being vital to the core appeal of the model, and/or the potential costs of fitting compliant engines being so expensive as to cause sales to fall to unsustainable levels.

Many of us have small workshops and not a vast workforce, but we all have many times that number indirectly employed who have specialist skills and rely on our continued, and regular, work.

As you will notice, on a day-to-day basis there are very few classic cars on the roads, often reserved for special occasions, days out and perhaps limited touring during the summer months. It is not uncommon for these cars to have limited mileage insurance, typically 2000-6000 miles per year, with many not covering more than 1000 miles annually. The emissions impact by this small ‘fleet’ of cars is also tiny and does not warrant the heavy-handed controls that are being considered.

We all hope that you now have a better picture of our industry and its precarious position if this legislation became enacted.

We strongly request that this part of the proposed new legislation be dropped.

The following companies and individuals have agreed to their names being added to this letter…

Clubs and individual owners

Complete Kit Car has had contact from a number of clubs expressing concern at the proposals. Hopefully the information we have provided above will clarify the situation. We understand some clubs will be more impacted by the proposals than others, and may wish to make their own representation to the contact details listed above.