UK: Proposed changes to emissions

Hi,
I've just completed my form (just the relevent 4.10-13 section)for the Emissions Consultation and e-mailed it to Mr Lloyd-Smith with the attached letter (I included the points in the Form as well and copied my MP). Hope you find it interesting. Responses have to be in by March 2nd:-


Ref: IVA Open Consultation
Road Vehicles: improving air quality and safety - 2 February 2018

Dear Mr Lloyd-Smith,
I have been studying your consultation document on the above subject, it is most thorough and naturally we all welcome any proposal that makes the world a cleaner and safer place - well done indeed. I have completed the Response Form but wish to add some detailed notes.

I am a professional Chartered Mechanical Engineer, Fellow of the Institution of Mechanical Engineers with a Masters Degree in Automotive Studies. My career spans 50 years, half with Ford Motor Company Limited and half in International Motorsport. I have also been President of the Ford RS Owners Club which is one of the biggest in UK. I therefore feel well qualified to give you a considered opinion.

The particular aspect that's dear to my heart is the subject of emissions on low volume restored classic cars, replicas and kit cars. (Question 16 / Report Section 4.10 to 4.13)

I propose that we leave the current legislation untouched on these categories.

These are my reasons:
1) These cars represent a minute percentage of the car and truck population and they cover minimal mileage for pleasure only.
2) Doing the mathematics: In 2016 there were 37.8 million registered vehicles (Government stat) covering an average of 7900 miles per annum (2015 Government stat). The Classic, replica and kit car population is not published but is probably not higher than 200, 000 doing an average of say 2000 miles a year. This only would represent a total of 0.14% of total UK road miles. (At the extreme, if there were 500,000 doing the average 7900 miles this would still only amount to 1.36%).
3) The vast majority of owners maintain them impeccably and retain them for long periods. Smoky or leaky engines just would not be tolerated!
4) The vast majority of owners are hugely responsible and talented people. This is reflected in very low insurance premiums
5) The cars do not lend themselves to costly mechanical upgrades and specialist electronic recalibrations to meet current and future legislation. These calibrations are very time consuming and costly to do accurately.
6) The current IVA test is a very comprehensive examination undertaken with specialist equipment and knowledgeable and experienced engineers. To pass the test means that the vehicle is fit for purpose and meets legislation.
7) Owners have restored and built replicas and kit cars to meet current legislation. Others are in build which typically takes a few years and are also working to current legislation. To make engine emission changes might be impossible without major mechanical and electrical upgrades.
8) Using OEM equipment is not an option because the engine management will not be suitable and in any case third party programming is not possible without 'hacking' the system. OEM engine management has to cater for a plethora of other equipment not relevant to Classics, replicas or kit cars.
9) Commercial third party electronic engine management is available but a professional calibration to cover the full operating spectrum of an engine will typically take weeks of dyno testing. Anything less is a fudge and probably using the so called 'self learn' ECUs. Systems can be set up for an emissions test 'on the day' and could then revert.
10) Future emissions legislation will probably get tighter and tighter making it even more difficult for owners.
11) Owners derive huge pleasure from driving and maintaining their cars themselves. Many are passing on invaluable skills to their offspring who are the next generation of talented engineers.
12) Restorations and donor parts enable a measure of recycling and waste prevention.

I sincerely hope that this analysis will help preserve the current situation and enable owners and future owners to continue to enjoy their motoring hobby in a very safe, cost effective and responsible manner.

Yours sincerely
Roger Allen MSc CEng FIMechE
 
Bravo Roger ...... very well worded.
I have put posts on several forums having done similar math to yours and arrived at staggeringly low percentage figures.
I have also pointed out that the change to the MOT requirements, as from May this year, whereby vehicles built before 1977 (previously 1960) no longer require an MOT, adds an additional 292,000 vehicles that become MOT exempt.
 
I received a letter back from my MP the main part was this.

You raise a number of important issues in your letter, particularly about the harm the proposals could cause to the kit car sector. I am aware that a number of kit car manufacturers and traders have also warned that the proposals could be catastrophic for the industry. I understand that the cost of installing a modern engine could be out of the reach to lots of people building a modified classic or kit car, and I am also aware that the older style of engine can be vital to the core appeal of the car. You call for the proposals to be dropped entirely, and I know that other kit car traders have voiced similar concerns that the proposals are heavy handed. The consultation is scheduled to close on 1 March 2018. I can assure you I will monitor developments on this closely.

I appreciate the concerns you have raised, however I do believe we must also establish a comprehensive and effective strategy to improve air quality across the whole country and the relationship between emissions and air quality is a fundamental issue. I am also concerned that the Governments response to date has been inadequate.


Thank you once again for taking the time to write to me. I can assure you I will bear in mind the points you have raised when this is next debated in Parliament.

Yours Sincerely.



I have taken some bits from Roger and Steve's excellent responses above and am planing to respond with this.


Dear Mr Rashid

Thank you for you for your letter, I fully agree the relationship between emissions and air quality is a fundamental issue. In fact I regularly cycle between Warrington and my workplace in Central Manchester, averaging around 4000 miles a year on a bicycle to help reduce my emissions.

I think you may have missed my main point, namely these proposals if implemented will not reduce emissions by any significant amount for the following reasons:


1) These cars represent a minute percentage of the car and truck population and they cover minimal mileage for pleasure only.
2) Doing the mathematics: In 2016 there were 37.8 million registered vehicles (Government stat) covering an average of 7900 miles per annum (2015 Government stat). The Classic, replica and kit car population is not published but is probably not higher than 200, 000 doing an average of say 2000 miles a year. This only would represent a total of 0.14% of total UK road miles. (At the extreme, if there were 500,000 doing the average 7900 miles this would still only amount to 1.36%).
3) The vast majority of owners maintain them impeccably and retain them for long periods. Smoky or leaky engines just would not be tolerated!
4) As from May this year, whereby vehicles built before 1977 (previously 1960) no longer require an MOT, adds an additional 292,000 vehicles that become MOT exempt.

Point 4 carries particular significance; these proposals we are told are being introduced to reduce emissions and improve air quality. At the same time, an increase in the number of cars having exemption to MOT tests is likely to increase emissions and reduce air quality. It makes no logical sense.

I would also like to re-emphasize the following:


1) The vast majority of owners are hugely responsible and talented people. This is reflected in very low insurance premiums .
2) The current IVA test is a very comprehensive examination undertaken with specialist equipment and knowledgeable and experienced engineers. To pass the test means that the vehicle is fit for purpose and meets legislation.
3) Owners have restored and built replicas and kit cars to meet current legislation. Others are in build which typically takes a few years and are also working to current legislation. To make engine emission changes might be impossible without major mechanical and electrical upgrades.
4) Using OEM equipment is not an option because the engine management will not be suitable and in any case third party programming is not possible without 'hacking' the system. OEM engine management has to cater for a plethora of other equipment not relevant to Classics, replicas or kit cars.
5) Commercial third party electronic engine management is available but a professional calibration to cover the full operating spectrum of an engine will typically take weeks of dyno testing. Anything less is a fudge and probably using the so called 'self learn' ECUs.


Yours Sincerely
 
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