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Aug 22, 2012 11:30:33 GMT
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It boils down to one simple question ,rather than arguing amongst ourselves over minutia, is allowing this proposal to go unquestioned and without registering our concerns a good or bad thing? This is my thinking to, I'd rather overreact and everything turn out fine rather that go 'whatever' and in six weeks time wake up to discover the majority of the people I know are out of work and all of our cars are no longer road legal.
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VIP
South East
Posts: 8,293
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Aug 22, 2012 11:32:40 GMT
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Check my previous answers to Hotwire that show why they will not pass MOT .They MUST meet original Type Approval / CoC . If you want to be pedantic it doesn't say they won't pass but even Dft say they will have to be refered for further testing. It boils down to one simple question ,rather than arguing amongst ourselves over minutia, is allowing this proposal to go unquestioned and without registering our concerns a good or bad thing? Please cite the extract from the proposal that specifically refers to Type Approvals.
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craig1010cc
Club Retro Rides Member
Posts: 2,993
Club RR Member Number: 35
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Aug 22, 2012 11:33:02 GMT
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better to over react and then be relieved than to do nothing and whinge once its happened (signed up too )
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Aug 22, 2012 11:36:46 GMT
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Check my previous answers to Hotwire that show why they will not pass MOT .They MUST meet original Type Approval / CoC . If you want to be pedantic it doesn't say they won't pass but even Dft say they will have to be refered for further testing. It boils down to one simple question ,rather than arguing amongst ourselves over minutia, is allowing this proposal to go unquestioned and without registering our concerns a good or bad thing? Please cite the extract from the proposal that specifically refers to Type Approvals. Please take the time to go back a few pages and find it yourself .
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VIP
South East
Posts: 8,293
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Aug 22, 2012 11:36:48 GMT
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However I don’t see anything in there that says the test would check the car’s absolute compliance to its original specification. Nor do I.
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Aug 22, 2012 11:38:22 GMT
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This is my question though ...
"Check my previous answers to Hotwire that show why they will not pass MOT .They MUST meet original Type Approval / CoC . If you want to be pedantic it doesn't say they won't pass but even Dft say they will have to be refered for further testing."
Will they pass with TYPE APPROVED PARTS ... like the German system?
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Aug 22, 2012 11:38:43 GMT
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It boils down to one simple question ,rather than arguing amongst ourselves over minutia, is allowing this proposal to go unquestioned and without registering our concerns a good or bad thing? +A billion. Some of the responses on Driftworks were galling when this was posted up. To the point I emailed several company sponsors of drift teams at 3am and suggested they read the legislation themselves, spelling out several key issues and the likely impacts on their businesses. They should be screaming down the doors of the 'teams' they sponsor who either aren't interested in reading the text or who seemingly genuinely believe it will 'mean more track days and drifting' if even half of them have read the actual document I'd be amazed.
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VIP
South East
Posts: 8,293
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Aug 22, 2012 11:42:56 GMT
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Please cite the extract from the proposal that specifically refers to Type Approvals. Please take the time to go back a few pages and find it yourself . If you mean this... ec.europa.eu/transport/doc/roadworthiness-package/com%282012%29380.pdfFor the inspection of vehicles and especially for their electronic safety components it is crucial to have access to the technical specifications of each single vehicle. Therefore vehicle manufacturers should not only provide the complete set of data as covered by the certificate of conformity (CoC) but also the access to data necessary for verification of the functionality of safety and environmental related components. The provisions related to access to repair and maintenance information should be applied similarly for this purpose, allowing inspection centres to have access to those information-elements necessary for roadworthiness testing. This is of crucial importance especially in the field of electronic controlled systems and should cover all elements that have been installed by the manufacturer. Before a vehicle is allowed to be put on the market, it has to fulfil all the relevant type or individual approval requirements guaranteeing an optimal level of safety and environmental standards. Every Member State has the obligation to register for the first time any vehicle that got the European type-approval on the basis of the “Certificate of Conformity” issued by the vehicle manufacturer. This registration is the official authorisation for the use on public roads and enforces the different introduction dates of different vehicles' requirements During a vehicle's lifetime it may be subject to re-registration, due to a change of ownership, or a transfer to another Member State for permanent use. Provisions on a vehicle registration procedure should be similarly introduced to ensure that vehicles which constitute an immediate risk to road safety are not used on roads. The goal of roadworthiness testing is to check the functionality of safety components, the environmental performance and the compliance of a vehicle with its approval. It does not state that a vehicle MUST conform to the original Type Approval in order to pass the 'roadworthiness test'. It is purely a statement of the Context of the Proposal, as does not form part of the Scope or Definition of the Legislation.
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Aug 22, 2012 11:57:39 GMT
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This is my question though ... "Check my previous answers to Hotwire that show why they will not pass MOT .They MUST meet original Type Approval / CoC . If you want to be pedantic it doesn't say they won't pass but even Dft say they will have to be refered for further testing." Will they pass with TYPE APPROVED PARTS ... like the German system? You have read the 'proposal' as have I. Anything else other than contained in there is just speculation .Remember ,thii is just getting A Regulation in place , they reserve the right to alter as they see fit , without further Consultation . Seeing as most of this is being driven by the Germans then we could end up with a system like theirs but answer unknown at mo. If you take a look at the DfT / VOSA questionnaire you can see a lot of ifs buts and maybes already , and they will be the ones responsible for enforcement.
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Aug 22, 2012 11:58:26 GMT
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I may be a bit slow.. But where does this leave stuff less than 30 years old that doesn't have type approval or a certificate of conformity? A modernish American import for example?
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...proper medallion man chest wig motoring.
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Aug 22, 2012 11:59:47 GMT
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Please take the time to go back a few pages and find it yourself . If you mean this... ec.europa.eu/transport/doc/roadworthiness-package/com%282012%29380.pdfFor the inspection of vehicles and especially for their electronic safety components it is crucial to have access to the technical specifications of each single vehicle. Therefore vehicle manufacturers should not only provide the complete set of data as covered by the certificate of conformity (CoC) but also the access to data necessary for verification of the functionality of safety and environmental related components. The provisions related to access to repair and maintenance information should be applied similarly for this purpose, allowing inspection centres to have access to those information-elements necessary for roadworthiness testing. This is of crucial importance especially in the field of electronic controlled systems and should cover all elements that have been installed by the manufacturer. Before a vehicle is allowed to be put on the market, it has to fulfil all the relevant type or individual approval requirements guaranteeing an optimal level of safety and environmental standards. Every Member State has the obligation to register for the first time any vehicle that got the European type-approval on the basis of the “Certificate of Conformity” issued by the vehicle manufacturer. This registration is the official authorisation for the use on public roads and enforces the different introduction dates of different vehicles' requirements During a vehicle's lifetime it may be subject to re-registration, due to a change of ownership, or a transfer to another Member State for permanent use. Provisions on a vehicle registration procedure should be similarly introduced to ensure that vehicles which constitute an immediate risk to road safety are not used on roads. The goal of roadworthiness testing is to check the functionality of safety components, the environmental performance and the compliance of a vehicle with its approval. It does not state that a vehicle MUST conform to the original Type Approval in order to pass the 'roadworthiness test'. It is purely a statement of the Context of the Proposal, as does not form part of the Scope or Definition of the Legislation. Have you also read the DfT / VOSA questionairre and their take on it Link and quotes at start of ACE article .
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Aug 22, 2012 12:01:20 GMT
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I may be a bit slow.. But where does this leave stuff less than 30 years old that doesn't have type approval or a certificate of conformity? A modernish American import for example? It leaves it being tested if it is between 10 and 30 years old. If less than 10 years old when imported it will have had to pass SVA / BIVA thus creating a CoC equivalent.
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VIP
South East
Posts: 8,293
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Aug 22, 2012 12:09:23 GMT
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If you mean this... It does not state that a vehicle MUST conform to the original Type Approval in order to pass the 'roadworthiness test'. It is purely a statement of the Context of the Proposal, as does not form part of the Scope or Definition of the Legislation. Have you also read the DfT / VOSA questionairre and their take on it Link and quotes at start of ACE article . 'Their take' is irrelevant, the Legislation will be provided with a list of criteria as to the definition of pass/fail and how the vehicle will be inspected. If the Legislation does not make reference to Type Approvals and CoC, then it may not be used within the Test.
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Aug 22, 2012 12:10:52 GMT
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VIP - That as may be, but what you have to ask yourself is what will the the DfT/VOSAs interpretation of it? I think it *probable* that it could turn out like something akin to historic racing regs i.e. if a given chassis type was never sold with/acquired approval for, a given option or factory/dealer available modification, then they would make it overly difficult to do it. While cars like 240/260z's and 510's might have a plethora of options in that respect, cars like a Sunny with an engine swap ...not so much I am just thinking out loud here, but if you think of the rise and rise of the Traffic Wombles that replaced real traffic police, how quickly that happened, and how in so many circumstances where they are involved with the general public without necessarily fully knowing either the extent of the law that their jurisdiction applies to; whether your car is 'safe' to be on the road (valid MOT or not) as per 'educated' judgement', then in a worst case scenario you'd just see them exercising more of this - "Vehicle & Operator Services Agency Officers have powers to stop vehicles on all roads, including motorways and trunk roads, in England and Wales. They will attract your attention by flashing amber lights - either from the front requesting you to follow them to a safe place to stop - or from behind directing you to pull over to the side by pointing and/or using the left indicator It is an offence not to comply with their directions. You MUST obey any signals given (see 'Signals by authorised persons'). [Laws RTA 1988, sect 67, & PRA 2002, sect 41 & sched 5(8)]" ...and directing you to a VOSA testing station..whether your car had been a road worthiness test, type approval or whatever, or not. Again, I'm thinking out loud, but I think we need to view this from the worst possible angle there is as we simply don't know. At the very worst end of it, it's really, really bad, from the sunnier side of the rainbow, we can probably live with it. Past experience should teach us not to hold our breath and wait, without first telling the powers at be deciding these things how grave indeed the consequences can be.
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Aug 22, 2012 12:15:45 GMT
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I may be a bit slow.. But where does this leave stuff less than 30 years old that doesn't have type approval or a certificate of conformity? A modernish American import for example? It leaves it being tested if it is between 10 and 30 years old. If less than 10 years old when imported it will have had to pass SVA / BIVA thus creating a CoC equivalent. And what if, say, I've got a largely standard 10+ year-old car with a few aftermarket parts; exhaust, wheels etc? That'll require testing too, yes?
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VIP
South East
Posts: 8,293
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Aug 22, 2012 12:20:48 GMT
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VIP - That as may be, but what you have to ask yourself is what will the the DfT/VOSAs interpretation of it? As I said above, their 'interpretation' is irrelevant, the Legislation is plain and simply that, just like the recent EU MOT, it already has the pass/fail criteria written into it. It's not open for individual member states to change those criteria to their own version.
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DutyFreeSaviour
Europe
Back For More heartbreak and disappointment.....
Posts: 2,944
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Aug 22, 2012 12:48:07 GMT
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VIP - That as may be, but what you have to ask yourself is what will the the DfT/VOSAs interpretation of it? As I said above, their 'interpretation' is irrelevant, the Legislation is plain and simply that, just like the recent EU MOT, it already has the pass/fail criteria written into it. It's not open for individual member states to change those criteria to their own version. ViP fella - they may not 'change' the legislation or guidance, but they are still open to interpretation....... the pain in Brussels itself being the example given: a suspension bush - NLA so no option other than after market - it's TuV approved. But they won't allow the vehicle on the road..... no way, no how, no chance. They won't even look at it - it's not the same bush, so you can't use it. Not in line with legislation as it stands even, but they simply refuse to issue the document so I can register and use the car So I am stuck in the legsilation limbo. My car is completely rebuilt, every nut, bolt and suspension component totally new - so it's better than factory spec (but not factory spec) so I'm (in their eyes) illegal/a bad man It will mean a long and slippery slope - as any item even considered for upgrading cars would have to be subjected to TuV like testing and the costs that implies..... meaning a lot of the rarer or less well supported vehicles would be stymied. The minute you adapt any TuV approved part to go where it shouldn't - you're back to SVA or cubing.
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Back from the dead..... kind of
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stealthstylz
Club Retro Rides Member
Posts: 14,852
Club RR Member Number: 174
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Aug 22, 2012 13:09:35 GMT
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As a reply to people saying "even if this comes in it would be impossible to enforce" this legislation would be ridiculously easy to enforce, infact it would take no extra work from the governments point of view. A car is MOT'd for a maximum of 12 months. The next MOT you go for the car would fail because the modifications didn't match its original type approval. Therefore within 12 months all vehicles that don't comply with the new legislation would be removed from the road. No extra enforcement needed than what's inplace already.
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Aug 22, 2012 13:16:40 GMT
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And my question remains,.. "The next MOT you go for the car would fail because the modifications didn't match its original type approval" ... original type approval, or have type approved parts? ... my car will probably need BIVA by the time it is complete. However if I buy a VW T4 van and lower it with all TuV level type approved kit (lets say it is equivalent to UK stuff and acceptable) will it be MOTable?
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stealthstylz
Club Retro Rides Member
Posts: 14,852
Club RR Member Number: 174
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Aug 22, 2012 13:26:01 GMT
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I don't even think that has been decided yet on a UK level (intact none of it has). If its like Germany you can modify a car using type approved aftermarket parts. However in Belgium you can't.
The problem is the not knowing of outcomes. The legislation could come in and the DFT/government opt out of it. It could come in and we'd end up like Germany where modifying is difficult but possible. It could come in and we'd end up like France or Belgium where modifying is illegal.
We need to fight this based on the fact that it could royally screw us if its interpreted in a certain way.
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