DVLA call for evidence

[Bigpie]

https://www.gov.uk/government/calls-for ... r-evidence

FYI UK members, worth responding

[rstevens81]

I'm probably going to draft a rather detailed letter for this as an OI spokesperson (unless someone else really to, lets hope they don't try and deport me )

[I'll update this list as as suggestions come in]

1. Any changes going forward should comply with what's in r100
2. Any Inspections should be done in the same way as IVAs not by companies with vested interests
3. Suggest boltholes and brackets should be allowed to facilitate safe mounting procedures of battery boxes/ motors etc
4 Allowing of fuel type to be changed on post 2001 cars so that emergency vehicles will be aware in event of an accident
[currently DVLA stance is fuel type and co2/taxation are locked together and cannot be changed....we dont mind paying tax just allow change to electric]
5. Suggest 2001+ maybe should just revert to <1500cc tax class (this is what is used for import cars of same era)
.....

Questions and respnses....

Section 3 – historic and classic vehicles [Not really or remit but just adding some input]

3.1 What do you consider to be a historic or classic vehicle? Please provide evidence
and reasons to support your views.
(Ans) Not within remit of organisation

3.2 If you think there should be a separate registration process for historic and classic vehicles, what would be the right process for these vehicles? Please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.3 If you think there should be a series of registration numbers specifically for historic and classic vehicles, how do you imagine this would work? Please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

3.4 Should there be a new type of safety check in place which takes into account the age of a historic or classic vehicle? If so, please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.5 Should there be a distinction made between restoration, where an existing registered vehicle with an established history is being refurbished, potentially with some new parts, and vehicles constructed as a replica not based on a registered vehicle, but constructed from a collection of old parts? If so, please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

Section 3 – reconstructed classic vehicles
3.6 If you think that the current guidance is still relevant, please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.7 What do you think should be the definition of a reconstructed classic vehicle? Please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.8 If you think it’s appropriate to ensure the components used to build a vehicle must be more than 25 years old and within the period the model of vehicle was originally manufactured, please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.9 Do you think the reconstructed classic scheme should be specific to vehicles not
previously registered, or should the scheme also apply to already registered vehicles
that have been rebuilt or restored?
.Specific to vehicles not previously registered
.Also apply to already registered vehicles that have been rebuilt or restored
.Not sure
Please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.10 What do you consider to be a replica vehicle as opposed to a reconstructed
classic or historic vehicle? Please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

Section 3 – rebuilt vehicles
3.11 What do you think should be the definition of a rebuilt vehicle? Please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.12 Do you think the current guidance is still relevant? For example, does it take into account emerging technologies and innovation. If so, please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.13 If you think there should be separate rebuilt policies for different vehicle types (motorcycles, cars, vans, etc), please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

3.14 To what extent should a vehicle be rebuilt before DVLA needs to be informed?
Please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

3.15 Is putting the main emphasis for assessing a rebuilt vehicle on modifications to
the chassis or monocoque bodyshell (or frame for motorcycles) still appropriate?
.Yes
.No
.Not sure
If not, what else should be considered? Please provide evidence and reasons to support your views

3.16 At what point should a chassis or monocoque bodyshell modification (or frame for motorcycles) affect the identity of a vehicle that has been rebuilt? Please provide evidence and reasons to support your views.

3.16 At what point should a chassis or monocoque bodyshell modification (or frame
for motorcycles) affect the identity of a vehicle that has been rebuilt? Please provide
evidence and reasons to support your views.

3.17 If you consider it important for a consumer purchasing a vehicle to know if it’s had major rebuild or restoration work done to it, please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

Section 3 – restored vehicles
3.18 Do you think restored vehicles should continue to be assessed according to the current policy for rebuilt vehicles or should there be a specific process for assessing restored vehicles?
.Continue to be assessed according to the current policy for rebuilt vehicles
.There should be a specific process for assessing restored vehicles
.Not sure
Please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

Section 3 – restored vehicles
3.18 Do you think restored vehicles should continue to be assessed according to the current policy for rebuilt vehicles or should there be a specific process for assessing restored vehicles?
(Ans) Not within remit of organisation

3.19 What do you think should be the definition of a restored vehicle? Please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

3.20 If you think there should be separate policies for different vehicle types (motorcycles, cars, vans, etc), please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

3.21 At what point should a chassis or monocoque bodyshell modification (or frame for motorcycles) affect the identity of a vehicle that has been restored? Please provide evidence and reasons to support your views

3.22 If you consider it important for a consumer purchasing a vehicle to know if it’s had major restoration work done to it, please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

Section 3 – kit-built and kit converted vehicles
3.23 If you think the current guidance is still relevant, please provide evidence and reasons to support your views.

3.24 If you think reconditioned or remanufactured components should be considered the same as brand new components, please provide evidence and reasons to support your views

3.25 Should reconditioned or remanufactured components be assessed to ensure they meet the specifications to be used on a different vehicle from the one they were designed for? If so, please provide evidence and reasons to support your views.

3.26 If you think kit-built vehicles should be registered as new vehicles if they have more than one reconditioned or remanufactured component, please provide evidence and reasons to support your views.

3.27 If you think the V5C should indicate that the vehicle has been built using reconditioned or remanufactured components, please provide evidence and reasons to support your views.

3.28 If you think that it is important for evidence to be provided to show where reconditioned or remanufactured parts are sourced from, please provide evidence and reasons to support your views.

3.29 What do you think should be the definition of a radically altered vehicle and why? Please provide evidence and reasons to support your views

3.30 If you think the current guidance is still relevant, please provide evidence and reasons to support your views

3.31 To what extent should a vehicle be radically altered before DVLA needs to be informed? Please provide evidence and reasons to support your views.

3.32 Should the main emphasis for assessing a radically altered vehicle be around modifications to the chassis or monocoque bodyshell (or frame for motorcycles) or should other components also be considered? If so, please provide evidence and reasons to support your views

Section 3 – vehicles converted to electric propulsion
3.33 If you think there should be a separate, specific policy for assessing vehicles that have been converted to electric, what would that policy or process look like? Please provide evidence and reasons to support your views.

3.34 If you think there should be specific safety tests for vehicles which have been converted to electric, what should these tests involve? Please provide evidence and reasons to support your views.

3.35 At what point should a chassis or monocoque bodyshell modification (or frame for motorcycles) affect the identity of the vehicle that has been converted to electric? Please provide evidence and reasons to support your views.

Section 3 – Q and QNI registration numbers
3.36 If you consider that a Q registration number should only be assigned to vehicles where the identity is unknown or cannot be determined, please provide evidence and reasons to support your views

3.37 Currently, any modification to the chassis or monocoque (or frame for
motorcycles) will result in a Q registration number being assigned to the vehicle.
Do you agree with this policy?
.Yes
.No
.Not sure
If not, to what extent do you consider it acceptable for a vehicle to be modified before it’s assigned a Q registration number? Please provide evidence and reasons to support your views.

3.38 If you consider it important for a consumer purchasing a vehicle to know if it’s been modified, please provide evidence and reasons to support your views.

3.39 Should historic and classic vehicles that have been rebuilt or restored be assigned an alternative age-related registration number instead of a Q registration number? If so, please provide evidence and reasons to support your views

3.40 In what circumstances do you think DVLA should allocate a VIN? Please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

3.41 A VIN is a unique identifier for a vehicle and is used by DVLA when assessing a vehicle’s originality and identity. This is done by checking archives and obtaining information from experts in the field. Where the original VIN is no longer present, how could DVLA authenticate a vehicle’s identity and originality instead of allocating a DVLA VIN? Please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

3.42 If you are a vehicle manufacturer, would you have concerns about the original VIN being retained or restamped on the vehicle, where the manufacturer has not approved the changes to the vehicle?
.Yes
.No
.Not sure
Please provide evidence and reasons to support your views
(Ans) Not within remit of organisation

3.43 We currently allocate a DVLA VIN where a chassis or monocoque bodyshell (or frame for motorcycles) has been replaced or modified. Modern vehicles have the VIN hard-coded into electronic control units and potentially stamped or engraved on other components. In these instances, do you think a DVLA VIN is still relevant?
.Yes
.No
. Not sure
Please provide evidence and reasons to support your views.
(Ans) Not within remit of organisation

Section 4 – what other countries do
4.1 Do you think there is any best practice from other countries that could be implemented here?
.Yes
.No
.Not sure
Please provide evidence and reasons to support your views.

Section 5 – independent advisory groups
5.1 Do you think that DVLA should explore the option of setting up independent advisory groups to support the registration process for historic vehicles?
.Yes
.No
.Not sure
Please provide evidence and reasons to support your views.

Section 5 – additional question
5.2 If you wish to put forward any evidence, suggestions or ideas not already mentioned around the registration processes, please provide your thoughts around how these might work.

[LRBen]

These are the questions specific to EV conversions.

R100 guidances fits quite well into specific safety tests, possibly suggest the ability to self evidence this for inspection by the DVLA when they send someone out as they do currently.

It also seems like they are questioning the zero cut/drill policy for chassis/bodies which is nice.

[rstevens81]

I have posted the entire Q&A most sections i dont think its appropriate that we should comment however anyone chip in if they think differently

[ianlighting]

The DVLA has published the responses to the survey discussed in this thread.

Section 3.33 covers EV conversion responses.

https://www.gov.uk/government/calls-for ... ary-report


Some comment from another org…

https://www.am-online.com/news/dvla-urg ... assic-cars


It wouldn’t surprise me if a more rigorous test process comes into being at some point. Which would probably mean more expensive. But whether the government prioritises this with all the other business they have to get through, we’ll have to wait and see.

[LRBen]

I have been a bit worried about some of the responses to that call for evidence. I get the feeling most of the call for evidence was aimed at historic vehicle restoration (which makes sense as it was pushed by the HCVA) with the EV part tacked on.
Some of the sample responses sound allot like things I hear from people who don't have a clue about EV conversions. For example: "ICE vehicles that are converted to electric require a separate policy as the whole vehicle is subjected to unknown stresses and strains…"
or "This is because the massive weight of batteries substantially alters the original designer’s weight distribution and handling qualities."

Unfortunately this survey is going to be taken as responses from the EV conversion industry by the DVLA so they will probably actually listen to them.

[ianlighting]

Some of the sample responses sound allot like things I hear from people who don't have a clue about EV conversions. For example: "ICE vehicles that are converted to electric require a separate policy as the whole vehicle is subjected to unknown stresses and strains…"
or "This is because the massive weight of batteries substantially alters the original designer’s weight distribution and handling qualities."

Unfortunately this survey is going to be taken as responses from the EV conversion industry by the DVLA so they will probably actually listen to them.

I’m a bit torn. I certainly don’t want to have to through some extensive crash test simulation or 3D modelling of the stresses and strains, or whatever the DVLA might come up with. But what those quotes you included say is actually true. And while this is a small crowd of enthusiasts probably taking good care of their projects because they plan to be driving the vehicle themselves, I can imagine as EVs become truely mainstream, other types of people will get involved. I can imagine dodgy characters start doing quick buck conversions purely to sell on as quickly as possible. It would be the new owners problem if a battery box shifted and crushed them in a crash for example.

It’s a tough one, but the DVLA’s focus will be safe vehicles I guess.

I just hope I get mine done in time before whatever new regime rolls in! Hopefully by summer I’ll be done.

It would be interesting to track any UK build’s experiences with the DVLA if they go through with certification to see how they’re reacting and if they start getting more stringent in anticipation of new rules.

[LRBen]

I’m a bit torn. I certainly don’t want to have to through some extensive crash test simulation or 3D modelling of the stresses and strains, or whatever the DVLA might come up with. But what those quotes you included say is actually true. And while this is a small crowd of enthusiasts probably taking good care of their projects because they plan to be driving the vehicle themselves, I can imagine as EVs become truely mainstream, other types of people will get involved. I can imagine dodgy characters start doing quick buck conversions purely to sell on as quickly as possible. It would be the new owners problem if a battery box shifted and crushed them in a crash for example.

It’s a tough one, but the DVLA’s focus will be safe vehicles I guess.

I just hope I get mine done in time before whatever new regime rolls in! Hopefully by summer I’ll be done.

It would be interesting to track any UK build’s experiences with the DVLA if they go through with certification to see how they’re reacting and if they start getting more stringent in anticipation of new rules.

My issue with the comments are the dramatic uses of words like "unknown stresses and strains" and "massive weight of the batteries". Because the stresses and strains are known, we know the nm of torque the motor outputs and the weight of it. The massive weight isn't always that massive, sometimes conversions will come in weighing less than the original. It feels more like the usual scare mongering you hear from people who don't have a clue.

Although it would be good to have at least some set of EV specific rules to follow apart from don't touch the chassis or monocoque body. Right now you can have the most unsafe conversion in terms of EV safety and as long as it looks ok from a glance it will go through.

[itiuk]

My issue with the comments are the dramatic uses of words like "unknown stresses and strains" and "massive weight of the batteries". Because the stresses and strains are known, we know the nm of torque the motor outputs and the weight of it. The massive weight isn't always that massive, sometimes conversions will come in weighing less than the original. It feels more like the usual scare mongering you hear from people who don't have a clue.

Although it would be good to have at least some set of EV specific rules to follow apart from don't touch the chassis or monocoque body. Right now you can have the most unsafe conversion in terms of EV safety and as long as it looks ok from a glance it will go through.

I totally agree, flowery language should have no place in engineering or it's legislation. In this context, there is no such thing as "heavy/massive/light". These things are subjective and cannot be held to account. Numbers and units are objective and can be measured against. Any legislation which pertains to engineering, especially design and performance, which is subjective is something to be cautious of.