391 replies to this topic

[CMcB]

Latest email:

"Approvals
Testing and Support Services (TaSS)
VOSA,
Ellipse,
Padley Road,
Swansea,
SA1 8AN.
Hi Craig,

As I stated in my previous e-mail, if a Mini is coming through the IVA
scheme, then it has almost certainly lost its original identity (V5 revoked
by the DVLA). Under these circumstances it will be issued with a new
chassis number and treated as a new vehicle for the purpose of IVA testing.
Therefore, the original date of manufacture is of no relevance.

It would be wrong to assume that all vehicles would fall under BIVA as this
is only the case if this exemption is proved by documentary evidence. By
default, all vehicles fall under NIVA until exemption is proved.

IVA is a complete check of the vehicle in all areas, not just the area that
is modified. This is because the vehicle is being approved as a complete
vehicle (hence the new chassis number) not as a component part.

With regard to your second e-mail, I am unable to comment on registration
matters, as I stated previously, but my understanding is that vehicles
could be issued with either a Q plate, an age related plate or a new
registration mark, depending upon the components used in the vehicle build.

Best regards,

Mark

Mark Vickers Eng Tech MSOE MIRTE
Technical Officer
Approvals
Passenger Cars & Light Goods Vehicles
Vehicle & Operator Services Agency
Department for Transport.

[dave21478]

Actually, I think it is correct

"If the vehicle is accompanied by satisfactory evidence of compliance with interior fittings and the vehicle does not appear to be modified such that it would affect the evidence, the requirements of this section may be considered to be met."

and

"Interior fittings:
Required Standards 1+2 (edge curvatures) will NOT apply to any part of the internal surfaces of a mass produced vehicle provided it is as originally manufactured."

Edited by dave21478, 15 July 2009 - 11:46 AM.

[Ethel]

I had a bit of a nose through the IVA manual from Craig's links last night.

It might be worthwhile making some Mini specific enquiries for anyone putting one through IVA. If people are importing them back from Japan they have probably already been considered, and there's the MiniSport Moke kits.

Steering Column: Will a collapsible wheel spacer be sufficient? I couldn't find anything that defined the deformation only that there should be some.

My personal take - Mini steering columns aren't inline with a likely frontal impact as much as other cars and have a large unfixed portion at the driver's end - a severe impact is as likely to bend the column or the mounting bracket and pivot the wheel away from the driver. I interpreted it as you're in the clear if it's an import with an Airbag but you can't fit an airbag to a self build, the implication is that the collapsible column is only to cushion an impact and not ensure the column doesn't enter the space occupied by the driver

Fuel Tank - Saloon: Is the location considered to be sufficiently inside the vehicle structure? Are extra sealing measures required to separate the boot from the passenger compartment required? If so, is there any criteria? I'm guessing blutack or cellotape are out!

Fuel Tank - Van/Estate: again, is the location ok. Any issue over proximity to the exhaust or the vented filler cap / lack of vent pipe?

Other than the above I don't see why the lil sod should have any problems with a test but there might be the odd sharp corner lacking a sufficient radius it would be good to know about.

[CMcB]

Actually, I think it is correct

Hi Dave, See my previous post with email from VOSA and highlighted sections. From what Mark has said the whole car will be treated like an unregistered newly built car.


As has been mentioned the Mini could be modified to pass the IVA - but from what I've been told its braking system alone would fail it, aside from other points listed in the document (sharp edges - ie roof gutter, wheel arches (with no arch on), fuel tank, collapsable steering wheel, head restraints, seatbelt anchorage points etc...).

The main point is to try and avoid the IVA altogether, and this is where it goes in to 'grey areas'. Having spoken to ACE and VOSA (and awaiting a reply from the DVLA - today or tomorrow hopefully), it has been suggested that there are no 'hard and fast' guidelines to what constitutes a mod - which is REALLY unhelpful to us as a community.

Basically as soon as you stray outside of what's allowed by the DVLA they will revoke the registration and put you through an IVA - which means a lot more expense to pay for the IVA and modify the car. As far as I am aware, and from the information given in emails by Mark from VOSA, once the DVLA revoke the registration the only way that car can get back on the road is by conforming to IVA standards (which are 2009 regs).

Edited by CMcB, 15 July 2009 - 12:01 PM.

[MK1]

Whaaaaaaa

Can someone tell me if I'm on the right lines here.

If you have a totally standard car, that seems correct with the DVLA records...you go to the MOT station and you pass (haha yea right) and thats the end of it?

Its only Minis that have either a lost identity or chassis/shell chop/modifications that will need this IVA to drive on the road. What about complete re-build projects with new A-series engines/brakes/suspension/interiors?

Edited by MK1, 15 July 2009 - 12:01 PM.

[CMcB]

Whaaaaaaa

Can someone tell me if I'm on the right lines here.

If you have a totally standard car, that seems correct with the DVLA records...you go to the MOT station and you pass (haha yea right) and thats the end of it?

Its only Minis that have either a lost identity or chassis/shell chop/modifications that will need this IVA to drive on the road. What about complete re-build projects with new A-series engines/brakes/suspension/interiors?

If your Mini matches the description the DVLA has, then no problems.

The problem occurs if the car has been modified and the DVLA not been informed and someone dobs you in (mot tester, police, public). Shortys are a prime example, as are roof chops, home-made cabrios etc.

There is a grey area which we are trying to clarify at this moment about how this affects people who buy aftermarket items, and what the DVLA needs to be informed of and what could possibly land you with an IVA call up - which is something we dont want.

Edited by CMcB, 15 July 2009 - 12:14 PM.

[MK1]

Whaaaaaaa

Can someone tell me if I'm on the right lines here.

If you have a totally standard car, that seems correct with the DVLA records...you go to the MOT station and you pass (haha yea right) and thats the end of it?

Its only Minis that have either a lost identity or chassis/shell chop/modifications that will need this IVA to drive on the road. What about complete re-build projects with new A-series engines/brakes/suspension/interiors?

If your Mini matches the description the DVLA has, then no problems.

The problem occurs if the car has been modified and the DVLA not informed and someone dobs you in (mot tester, police, public). Shortys are a prime example, as are roof chops, home-made cabrios etc.

There is a grey area which we are trying to clarify at this moment about how this affects people who buy aftermarket items, and what the DVLA needs to be informed of and what could possibly land you with an IVA call up - which is something we dont want.

If the owner of the car has done everything legally...such as informing them of a change from a 998 to a 1275, is that not an issue?

[CMcB]

If the owner of the car has done everything legally...such as informing them of a change from a 998 to a 1275, is that not an issue?

If you have informed them of the change and they have acknowledged you, then it is fine.

[dave21478]

GENERALLY SPEAKING - iva is only required if you have altered the shell or chassis of a car. Bolt-on parts will not require iva testing. HOWEVER, using a load of used parts from another donor car on an unmodded (and therefor not needing iva) shell will make you fall foul of the DVLA`s points system for keeping an existing registration on a reconstituted vehicle. If you cant keep your registration, you will need to take the test.

The only real grey area is what they consider to be a modification to a shell/chassis. Replacing parts like-for-like during a restoration wont, but welding on new mounts for alternative engine or suspension might do, whereas lengthening/shortening a chassis definately will do.

[BoboGib]

where do you think chopping inner wings for a flip front will fall?

[ferrit]

Dave whats your thoughts on flip fronts and f/glass or CF front ends. In my uniformed opinion these would constitue a significant change to the monocoque. That said previous concensus was that the affect on the structural strength of the front end was minimal and nothing that couldnt be rectified by installing brace bars to the inner wings/subframe (even this requirement has been questioned in the past where solid subbie mounts are used.)

whoops as above

Edited by ferrit, 15 July 2009 - 12:24 PM.

[Ethel]

It takes us back to the points counting.

Your car will never need IVA if it has a V5 unless they decide it isn't the car described by the V5.

From a previous enquiry with the DVLA they have 29 data fields to store the info on your car under. They will only be able to record info that fits one of those fields and it's changes in those they ask you to notify them of - as listed earlier. (Ferrit - page 14)

An MoT covers everything that an IVA would for things like wheel arches and flip fronts.

[miniman_78]

This law will not only affect you guys but also people over here in belgium. We already have a law like that over here for about 4 or 5 years. The only way there was left for people with kitcars or heavely modded cars (chopped or none original mini engines) was to export it to the uk, get a SVA, register it and import it back to get a SVA here an get it legaly registered. Its expensive but its the only way to do so. So if that law comes that would be the dead of kitcars in Belgium.

We are not even allowed by law to change the wheel size, steering wheel, seats or convert from drum to disc brakes ( or even upgrade the brakes or exhausts without a certificate), put in a front roll cage or change anything on the suspention . Luckely for us minidrivers the people of the MOt are not that used to deal with mini's and don't always see all the moddifications. Downsize on the other hand is they sometimes see mods that aren't even there . If we for example tint the windows or put a bodykit or wide arches on, or even big stereo they mark it now as tuning and we have to pay extra for MOt.

It even happens that the police knows when and where meetings are for tuned cars and they wait at parking lots where they know people come together to travel in a group to the show and they take them to an MOt center to check the cars. They even stop people at the roadside and get a full check if they think something is modded. At the Mot center they can see what kind of brakes, wheels, tyres or suspencion you'll need to have in the computer.

I have friends who are hardcore tuners who only use the cars to go to shows and they need to change a lot of the car to go to the MOt, sometimes that's 3 days of work to convert, get an MOt and convert it back. They even start trailering unregistered cars.
The real bad thing about the law is that there are more and more people who don't get an MOt and drive around without insurance with badly tuned cars and the real passionated tuners with expencive but save cars that are even tuned within the regulations get a bad name from this.

As I said before how it works over here in belgium and now read the rest of the discussions I have to mention some more on this topic. People are saying (or thinking) here if you modd your mini it needs an IVA. This was a discussion over here as well wen the law came true. First: You guys know it already 3 years before it comes in. We only knew it 3 months before date!! The first year about 1 car of 4 failed the MOt at some point because something was modded. 1 of 100 failed seriously and wasn't alowed to drive anymore. All we had to do was to convert it back to standard or get back with a certificate stating it was CE aproved and in some cases was converted by an approved person or compagny. But what is not approved is to convert the brake set up or the suspention i.e. in mini case rubber spring to coil over, drum to disc; air ride on all type of cars... An other example mini bassed: standard the geometry setup is not adjustable so we are not allowed to change it with adjustables.
What happens is that mostly they don't even see it at MOt or don't even know how some things supposed to be and you pass. If they see it you don't and have to come back in standard form. If some is lucky enough they don't see it for years.
But there is a way to pass this. We can get a sort of approvel testing (no ISA) where all the mods get full checked and tested. I.e. An '83 mini changed with disc brakes set up, fully adjustable suspention, 13" wheels, coilovers, 1300 turbo or supercharger? normal MOt failed all the way. Get an approvel testing and declaired ok--> You KEEP your VIN number, just are given a from with all the mods marked on and clear to pass further MOt's with the mods.
This is also the case in other european country's so if the VOSA or DVLI is changing to the EU norm there is a big chance it will be the same in the UK.
NOTE. FLip fronts are not allowed. Vtec-cars Zcars shorty's ex. are seen as kitcars, they need an ISA and get a new VIN. If I'm not wrong Zcars tryed to get 2 cars registered over here 2 years ago and they failed because they were not conform to EU regs.

[dave21478]

Actually, I think it is correct

Hi Dave, See my previous post with email from VOSA and highlighted sections. From what Mark has said the whole car will be treated like an unregistered newly built car.


As has been mentioned the Mini could be modified to pass the IVA - but from what I've been told its braking system alone would fail it, aside from other points listed in the document (sharp edges - ie roof gutter, wheel arches (with no arch on), fuel tank, collapsable steering wheel, head restraints, seatbelt anchorage points etc....

I lifted this from the RR thread,....

"Interior fittings:
Required Standards 1+2 (edge curvatures) will NOT apply to any part of the internal surfaces of a mass produced vehicle provided it is as originally manufactured."

which is lifted from the IVA manual, (i cant access the manual from this computer) so even though the whole car hs to be tested according to your email reply, the interior doesnt have to meet modern standards.

As for the rest, brakes, I would have to read the manual, but I see no reason a well serviced minis brakes wont meet requirements. (front drum efficiency is the only thing I can think of, I suppose)

Same for the rest, I would need to study the manual in detail for the specifics. However, this car....

has passed the test. its not a great pic, but a quick look shows some kind of guttering, square edges to the load bed edge, the pointy sunshade, some kind of bonnet emblem, suicide doors, and several other things that at first glance, would arouse suspicion regarding exterior projections. It just shows that there is always a way to get anything to conform. A baremini gutter would fail, but what if it has the std plastic trim? iirc that edge of that should be within the radius spec. Take the suicide doors on that car. the manual specifically states that all doors must hinge from the front edge. yet he has managed to get this passed, as you CAN have rear-hinged doors as long as you have a warning buzzer that sounds if its not closed when the ignition is on. Its just a case of studying the manual in detail and carrying out your modifications accordingly.
Anyone who is capable of modifying a car enough to require an IVA (altering the bodyshell for coilovers or a different engine) should be well capable of making it conform too.


By the way, Im not deliberately being argumentative, I just believe that the problems are not as serious as people presume, and that nothing in insurmountable. There is no reason for anyone to bury their head in th sand and hope this will go away - it wont, but as long as people are well informed of the facts, they should have no fear of modifying their cars as the wish. What people DEFINATELY need to do is support ACE who are looking to the future for whatever may be next on the horizon for our hobby.

Edited by dave21478, 15 July 2009 - 12:39 PM.

[dave21478]

A flip-front will definately need an IVA imo, you are removing the front 30% of the monocoque and replacing it with some steel tube and a bit of fibreglass. This is imo obviously a radically altered shell.

Its my personal opinion that flip-fronts are a very bad idea indeed. Yes, they have been done for decades, and yes they will pass an MOT and yes, the front of the subframe is adequately supported by brace bars, BUT removing welded-on panels drastically alters the oveall stiffness of a shell, and will have a serious effect on how it performs in extreme circumstances like a crash. Minis are not strong impact resistors anyway, but if I had the choice of crashing a std one or one with a fibreglass flipfront, then I choose standard every time.