ESC mandatory

[spookypt]

Originally Posted by Merv and Sharon

Surely you are not going the 3 wheel trike route Les???? Could be an interesting picture!

I was also wondering if some manufacturers have considered the LCV (low compliance vehicles) route? Particularly those that build complete cars?

Merv

Merv I may be interpreting your previous ? incorrectly so please ignore this if it doesn't apply...

My limited understanding is that no manufacturer of ICV kits can build complete cars under ICV. They can only build kits for Individuals to individually construct. I believe no manufacturer can actually build an ICV for a purchaser like you an me. Effectively that said we assume then that no ICV on the road today or planned for road use to come, has been built or is being built by a KIT supplier??? Harrison, DRB, RCR only sells kits for US to build. That I see in itself is an issue that some may not be too keen highlight...

[Zedn]

My limited understanding is that no manufacturer of ICV kits can build complete cars under ICV. They can only build kits for Individuals to individually construct. I believe no manufacturer can actually build an ICV for a purchaser like you an me. Effectively that said we assume then that no ICV on the road today or planned for road use to come, has been built or is being built by a KIT supplier??? Harrison, DRB, RCR only sells kits for US to build. That I see in itself is an issue that some may not be too keen highlight...

I dont think this is true, i know that Classic revival sell turn key models. Probably others do to. Correct me if i am wrong.

[spookypt]

Zedn if you're right... and you may very well be.

Then they wouldn't be Individually Constructed Vehicles then.....

Would they????

[Merv and Sharon]

You are of course correct Spooky - I was referring to those few in Kitcar mag who do in fact make and sell complete cars by that LCV route. I was wondering if any of our kit suppliers have considered that route for customers who would like a turnkey vehicle?

[400TT]

The National Code states the cut-off for builders assembling ICV's is no more than 3 vehicles per year. It can be the kit manufacturer or a 3rd party. But each state has it's own views on that regulation, some restrict you to only one kit a year. So you need to contact the local transport authority for clarification. It certainly isn't something that the transport authorities encourage, but by the same token the authorities can not discriminate either against an individual who does not have the capability to build there own. I know I have been approached by a physically disabled person looking to own an ICV built to their own specification. Now what do you do then.

Merv, the decision to go low volume path is a complex one. I think you need the right platform to do so. But it does have it's advantages. I've certainly considered the implications, but at the moment I would prefer to just sell kits.

[Zedn]

Is there a difference between low volume and ICV?

Individually constructed vehicles are currently allowed to be assessed for compliance using alternative procedures and exempted from the occupant protection ADR's (Crash testing) because the Federal Department of Infrastructure, Transport, Regional Development and Local Government has a scheme that allows low volume production cars to be complied in this way. That is, the state authorities that register ICV's allow the same freedoms allowed low volume cars by relying on the federal system. (This is set out in the Administrator of Vehicle Standards Admin circular 0-2-13, see RVCS website http://rvcs.dotars.gov.au/). This could be readily extended to allow an exemption from the requirement to have ESC fitted for these vehicles.

[Krait]

Originally Posted by Zedn

Is there a difference between low volume and ICV?

Low volume are vehicles by companies such as Chamonix Australia http://www.550spyder.com.au/ that import 'kit' cars in a broken down form (or not), assemble and compliance them for sale.

Cheers

[Zedn]

Yes, i know what they are. I should have been more clear. Is there a difference in compliance requirements?

[spookypt]

Merv.... It just highlights the many twists and turns that the whole standards issue raise....

I would suggest that LCV in itself is a whole new ballgame again!

[Merv and Sharon]

That was one of the ones I was referring to Geoff. I was wondering if that was an option for some manufacturers and whether they would be affected by the impending rule changes (ESP, etc)? From what Craig has said this is an area that he and others have considered.

Merv

[Krait]

Merv,

Peter Gillard owns Chamonix Australia and is also an approved NSW RTA engineer, guess he knows what is going on.

Cheers

[martrogers]

Success, a reply from Anthony Albanese (or rather Stephen Spencer, Acting General Mgr, Vehicle Safety Standards, on his behalf).

Meat of the letter is:

"The primary focus of your letter appears to be on kit cars that are built as ICVs for personal use. ICVs are regulated by the states and territories.The Department of Infrastructure, Transport, Regional Development and Local Government (the Department) will raise the issue of ESC requirements for such vehicles at the next meeting of the Australian Motor Vehicle Certification Board on 25 November 2009 and provide you with further advice. The Board comprises the Department and territory registration authorities.

Commonwealth certification arrangements apply to vehicles supplied commercially in limited numbers. While no consideration is currently being given to exemptions from ESC requirements, it is open to low volume manufacturers to provide the Department with more details of their cases. The contact is Mr Robert Hogan, the Administrator of Vehicle Standards, on email robert.hogan@infrastructure.gov.au"

So, anyone who has an interest in this issue should probably drop Mr Hogan an email before their meeting. Those who think "she'll be right" should note the last para...

[Zedn]

Martin,

This is a great bit of progress!

Lets all get emails off to Robert Hogan, now is the time to let them know we exist!

Great work Martin!

[Rebel1]

My email will be off tonight.

We also need to spread the word to as many members as possible.

[400TT]

Originally Posted by martrogers

Success, a reply from Anthony Albanese (or rather Stephen Spencer, Acting General Mgr, Vehicle Safety Standards, on his behalf).

Meat of the letter is:

"The primary focus of your letter appears to be on kit cars that are built as ICVs for personal use. ICVs are regulated by the states and territories.The Department of Infrastructure, Transport, Regional Development and Local Government (the Department) will raise the issue of ESC requirements for such vehicles at the next meeting of the Australian Motor Vehicle Certification Board on 25 November 2009 and provide you with further advice. The Board comprises the Department and territory registration authorities.

Commonwealth certification arrangements apply to vehicles supplied commercially in limited numbers. While no consideration is currently being given to exemptions from ESC requirements, it is open to low volume manufacturers to provide the Department with more details of their cases. The contact is Mr Robert Hogan, the Administrator of Vehicle Standards, on email robert.hogan@infrastructure.gov.au"

So, anyone who has an interest in this issue should probably drop Mr Hogan an email before their meeting. Those who think "she'll be right" should note the last para...

Great work.

But this does outline the real problem. It really doesn't matter what the Commonwealth decides as the states and territories can overrule and do so. So a particular state can mandate extra requirements such as ESC even if it is not a National requirement. Just have a look at the rules now, each state asks for extra requirements and those extra requirements are different in each state. Just the way ICV regulations currently work.

[martrogers]

I'm no expert here but it says "The Board comprises the Department and territory registration authorities."

Surely it is worthwhile trying to influence these guys as early in the process as possible? How hard can it be to send an email?

[Rob. Smith]

Could this be the reason Superformance supplies a complete vehicle...less an engine ?

[Modena]

Vic already jumped the gun and are saying it will be mandatory by Jan 1 2011, I am sending that infra guy my email before Nov 25.

[Zedn]

Quick update on this topic.

I received an email from Mr Hogan today as follows:

Dear Mr Martin

As you are aware, the Australian Government announced on 23 June 2009 that ESC would be mandated through the Australian Design Rules (ADRs) for new vehicle models from 1 November 2011. Research both here and overseas has found that the technology has a significant potential to save lives and make our roads safer.

In line with your suggestion, the Department intends to raise the issue of ESC requirements for Individually Constructed Vehicles at the meeting of the Australian Motor Vehicle Certification Board on 25 November 2009. The Board comprises the Department and state and territory registration authorities. I will advise you further of the outcome.

Commonwealth certification arrangements apply to vehicles supplied commercially in limited numbers. While no consideration is currently being given to exemptions from ESC requirements, it is open to low volume manufacturers to provide the Department (me in the first instance) with more details of their cases.

Regards

Robert Hogan

Basically the same response as Martin had, but at least they are aware of the situation.

If any manufacturers are watching this thread, please send off an email to Mr Hogan. I know he is refering to LV manufacturers, but kit manufacturers should also be making noise.

Cheers

[Modena]

I also sent an email to Mr Hogan, will advise if I receive a response.