Davie F · Feb 25, 2011

Thank you for your e-mail enquiry dated 23rd February 2011, concerning new MOT rules.

EU Regulation 2010/48 refers to inappropriate repair or modification to springs or stabilizers and I presume that is what you are referring to. This (and others) is component specific e.g. the springs themselves, and would not apply just because the vehicle has been modified by fitting a different type of suspension.

This is the reply I got from VOSA, it pretty well sinks the debate as to weather this will apply on the coil conversion kits. Thank god as I for one do not want to change back to EAS. That will mean the Rangie stays and does not get replaced by a Landcruiser. For the EAS brigade-one argument gone.

Davie

wammers · Feb 25, 2011

Davie F said:
Thank you for your e-mail enquiry dated 23rd February 2011, concerning new MOT rules.

EU Regulation 2010/48 refers to inappropriate repair or modification to springs or stabilizers and I presume that is what you are referring to. This (and others) is component specific e.g. the springs themselves, and would not apply just because the vehicle has been modified by fitting a different type of suspension.

This is the reply I got from VOSA, it pretty well sinks the debate as to weather this will apply on the coil conversion kits. Thank god as I for one do not want to change back to EAS. That will mean the Rangie stays and does not get replaced by a Landcruiser. For the EAS brigade-one argument gone.
Davie

So the fact that the type certification for the P38 lists variable air suspension with certain built in safety features, which are removed when coils are fitted means nothing then? We will have to wait and see.

Golan · Feb 25, 2011

wammers said:
So the fact that the type certification for the P38 lists variable air suspension with certain built in safety features, which are removed when coils are fitted means nothing then? We will have to wait and see.

Amen brother...

paul_c · Feb 25, 2011

wammers said:
So the fact that the type certification for the P38 lists variable air suspension with certain built in safety features, which are removed when coils are fitted means nothing then? We will have to wait and see.

What type certification requirements do variable air suspension achieve, which coil springs can't?

Golan · Feb 25, 2011

paul_c said:
What type certification requirements do variable air suspension achieve, which coil springs can't?

Well I'm no expert but if you can make a tall car lower when traveling at speed it's going to be safer and more stable....
That's how it was built.
Springs can't do that.

paul_c · Feb 25, 2011

I'll accept its safer/more stable, but is it a type approval requirement for cars to become lower at speed?

wammers · Feb 25, 2011

paul_c said:
What type certification requirements do variable air suspension achieve, which coil springs can't?

Automatic leveling no matter what the weight distribution in the vehicle. For stability. Automatic squad position to lower C of G at speed. For stability and handling when sharp evasive manouves are required. They don't go out of control or roll as easily. Springs take all that away. Fitting springs removes built in safety features in my book. That is inappropriate modification to me. But we will have to wait for VOSAs interpretation of the regs and the **** to hit the fan. Maybe it won't, maybe it will.

wammers · Feb 25, 2011

paul_c said:
I'll accept its safer/more stable, but is it a type approval requirement for cars to become lower at speed?

It is for the P38.

Davie F · Feb 25, 2011

Ever been in one when an airbag has let go, I have and that was the final nail in the coffin for the EAS as I thought I was going to end up in the coffin. Air bags, air lines, compressors, electronics safer ! give me strength. The ONLY downside is the car does not lower so getting in and out for anybody with mobility problems is a problem. It has a very predictable and stable ride with the coils. And by the way that is an official reply I got from VOSA this morning as enough speculation so I got the official line. It's not people like me fitting coils that is dangerous it's those that try to run them on a shoe string and don't maintain them right or run the tyres to the minimum before getting new ones and please don't start me about 2nd hand tyres. Safety and maintenance I'm all for, not scare mongering by people who have probably never tryed one on coils. On motorways I can understand the advantage of the motor being able to lower itself but luckily up in the forgotten part of the UK (N E Corner of Scotland) we have no motorways but plenty potholes
Davie

kooky_guy · Feb 25, 2011

It doesn't alter the fact that the type approval for P38s was only for automatic air suspension and NOT coils.

I think the reply from vosa is misleading. On first reading it appears to support your assertion, but reading it again it sounds like the usual non commital response from someone who doesn't understand what they are being asked.

What you're doing by fitting coils is to make a non type approved modification which I think would be the 'inappropriate repair or modification' mentioned in the Vosa reply.

It's probably just the sort of thing that nobody will stick their neck out and make a definitive statement about until there is a serious accident (or an expensive insurance claim!).

jamesmartin · Feb 25, 2011

with the right coils and shocks they can be made to handle far better than air

paul_c · Feb 25, 2011

kooky_guy said:
It doesn't alter the fact that the type approval for P38s was only for automatic air suspension and NOT coils.

You're right, it doesn't alter that fact.

However in UK law, its not illegal to modify a car, ie alter or replace components which were once assessed as part of type approval.

kooky_guy said:
I think the reply from vosa is misleading. On first reading it appears to support your assertion, but reading it again it sounds like the usual non commital response from someone who doesn't understand what they are being asked.

It makes sense to me, because I understand what they're being asked, and how their reply clarifies this. They're not interested in type approval, merely the checking of the components of a car when its presented for MoT. They're saying so long as the suspension components, whatever they might be (air or coils) are not inappropriately repaired or modified, then its ok. eg a whole coil spring which is unaltered, but not original for the car, is still okay; but if that coil spring were cut (eg as some people do to lower their cars!) then the tester may well assess that as an inappropriate modification and fail the car.

kooky_guy said:
What you're doing by fitting coils is to make a non type approved modification which I think would be the 'inappropriate repair or modification' mentioned in the Vosa reply.

Most modifications don't need to be type approved. They just have to comply with Construction & Use law.

kooky_guy · Feb 25, 2011

paul_c said:
You're right, it doesn't alter that fact.

However in UK law, its not illegal to modify a car, ie alter or replace components which were once assessed as part of type approval.

It makes sense to me, because I understand what they're being asked, and how their reply clarifies this. They're not interested in type approval, merely the checking of the components of a car when its presented for MoT. They're saying so long as the suspension components, whatever they might be (air or coils) are not inappropriately repaired or modified, then its ok. eg a whole coil spring which is unaltered, but not original for the car, is still okay; but if that coil spring were cut (eg as some people do to lower their cars!) then the tester may well assess that as an inappropriate modification and fail the car.

Most modifications don't need to be type approved. They just have to comply with Construction & Use law.

Hmm. Well put.

Datatek · Feb 25, 2011

It does not get round the requirement for headlight leveling which is done by the EAS on the P38.

Davie F · Feb 25, 2011

Well its there in black and white, I got fed up with the speculation and went to the source, if anybody wants to argue with VOSA I,ll supply the officials name. You could almost guarantee that this ruling would stick in the EAS brigades throat and like Paul it makes sense to me.
Davie

wammers · Feb 25, 2011

However in UK law, its not illegal to modify a car, ie alter or replace components which were once assessed as part of type approval.

No your right it isn't, but it will be when the new European regs come out from what i have seen of them. It will be illegal to fit brighter head lamps, that are not standard to the car for instance. Could be a bloody minefield this, depending on how it is interpreted. Might be a godsend for a government dedicated to getting older vehicles off the road. We will have to wait and see, but don't be surprised if everything goes tits up.

kooky_guy · Feb 25, 2011

wammers said:
However in UK law, its not illegal to modify a car, ie alter or replace components which were once assessed as part of type approval.

No your right it isn't, but it will be when the new European regs come out from what i have seen of them. It will be illegal to fit brighter head lamps, that are not standard to the car for instance. Could be a bloody minefield this, depending on how it is interpreted. Might be a godsend for a government dedicated to getting older vehicles off the road. We will have to wait and see, but don't be surprised if everything goes tits up.

And of course the rest of the EU will ignore any new rules like they usually do anyway.

fanatic · Feb 25, 2011

one of the cars 90w /100w lamps in car, reason being is you can't see with standard lamps-passes an mot, nobody ever flashes for being too bright and due to deterioration of headlamps the light is same as standard lamps.

The law is an arse

Davie F · Feb 25, 2011

We are the boy scouts of europe thats true but like the headlamps I read that you can upgrade the bulbs as long as they are legal and not just like for like. Coloured bulbs will be illegal and a failure but they already are. As far as I can see if its legal like a bulb upgrade (or coil conversion) its ok.
UKIP for me (hope that does not break the forum rules)
Davie

wammers · Feb 25, 2011

kooky_guy said:
And of course the rest of the EU will ignore any new rules like they usually do anyway.

Of course they will, we are the only planks in Europe who obey the rules.
I can see VOSA bringing in a vehicle check for modded cars. Were you have to go to a VOSA station and have your car inspected by someone who knows as much about them as i do about nuclear fusion by has done a NVQ in testing. "Yes sir your car if fit for the road that will be £150.00 please". "Don't for get you will have to bring it back and have a retest if you fit larger numberplate lamp bulbs". "But the retest is only £50.00. "Have a nice day".

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