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Rob Bell

The Hated ULEZ - getting your shitecar exempted

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Hi guys, 

Apologies for raking this subject of ULEZ up again, but living within the iron curtain otherwise known as the A406, I am about to be whacked with punitive taxes based on Emissions (NOx). One of the fleet has to go as a result (2003 MG ZTT CDTi - now FOR SALE) but I don't want to rid myself of my 1995 MGF.

 

Yes, it's Euro2. There's no homologation emissions data for EU2 (only combined HC+NOx), but later MG Rover stuff had NOx under 0.08 (the magic Euro4 number that saves polar bears).  Heck, my Hippo (a 2001 Freelander 1 1.8) is compliant, as too is a ZR105 from 2003 I bought to fix with the kids.

 

Converting my MGF to Euro3 spec is a doddle. I could fit the ECU and emissions equipment from a scrapped later car - but it would need to be TfL approved for it to become emissions exempt. 

 

Has anyone been through this process? 

I had some excitement as I discovered that ancient motorbike-shite could be tested for NOx and approved for emissions exemption. It was a false dawn. Having spoken to Riverbank Motorcycles, they ONLY do bikes not cars. Arrrrggghhh!

 

Any thoughts? I'm not about to give in to this bureaucratic nonsense just yet... ;)

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A little update, I contacted CVRAS via TfL. You'll see my original email below Colin's response below. He was trying to be helpful, but I wasn't asking about Euro4 conversions, as K-series (and I gather some Ford engines etc) are compliant with ULEZ based on their already-low NOx levels (<0.08%).

 

Dear Rob

Many thanks for your email, unfortunately we do not have any approved retrofit systems for petrol cars to take a petrol car from pre-Euro 4 to Euro 4 equivalence. We are not expecting any retrofit system supplier to develop systems for this market sector due to the limited market demand that would justify the investment. TfL would only accept a retrofitted vehicle if the system was CVRAS approved.

I understand this is considered a cherished vehicle but unfortunately not quite “historic vehicle” tax class/status that would be exempt from the ULEZ. The only way I think TfL would recognise your car as ULEZ compliant is if you could provide the evidence to TfL that the vehicle was now Euro 4 level for NOx (i.e. 0.08 g/km or 80mg/km) as tested over the New European Drive Cycle (even though this has been superseded by the WLTC). This would also most likely be needed to get your V5C document changed to reflect the new NOx value and alter the record on the DVLA database. This is not a simple MOT style test and it would need to be conducted at a VCA approved test facility on a rolling road and not cheap to conduct, this could be around £8k to £10k, so along with the cost of the conversion this test would also need to be covered by yourself or the supplier of the conversion. The test would be equivalent to the one conducted by MG to get the original type approval values.

If you are only driving this vehicle occasionally then it may take quite a while to repay the cost of conversion and the emissions approval test when the daily charge is £12.50. Unlike the congestion charge the ULEZ applies all day every day.

The ULEZ policy is designed to deter the more polluting vehicles from driving in the zone in order to improve air quality for all and with the evidence pointing towards the NO2 levels in London leading to more health issues, including cardiovascular problems.

I hope this helps even though it may not have been the response you were hoping to hear.

Kind regards
Colin

Colin Smith
Programme Manager – Freight & Clean Vehicle Retrofit Certification
Group Transport

Energy Saving Trust | 30 North Colonnade | Canary Wharf | London | E14 5GP

From: Bell, Robert
Sent: 15 November 2019 14:51
To: CVRAS <[email protected]>
Subject: Rover 4-cylinder K-series engines

Dear CVRAS team,

I am writing to ask about certification for my 1996 MGF. It currently has an EU2-compliant K-series engine and engine/emissions management system. I can up-grade this to the later EU-compliant specification by fitment of the newer engine management, ignition and emissions equipment.

As you know, EU3-compliant 4-cylinder Rover K-series engines are ULEZ compliant by dint of their lower homologated NOx emission.

Can you give me the process by which I can convert my car and gain appropriate regulatory approval? (I will live within the extended ULEZ zone when it expands to the North Circular – I do not use my car for commuting, only for weekend social use).

Many thanks for your help

Rob



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To get approval, I think the approach will either be:

  1. Get the exhaust emissions tested by a TfL approved testing location. The protocols and the emission limits are different between cars and motorcycles, so unfortunately it would seem that Riverbank Motorcycles is not going to be the route that will work.
  2. Work out a way with the DVLA to get the car certified by retro-fitting a later car's ECU and emissions equipment

I have a sneaking impression that Euro2 K-series may have a low NOx rating out of the box, but proving this may be prohibitively expensive :(

Is there another approach anyone has used?

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This is a good thread. I've often wondered if there is anything that can be done to prove that cars running on lpg are compliant, as lpg is supposed to have much lower NOX emissions due to running cooler, but actually proving it would be a hassle.  I've had products approved by VCA before and they really know how to charge.

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39 minutes ago, purplebargeken said:

Clone some plates from a bloody electric car.

ULEZ grumble, grumple, grumble.

 

I’d be highly tempted to acquire a very very fucked compliant one and use the plates on the earlier one. Insurance would be my worry with that, but solvable easily I would have thought.

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There is another solution but one you may not like. simply move out of the area. Radical I know. It does seem to me that anywhere within the M25 is becoming the preserve of the wealthy. What with the outrageous rents and property prices and now all these emission zones. I must admit it would be one hell of an upheaval for the sake of an old but cherished car.  

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2 hours ago, 2flags said:

There is another solution but one you may not like. simply move out of the area.

I wish I could move out! I was born here, didn't move here by choice!

I solve the ULEZ problem by getting a 43 year old Invacar, pretty much exempt from everything :mrgreen:

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All classics which are MoT/Tax 'historic' exempt are ULEZ exempt - find a diesel Merc of that era and you'd be fine - still pretty usable.

Me - I'm going to import something from France in that category as there is a bit more choice than what is on offer in the UK.  A Peugeot 404 - possibly of which there are plenty about and not too pricy.

This ULEZ approach will be adopted by other UK cities in due course...

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1 hour ago, lesapandre said:

This ULEZ approach will be adopted by other UK cities in due course...

Not here in Nottingham it won't (yet)

https://www.transportnottingham.com/no-clean-air-zone-for-nottingham/

(Council's decision was ultimately approved by Ministers - https://www.fleetnews.co.uk/news/environment/2018/11/23/government-approves-nottingham-s-air-quality-plan )

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As you like Rovers how about an old P4? If you don't do many miles, living in London you wont travel far. You can then travel in stately splendour. 😁😁😁 

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5 minutes ago, 2flags said:

As you like Rovers how about an old P4? If you don't do many miles, living in London you wont travel far. You can then travel in stately splendour. 😁😁😁 

Streetwise is ULEZ compliant if I ever want to go to that there London (which I don't). Good old Rover and their EU4 engines, well ahead of the game.

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On 11/30/2019 at 4:42 PM, Ian_Fearn said:

Classic Car Weekly ran a story on this:

 

1FDDD432-F9D2-4E45-8B04-C243CF1443B8.jpeg

Thanks - that's exactly what I thought would be the case, thanks for posting this Ian! :D 

Unfortunately, what the article does not indicate is HOW to prove to TfL that your car is compliant. I reckon my old MGF will be compliant with its EU2 engine - particularly as the ECU enables tweaks of ignition and fuelling to get the NOx levels "just so".

 

I know Dave Andrews - I'll drop him a mail, and I'll see if I can get hold of Charlie Calderwood to see whether he is aware of the process of retrograde exemption :D

 

[PS - could move out of London: you don't know how many people have suggested this! Kids would kill me however LOL And I already have a Mk3 Triumph Spitfire and a really nice and toxic 1929 M-type - so that'll be fun! Want to keep the shite old MGF though - I bought it new in 1996 and it has too many happy memories associated with it :D]

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I have had a really useful conversation with Charlie Calderwood. There is no proven route for retrospective approval, and all TfL are prepared to accept that it is "possible". 

 

Charlie had the good suggestion of using an IVA test centre for measuring the emissions - that might be a good way forward as there does not appear to be an alternative option available for us with cars. But at the moment, I don't know who at TfL would be responsible for taking this "proof" and getting the APNR database updated with your now "clean" car's details? I may need to give Riverbank Motorcycles a call to understand the process for bikes, as one might imagine the process ought to be similar for cars...

 

Will keep you all updated! :)

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I contacted Riverbank Motorcycles to see who their contact was at TfL. Unfortunately, for confidentiality reasons, they could not give me this information. Understandable, if a little frustrating.


I'll try and contact one of the local IVA test stations to see whether they would be able to undertake NOx emissions testing on road cars. And then work out who'd they'd need to liaise with at TfL to get retrospective exemption...

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On 11/25/2019 at 1:22 PM, Rob Bell said:

One of the fleet has to go as a result (2003 MG ZTT CDTi - now FOR SALE) but I don't want to rid myself of my 1995 MGF.

 


Any more info or a link to the ZTT for sale? I sort of fancy having another one and diesel might make more sense this time round

As for the MGF, I hate to say it but it might actually work out cheaper to just pay the charge, depending on how often you actually use it?

 

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On 12/1/2019 at 2:41 PM, lesapandre said:

All classics which are MoT/Tax 'historic' exempt are ULEZ exempt - find a diesel Merc of that era and you'd be fine - still pretty usable.....

Although I live outside ULEZ, I hope the CX will survive long enough to pass into historic exemption, at which point I will increase the dosage of tetraethyl lead before crossing the North Circular into the forbidden land. Is all very well having an exclusion zone, but wind direction doesn't necessarily respect zones, so expect a lot of pollution around the perimeter and just inside the zone as well.

Another nine years to go....

 

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39 minutes ago, Dan_ZTT said:


Any more info or a link to the ZTT for sale? I sort of fancy having another one and diesel might make more sense this time round

As for the MGF, I hate to say it but it might actually work out cheaper to just pay the charge, depending on how often you actually use it?

 

I've dropped you a PM about the ZTT Dan :)

As I have two MGFs, and one goes racing, spewing CO2s and HCs into the hedgerows, I will be paying the ULEZ charge when I drive that as strangling it with emissions tune won't be making it any faster. For my other MGF, if I can find someone who can do the same as Riverbank Motorcycles (who definitely are not VCA) and can do the test on smelly 35 year old two-strokes for £175. then that's my preference: that's little over 10 days' usage. 


But it may cost more for cars. Let's see. I've contacted a privately run IVA approved test centre to see whether I can get them to bite :)

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I think that TFL simply follow the NOx numbers on the V5 document.  They will accept any car that says that it is Euro4 on the V5, or one with emissions on the V5 that are lower than the Euro4 limits.

In fact they have proven to be quite pragmatic about judging cars on the emissions numbers rather than the certification.

I don't think that it's TFL that you need to argue with but the DVLA. 

Maybe you should ask them if you put the engine and emissions controls from another car would they put the emissions data from that car onto the V5 ?

I know that you don't want to swap the engine but somehow I suspect that might send them down a different path.

Your only other option is car storage outside of the A406. 

Otherwise this is the end of Japanese and US imports in London as well.  I wonder what the stretched limo for hen night business will do?

I also noticed that they are updating the LEZ for commercial vehicles to Euro 6 for diesels which could be quite annoying for folks that spent thousands on retrofitting DPFs onto commercials a few years back if they are not accepted.

Lastly, there are a few routes in and out of the LEZ zone on which there are no cameras and which people have been known to sneak non compliant commercials in and out of London on.  You only have to find one road from the A406 to your house with no cameras on it and then park up with a cover over the car.  You could even register the car on the "automatic payment" thing for ULEZ just in case it gets spotted.

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I think the problem with this is that the NOx number on the VIN plate and logbook is averaged over some sort of cycle, not based on a static test. 

TFL have clearly managed to figure something out for motorbikes, can you get in touch with the magazine the article is from and ask them for some contacts at TFL/DVLA?

Good thread though, keep us posted.

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1 hour ago, dieselnutjob said:

I think that TFL simply follow the NOx numbers on the V5 document.  They will accept any car that says that it is Euro4 on the V5, or one with emissions on the V5 that are lower than the Euro4 limits.

In fact they have proven to be quite pragmatic about judging cars on the emissions numbers rather than the certification.

I don't think that it's TFL that you need to argue with but the DVLA. 

Maybe you should ask them if you put the engine and emissions controls from another car would they put the emissions data from that car onto the V5 ?

I know that you don't want to swap the engine but somehow I suspect that might send them down a different path.

Your only other option is car storage outside of the A406. 

Otherwise this is the end of Japanese and US imports in London as well.  I wonder what the stretched limo for hen night business will do?

I also noticed that they are updating the LEZ for commercial vehicles to Euro 6 for diesels which could be quite annoying for folks that spent thousands on retrofitting DPFs onto commercials a few years back if they are not accepted.

Lastly, there are a few routes in and out of the LEZ zone on which there are no cameras and which people have been known to sneak non compliant commercials in and out of London on.  You only have to find one road from the A406 to your house with no cameras on it and then park up with a cover over the car.  You could even register the car on the "automatic payment" thing for ULEZ just in case it gets spotted.

Which routes into London? Seems unlikely? 🙄

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My point is that the current ULEZ is a small area and so TFL can cover all roads in with cameras. The current LEZ is the whole M25 and there odd roads in and out that don't have cameras. Eventually I'm sure that you would pass one but there are pockets of greater London that you can get in and out of. 

The new ULEZ zone will be pretty big with thousands of roads crossing its boundaries. 

It wouldn't surprise me if there are certain side streets and small areas where it just won't get enforced because it won't be worth it for them to put up cameras. 

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I’ve anecdotally heard that you can update the database if your manufacturer holds emissions info, you just submit letter-headed paper from the manufacturer, so it’s definitely update-able. It works for circa 2003 Vespas for instance where they’re not Euro3 certified but are below the limit. I reckon the equivalent of Riverbank motorcycles but for cars will pop up before too long- people were really quick to sell old Vespas and the like, before it surfaced that they could be got through a test or update the database with manufacturer info. 

Speculation obviously, but I do sometimes wonder if it will go ahead at all. The inner ULEZ is made possible by having the same boundary as the congestion zone hence piggy backing on those cameras, whereas the the outer ULEZ would take one hell of a lot of infrastructure to enforce. Whilst I don’t think it’s a political issue, I can imagine a scenario where if a conservative mayor gets elected in 2020 they wouldn’t pursue it as hotly and could potentially de-prioritise it. Also residents within the current ULEZ got a grace period, so perhaps that’ll buy you another year if the same logic is applied. 
 

TL;DR: I live within the boundary and I ain’t selling anything just yet! 

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4 hours ago, Fabergé Greggs said:

.... I do sometimes wonder if it will go ahead at all. The inner ULEZ is made possible by having the same boundary as the congestion zone hence piggy backing on those cameras, whereas the the outer ULEZ would take one hell of a lot of infrastructure to enforce. Whilst I don’t think it’s a political issue, I can imagine a scenario where if a conservative mayor gets elected in 2020 they wouldn’t pursue it as hotly ....! 

When Mayor Ken extended the Kengestion Charge to cover the West End (subsequently reversed by Boris) it wasn't a problem to install more cameras. The speed with which they were installed was frightening. 

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