VERY NASTY INFORMATION FOR US ALL?

General General Lotus Talk
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Have a read at this lot: the difinitive answer to my rambling questions regarding tuning new cars, specifically the Elise. Lifted from Rob’s excellent www.elises.co.uk site this is terrible news for the uk tuning industry and also for any DIY’ers out there. I do have an issue with it which I’d like some opinions on but read this firstAhem…Since the 1st of January this year all new cars sold within the European Community with full vehicle type approval have had to comply with new exhaust gas emissions regulations, which came into force on that date. These regulations are as ECD 3 (European Community Directive step 3). They called for a reduction in the emissions of noxious gases from cars, but also introduced a requirement for a self checking system, which monitors the function of the emissions control systems. This was done so that in the event a malfunction which causes more pollutants, the driver would be made aware and should take immediate action. This system, known as On Board Diagnostics (OBD), is similar to that introduced to the USA a few years ago. In the event of the OBD system identifying a fault it illuminates a check-engine light or Malfunction Indicator Lamp (MIL) on the dashboard. When this lamp illuminates the driver is legally obliged to make arrangements to have the car checked at the earliest opportunity. There is currently no method to monitor the period of time the lamp was on before action was taken, but this will probably be introduced later as ECD 4, which is due in 2004. The Elise will fail its MOT if the lamp is illuminated, even if the emissions meet the required standards. The system works by continually monitoring the outputs from all of the sensors that are used to control the engine emissions (throttle position, MAP, O2 (pre and post Catalyst), crankshaft position, coolant temperature sensor, etc) and compares the outputs with pre-defined, acceptable ranges, for given engine speed and load. If any sensor moves outside these ranges the system will assume there is a fault and will illuminate the light. The system monitors other factors such as vehicle acceleration (through rate of change of engine speed) and if any of these go outside normal limits again the light will illuminate. Changing any components which affect the performance or emissions of the car (air cleaner, catalyst, wheel/tyre size, etc.) may put the sensor readings out of normal range and the lamp will illuminate. Lotus approved tune up parts will be fully tested to ensure they do not make the lamp illuminate or will be sold as off road/track parts only. The latter will cause the lamp to illuminate and you will not be able to legally drive on the road. There are a number of safeguards built in which will prevent false illumination of the light in the event of a momentary false reading etc. The number of events necessary to illuminate the lamp depends on the sensor/system being monitored and the amount of the deviation from normal. The system only functions when the engine is running, so a flat battery will not cause the light to illuminate. Once illuminated the light will however stay on, as long as the fault is present. If/when the physical fault is no longer present and the appropriate built-in OBD check has been passed on three consecutive trips, then the MIL will go off. The fault’s associated code will still be stored, until the appropriate OBD check has been passed on forty consecutive trips. Because the system is fully integrated with the engine management system and uses all of the sensors that are needed to run the engine, it is not possible to bypass the MIL. The only method would be to totally replace the engine management system with another non-OBD system. This equates to breaking the law, if then used on the public road, as the car would no longer comply with it’s type approval. The engine management system has been specified to include memory which Lotus intend to use for a future upgrade that will provide a data-logging facility for use on the track. At present this memory is used to gather data needed to onward develop the OBD system. There is also a ‘snap-shot’ logging facility which records the sensor outputs at the moment a fault is triggered to aid diagnosis by a dealer. There is no ‘black-box’ system for accident investigation but, the data captured can be used by Lotus to check on how the car has been used during it’s life. This information could be used to decide whether a warranty claim is justified or not. The data recorded includes the percentage of time spent at each of five throttle opening bands, five engine speed bands, five wheel speed bands and five manifold pressure bands. Further data on time spent at various coolant and oil temperature bands is also collected. Additionally it records data on the maximum engine speeds attained at certain coolant temperatures, the five highest vehicle speeds recorded total engine running time and the fastest and latest 0-100 kmh and 0-160 kmh times. The system also recognises and records the number of full load standing starts performed. The data is not linked to any real-time system and cannot therefore be used by other authorities as it is not possible to determine when or where any of the data was recorded. No customer details are recorded in accordance with the data protection act. It is not possible to clear the memory. The data can be accessed by the dealer using an interrogation tool, and copies are returned to Lotus. It was not intended that this data be shared with the customers, but there’s no reason why your dealer can’t let you have a look. All this has massive implications for the tuning companies and is one reason why Lotus are unable to announce precisely what engine upgrades will be offered in the near future. In the UK, Single Vehicle Approval (SVA) cars appear to be exempt at present. After market accessories have to be tested to see if they trigger the MIL and replacement of the K4 ECU is not legally allowed under the new legislation. This effectively means that third parties are very limited in what they can offer unless they work with Lotus to reprogram the ECU. CreditsThe majority of the information on this page is from Nick Adams, the lead designer on the Elise S2, and was originally posted on the Lotus Life BBS. OH BUGGER!One thing - surely it is illegal in itself for Lotus to be the only “approved” supplier of parts (the ECU) for a product (the car) it produces - this must contravine about 1000 free trade laws (also a load of Euro twaddle). Surely the truth is more like ; The replacement ECU and any other bits must be EURO3 compliant and the car must maintain a functioning MIL light and OBD system throughout its life.Which would explain Thielart’s “EURO3” compliant 180bhp tuning package…COMMENTS? - (other than just “bugger”, please!)

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I think that’s why lots of (if not all) remaining Exiges were registered by Lotus last year.

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quote:Originally posted by Julian Thompson:COMMENTS? - (other than just “bugger”, please!)Bloody glad I got my dream car, before this hits the streets [image]http://www.exiges.com/ubb/NonCGI/images/icons/grin.gif[/image]

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Bugger! [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image]I’ll be sticking to pre-1st Jan cars in that case which leave more options open in terms of tuning. The slight good news is that cars reg’d prior to that date should be more desirable. The annnoying thing is that, from the last figures I read, cars contribute a negligible amount of pollution in percentage terms. Politicians just love to tinker though to justify their jobs. [image]http://www.exiges.com/ubb/NonCGI/images/icons/mad.gif[/image]

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look lads dont get worried , i know a very friendly mot bloke on the isle of dogs … i was going to say as long as its got wheels on it but i dont think he even cares about that … [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image]

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Remember that Lotus got an extra special extension to sell the Exige until the end of 2001 - in actual fact these laws came into force as far as I am aware on Jan 1 2001, not Jan 1 2002, so all Mk2 Elises are implicated and everything else with a EURO3 system on board. Ie If you got an end of line Mk1 Elise with no OBD system mid 2001 then fine but if it had it from new beyond 31 Dec 2000 then the car must have a Euro3 compliant system for the rest of its life.I take this quite seriously for 2 reasons:1) You guys who are happy with your current cars will probably want to swap them for less worn out ones in a couple of years and so it will then implicate you too!2) I don’t want to wipe out a bus queue and then be told by Mr Insurance Inspector ™ that since my car has no OBD system and a pair of cams that look like the Himalaya’s my insurance is invalid. Not recommended at all.As one guy quite rightly said, Thilart do 180bhp Euro3 Elise in Germany @ about 7k (christ!) so it IS possible, just frappin’ big coin.

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hey Julian, you are right. this law came into force on 1.01. that is why all new Exiges here in Switzerland had to be imported and customs cleared until 12.00. do we just all luv the poxy EU for all these regulations…mind you, we are not in the EU (thank God for that) but unfortunately, in some ways, we just adopt some of these poxy laws and sometimes, we are even worse off…so, what are you going to do? have you made up your mind yet about an Exige? common, you know it makes sense…

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On the point “surely it is illegal in itself for Lotus to be the only “approved” supplier of parts…” unfortunately it isn’t today;Article 81… would make this illegal… http://europa.eu.int/comm/competition/legislation/treaties/ec/art81_en.html But the automotive industry still enjoys what has become known as “Block Exemption” http://europa.eu.int/eur-lex/en/lif/dat/1995/en_395R1475.html It essentially enables motor manufacturers to control supply and to control the activities of its dealers.Fortunately it expires 30 Sep 2002 and has just been reported on: http://www.europa.eu.int/comm/competition/car_sector/distribution/eval_reg_1475_95/studies/impact_legislative_scenarios/ The commission has said it is unlikely to renew the regulation in its current form.YoursEuropean Automotive Law Geek

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Aha, Matthew! I think you are just the person I’ve been looking for!Tell me, as far as you know, what is the position legally with modifying a new car; is it stated in any laws that you must have an O.B.D. (on board diagnostics) system even after you have taken delivery of the car, or is it stated only that the car must pass MOT to the NEW standards, ie we just struggle like we did last time they tightened the standards.The point is this : They made it illegal, plain and simple, not to have a CAT. Everyone understood this legislation becuase it was logical. As of June 1992 all new cars will have a CAT. No problemo, the tuning industry introduced freer meshed cats and we’re laughing.With Euro 3, they’ve introduced tighter emissions laws at MOT time. Fine. We all understand that too - back off the cams, tweak the map perhaps and bingo, MOT.But what the hell is the definative position on the rest of it; I mean if you take the view of throwing away the old ECU and get told either on a spot check or at MOT time that the car is illegal you risk a fine and also it will cost thousands to put the car back to standard to have the old ECU back.Also, bearing in mind your points about the motor industry being able to dictate what parts are used, surely that is just for warranty purposes? ie Whilst they can’t legally say that a car must be serviced by a franchised dealer they can say you must use genuine parts.Someone somewhere said (cleverly) - If a car must comply to its type approval throughout its life to be legal to use on the road then that means you can’t swap the steering wheel, beef up the exhaust or change the stereo (if it had one)???can’t be right?

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quote:Originally posted by Julian Thompson:Aha, Matthew! I think you are just the person I’ve been looking for!Do we need to buy new hats ? [image]http://www.exiges.com/ubb/NonCGI/images/icons/grin.gif[/image] [image]http://www.exiges.com/ubb/NonCGI/images/icons/grin.gif[/image] [image]http://www.exiges.com/ubb/NonCGI/images/icons/grin.gif[/image](Cilla Black quote)Just buy the bloody Exige & be done with it!!! [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image]

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here here pesky , i would suggest an exige isnt a car for somebody worried about the last details of mot regulations , the tyres are virtually illegal when theyre new … just buy it ( or dont ) and pay the fines …or buy an electric car and join the milk float forum [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image]

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This is scarey. I’m no longer going to do my early Sunday morning run on Slicks ever again.

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quote:Originally posted by trevor:This is scarey. I’m no longer going to do my early Sunday morning run on Slicks ever again.Surely not as scarey as driving on a wet & greasy highway with slicks [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image] [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image] [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image]CU on Friday [image]http://www.exiges.com/ubb/NonCGI/images/icons/grin.gif[/image][This message has been edited by Pesky (edited 06 January 2002).]

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I knew I shouldn’t have strayed outside of Exige Talk [image]http://www.exiges.com/ubb/NonCGI/images/icons/smile.gif[/image] There are quite a few different points so I’ve broken them out below.WHAT MAKES A CAR A CARFor a car to be a car in the UK it has to have whole type-approval from the Vehicle Certification Agency (http://www.vca.gov.uk) or it must pass a Single Vehicle Approval (SVA) test (either the standard or the enhanced flavour). The SVA and eSVA is administered by the Vehicle Inspectorate, the same nice people that manage the MOT.Type approval is for volume manufacturers; this is an onerous and expensive process. New and tightening regulation makes this a more expensive and complex process every year. Manufacturers work with the VCA (or similar EU bodies or consultancies) through the development and build process to mitigate the risk and cost of cars not getting type-approval. VCA works with major component builders to aid approval. Type-approval not only considers the parts but also the management processes etc of the manufacturer to ensure that all vehicles are built the same way and that records are available of which components ended up in which vehicles (i.e., for recalls where cars produced deviated from type-approval). The burden of all of this is one, understandable, reason that manufacturers want to keep block exemption (i.e., at least one regulation working in their favour).I�m not aware of the detailed list of things that are tested in type-approval but it will be the most thorough of all the testing approaches mainly because it applies to a significant volume of vehicles and that�s the easiest way to raised safety and emissions plus it is practical to test and implement more complex regulations this way. For example OBD the testing of which is non-trivial. I don�t know who many cars in the UK are under SVA but I would be surprised if it is more than 0.5%.SVA is for genuine home built cars, very low production vehicles, modifications from a type-approved vehicle or special vehicles. ESVA is for vehicles that don�t have type-approval but are out-of-scope for the SVA. ESVA applies some tests. I don�t have a definition for �Very low production volume�, I�d be interested to know how Lotus dealt with the Exige. There is/was a provision for processing �identical vehicles� through SVA which I assume was used especially considering the major components of the Exige were derived from a vehicle that already had type-approval. My Exige has an SVA certificate but I�m not sure on what basis it was issued.The upshot of all this is that your car is only a car if some-how it gets one of these approvals.WHEN DOES A CAR CEASE TO BE A CAR?If you change any bit that was tested when it was approved then your car will be defective against its approval. My assumption is that if you change a part for another part that meets the same regulations that fine � I only assume this as it wouldn�t be practical to retest cars every time a component was changed. I.e., a tyre.On that basis it is fine to change exhaust, steering wheel, stereo, tyres etc! but not to one that doesn�t meet regulations. For example a radio that didn�t meet radio interference regulations would invalidate the approval.CONTINUOUS COMPLIANCEIt is the owner�s responsibility to maintain the car to comply continuously with the relevant approval by doing things like replacing tyres and light bulbs as much as not removing components critical to emissions (like say for example removing the catalytic converter) or fitting big noisy exhausts instead.Such compliance is tested at the MOT and on roadside checks. A Vehicle Defect Notice as served by a police officer on the side of the road is effectively a defect against the approval. The MOT certificate and SVA are valid at point of issue only. They offer no ongoing certification. I.e., if your brake light fails its no defence to say I�ve got an MOT certificate. I�ll guarantee that your insurance company will also take a keener view on post-approval modification too.SO WHAT?That�s all useful background I hope but I�ll stop typing now and answer the question. Or at least own up to not having all the answers.If you modify a vehicle such that it would invalidate the approval then your vehicle won�t be road legal. If you want to make such mods to type-approved vehicles in the future there is going to be a need to pass the vehicle back through SVA. People like Turbo Technics must be doing this today.What I don�t know is how new regulations will shift the SVA test requirements. Things like OBD are very difficult to test ad-hoc but the SVA could simply require an ECU with type-approval to be fitted. Especially as block exemption goes and parts are more widely sourced.David � did you Exige have to have another SVA test after being upgraded?The SVA Test Manual will give the details of things that are checked and the things that aren�t.WARRANTIES AND PARTSThis is a related but separate matter. Manufacturers can, under block exemption, control the supply of approved parts. The cost of approval is one of their very understandable arguments for retaining block exemption.In the first year of warranty manufacturers can only insist on reasonable care and maintenance of the vehicle. If you start fitting non-standard parts or do anything that would invalidate the approval it would be easy for a manufacturer to demonstrate that you hadn�t taken reasonable care.Be aware though for extended warranties, these are just insurance policies, and the seller of the warranty, whether the manufacturer or otherwise, can quite legally and reasonable make servicing at an approved dealer and the fitting of certain makes of parts a term of the policy. This is a common practice. If you don�t like it by a more open policy elsewhere (and pay for it).Hope all that helps or was at least useful background.Does anyone have reference online or knowledge of?1. List of regulations and standards as applied to type-approval?2. How the Exige was processed?3. Current SVA test procedures for a modified type-approved car (like the Elise 2 for example)?[This message has been edited by Matthew Treagus (edited 06 January 2002).]

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That post looked smaller in Word! Must try and get out more.

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Me again on the same subject. The prevailing EC legislation can be found at http://europa.eu.int/eur-lex/en/lif/reg/en_register_133010.html Most of the bother is caused by this chap and the challenges in getting type approval. http://europa.eu.int/eur-lex/en/lif/dat/2001/en_301L0027.html Amusing to see that the spirit of the legislation would seem to be addressing the use of “defeat devices - a device which measures, senses or responds to operating variables (e.g. vehicle speed, engine speed, gear used, temperature, intake pressure or any other parameter) for the purpose of activating, modulating, delaying or deactivating the operation of any component or function of the emission control system such that the effectiveness of the emission control system is reduced under conditions encountered during normal vehicle use unless the use of such a device is substantially included in the applied emission certification test procedures.” and "irrational emission control strategy - any strategy or measure that, when the vehicle is operated under normal conditions of use, reduces the effectiveness of the emission control system to a level below that expected on the applicable emission test procedures."Presumably this would encompass things like adding a wheel speed sensor to open and shut valves at certain road speeds [image]http://www.exiges.com/ubb/NonCGI/images/icons/smile.gif[/image]I’m going out now to be with real people. [image]http://www.exiges.com/ubb/NonCGI/images/icons/wink.gif[/image]

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This was the 100th Lotus Talk topic.What a cracker!Ian [image]http://www.exiges.com/ubb/NonCGI/images/icons/smile.gif[/image]

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Matthew, thanks for the info:A couple of points, Firstly I have spoken to Turbo Technics today and they said that their Elise S2 Supercharger 190bhp conversion meets Euro3 standards (or at least it will in a week or two when some new additions are made to its Emerald ECU (!!!)Secondly, I also wondered if it was possible to put a modified car back through SVA, or more craftily, put the standard car back through SVA. That way, you obiviate the need for any OBD system since SVA doesn’t require it…Thoughts?

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Matthew, thanks for the info:A couple of points, Firstly I have spoken to Turbo Technics today and they said that their Elise S2 Supercharger 190bhp conversion meets Euro3 standards (or at least it will in a week or two when some new additions are made to its Emerald ECU (!!!)Secondly, I also wondered if it was possible to put a modified car back through SVA, or more craftily, put the standard car back through SVA. That way, you obiviate the need for any OBD system since SVA doesn’t require it…Thoughts?

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quote:Originally posted by Julian Thompson:Thoughts?Either hug a tree or buy an Exige, the choice is yours [image]http://www.exiges.com/ubb/NonCGI/images/icons/grin.gif[/image]