New RTA rules for vehicle modifications

[MR22ZZ]

could a board member put together a petition on behalf of the club by dyno day for people to sign in person (this has more standing than online petitions)? provided that is the clubs stance of course, can't see how it would not be though given the nature of the clubs activities and promotion.

[river]

Hi,

toymods forum has 14,000 members.... although only maybe 100-150 of them are toymods car club paying members...
would be nice if we could band together and do something positive for our hobby/way of life....

Actually it has 16,827 at the moment. Yes, only a little over 100 are Club members. Removing non-Aussie forum members, we'd still have over 15,000. A good number to send their disatisfaction to the RTA, and also to their local member. We are, after all, voters.

seeyuzz
river

[o_man_ra23]

Can we get GetUp on board? Usually they are a bunch of seal clubbing hippies who want a nanny state, but they may see the bright side when we point out the fact that illegal and dangerous modifications will increase regardless of fines.

[river]

Hi,

I just rang the RTA and they're emailing me the two Word documents. So, I'll have a squizz at them and see if I can get them put up on the forums and from there we can see what the next step is.

seeyuzz
river

[oldcorollas]

but they may see the bright side when we point out the fact that illegal and dangerous modifications will increase regardless of fines.

hmm, the "we'll keep doing illegal things no matter what" is never a good argument when it comes to laws and things...

like saying you'll keep drifting on the street until the goverment builds a track for you (to slide off into the dirt/fence/tyres)

[river]

Hi,

Okey-dokey, I got the 2 Word documents here.

Firstly, here is the part about significant/non-significant mods...

Modified Vehicles requiring a certificate
Modified vehicles will require a compliance certificate if they have been “significantly modified”. The draft Regulation defines a significant modification as one where the vehicle has been modified, or components have been added to or removed from the vehicle, in a manner that:
(a) alters the performance characteristics of the vehicle in a manner not intended by the vehicle’s manufacturer, or
(b) affects the vehicle’s occupant safety systems, or
(c) affects the safe handling of the vehicle, or
(d) is specified by the RTA on a list published in the Government Gazette.

Significant modifications do not include modifications that involve:
(a) the replacement of components with identical or equivalent components for the purposes of maintenance or repair, or
(b) the fitting of optional parts or components by the vehicle’s manufacturer or the manufacturer’s agent, or
(c) modifications specified by the RTA on a list published in the Government Gazette.

Rules affecting vehicle owners
Under the proposed Regulation, vehicle owners are required to obtain a compliance certificate for a significantly modified, individually constructed or personally imported vehicle before allowing it to be driven on a road or road-related area.
This rule is to ensure that these vehicles are assessed and certified to manage the potential safety risks to occupants of the vehicle and other road users.
The RTA recognises that a vehicle owner of an unregistered vehicle needs some way of getting the vehicle to the licensed certifier’s premises. The draft Regulation contains a provision that allows the vehicle to be driven for the purposes of obtaining certification. If the vehicle does not pass then it must be towed or floated back.
Vehicle owners are also required to submit a copy of their compliance certificate to the RTA within 28 days of obtaining it. Again, this only applies to registered vehicles. Certificates for unregistered vehicles would be provided to the RTA as a matter of course during the process of establishing registration.

So, you only need to be checked for significant modifications.

There is a lot of info about how the RTA will qualify/test/audit the license holder (ie the person who checks the vehicle for mods and issues the certifiacte and attachs the mod plate to the car).

There is no mention whatsoever about testing a modified car at a special non-public race-track or taking the vehicle to 160kph etc.

If you already have a modded and certified/engineered-approved vehicle, then read this...

Vehicle owners and old certificates
With the commencement of the VSCCS, it is intended that the only compliance certificates that will be accepted by the RTA in future are those issued from VSCCS Online. However, the RTA does not wish to disadvantage persons who may have obtained a certificate under the ECS in the past but forgotten to present it to the RTA and change their vehicle records.
The Regulation therefore provides such people with six months following its commencement in which to provide a copy of the certificate to the RTA. The way that this is done is by the registered operator of the vehicle obtaining a “Change of Vehicle Details” form and a blue slip from an Authorised Unregistered Vehicle Inspection Station, and presenting both documents, along with the compliance certificate, to the RTA at a Motor Registry.
From six months after the commencement of the Regulation, old ECS certificates will no longer be accepted by the RTA and vehicle owners will need to obtain a new compliance certificate under the VSCCS.

I hope this clears up a few things. I'll go through it in more detail and report back. I will also see if I can get one of the forum techheads to put these documents online so you can all have a read.

seeyuzz
river

[Shakotan_Aaron]

you have to be joking? fuck this state.

haha, suckers to you guys. i dont even need a mod plate for the 2j/manual swap just a look over on a hoist inspection and change of engine number

[o_man_ra23]

OlRollas, I am talking about using that argument to get GetUp on side. It worked with the mandatory internet filtering issue, where they realised that the kiddie porn peddelars would just get around the filter anyways and it would be a massive burden on the well meaning innocent bystanders.

The fact is that the masses will modify vehicles anyway. If it is a huge burden to get it legally engineered, then many will abandon their projects and waste huge money, others will pay the exhorbitant costs, some will move their cars onto a trailer and dedicate them to the track, but an alarmingly high number will simply drive without the engineering. Of the last group, there will be a small number in there which are modified in a way that is dangerous, and due to the excessively high number of people being caught for un-approved rear spoilers and the like, the dangerous vehicles chances of slipping through the cracks increase.

As a new example of the brake testing requirement issue. For my modifications, I will be greatly increasing the performance of my vehicle, however the donor car for my engine is effectively the same model as my car. In Australia our LT spec RA28s already had the GT spec brakes. The fact I am adding a turbo and making it rediculously faster is irrelevant with respect to the brakes, as I am not altering the mass of the vehicle by significant amounts, thus the vehicle will continue to comply with ADRs. So a person in my position who didn't understand the importance of a good braking package would legally be able to modify the car with no attention to the brakes, and not need to get the braking test, and would be more dangerous because the laws were pushing them to be more dangerous.

PS. this post is out of sync with the conversation as I was unable to complete it in one sitting.

[river]

Hi,

Here is the link to the new VSCCS requirements to become a licensed inspector.

http://www.rta.nsw.gov.au/registrati..._certifier.pdf

Interesting, as the VSCCS replaces the current ECS (Engineering Certificate Scheme), and here's a little part from the document....

The Vehicle Safety and Compliance Certification Scheme (VSCCS) licenses competent individuals to inspect non-standard vehicles and certify compliance with the relevant vehicle safety standards.

Non-standard vehicles that may require certification include modified vehicles, individually
constructed vehicles, and personally imported vehicles.

In 2011, the VSCCS will replace the Engineering Certification Scheme (ECS).

The scheme described in this guide may change as a result of the public consultation on the draft VSCCS regulation.

Working as a VSCCS licensed certifier

The work of a VSCCS licensed certifier includes
• inspecting and testing vehicles
• assessing the compliance of vehicles with the applicable standards
• deciding whether to certify a vehicle.

The VSCCS does not prescribe how certifiers go about these activities. It relies on the training, experience and professionalism of its certifiers to determine how best to do this. Similarly, the VSCCS does not specify which tests must be carried out or what equipment should be used: it is up to the certifier to decide how to assess a vehicle’s compliance with the applicable standards.

However, to ensure the integrity of the scheme, the VSCCS does expect a certifier to:
• abide by a code of conduct
• follow the scheme’s administrative procedures
• use the VSCCS IT system to issue certificates.
A certifier is also expected to maintain the currency of their knowledge and competence.

Code of conduct
As a VSCCS licensed certifier, you will be working as a business partner with the RTA; this means you’ll be held to the same standards of behaviour and conduct expected of an RTA employee.

The RTA code of conduct requires that, as a business partner, you:
• show respect for all persons associated with your duties
• perform duties with professionalism, objectivity, honesty, integrity and compassion
• be conscientious, fair and equitable in the performance of duties, and accountable for actions and decisions
• serve public above private interests
• avoid real or perceived conflicts of interest
• ensure the proper use of official information
• maintain proper standards of confidentiality
• report suspected breaches of the code and any actual or suspected corrupt behaviour.
Please refer to the RTA’s Code of conduct and ethics, available from the RTA website (hint:search for “code of conduct”).

I highlighted the interesting points. Basically, anyone can become an inspector. You need to read the document, but if you have relevant automotive experience and meet their 100-points required, then you can become an inspector. Please read the doco for more info.

Second point I highlighted is the licenser makes the decision on what equipment and testing needs to be done to validate any mods. So, if someone says you need to go to a race track and pay through the arse, then tell them to fuck off and find another one.

Also there is no guideline for how much an inspector can charge a person for inspection. That is up to the individuals involved. The RTA charges $500 per annum for the inspector to have a license to check cars.

Basically, not much has really changed, and, if anything, it gives more people the ability to become inspectors. Also inspectors can specialise in certain areas.. such as brakes, engine, suspension, etc.

seeyuzz
river

[JustenGT8]

Nice sleuthing River +rep

I wonder what happens for interstate vehicles seeing states were supposed to be moving to National guidelines for modded vehicles?

[CrUZida]

Modified Vehicles requiring a certificate
Modified vehicles will require a compliance certificate if they have been “significantly modified”. The draft Regulation defines a significant modification as one where the vehicle has been modified, or components have been added to or removed from the vehicle, in a manner that:
(a) alters the performance characteristics of the vehicle in a manner not intended by the vehicle’s manufacturer,

And there in lies the RTA's ability to ream you for even the slightest performance related modification.

[oldcorollas]

yeah, that's a worry... hopefulyl focused on new cars, which actually have some handlign and performance?

in the introduction of the NCOP, they seem to be saying that if a car is modded according to NCOP, then it should be acceptable to any state... as opposed to the NCOP being adopted by all states..
ie, lowest common denominator.. or in this case, strictest?

there was some line somewhere, about things outside the "guideline" also being acceptable, sunject to technical justification,.. which again sounds liek it has always been anyway

[petergoudie]

Be careful with how you interpret some of the bits of information above. There are several things happening at once. Looking at a piece of the jigsaw puzzle will not necessarily let you see the picture. Some of the VSCCS documents describe the administrative bits to be in the scheme but not how to demonstrate compliance with the standards. What is being said in those paragraphs where they are not going tell the certifier about how to go about their business means that they won't say how to prove a vehicle meets the ADRs just that you have to show it does. As such, how are you going to show a car can brake 15 times in 45 second intervals from 100km/h without actually doing the test?

Another person received a reply from the RTA to some questions and the following is an excerpt of one of the answers:

"6. Vehicle Standards in the new Vehicle Certification Scheme-

The standards that apply to motor vehicles are set in the ADRs (for new vehicles) and the Australian Vehicle Standards Rules for vehicles in service. In addition there are specific requirements the RTA has established for certain vehicle types, such as modified vehicles and street rods etc. The new scheme for engineering certification does not involve changing any of the relevant standards, just the manner by which they are applied and enforced."

Don’t forget the comment period for the draft regulation closes on 27th this month.

[dave368]

Guys,

After having a quick read of the proposed document and after many years (over 17 years now) working a the bureaucracy of government and semi-government organisations, my concern is actually about the decision making process behind the ability to change regulations or standards that apply.

In my experience, what happens is a set of rules is set up and quite strictly enforced initially. At the moment this includes public and industry consultation and we get the opportunity to have input...this is a very good thing :-)

But with the wording of the following para is of concern:
[COLOR="Blue"](1) For the purposes of this Part, a vehicle has been significantly modified if the vehicle has been modified, or components have been added to or removed from the vehicle, in a manner that:
(a) alters the performance characteristics of the vehicle such that those performance characteristics are not as intended by the vehicle’s manufacturer, or
(b) affects the vehicle’s occupant safety systems, or
(c) affects the safe handling of the vehicle, or
(d) is specified by the Authority, by order published in the Gazette, as a modification or class of modifications for the purposes of this paragraph.[/COLOR]

Specifically the last sentence. This allows an internal, not visibile to the public process to occur to change bits of the rules pretty much whenever they want based on pressure internally or from the government of the day.

Again, this is OK whilst a strong governance process is in place and there is transparency in that process. You could possibly live with that but probably wouldn't be too happy.

However, what happens in the real world is that the strong governance is enforce for a while maybe a year or two possibly more, then there is a change in staff/change in attitude/new government etc etc etc and they weaken the governance process without consultation to the industry and start making whatever changes they like to make it harder to get things past.

Then the engineer has to keep up with every single gazette to make sure that he/she is applying the correct rules at the time which could be interesting for a longer build process. This takes time and effort that someone (us) has to pay for, driving the prices of these services up.

Most engineers and mechanics I know aren't huge fans of lots and lots of reading to keep up to date like this, so that drives them away from wanting to do the work. Smaller market = driving the prices up, yet again.

Take someone that is a young student interested in mechanics/modifications. They are sensible persion, have an uncle/father/other relative/friend that is a responsible person and likes to mod their cars. The also have no money. The responsible person would advise them to make the mods properly, help them do it and recommend to get them engineered.

They find out that only 4 businesses in the greater Sydney area are now doing the engineering and the cheapest price is now $4000 and goes up to $9000 because they are too busy now. The car and mods cost them the same price as the engineering ticket. What do they do?

What reasonable person would understand (not necessarily condone) why they didn't end up getting the engineering ticket. Others would argue that they should have investigated it properly to ensure that they could afford it before they started - yeah someone thinking everything through before they do it...mmmmm it could happen I guess :-)

Anyway, this has become a bit of a ramble. The simple message is, make sure that we protect the visibility and independance of the decision making process. Use an independant industry reference group to validate all decisions before they become final and get gazetted. Make sure that there is an escalation and appeals process in place so that unfair or unreasonable decisions can be appealed. Ensure that emperical evidence of benefit must be provided i.e. the government can't arbitrarily say that they no longer want pearl based paints on cars because of the potential "hoon" factor - make them back it up with real evidence to demostrate why they must do it.

Or there may be other ways of doing the same thing, but the important thing is to make sure that arbitrary decisions cannot be made by the government machine.

Cheers,
Dave

[BlackSupra]

Dear Petergoudie,

According to your profile, it would appear you are a NSW automotive engineer with a vested interest in the outcome of this proposal. Your hidden agenda to rally support from car forums is nothing more than scaremongering and is merely using the wider community to ensure job protection.

The ADR's haven't changed, it's just the method of testing and it is this part you are worried about without directly declaring your position.

Love The Dong.