Death of special building in NZ

[jansens]

OK, this might turn into a long rant...

Most people will know I have been building my Austin 7 Special for the last 10 years. In that time I have been lucky to meet so many people who have taught me how to do things or helped me with information, advice and even parts so I could build a close to a period correct special as I could get. I am very thankful to all of them, some of whom aren't with us anymore. It's finally come time to try to get the car road registered so I can drive the thing. It's not 100% finished (are specials ever?) but it's ready to be driven.

Only it seems the entire system is set up to prevent that these days and I am almost at the point of saying why bother? Certainly I am thinking after I finish my Riley Brooklands replica, which it's looking like I can never register if built to be period correct (it will probably be an unregistered race car or sold overseas), what's the point in continuing to learn these skills if you can never use them. 

The main issue with my special is it has no paperwork. When I first started 10 years ago that wasn't so much of a problem. But in that time the rules have changed, several times it seems, and it's at the point now where it seems no one really knows what the rules are where vintage cars are concerned and no one can offer decent advice. Everything pushes you into the LVVTA certification route. In NZ that is a small group of people who inspect non standard cars and basically say if the car can be registered or not. Mainly things like hot rods, race cars and boy racer type mods. I was trying to avoid that path if possible. 

I had gone through the Vintage Car Club here as I am a member and they did come inspect the car and I got the right paperwork to say the car was period correct. This is the 'VCC Date of Manufacture & Authenticity Statement'. They call this the DOMAS. I also got the right documents to say the car has no paperwork and had those witnessed by a JP as you have to do.  

That should help me get the car on the road as per these statements:

5.6 The VCC Date of Manufacture & Authenticity Statement may be used by a Transport Service Delivery Agent (WOF Agent) and a Certifier on behalf of the NZ Transport Agency (formerly Land Transport NZ and previously LTSA), to classify a vehicle’s date of manufacture and authenticity. 
5.7 The VCC Date of Manufacture & Authenticity Statement has provision on the form to advise a Certifier if the vehicle is modified in any area that may affect a vehicle Safety Standard and suggests the vehicle be certified using the Low Volume Vehicle Code. 

When I went to talk to the testing station they don't known anything about that at all and said I need to fill in another form, a CA03, which is one that says there is no paper trail for the vehicle. There is no mention of this form anywhere else on the NZTA web site as far as I can find apart from the form itself. The form does say it costs $184NZ an hour to process your application and they don't say how long it takes. I guess if they say no then you're basically screwed, that car can never be on the road. 

Before filling that in I asked for advice from someone in the club who is very knowledgeable about how all of this works. I was hoping he could advice on how to fill in the CA03 application. He reviewed my forms for me and pointed out an error on my DOMAS form so now apparently the forms will be re-issued and these will now say I do have to now go though LVVTA. He said the car might now need seatbelts? The NZTA website says:

Exceptions for older vehicles
If your vehicle was manufactured before 1990 it may be excluded from many of the standards requirements. However, your vehicle must still meet the general safety requirements in the Land Transport Rules, and it must have at least front seat passenger safety belts if manufactured after 1955.

A historic vehicle must meet the safety requirements applying at the time it was manufactured. Contact the Vintage Car Club of New Zealand(external link) to find out more.

So now as far as I can tell it comes down to the individual LVVTA certifier as to how they decide to interpret that rule. And the problem is they then start looking at ALL the LVVTA rules as set out in the handbook. This is the New Zealand Car Constructors manual (https://www.lvvta.org.nz/shop/new-zealan...l-version/). The handbook is very good if you are building a hot rod or a modern race car or modding a vehicle. If it's vintage, you're probably screwed. It has all sorts of things in it vintage cars have trouble meeting such as: 



So now I need to either make a steel floor or weld supports to the chassis rails. That opens another can of worms. Then if they start looking at fasteners you're really screwed, pardon the pun. Depending on how the individual certifier looks at the rules you might now need to use all metric or modern UNC/UNF fasteners in the thing. Oh, and I still don't know how to fill in the CA03.

So how do you find a certifier who understands vintage cars, understands the DOMAS and what paper work is needed and can access the car realistically based on what it is? No idea and I am not even sure it's possible. There is a list of them on the LVVTA website. There are about 40 in NZ. They are responsible for all low volume certifications in NZ including any modified vehicles so they are kind of busy. The only way to find someone is to individually ring them and chat to them. I tried a few months ago, the nearest one started ranting to me about how the vintage car people had made the process so much more difficult for the hot rodders! So he's probably not sympathetic. You do hear stories about 'so and so' out the back of somewhere who is good but by the time you hear that the information is years out of date. Are there even any who know about vintage cars now? 

When even the experts can't really offer concrete advice what do you do? I guess I just now have to wait for the new documents and start ringing around again. Of course all of this costs time and a not inconsiderable amount of money. Fees to the certifiers, fees to LTNZ, the cost of transporting cars to places to be inspected (and back and forth if they find things you have to fix). And once you go to one the car is 'in the system' so if they say no, again you're screwed.

My advice for someone wanting to build a vintage car in NZ now would be don't bother. Or at least start with a registered, road legal car and modify it. That way you can bypass all these rules and no one really cares. Of course that's what all us old car people hate, destroying a perfectly good car to make a special, but it seems now, in NZ at least, that's the best way to do it. If you try to do it from scratch following the rule book you can't end up with a period correct special.

It's just really frustrating when you try to build something well and do everything right and the system just makes it impossible. And they are making it harder all the time. After the Riley I don't think I'll bother with coach building vintage cars anymore. I'll stick to restoring things (so much easier anyway) or maybe build something modern. At least the Riley has some value in it. An Austin 7, not so much. Maybe I can find a standard car that needs restoring and put the good restored running gear I have in that and scrap (or sell) the special body. Or just hang it on the wall of my shed. That might actually be cheaper than trying to get the special on the road. As I said in the subject maybe the time of special building is now nearly at an end?

If anyone in NZ knows of a good certifier in the Wellington region let me know. Actually if someone knows a good one who knows vintage cars anywhere in NZ let me know. It might be worth transporting the car to them.

Rant over.

Simon

[Bob Culver]

Does acquiring the registration of a vehicle on hold assist? There would then be some evidence of a past, although still have to have the mods approved. Sadly many cars have been scrapped to provide an identity for others. Tricky once in the system
What happens if the registration for a special lapses? it is hard enough for a regular car.

[circeonya@hotmail.com]

In Victoria Australia, the rules changed a couple of years ago where a vehicle has to have an Engineers Certificate if modifications such as hydraulic brakes on a Seven have been carried out and the vehicle is to be registered, a change of ownership or Club Permitted.. Therin lies a problem as the Engineer has to put his reputation on the line and become liable if any event in the future relates to an accident where the modification is involved. Plus his costs of personal liability insurance, so it can all easily get out of hand. It seems NZ has really gone over the top with their rules, I hope our mob does'nt want to copy them. BTW we have a culture with Insurance Companies here that when a claim is made they go through all the loopholes they can exploit right at the start.

[39Jet]

Big sympathy Simon.
I haven't done what you are attempting to do, but a couple of things occur to me. The designation "special" implies that the vehicle has been modified from the form that it left Longbridge in. If your chassis was originally under a sports model (and who's to say that it wasn't) then you have only recreated the original bodywork - there has been no modification and so no certification is needed.
One of our children bought a car which, it turned out, had lapsed registration. (In NZ, if the registration fee isn't paid for two years, and the registration hasn't been put on hold, the car's registration is dropped from the system and the last registered owner gets a bill for two year's registration). We went through the process of re-registering it which was reasonably straightforward, though quite expensive. I forget what happened about the previous owner signing the paperwork. Perhaps he was overseas, or had changed his name, but it didn't seem to be a huge obstacle, we could have made a statutory declaration if we hadn't managed to get his signature.
So my suggestion is that you present the car as an un-modified original sports with re-built bodywork to one of the designated testing stations. They will tell you what you need in the way of documentation.

Completely off topic, but I re-registered an old trailer which I had bought years before from a neighbour who wasn't, it turned out, the registered owner. The trailer was registered to another, long gone, neighbour. The authorities weren't worried and gave me new plates for my "rebuilt" trailer for a modest fee. I didn't need any paperwork at all, except identification, and no-one at all saw the trailer.
It is no wonder so many trailers are stolen.

[Howard Wright]

Hi Simon

You have my sympathy too.  I’ve followed your build since the early days and was so looking forward to seeing the car on the road.

Here in the UK we have similar rules and regs, and both the specials I have built were registered using a similar route to that described by 39jet.

I do hope you are successful soon.

Cheers

Howard

PS In answer to your question “are specials ever finished”…IMHO….No!

[jansens]

I don't know what happens to a special if the rego lapses? That's a good question. I do know if you have a car in the system as a special then you can do anything. Who would know if you totally rebuilt the body? Or redid the chassis. Or did anything really. Once it's in there it's there. In fact I know someone doing just that, they have a special with the rego on hold so they are rebuilding it but when the time comes they just need a WOF and it's legal again. The WOF people have no clue what's changed so they are fine. I don't think special has any particular meaning. I suspect people just put that when it's a non production body.

I think if it was a standard car registration on hold then you try to re-register it with a new body you'd then have to get the new body certified and that puts you in exactly the situation I am in now. It's not a production body so they treat it as a new build. I think even the most clueless WOF inspector can see it's not a factory body so they'll just fall back on saying it needs low volume certing.

I thought the paperwork from the VCC would help but as far as I can tell there is no legal weight behind that? The inspection people have no clue about the VCC documents. When I talked to them they said I needed the CA03 document to say there were no papers. I think the VCC documents are meant to be used to help get the CA03 form application though. When I asked the VCC about that they looked at my existing documents and decided to change them. So now I guess one of the little boxes saying needs low volume certification or modifications that affect a safety standard is ticked.

So now to get the CA03 which the inspection place needs I have to apply to NZTA with the updated VCC documents which will say I need a low volume certifier. And if the low volume certifier decides they don't like something on the car I have to fix it or you go no where. And it's up to them to interpret the rules how they like.

I thought being a VCC member and trying to do things properly would help but apparently not. My understanding of this might all be wrong but that's the f-ing problem (sorry for the language but it's VERY frustrating). No one can clearly or logically explain the rules! No one knows them or they aren't defined or it's left up to individuals to decide and since they end up being liable they decide no unless you do everything they think they need to to cover their arses.

Like I say maybe if I find the right certifier it will work out OK. But you have no way of knowing till you try and really you only get one go.

Simon

[Stuart Giles]

Sounds like you have a Kafkaesque nightmare going on there. What happens when you import a car which has paperwork declaring it to be "historic"? would the registration authorities rubber stamp your application or would you have to go through the same rigamarole you're going through with the NZ authorities? I'm thinking you could 'sell' the car to somewhere that has a more accommodating registration system and then import it back.

Something like this used to happen in the UK with kit cars that had inconvenient registrations; they got 'sold' to a Northern Ireland address, registered there. Subsequently exported to the mainland. Getting a shiny new registration when they arrived.

[jansens]

Hi Stuart, that has actually been suggested to me before regarding the Riley! I think 'historic' cars are another thing altogether They call them SIVs. These are the rules below. I am guessing Austin 7s specials don't apply! The devil is always in the details here. That last line "prove that the vehicle otherwise complies with the Land Transport Rules" would worry me. 

The whole vehicle licensing agency, Waka Kotahi - NZTA, are in a bit of a state by the sounds of it and they have been in the news a lot the last few years mainly around truck certifications. I think they got done by the government for being too lax on things in and recent years have swung too far back the other way.

Requirements that the vehicle must meet
To have a vehicle identified as a special interest vehicle, the Transport Agency must deem it to have historic value or it must meet three of the following four requirements:

• The vehicle (or its make, model and submodel) is identified as being a collector's item in one of the following magazines or their respective websites – Australian Classic Car, Car and Driver (US), Automobile (US), Motor (Australia), Motor Trend (US), New Zealand Autocar, New Zealand Classic Car, Road and Track (US), Top Gear (UK), Top Gear NZ, Unique Cars (Australia) or Wheels (Australia).
  
  
• Less than 20,000 units of the vehicle’s make and model have been (or were) manufactured annually.
  
  
• The vehicle is, and was manufactured as, a two-door coupe or a convertible.
  
  
• The vehicle is, and was manufactured as, a high-performance vehicle.
  Additional requirements attached to special interest vehiclesIn addition to the declaration on the application, you must:
  • have another vehicle (eg car, ute, minivan) for your everyday use
    
    
  • not have any other special interest vehicle registered in your name
    
    
  • prove that the vehicle otherwise complies with the Land Transport Rules.
    

[Ian Williams]

Simon, you can be too honest as I tried to tell you! Your rolling chassis is as you found it other than you have completely restored it, but everything is still standard Austin specification. When you purchased the car the body work was totally beyond salvage so you have built a period correct body for it ( abet 1950's style construction, but that not an issue ) that falls nicely into the VCC dating criteria. There were two recent cases of A7 builds here where one guy built a special carried out and proudly told the inspectors about every modification he could think of, and as a result he went through the mill trying to get it registered. Another where the owner was more restrained, carried out only pre war style mods, with his own take on bodywork and it flew through. There is a crowd in Auckland who a sympathetic to our cause, I thought I had given you a card, certainly some of the other guys in the Auckland body building group have them, afraid my records are still with the rest of my stuff in Auckland. I hear that because of the drive towards an electric revolution authorities are trying the make it harder and harder for fossil fuel cars to be on the road but I feel sure that if you speak to the RIGHT people you will get there.
On that note to meet current demand and fuel our power stations we are now (2021) as a country importing more then double the coal (which is the dirtiest fossil fuel) into out country than we did in 2017 and 2018 combined and struggling with our aged infrastructure to distribute that power. That will change of course once we dam a few more rivers for hydro, build further geothermal power stations, wind farms and totally overhaul the national grid. But we do have a couple of years to do that and you know how quickly we undertake major infrastructure projects in NZ..... just look at transmission gully!

[jansens]

Hi Ian, I thought the guy in AK wasn't doing it now? I thought he was one of the causalities of the massive tightening up by LTNZ a few years ago after the damning report came out on them. The problem isn't around be honest with what I have done in terms of modifications. It hasn't even got to the point yet where anyone has asked me what I have done apart from knowing it's a new body. It's around the paperwork and if you are even allowed to get it into the system.

I am still trying to understand the rules because as far as I can tell they aren't clearly set out anywhere and everyone you ask has a different opinion on what they are. To get a car with no papers back on the road you need to have a VIN number. To get that you have to apply to LTNZ via the CA03 form. That is where you need to prove you own the car and what it is (and pay then $184 an hour to look into it for you). This is where the VCC documents are meant to help I think.

A testing station won't even look at the car until that has been approved and has a VIN. With a VIN then you can then take the car to get the compliance done. Because my forms say there are modifications that affect a safety standard it has to go to the LVVTA. It's all very well to say talk to the RIGHT people. That was from talking to the VCC who issue the forms. How they determine how to fill in the forms is a mystery apparently. I guess it comes down to the definition, group and category they put the car in. Those are well defined. How they decide if the mods affect the safety standards I don't know, they don't explain that. The document is here: http://vcc.org.nz/wp-content/uploads/202..._11_20.pdf

My car is classified as a B5 PSG1.

Once the forms arrive from the VCC I can see if it does need LVVTA in which case I will ring their technical people to talk to them. Again it comes down to finding the right person but how do you do that? It's one reason I am posting here. Can someone direct me to a certifier who knows pre-war cars?

What paper work did the guys in Auckland with the A7 specials have already? Were they unregistered cars to start with? Do they have VICs and what categories are they under?

Simon