[boxhead]

Letter sent.

Hon. Anthony Albanese MP
Minister for Infrastructure,
Transport, Regional Development
and Local Government
PO Box 6022
Parliament House
Canberra ACT 2600


Dear Mr Albanese,


I am writing to express my concern with the introduction of the new ADR 31/02 that requires mandatory Electronic Stability Control to be fitted to all new vehicles from November 2011, and how it will affect the ICV and low volume car industry. I am also writing to request that provision be made to allow exclusion to this new requirement for individually constructed vehicles (ICV) in all states of Australia.

The kit car, hot rod and ICV industry provides hundreds of jobs within Australia for manufacturers, mechanics, suppliers, and associated automotive trades. The introduction of the new ADR requirement of Electronic Stability Control to be fitted to all new vehicles puts the future of this industry in serious jeopardy.

I myself am an enthusiast part way through the build of an ICV, due to me living in Alice Springs I need to comply with regulations set out by the Northern Territory regulators, in the case of the NT (and from my understanding all states and territories excluding NSW), I have had to apply to build the vehicle and seek an "Approval in Principal"
So I there fore have a pre set ADR list that I must comply with. But in the case of NSW, the vehicle must comply with whatever regulations are in place on the day the vehicle is presented for inspection. So it is highly possable that a builder could start a build today, and not be completed for 5 years (I have read somewhere that this is the average build time), then present the vehicle only to be denied due to not meeting current regulations.
And in the case of ADR 31/02 this will make building an ICV totally unaffordable to the vast majority of Australian's.
One kit car manufacturer has received an estimate from Bosch Aust for $1.3M to design a system for one vehicle. As no two ICV’s are the same, there is no one size fits all system that can be adopted. Hence a system would need to be specifically designed for every individual car at the cost of $1.3M (currently ICV’s are built for $30k-$100k).

Whilst I understand that you have a responsibility to improve road safety, I hope that you will consider the impact that this ADR has on the ICV industry as a whole. I am requesting that you make a provision for individually constructed vehicles to be excluded from the requirement of ADR 31/02 as is the case for other selected ADR’s (such as those listed on Vehicle Standards Admin circular 0-2-13).

Thank you for considering this concerning issue, and although this regulation will not affect me in my situation, I can see atleast 2 down sides to this issue.
First one being a large industry (parts suppliers, kit suppliers, workshops etc) all loosing the oportunity to remain employed in there chosen field.
Second issue being it would mean the end of a dream for alot of Australian's who have allways wanted one of the vehicles they are wanting to build

Regards,

David Rawnsley