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Learning how to build Lotus Seven replicas...together!
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PostPosted: May 3, 2017, 1:45 am 
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Joined: December 18, 2013, 8:02 am
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Location: Southeast CT
This is an interesting thread. I am about a year away from the inspection process and haven't considered frame requirements. First question is: hasn't someone done this in CT before? Build a frame from scratch, that is. What did they have to do? When I had my Factory Five inspected, they required a manufacturer's certificate of origin for the frame. This issue may be an offshoot of that requirement in that they want something analogous to an MCO.

That said, I happen to be a licensed PE (mechanical/structural). I'm curious whether that will carry any weight during my inspection.


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PostPosted: May 3, 2017, 9:10 pm 
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Joined: November 13, 2009, 9:31 pm
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Location: Connecticut
With all the "recent" updates to the CT DMV site about composite vehicles I thought they had gotten it straightened out. Sorry to hear that isn't the case.
I'll be keeping an eye on this thread to see where it goes for certain before I start building.

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PostPosted: May 5, 2017, 5:49 pm 
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Location: Connecticut
Another option is to contact the Attorney General's office. Their job is to make sure that the law as written is upheld. Since the only written statute appears to be:

FRAME - Shall be capable of supporting vehicle weight without excessive flexing. Fish plates or
other suitable reinforcement at points of stress. All welding shall be of industry standard quality and
type. Cut and rewelded frames between the front and rear suspensions shall be cut at a 45 degree
angle where possible and must have a continuous reinforcement overlapping approximately one
foot.


Then there really isn't much they can ask for other than proof that it will support the weight without flexing and the AG should enforce that. To prove the strength of the chassis, the previously mentioned 'Aussie mods' would be good to add (both for this issue and for a better chassis anyway). And you could make a build book showing yours and others completed chassis and show that the others are complete and registered (in other states) and therefore must be roadworthy. In the end if they prevail with their requirement of a PE, you will have something to show the PE why he should accept your chassis design/build.

Good luck!

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PostPosted: May 5, 2017, 8:48 pm 
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Those requirements are easy to certify. Engineer should prepare a one paragraph statement addressing the frame requirements including the following:

.."without excessive flexing." Support frame on 4 jack stands. Place two large people (or equivalent weight) in car and observe deflection. Report that "no excessive flexing was observed."

..."suitable reinforcement at points of stress." State that "frame is triangulated."

... "welding...industry standard." "Frame was visually inspected and fabricator was interviewed. Frame was (MIG, TIG, whatever) welded to normal standards."

... "cut and rewelded." "Does not apply. Frame newly fabricated."

Sounds like wording was developed for hotrods and dune buggies. The absence of any code reference or quantitative measures allows judgement to be used to certify that these vague requirements are satisfied.


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PostPosted: May 10, 2017, 3:04 pm 
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Joined: June 10, 2010, 11:35 pm
Posts: 26
Location: Ridgefield, CT
I contacted the DMV for further clarification and they sent my request to the same Sgt. who was there for inspection and he stated the following:

Quote:
The Principal Automotive Engineer must say in his certification letter that the homemade vehicle frame that you have constructed is in full compliance with all of the following federal and state regulations:

*Code of Federal Regulations 49, Subtitle B, Parts 500 through 599 inclusive

*Connecticut General Statutes 14-271a-1 through 14-271a-2 inclusive
http://www.sots.ct.gov/sots/lib/sots/re ... 4/271a.pdf


The Principal Automotive Engineer’s original letter must be on firm or company letterhead. If you have any further questions please feel free to contact me.

The Composite Vehicle requirements that you’re referencing is a guideline only. Given the abundance of laws and regulations associated with motor vehicles it is impossible to put that much information in one document as it would further confuse the public.


They are now saying Principal Automotive Engineer, seems they do not know the difference. As far as I know, there aren't really any Professional Engineer Automotive Engineers, which would basically make it illegal for someone to furnish any statement as an "Automotive Engineer". Additionally, they are trying to hold me to FMVSS regulations as cited above which only apply to motor vehicle manufacturers. When I told them that FMVSS does not apply to the frame, the Sgt's supervisor said I was "entitled to disagree" but they would absolutely not pass it until I meet their requirement.

He also stated the following, "CGS 14-103a gives us the authority to inspect motor vehicles to ensure they are safe for the road. We do not have an engineer on staff and could not possibly make a determination of whether or not a frame made by a citizen would qualify as “safe.” Signing off an any inspection without being satisfied that the components are safe would not only be irresponsible of the agency, but could deflect liability back to us (DMV), something we will not entertain. That being said, we will have no further discussion about this “frame issue” as we have made clear what we are looking for in order to pass your vehicle."

CGS 14-103a actually doesn't use the verbiage safe but specifically states, "shall be inspected by the commissioner to determine whether the vehicle is properly equipped, in good mechanical condition and in the possession of its lawful owner." I'm pretty sure "engineering certification" falls nowhere in there, and as they stated they have no engineer who could make such a determination. Why am I required to take it elsewhere for inspection by a third party before the inspection at the DMV?

So I am now going down the road of pursuing legal action with a lawyer. This seems to me to be pretty straightforward of a case but we'll see what the lawyer thinks.

Another interesting thing, the statutes actually state that a composite inspection can be performed at any DMV, but the DMV says it can be only performed at the Wethersfield DMV...

I'm hoping this will get sorted out for myself and any future individuals who get to go through this joyous process in CT :roll: :BH:


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PostPosted: May 10, 2017, 4:03 pm 
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I'm not sure lawyer will be able to help. I'm afraid you need something more like a lobbying organization like SEMA.

I think where you will get to is that it turns out someone at the higher up in your states Motor Vehicle department is authorized to make these type of decisions. There will be something that says "the director of the motor vehicle department, at the time and place of his choosing, may supplement these regulations by issuing a letter". that's not true legalize, but I know Massachusetts has such a statement somewhere.

I was going to mention we have FEA models for some cars here on our website, but I think you are past being able to use such a thing. I did work with a forum member to generate an engineering report, but that was for an organization that was friendly not hostile as they people appear to be.

"Principal Automotive Engineer" would be a job title you get while working for a manufacturer. I don't know of a standard for such a thing, it's odd they used those terms. A Principal is a step up from Senior. In the old days it would have been a very serious position equivalent to a Vice President, but nowadays even some one like me can get that. If you were a principal they used to list your salary in the annual report to the stockholders...

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PostPosted: May 10, 2017, 4:21 pm 
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kjcorley wrote:
I contacted the DMV for further clarification.... That being said, we will have no further discussion about this “frame issue” as we have made clear what we are looking for in order to pass your vehicle."... :roll: :BH:


When someone working for the state says something about having "no further discussion" it sounds like the problem is a personal problem. His job is to serve the public, unless you were being inappropriate somehow, he owes you as thorough an explanation as you want. Not whatever he feels like giving that day... A lawyer making some threat$ seems like it might help some in this case.

Good luck


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PostPosted: May 10, 2017, 5:27 pm 
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As my teenage daughter would say, "that's very suckish". I feel for you, having to deal with this. However, I agree with Marcus that a lawyer may be of little help. If you are already dealing with such an attitude, I think that positions will harden, and you'll spend a lot of money and time.
If it was my problem, I would think of alternate ways to deal with this. I don't know your laws, but I would investigate different possibilities. Here are just a couple of ideas:
Can you sell the project to a friend, and have him have it inspected at a different locale from yours?
Can you sell your project to friend in a different state, inspect it there and then bring it back to your home state?
Can you have someone send a letter to the DMV, stating that they would like to start a build, and what would be the inspection requirements?
I'm sure others will chime in with more ideas; this is a pretty resourceful crowd.
Good luck.

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PostPosted: May 10, 2017, 7:26 pm 
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Joined: December 18, 2013, 8:02 am
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Location: Southeast CT
Just one more of many reasons more people are leaving Connecticut than coming in. The bureaucrats believe they are the ones to be served. I am about four years into my build and now I'm wondering what my chances are of getting through inspection. I can produce a letter stating the frame meets XYZ, and stamp as a PE, but if I get the same Nazi inspector, that may not work.

As for the earlier suggestions, there is only the one inspection station in Wethersfield, so no chance to go elsewhere. Selling to a friend in another state who can get it through inspection, then sell it back might be the best idea. However, I don't know what you might encounter in the neighboring states - NY, RI, MA are not exactly taxpayer friendly either. If you could do that, the only thing you would need to do in CT to register would be a VIN verification.

Good luck - I'm watching this issue closely.


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PostPosted: May 10, 2017, 7:32 pm 
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......That being said, we will have no further discussion about this “frame issue” as we have made clear what we are looking for in order to pass your vehicle."


What a total a$$hole.

I would tell him that you are unfamiliar with the state qualifications or definition of "Principal Automotive Engineers" and cannot find any reference to them in your state laws, then ask him for clarification so you don't waste any more of his valuable time. And cordially ask him for a list of "Principal Automotive Engineers" in your area that would satisfy the state requirements lest you waste more of his time. I bet there he can't and there isn't any.

After getting no response in a reasonable time period, ask your State Representative for his help in navigating the red tape. He might just put some effort into satisfying a voting constituent.

The truth be told, you would be better off chumming up to the inspector however insincere you might be, rather then confronting him. You need him eventually to approve your vehicle. And from what I read, even bringing in a registered vehicle from out of state has to go thru the same guy. I feel your pain. :ack:

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PostPosted: May 18, 2017, 8:39 pm 
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Joined: March 10, 2006, 12:48 am
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Location: CT
As a fellow CT resident, I'm watching this closely. You've got me anxious and looking at maybe just turning mine into strictly a track/autox build :ack: I'm really hoping not to have to trailer it everywhere.

Was there any rationale provided for why home built hot rods are necessarily less scary?
-Andy


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PostPosted: May 18, 2017, 9:34 pm 
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I think making friends with him is definitely the way to get what you want. I once had a Quarter Master when I was serving in Germany who believed stores were for storing and would find any excuse not to give you stuff.
However he once came out running with me when I was on the boxing team. From then on every time I went to the Quarter Master I started with hey hows your running coming along, listened to him for 5 minutes and then got everything I wanted.

I recommend going and talking to him personally without the car, maybe take coffee and donuts and talk to him about how many hoops you can jump through, how high and how fast you should jump through said hoops and see if you can get him to open up.

Police are trained to resist force and above all else must never back down. I doubt you will force him to do anything, with laywer, his boss etc and if he does he will screw you with something else.

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PostPosted: May 19, 2017, 11:14 am 
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Joined: June 15, 2010, 8:29 am
Posts: 501
Location: Duxbury, MA USA
Have you asked about any other hoops you might have to jump through? I imagine CT to be even worse than MA.
I did not have any frame issues...I just told them that it was a 64 Lotus Seven replica and that body parts were interchangeable with the original.
I had an issue in MA with my engine setup. They wanted the engine to be set up with the exact same equipment as it came from the manufacturer to meet US emissions requirements. With a MegaSquirted 20V Toyota 4AGE never sold in the US, this was not possible. They do provide a means of getting such a car titled however, and I know others that have been successful with the approach. You scrap a pre-emissions standards car that has been registered within the last 6 months and they will grant you a waiver for your car. A friend did this with his Caterham and got it on the road. He found an old pickup he picked up for cheap and scrapped it. Took the scrap certification to the state inspection facility along with the letter from Director of the RMV outlining the loophole and they passed him.
Me, I titled in NH in my sons name...no problems. I have recently switched it back to a MA title...no problems.
Good luck!
Paul

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PostPosted: September 11, 2017, 12:40 pm 
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Joined: November 13, 2009, 9:31 pm
Posts: 90
Location: Connecticut
Hey Kevin,
Any progress on the CT registration?

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PostPosted: November 14, 2017, 3:13 am 
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Best way forward is going to be contacting your elected representatives within your state government. I would contact the senator representing your district in the state senate (not federal) and put forth your case to them.

Thats what they are there to do.

I would be sure to lay out all means you took ahead of time in researching the laws and building to meet them. Then lay out the demands that are being made of you that are NOT within the codified laws.


I work in a government regulatory office, the politicals (elected ones) are the ones we fear and the ones that can make our lives miserable.

Either your inspector is on a power trip or is in the fallback mode of "if I dont understand it, the answer is NO because then I cant be held liable"


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