This is the letter I sent to my state Representative for our district. I hope it describes what you good folks are trying to do. Feel free to plagarize if you feel it appropriate.
Bill
Honorable Representative Mr. Phil King
District 61
2110 Fort Worth Hwy
Weatherford, TX 76086
Subject: Texas Administrative Code 217.3 regarding Vehicle Titles and Registration.
Mr. King,
I am writing you in reference to a recent change of policy of the Texas Department of Motor Vehicles with regards to registration of certain vehicles. Specifically Texas Administrative Code 217.3 regarding Vehicle Titles and Registration.
The state has determined that certain vehicles, ie. Kit cars, dune buggies, or cars modified from previously manufactured vehicles " pose a risk to the general public".
I do understand that preventing highway fatalities are a top concern to the Texas DMV as it should be. What I do not understand is how these vehicles have been determined to pose a noteworthy risk to the general public. I have not seen any quantitative data backing up this claim. I believe DMV owes us this prior to changing regulations affecting licensure and titling of vehicles.
In addition, the state argues against dune buggies allegedly boils down to safety concerns. Texas DMV spokesman Adam Shaivitz told Hemmings that the ban resulted "because many of these vehicles do not have key safety components or do not have a body at all. These vehicles, as manufactured, were not designed for on-road use. These vehicles, as modified from previously manufactured vehicles, also do not keep their on-road qualities."
Note: Farm tractors are not designed for on-road use yet ply many of our roadways with nothing more than an orange triangle on the back of them.
Read more:
http://autoweek.com/article/car-news/texas-dmv-revoking-titles-dune-buggies-and-other-kit-cars#ixzz4yiivkcU4
In another letter DMV asserts: "They (dune buggies) pose a risk to the general public".
Mr. Shavitz/DMV’s assertions appear to be based on supposition and not factual data. As a matter of fact I have endeavored to derive crash accident data from the TXDOT site and have been unsuccessful. The TXDOT search engine is not very useful.
https://www.txdot.gov/government/enforcement/annual-summary.html
To wit, I cannot see how DMV determined that these types of vehicles any more risk than any other vehicle on the road. I would assume that more people were killed in Texas by cement trucks or minivans than several years’ worth of data on kit/owner assembled vehicles.
- Interesting that in the United States a:
- Texas citizen may build or modify a boat all they wish.
- That same Texas citizen may build and fly an aircraft of their own design.
- However, in the state of Texas it is currently not possible to build the most personal of personal conveyances. An automobile.
It is a sad state of affairs when we tell our young and bright Texans that they can drive a car as long as a factory designs it and puts it together for them. To me, that’s sort of like eating BBQ beef brisket from a can processed in Detroit.
I firmly believe that the folks in TXDMV need to eliminate this wasteful and unnecessary policy.
I would ask that you encourage TXDMV to revise Texas Administrative Code 217.3 to:
- allow licensing and titling of “owner built” or “self-built” vehicles meeting minimum safety requirements (i.e. seat belts, lighting, brakes, etc.)
- allow licensing and titling of owner built “kit” vehicles built with components of production vehicles meeting minimum safety requirements (i.e. seat belts, lighting, brakes, etc.)
- allow licensing and titling of “owner built”, “self-built”, or kit built “dune buggies” specifically, meeting minimum safety requirements (i.e. seat belts, lighting, brakes, etc.)
There is a TXDMV meeting this December 7 concerning this matter
http://www.txdmv.gov/about-us/txdmv-board-meetings
If you should wish to discuss this matter further please do not hesitate to contact me.
Respectfully submitted,
William R “Bill” Goebel