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Side lights

As if that would do any good!

The Road Vehicles Lighting Regulations 1989 (as amended) Regulation 15. - (1) Every motor vehicle first used on or after 1st April 1991 shall be so constructed that every position lamp, side marker lamp, end-outline marker lamp and rear registration plate lamp with which the vehicle is fitted is capable of being switched on and off by the operation of one switch and, save as provided in paragraph (2), not otherwise.

(Para (2) is not relevant in this case).

Clearly the Grenadier does not comply with this since both the ignition switch and the light switch must be operated in order to activate the obligatory position lamps front and rear.
 
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The question that rises, was it intended for there to be parking lights, as implied by the manual, ( albeit the manual often doesn't bear any resemblance to reality ) and subsequently the software programming inadvertently turned them off when it put the vehicle "to sleep". Which then begs the question if it does legally require them, how did it get type approval. I can't believe it has type approval if there is something non compliant. I am trying to find from where I was informed that " modern cars" did not require parking lights. And if they are required, why are they excluded from the MOT test.

Although it might sound pedantic, it is important to be clear that the issue is not "parking lights" per se (which have a specific legal definition and are optional), the issue concerns the ability to illuminate the mandatory front and rear position lamps when the vehicle is not running and/or is locked. The mandatory front and rear position lamps consist of the tail lamps, the rear number plate lamps and the front sidelamps, and there is no doubt that they are present on the Grenadier. However the law requires that the the mandatory front and rear position lamps (a) are operated by a single switch "and not otherwise", and (b) are illuminated whenever the vehicle is stationary on a road between sunset and sunrise unless the speed limit is 30mph or less.

The issue, in which I clearly failed to interest Customer Services in the slightest, is that two switches must be operated to illuminate the mandatory position lamps (which I shall abbreviate to MPLs), specifically the ignition switch and the light switch, as a consequence of which it is not possible to stop the vehicle and leave the MPLs illuminated unless both switches remain on, which means that the keys must be left in the car and the car cannot be locked.

I think it possible - albeit this is pure speculation - that the vehicles supplied for TA testing did have MPLs which operated as described in the owners' handbook and were therefore compliant but for some reason subsequently they were disabled in software. The lamps are evidently software controlled from the BCU and to leave them on would require the BCU to remain powered up. This is consistent with the warning in the handbook that leaving them on will drain the battery, which on first appearance is an odd statement since there are only six LED lamps which need to be on, and these should draw very little current and hence would not be expected to be a significant drain on the battery. If, however, the BCU and its associated systems - effectively the entire vehicle - have to remain powered then I imagine that the battery could well be drained fairly quickly and the warnign would be appropriate.

It seems to me (as an electronics/systems engineer by profession) therefore that it is plausible that the functioning of the lights was reprogrammed to avoid unintentional battery drain and that no-one has fully thought through the consequences.

I will attempt another communication with Customer Services tomorrow but today's experience did not raise my hopes. I have so far been very impressed with my dealer and will also approach the dealership to see if they would be prepared to raise this through whatever means is available to them. If all else fails, I might take a guess at Lynn Calder's email address in the hope that someone at least pretends to take this seriously.
 
As if that would do any good!

The Road Vehicles Lighting Regulations 1989 (as amended) Regulation 15. - (1) Every motor vehicle first used on or after 1st April 1991 shall be so constructed that every position lamp, side marker lamp, end-outline marker lamp and rear registration plate lamp with which the vehicle is fitted is capable of being switched on and off by the operation of one switch and, save as provided in paragraph (2), not otherwise.

(Para (2) is not relevant in this case).

Clearly the Grenadier does not comply with this since both the ignition switch and the light switch must be operated in order to activate the obligatory position lamps front and rear.
Good find. Those regulations are far more specific than the more general Construction and Use documentation.
 
I've replied to Customer Care pointing out that they appear to have misunderstood the issue and asking that they refer my enquiry to someone with the technical and regulatory knowledge to answer in a helpful way. Watch this space.....
 
I've replied to Customer Care pointing out that they appear to have misunderstood the issue and asking that they refer my enquiry to someone with the technical and regulatory knowledge to answer in a helpful way. Watch this space.....
So. have I
 
You are honoured! I've had a second reply telling me to go via the dealer and it is clear that approaching 'Customer Care' is going nowhere. I will speak to the dealer.

"We are confident that your dealer would have been willing to discuss this with the after-sales service managers, who would then have forwarded the information to the technical team, which will certainly help the regulatory compliance teams overcome the technical difficulties."

It's become very reminiscent of trying to get sense out of Landrover!
 
I am just imagining the converstation.
"Some people have contact customer services and said parking lights don't work"
"Are they right?"
"Yes"
"Ooops, have you told Calder?"
"No"
"Whose fault is it?"
"The company we engaged to provide bulk type approval"
"Can we make them pay?"
"No, it's a consequential loss so excluded from the contract"
"F**k"
 
My lunchtime activity today has been a "deep dive" into the MoT test aspect of this.

The testers' manual states that "It must be possible to switch on the position lamps from the driver’s seat with a single operation of the switch. The position lamps must light up at the same time as the registration plate lamps and any end-outline marker lamps where they are fitted." Whilst this is perhaps a little ambiguous, diving into MoT testers' forum suggest that a vehicle will fail (or at least should) if more than one switch must be operated in order to energise the position lamps. I think that this is consistent with, and was more clearly articulated, in earlier editions of the Testers' Manual.

Certainly the majority of testers who have expressed a relevant view online seem to agree that if the position lights cannot be energised by means of a single switch and therefore with the igntion off, then vehicle will fail the test.
 
My lunchtime activity today has been a "deep dive" into the MoT test aspect of this.

The testers' manual states that "It must be possible to switch on the position lamps from the driver’s seat with a single operation of the switch. The position lamps must light up at the same time as the registration plate lamps and any end-outline marker lamps where they are fitted." Whilst this is perhaps a little ambiguous, diving into MoT testers' forum suggest that a vehicle will fail (or at least should) if more than one switch must be operated in order to energise the position lamps. I think that this is consistent with, and was more clearly articulated, in earlier editions of the Testers' Manual.

Certainly the majority of testers who have expressed a relevant view online seem to agree that if the position lights cannot be energised by means of a single switch and therefore with the igntion off, then vehicle will fail the test.

I also had a dive into the IVA test (individual vehicle approval) as used for kit cars and imports. It says

Note 2: The parking lamp(s) and, if applicable, the front and rear
position lamps must be able to operate even if the device which
starts the engine is in a position which makes it impossible for the
engine to operate.

(My take on that awkward wording is that it means the ignition key or keyless start do not need to be on)
 
I suppose it depends on the demand from EU, AUS, US and ROW as to whether it is worthwhile, costly or achievable a retrospective ( or for future models) software update is developed.
I know this is UK-specific concern, but no, I don’t anticipate any US Department of Transportation motion towards this UK requirement. I think you’re on your own - and honestly, given the battery drain, I don’t see how anyone COULD be compliant. Like you, if we lock with the fob, the lights will stay on for just a while - and then all turn off automatically. Or if you double click, then they all just turn off on the second click. But to be honest, most high speed roads (in cities) have “no parking” signs, unless there are designated parking lanes and plenty of room.
 
I know this is UK-specific concern, but no, I don’t anticipate any US Department of Transportation motion towards this UK requirement. I think you’re on your own - and honestly, given the battery drain, I don’t see how anyone COULD be compliant. Like you, if we lock with the fob, the lights will stay on for just a while - and then all turn off automatically. Or if you double click, then they all just turn off on the second click. But to be honest, most high speed roads (in cities) have “no parking” signs, unless there are designated parking lanes and plenty of room.

I think you are correct that the US do not require the parking lights to be independent of the ignition switch.

However the UNECE does mandate this (unless individual countries have specific opt out clauses)
Most countries in Europe, Australasia as well as Thailand, Japan, South Korea etc have signed up to UNECE.
 
I know we have contacted customer services asking how to activate when parked and we have then been referred to the dealer. Has anyone stated to customer services that it is impossible to have the side lights on when parked, turned off and locked. Then provided the UK regulatory information for vehicle requirements and then MOT?
As this is an MOT failure issue and the warranty is for 5 years then in a year or 2 they are going to have a lot of cars off the road due to failure of compliance.
State that if the issue becomes public on your normal social media sites then there is a good chance all UK mot stations will be checking.
 
I know we have contacted customer services asking how to activate when parked and we have then been referred to the dealer. Has anyone stated to customer services that it is impossible to have the side lights on when parked, turned off and locked. Then provided the UK regulatory information for vehicle requirements ...

Yes. Was told (twice) in no uncertain terms to go through a dealer.

...
As this is an MOT failure issue and the warranty is for 5 years then in a year or 2 they are going to have a lot of cars off the road due to failure of compliance.
State that if the issue becomes public on your normal social media sites then there is a good chance all UK mot stations will be checking.

At this stage it is not certain whether this is an MoT failure or not and there are contradictory views on this.

I have now contacted the DVSA to seek its opinion on whether the vehicle in its current configuration is legal.
 
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