Chapter 3: Self-containment documentation

Caravans and mobile homes of holidaymakers under starry sky along wooden walkway to base of Mount Maunganui New Zealand

Current Self-containment documentation issued under the voluntary standard

Under the voluntary Standard, vehicles certified as self-contained are issued with a self-containment certificate, a self-containment warrant and a self-containment sticker. The Standard sets out:

  • the form of a self-containment certificate, warrant and sticker
  • where the warrant and sticker must be placed on a self-contained vehicle.

A vehicle’s self-containment certificate is a detailed document. It lists the details of the plumbing facilities fitted, the minimum diameter and length for these (as applicable), and the number of people the vehicle’s fresh and wastewater systems can support. The certificate gives enforcement officers additional documentation if they have concerns about the reliability of the vehicle’s self-containment warrant.

A vehicle’s self-containment warrant is a blue card that is fixed to the front of the windscreen. It lists only the critical details: the licence plate of the vehicle, the issuing authority who certified the vehicle, the date of certification, the number of people for which the vehicle is self-contained, the expiry date of the warrant and a unique reference number.

A generic blue coloured self-containment sticker is issued once a testing officer certifies the vehicle as self-contained. This sticker is placed on the rear of the vehicle. It does not contain any details that link it to that vehicle, such as the licence plate number. But it provides evidence that a vehicle has been certified under the Standard. This can be useful for vehicle owners between the time a vehicle has been certified as self-contained and their warrant has been issued to them.

Having self-containment documentation issued costs the vehicle owner money. This cost may be:

  • included in membership fees, if the owner is a member of an organisation that provides these services to members[9]
  • bundled into an overall testing fee[10]
  • charged specifically to the vehicle owner[11].

Problems with the current self-containment documentation

There is a lack of public trust in the implementation of the voluntary Standard. Many freedom camping bylaws and notices require campers to stay in a vehicle certified to the Standard, because this is the best available way for enforcement authorities to ensure that vehicles will meet minimum sanitary requirements. However, the lack of oversight by a regulator has led to allegations of inconsistent and inappropriate certification of vehicles[12]. We have heard that the generic blue self-containment stickers are also being counterfeited and, because there is no register of certified vehicles, it is difficult for enforcement authorities to check whether a vehicle is genuinely certified.

This creates issues of fairness in the system. Many vehicle-based freedom campers do the right thing and have their vehicles certified under the voluntary Standard. However, an unknown number of campers are choosing to freedom camp in uncertified vehicles sticking fraudulent self-contained stickers to their vehicles. This behaviour is impacting the social licence for freedom camping and undermining the integrity of the voluntary Standard.

What the Bill would change

The Self-Contained Motor Vehicles Bill would:

  • create a Register of Self-Contained Vehicles. This would be an online register established by the PGDB. Enforcement officers would be able to access the register to check a vehicle’s self-containment information, vehicle inspectors and certification authorities would be able to access the register to input a vehicle’s self-containment information and certificate and warrant details, and the general public would be able to search the register to see whether a vehicle has been certified as self-contained
  • replace the current blue-coloured warrant card with a new green warrant card. The green card would signal that the vehicle meets the new self-containment regulations. There would be a transitional period between the current unregulated self-containment system to the new regulated system
  • require certification authorities to issue both a self-containment certificate and a warrant to vehicle owners if their vehicle has been assessed as meeting the self-containment technical requirements. A vehicle’s certificate and warrant would be issued to the vehicle owner (likely by email) at the time of certification. The vehicle inspector would also enter the details of each inspection into the online national Register of Self-Contained Vehicles
  • make each warrant and certificate valid for four years
  • make new infringement offences related to people not complying with warrant obligations, for example by not displaying a warrant or displaying an expired warrant
  • enable regulations to be made that specify the format of the new self-containment certificate and warrant card.

We are consulting you about options for the format of the self-containment certificate and warrant card

In this section of the discussion document, we have listed some options for the format of the certificate, warrant card and generic identifier options. We have included:

Self-containment certificate options:

  • Option 1: continue to record the details of a vehicle’s self-containment facilities on the self-containment certificate.
  • Option 2: a simplified self-containment certificate.

Self-containment warrant:

  • Option: retain the format of the current self-containment warrant but make the colour green.

Generic identifier options:

  • Option 1: not having a generic identifier
  • Option 2: having another generic identifier.

Options for the self-containment certificate

Option 1: continue to record the details of a vehicle’s self-containment facilities on the self-containment certificate

Under this option, the format of the self-containment certificate would largely mirror the format prescribed in the voluntary Standard. Therefore, the warrant would record:

  • the licence plate details of the vehicle
  • the date the warrant was issued
  • the date the warrant expires (which would be four years from the date of issue, as long as no major modifications are made to the vehicle)
  • the name of the certification authority that issued the warrant
  • the maximum number of people for which the vehicle has been certified as self-contained
  • a unique number that identifies the vehicle
  • the technical details of a vehicle’s self-containment facilities as set out in the online register (e.g., pipe diameters and length, the size of fresh and wastewater tanks, the length of evacuation hoses and diameter of release valves, or other detail about how technical requirements have been met).

The self-containment certificate would be issued by the certification authority immediately after it had reviewed the vehicle’s inspection and the vehicle owner had paid the self-containment monitoring levy (and any fee charged by the certification authority).

Information about a vehicle’s technical requirements would not be required to be displayed on a warrant. These details would be entered into the national Register of Self-Contained Vehicles. This register will be available for enforcement officers to check online either at the site, or, in the case of there being little to no internet access at a site, back in the office, as well as by the certification authority that certified the vehicle and the PGDB.

However, vehicle owners may want to have an easily accessible copy of their self-containment particulars. For example, to prove to other parties (e.g., potential vehicle buyers) with the self-containment facilities’ particulars that are listed on the register. This would enable the other party to compare the particulars listed on the vehicle’s self-containment certificate with the vehicle’s fittings. (Prospective buyers should still make sure that a vehicle is both road-worthy and self-contained, for example, by consulting a mechanic/self-containment testing officer).

Option 2: a simpler self-containment certificate

Under this option, the format of the self-containment certificate would be simplified so it only includes the name and contact information of the vehicle’s owner and the following information:

  • the licence plate details of the vehicle
  • the date the warrant was issued
  • the date the warrant expires (which would be four years from the date of issue, as long as no major modifications are made to the vehicle)
  • the name of the certification authority that issued the warrant
  • the maximum number of people for which the vehicle has been certified as self-contained
  • a unique number that identifies the vehicle.

Under this option, the certificate would not list the technical details of the vehicle’s self-containment facilities. The technical details of vehicles’ self-containment facilities will be entered into the national Register of Self-Contained Vehicles. This register will be available for enforcement officers to check online, either at the site, or, in the case of there being little to no internet access at a site, back in the office.

Prospective vehicle buyers of self-contained vehicles would not be able to access a list of the particulars of a vehicle’s self-containment facilities but would be able to search the register to see whether a vehicle held a current certificate of self-containment. (Prospective buyers should still make sure that a vehicle is both road-worthy and self-contained, for example, by consulting a mechanic/self-containment testing officer).  

The self-containment certificate would be issued by the certification authority immediately after it had reviewed the vehicle’s inspection and the vehicle owner had paid the self-containment monitoring levy (and any fee charged by the certification authority).

Assessment of options for the self-containment certificate

Option Costs – the costs on participants in the regulatory system Practicality - how easy each option is to implement Effectiveness – the potential to drive freedom camping reform and regulatory outcomes Overall score
Option 1: continue to record the details of a vehicle’s self-containment facilities the on the self-containment certificate Similar cost to certification authorities and vehicle owners as the status quo.

0
Would require more regulatory design work to implement if technical requirements are prescriptive based.

Would require even further additional policy and design work to implement if technical requirements are performance-based.

-1
A lot of the information about the vehicle’s self-containment facilities would duplicate what is on collected on the register of self-contained vehicles.

But it could provide additional assurance to prospective vehicle buyers that the vehicle’s self-containment facilities meet regulatory requirements.

2
1
Option 2:  a simplified self-containment certificate Similar cost to certification authorities and vehicle owners as the status quo.

0
Straightforward to implement and administer.

0
Removes unnecessary detail from the current certificate that enforcement officers had previously relied on.

However, vehicle owners would not have access to the details of their vehicle’s self-containment facilities.

1
1

Option for the self-containment warrant

Retain the format of the current self-containment warrant but make the colour green.

We propose that the format of the warrant card stays much the same as it is now. Warrants would include:

  • the licence plate details of the vehicle
  • the date the warrant was issued
  • the date the warrant expires (which would be four years from the date of issue, as long as no major modifications are made to the vehicle)
  • the name of the certification authority that issued the warrant
  • the maximum number of people for which the vehicle has been certified as self-contained
  • a unique number that identifies the vehicle
  • a scannable QR code or barcode included to access the above information.

The new self-containment warrant card would be green. Since the current warrant cards (issued under the voluntary Standard) are blue, this would make it easy for enforcement officers to see whether a vehicle has been certified under the voluntary Standard or the new regulations.

The requirement for where the warrant card is displayed would stay the same. This would mean a warrant card would continue to be displayed in the inside left of the front window/windshield with the warrant details facing out.

Alternative options

We have not put any alternative options for the format of the self-containment warrant because we consider that the format set out above is fit-for-purpose.

At the end of this chapter, we ask whether there is any information you would like to see added to or removed from the warrant card.

Options for the generic identifier

We are not proposing to keep the generic blue sticker

We are not proposing to keep the generic blue sticker. We consider these stickers to be too closely associated with the voluntary Standard and no longer needed. The technical details of vehicles’ self-containment facilities will be entered into the national Register of Self-Contained Vehicles. This register will be available for enforcement officers to check online, either at the site, or, in the case of there being little to no internet access at a site, back in the office.

Option 1: not having a generic identifier

Under this option, there would be no generic identifiers (e.g., a generic sticker) issued by vehicle inspectors after a vehicle was certified.

Option 2: having another generic identifier

Under this option, a generic identifier would be issued by vehicle inspectors. This could be, for example, a generic green sticker that indicates a vehicle has been certified as self-contained under the new regulatory requirements.

Further policy and regulatory design work would be required to determine the format of the generic identifier, which would be prescribed in regulations.

Assessment of options for a generic identifier

Option Costs – the costs on participants in the regulatory system Practicality - how easy each option is to implement Effectiveness – the potential to drive freedom camping reform and regulatory outcomes Overall score
Option 1: not having a generic identifier Reduces costs for certification authorities (CAs) and vehicle owners.

1
Straightforward to implement and administer.

0
Removes public concern about fraudulent use of generic identifiers. Increases confidence in the system.

2
3
Option 2: having another generic identifier Slight increase in costs for CAs to replace the generic blue stickers with a new generic identifier.

-1
Would require further design work to implement, in particular to design a generic identifier that could not easily be forged.

-1
A generic identifier is unnecessary because certificates would be issued to vehicle owners very soon after a vehicle has passed its self-containment inspection.

-1
-3

Our Preferred options for self-containment documentation

At this stage, we prefer the following options:

  • continuing to record the details of a vehicle’s self-containment facilities on the self-containment certificate
  • a new green self-containment warrant
  • not having a generic identifier.

The current certificate contains the technical details for many of the certified vehicle’s self-containment facilities. Enforcement officers currently use the self-containment certificate to check the validity of a vehicle’s warrant, especially in remote places. If the Bill passes, the technical details of a vehicle’s self-containment facilities will be entered into the national Register of Self-Contained Vehicles. This register will be available for enforcement officers to check online (either at a freedom camping site, or back in the office). However, we think that, because vehicle owners will not be able to access this information on the online register, it should continue to be provided on a certificate.

We consider that the information proposed to be displayed on a new green warrant card set out above would provide critical self-containment information to enforcement staff.

We also consider the generic blue sticker to be ineffective because it shows no specific details about the certified vehicle and can therefore be stuck on any vehicle regardless of its self-containment facilities and certification status. Counterfeit stickers can easily be made and this problem could persist if another generic identifier was used. Enforcement officers would still be able to check the warrant card on the front windscreen for evidence of certification, meaning there is no additional need for a generic identifier.

Questions

Self-containment certificate

Question 10. To what extent do you agree with Option 1: continue to record the details of a vehicle’s self-containment facilities on the self-containment certificate?

Please explain your reasons.

Question 11. To what extent do you agree with Option 2: a simplified self-containment certificate?

Please explain your reasons.

Self-containment warrant

Question 12. To what extent do you agree with the option for the self-containment warrant?

Please explain your reasons.

Question 13. Is there any additional information that should be collected?

Question 14. Is there any information proposed to be collected that does not need to be?

Generic identifiers

Question 15. To what extent do you agree with Option 1: not having a generic identifier?

Please explain your reasons.

Question 16. To what extent do you agree with Option 2: having another generic identifier?

Please explain your reasons.

Footnotes

[9] For example, the New Zealand Motor Caravan Association maintains a network of testing officers, which its members can approach for testing. Many of these testing officers are volunteers. NZMCA incorporates the costs of issuing documentation in its membership fee.(external link)

Certified Self-Containment FAQs(external link) — New Zealand Motor Caravan Association

The current membership fee is $90(external link) — New Zealand Motor Caravan Association

[10] For example, Self Contained New Zealand offers self-containment testing and issuing of documentation at $119 for a 20-minute test.

Campervan self containment kit(external link) — Self Contained New Zealand

[11] For example, New Zealand Lifestyle Camping currently charges a fee of $45 to process self-containment documentation. It notes that this is additional to any testing officer charges.

North Island Testing — New Zealand Lifestyle Camping

[12] Summary of submissions: Supporting sustainable freedom camping in Aotearoa New Zealand [PDF, 1.2 MB], (24 August 2021), 18.