Chapter 1: Self-containment technical requirements

Current self-containment technical requirements under the voluntary standard

The voluntary Standard Self containment of motor caravans and caravans (NZS 5465:2001) (the Standard) specifies the requirements for “water supply, sanitary plumbing and drainage installation and solid waste containment in motor caravans and caravans for the purpose of obtaining a self-containment certificate.”

You can find the Standard here:

NZS 5465:2001 Self containment of motor caravans and caravans(external link) — Standards New Zealand

At a glance, the Standard requires self-contained vehicles to have a:

• freshwater tank: 4L per person per day for no less than 3 days
• sink: via a smell trap/water trap connected to a watertight sealed wastewater tank
• grey/black wastewater tank: 4L per person per day (12L per person minimum, vented and monitored if capacity is less than the freshwater tank)
• evacuation hose: 3m for fitted tanks or long enough to connect to a sealed portable tank
• sealable refuse container (rubbish bin with a lid)
• toilet (portable or fixed): minimum capacity 1L per person per day (3L net holding tank capacity per person minimum).

Compliance with the Standard is not compulsory, but compliance enables an occupied vehicle to enter some areas where it would otherwise be denied (for example where a council permits only self-contained vehicles to stay overnight at a particular site).

Problems with the current self-containment technical requirements

There is a lack of trust in the implementation of the Standard – the key tool currently relied on by enforcement authorities to manage freedom camping. The Standard is implemented inconsistently or inappropriately, self-containment stickers can be easily counterfeited, and there is no national register of self-contained vehicles to support enforcement.

This creates issues of fairness. 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 Legislation Bill would:

• create a ‘light touch’ regulatory system for self-contained vehicles with the Plumbers, Gasfitters and Drainlayers Board (PGDB) as the regulator
• enable the creation of regulation-making powers to specify the technical requirements that must be met for a motor vehicle to be certified as self-contained. These regulations would eventually replace the current voluntary Standard
• ensure the new regulatory requirements for self-contained vehicle certification require a toilet to be fixed within the vehicle and exclude portable toilets
• ensure that, after the Bill is enacted, a vehicle may not be re-certified as self-contained under the Standard if it has a portable toilet.

The impact of the fixed toilet requirement is outside the scope of this discussion document

The impact on self-contained vehicle owners who need to upgrade their vehicle to meet the fixed toilet requirements (i.e., a toilet that is permanently fixed to the vehicle and drains to a cassette or a blackwater tank) is not within the scope of this discussion document. This is because this change is being made through the Bill rather than through regulations.

The impact on vehicle owners with a portable toilet is therefore covered in the Regulatory Impact Statement (RIS) for the Bill. If you want to provide feedback on the fixed toilet requirements, you should do this by making a submission to Parliament:

Select committees(external link) — New Zealand Parliament

For completeness’ sake, we have provided the information included in the RIS where we estimated the costs associated with upgrading a larger vehicle’s toilet to a fixed toilet at $1,600 for a basic conversion, though this may be higher in some vehicles^[8]. A member of the technical advisory group estimated the cost of conversion at between $1,188 - $1,825 minimum, based on their knowledge of self-contained vehicle facilities (including purchasing a toilet and external locker and installation labour).

The RIS also notes that an unknown number of vehicles currently used for freedom camping will not be able to be upgraded to meet the new toilet requirements due to size restrictions. These vehicles do not have sufficient space to install a fixed toilet in addition to other required self-containment facilities, such as sinks and wastewater facilities. A member of the technical advisory group estimated a minimum area of 450mm x 650mm would be needed to install a fixed toilet along with a minimum wall height of 700mm.

We are consulting with you about options for the new technical requirements

Below we have listed some options for how the new technical requirements could be set out in regulations. We have included:

• Option 1: ‘light-touch’ performance-based requirements.
• Option 2: prescriptive approach to setting technical requirements.

Option 1: ‘light-touch’ performance-based requirements

Under this option, technical requirements would be less prescriptive than the voluntary Standard. The requirements would set outcomes or objectives and provide flexibility as to how these are met.

For example, rather than specifying that “an evacuation hose must be at least 3m in length,” the technical requirements would instead require that “the hose be fit-for-purpose,” with guidance on how to determine what “fit-for-purpose” means in that context.

This option would set out the self-containment technical requirements in the following four tiers:

• An objective – the social or environmental objective that must be achieved.
• Functional requirements – what the regulated thing must do to satisfy the objective.
• Performance requirements – the qualitative or quantitative criteria the regulated thing must meet in order to comply.
• Details on how requirements should be interpreted, to ensure consistency in certification decisions, for example a standard inspection manual for vehicle inspectors to use when inspecting a vehicle’s self-containment facilities.

The first three tiers would be set in freedom camping regulations, whilst the fourth would be in the formal guidance, referred to above, that would be issued by the PGDB, in consultation with the sector.

The performance requirements would also specify, where practical, applicable Aotearoa New Zealand and international standards (or parts thereof) that will be recognised as demonstrating compliance. 

Regulations would be made shortly after the Bill is enacted and come into force six months after the Bill comes into force. The formal guidance issued by the PGDB would be gazetted and come into force around the same time that it is issued. Interpretation material will be produced by the PGDB. The Standard would be withdrawn two years after the Bill is enacted.

Appendix One sets out how these technical requirements could look in detail. It also sets out some additional matters for consideration.

Option 2: prescriptive approach to setting technical requirements

This option would see the technical requirements set out in sections 1 to 10 of the Standard set out in regulations and modified, where necessary, to comply with the fixed toilet requirements in the Bill and other quality of life upgrades to modernise other technical requirements. You can access these requirements free of charge at the following link:

NZS 5465:2001 Self containment of motor caravans and caravans(external link) — Standards New Zealand

Regulations would maintain the Standard’s current scope, objectives and definitions. Most notably, the requirements would continue to prescribe the particulars of water supply systems, plumbing requirements, sanitary fittings, toilets (which would need to be fixed), waste tanks, evacuation hoses, wastewater treatments and solid waste containment.

This would mean regulations would specify pipe diameters and length, and minimum volumes for potable and wastewater containers. For example, it would be explicit that all waste pipes with a length of less than 3m from sanitary fitting to waste tank must not be of a diameter less than 18 millimetres (mm). For pipes that exceeded 3m, the diameter must not be less than 25mm.

Regulations would be made shortly after the Bill was enacted and come into force six months after the Bill came into force. Prior to the making of regulations, we would undertake more regulatory design work to modernise the technical requirements.

Guidance on how to meet prescriptive technical requirements may not be needed, but if it was, the PGDB, in consultation with the sector, would be able to issue things like inspection manuals and other guidance that vehicle inspectors could use. The Standard would be withdrawn two years after the Bill is enacted.

Assessment of options

Our preferred option and additional matters

At this stage, our preferred option is for regulations to prescribe a set of ‘light touch’ performance-based technical requirements. Our view is that this option should result in lower costs and impacts on vehicle owners, and it aligns strongly with the freedom camping regulatory outcomes. Although it would require guidance to implement, we think this is outweighed by not needing to frequently update the regulations to keep up with changes in motorhome and motor caravan technologies and products.

Footnotes

[8] Ministry of Business, Innovation and Employment, Impact Statement: Reducing negative impacts of freedom campers, (14 October 2021), p 27 - 28.

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