DOE for campers

Irishgoatman

peasant wrote: »

Nope ..."foreign" equivalents of NCT or DOE tests are not recognised here.
Others have tried and failed on the whole EU argument

Why oh why do our governments, past and present, enforce some E.U. regs. to the full and interpret others to suit themselves?.
Just to be b***** minded perhaps.

peasant

You will find that this works the other way around aswell ...try and get an Irish NCT test recognised in Germany ...you won't

Irishgoatman

peasant wrote: »

You will find that this works the other way around aswell ...try and get an Irish NCT test recognised in Germany ...you won't

That's fair enough but are campervans in Germany tested as commercial?

peasant

There are no different types of test in Germany, only the one. Depending on the weight and/or use of the vehicle criteria do differ between vehicles though. Most campers would get tested like any other private vehicle, bi-annually. Above a certain weight (can't remember which 3.5 or 7.5 tons) the test becomes an annual one. With campers there then is an additional gas safety test.
(In Germany they've been testing every roadgoing vehicle (including motorbikes, tractors and even classic vehicles) since before WWII)

Irishgoatman

We have plenty of non-Irish E.U.citizens, myself included, living here so does anyone know of another E.U. country where campervans/motorhomes are tested as commercial verhicles?.
If we are the only one this information would be a help in trying to get things changed.
Let's hope we are alone in this.

peasant

Now, let's not confuse two things here:

Technically speaking, you cannot test a camper based on a truck chassis to the same criteria like a converted Hiace van for example. So techically speaking, some campers will have to be tested (if they are indeed to be tested) like their non-camperised, commercial counterparts.

However, leaving technical issues aside, it is decidedly unfair, that a private vehicle like a camper should be tested more often or at greater expense than any other private vehicle only because the NCT refuses/doesn't have the equipment to test it.

Irishgoatman

peasant wrote: »

Now, let's not confuse two things here:

Technically speaking, you cannot test a camper based on a truck chassis to the same criteria like a converted Hiace van for example. So techically speaking, some campers will have to be tested (if they are indeed to be tested) like their non-camperised, commercial counterparts.

However, leaving technical issues aside, it is decidedly unfair, that a private vehicle like a camper should be tested more often or at greater expense than any other private vehicle only because the NCT refuses/doesn't have the equipment to test it.

My point exactly. Let private vehicles be tested as private vehicles and commercial vehicles as commercial vehicles.
Of course there may well be the need for different classes within the campervan/motorhome category, but I'm sure no-one would object to that would they?

Big_Mac

Hang on a sec, bill barry said that

Speed limitation devices are required on goods vehicles with a design GVW exceeding 3500 kg. This is covered under S.I. No. 831 of 2005, a link to which can be found on the RSA website, www.rsa.ie.

Campers aint Goods vechicles, they's leisure vehicles. Can we therefore deduce that they are exempt?

georgeawe

peasant wrote: »

Nope ..."foreign" equivalents of NCT or DOE tests are not recognised here.
Others have tried and failed on the whole EU argument

Can any1 out there tell us what all the clubs are doing. Think they should be taking action and telling there members.

peasant

georgeawe wrote: »

Can any1 out there tell us what all the clubs are doing. Think they should be taking action and telling there members.

+1
We could hopefully throw some weight behind what they're doing ...(or at least avoid sabotaging it )

2 stroke

georgeawe wrote: »

Can any1 out there tell us what all the clubs are doing. Think they should be taking action and telling there members.

Support a club or 2, and find out.

georgeawe

I am a dedicated member but no-one tells us anything. I wonder if they know themselves.

sunchaser

georgeawe wrote: »

Can any1 out there tell us what all the clubs are doing. Think they should be taking action and telling there members.

The question has been asked what are Clubs doing about DOE’s for Campers/Motorhomes. There is a meeting between the RSA and two Clubs scheduled for 1st September. For owners of motorhomes have a look at Directive 2007/46/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL. Of 5th September 2007.
Annex X1 Nature of and provisions for special purposes vehicles
Appendix 1 Motor-Caravans, Ambulances and Hearses
Item 47 Speed Limiters 92/24/EEC not required.
You will also need to download Council Directive of 6th February 1970 (70/156/EEC)
There are 263 pages in the Official Journal of the European Union so have some fun reading it and deciphering its contents. Then you can present your views to your DOE centre.
　

peasant

Ok ..maybe it needs to be spelled out more directly

This forum is a forum for all motorhome/campervan enthusiasts ...regardless which club they are or aren't affiliated with.

We all are very anxious about this whole DOE thingy and we all would like to be involved in decision making process and/or put our weight behind any initiatives that may be going.

It would be counterproductive however if we here cooked up our own little thingy, possibly sabotaging any developments that clubs may have initiated. (No point in 100 odd readers of this forum signing a petition for a DOE test with conditions attached if the clubs are near getting it struck off totally, for example)

I would therefore like to invite clubs and club members (in as much as they can and in as much as it doesn't interfere with the ongoing dialogue with the RSA/DOE people) to share their thoughts and plans with us.

I would also like to invite all clubs and club members to use this forum (and this thread in particular) as a "neutral ground" for discussion of the issue, if that would be helpful/desirable.

zagmund

Peasant, thanks for your work on this. I haven't had anything to say on it recently, other than what has already been said by yourself and others so I haven't contributed.

I have to say that it says something about the clubs in Ireland that a neutral ground has to be proposed. I have never had any dealings with the clubs (not that I remember anyway) other than the Caravan Club in the UK, but *almost invariably* whenever I meet anyone at a site and a club is mentioned there is harrumphing and groaning and moaning. I thought clubs were supposed to be . . . you know . . . fun places, but it seems this is not the case here.

I'm all for co-operation and sharing of information on forums such as this. I would like to think that the clubs would be also. You never know, a bit of positive input from them might actually help their image among non-aligned campers and gather up some new members.

As it stands I would be a lot happier to meet some boardsies at a campsite than club members - we have a lot in common, shared experience, shared knowledge, etc . . . here.

z

edit -> I know that some boardsies are also club members, but there seems to be no identifiable club presence here. I know there doesn't have to be, but it would make sense in my view.

peasant

zagmund wrote: »

I'm all for co-operation and sharing of information on forums such as this. I would like to think that the clubs would be also. You never know, a bit of positive input from them might actually help their image among non-aligned campers and gather up some new members.

Well, the invitation stands.

And to make sure it happens, please let's not have a club discussion now and stick to the DOE topic

zagmund

Ah yes, sorry about that. Lost the run of myself.

z

blue42

for what its worth i think its comming..and sooner rather than later,sold my own camper last week, its going to get much harder to shift them when this is enforced!

2 stroke

blue42 wrote: »

its going to get much harder to shift them when this is enforced!

Why? The nct test didnt stop people buying cars. If a vehicle is road legal, it will pass. My only prob is the doe test is too frequent and not designed for campers.

killalanerr

2 stroke wrote: »

Why? The nct test didnt stop people buying cars. If a vehicle is road legal, it will pass. My only prob is the doe test is too frequent and not designed for campers.

true im not afraid of the test,for me it would be a selling point .
eg (just passed doe) as in just past nct ,i just want the test to be fare

Macspower

agree on the above... camper with a test would make premium money...

Fair test is all we ask....

Richie15

peasant, you said that no other private vehicle besides a camper gets tested anually. Not trying to contradict you here, just wondering, what's the policy for a private van? Is that treated as commercial for testing purposes? If the DOE thing goes ahead without the changes you're suggesting, it's another complication in deciding whether or not to re-register a conversion.

Macspower, your response from the RSA doesn't address the issue of a speed limiter. I'd say it would need one, if it's over the 3500 but that's just based on one of the questions in the category C theory test. Might be an exemption, suppose we'll see.

niloc1951

I have a 3,850 kg motorhome but have no intention of going to a DOE test centre to have it tested, here's why.
[FONT=&quot]Reference the [/FONT][FONT=&quot]Circular RSA VI 07/09[/FONT]
[FONT=&quot]Roadworthiness Testing of Camper Vans and Motor Homes[/FONT]
[FONT=&quot]Campers, camper vans, and motor homes are subject to roadworthiness testing under S.I. No. 771 of 2004, European Communities (Vehicle Testing) Regulations 2004. For vehicle testing purposes, these vehicles fall under the “goods vehicle” category which is defined in the SI as follows;[/FONT]
[FONT=&quot]“goods vehicle” means a mechanically propelled vehicle, or an articulated vehicle, constructed or adapted primarily for the conveyance of goods or burden of any description whether or not the vehicle is used for such a purpose[/FONT][FONT=&quot].[/FONT]
[FONT=&quot]
[/FONT]
[FONT=&quot]The RSA are incorrect in classifying ‘motor caravans’ as ‘goods vehicles’ and therefore have no authority vested in them to instigate the testing of ‘motor caravans’ as per the ‘Vehicle Testers Manuals’ for ‘Heavy Goods Vehicles’ or ‘Light Goods Vehicles’.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]It is apparent that here in the Republic of Ireland we have neglected to make provision for ‘motor caravans’ when formulating the legislation and regulations which require DOE and NCT testing for roadworthiness. [/FONT]
[FONT=&quot]Both tests are now operating with neither having been assigned an appropriate manual for the testing of ‘motor caravans’.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]The Motor Vehicle (Duties and Licences) (No. 2) Act 2008 describes a ‘motor caravans’ as ‘vehicles which are shown to the satisfaction of the Revenue Commissioners to be designed, constructed or adapted to provide temporary living accommodation etc. etc[/FONT].’
The Act describes ‘goods vehicle’ separately as
‘Vehicles (including tricycles weighing more than 500 kilograms unladen) constructed or adapted for use and used for the conveyance of goods or burden of any other description in the course of trade or business’.
The Motor Taxation Office defines a ‘motor caravan’ separately from ‘goods vehicle’ for Motor Tax classification purpose’s as ‘That the vehicle has been designed, constructed or adapted to provide temporary living accommodation’ in its guidelines of conditions necessary to fulfil its role as a ‘motor caravan’ and be classified and taxed as such and not a ‘goods vehicle’.
The organisation charged with vehicle testing in the UK, VOSA (Vehicle and Operator Services Agency), also describe ‘motor caravans’ as ‘a motor vehicle (not being a living van) which is constructed or adapted for the carriage of passengers and their effects and which contains, as permanently installed equipment, the facilities which are reasonably necessary for enabling the vehicle to provide mobile living accommodation for its users’. VOSA adds, ‘Motor caravans are not classed as goods vehicles for MOT test purposes and are therefore in class IV or V depending on their seating capacity but regardless of their size or weight’.
[FONT=&quot]The Motor Vehicles (Type Approval) Regulations (Northern Ireland) 2007[/FONT]
[FONT=&quot]“motor caravan” means a motor vehicle which is constructed or adapted for the carriage of passengers and their effects and which contains, as permanently installed equipment, the facilities which are reasonably necessary for enabling the vehicle to provide mobile living accommodation for its users”[/FONT][FONT=&quot] [/FONT]
The National Roads Authority does not treat ‘motor caravans’ as ‘goods vehicles’ in its toll charge structure.
The Dublin Port Tunnel does not consider ‘motor caravans’ fulfil its criteria for ‘toll free passage for commercial vehicles above 3.5 tonnes laden weight’.
The EU has also given definitions which clearly positions ‘motor caravans’ separately from ‘goods vehicles’.
[FONT=&quot]Directive 2001/116/EC[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]"A special purpose M category vehicle constructed to include living accommodation which contains at least the following equipment: seats and table, sleeping accommodation that may be converted from the seats, cooking facilities, and storage facilities. This equipment shall be rigidly fixed to the living compartment; however, the table may be designed to be easily removable." [/FONT]
[FONT=&quot][/FONT]
Council Directive 70/156/EEC

[FONT=&quot]DEFINITION OF VEHICLE CATEGORIES AND VEHICLE TYPES[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Category M: Motor vehicles with at least four wheels designed and constructed for the carriage of passengers.[/FONT]
[FONT=&quot]2. Category N: Motor vehicles with at least four wheels designed and constructed for the carriage of goods.[/FONT]
[FONT=&quot]5. "Special purpose vehicle" means a vehicle of category M, N or O for conveying passengers or goods and for performing a special function for which special body arrangements and/or equipment are necessary.[/FONT]
[FONT=&quot]5.1. "Motor caravan" means a special purpose M category vehicle constructed to include living accommodation which contains at least the following equipment:[/FONT]
[FONT=&quot]- seats and table,- sleeping accommodation which may be converted from the seats,- cooking facilities, and storage facilities.[/FONT]
[FONT=&quot]This equipment shall be rigidly fixed to the living compartment; however, the table may be designed to be easily removable.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]In light of the foregoing, it is obvious that ‘motor caravans’ (category M vehicles) should not be required to be examined for roadworthiness under regulations enacted specifically for ‘goods vehicles’ (category N vehicles) as per Circular RSA VI 07/09 and S.I. No. 771 of 2004.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]With reference to Council Directive 70/156/EEC, a ‘motor caravan’ is clearly NOT a category N vehicle; it IS a category M vehicle. [/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]The RSA were erroneous in the directions and assumptions contained in Circular RSA VI 07/09.[/FONT]
[FONT=&quot] [/FONT]
[FONT=&quot]Neither category M nor its sub-categories are defined in S.I. No. 771 of 2004.[/FONT]

salamander27

Thank you very much niloc1951.

That answers my earlier question fully!

niloc1951

Peasent and others, 'motor caravans' ARE NOT goods vehicles, no matter what other vehicle on the road they may 'look like', Ducato's Transits, sprinters, etc.
Checkout

Article 6 Commission Directive 2001/116/EC of 20 December 2001 adapting to technical progress Council Directive 70/156/EEC on the approximation of the laws of the Member States relating to the type-approval of motor vehicles and their trailers

See my post elsewhere on this topic.

peasant

That is all very well ...what are we going to do though when at the next tax renewal date a DOE test becomes mandatory in order to get our motorcaravan taxed?

Not pay it? Drive untaxed?

niloc1951

peasent, I have set out the full argument in the thread 'DOE for Campers'.
'motor caravans' are not included in S.I. which makes DOE testing for goods vehicles a legal requirement.
Therefore there is no legal requirement to have the test done.
Please read my post and google and read the EU and Irish documents quoted in it and I'm sure you will agree.

peasant

Whether I agree or not sadly isn't the issue ...because I do

Going by the arse-about-tit way that the RSA going about this, I wouldn't be totally surprised if they just ignored this detail and made the DOE test mandatory regardless.

So what then? Take them to court?

niloc1951

peasent, twas only 12 minutes between my last post and your reply.
I think you need to read ALL the relevant documents I refer to in the other thread.
The simple fact that screams from those documents is that there is no statuary basis on which the RSA are basing their current position AND there is no Statuary Instrument on the Irish Statute Books which direct that 'motor caravans' are required to have a roadworthiness test.
No organisation or person (including a member of An Garda Síochána) has the authority to demand a valid DOE cert for a 'motor caravan' as there is no basis in law for such a demand.

zagmund

niloc1951 - I think you will find that most people on the forum accept what you are saying and don't doubt the references you provided.

As outlined above, the people on this forum are not the ones charged with enforcing the regulations.

If stopped by the side of the road by a Garda saying "Where's the DOE cert for this here vee-hickle ?" there will be little point in trying to get him to check the SIs. All he has *on the road* is the understanding that campervans need a valid DOE.

It may well be fine taking a case after the event, but most people would want the event never to take place by having the situation sorted out in advance.

What I'm saying is that in a 'discussion' at the side of the road between a Garda believing you do require a DOE and an owner believing you don't is only going to go one way.

z