DOE for campers

peasant

I have read ALL the relevant articles (you posted them yesterday)

Question: have you or has anybody else presented the RSA with those facts and have you (or anyone else) had a reply out of them?

Because from where I'm standing it looks like they're pretty determined to introduce a DOE test for motorcaravans regardless of minor details like statutes and such.

And in addition to what zagmund just posted ...what is stopping the RSA from (rightly or wrongly) instructing the road tax people in Shannon to just simply demand a DOE cert with your next tax application? And if you don't have one then you can't tax your camper ....that certainly wouldn't go down well with the garda at the checkpoint.

niloc1951

Perhaps we should all print off copies of

[FONT=&quot][/FONT]http://www.irishstatutebook.ie/2004/en/si/0771.html

http://www.irishstatutebook.ie/2008/en/act/pub/0024/print.html

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001L0116:EN:NOT

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31970L0156:EN:HTML

If stopped, produce them to the Garda and politely suggest his/her time would be better spent perusing un-insured boy/girl racers eg. those who have 'overlooked' to tell their insurance company that the Toyota Corolla 1.6 is not your common or garden model but a 20 valve, turbo charged and chipped heigh performance model with a gizzillion BHP.:D:rolleyes::rolleyes:

peasant

Still ...I'd like to find a somewhat more workable (and permanent) solution to the question than hitting people with a wad of virtually illegible and incomprehensible printouts

peasant

the last few posts on this thread were moved here from another thread to keep the discussion in one place

niloc1951

peasent, in reply to your earlier post I have sent a four page letter to Bill Barry and Noel Brett at the RSA (as an attachment) plus a number of emails. The letter is a comprehensive argument using numerous official documents which support the proposition that [FONT=&quot]Circular RSA VI 07/09 has no basis in law as [/FONT]S.I. No. 771 of 2004 has no relevance to 'motor caravans'
I have recieved the following reply from Noel Brett CEO of the RSA "Many thanks for your e mail. The Vehicle Standards section will act on this accordingly".
The RSA is a statuary body its remit is to carry out testing as per the S.I. above, it is not at liberty to amend that statute, that is the prerogative of Government.
Hence it cannot add (or subtract) category's of vehicles to S.I.

peasant

niloc1951 wrote: »

peasent, in reply to your earlier post I have sent a four page letter to Bill Barry and Noel Brett at the RSA

good man, well done !

"Many thanks for your e mail. The Vehicle Standards section will act on this accordingly".

The RSA is a statuary body its remit is to carry out testing as per the S.I. above, it is not at liberty to amend that statute, that is the prerogative of Government.
Hence it cannot add (or subtract) category's of vehicles to S.I.

So basically this means that the RSA "vehicle standards section" (whoever they are) will now have to go and pester the governement to change the law to allow for motorcaravans to be tested?

Have you any idea how long this could take?
The governement probably have other more pressing issues right now, but I've seen new laws pushed through pretty quickly when the right (or wrong ) people were lobbying for it.

EDITED to add:
This certainly means that we shouldn't really write that letter from the other thread right now ...they might just forget about testing altogether or have to put it on the really long finger
...here's hoping

niloc1951

FWIT, I finished my acknowledgement to Noel Brett for his prompt reply to mine with the following request.
"I trust that the action taken by the Vehicle Standards section will result in an appropriate roadworthy test manual for 'motor caravans', (category M, 'special purpose vehicle', 'motor caravan') similar to that which is applicable for example in France or Germany, without undue delay"

peasant

niloc1951 wrote: »

FWIT, I finished my acknowledgement to Noel Brett for his prompt reply to mine with the following request.
"I trust that the action taken by the Vehicle Standards section will result in an appropriate roadworthy test manual for 'motor caravans', (category M, 'special purpose vehicle', 'motor caravan') similar to that which is applicable for example in France or Germany, without undue delay"

This being Ireland ...do you think that there is a chance that "we" motorhome owners (or someone we know) could stick our oar in when (if!) that test manual is being drafted so that we could possibly avoid potential pitfalls and make the whole thing as pain-free as possible?

niloc1951

If the RSA simply make a copy of the French or German manual and put their name on it that will do me fine. After all, it is a 'motor caravans' represent a significant business and recreational sector in those countries which is ably represented by manufacturers, organisations and clubs.

peasant

hhhm ...the German test for motorhomes for example is a pain in the behind, because it's basically two tests. One where they test the driving components similar to a NCT test and a completely separate test (in a different location and by a different body) for the gas appliances.
It's a lot of running around and red tape and adds up to quite an expense as well.

This is something I personally could very well do without and an example of what I meant by avoiding pitfalls and making it as pain free as possible.

Generally speaking, the German test criteria are not something to be aimed for because they are terribly bureaucratic. Add some nice alloys or some auxiliary lights for example and you have to provide bloody manufacturers certificates for everything

Irishgoatman

niloc1951 wrote: »

Perhaps we should all print off copies of

http://www.irishstatutebook.ie/2004/en/si/0771.html

http://www.irishstatutebook.ie/2008/en/act/pub/0024/print.html

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001L0116:EN:NOT

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31970L0156:EN:HTML

If stopped, produce them to the Garda and politely suggest his/her time would be better spent perusing un-insured boy/girl racers eg. those who have 'overlooked' to tell their insurance company that the Toyota Corolla 1.6 is not your common or garden model but a 20 valve, turbo charged and chipped heigh performance model with a gizzillion BHP.:D:rolleyes::rolleyes:

Hi, I'm with you on this one. Thank you. Having scanned through the refs. that you gave,(only briefly at the moment), I will carry copies with me. Yes, peasant, it would be better to get it sorted but in the meantime it is not our fault if the Garda have been given misleading information (if they have been given any). If it came to it (which I hope it wouldn't) I would be prepared to fight it in a court of law if needed, I did a similar thing in the U.K. many years ago and won because the law was vague. This seems to be the case with this issue.

blue42

:(the government will always find a way to screw us! wait and see.

Slidey

The RSA has issued a letter stating that pending a review speed limiters are not required on Campers over 3500kg for the time being.

zagmund

blue42 wrote: »

:(the government will always find a way to screw us! wait and see.

You mean the way they screwed us with the €50 VRT for heavier vehicles and vastly reduced VRT for the lighter ones ? I could have sworn this was positive doscrimination in favour of campervan owners.

z

peasant

from the latest RSA letter:

In light of recent feedback regarding the testing of camper vans and motor caravans, the RSA plan to conduct a review of specific testing procedures for these vehicles.

so, in plain English this reads (to me);
We don't really know what we're doing, we don't really know what you (the testers) should be doing either, but please carry on doing so.

Only in Ireland :rolleyes:

niloc1951

So, The RSA have made another temporary exemption for Speed Limitation devices.
Have they not yet read their own regulations and the related S.I's.
It is clearly indicated therein that Category M 'Specal Purpose Vehicle' - 'Motor Caravan' is NOT included as a type of vehicle which is required to be tested under the above Statutes and Regulations.
I wish they would stop messing about, retract Circular RSA VI 07/09, and set about putting in place an appropriate test manual, as is the situation elsewhere in the EU, without further delay.

niloc1951

niloc1951 wrote: »

It is clearly indicated therein that Category M 'Specal Purpose Vehicle' - 'Motor Caravan' is NOT included as a type of vehicle which is required to be tested under the above Statutes and Regulations.

Just to clarify, what I mean is that by virtue of the fact that there is no mention of Category M 'Specal Purpose Vehicle' - 'Motor Caravan' it is clear that they are not included in the Regs. In simple words, if something is not included in a description, then it is not part of what is described :rolleyes:.
Jeeez, this is getting tedious.

darmurt

im new here..ive read all the posts on doe...and me head is fried....my van has 3850 stamped on a plate ....now,, do i need a doe or not and do i need c license....

Richie15

darmurt wrote: »

im new here..ive read all the posts on doe...and me head is fried....my van has 3850 stamped on a plate ....now,, do i need a doe or not and do i need c license....

Yep, you'd definitely need a C or C1 licence if the plate says 3850kg. As for the DOE, that remains to be seen...

killalanerr

so as far as i can tell after reading all a can find their is still no need for class m (read motorhome/camper) to do a doe at this time,they are still exempt as things stand,:rolleyes:
or am i reading it wrong ???

salokin

Hey there.. sorry to jump in.. Im kinda stuck..

I imported a pop top and have just been told it will be classed as a "van with side windows" and not a campervan. Can anyone explain what will happen when I go to the tax office? I know a friend with a similar van who pays camervan tax circa 86 euro and no DOE..

Am I now liable for DOE and higher tax charge?

Cheers

niloc1951

Hi Salokin, this is the regulation which defines a 'motor caravan' for road tax purposes under The Motor Vehicle (Duties and Licences) (No. 2) Act 2008
motor caravans, being vehicles which are shown to the satisfaction of the Revenue Commissioners to be designed, constructed or adapted to provide temporary living accommodation which has an interior height of not less than 1.8 metres when measured in such manner as may be approved by the Revenue Commissioners and, in respect of which vehicles, such design, construction or adaptation incorporates the following permanently fitted equipment—(i) a sink unit, (ii) cooking equipment of not less than a hob with 2 rings or such other cooking equipment as may be prescribed, and (iii) any other equipment or fittings as may be prescribed.

As regards a DOE test if it fulfils the following criteria as per European directive Directive 2001/116/EC "A special purpose category M constructed for the carriage of passengers 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."
It is categorised as a 'motor caravan' and is NOT included in the S.I. No. 771 of 2004 which sets out the categories of vehicle which are required to under roadworthiness testing.

Motorhome, camper, pop-top, campervan, etc. are all vehicles which are officially known as 'motor caravans' in local and EU laws and regulations if they fulfill the above specifications.
Hope the above helps and is not to technical.

Richie15

niloc1951 wrote: »

...motor caravans, being vehicles which are shown to the satisfaction of the Revenue Commissioners to be designed, constructed or adapted to provide temporary living accommodation which has an interior height of not less than 1.8 metres when measured in such manner as may be approved by the Revenue Commissioners...

I read somewhere that this applies to pop-tops, but I read somewhere else that the top has to be in its lowest position. Can't remember where, so just make sure to check it out.

spaceHopper

salokin wrote: »

Hey there.. sorry to jump in.. Im kinda stuck..

I imported a pop top and have just been told it will be classed as a "van with side windows" and not a campervan. Can anyone explain what will happen when I go to the tax office? I know a friend with a similar van who pays camervan tax circa 86 euro and no DOE..

Am I now liable for DOE and higher tax charge?

Cheers

I think that you will have to pay 36% VRT but will still get the low road tax, call the Roslare office and ask

isup

i think that people emailing the authorites is not a good idea, say nothing

Macspower

met a guy yesterday who had just in to tax his motorhome in wicklow and they refused to tax it without a DOE... this is the first I've heard of this..

He got it DOE'd and said it was hassle free.. No mention of windows or weight plates or anything like that..

niloc1951

ISUP, I don't believe in saying nothing when I get screwed or am personally affected by incompetence.

MACSPOWER, there is no law against a person voluntarily submitting to incompetence or to laws which in reality do not exist.

Personally I got my motor caravan taxed in July, after the RSA's erroneous inclusion of such vehicles in the DOE test regime, and the motor tax office DID NOT make reference to a DOE cert.

2 stroke

Macspower wrote: »

met a guy yesterday who had just in to tax his motorhome in wicklow and they refused to tax it without a DOE... this is the first I've heard of this..

He got it DOE'd and said it was hassle free.. No mention of windows or weight plates or anything like that..

Macs, was it a fully fledged motorcaravan or a van with windows?

Macspower

2 stroke wrote: »

Macs, was it a fully fledged motorcaravan or a van with windows?

He was driving a 4 berth Hymer AFAIK.. met him on a site in Leitrim

Irishgoatman

Just (last monday) paid the vrt on my van, taxed it yesterday and no mention by anyone of any sort of test.