The Honourable Bryan Green
Deputy Premier and Minister for Local Government
Parliament House
Hobart
Tasmania
Dear Minister
Re: Local Government Association Tasmania (LGAT) State-wide Directions Paper - Review of Council Recreational Vehicle Overnight Camping Services
Background
The Australian Caravan Club Limited (ACC) with a membership of 2,400 is a National representative body for all Recreational Vehicle (RV) Owners in Australia.
ACC has joined forces with other Australian RV groups under the banner of ‘MoTOURing Australia’. Representing approximately 500,000 domestic RV tourists, MoTOURing Australia has been able to create a united and co-ordinated approach to the many issues that face this sector of the tourism market.
The evolution of modern RVs and the expectations of their users have outpaced the capabilities and willingness of the traditional camping industry to satisfy growing demand. The newer generation of RV tourists are seeking an experience that offers freedom of choice along with new options to satisfy their desires.
RV tourists are looking for a unique experience; something more than the average tourist. They are now seeking a cultural, social and environmental adventure that is unique to regional Australia. It is critical that the demands of those wishing to explore Australia in a modern RV are matched by facilities developed to meet those needs in a responsible and sustainable manner.
Review of the Consultation Draft
The consultation draft raises these issues of concern:
§ Complaints to the Office of the Tasmanian Economic Regulator by four privately operated caravan parks constitutes only 3.6% of the 107 caravan parks across the state; ACC believes that the interests of this minority is being put ahead of the Tasmanian RV tourism industry as a whole and will undoubtedly be detrimental of small business across the state. The Competitive Neutrality Regulation (CNR) was introduced primarily for large contracts and tenders, of (10 million plus) that Government was tendering/entering into and was not aimed at the operations of Caravan Parks and camping areas. We question the use of CNR in this area we believe it should be the Local Authorities who make the decisions in the best interest of their community. We feel that Local Authorities are being forced to act for the interest of one business (Caravan Parks) and not for the whole community. We believe this decision will seriously impact more local businesses for a much greater loss than the gains of the caravan park.
§ At a time of economic uncertainty, particularly where your Premier and state treasurer warn that the state is facing “far more challenging times than anticipated”, we believe the Tasmanian Government should be trying to encourage and facilitate RV tourism, not removing currently available rest areas and alienating the travelling public with these proposed measures.
§ ACC unequivocally believe that the proposals in the LGAT Directions Paper are economically irresponsible and will lead to RV tourists travelling to alternate destinations and avoiding Tasmania, as the state will no longer offer the freedom of choice they are looking for. We believe this has the potential for serious economic impacts on Tasmanian businesses large and small including TT-line Company’s Spirit of Tasmania. RV Tourists currently spend an average of $572 per week when travelling. We estimate that that if this freedom of choice is removed Tasmania might never recover, even if these directions are later reversed or ameliorated.
§ Many RV tourists, both fully and semi self-contained, will now be forced to stay in caravan parks and pay higher premiums for services and facilities they do not want or need. The result will be that a large number of these disaffected RV tourists will make alternate arrangements and not visit Tasmania or make much shorter trips. These increased costs coupled with the high cost of transporting their RV from the mainland will be the deciding factor for them to rethink visiting Tasmania.
§ Currently alternate arrangements exist in towns such as Franklin and Gordon, where community groups manage council owned rest areas and reap the financial benefit for their labour. This arrangement ensures that the community benefits both socially and financially from these rest areas thereby creating goodwill with RV tourists.
§ It also needs to be recognised that RV travellers have developed their own community continually sharing experiences and advising the must-sees and the must-avoid. Word of mouth is one of the best advertisements the Tasmanian tourist industry has. We are very much aware that this issue is being monitored and commented upon over electronic social media and that some RV tourists are considering changing plans.
Conclusion and Recommendations
Camping and RV tourism is a very personal choice. There are those that enjoy the modern amenities and close neighbours in a caravan park, and those that prefer more basic and secluded camps. Australians have always enjoyed freedom of choice as to where to stay for camping holidays. Our desire is to see that freedom of choice continues.
Due to health issues where grey water becomes toxic if stored for more than 12 hours, the ACC does not support the proposal for councils to amend by-laws restricting the use of public reserves for camping and caravanning by making clear distinction between self-contained vehicles and only allowing self-contained vehicles to use the facility for overnight camping. The collection of grey water at camping sites should only be necessary where the soil types and usage do not allow the grey water to drain away creating a hazard
The example definition of self contained RVs is very narrow and restrictive and seen as somewhat discriminatory. To be more inclusive it is recommended that the definition of self contained be amended to include:
A vehicle is fully self contained with respect to shower toilet, washing cooking and sleeping and must have the ability to collect and retain all toilet waste and sullage water sufficient at least for 18 hours.
Note: Toilet waste can be contained within a portable toilet albeit it is not in built and sullage can be effectively contained for disposal in a separate sealed container albeit not built into the vehicle.
Such change will make the proposal more inclusive and be much more acceptable, particularly for caravaners with older caravans and campers.
Anecdotal projections indicate that the RV and camping market is likely to double by 2020. Should the Tasmanian Government proceed with the recommendations in the LGAT Directions paper, ACC and MoTOURing Australia believes that the state will not benefit from this growing market; instead it will drive valuable tourist dollars to more RV friendly and inclusive destinations.
Yours faithfully
Tom Smith
Chairman
Australian Caravan Club
0267233303 0429870823
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The above was transmitted to The Honourable Bryan Green on the 29th November 2011