DOE for campers

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 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?

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 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?

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 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, 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.

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

z

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.

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

Fair test is all we ask....

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]

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.

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.

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.

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.

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

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.

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"

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.

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.

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 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 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...