I am an NI civil servant myself (different Dept though) so I may need to be careful about overtly lobbying other civil servants in case it is seen as a conflict of interest. I’m well used to see outgoing consultation documents and reading replies. This consultation will have been by civil servants (they are always the ones that produce these documents anyway) and the only real difference is that a minister has not signed off the document before it has foment out. They can put out consultations and compile responses without approval for a minister but changing the legislation without a minister is trickier for more controversial proposals. At least by carrying out the consultation they can have that element ready for an incoming minister to sign it off. If it is not too controversial a permanent secretary (head of Dept) may be content to sign it off and can take Dept legal advice on whether they can or not. I don’t see this legislation as being particularly controversial myself.
Today is the first chance I have got to read through the document. Luckily it reads in fairly plain English and like other have said it real does seem to just apply to formal campsites. I don’t think a council/Dept Infrastructure car park can be a campsite as it would have its own legislation covering it. The document outlines what a campsite is. It does not outline what is not a campsite e.g. field for a festival, a car park, school car park or playing field for use at weekends.
There seems to be plenty of wriggle room for the councils in the document where they can explain why they are not making individual licences adhere to the the exact requirements of the proposed legislation. Handy seeing as the councils will be reviewing and awarding licences to themselves seeing as many campsites are run by councils or even government depts in some cases.
If some campsites have to physically change their layout dramatically as a result of this it can only lead to costs being passed on to those staying in them which will make them even less attractive to Motorhome owners who do not need their facilities but rather just somewhere to park.
For a council or anyone else setting up an Aire it look much easier not to provide electricity, water, disposal etc seeing as everything has to be done by specifically qualified personnel and to British Standards. The 6 and 3m rules are points that at well be varied over to Aires.
This consultation already roles two previous pieces of legislation together and I think Aires and Motorhome parking would be better placed in a document if it’s own. However I can’t see it as being seen as important enough to warrant going through all of the steps of consulting and preparing legislation just for that alone as it is such a niche area while so much other legislation needs reviewed and brought up to date (think of e-bikes still being deemed to be motorbikes in NI).
We definitely should return a response but perhaps we should make contact with other Motorhome clubs in NI and combine our efforts? It could be an issue if they deem that schools need a licence to allow motorhomes or caravans to stay on site at weekends or during the summer. That would have a more immediate impact.
Just my initial thoughts. Note
@Davy and
@Ally
