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What is ‘self-contained’, anyway?
Miriam Richardson
Self-containment is at the heart of the the latest raft of freedom camping changes instituted in 2023.
What is ‘self-containment’?
The NZ Standard gives us our definition of self-containment. To provide “for the containment of solid waste, toilet waste, and grey waste water, resulting from the approved number of occupants’ daily activities, and to supply their minimum fresh water needs, for at least three days.” NZ Standard, Self containment of motor caravans and caravans (NZS 5465:2001), © 2024 Standards New Zealand.
Do you need a fixed toilet to be self-contained? No.
Can you be self-contained and use a portable toilet in a toilet tent? Yes.
Does a preference for using public toilets mean you aren’t self-contained? No.
Does the one-in-many-million chance of catching Legionnaires disease feature in self-containment? What?! No!
Do cassette toilets enable the containment of toilet waste? Yes.
Do toilet cassettes have any problems doing it? No.
Does every toilet cassette in the country need to be modified to be self-contained? No. (Do the new regulations require such a change? Yes. Why? Ignorance on the part of the regulation writers.)
What is the point of self-containment?
The point is protecting the environment by making sure all those enjoying it can keep their waste contained and can dispose of it safely and cleanly in the right place and time.
How did we get here?
When the NZMCA first mooted self-containment as a way to protect the environment, they focused on facilities rather than behaviour. It’s much easier to work out if there is a toilet, than it is to know that a person truly knows that peeing or shitting in the bushes is not acceptable. (Oh, men, should I have left peeing in the bushes out?)
The Responsible Campers Association promoted an alternative, a teaching-based option, where campers learned how to handle their waste responsibly. Sadly, this got little traction. Climbers and trampers learn to handle their waste responsibly; it can be done, even without a vehicle. Many of the reported problems with travellers and waste are not about facilities within their vehicles so much as actions taken by the travellers: education might have successfully managed this, particularly for short term visitors.
Many are self-contained but are not “certified self-contained”
Some are self-contained to the same criteria as those who get certified, and some follow the definition and intent of self-containment but not all the details of the standard. It is not hard to contain your waste, and jumping through the certification hoops has only become necessary as exclusionary laws have been enacted, barring those who are not certified.
There is now a legal requirement to be ‘certified self-contained’ if you want to freedom camp which means having passed the test to prove your vehicle meets either NZS 5465:2001 the ‘old’ standard (blue warrant)(until 7/6/25) or the new regulations for a green warrant.
Certifying for self-containment: the laws and regulations
Strangely, nowhere in either the Freedom Camping Act 2011, or the Self-contained Motor Vehicles Legislation Act 2023 do they trouble to define self-containment. They define enforcement officer, freedom camp, motor vehicle inspection, motor vehicle inspector, Registrar of Motor Vehicles, and even the humble ‘registration plate’, but not what they mean by “self-contained”.
The Plumbers, Gasfitters, and Drainlayers (Self-Contained Vehicles) Regulations 2023 which are the new regulations for self-containment, don’t define it either. They define blackwater, greywater, wastewater, wastewater system, Board, certificate of self-containment, self-containment levy, self-containment authority, enforcement officer, and warrant card, but nope, not “self-containment”.
The government department charged with making the regulations, the Ministry for Business Innovation and Employment (MBIE), does not show any awareness what it means.
The simplest reason to infer from these omissions is that none of those involved in regulating it really care about self-containment, per se. Being either ignorant, or able to ignore, what self-containment actually means, they can regulate to the tune of their other imperatives which are more about restricting freedom camping to large vehicles and wealthier people, than to containing waste and protecting the environment.
Given that the laws and regulations are not based on any definition of self-containment, it is perhaps explicable that they demonstrate a lack of knowledge around how motorhome waste can be safely and sensibly managed, they perpetuate ex-Minister Nash’s peculiar fetish around the fixedness of toilets, and they give plenty of rope, I mean scope to show how little house-based plumbers know about vehicle-based plumbing.
Usually this ignorance would have been ameliorated by the Select Committee process, and by consultation with experts during the formation of the regulations. Sadly the Select Committee process was knee-capped by the then-opposition members (now the government), and those tasked with developing the regulations seem to have taken shortcuts with the consultation, only choosing to hear who or what suited them, and their lack of knowledge and professionalism is evident in the regulations, for all to see.
Unintended consequences: the mandate for large campers
The shift from small vehicles to large vehicles is going to increase the impact of each traveller on the environment. Being larger, heavier, and taller, they will make a bigger impact on the roads, on the phyiscal environment and intrude much more on the scenic view.
Notes
Download a PDF of the standard (this free download is time limited).
PGDF on self-contained vehicles
MBIE on freedom camping changes
Articles in this issue on the freedom camping law changes:
Editorial (p3)
No more freedom camping (p16)
7 days a week (p21)
Celebrating Summer (p5)
none of those involved in regulating it seem to really care about self-containment, per se
7 Autumn 2024
, p
10