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24 September 2019

Camping and Caravan Parks – review by the State Government

Camping and caravan parks are typically associated with short-stay accommodation at popular holiday destinations.

However, whether intended or not, camping and caravan parks are a part of the housing affordability ‘jigsaw’ and provide permanent residency for the community’s most vulnerable and disadvantaged.

But is this good planning?

The State Government is currently reviewing the regulations related to camping and caravan parks, which are about to expire in 2020, to assess how well they are working and whether to make any changes. 

This represents an opportunity to provide some input into this complex town planning and community issue.

Background

Traditional camping and caravan parks offer a valuable alternative form of short-term accommodation, particularly in tourist regions. They continue to be popular among people seeking a more affordable short-term accommodation, and a more informal ‘outdoor’ experience where there is a greater connection to the surrounding environment. Further:

  • In addition to the traditional markets, in more recent times, the ageing population and its desire to travel in caravans and recreational vehicles (RV’s) has increased the demand for these facilities. Improvements to the standard of accommodation (including ‘glamping’ and the use of cabins) have also increased the market appeal.
  • They have traditionally been established on Crown lands or on the outskirts of urban areas. However, in many urban areas, many facilities are closing due to pressures associated with land demand and values. 
  • In reality, new facilities are unlikely to establish on urban zoned land unless specific provision is made for them (such as in PSP’s). It follows that rural areas are often desired for new camping and caravan parks.
  • The discretion in most rural zones is an acknowledgement that such areas can, and do, appropriately accommodate camping and caravan parks.

However, ‘camping and caravan parks’ are not necessarily only for short-term accommodation.  Indeed:

  • The definition of ‘camping and caravan park’ in the planning scheme does not limit the duration of a stay, and simply states that it is a ‘land used to allow accommodation in caravans, cabins, tents, or the like’. It also does not limit the types of services/facilities that can be provided in these forms of accommodation, which may be the same as those commonly found in ‘dwellings’ and (by implication) make them ‘self-contained’. The definition is silent on whether the accommodation can be someone’s ‘normal place of residence’, or the degree of permanency associated with the stay.
  • Section 518 of the Residential Tenancies Act 1997 states that a planning scheme or permit under the Planning and Environment Act 1987 (whether made before or after the commencement of this section) cannot limit the duration of residency in a caravan park.

It can reasonably be inferred from this that permanent residency in a caravan park, and in rural areas, is contemplated by the Planning Scheme and other State legislation. 

Commentary

The caravan parks with a permanent residency that I have visited are clearly affordable but, encouragingly, have thriving communities where the residents take a great deal of pride in their homes and their estates. They seem to ‘work’, but don’t try to apply the usual ResCode Standards to them – they would fall well short.

Community benefits arising from permanent residency in camping and caravan parks include the provision of a valuable alternative source of affordable accommodation. This can lead to positive social and economic benefits for those members of the community that need this. 

However, it can also lead to disbenefits if (owing to the location and/or design of a facility) it results in social isolation and/or additional service costs for relevant providers. It can also potentially lead to substandard accommodation and estates for the community’s most vulnerable.

So, should the current provisions be amended?

In Ratio’s submission to the State Government, we noted the following:

  • There is a seeming ‘loophole’ for caravan parks created by the inadequate definition in the VPP's and the requirements of the Residential Tenancies Act.
  • The difficulty is that the most disadvantaged and vulnerable in our communities need permanent accommodation in caravan parks because there are no other options. Whilst potentially not intended to be for permanent occupancy, camping and caravan parks play a useful role in the community for affordable accommodation.
  • The underlying issue is, therefore, that the current system of public housing supply is failing the community, and hence people 'need' to live in caravan parks. The long-term solution is improved systems for public housing.
  • Ratio Consultants has championed discussions regarding housing affordability and social housing, and it appears that the government is moving in the right direction at multiple levels and via multiple pathways (public housing for development uplift etc). However, there is a lot more to do and, invariably, this will take a lot of time.
  • Addressing the ‘loophole’ in a traditional planning scheme sense will potentially disadvantage the very people who use caravan parks for permanent accommodation (e.g. - require minimum standards of accommodation, amenity etc). But, to do nothing, will mean the most disadvantaged will continue to live in substandard accommodation in locations that are often poorly serviced.

In terms of potential solutions, we suggested:

  • The Residential Tenancies Act could potentially be amended so that the Planning and Environment Act and planning schemes can limit tenure for camping and caravan parks established after (say) 2020.
  • The definition of ‘camping and caravan park’ could potentially be amended to state 'for people away from their normal place of residence’ and make it clear that it is a 'short term' accommodation.
  • The definition of 'Residential village' could potentially be amended to state the accommodation can be in 'caravans or cabins or the like', and this becomes the land use definition for permanent residency in caravans (as currently occurs in camping and caravan parks).

If this is done, camping and caravan parks will operate in the manner originally proposed (e.g. for short-term accommodation in the more remote tourism areas etc.), and permanent residency (via Residential village classification) will more likely be established in urban areas closer to facilities.

There is then the issue of whether permanent residency in caravans and cabins (Residential Village) will establish in urban areas and close to services/facilities. In reality, this may not occur because such land has a higher development value. However, an option (in new PSP areas) may be to designate (potentially zone) sites for uses of this nature (similar to what is done for schools) to require that the land be used for low-cost accommodation.  

This will occur if the value of caravan and cabin accommodation for permanent residents is recognised by the broader community, and suitable minimum standards are imposed to ensure they appropriately integrate with their surroundings.

Conclusion

At ratio: we don’t profess to have the correct or only solutions to the role of camping and caravan parks in general or as a potential source of valuable low-cost housing. 

However, it seems to us that great care needs to be taken to ensure any solution does not prejudice the growing number of people in our communities who need this form of accommodation in the absence of other options.

We will continue to work with the State Government as part of our ongoing interest in housing affordability to ensure this piece of the jigsaw becomes part of a larger coherent housing-affordability picture.

If you want to have your say, visit https://engage.vic.gov.au/caravan-parks-regulations-sunset-review

Author: David Crowder, Director: Planning

 

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