I am currently preparing a submission - due by 23rd June, 2019, and urge others with a similar interest to consider doing so.
I will post a copy of my submission after 23rd June, as I consider others should write their thoughts, not mine.
One note of caution is that I have not finished reading all the details as yet, and thus there may be something which precludes my submission, in which case I will send it to the relevant Minister and regret the lost opportunity.
The invitation is at https://engage.vic.gov.au/caravan-parks-regulations-sunset-review.
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It's a few hours early, but in the end I went with a simple form entry rather than the more complex document I had started working on. My submission is below.
What do you think about caravan park registration requirements?
This can include length of registration
period, documents required, suggested categories of registration. Feedback can
relate to caravan parks as a whole, or different types of park.
No comment
What do you think about caravan park safety requirements?
This can include fire safety requirements
and reports, emergency management plans, flood risks, safety of common areas.
This can relate to caravan parks as a whole, or different types of park.
No comment
What do you think about the facilities that are/should be required in
caravan parks?
This can include required number of toilet
and shower units, standards for water quality, lighting, rubbish, or the
maintenance of facilities. This can relate to caravan parks as a whole, or
different types of park.
No comment
What do you think about movable dwellings standards?
This can include construction, installation,
and compliance requirements. 'Unregisterable movable dwellings' includes cabins
and dwellings in residential villages, but does not include caravans.
The following comments are based on owner-built (and for those people, it would be extremely
beneficial for a single and readily accessible document detailing all
applicable requirements in an understandable way for the lay person, as the
construction document is the first time I have been able to find these) or
built-for-an-owner tiny home.
This should include tiny homes, however tiny homes can be
transported by truck / trailer, so they do NOT necessarily have to be
registerable.
Tiny homes have been designed by architects, so they are
capable of being built to most building requirements EXCEPT size. However, if
building to higher standards is made COMPULSORY, the low cost advantages of
tiny homes is lost, and they become useless as a means to prevent or address
homelessness. Also, the tiny home market could potentially be used to help
cater for downturns in the larger house market - provided they are affordable. (It is unlikely that this will become a
major portion of the market, as the number of people who wish to live this way
is a small, but unknown percentage of the total housing market.)
What SHOULD be made compulsory is means of securing them
in high wind, and (unless they will only
be use in a park with adequate facilities), for wastewater, a composting
toilet / onboard WwTP (e.g., small MBR)
/ holding tank - the latter of which should also include grey water. In
addition, tiny homes can be constructed to be fire resistant - see, for
instance, https://www.youtube.com/watch?v=l2FyCO9FJ-s
With regard to environmental standards, the main benefit
is their small size, and thus more stringent requirements for insulation may be
counter-productive as they will result in fewer people being able to pursue
this option. Similarly, minimum sizes would be counterproductive (and, frankly, absurd, as the small size is
one of the key attractions - and those advocating for imposition of a minimum
size should be careful they are not trying to impose their preferences and
comfort zones on a small percentage of people who are genuinely OK not living
in a semi-palace).
Expert inspection during construction would be useful if
inspectors had the attitude of trying to enable / aid those building tiny homes
- but it is vital that flexibility be allowed (e.g., GRP construction / steel frames may be used at some stage, if
not already).
For the tiny homes in this category, universal design
should no more be imposed than for private larger, fixed dwellings. However, if
the tiny home is publicly owned (e.g., as
part of a homelessness project), universal design would be appropriate.
Do you have any other feedback on how the current regulations are
working, or suggested changes?
If you have any other feedback, or are
unsure where to include your feedback, please provide it here.
As has been shown in some overseas cities, allowing
people to have tiny homes in their backyards can be a quick way to address
homelessness and aid those at risk of homelessness. This also allow homeowners
to gain a source of income by renting space, with minimal cost (connection to sewer, and possibly water and
power).
The developments of tiny homes also shows it is possible
to live comfortably in much smaller places than the current range of palaces on
offer in most areas, and some houses have been built using tiny home principles
- for instance, see https://www.youtube.com/watch?v=jPBDPcqfCwA
Smaller houses would result in an IMMEDIATE reduction of both construction and
operating GHG emissions (and costs),
so ALL area requirements should be reviewed with the intention of reducing the
area requirements to around half of what they are now.
It would also be useful if all surveys on the size of
dwellings desired by people included guidance on likely costs, so that such
surveys don't show unrealistic pipe dreams.
For those who cannot build their own tiny home, ways of
encouraging the market to move into this in a reasonable way (especially during
downturns for conventional houses) would be beneficial.
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