6th Report of Market Access Ombudsman Council (March 16, 2000)

3-(3) Review of standards, etc. certificate of custody space for motor homes (large campers)

1. Complainant: US Embassy

2. Ministry concerned: National Policy Agency

3. Background:

Based on the Article 1 of the Enforcement Order for the Law for Securing Custody Space for Vehicles and Related Issues, custody space for a vehicle must be secured within a 2 km radius of the base of its usage [owner's residence]. However, when the conditions described below are met, motor pools are recognized as the "base of using" and motor home owners are able to obtain a parking certificate:

(1) Custody and management of the motor home is delegated to a custody facility meeting the following requirements, for a certain period on a continuing basis:

1) the facility is delegated by the vehicle owner and is in the business of storing and caring for motor vehicles

2) the facility has a manager and entrances/exits of the vehicles in question are recorded in a logbook, .

(2) The vehicles eligible belong to class a) and b) below:

1) the vehicle is classified as a camper, a vehicle for special use (license class 88), in the usage classifications of the vehicle inspection certificate system

2) the vehicle in question meets the following size criteria:

vehicle length over 5.7 meters or
vehicle width over 1.9 meters

4. Complaint:

(1) Among camper vehicles which belong to license class 88, many are trailers less than 5.7 meters long and under 1.9 meters wide. It is difficult to find parking for such vehicles near their owners' residences and if kept near owners' residences, such vehicles could obstruct the smooth flow of traffic. Accordingly, even though they are less than 5.7 meters and under 1.9 meters wide, issuance of parking certificates for these vehicles [in motor pools] should be allowed. However, this excludes self-propelled vehicles (equipped with a motor) and applies only to camper-trailers and cargo trailers.
Camper-trailers and cargo trailers are vehicles used infrequently (several times a year, at most) and since they are not always being towed, they are likely to cause traffic jams or accidents in urban areas with heavy traffic. To avoid such accidents, ., delegating storage of camper-trailers and cargo trailers to suburban parking lots is expected to reduce accidents, . since owners would drive to these parking lots in the vehicles they usually drive and leave from there for recreation.
Further, there are few parking lots in the center of cities, so keeping such vehicles in suburban parking lots would free up parking space.

(2) Where care and supervision are concerned, a caretaker must be on duty at all times, and in terms of operation, the storage area must be fenced in and the entrance locked. However, this type of supervision is expensive and places a great burden on motor home owners. Therefore, measures for simplifying actual supervision should be taken, by permitting a type of supervision involving locking the vehicle wheels by a clump and leaving the key in the care and supervision of a caretaker living nearby and so on, to achieve the same effect as at present.

5. Results of deliberation:

Towed camper-trailers are not used on a daily basis, and considering their size when hitched to the towing vehicle, they certainly qualify for special measures concerning certificate of custody space, and therefore this matter needs to be handled realistically. The agency concerned is currently conducting a study on camping trailer formats and their usage, and its willingness to apply the same special measures to small trailers as to large motor homes if there are no particular problems is a positive step.
Regarding whether to recognize the parking lot applied for as the base of using of motor homes, the agency concerned follows standards and makes decisions on a case by case basis. But where application of the standards in question is concerned, as long as vehicles can be prevented from entering or leaving without restriction in the absence of the caretaker, it is not necessary for a caretaker to be on duty 24 hours a day, and it is also not obligatory to install a fence, and all parties concerned should be informed of this.

Based on the above, the agency concerned should take the following measures concerning review of standards, etc. for certificate of custody space for vehicles:

The agency should study whether to approve motor pools as the base of using for small towed camper-trailers, based on their format, usage, etc., and whether they are eligible for the special measures permitting their owners to obtain a certificate of custody space [in motor pools], and take the necessary measures during 2000 if there are no particular problems.

Government decision (March 21, 2000)

3-(3) Review of standards for parking certificates for motor homes (large campers)

The following measures concerning review of standards for parking certificates for motor homes (large campers) will be taken.

(1) The issues of whether to approve motor pools as the main place of use for small towed camper-trailers, based on their format, usage, and whether they are eligible for the special measures permitting their owners to obtain a parking permit in motor pools will be studied, and the necessary measures will be taken during 2000 if there are no particular problems.