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Government Stimulus called for by Caravan Park Industry

Caravan Parks Association of Queensland (CPAQ) has requested the Queensland Government provide a stimulus package for the caravan parks sector in Queensland in order to support jobs, support regional tourism, and to support the many Queenslanders that live in caravan parks full time.

This cross-departmental request urgently calls on multiple departments and ministers to support our sector through this time of need, with the Government mandated closure or limiting of trade for Queensland’s caravan parks.

For over 100 years, the caravan and camping sector has been a stalwart of the Queensland tourism sectors. It is an industry that has continued to push the boundaries of innovation, deliver jobs in regional communities, provide homes for people in need, created places for families to holiday and create amazing memories, and generated significant economic benefits for regional economies across the State.

On behalf of our members we have called for:

 

A Land Tax Exemption

While parks with a significant residential component have a land tax exemption, pure (or primarily) tourist businesses currently have land tax obligations.

In Victoria, land tax is not charged on all residential, tourist and mixed use parks which encourages the owners of these properties to keep them as caravan parks, and not to increase the number of residents within the property.  This exemption recognises that caravan park land is similar to land used for primary production where income is also derived almost solely from the land and which is exempt from land tax.

CPAQ is calling for the land tax exemption for residential parks to be expanded to include tourist parks.

The land Queensland caravan parks are located on is highly valuable due to their fantastic locations.  Caravan parks, however, have a low income to land area ratio due to their low density, largely single story accommodation.  Both cabin accommodation, and powered and unpowered sites are significantly lower in density when compared with apartments, hotels & motels because of the detached nature of each unit, and are generally charged out at a much lower rate per night, particularly as caravan parks primarily derive income from the land alone.

 

Stamp duty relief on insurance

CPAQ is calling for the waiving of Government required insurance premiums (such as workcover and CTP) and a refund of stamp duty on insurance for the past 12 months.

Further, we ask that the Queensland Government assist the broader tourism sector by putting pressure on insurance companies to reimburse caravan parks for the premium on their public liability and other insurances which are not required at present as they have limited or no guests.

One of our member parks has seen their turnover reduce from $7 million to $2.5 million.  This park has several facilities to entertain families (water parks, pools, jumping pillows, playgrounds) which are now closed.  Despite the fact that the high risk components of their business are now unavailable and the bulk of their sites and cabins remain empty, their insurance company has not provided any relief on their $240,000 per year premium (which has increased from $68,000 just three years ago).

Any reduction in insurance and a refund of stamp duty will provide a vital lifeline and cash flow to caravan parks and other tourism businesses.

Utility Bill Rebate Administration Fee

As caravan parks (generally) operate embedded networks, they will be required to administer the $200 utility bill relief for the Queensland Government to their residents.

Caravan parks are understaffed and under significant financial stress due to the Non-essential business, activity and undertaking Closure Direction.  Further due to the Manufactured Homes (Residential Parks) Act 2003 and Residential Tenancies and Rooming Accommodation Act 2008, caravan parks make a significant loss by supplying electricity to the residents within their business.

The additional burden of administer this Government stimulus measure creates work load for businesses already under significant stress with no recognition of the work required to administer the program.

An administration fee paid on every utility rebate would allow these businesses to effectively administer these payments without putting added stress on their business.  This fee would recognise the administration associated with these payments (claiming the payment, passing it on to the resident, educating the resident etc).

 

Utility Bill Relief for caravan parks

Most caravan parks in Queensland are large users of electricity (above 100MwH per year) due to the complex make up of  their business and the services they provide, despite the fact most would be considered micro or small businesses.

Due to their electricity usage we are calling for a utility relief for caravan parks, recognising the complex make up of their business (which often includes a residential component).

While electricity usage has reduced with a reduction in guests at the caravan park, many facilities continue to require power, even when not in use.

The average caravan park bill in Queensland comprises of a significant number of regulated charges including AEMO Ancillary Charge’s (or network charges), Emissions and renewable energy charges and other charges (AEMO Pool Fees, AEMO Ancillary Charges, Metering Charges and a Retail Service Fee).  These charges make up approximately 50% of the charges on an electricity bill for a caravan park.

A waiver on these charges (as opposed to the tariff) would provide caravan park with some desperately needed relief at this time.

 

Feed In Tariff for Solar

With a significant reduction in the amount of power required by caravan parks at present, many of those with solar panels are currently pushing power back into the grid.

These businesses are large users of electricity (over 100MwH per year) and are not currently receiving a rebate for this power going back into the grid despite the benefit the power companies are getting from this.

Electricity Retailers must be required to provide a feed in tariff for these businesses, that due to COVID-19, are currently generating power on their behalf.

 

Relief on car, truck and concessional registration

Caravan parks have several vehicles which are registered with the Queensland Government and currently sitting unused.  This includes cleaning vehicles (both cars and golf buggies), maintenance vehicles and guest courtesy vehicles.

As these vehicles are not being used, caravan parks should be allowed to apply for a hold on registration renewals and an extension on the registration of those vehicles that are not currently due  for their registration renewal (i.e. if the current restrictions remain in place for 6 months, extend the registration on vehicles for 6 months at no charge).

 

Waste Levy

While the waste levy is a great initiative designed to reduce waste within the state of Queensland, the unintended consequence of this levy has been a significant increase in waste costs for caravan parks.

One park has reported their waste costs have increased by 88% since the introduction of this levy.  This park has been able to claim a small amount of this back through the waste levy rebate (as they have some residents) however this rebate was only for 30% of the increased cost.

We are calling for a  full rebate on the waste levy that has been passed on to caravan parks over the past twelve months and a waiver on the levy for the next two years.

 

A Guarantee on Rents

With the announcement of the moratorium on evictions, many parks are facing situations where residents are refusing to pay rent.

While we support this measure it is important there is clear guidance around who is entitled to claim hardship, how they go about it and what reasons it can be rejected for.

There will be several situations where park residents are facing genuine hardship and while park operators would like to support them during this time, however park operators still have significant mortgages to pay, operating costs to cover during this time (water, power, insurance etc).  These costs don’t go away due to hardship.

If a tenant is receiving benefits from Centrelink and wishes to claim hardship, provision should be made for part of their benefit payment to be directed immediately to their landlord to cover what rent they can.  The remaining unpaid amount still needs to be paid, whether that be by the Government, or another party.

 

State Government Lease

While the Queensland Government has offered a deferral of rent on State Government leases through to early 2021, this provides limited support for the tourism sector, which in many cases will not see their cashflow return to normal until winter 2021 (unless the Queensland border reopens prior to June 2020).

This deferral simply pushes the financial commitment from 2020, to a period in 2021 when cashflow is likely to be even tighter.

We call for the Queensland Government to waive the rent payable on these leases until May 2021.

Where a council leases the land on which a caravan park is situation and then leases that caravan park to another individual/business, the Queensland Government must require that the Local Government passes the benefit of the rent payment waiver on to their leasee.

 

Membership of CPAQ

Our members are under incredible financial stress at present and may not be able to pay their membership renewal in the new year, which will see them lose access to our organisation as a source of information and support at a time when they need it most.

In recognition of the significant role CPAQ have played in sharing Government information, providing advice in terms of Government Directions and acting as a conduit between the Queensland Government and caravan parks across the state, we are seeking grant funding to allow us to waive (or significantly reduce) membership fees for caravan parks in Queensland for the next two years while they get back on their feet.

This funding would also allow those caravan parks that are not currently members of the association to join at a reduced fee, providing them the support they will need to get back on their feet post COVID-19.

Caravan parks in Queensland are at significant risk as a result of COVID-19, and we believe the above measures will provide these businesses the breathing room they need to make it through the coming 12 months.

 

Amendment of the Non-essential business, activity and undertaking closure direction

Our member caravan parks are currently working hard to exceed the expectations placed upon them by the Australian and Queensland Governments in terms of COVID-19 however are incredibly frustrated by the strict restrictions placed upon them when hotels, motels and resorts continue to operate with no Public Health Direction restricting them.

This frustration is exacerbated by:

  • Properties with no approval to operate and no procedures in place to protect visitors offering their land for caravanners:
    • Farmers offering their land for caravanners – this article show examples from other states however we have anecdotal evidence this is also happening in a significant way in Queensland
    • Individuals and businesses – this is just one example we have been provided.. We have received comments from many parks stating we have had numerous guests check out and say they are going to park at friends or park on a dam etc
    • You Camp continuing to list properties in Queensland and accept bookings
  • Other accommodation providers having no restrictions placed on them (and taking advantage of this):

Add to this, the fact that councils and police are (in many but not all cases) not closing down free/unregulated campgrounds – we have received advice from more than one region that they were informed by the local police that “because it is not a designated camping ground, there is nothing they can do about roadside camping or free campers in their area, or any other area, under the current health directives.”

The current health directive (while significantly improved from its original iteration) significantly limits our members ability to take in those people that are in genuine need of accommodation at present.   Caravan parks are making their best endeavours to help people however due to the various interpretations of the Non-essential business, activity and undertaking Closure Direction parks are concerned about taking in some potential visitors as they do not want to do the wrong thing, or worse, be fined.

This Public Health Direction provides the following exception for caravan and camping parks:

Where people live permanently in caravan parks or are staying in caravan parks as interim abodes where their primary residence is not available, they may continue to do so, with social distancing observed. This includes the use of cabins within caravan parks.

 May continue to operate for essential workers such as health practitioners or other persons providing essential services for example, emergency services or infrastructure projects, with social distancing observed.

We are particularly concerned about the ‘they may continue’ to do so as this would indicate that people living permanently in caravan parks and because their primary place of residence is not available to them can only be in the park if they were there when the Directive took effect – this is also how it has been interpreted by the police in many regions.  If this phrase was removed we believe that caravan parks would once again have the ability to accept people in transit, backpackers looking for a place to stay and people who are moved on from unregulated campgrounds (where there is evidence they are still camping despite the fact these sites should have been closed) and individuals looking to self-isolate away from their standard household (I can give some specific examples here if required).  Alternatively (and preferably), caravan parks could be grouped with hotels, motels and resorts with a restriction around tourists and holiday makers, rather than the current exemption which is being interpreted by the local police, with different interpretations in each region.

Our member parks very clearly understand that they are not to take tourists or holiday makers, but the current restrictions limit their ability to take in those people with a genuine need.

In order to achieve best practice in terms of COVID-19 our member parks have implemented a guest declaration which requires potential guests to self-declare the reason for their travel, if they are currently experiencing symptoms of COVID-19 or may have been in contact with someone with a real or suspected case of COVID-19, along with information about where they have come from and where they are going for contact tracing purposes should it be required.

We are calling for the Chief Medical Officer to amend the Non-essential business, activity and undertaking closure direction to either remove caravan and camping parks from the list completely  OR to amend the Direction to include hotels, motels, resorts, and caravan and camping parks for the provision of accommodation to holiday makers and tourists (effectively providing an exemption for those travelling for one of the permitted purposes).

 

As the peak body for the sector, we strongly encourage the Queensland Government to act boldly in the decisions and economic stimulus that they propose to ensure the long sustainability of Queensland’s caravan parks, which are the life blood of regional tourism in our state.