My wife and I run Pant y Saer Caravan Park, Benllech, Anglesey, a small 35 pitch caravan park for private owner holiday homes. The park is open from 1st March until 4th January each year.

We are wholly supportive of the bill`s aim of preventing the misuse of holiday caravans for residential purposes. However we think that the proposals in the bill regarding Park owners and LA`s are  unecessarily burdensome for small businesses.

If we make a sale to a party who wishes to purchase a holiday caravan they sign a contract, as per the BH & HPA template, which includes a clause which prohibits residential occupation.

We take details of their home address and latterly have asked to see a copy of a council tax demand. Subsequently we send bills to all home addresses three times each year for pitch fee, insurance and utilities. Each owner responds by paying their accounts, thus proving to us that they are at the address given to us.

As we are are a small park and live on the premises, we are able to monitor occupancy, pick up on any potential abuse, and deal with the situation  should a problem arise. We are also alert to potential buyers wishing to use a holiday caravan for residential purposes and terminate any discussions re a purchase if this situation arises.

Because we are in close contact with our caravan owners we feel that an annual request for proof of residence could imply that we do not trust them, and may be damaging to our relationship with them in the longer term. 

We are also concerned about the level of the proposed fixed penalty for breach of Site License conditions and absence of an appeals process. It seems to us that in relation to other offences, eg. motoring, that £500 is totally disproportionate to the potential offences and could be seriously damaging to a small business. It is also open to abuse by LA`s who may seek to use it as a means of funding and should we be in a position of being served with such a notice we would definitely go to court to be given opportunity to make our case.

The fit and proper person test is also a matter for concern. We operate in a competitive market and if we do not treat our customers fairly, provide good service, and value for money, would not remain in business. Adverse comment about any of these areas is easily propagated through social media and we cannot afford negative comment which would deter future customers. We also doubt whether LA`s have the resources to carry out comprehensive checks to identify the really undesirable who will always find ways to circumvent such checks.

In conclusion we support the general aims of the Bill, but are concerned that the way it is presently drafted ( particularly since it incorporates much relating the the residential sector ) is

inappropriate for small holiday businesses in Wales and will put us at a competitive disadvantage to similar businesses in other parts of the UK.

We support the representations made by BH & HPA and hope you will take note of what has been said, both in their representations and ours above.

Yours faithfully

Maire & Peter Hoyland

Pant y Saer Caravan Park

Benllech

Ynys Mon

LL74 8SD