Caravan Sites a potential housing time bomb? Nick Jones Planning and Environmental Enforcement Manager

North Wales

Why come to Conwy?

4.6m 4.5m SL 4.4m Play Area Bryn Euryn El Sub Sta 4.6m MP 22 Homelea Waverley Wilmar Lowther Caravan Park Tyddyn Isa Gaingc View Coedmor Cartref A 548 Sunnyside Pen-isa El Sub Sta Camping Site Gaingc Fawr Galnc-bach Braefells 4.4m Sunny View Caravan Site Endon PH Stones Caravan Park 4.4m Play Area St Ives Camping Site Henllys Heywood Community Centre 7 Emoclew Church 2 6 4.5m 3 PH LB s PO 25 2 4.7m 9 2 Y 4 M ort o n Arm s 8a 8b (PH) 22 3 7a 7b Plastirion Park 20 4 2 24 6 PEN LAN 72 5 26 3 4 4.8m 3 3 70 8 5 29 Sandbank House 22 8 2 4 Yt y Cl Car Park Hillvie 2 64 22 Graceland 33 E Su St Fairfield 30 Photo of Towyn caravan sites Le MP.7 5 Stones Hol iday Cam p Swn-y-m or Sand Sloping masonry SA N RE MO AVE NU E Franklyn W i nd h av en Overton Boulde rs San Remo Chalet Park The Norge Belmont Hol iday Cam p Wayside Lyndhurst Brindle Heath Coed Heri Runnymede Woodlyn Shingle Mean High Water E D Bd y Le vel Crossing Mountview Ty Gaingc Glendene G AIN GC R OAD Sandy Bay Holiday Camp SA NDB ANK RO AD The Sandy Bay (PH) Braem ar Brookleigh Mortons The Paddocks Ba rns t ea d Bakery Fernlea Y Mynachlag Pili-Pala Ty Ne wy dd Lynton Thornham Shingle Miller's Cottage Holiday Camp 24 MAES LLAN 24 9 G AIN GC R OAD 5 MP 0. 25 Golden Gate Holiday Centre Edward's Holiday Camp Edward's Holiday Camp Tyn-y-coed 4 WEN DO VER A VEN UE St Ma ry's Chur ch Ty'n Llan Path Cambria Caravan Park M ar-ean Colmonell Owen's Holiday Camp Ro ck wo od Westdale Ha f od Dormy Shelter Re st-ha v en 0 Caravan Park Cambria Lodge 6 Madeley's Holiday Camp Th e Wend over 20 Cartref 4.3 m Kenora M au-hara 2 4.5 m 5 7 TO WYN ROA D Old Farmhouse Inn (PH) Ty Mawr Holiday Park 0 4 23 20 25 LLYS NAN T T a nk 5 Sports Area 2 to 24 to 8 Ty Mawr Holiday Park 7 0a

In Conwy there are:- 45 Licenced Caravan Sites 9 Residential Sites 7 Touring Sites 9 Static Holiday Sites These sites provide a total of 0,670 caravan pitches

The Act Section () No occupier of land shall cause or permit any part of the land to be used as a caravan site unless he is the holder of a site licence. (2) - Contravention of sec is an offence liable on summary conviction to a fine not exceeding Scale 4. (3) - Caravan Site Land on which a caravan is situated for the purposes of human habitation

The Act - 2 Sections 3 & 4 Where an application for a licence is made, if the applicant is entitled to the benefit of the land in planning terms then the local authority shall issue a site licence. Section 5 Provides a power to attach conditions to the licence in the interests of those dwelling in the caravans or the public at large

Model Conditions The Secretary of State introduced model standards normally to be expected as a matter of good practice. Most local authority conditions reflect those standards although they should be applied with due regard to the particular circumstances of each case

Case Law Mixam s Property Ltd. V Chertsey UDC Any condition must be related to the physical use of the land and can t include conditions which affect rent, security of tenure and the personal and social lives of the caravan occupiers. Babbage v North Norfolk District Council Cannot impose conditions designed to preserve the visual amenity of the site

The Problem. Inadequate accommodation 2. The hidden population 3. The development of densely populated pockets of residential accommodation (Ghettos) 4. Increase numbers presenting themselves as homeless

Old caravan

New caravan

Types of Licence. Touring 2. Static Holiday 3. Residential

Regulatory Reform (Fire Safety Order) 2005. Applies to caravan sites 2. Onus on the responsible person to undertake a fire risk assessment 3. Places a duty to take such general fire precautions to ensure the site is safe 4. Fire Service enforcing Body

HHSRS. Category s Excess cold and heat 2. Other criteria Cat or 2 depending on severity: Damp condensation Crowding and space Entry by intruders Domestic Hygiene Food Safety

HHSRS Personal Hygiene Electrical Fire Collision Hazards Poor Ergonomics

Can we apply HHSRS to a caravan Housing Act 2004 dwelling means building Public Health Act 936 s268(2)

Case Law. R v- Bristol City Council ex parte Everett 999 Condition must present a risk of injury rather than a safety risk likely to cause injury. i.e. dampness which can cause ill health is prejudicial to health

The Hidden Population. Funding 2. Council Tax 3. Most vulnerable and greatest need 4. Increased resources

Ghetto s and homelessness. Local fear of ghetto type areas occurring 2. Increased risk of homelessness

Question raised by Lord Roberts of Llandudno Asked by Lord Roberts of Llandudno To ask Her Majesty's Government whether they will review the effectiveness of the Caravan Sites and Control of Development Act 960 in light of developments in mobile home design and construction since 960. [HL207] To ask Her Majesty's Government why local authorities cannot levy a fee to recover their costs in administering licence applications, variations and site monitoring under the Caravan Sites and Control of Development Act 960; and what action they will take to give financial help to councils in popular holiday areas, such as Conwy County Borough Council, in discharging their obligations under the Act.

Minister s response to Lord Roberts question The Parliamentary Under-Secretary of State, Department for Communities and Local Government (Baroness Andrews): The Government intend to consult on proposals to reform the Caravan Sites and Control of Development Act 960 to address issues concerning management and other standards in residential mobile home and other caravan sites through site licensing. It is proposed to consult on whether local authorities should be able to levy a fee in respect of their licensing functions.

Meeting the Housing Challenge. Consultation Document prior to the new Housing Bill which is imminent

Meeting the Housing Challenge Response Concern that caravans were being seen as a housing solution Welcomed the recognition that site licensing regime should be enforceable Welcomed the proposal that costs should be recoverable Welcomed that licence holders should be fit and proper Proposed that licences should be time bound Raised concerns that there needs to be a balance between housing needs and tourism Raised the issue that there was a potential for an increase in homeless presentations