Memorandum submitted by the British Holiday
& Home Parks Association (DMB 54)
The British Holiday & Home Parks Association
(BH&HPA) is the national trade body representing developers
and operators of holiday caravan and chalet parks and residential
home parks in the UK.
TOURISM
The Association represents an industry which
accounts for a tourist spend of some £2.9 billion each year,
accommodating some 20% of all holiday bed nights in the U.K[21].
The industry comprises holiday chalets, caravan holiday homes,
lodges, touring caravans, tenting and all types of self-catering
accommodation.
The BH&HPA membership owns and manages an
estimated 80% of the total licensed caravan and self-catering
"on-site" pitches in the UK. BH&HPA estimates there
to be some 3,500 holiday parks geographically dispersed to the
coastal and rural areas that are attractive to holiday makers.
Research shows that some 50% of the British population took a
holiday in some form on a park in their lifetime and that the
typical pattern of park holidays is as a child, parent and grandparent.
The industry includes well known brands such as Bourne, Butlins,
Haven, Parkdean, Park Holidays UK, and Park Resorts but the majority
of the 3,500 businesses in the sector are SMEs or micro-enterprises,
usually independently owned and managed as a family concern.
HOUSING
The Association's membership also owns or manages
residential parks, often known as "Park Home Estates"
or "Mobile Home Parks", accounting for 60% of residential
home park pitches in the UK. Economic consultants, working on
a project for the Office of the Deputy Prime Minister in 2002[22],
found that there may be up to 2000 residential home parks; they
also established that demand for this sort of low-cost market
housing is likely to increase.
KEY ISSUES
FOR THE
PARKS' INDUSTRY
BH&HPA welcomes the potential benefits of
enhanced coastal access to rural tourism and in particular to
the holiday parks industry. However, we remain concerned about
some important aspects of delivery of coastal access as proposed
in the draft Marine Bill.
1. The draft Bill leaves most of the detail
in the hands of Natural England; as we understand it, the outline
and the detail of the "methodology" to be developed
by Natural England will not be exposed to the rigour of full public
scrutiny. This is patently not a transparent way of dealing with
the process.
2. The work carried out by Natural England
in preparing its proposals was devoid of robust data to quantify
the economic impact of its proposals on tourism business and in
particular holiday and residential parks across England.
3. No indication of resource allocation
for the delivery of the scheme has been provided leaving park
owners with concerns that [clause 280(4)(a)&(b)] they could
face costs in the proper delivery of the trail across their land.
4. There is a lack of rigour in the proposals,
in both the draft Bill and Natural England's outline scheme. For
example:
(a) No precise definitions are proposed in
connection with key features of the scheme including "the
trail", "spreading room".
(b) How will a "fair balance" [clause
273(3)] between public and land owners' business interests be
achieved?
5. Coastal erosion is already a serious
cause for concern for park business that sees its assets crumbling
into the sea in some locations. The proposed coastal trail, encroaching
even further into members' parks, is very worrying as the Bill
provides for the trail to "roll-back" in the face of
coastal erosion [clause 277]. This could threaten the viability
of parks whose land-holding, and ability to generate an income,
is already under pressure in the face of coastal erosion. Even
in cases where park owners may own adjacent land it is usually
extremely difficult to obtain planning permission to roll back
the park development to compensate for such losses.
6. We remain concerned about the presumption
against compensation for landowners, and others, who may suffer
adverse impacts; it is not fair or reasonable for businesses whose
operational viability and capital value is reduced that they cannot
expect to be recompensed for losses.
7. The draft Bill does not require there
to be any mapping of the proposed trail and spreading room. Mapping
of proposed altered and proposed new routes is essential to provide
clarity for both landowners and potential users of the coastal
trail (and spreading room); it is the only way to ensure transparency
in the process.
8. We remain concerned that there appears
to be no formal mechanism that would hold Natural England to account
in the process of establishing the coastal route. It appears to
be the case that once Natural England's "methodology"
has been approved neither the landowner nor any other interested
party would have any right to challenge the proposed route other
than to dispute adherence to the methodology. Natural justice
requires that substantive rights of appeal should be given to
affected land owners.
We hope that these key issues, concisely presented
here, will receive your attention; we would be pleased to elaborate
these points further if that would be helpful to the Committee.
Joan Clark
Deputy Director General
British Holiday & Home Parks Association
May 2008
21 UKTS 2005 Back
22
Economics of the Park Homes Industry, ODPM October 2002 Back
| 
