Dear Sirs


I am writing regarding the

Holiday Caravan Sites (Wales) Bill: consultation


This still seems to be a knee jerk reaction to a few people who cannot be homed by the local councils as they do not have enough housing stock and have surreptitiously crept into caravan accommodation rather than live on the streets and gutters.


If the welsh assembly built more houses then this would go away. All park operators would rather have fare paying customers enjoying their facilities rather than becoming a council estate by the back door.


As research shows there are over 2900 caravan parks in the UK, some run on farms some in back gardens/paddocks with only a husband and wife team doing all the work. Some are large groups which have a proper management structure  but the directors do not get out into the field much to see what actually happens on their parks.


"Fit and proper persons" - if someone has run a park for 25 years plus,  now its up to them to prove they are "fit and proper people" totally open to abuse by the councils who in some areas still think the parks are run by and occupied by gypsies!!!!


"Fixed penalty notices" - this will make the councils come round every year/ time someone moans and "Find a problem" to allow themselves the ability to raise more money by way of fines from a small business sector which is still bouncing along trying to come out of the recession!


"Residence Tests". I think you will have found from the BHHPA response that most parks operate a system of having and holding UK addresses for ALL their customers, many ask for this on an annual basis when each holiday home owner renews their pitch fee agreement. This can be backed up especially where they have had to carry out a flood risk assessment - Q:_ what happens when  the park floods- A:- All customers have returned home, when the EA warnings and reached the critical state!!!!


"Holiday Agreements" - over the past 20 odd years since we have been operating under an approved Code of Conduct, All BHHPA member parks have offered to their customers a contract for use of their caravans which has a complaints procedure built into it. Why do we need more bureaucracy to work under. This is meant to be the time that governments are reducing red tape not increasing it  on a whim!!


We as an industry should not be found as scapegoats to a failing over the past 20 years for lack of house building, maybe the nimby planning should be looked at and expanded asap!


Also what happens to all those you say living on holiday parks. - who finds a home for them. the councils cannot does that mean the Welsh assembly will put them up in their building in Cardiff???


Surely you should be supporting one of your great industries in Wales. Tourism of any sort brings in money and jobs. the more you penalise it the less this happens. even to the end that businesses will shut causing a devastating effect on the local economy and probably putting more people on the housing list needing a home - But you do not have enough!!! back too square one!


allowing one or two parks to become residential parks with the back in of the Assembly could probably take most of the "alleged" homeless people and solve your problems!!

just an idea from business rather than a desk jockey!


:--- and those who choose to ignore the planning law as laid out today, will not be bothered by what is dealt up in the future!!!!

Most have more money than the councils are able to allocate to legal fights, so they fight until the councils give in!! its a great shame but has been proved fact many times around the UK already!!!


This bill has not been brought in to protect customers or business but to protect Councils &/or The Welsh Assembly from their failings. If you want proper reform it needs to be done with all the tourist sector, to allow a cohesive approach to benefiting in this case Wales, but could be rolled out to the whole of the UK if a fit and proper template was created.




Gary Duce


Company Secretary

St Lawrence Caravans Ltd

10 Main Road

St Lawrence Bay