Christine Chapman AM

Chair, Communities, Equality and Local Government Committee,

National Assembly for Wales


Dear Ms Chapman,


I am the Managing Director of Celtic Holiday Parks who own and operate 3 holiday parks within Pembrokeshire. The holiday parks operated by Celtic Holiday Parks provide 168 touring and tenting pitches with 300 pitches for static caravan holiday homes, and employ approximately 45 people, the majority of which are in full time year round employment, in the last 12 months we have invested over £1.5 in development of these parks including the major upgrade of a central facilities building which is scheduled to be the first of a series of a major development programme scheduled across the group. Celtic Holliday Parks is a privately owned Company, which is made up of my parents and myself. 


I write in response to the consultation on the Holiday Caravan Sites (Wales) Bill. My trade association, BH&HPA has responded on behalf of all members and I endorse their evidence - on this link - to you.


In addition to the response of the BH & HPA, I would like to suggest that the main stimuli for the creation of the proposed Bill is the perceived residential misuse on parks. Whilst I agree that we need to ensure an industry as important as the holiday park sector is protected for the future economy of Wales, we also need to be sensible with the implementation of laws to do this. Local authorities already have powers to deal with this problem, and if the benefit system did not make payments, schools did not register children, and doctors did not register patients to people living illegally on holiday parks it would go a long way to eradicate the problem.


A park owner who sells a caravan to an individual who has sold a house is not doing themselves any favours – if an individual were to realise say £100k from the sale of bricks and mortar to spend £50k on a top of the range caravan licensed for 15 years and, they treated themselves to a £10k car leaving themselves a balance of £40k to live on for 15 years, how would they be able to afford to  upgrade when the licence expires, the park owner then has to either extend the licence or remove the caravan therefore making the individual homeless, or continue to let the caravan owner stay on the park, the park then becomes tatty thus making the sale of additional units less likely. The additional problem of when the time to sell the park comes, and the park is occupied by people in contravention a site licence, thus devaluing the park, and making it difficult to realise the true value thus affecting a park owners ability to retire maybe…..


Proposed changes to law often have unintended consequences, and whilst this proposed Bill is much improved over the original proposals made by Mr Millar, I believe it still goes too far and could potentially be damaging.


I ask please that you ensure my park business is not placed at competitive disadvantage, jeopardising the direct and indirect employment we sustain.



Kind regards,


Yours sincerely,




C Huw Pendleton

Managing Director