Change to Pitch Fee Uprating Under the Mobile Homes Act 1983: Island Communities Impact Assessment Screening

Gathering Data and Identifying Stakeholders

Location of Mobile Home Sites across Scotland and the Islands

The overall number of homes affected is small. Research by Consumer Focus in 2013 identified 92 park home sites in Scotland, housing an estimated 3,314 mobile homes^[2]. Most sites were concentrated in six local authority areas: Perth and Kinross, Dumfries and Galloway, Fife, Angus, Argyll and Bute, and Aberdeen.

Though now somewhat dated, research for the Scottish Government carried out by the University of York in 2007^[3] included a survey of Local Authorities which gathered information on the number of mobile homes in their area as well as detailed case studies in Highland, Argyll and Bute and Midlothian. The research included those living in one-off mobile homes in the grounds of houses or unlicenced sites, who would not be affected by these measures, as well as those on licenced sites. The local authority survey identified residential pitches in island authorities of Shetland Islands (11) and Orkney Islands (18) but none were reported in Eilean Siar. However, a comparison with websites and directories for mobile home sites found no pitches in these island authorities which suggests that these may have been individual mobile homes rather than homes on licenced sites.

This is supported by the case studies which identify a difference in the pattern of occupation of mobile homes between the two more rural authorities and Midlothian. Three localities were identified in Highland Council area, including the Ardnamurchan peninsula, South Skye and thirdly Glenelg and Arnisdale. Three areas in Argyll and Bute were examined: Tiree, the Ross of Mull, and Craignish as well as the area around Gorebridge in Midlothian.

The Consumer Focus study highlights the role of individual mobile homes in meeting housing needs in rural areas, sometimes in the short term, e.g. where a house is being built, and sometimes over the longer term due to lack of affordable housing. The studies found that, in the Highland area, a low proportion of the total number of caravans and mobile homes were on licensed parks when compared with census data. Similarly, on Skye reference is made to very few of the mobile homes being located on residential caravan sites. No licenced sites were found on Ross of Mull.

This is contrasted with Midlothian where “The 2001 Census showed that there was a very different distribution of mobile homes in Midlothian compared with the other two case study areas. Most of the mobile homes identified in the 2001 Census in Midlothian were on licensed parks - there were very few individual units recorded in the Census in this local authority area.”

Although this data is quite old now, in conjunction with the small overall number mobile homes in Scotland, (likely 4,000 or less) we have concluded that the overall number of mobile homes likely to be affected by this measure in island communities is extremely small.

Stakeholders

In addition to residents and site owners, the main stakeholders are the Scottish Confederation of Park Home Residents Associations, the British Holiday and Home Parks Association and COSLA and national organisations such as the National Caravans Council.

Consultation

The Scottish Government carried out a public consultation to gather views to inform decisions on whether:

• it would be more appropriate for the presumption for annual uprating of pitch fees to be set at CPI rather than RPI or CPI with housing costs (CPIH);
• the change should apply to agreements that are made in future only or to existing and future agreements; and
• it would be appropriate for Ministers to be able to update the index in future via secondary legislation, to keep pace with developments in statistics.

The consultation ran from January to April 2023 and received 171 responses in total. Organisations accounted for 12 responses and there were 159 from individuals, almost all of whom identified themselves as residents of mobile home sites. The consultation analysis was published in June 2023. The consultation paper, analysis report and other documents are available on Citizenspace^[4].

We asked a question in the consultation about the impact of the proposed policy change on individuals and on organisations. No concerns regarding the impact of the measures on the island communities or island living were raised. No feedback suggested that there would be a differential effect based on location.