Dear Members,
‘Why is it always us?’
‘Living in a park home – we’re second-class citizens!’
‘Why isn’t the Government helping us?’
These are just a few of the deep concerns made known to IPHAS recently. The country is facing some of the biggest social and financial challenges since 1945, and the situation for many park home residents is becoming acute. ‘Living the dream’ in a park home community no longer has quite the same allure as it once did.
In addition to the energy and cost of living crisis, residents must also absorb Pitch Fee Inflation, still charged at the appropriate RPI increase, despite years of Government promises to change this to CPI. RPI ranged from 8.2% in February 2022, to 13.4% in January of this year, peaking at 14.2% in October 2022, making the average monthly increase 12.6% per month over the past 12 months. As if the constant spectre of your park owner imposing some new, and worrisome edict upon you is not enough, the failure of Government to issue you with the much-heralded Energy Support Relief packages on time, has resulted in serious financial hardship for many.
What has IPHAS been doing on behalf of residents throughout this time, – you may ask?
IPHAS has been very active in the following areas:
- RAISING ISSUES WHERE PARK HOMEOWNERS ARE NOT DOMESTIC CONSUMERS OF ENERGY
- THE ROLE OF IPHAS WITH GOVERNMENT
- COMPENSATION ISSUES
- THE GOVERNMENT COMPENSATION SCHEME
- IPHAS ENGAGING AND MEETING WITH OFGEM
- IPHAS ENGAGING WITH OFGEM CONCERNING NON-DOMESTIC CONSUMERS
MOST PARK HOMEOWNERS ARE NOT DOMESTIC CONSUMERS OF ENERGY
Government research identified 1,832 PH sites and there are 100,406 separate PH addresses in England alone, many of which must purchase their energy from their park owner. IPHAS considers that most park owners are unlicensed, unregulated re-sellers of energy. The park owner’s contract with an energy retailer licenced by Ofgem is a business contract, and his/her unit tariffs are not subject to the Government’s energy price capping scheme, administered by Ofgem. If you are in this category, then you are deemed to be a non-domestic consumer, and you are very likely to be paying a higher unit tariff than a consumer benefitting from having a direct supply contract. Additionally, you are denied freedom of choice in appointing an alternative source of supply. At present, business tariffs are capped by the Government, which keeps the unit price artificially low. These lower tariffs are supposed to be passed on to the consumer, but it is not clear to IPHAS if, in practice, that is always the case. Also, there is no incentive for the park owner to scope market prices for the best possible deal for those to whom he re-sells energy, nor is it clear if these temporary arrangements will be extended by the Government beyond April 2023. In summary, you may not benefit from the same protections from the Energy Regulator Ofgem as other consumers.
THE ROLE OF IPHAS WITH GOVERNMENT
Since discovering these alarming circumstances, IPHAS has been working hard to address these anomalies, and has forged relationships at a high level within Ofgem, the Department for Business, Energy and Industrial Strategy (now the Department for Energy Security and Net-Zero DESNZ), and the Department for Levelling Up, Housing and Communities (DLUHC). IPHAS’ findings have also been reported to the All-Party Parliamentary Group for Park Homes (APPG), and the topic is now a standing agenda item of business, at the request of the Chairman, Sir Christopher Chope, OBE MP.
In early June 2022, IPHAS contacted AGE UK about the issues facing park home residents. AGE UK had been very keen to find a park home residents’ representative group and said that IPHAS was the perfect platform to address their issues. AGE UK publishes information for park homeowners on its website and it became aware of an increasing range of challenges for park homeowners from complaints received direct. Since that initial contact, AGE UK has remained hugely supportive of IPHAS’ aims and objectives and has been prominent in progressing park home issues with ministerial departments and Ofgem. Further information follows.
COMPENSATION ISSUES
In late November 2021, the first of a series of named storms (Arwen) of that winter season wreaked havoc on park home communities in Scotland, the North and East of England, with gusts of 98mph recorded in Northumberland. Five other storms followed in quick succession, concluding with three during the week commencing 16th February 2022 (Dudley, Eunice, and Franklin). Immediately, IPHAS began to receive calls from worried park homeowners caught up in these storms. Many suffered power outages for up to 5 days and others for even longer periods, with some reporting considerable damage to electrical equipment in their homes, with replacement costs running into many hundreds of pounds.
GOVERNMENT COMPENSATION SCHEME
IPHAS quickly established that the same contractual issue described above left those who suffered serious power outages without access to the Governments’ compensation scheme.
On behalf of members, IPHAS made urgent written complaints to Ofgem, BEIS/DESNZ, DLUHC, and the APPG for Park Homes, questioning why park homeowners are disqualified from the Government’s compensation arrangements for consumers, set out in The Electricity (Standards of Performance) Regulations 2015. Ultimately, it was confirmed to IPHAS that the compensation arrangements currently in force would not apply to those park home consumers without a direct supply contract with an energy retail company. At that time Ofgem commissioned a report into storm Arwen* and the failings of service delivery. This report was published on 9th June, which included another document ‘Customer Experience of Storm Arwen’*. This prompted Ofgem to “commission a review of the Guaranteed Standards of Performance for Severe Weather, to identify amendments that will better acknowledge the impact of extended power cuts on customers.” The company, PricewaterhouseCoopers LLP of London (PwC), were appointed as contractors, and they chaired a virtual meeting on 22nd September 2022, attended by senior managers from Ofgem, with IPHAS (2021) Ltd members represented by chairman, Ian Pye.
Subsequently, Ofgem published its consultants’ report on 22nd November 2022, containing an ‘Open Letter’ * on the ‘Outcomes from the Ofgem Review’*.
The Outcomes document sets out their recommendations, including a further section on Implementation of the recommendations*. IPHAS sought clarification on some of the points, and we are pleased to advise members that issues around power outages and future compensation arrangements are included in the review recommendations, and we shall continue to press Ofgem for improved regulation and compensation arrangements to be introduced as soon as possible.
OFGEM MEETING WITH IPHAS
On 8th November 2022 IPHAS, represented by IPHAS chairman, Ian Pye and Team Member and qualified Electrical Engineer, Martin Hampton, attended a virtual meeting with senior officials from Ofgem.
A range of issues was tabled and after considering the points we raised, Ofgem (please see the AGENDA* under OFGEM – Meeting Agenda on the IPHAS website www.iphas.live,* agreed to examine the issues in detail with a promise to issue a report in the new year.
One of the positives from this meeting has already been delivered. For the first time, Ofgem has raised an information page for park homeowners on its website, Advice for park home residents | Ofgem.
OFGEM AND NON-DOMESTIC CONSUMERS
At this time, Ofgem cannot introduce regulations for licensing park owners because it has no powers to do so. Park home sites and any amenities on them, including facilities relating to the delivery of utilities, are the responsibility of local authorities under their site licensing functions and, as such, any concerns must be directed to the local authority in the first instance. If a local authority is failing to carry out its licensing functions, residents can make a complaint using the local authority’s complaints procedure and then to the Local Government Ombudsman if the case is not resolved satisfactorily. However, the supply and payment of utilities are contractual matters between the occupier and the site owner. Contractual disputes of any kind are matters for the courts to determine and, in most cases, payment of a fee will be required. The court that has jurisdiction for matters arising under park home legislation, is the First Tier Tribunal Property Chamber.
As a key stakeholder, IPHAS has received a “Call for Input for the Non-domestic market review” which is live on the Ofgem website: Call for input on the Non-Domestic gas and electricity market | Ofgem. This is a very important step forward for park home owners. In addition to the facts put forward at our meeting with OFGEM, your IPHAS team is reviewing recent correspondence from members about irregular power supplies or significant power outages and encouraging others to contact us about their experiences, by email to advice@iphas.co.uk under the subject “OFGEM REVIEW”, as soon as possible.
PLEASE NOTE: The documents marked * and any further developments on these matters, will be published on our website www.iphas.live .
IPHAS MEMBERSHIP is open to all occupiers of a residential park home site in ENGLAND and WALES, or any other parties interested in the park home lifestyle. IPHAS is an entirely voluntary, not-for-profit organisation. In addition to membership administration, the main purpose of our volunteers is to offer-up-to date advice and support on all matters relating to park home legislation and lifestyle. You can contact IPHAS by using our Freephone telephone service: for ADVICE call 08006126399 or for MEMBERSHIP, CALL 08006126273. You can contact us for advice or membership, and by using the MESSAGE BOARD on the HOMEPAGE of our website www.iphas.live. You can also reach us via Email to advice@iphas.co.uk or membership@iphas.co.uk. Using our email service and postings on our website, we are able to advise many members about the important issues such as the Government Energy Support Schemes outlined above, enabling many to quickly register to obtain their Energy Support Payments. Email is a quick and efficient method of communication, often direct to your mobile phone. If you would like to have your EMAIL ADDRESS added to our records, even if you normally contact IPHAS through your Distributor, please get in touch.
Please remember that we do not send out reminders that your annual subscription of £6 per home is due. We do recommend that you use a Standing Order, details are available on request.
You can help IPHAS to grow if you tell neighbours, new and old, about us, or others who are not currently members The more park home residents we represent, the louder our voice with Government Departments and other bodies, will become to improve terms and conditions for park home occupiers.
Would members Ms J Turner, P Hornby, Ms C Morris, L E Ring, CA & JV Brown please contact us as soon as possible as we need to update your contact details.
Finally, we have some interesting opportunities for developing IPHAS SERVICES this year, so if you are interested in the work of IPHAS and would like to know more about our voluntary services, please contact me with your details at advice@iphas.co.uk.
Thank you for your continued support of IPHAS.
IAN R PYE, CHAIRMAN 14TH MARCH 2023