UK GOVERNMENT ENERGY BILLS SUPPORT SCHEME

Dear Fellow Members,

Many of you have been in contact with our Advisory Services Team, seeking advice about how you will receive the promised £400 energy relief package, promised to be ‘delivered to every home’, by the Prime Minister.

If you purchase your energy from a supplier in the domestic market, you will be registered with one of the energy retail companies and should have no problem in receiving the £400.

However, although park home legislation affords you the right to source your own energy supplies with an energy retailer, many of you have accepted the convenience of purchasing your energy from your park owner. Unwittingly, in so doing, this has created a major obstacle to you having access to the grant. As a business owner, your park owner must purchase his energy from the non-domestic market, which is not subject to the same price capping controls as the domestic market. The site is likely to have one gas and one electricity meter registered to the park’s business. I understand that you all have meters in your homes, but as you are not registered with the energy retailers, they don’t know about you. Also, it’s unlikely that your park owner has created a record of the serial numbers of your individual meters.

We have also been asked, ‘Why can’t we receive the grant though our Liquid Petroleum Gas (LPG) supplier? LPG is also sold through the non-domestic market, and IPHAS understand it does not provide a platform that could be used to deliver the grant.

The lack of registration has raised other concerns, for you may well be suffering from a ‘loyalty penalty’, in that you be may paying higher unit charges than you would as an independent consumer, even though your park owner is only allowed to charge you the same unit tariff that he is charged, and he must provide you free of charge, documentary evidence in support and explanation of all his charges to you.

Another consequence of this scenario is, should you suffer an outage that leaves you without power, heat and light for a time, an event which may also have damaged electronic equipment in your home beyond repair, you are unlikely to benefit from the industry compensation scheme, as they only have a contract with your park owner. However, he will be compensated for any personal loss.

As many of you are aware, park home communities are predominately retirement communities, a lifestyle choice for many. Due to the increasing disquiet over how the EBSS can be delivered to all communities (those living in residential care settings are affected in the same way as park homeowners), IPHAS are now engaged with AGE UK to pursue an early resolution to the current impasse on payments. We also seek to establish whether there is further scope for co-operation on all issues affecting park home residents. AGE UK has kindly sanctioned IPHAS to post the following link for your information.

Ian Pye CHAIR, The Independent Park Home Advisory Service (2021) Ltd.                                08/06/2022

https://www.ageuk.org.uk/globalassets/age-uk/documents/reports-and-publications/consultation-responses-and-submissions/safe-at-home/consultation-response—technical-proposals-for-the-energy-bills-support-scheme-department-for-business-energy–industrial-strategy.pdf

Important Announcement

Dear Members and Park Home Owners,

Last year the Department for Levelling Up, Housing and Communities, commissioned the University of Liverpool, assisted by Hallam University, Sheffield, to carry out research to gather data to enable an assessment to be made of impacts on the sector of a change to the maximum 10% commission paid on the sale of a mobile home. I am pleased to inform you that we have today received the final report “The impact of a change in the maximum park home sale commission”, from the Department.

A copy of the report is available at:
https://www.gov.uk/government/publications/mobile-homes-the-impact-of-a-change-in-the-maximum-park-home-sale-commission

The Government will now consider the report and recommendations in more detail and set out the next steps in due course.
IPHAS would like to thank all those who participated, and contributed to this important piece of research.

IAN R PYE, CHAIR – IPHAS(2021) LTD.

ENERGY STATEMENT FROM BEIS

Dear Mr Pye,

Thank you for your letter of 21st March, about the challenges facing Park Home residents in terms of their energy contracts.

The Secretary of State is grateful to you for having taken the time to write. I have been asked to respond on his behalf.

We recognise the difficult position that many households are in with the continued impact of Covid-19 and rising energy prices. How much consumers pay for their energy, as well as fairness and affordability are at the heart of the government’s commitment to driving bill savings and ensuring costs are distributed fairly.

The energy price cap was introduced through legislation to address an issue where certain groups of customers in the domestic market were found to be paying too much for their energy through a loyalty penalty. It was not designed to mitigate high global wholesale prices which is what we are currently seeing.

Park home owners purchase gas or electricity in the non-domestic market, which has a greater diversity of supply arrangements for businesses compared to the domestic sector. We are not aware that commercial contracts purchased by businesses, like mobile park owners suffer a loyalty penalty like domestic default tariffs do, and this is why the price cap legislation doesn’t cover them.

Ofgem sets the Quality of Service Guaranteed Standards that must be met by each electricity network company, which includes an entitlement to compensation if distribution companies fail to meet the service standards required.

If residents are connected to a private network that is owned and operated by the residential park owner or operator, instead of being connected directly to the local Distribution Network Operator network, the Distribution Network Operator only has one customer directly connected to their network – the private network owned by residential park owner. Under the Guaranteed Standards of Performance, Distribution Network Operators are only required to make payments for supply interruptions to customers that are directly connected to their network. Private network operators are not required to make payments to their customers under this scheme.

The current compensation rules were set in April 2015 for the duration of the current price control period, which runs from 1 April 2015 to 31 March 2023, and cannot be changed. I understand that Ofgem is in the process of considering the arrangements for the next price control period, which starts on 1 April 2023, and as part of this they will review the eligibility criteria for compensation claims due to power disruptions.

The Energy Ombudsman has been approved by Ofgem to independently handle and resolve disputes between customers and energy companies. If residents feel that their energy company has not appropriately handled and resolved their complaint, they can refer this to the Energy Ombudsman. Further details and points of contact can be found at the following link. www.ombudsman-services.org/sectors/energy.

The Government recognises this is a worrying time for consumers facing pressures due to the significant increases in global gas prices. Our priority is to ensure costs are managed and supplies of energy are maintained. The Secretary of State is in regular contact with the energy industry and Ofgem to manage the impact of high global gas prices and will continue to monitor the situation incredibly closely, including the impacts for consumers supplied by commercial energy contracts.

Yours sincerely,

Helen Huish
BEIS CORRESPONDENCE UNIT

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MHCLG SURVEY ON 10% COMMISSION

The Ministry of Housing, Communities and Local Government commissioned The University of Liverpool and Sheffield Hallam University to provide essential research on the residential park homes sector to inform their review of the maximum 10 per cent commission paid on the sale of park homes. Their report was received at the Ministry of Housing Staff on 12th January 2022 and is currently being assessed by their staff.

FIT AND PROPER PERSON TEST

The fit and proper Regulations were made on 23 September 2020 and came into force in two parts. The first part came into force on 1 July 2021 by which time local authorities were required to be ready to receive applications from site owners. The second part came into force on 1 October 2021 by which time all site owners were required to have submitted applications to be assessed.

Local authorities will be able to charge an application fee and an annual fee and to recover the costs they have incurred, or which will be incurred, in appointing a person to manage a site with the site owner’s consent. This is consistent with the approach to other licensing fees (i.e., site licence fee). The charges should be shared between all residents and should be added to the Pitch Fee Review The fit and proper Regulations were made on 23 September 2020 and came into force in two parts. The first part came into force on 1 July 2021 by which time local authorities were required to be ready to receive applications from site owners. The second part came into force on 1 October 2021 by which time all site owners were required to have submitted applications to be assessed.

Local authorities will be able to charge an application fee and an annual fee and to recover the costs they have incurred, or which will be incurred, in appointing a person to manage a site with the site owner’s consent. This is consistent with the approach to other licensing fees (i.e. site licence fee). The charges should be shared between all residents and should be added to the Pitch Fee Review under Section 4C of the PFR form – ‘Recoverable Costs’.

https://www.legislation.gov.uk/uksi/2020/1034/data.pdf

https://www.gov.uk/government/publications/mobile-homes-fit-and-proper-person-test-guidance-for-local-authorities/mobile-homes-a-guide-for-local-authorities-on-the-fit-and-proper-person-test