Matthew Pennycook
MP for Greenwich and Woolwich · Labour · United Kingdom
“It is a pleasure to serve with you in the Chair, Dame Siobhain. I congratulate the right hon. and learned Member for Kenilworth and Southam (Sir Jeremy Wright) on securing this debate.”
“I will address the right hon. and learned Gentleman’s specific question in due course. Before I do so, I want to put on the record the policy in relation to villages. He can rest assured that I will address the point; if he is unsatisfied, he is more than welcome to intervene again. A number of hon. Members mentioned villages.”
“I will say two things in respect to that, and I will come on to detail how the approach works in relation to decision making very shortly. In general terms, developers can make whatever claims they like about any particular site across the country; it is for the local authority to assess whether, in its view, that site constitutes grey be…”
“and learned Gentleman’s point about what is likely to constitute grey-belt land. Let me directly address his other two specific points. Is this a significant policy? Absolutely, and it has been judged as much by the Office for Budget Responsibility and other external commentators. Is it deliberate? Absolutely. We want, as the right hon.”
“Where authorities may wish to restrict development in villages for other reasons, a range of tools are available, such as conservation areas or normal development management policies. On the right hon.”
“We have to put in place policies that, through the decision-making route, allow homes still to be brought forward in that interregnum, but then we have to push heavily to drive towards universal plan coverage. At that point, the protections are in place.”
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“Funding is already available for councils to acquire new market homes for social and affordable housing through our social and affordable homes programme. They can obviously also rely on section 106 contributions and the local authority housing fund, the fourth round of which makes £950 million available for councils to acquire homes for better-quality temporary accommodation.”
“We continue to target a win-win for both development and nature. I am more than happy to sit down with my hon. Friend to discuss how the NPPF contributes to that objective.”
“I do not intend to reverse the decision; I made the decision. The hon. Member’s local authority is one of nine that have been designated for poor performance, just as the previous Government designated local authorities when they fell below the required standards in their planning processes.”
“We think it is right that developers can use site-by-site viability assessments, as the alternative where viability challenges are acute is that we get no homes coming forward at all. We have consulted, in the recent consultation on the NPPF, on standardised inputs to viability, and we will set out further steps in due course.”
“I am aware of my hon. Friend’s robust views on this matter. There are a range of views about the right geographies for spatial development strategies. The Under-Secretary of State for Housing, Communities and Local Government, my hon. Friend the hon. Member for Barking (Nesil Caliskan), and I are looking at all the consultation responses we have received, and we will make decisions on the full basis of having those fed in.”
“We will not rule out retrospective planning applications of any kind—I think residents across the country who build a conservatory and then make an application, having forgotten to submit the paperwork, would take issue with that. There is a specific issue of intentional unauthorised development, and we are looking at that through the NPPF. I recently had a meeting with a large group of Members from across the House, including Front-Bench Members, and we discussed possible options that we could use to bear down on the practice we are seeing, which is a new business model that exploits a particular set of challenges.”
“In turn, highways authorities and drainage bodies must know that any infrastructure and amenities offered for adoption meet proper standards and are durable.”
“Members have been engaging with them—but in simple terms, they sought views on how best to implement the new consumer protections for homeowners on freehold estates contained in the last Government’s Leasehold and Freehold Reform Act 2024, and on the ways in which we might reduce the prevalence of privately managed estates over the coming years. We are currently analysing the many responses received, with a view to setting out next steps in due course. I am clear that our approach must be balanced. Homeowners must be protected. They should know before they buy whether the public amenities they will rely on will be adopted, and what that means for service standards and costs. Local authorities operating under significant pressures must have confidence that adoption is safe and sustainable and provides value for money.”
“Our objective is clear: we are determined to reduce the prevalence of private estate management arrangements, which are the root cause of the problems experienced by many residential freeholders, and we also want to provide those who currently live on privately managed estates with greater rights and protections, so that the fees they pay are fair, transparent and robustly justified. As my hon. Friend is fully aware, the Government are taking action to deliver on their manifesto commitments in this area. He rightly referenced the two comprehensive consultations that we launched on 18 December last year, both of which closed on 12 March. I do not intend to summarise the contents of those two quite lengthy consultations—I know that hon.”
“These issues blight people’s lives and, with few of the rights to redress found in other markets and no ability to control the management of the estates on which they live, residents feel that they are being treated as second-class homeowners. The Competition and Markets Authority, which has been mentioned, published a house building market study in 2024 that identified significant consumer detriment arising from the private management of unadopted public amenities on housing estates, and concluded that without Government intervention, this consumer detriment was likely to increase. This Government believe that homeowners living on freehold estates deserve a fair deal. That is why we pledged in our manifesto to act to bring the injustice of fleecehold private housing estates and unfair maintenance costs to an end.”
“Roads, sewers, drains, green spaces and other amenities that historically would have been maintained by the local authority or utility companies are instead now routinely left to be managed by private estate management companies, often with little transparency or accountability. In many cases, the quality of the amenities on such freehold estates is inferior to those adopted by the relevant public authority, and falls far short of what people have a right to expect. Residential freeholders across the country frequently report open spaces not fit for purpose, roads left unsurfaced and drainage systems that are often little more than open ditches.”
“Whether it be roads, street lighting, or sewers and drains, homeowners rightly expect that public amenities on new housing estates should be built to an acceptable standard that enables them, in due course, to be adopted by the local authority or other relevant body. Yet, for far too many homeowners, the experience of living on a newly developed housing estate has been tainted by the hidden and enduring consequences of unadopted infrastructure. Unadopted roads and private estate amenities are not, in and of themselves, new, as my hon. Friend mentioned. What has changed is their prevalence and the impact of private estate management arrangements on homeowners.”
“I congratulate my hon. Friend the Member for Hitchin (Alistair Strathern) on securing this important debate. He is an incredibly hard-working and effective advocate for the interests of his constituency, and he has long championed action to address unadopted amenities on privately managed housing estates. I warmly commend him for his ongoing efforts to secure a fair deal for homeowners living on freehold estates in his constituency and across the rest of England. I also thank my hon. Friends the Members for Carlisle (Ms Minns) and for Hastings and Rye (Helena Dollimore), and the hon. Member for Exmouth and Exeter East (David Reed), for their interventions in the debate, and my hon. Friend the Member for Stafford (Leigh Ingham) for sharing the experiences, which are clearly unacceptable, of residents on developments in her constituency.”
“I would refer the hon. Gentleman in the first instance to that CMA house building report, which says very clearly that a twin-track approach is needed. We need common adoptable standards. Only at the point that we have common standards can we force local authorities to adopt. I understand, as I know many hon. Members do, the dilemma that local authorities can face when they have substandard amenities and are asked to adopt them and incur all the costs of bringing them up to the necessary standard, as well as the cost of their ongoing maintenance.”
“We are acting through the two consultations that concluded in March, the draft Commonhold and Leasehold Reform Bill, the implementation of the Leasehold and Freehold Reform Act 2024, our sponsorship of the Law Commission’s project, which I just mentioned, and our ongoing efforts to strengthen the regulation of property agents. I look forward to continuing to engage with my hon. Friend and other hon. Members from across the House as this work progresses, so that we can deliver a system that is clearer for consumers, fairer in practice, and better at ensuring that the places we build come with the adopted, well maintained amenities that residents rightly expect. Question put and agreed to.”
“We know some that private management arrangements can work well, particularly where there is a clear resident-focused governance model and robust oversight, but where such arrangements are used, it is vital that residents are not left exposed to opaque fees, poor service or enforcement measures that feel disproportionate. That is precisely why our reform programme spans both the prevention of poor outcomes, by reducing the creation of problematic unadopted estates, and the strengthening of protections and accountability where those arrangements remain. In conclusion, the Government recognise the strength of feeling on this issue, and the very real impact that current practice is having on homeowners.”
“When those amenities are not properly completed, or when their long-term upkeep is not clearly and fairly arranged, residents can feel that the place they were promised has not been delivered. That is why transparency at the point of sale matters so much. People are making the biggest financial commitment of their lives in most cases. They should be able to understand in plain terms what is intended to be adopted, what will remain private, what services will be provided, how charges will be set, what protections exist if standards slip and what happens if the original developer is no longer on the scene. Certainty and predictability are not luxuries—they are essential.”
“In parallel, a Future Homes Hub project is under way that is helping my Department to engage with industry, local government and others on quality, standards and delivery. Ensuring that new estates come with well-designed, durable and maintainable infrastructure is an integral part of building the high-quality places that communities expect. Before I conclude, I want to briefly mention transparency. It is important to recognise that this debate is not one only about one type of amenity; it is about the whole public realm on new estates—as has been mentioned, the play areas, open spaces, water features, attenuation ponds, sustainable drainage, street lighting, verges, footpaths and the smaller pieces of infrastructure that, taken together, determine whether a development feels like a coherent community.”
“Concerning roads specifically, alongside our consultation, the Department for Transport has commissioned independent research by Ipsos UK into the barriers to road adoption. This will help to ensure that we have a clearer evidence base about what is preventing adoption in practice, whether it be issues of technical standards, inspection and certification processes, funding and commuted sums, long-term liability, or the interaction between planning consents and highways agreements. That work will help inform my Department’s thinking about next steps, including how we can support local highways authorities and ensure that the system encourages timely adoption where that is the appropriate outcome.”
“We are also considering what further steps we can take to strengthen the regulation of property agents because the quality and conduct of the managing agent can make a profound difference to residents’ experience, particularly in respect of communication, responsiveness and the handling of disputes. This issue also engages the responsibilities of other Departments, including the Department for Transport and the Department for Environment, Food and Rural Affairs. Residents do not experience these matters in departmental silos. A road that is not adopted affects safety and accessibility; poorly managed drainage affects flood risk and local environmental quality; and under-maintained public spaces affect community wellbeing and pride in place.”
“We are acting to ensure that enforcement mechanisms are fair and proportionate, and that people are not faced with undue threats or escalating penalties in relation to their home. In addition, we are sponsoring a Law Commission project to consider longer-term legal frameworks so that residents could be given greater control over the management of their estates. I really do think—alongside the consumer protections that are the short-term answer to some of those unfair charges being levelled, and looking at how, in the long term, we end the prevalence of these arrangements—that control is the vital third leg of that stool, giving residents in such situations control. I know that is what the private Member’s Bill of my hon. Friend the Member for Hitchin seeks to address.”
“Alongside the consultations I have referenced, we are bringing forward measures to help those on existing unadopted housing estates, including the removal of draconian enforcement practices that can cause real anxiety for homeowners. Through the Commonhold and Leasehold Reform Bill, which was published in draft in January and is obviously mentioned in substantive terms in the King’s Speech today, we intend to repeal sections 121 and 122 of the Law of Property Act 1925— a 100-year-old law—in order to bring arrears collection into the modern era. The Bill also strengthens safeguards around enforcement, including requiring notice before enforcement action can commence.”
“I will happily direct my counterpart in Northern Ireland to the Government’s response when we publish it in due course, having analysed those two consultations. Where private arrangements exist, they must be transparent and properly regulated. If residents are expected to pay for services, they must be able to see and scrutinise what they are paying for and to access effective routes to redress. We must, of course, ensure that any reforms taken forward work in practise across different types of development and support effective long-term stewardship. But we also have to avoid unintended consequences—for example, implementing measures that would reduce overall housing delivery or that simply shift costs in ways that do not ultimately benefit homeowners.”
“I look forward to receiving feedback on the forthcoming proposals and debating the amending regulations before they are made. I thank hon. Members again for speaking up for their constituents and their interest in this extremely important issue.”
“The regulations in question have been in force for more than a decade and there will inevitably be a significant amount of variation between cases. There are limits on what the CIL legislative framework can do in such a context, but I remain committed to addressing those concerns in a revised system going forward, and I am more than happy, as I have been striving to do over recent months, to keep hon. Members with an interest in this issue and whose constituents are affected, fully updated. It is certainly not the case that when it comes to those already affected we intend to do nothing. I look forward to updating the House in due course in respect of the proposed steps I have set out today and in respect of the consultation and when hon. Members will have a chance to fully engage.”
“I recognise that many hon. Members who have spoken today will be concerned not only about what we do in future to amend the regulations, but about how proposals will help constituents who have already incurred a CIL charge as a result of non-compliance with procedural requirements for securing an exemption, arising from the way the regulations were framed in 2014. I am afraid I have to repeat what I said earlier: I cannot comment on individual cases and facts that are not known to me, nor on the approach taken by specific charging authorities, but I want to reassure hon. Members here today that we take such concerns very seriously. They are actively informing our work to reform the system going forward.”
“We are also mindful of the need to ensure that any revised process continues to help local planning authorities to properly administer CIL in an effective way and to ensure that CIL liabilities are discharged appropriately. After all, as has rightly been noted today, CIL remains a vital system to support the development of an area by funding essential local infrastructure. I appreciate that hon. Members will want to engage carefully with the detail of these proposals once they are published. The Government aim to publish a consultation on the proposals as soon as possible. Although I am loath to give a specific date, as Ministers always are, I anticipate being able to do so before the summer recess. Before I conclude, I will briefly address what I know is probably the biggest concern that exists, which is the issue of retrospectivity.”
“Through the forthcoming consultation, the Government will put forward proposals aimed at improving outcomes for householders and self-builders, while safeguarding the integrity of the CIL system and ensuring that local planning authorities can properly administer, scrutinise and enforce that system. We want to ensure that in the future, the system minimises the opportunity for procedural errors and that, when errors are made, it does not impose disproportionate penalties. We also want to prevent homeowners and self-builders from incurring significant and unexpected CIL charges, which, as we have heard today, can have significant consequences for individuals and their families.”
“Many authorities administer CIL exemptions carefully and conscientiously, often supporting householders through what can seem to be a complex process. That said, we have identified an important opportunity to provide greater clarity and flexibility for applicants and charging authorities. Let me set out the next steps. Having considered the concerns that have been raised with me—primarily by the right hon. Member for Godalming and Ash, but also by others, including the hon. Member for Farnham and Bordon, and my hon. Friend the Member for Dagenham and Rainham (Margaret Mullane)—I am pleased to confirm today that the Government intend to consult on proposals to amend the CIL regulations, in order to improve the process for obtaining householder development and self-build exemptions in the future.”
“They might not fully appreciate the consequences that arise from commencing their development between permission being granted and commencement taking place. Furthermore, the nature of the regulations means that developments that receive retrospective planning permission under section 73A of the Town and Country Planning Act 1990 cannot benefit from an exemption because, in planning terms, this is the grant of a new planning permission. A section 73A permission is treated as having commenced when that permission is granted. As a result, any exemption previously obtained does not carry over and it is not possible to comply with the procedural requirement of applying for an exemption before commencement. I want to make it clear that local planning authorities are operating within a prescribed statutory framework.”
“Members have highlighted, failure to complete the necessary processes before works commence on a site has resulted in some homeowners and self-builders losing their eligibility for an exemption. In such cases, the full CIL charge has been imposed. Sometimes, it has been payable immediately, with late payment interest and surcharges also applied, as was mentioned earlier. The Government appreciate that compliance with the process requirements of CIL can appear complex, particularly for developers who might not otherwise be involved in planning and development on a regular basis, or who do not have professional builders or advisers involved in the process. A householder developer might not be aware of their CIL liability until after planning permission stage, when a levy liability notice is issued by the authority.”
“The developer must wait to be notified by the CIL-charging authority of its decision on the exemption claim before development can commence. The Ministry of Housing, Communities and Local Government publishes comprehensive guidance on CIL, which is available on the gov.uk website. This guidance also refers to the relevant forms that must be completed. Apart from those who are building residential extensions, developers are required to serve a commencement notice to the charging authority; again, this must occur prior to commencement of development. This is for good reason—to ensure that the charging authority is aware of when the building is to commence, because that triggers the payment of the levy. As hon.”
“This approach helps to provide clarity on the CIL liability prior to the commencement of development, and guards against abuse by those who might seek to game the system or by those who are not genuine applicants—in this case, self-builders and residential developers. Turning to the matter at hand, however, the Government have become increasingly aware that, in some cases, that balance has not always been achieved in practice. Therefore, it is right that we pause, reflect and consider whether regulatory changes are needed. To obtain an exemption, a householder must first assume liability for CIL. The next stage is to formally apply to the CIL-charging authority for an exemption. Both processes require the submission of forms prescribed by the Secretary of State that are available on the planning portal.”
“That is to ensure that both the householder and the local authority are clear about any CIL liability or exemption granted before commencement of the build. That is necessary because, once commencement of development occurs, the levy becomes payable in accordance with the levy payment requirements. The CIL regulations were designed to provide transparency, certainty and consistency for local planning authorities and developers. The procedural requirements are intended to secure those aims. As is typical for levy or tax regimes, they require that any exemption from payment is claimed through a formal application in good time.”
“Further to that, development of less than 100 square metres will not be liable for CIL unless the development consists of one or more dwelling. Other types of development can also be subject to a specified exemption or relief from CIL. That includes social housing and charitable development. The CIL regulations were amended in 2014 under the coalition Government to introduce express exemptions for individuals who build their own homes, undertake extensions of more than 100 square metres to their existing homes, or construct a residential annexe within the grounds of their homes. To secure those exemptions, the regulations made in 2014 require that applicants must apply to the relevant CIL charging authority and receive confirmation that the exemption has been granted before development commences.”
“After the grant of planning permission, the CIL charging authority, more often than not the local planning authority, must issue a CIL liability notice as soon as practical, which sets out the CIL liability for the proposed development. A developer must normally pay the CIL liability within 60 days of commencement of development or within the terms of the charging authority’s published instalments policy. Charging authorities set their own levy rates, which undergo public consultation and independent examination. The levy rates are set out in charging schedules, which are published on the relevant authority’s website. Authorities can specify some types of development as being subject to a zero levy rate.”
“Before charging CIL, a local planning authority must consult on a draft charging schedule, which sets out the authority’s proposed local set levy rates. In answer to the point made by the Liberal Democrat spokesperson, the hon. Member for Taunton and Wellington (Gideon Amos), we expect that to take into account issues such as viability. The charging schedule must then undergo independent examination in public. It must be formally adopted by the local authority and published on its website. In addition to the procedures that must be followed before an authority can charge CIL, the legislation sets out what steps must be taken to collect CIL payments.”
“That includes transport schemes, education and health and social care facilities, blue light infrastructure, flood defences, green spaces and other leisure facilities. More than half of local planning authorities in England charge CIL, and the Government are committed to strengthening further and improving the system. It supports development by funding the provision, improvement, replacement, operation or maintenance of infrastructure, which brings significant benefits for local communities. Turning to the legislative context, CIL is intended to be a clear and transparent system providing certainty to developers about what kinds of development are liable to pay the rates that will apply and when payment is due.”
“The Government none the less expect, as I have reiterated on numerous occasions, charging authorities to consider each case very carefully and in accordance with their legal obligations. Hon. Members will forgive me if I provide a brief overview of the CIL system, but I think it is important in the context of the debate. The CIL legislative framework was introduced through the Planning Act 2008 and subsequent regulations were made under those powers in 2010. It is a local charge that local planning authorities can levy on new development in their area to help fund the infrastructure needed to support development of their area. CIL receipts can be used to fund a wide range of infrastructure across the charging authority’s area.”
“I am pleased to have the opportunity to set out the Government’s proposed intentions in relation to it. As the right hon. Member for Godalming and Ash was able to secure a 90-minute debate, I have the time I need to address all his points. Hon. Members will appreciate that it would not be appropriate for me to comment on specific cases, nor on the approach taken by individual local planning authorities to those cases and the particular facts and circumstances that applied. I appreciate that that is somewhat frustrating, but I am afraid that it is the Government’s position. It remains the case that local planning authorities are ultimately responsible and accountable for their own decisions on charging and enforcement of CIL.”
“At the outset, as the shadow Minister just mentioned, I want to stress that the Government appreciate fully that noncompliance with procedural requirements relating to exemptions for household applications under the Community Infrastructure Levy Regulations 2010 have had financial consequences for some owners. In a number of cases, those financial consequences have been extremely severe. The Government recognise and take extremely seriously the concerns that have been raised about CIL liabilities applying to householder and self-build developments. We have been giving very serious consideration to the issue over many months. I have welcomed the engagement I have had with the right hon. Member for Godalming and Ash and the hon. Member for Farnham and Bordon.”
“It is a pleasure to serve with you in the Chair, Mr Turner. I warmly congratulate the right hon. Member for Godalming and Ash (Sir Jeremy Hunt) on securing this important debate, and I commend him on his thoughtful opening remarks and the determination with which he sought redress for about 50 families in his own constituency and families affected across the rest of the country. I thank the hon. Member for Farnham and Bordon (Gregory Stafford) for his well-argued contribution and the shadow Minister, the hon. Member for Orpington (Gareth Bacon), for his remarks. I am also grateful to the CIL Injustice Group for helping to ensure this issue gets the national recognition it deserves and bringing the cases in question to our attention.”
“I encourage residents and site owners across the country to engage with that call for evidence before it closes on 29 May. I encourage all hon. Members here to tell their constituents about it so that we can get the maximum amount of evidence submitted. Then we can properly consider what, if any, changes are needed to the payment of a commission, what the options are and how they would impact on the sector.”
“There is a reason the Government published a call for evidence on 5 March this year concerning the rationale for the commission payment. Through that call for evidence, we are seeking to understand the following: the reasons for charging a commission before it became a statutory requirement in 1975, and whether those reasons have changed; what goods and services are paid for by the commission; how the commission rate is calculated to be a percentage of the future sale price of a park home; how the commission payment relates to other charges in the sector; and how receiving commission in the future enables site owners to meet their obligations effectively and efficiently. To date, we have had 400 responses from park home residents.”
“I fully understand hon. Members’ desire to secure change in this matter, and I assure those present that I share their impatience. Unfortunately—this is where I have to take issue slightly with the hon. Member for North Shropshire (Helen Morgan)—research undertaken by the previous Government was not conclusive on either the purpose of the commission or the impact of its removal or reduction. The final report, published in 2022, recommended further work to clarify the rationale of the commission so that the Government can make informed policy choices. In 2023, the then Government sought feedback from stakeholder representative bodies on the report’s recommendations. The feedback reinforced the view that there was no clarity or consensus in the sector on the rationale for the commission. We are not consulting for consultation’s sake.”
“They can then consider escalating the matter to the Local Government and Social Care Ombudsman if their local authority does not deal effectively with their complaint. Turning to the commission payment, the 10% commission fee charged on the sale of park homes has been the subject of intense debate over many years, as we all know. Park home residents see it as an unfair and unjustified charge that has a negative impact on their finances and mobility. Site operators argue that the commission is a vital part of their income and that a substantial reduction in the commission rate would reduce total income without reducing expenditure, thus threatening the financial viability of parks. That important point was raised by the right hon. Member for Herne Bay and Sandwich (Sir Roger Gale); there are many elements of this complex problem.”
“At this point, I want to acknowledge the commendable work done by individual local authorities over the years, as well as the notable successes some have had in ensuring that sites are well maintained and in successfully prosecuting non-compliant site owners. However, my Department is aware that some local authorities do not apply or enforce existing legislation as effectively as they could and should. There are a variety of reasons for that, including cost and, on occasion, lack of expertise, but in some cases local authorities might simply decide not to take appropriate enforcement action. I therefore encourage residents who have concerns about health and safety on their site to raise them initially with the local authority if the site owner fails to address the problem.”
“It also provided local authorities with powers to charge annual fees, to provide the resources they need to carry out their functions. Since 2021, there have been additional requirements for all site owners to be assessed by the local authority and placed on a local register of fit and proper persons. I commend Peter Aldous, a very valued former Member of this House, for the private Member’s Bill he took forward on that issue. A person can be included on the register, with or without conditions, for up to five years, and local authorities can charge fees to cover their functions in respect of the fit and proper person test. Taken together, those measures provide a robust range of powers for local authorities to draw on, and the Government expect them to be used effectively to ensure that sites are well managed by competent persons.”
“Unless a given site is exempt from having one, it will require a licence after planning permission has been granted, with relevant conditions attached by the local authority. The requirement for a licence is designed to ensure that sites and the amenities on them are properly maintained and kept safe for residents and other users. The wide-ranging Mobile Homes Act 2013, introduced changes to the procedures and penalties for enforcement of site licence conditions on residential parks. The new site licensing system, subsequently brought into force in 2014, gave local authorities substantial enforcement powers, including the ability to issue compliance notices and the discretion to refuse to grant or transfer applications.”
“Unfortunately, as the debate has powerfully reinforced, the experience of many park home owners is far removed from that idyllic vision. I am unlikely to be able to cover all the points raised in this wide-ranging debate in the time available, but let me ensure that I at least cover the two main issues raised: site licensing and enforcement, and the commission payment. On licensing and enforcement, the Caravan Sites and Control of Development Act 1960 provides the foundational legislative underpinning for the site licensing regime operated by local authorities. The primary purpose of that regime is to ensure that sites are set up in the right places, which is why site owners are required to obtain planning permission to operate land as a caravan site.”