Analysis of responses to consultation on mobile home sites regulations

Responses received to the proposals for regulations supporting the new licensing system for mobile home sites with permanent residents.

Caravan dimensions

The final consultation question did not address the new licensing regime but concerned possible changes to the maximum permitted caravan dimensions. The Caravan Sites Act 1968 sets out the maximum permitted size of a caravan in Scotland (in legal terms, a mobile home is a caravan). The Scottish Government considers that, given the changes in the use of mobile homes over the past decades including people now living in them as permanent homes, the maximum permitted size of a caravan should be larger. The proposed change would increase the maximum permitted size of a caravan by around 10% and would bring the maximum caravan dimensions in Scotland in line with those that apply in England and in Wales.

Question 11: Do you support the proposed increase to the maximum permitted dimensions?

Question 11 asked respondents if they supported the proposed increase to the maximum permitted dimensions. Responses by respondent type are set out in Table 14 below.

Table 14: Question 11 - responses by respondent type

Type of respondent Yes No Don't know Total
Community or residents' group 4 1 5
Housing Association 1 1
Local Government 6 1 1 8
Private sector organisation or trade body 3 3
Total Organisations (14) (1) (2) (17)
Individuals 10 1 1 12
Total 24 2 3 29

The majority of respondents (24 out of the 29 who answered this question) supported the proposed increase. One local government respondent and one individual respondent disagreed and three respondents (a community or residents' group, a local government respondent and an individual) did not know.

Eighteen respondents made a further comment. Those supporting the proposal pointed most frequently to the advantages of harmonising the approach in Scotland with that in England and Wales. The specific benefits identified were making a greater range of park homes available to purchasers, allowing manufacturers to standardise their product range, and recognising that people have increasing expectations around quality and space standards. The potential benefits of an increase in the dimension of mobile homes allowing for improved insulation was also raised. It was noted that, under current arrangements, the cladding of mobile homes can increase their size such that they breach site licence conditions. One local government respondent suggested that any changes should not permit increased internal space without improvement in thermal efficiency.

Those supporting the change were amongst those noting the importance of ensuring that pitch size regulations and requirements around the space between mobile homes are still respected. A local government respondent who answered 'Don't know' at Question 11 was concerned primarily about the particular challenges associated with maintaining these minimum distances between mobile homes. They suggested that existing sites could require significant infrastructure works and that a range of fire safety and amenity issues would need to be taken into account. They went on to suggest that clear and concise guidance on how councils should deal with the introduction of larger vans to existing sites would be required. Another local government respondent (who supported the proposal) also raised the issue of fire safety. Their primary concern was that the fire safety regime is not aligned with the licensing regime, with fire separation distances now the responsibility of the Scottish Fire and Rescue Service. They called for the two regimes to be aligned.

Other issues raised (by respondents who had disagreed at Question 11) were:

  • The proposal should reference equivalent area to allow for shorter or wider mobile homes.
  • The entrances to some sites would make delivery of larger vans impossible.
  • Finally, a housing association respondent noted that as a provider of a Travelling Persons Site they are required to meet site licence requirements while a local authority provider is not. They suggested that this lack of parity should be given further consideration.


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