Caravan Sites

– in the House of Commons at 12:00 am on 8th August 1966.

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3.29 a.m.

Photo of Mr Eric Lubbock Mr Eric Lubbock , Orpington

I do not apologise for detaining the House at half past three in the morning because the problem I wish to raise is the extremely important one of the conditions of residential caravan sites. I have been waiting for a suitable opportunity to draw attention once again to this subject.

It is nice to see the Joint Parliamentary Secretary in his place. It is rather like old times—like our deliberations on the Rent Bill and, before that, the Protection from Eviction Bill. On those occasions we had a number of opportunities to argue about what should be done in connection with residential caravan sites. I hope that some progress has been made since we last discussed the matter in public. I have had a number of opportunities to discuss the subject with the hon. Gentleman in private and I hope that, as a result of those discussions, he will say that progress has been made towards solving this problem.

The problem is one of increasing importance because the number of people living in residential caravans is growing rapidly. That is obvious from the figures.

If we take the period of the last 15 years, we find that from the census of 1951 to the census of 1961 the number of residential caravans increased from 30,000 to 75,000, and that at the date of the 1961 census there were about 184,000 persons living permanently in caravans. Recent estimates suggest a further growth, and the National Caravan Council estimates from production figures that there may today be around 100,000 residential caravans, in which some 300,000 people are living.

My first point, and the Joint Parliamentary Secretary will know that I have made it in correspondence with the Minister, is that the Government cannot just ignore the contribution that is being made, and which will continue to be made in future by the mobile home for the satisfaction of the country's housing needs. I make it absolutely clear that by "mobile homes" I do not mean "mobile homes" in the old L.C.C. terminology but as they are called in the trade, which means a caravan of at least 250 sq. ft. of floor area, and which also conforms to British Standard 3632 of 1963.

To the extent that local authorities are prepared to grant licences for residential caravan sites, the number of people who need accommodation in permanent houses will be reduced. I believe, therefore, and I have told the Minister this, that the Government should take steps to obtain periodic reports from local authorities showing the number of residential pitches licensed, and the number occupied, so that the information could be included in the national housing statistics.

When I put that idea to the Minister last autumn, suggesting that an appropriate medium for publication of the figures would be the quarterly Housing Returns, he replied that the return is basically … a record of the number of permanent dwellings provided or, in the case of slum clearance, demolished and replaced. The Minister sees the information as providing an index of the Government's performance and that of the housing authorities.

For this reason, additional details are given in the quarterly Returns as, for example, of the number of temporary houses still in use, and the number of people living in camps. The Minister stresses that a comprehensive housing picture could not be presented in the quarterly Housing Returns because it would be far too big a job to be undertaken quarterly. He also pointed out to me that further information about the present size of the caravan population would be obtained in the same census that was begun, I believe, last April.

I entirely accept that the quarterly housing figures cannot be complete, and also that they should be regarded as a measure of the total achievement of Government and local authorities together against a target that has been set in advance, but I should have thought that in that case the number of mobile homes is a more important indicator than some other figures given; as, for example, the number of pre-fabs., which must be at least as much trouble to collect. It would be quite simple for local authorities to require site operators who have received licences from them to submit returns showing the number of pitches occupied at the end of the quarter as a condition of the award of a site licence.

Even in the absence of reliable figures, we can say that residential caravanning is increasing to an extent at which it must be taken into account by the Government in their long-term planning, and also that their rather laissez-faire attitude to conditions on the sites must be replaced by a positive concern for the welfare of people who have chosen this way of life. So far, I have found the Minister long on sympathy and short on constructive proposals. He and the Joint Parliamentary Secretary always appreciate problems which we put to them, but they have always found some objection to every suggestion I have made so far about how these problems might be solved.

In particular the Parliamentary Secretary does not think that local authorities need to be reminded of their powers under the Caravan Sites and Control of Development Act, 1960, to require operators to improve their sites and to install basic amenities. While it is no doubt true that since the 1960 Act there has been a substantial and marked improvement in average standards and the best sites provide a living environment which would be the envy of many people living in permanent houses, there is still a very large number of sites which do not measure up to the Ministry's model standards. Local authorities vary widely in the amount of effort they make to enforce standards and raise them to the model provided by the Government.

According to a recent survey carried out by Social Survey Gallup Polls Ltd. for the Consumer Council, no fewer than one in three of the people who live in caravans think they have cause for complaint about the facilities provided. I have had many letters from all parts of the country drawing attention to conditions on particular sites. In some cases I have written to the Minister drawing his attention to the allegations made and I believe that the Consumer Council has sent him a long list of complaints made as a result of the survey which it undertook.

I do not think there is much point in giving a long list of further examples, but so that the House may see that some of these sites are as bad as any urban slum, I will quote a description of one site given in an article by Mr. William Rankine in the News of the World on 5th June. This site is the Mytchett Farm Caravan Site near Camberley, Surrey. The article said: On the credit side you could say the residents have fresh running water—if they care to trek from their vans along unmade roads and across mud to communal water taps scattered about the grounds.But that's about the extent of amenities on this site, where 70 or 80 families live and pay £1 a week to park their own vans.The site has been used for more than 10 years—plenty of time, you might think, for improvements to be made. But modern amenities are totally lacking. There is no electricity supply.The vans are lit by Calor gas or oil lamps. And though in wet weather the grounds are like an Army assualt course, there is no lighting.There are no lavatories, no baths, no showers, no laundry facilities, no effective sewerage or drainage, no concrete bases for the vans. That site is not by any means unique, so I think that a case can be made for the Minister to draw the attention of local authorities to their powers under the Act to increase standards. I ask him to think about that again.

There are probably many more unlicensed sites than we imagine. Mr. Rankine drew attention to these in his article. Local authorities may not wish to require unlicensed operators to improve standards, because by so doing they would countenance those operators. If the Parliamentary Secretary has read the series of articles by Mr. Rankine, he may have noticed what was said about unlicensed sites at Beoley Mill, in the Red-ditch area. Mr. Rankine says that those vans have been on the site for two years. One would like to know why no action was taken against them in view of the fact that the water supply had been condemned by the local authorities.

This illustrates that perhaps the powers of local authorities to take action against unauthorised sites are not as strong as one would like them to be. If we are to raise standards it must be a two-edged approach—one, to persuade local authorities to use powers for the licensed sites and, two, to make sure that they have powers to eliminate sites which do not have a licence. In almost every case I know of sites without proper amenities they are not operated by members of the National Caravan Council or the National Federation of Site Operators. Where they are, one finds that probably they have only recently been taken over by a member of one of these organisations and that improvements are scheduled by the member. Both these bodies are determined to raise the standards and eliminate these squalid rural slums that still exist, though I believe that they are far too optimistic about the prospects of achieving this on a voluntary basis.

In the same way, the National Caravan Council and the National Federation of Site Operators have been trying to secure the acceptance on a voluntary basis of a code of conduct to govern the relationship between the site operator and the caravan resident. They believe that there should be written agreements between the parties and they have drafted a model form of agreement which they recommend should be used by their members.

The House may be surprised to learn that, according to the Consumer Council survey which I mentioned earlier, 55 per cent. of caravan residents have no written agreement whatsoever, and here is another example of the inferior position of caravan dwellers as compared with the tenants of rented properties who have to be provided, by law, with the terms of their tenancy in a rent book.

The site operators organisations also recommend that nobody should be evicted provided he pays his rent and observes the conditions of his licence, and they say that, if it does become necessary to evict, the site operator should give not less than 28 days' notice. They also say that no premium should be charged for entry on to the site by a new resident because of the scarcity value of the pitch.

These are wholly desirable objectives which should be given every possible encouragement by the Government. Some of us believe that we should go even further than these organisations in protecting the licensee, but under the law as it now stands he is without any protection whatsoever, other than what the site operator is prepared to give him voluntarily.

It is not as uncommon as the trade associations believe, I think, for caravan residents to be evicted arbitrarily by the more disreputable site operators. Just as with the Milner Holland findings on private rented property, here in the case of caravan dwellers we find that the fear of arbitrary eviction is just as important as the actual happening itself.

One finds in correspondence with caravan dwellers that they are prepared to accept the most appalling conditions without complaining in public, simply because of this fear of eviction. I can show the Minister many letters I have received from caravan residents which end by imploring me not to quote their names in public in case the site operator took reprisals against them.

It is even more usual for large premiums to be demanded for entry on to a site, which families desperate for accommodation will be prepared to pay, while at the same time the operator may be pocketing a commission from the firm which has sold the caravan to the resident coming on to the site. But when the same family is forced to leave, not an penny is normally returned to them.

Let me give an example from my own constituency—and the Minister knows of this one because I have written to him about it before. The Restavon caravan site at Berry's Green is operated by a Mr. Jack Stevens of the Slough Caravan Centre and this gentleman has been charging £150 key money for a caravan coming on to the site. The Minister has told me that nothing can be done to counter this activity by Mr. Stevens. But I should like to mention another matter. Mr. Stevens is charging 4d. a unit for electricity despite the fact that since 1st July, 1965, the maximum price at which electricity may be resold is supposed to be l·95d. The site operator in this case is extorting from his victims more than twice the maximum permitted charge for electricity. In the Consumer Council survey we have evidence to show that overcharging at over three times the maximum permitted resale price is not unknown.

At one time when I made these complaints, the Ministry of Power asked me to send evidence, but I stopped doing that because there is no point in it with regard to caravan residents. There is nothing to prevent the site operator from increasing the plot charges that he makes to his residents to recoup himself for any refunds that he has to make on the electricity charges. Thus, when the Resale of Electricity Order came into operation last July, many operators who observed it not only increased their charges to cover the loss of money on electricity but at the same time, added a bit of extra profit for themselves. Again, I have sent the Joint Parliamentary Secretary examples of this.

Yet another excuse which is frequently used for raising plot charges is that the rates levied on the site as a whole have been increased. In this case, the resident has no means of knowing whether he is merely being asked to pay the actual amount of the increase in rates or whether the site operator's profit has been put up as well.

I believe, therefore, that the decision of the Court of Appeal earlier this year that a caravan is a hereditament which can be assessed separately for rates will be to the long-term advantage of the caravan population. It will mean that the caravanner knows exactly how much he should pay as an increase when the rates are increased by the local authority. It will also particularly benefit the less-well-off caravanner, who will now, for the first time, be able to apply for a rate rebate under the legislation recently passed by the House.

The Joint Parliamentary Secretary wrote to me about this matter on 18th May and said that it would be up to the valuation officers of the Inland Revenue rather than the rating authorities to make the running on individual rating of caravans. Whilst I appreciate that, I think that his right hon. Friend the Minister has some responsibility, because it would be quite unfair if valuation officers in one part of the country were to rate caravans individually whilst in another area they were still on site lists and, therefore, certain caravan residents were not able to obtain the advantage of the rate rebates, which I want to see extended as rapidly as possible to the caravan population as a whole.

There is one further question of great importance to which I would like a reply tonight. I have shown that the caravan resident has no protection against the imposition of higher rents whether or not they are justified by increases in cost. I should like to know from the Joint Parliamentary Secretary whether the prices and incomes standstill will apply to the plot rents. It would be most unfair if the Government's policy of a rent standstill did not apply to the 300,000 peope who live in caravans when council house tenants have their rent standstill and people who live in private rented accommodation have the protection of the Rent Acts.

The hon. Gentleman may remember that in Standing Committee on the Rent Bill in June last year, he told me that the more I kicked him in the pants about this problem the better he felt, because it kept him alive to the importance of it. Since then, as he knows, I have on a number of occasions sought with him to find solutions that both of us could accept without the use of physical violence. In the meanwhile, a great deal of additional evidence has been published, in particular the survey by the Consumer Council which I mentioned. Tonight I have reminded the hon. Gentleman of the many facets of this question to which answers are still awaited by 300,000 people.

Photo of Mr James MacColl Mr James MacColl , Widnes

The hon. Gentleman is not quite accurate in saying that the survey has been published.

Photo of Mr Eric Lubbock Mr Eric Lubbock , Orpington

I am sorry. In Focus the Consumer Council gave a fairly full summary of the evidence which it has obtained in the survey.

I was saying that I hoped that the hon. Gentleman would be able to answer some of the questions that we have been discussing during the past year since the Rent Act, when I first began to raise the important problems of caravanners. I hope that this morning he will at least be able to give me some encouragement to continue to seek a fair and equitable deal for the caravan residents of Britain.

3.50 a.m.

Photo of Mr Albert Murray Mr Albert Murray , Gravesend

It would be helpful to hon. Members if the Minister could answer not only some of the questions put by the hon. Member for Orpington (Mr. Lubbock) but some of those that I shall put to him.

Since the war, residential caravanning has grown enormously in this country. At one time, many of us thought only of gypsies when we thought of caravans, but this way of living is growing year by year, and caravans are not being filled just by people who cannot find anywhere else to live—although there are a great many of those—but are now being used by people who prefer to live in them.

There are two very large caravan sites in my constituency, one with over 360 caravans and the other with about 280. On my visits to these sites I find a growing number of people who have moved from their own houses because they prefer to live in a caravan. The cost of these caravans can be anything up to £1,800.

Those who spend their lives in caravans have not the same protection as those living in rented accommodation. We are not certain, even now, how many people are resident in caravans on caravan sites. These people are an underprivileged group. They have not the protection of the Rent Act; they have not the possibility at present, it seems, of obtaining rate rebates; and they have not the facility of a person who lives in rented accommodation to be able to claim without fear that he is being overcharged for electricity.

The hon. Member for Orpington said that some of his constituents were being charged 4d. per unit. During my dealings with caravan operators, some of my constituents raised the point that they were being charged 7½d. per unit. After long negotiations with the operators, I got the price down to the maximum resale price of l·95d. per unit. Just after this, the residents of the caravan site received a letter pointing out that there had been changes in the prices that could be charged—it did not say that that there had been over-charging—and after the prices were regularised the tenants found that their rents had been increased. This is the difficulty that these people face.

If the site operator had decided that he would not lower the price of 7½d. per unit, what would have been the position of the tenants? They could have brought a civil action in the courts. But, because they do not have the protection which tenants in houses have against eviction, they cannot do that. Nobody else can take action on their behalf. I have had talks with the Minister about this problem, and I have sheaves of letters from the Ministry of Power about it.

I was told by the site operator with whom I took the matter up, We have checked with the National Caravan Federation and find that our new charges are still well below any other site in the country, few of whom appeared to consider the Board's circular to apply to them in any case". Thus, the law is being flouted by site operators, but the tenants fear to take action because they know that there is the chance of being evicted. Even if they did take action and were successful, they would then find the counterbalance going up the other way, with an increase in rents.

The situation is much the same when there is a rating revaluation. The tenants have a bulk charge, as it were, passed on. Their rents are just "upped" by 2s. or 2s. 6d. without regard to the size of their caravans or their particular circumstances.

Often, there is a "tied" grocer on a site. I take this information mainly from the Consumer Council, though I have had correspondence about it. Only a certain grocer, baker or milkman is allowed on a site because some consideration has passed between the site operator and the trader, and the arrangement is that he will have a monopoly.

Like the hon. Member for Orpington, I have had people writing to me about their problems and then saying, "Please do not mention my name in any letters you write because I am afraid it may mean our being removed from the site".

The position is serious. I want the Minister to give careful attention to it, and, perhaps, make representations to his right hon. Friend the Chancellor of the Exchequer about the recent changes in hire-purchase regulations. I hope that residential caravans which are not towable but have to be moved by lorry will not be affected by the changed requirements for hire-purchase repayments.

The people who live on residential caravan sites are under-privileged. They are expected to pay their taxes. As politicians, we ask them to play their democratic part in our society. This House of Commons should ensure that they have the benefits of that society.

4.0 p.m.

Photo of Mr John Pardoe Mr John Pardoe , North Cornwall

Mr. John Pardoe (Cornwall, North) rose——

Photo of Dr Horace King Dr Horace King , Southampton, Itchen

Is the hon. Member for Cornwall, North (Mr. Pardoe) seeking to speak on this topic?

Photo of Mr John Pardoe Mr John Pardoe , North Cornwall

Yes, Mr. Speaker. I will be very brief. There are one or two questions which I want to raise on the subject as it relates to Cornwall and the coastal strips.

It seems to me that there is a need for further regulations governing the use of caravans, and they should be threefold: first, to protect the residential tenant so far as rent, security of tenure and conditions generally are concerned; secondly, to offer the touring caravanner proper facilities; and, thirdly, to preserve certain aesthetic standards of the English countryside.

When one tries to get to the root of the regulations governing the rights of caravan dwellers, one comes up against a blank wall. There do not seem to be very many regulations. Caravan dwellers are relatively unprotected, and my questions arise out of a desire to inform them of their rights and the sheer inability which I have found to find out what they are.

The Caravan Sites and Control of Development Act, 1960, gives local authorities certain powers. However, I think that it gives them the wrong ones. For example, in paragraph 3 of the First Schedule, owners of land of five acres or more are allowed to have three vans on their land for not more than 28 days in any one year", which need not be consecutive. It is quite impossible for any local authority, whatever degree of supervision it exercises, to count up the 28 days in any one year and exactly the number of three vans, and ensure that the law is observed. Indeed, it does not appear to matter very much if it is not. It seems strange that we should pass an Act with that kind of ruling in it which cannot be put into practice.

Local authorities have the right to enter caravan sites and order all sorts of things. A recent example of the exercise of the power was where a local authority moved into a quiet caravan site and demanded that all the tenants should remove the little wattle fences which they had put round their gardens. As they were only about 18 inches high and quite inoffensive, I think that this kind of power is not the sort of thing that is needed.

However, when one wants to establish what the rents of caravan sites are, one finds oneself up against an entirely different problem. Recently I wrote to a local authority asking for advice on the matter, and its clerk was unable to give me any information. He said he had made inquiries about rents and had found that owners and owners' solicitors took the attitude that it had nothing to do with the council and withheld the information.

One example of the rent problem which has come to my notice recently is where, on one caravan site, the rent for the actual block of concrete on which a van stands has increased since 1962 from 18s. to 36s. a week. Certain improvements have been made to the site, the park and the facilities offered, but that represents a 100 per cent. increase in four years. It has come about by four separate increases, and the tenants have not been given adequate reasons for them. There seems to be a strong case for the protection of the tenant so that he knows why his rent is being increased and to whom he can appeal. At the moment, there is no one to whom he can appeal.

After all, there is a shortage of caravan sites. It has been created by Government action, by the planning authorities and by the sheer necessity to get planning permission. As in all forms of rationing, it seems to me that it is important for the Government to exercise price control.

There is also the problem of evictions from sites. This is something which has been mentioned, and one particular case which I have come across several times is where a local authority exercises power to close down a site because it does not have the right permission or is overcrowded or has not the right facilities.

When the local authority exercises its right to close down a site or reduce the number of caravans on it, the tenants, who have had no idea that there was infringement of the regulations and had been paying their rent, get no form of compensation from the owners. If owners have been infringing the regulations and thereby inconvenience tenants by having to throw them out on the instructions of the local authority, the tenants should a least be able to get them to pay the cost of removals—always providing that they can find another site to move to.

On the whole, the conditions of various caravan sites, certainly in Cornwall, are well supervised and the tourist is well catered for. He can expect in Cornwall model standards rigidly enforced by the local authorities. As for aesthetic standards, we do not want the Cornish coast to become the coastal slum that some parts of the South of England have become.

One of the problems is that of user rights, whereby there is no kind of enforcement over people who have had caravans on a piece of land for a very long time. It might help if the Government looked at this again and considered whether just because someone has had the privilege of having a caravan on their farm for several years they should be able to go on exercising the right without any appeal by the local authority.

I hope the Minister will pay some attention to the loopholes in the 1960 Act, some of which he has received representations about from the Rural District Councils Association and the County Councils Association recently. The best supervision tenants could have is to be made fully aware of their rights and I hope that from this debate, which has been useful for what has been called an under-privileged section of the community, we shall have a reply which will give us the conditions we can stand by in giving these people a better deal.

4.4 a.m.

Photo of Mr James MacColl Mr James MacColl , Widnes

If one could at any time be pleased to be talking on any subject at this hour I should be pleased to be talking to the hon. Member for Orpington (Mr. Lubbock) about caravans, about which he has been quite right in assiduously pressing for action. I cannot do much more than touch on some of the points he raised and give him some idea of what my right hon. Friend's views are.

The basic problem is of the attitude one takes about caravans as a way of life. Are they to be a permanent contribution or are they only a temporary substitute for housing which is likely to disappear when the housing shortage disappears? According to the report the hon. Gentleman quoted, 36 per cent. of the people interviewed—a little over one-third—said they liked life in caravans while 58 per cent.—slightly over half—among the older people were quite content to be in caravans.

This is one of the difficult things to discover, yet it governs both the selection of sites and the length of permission given for them. If the planning authority gives, as it is entitled to do, a short permission because it regards sites as temporary, it prevents the site owner from spending a lot of money on it and by creating insecurity allows it to deteriorate in quality.

My right hon. Friend has been encouraging planning authorities, where sites are reasonably good from the point of view of amenity and convenience, rather than play a cat-and-mouse game by granting temporary permissions one after the other, to grant permission for long periods, or for ever.

There are provisions in the planning laws for planning authorities to stop bad sites being used, even though there are user rights, but this means compensation, which can often be very heavy.

The hon. Member for Orpington said that since the 1960 Act was passed there had been a substantial and marked improvement in conditions. It is only fair to say that neither myself nor his hon. Friend the Member for Cornwall, North (Mr. Pardoe) are responsible for the weaknesses of that Act. It does need tightening up and I hope that we can do this, but I should not like to begin legislation to this end until we have solved the problem of security of tenure, which is so closely linked with this problem of standards.

The hon. Member for Orpington quoted the model form of agreement and said that over half the people had no written agreement. I do not know how far occupiers of caravan sites want written agreements. It does not necessarily follow that the reason that they do not have any is the fault only of the site operator. It may be that they prefer not to commit themselves because an agreement is binding both ways. They may not wish to be bound, because they are liable to have to move quickly, or for some other reason.

If the Caravan Council could improve its present model agreement—which is not bad but which could be improved—and make it a basis of good practice, recognised by all the best site operators then it would be easier to use legislation to enforce it. The hon. Gentleman also referred to the profit on things such as the sale of caravans, shops, etc. Here there is the dilemma that, if one is to spend money on equipping a site, improving amenities and so on, and if the licensing authority is to be tough in enforcing licensing conditions, it has to get the money back to pay for such things. That means that the charges for the site go up and complaints are then made that they are exorbitant.

That is one of the reasons for the failure of full licensing control to bite. Local authorities are a little nervous about creating a situation in which charges will go up steeply. There is the further difficulty that if the site operator packs up and says that he cannot work under such conditions one loses the site and people become homeless.

The hon. Member asked about rates, and the position here is—and I agree with him that caravans should be treated as separate hereditaments—that not only will caravans get rate rebate, but they will also qualify for the domestic element; that is, that part of the new local government grant which goes to domestic ratepayers. We have been arguing about that upstairs, and no doubt we shall argue more about it on the Floor of the House. The hon. Member quoted some cases of complaint, and said that the Government should do more.

Photo of Mr Eric Lubbock Mr Eric Lubbock , Orpington

Before the hon. Gentleman leaves the question of rates, would he say why, if the Inland Revenue in some areas can work faster and get the caravans on to the lists and the people in those areas will be able to claim rate rebates, something cannot be done for those areas where the rating officers work more slowly?

Photo of Mr James MacColl Mr James MacColl , Widnes

There are powers available, but one has to recognise that one of the problems is the shortage of valuers. That was one reason why we had to postpone revaluation. That caravans are hereditaments was a decision of the courts. I am not sure that we are out of time, but it was a recent decision, and it is surely a little early to say that there will be anomalies. However, that is something which we shall watch.

The hon. Gentleman also spoke about the licensing conditions and I agree that in some cases the licensing authorities may have been slack, but, in some cases, they have been in a dilemma. We must remember that we are not dealing with a fixed position. There are often long periods of arguing and bargaining. I knew of a case where the access road was appalling, but ownership was eventually established, and the road was improved and the people on the site expressed themselves as satisfied. The majority thought that the lavatory arrangements were satisfactory or very satisfactory, and 66 per cent. said that they had no complaints and, of those with complaints, 10 per cent said that they did not complain through fear of eviction.

There is then the question of security of tenure. This recalls a site at Waltham Abbey, where the owner said that he did not think that there should be security of tenure because caravan life had an intimacy about it so that a bad tenant could cause a lot of trouble. That might be an argument for saying that one should not use the machinery of the Rent Act. Perhaps more suitable would be machinery similar to that given for furnished accommodation which allows for the provision of services as well as the accommodation.

I am looking forward to the publication of the survey in full. It has not yet been published in full but, when it is, it will make a very useful contribution to getting some sort of idea of the kind of thing we could put into legislation. We cannot at present promise any specific date because of the state of the legislative programme, but we are anxious to do something. We are giving a good deal of thought about how best to tackle this.

The hon. Gentleman also asked if the prices and incomes policy would apply to pitch fees. Inasmuch as the charges are for services or for rent of land I would have thought that they came within Part IV of the Bill.

I thank my hon. Friend and the hon. Member for the points they have raised. The detailed cases they quoted I will consider, and if I have any further information to give them I will write to them in detail about those cases.