PP 2014/0132

REPORT OF THE SELECT COMMITTEE ON TOWED CARAVANS

2014-15

REPORT OF THE SELECT COMMITTEE ON TOWED CARAVANS

On 17th June 2014 it was resolved –

That a Committee of three Members be appointed with powers to take written and oral evidence pursuant to sections 3 and 4 of the Proceedings Act 1876, as amended, to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park and the need for regulating the entry on to the island and usage of caravans.

The powers, privileges and immunities relating to the work of a committee of Tynwald are those conferred by sections 3 and 4 of the Tynwald Proceedings Act 1876, sections 1 to 4 of the Privileges of Tynwald (Publications) Act 1973 and sections 2 to 4 of the Tynwald Proceedings Act 1984.

Committee Membership

Mr A F Downie MLC (Chair) Mr C G Corkish MLC Mr D J Quirk MHK (Onchan)

Copies of this Report may be obtained from the Tynwald Library, Legislative Buildings, Finch Road, Douglas IM1 3PW (Tel 01624 685520, Fax 01624 685522) or may be consulted at www.tynwald.org.im

All correspondence with regard to this Report should be addressed to the Clerk of Tynwald, Legislative Buildings, Finch Road, Douglas IM1 3PW.

Table of Contents

I. THE COMMITTEE AND THE INVESTIGATION ...... 1

II. INCREASING NUMBERS OF TOWED CARAVANS IN THE ...... 2

III. REGULATING THE ENTRY OF CARAVANS TO THE ISLE OF MAN: THE “GENTLEMEN’S AGREEMENT” ...... 3

IV. POTENTIAL ABUSE OF TOWED CARAVANS WITHIN THE ISLE OF MAN...... 4

ABUSE WHICH IS ALREADY CONTRARY TO LAW 4

ABUSE WHICH IS NOT CURRENTLY CONTRARY TO LAW 5

FEATURES OF A NEW REGULATORY REGIME 6

ISLAND-WIDE CONSISTENCY IN THE LICENSING OF CAMPING SITES 7

V. URGENCY AND TRANSITIONAL ARRANGEMENTS: THE “FLOODGATES” ARGUMENT ...... 8

VI. TOWED CARAVANS AS AN ECONOMIC OPPORTUNITY...... 9

VII. THE WAY FORWARD IN SUMMARY...... 11

VIII. CONSOLIDATED LIST OF CONCLUSIONS AND RECOMMENDATIONS ...... 12

ANNEX 1: PHOTOGRAPHS ...... 15

ANNEX 2: PAPER BY THE TYNWALD CHAMBER AND INFORMATION SERVICE ABOUT OTHER JURISDICTIONS ...... 21

ANNEX 3: PAPER DATED 1ST AUGUST 2014 BY COMMITTEE CLERK ...... 25

ORAL EVIDENCE ...... 29

MONDAY 13TH OCTOBER 2014 EVIDENCE OF MR DAVID CRETNEY MHK AND MS ANGELA BYRNE, DEPARTMENT OF ECONOMIC DEVELOPMENT, AND MS JANE DELLAR AND MS SARA RICHARDS, CHAMBER OF COMMERCE 31

WRITTEN EVIDENCE ...... 55

APPENDIX 1 SUBMISSION DATED 11TH JULY 2014 FROM THE DEPARTMENT OF INFRASTRUCTURE 57

APPENDIX 1A E-MAIL DATED 24TH OCTOBER 2014 FROM THE CHIEF EXECUTIVE, DEPARTMENT OF INFRASTRUCTURE 65

APPENDIX 2 LETTER DATED 8TH OCTOBER 2014 FROM THE DEPARTMENT OF INFRASTRUCTURE 69 APPENDIX 3 SUBMISSION DATED 11TH JULY 2014 FROM THE DEPARTMENT OF ENVIRONMENT, FOOD AND AGRICULTURE 75

APPENDIX 4 SUBMISSION DATED 7TH OCTOBER 2014 FROM THE DEPARTMENT OF ENVIRONMENT, FOOD AND AGRICULTURE 79

APPENDIX 5 SUBMISSION DATED 14TH JULY 2014 FROM THE DEPARTMENT OF ECONOMIC DEVELOPMENT 85

APPENDIX 6 MARKET RESEARCH PAPER SUBMITTED ON 13TH AUGUST 2014 BY THE DEPARTMENT OF ECONOMIC DEVELOPMENT 89

APPENDIX 7 E-MAIL DATED 8TH AUGUST 2014 FROM MR MIKE KELLY, ISLE OF MAN POST OFFICE 103

APPENDIX 8 E-MAIL DATED 8TH AUGUST 2014 FROM MR JIM ROWLES, DIRECTOR OF PLANNING, STATES OF 107

APPENDIX 9 E-MAIL DATED 17TH SEPTEMBER 2014, AND ATTACHMENT, FROM THE CHIEF CONSTABLE 111

APPENDIX 10 PRESENTATION SUBMITTED ON 1ST JULY 2014 BY THE ISLE OF MAN STEAM PACKET COMPANY 117

APPENDIX 11 E-MAIL DATED 10TH JULY 2014 FROM MR MARTIN STRINGER, CARAVAN CLUB OF 145

APPENDIX 12A SUBMISSIONS FROM MEMBERS OF THE PUBLIC IN FAVOUR OF CARAVANS 149

APPENDIX 12B SUBMISSIONS FROM MEMBERS OF THE PUBLIC AGAINST CARAVANS 165

To: The Hon Clare M Christian, , and the Hon Council and Keys in Tynwald assembled

REPORT OF THE SELECT COMMITTEE ON TOWED CARAVANS

I. THE COMMITTEE AND THE INVESTIGATION

1. This Committee was established by the following resolution of Tynwald on 17th June 2014:

That a Committee of three Members be appointed with powers to take written and oral evidence pursuant to sections 3 and 4 of the Tynwald Proceedings Act 1876, as amended, to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park and the need for regulating the entry on to the island and usage of caravans.

2. At the beginning of our investigation we were briefed in private by representatives of the Department of Infrastructure, the Department of Environment, Food and Agriculture, the Department of Economic Development and the Isle of Man Steam Packet Company. The private briefings aided our understanding of the written evidence, which we have published in full.

3. We have also received and published written evidence from the Isle of Man Post Office, the Isle of Man Constabulary and around 100 members of the public who responded to a public call for evidence.

4. We heard oral evidence in public from representatives of the Department of Economic Development and the Isle of Man Chamber of Commerce. The oral evidence is reproduced within this Report.

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II. INCREASING NUMBERS OF TOWED CARAVANS IN THE ISLE OF MAN

5. A number of sites already exist in the Isle of Man where visitors may stay in a towed caravan. The Department of Infrastructure also told us that:

there are:

 11 permanent sites (lawful for all year round – although they may not operate as such);

 11 more that operate only during the TT and GP; and

 a further 3 that are seasonal.

These sites provide for 119 caravan / motorhome pitches, with a further 66 during TT.1

6. However, not all towed caravans are in lawful camping sites. There appears to be an increase in the prevalence of towed caravans in other places around the Island. We have included at Annex 1 a series of photographs taken by Members of the Committee and the public illustrating this.

7. Our observation as to a general increase in numbers are supported by the evidence of the Department of Infrastructure, which shows a dramatic increase in requests for “caravan letters” since 2011, as set out below.2 Virtually every request for a caravan letter is granted.3

Requests for caravan letters (source: Dept of Infrastructure) 250

200

150

100

50

0 2007 2008 2009 2010 2011 2012 2013 Requests for caravan letters 73 55 51 55 92 101 238

1 Appendix 1 2 Figures taken from Appendix 1 3 Appendix 1A 2

We conclude that the number of towed caravans in the Island is increasing. Towed caravans may not amount to a serious problem today. However, as the numbers increase, so do the risks.

III. REGULATING THE ENTRY OF CARAVANS TO THE ISLE OF MAN: THE “GENTLEMEN’S AGREEMENT”

8. There is a widely held belief that caravans are not allowed in the Isle of Man. The prevalence of this belief is clear from the responses to our consultation, the vast majority of which urged us not to remove the controls.4

9. The Department of Economic Development’s website states:

Bringing a caravan to the Isle of Man is controlled by way of an agreement between the Department of Infrastructure and the Isle of Man Steam Packet Company. So, if you’re thinking of bringing your caravan to the Isle of Man, you’ll need to submit a written request to the address below at least two weeks before your visit. This should include details of your proposed date of arrival and departure, the purpose of your visit, and where your caravan is to be sited while on the Island.5

10. The Isle of Man Steam Packet’s website states, similarly:

Please note that written permission is required from the for the Steam Packet to allow Caravans on the island. Bookings may be made but Caravans will only be carried on production of this document.6

11. The Department of Infrastructure told us that the agreement referred to has no basis in legislation,7 although it:

has been effective in limiting the number of caravans and has made a significant contribution to the popular perception that caravans are illegal on the Island.8

12. In its written evidence to this Committee the Isle of Man Steam Packet Company (SPC) stated:

4 Appendix 12B 5 http://www.visitisleofman.com/accommodation/caravans.xml (20th October 2014) 6 http://www.steam-packet.com/Vehicles (20th October 2014) 7 Appendix 1 8 Appendix 2 3

 SPC has no basis on which to refuse to transport a caravan so is acting as an ‘unofficial gatekeeper’

 SPC do not monitor consent received or removal.9

13. In summary: the Department of Economic Development and the Steam Packet Company advise people to obtain permission before bringing their caravans to the Isle of Man; the Department of Infrastructure grants or refuses such permission in accordance with planning law; but there is no evidence that anyone who attempted to bring a caravan to the Island without permission would face any adverse consequence.

We conclude that there is a widely held view that towed caravans are not allowed in the Isle of Man but this is a myth. The “Gentlemen’s Agreement” between the Isle of Man Government and the Isle of Man Steam Packet Company is an anachronism. Under the Agreement, people wishing to bring a towed caravan to the Island are advised that they must seek permission in the form of a “caravan letter”. However, neither the Steam Packet Company nor any Department of Government can actually prevent anyone from bringing a towed caravan to the Island.

The Agreement may in the past have deterred some people from bringing a caravan to the Island. The rising number of “caravan letters” being requested and issued shows that any deterrent effect of the Agreement on caravanners is on the wane.

IV. POTENTIAL ABUSE OF TOWED CARAVANS WITHIN THE ISLE OF MAN

Abuse which is already contrary to law 14. Our public consultation exercise identified a number of concerns held by the general public about the potential impact of towed caravans on Manx life. Many of these concerns are already subject to control under the existing general law. These are:

(i) Manx residents, visitors, or itinerant communities living in caravans in beauty spots or other non-residential areas off the highway contrary to planning and/or public health controls, “putting down roots” and therefore being difficult and/or costly to move on (cost being of particular concern when the landowner is DEFA or another public body);

(ii) holidaymakers living in caravans in unauthorised campsites off the highway (such as beauty spots) contrary to planning and/or public health controls. Even if the individuals do not stay long enough to “put down roots”, planning

9 Appendix 10 4

enforcement action may become more difficult over time as a change of use becomes established;

(iii) visitors and/or Manx residents living in caravans on the highway contrary to planning, public health and highways controls;

(iv) Manx residents keeping a caravan on their driveway and living in it as a substitute for an extension to their house, contravening planning and public health controls and resulting in a “spillover” impact on the highway through them parking their car in the road when they otherwise would not have to;

(v) Manx residents keeping a caravan on the public highway near their home, contrary to local authority bye-laws in Douglas, Braddan and Ramsey but not everywhere;

(vi) caravans abandoned on the highway, contrary to highways controls.

We conclude that many forms of potential towed caravan abuse are already contrary to existing planning, public health and highways controls.

Abuse which is not currently contrary to law 15. There remain certain forms of potential caravan abuse against which, if they became prevalent, the Departments, Boards and Offices of the Isle of Man Government would be powerless.

16. The first of these is the risk of visitors with towed caravans “clogging up the roads” and provoking irresponsible overtaking, road rage etc. The remedy would appear to be to restrict towed caravans to certain routes. The Department of Infrastructure has advised that this could be achieved through regulations under the Road Traffic Regulation Act 1985.10

Recommendation 1 That the Department of Infrastructure should make regulations under the Road Traffic Regulation Act 1985 restricting the routes on which caravans may be towed.

17. The remaining uncontrolled risks are:

(i) abandoned caravans on public or private land detracting from the beauty of the countryside with no way of the landowner establishing who is responsible for them;

10 Appendix 2 5

(ii) Manx residents keeping a caravan on their driveway, not living in it, but nevertheless still causing a “spillover” impact on the highway through them parking their car in the road when they otherwise would not have to;

(iii) decaying caravans being used on private land for agricultural purposes to the detriment of the beauty of the countryside.

18. To address potential social tensions arising from abuses such as these, new powers are needed. The planning and highways authorities need to be able to develop and apply a policy where, if the keeping of a caravan is detrimental to the environment or to a particular neighbourhood, the person responsible for the caravan can be required to move it.

19. We consider that the best way to address these risks would be to put in place a permit scheme for the caravans themselves, similar to the “tax disc” which must be displayed on motor vehicles. Every caravan would require authorisation and the authorisation would be given with conditions. Such a scheme would require new primary legislation.11

We conclude that to control all the risks associated with towed caravans would require new primary legislation. Such legislation would clearly be a prerequisite to promoting the Island as a destination for towed caravans. However, even without such promotional activity, the number of towed caravans in the Island is increasing to the extent that the legislation is now necessary.

Features of a new regulatory regime 20. Some possible features of a new regulatory regime are identified in the paper at Annex 3. Details would have to be settled as part of the legislative drafting process. The key features would be:

 No caravan will be allowed to enter or remain in the Isle of Man without a permit. The Department of Infrastructure will place a requirement on the Steam Packet Company (and on all other carriers) that they may only carry a caravan to the Island if the customer has the required permit, and if it is a short-term permit they may not sell a single ticket, only a return.

 Short-term permits should be able to be issued by people in the tourism industry, e.g. private sector campsite operators, under the authority of the Department of Infrastructure. Longer-term permits should be available for Manx residents or people wishing to visit for longer than three weeks.

11 Appendix 2 6

 In all cases the permit should specify where the caravan may be towed, where it may be kept and where (if at all) it may be lived in.

Recommendation 2 That the Department of Infrastructure should legislate for a towed caravan permit scheme.

Island-wide consistency in the licensing of camping sites 21. Many of the concerns expressed by members of the public would be addressed by towed caravans remaining in legitimate camping sites. Such sites need to meet certain standards. The Department of Environment, Food and Agriculture advised as follows:

The legislation controlling the use of land for camping purposes is the Local Government Amendment Act 1929 (section 3) which requires that the occupier of any land before erecting or ‘placing’ on said land any tent van (caravan) shed or similar structure used (or intended to be used) for human habitation shall make application to the relevant Local Authority for a Licence to use the land for this purpose.

Under the provisions of this legislation each of the Island’s 24 Local Authorities has the power to create By-laws to enable them to Licence camping sites or grant Exemptions & apply operating restrictions/conditions upon the use of any land as a camping site. The Department acts in an advisory capacity to each of the Local Authorities concerning the creation of camping sites with the additional duty, as the inspecting body, for the monitoring of operational standards within these sites.12

22. The Department has put forward a case for transferring responsibility for licensing camping sites from local authorities to central Government.13 We believe that this proposal merits further consideration.

Recommendation 3 That consideration should be given to the introduction of a central licensing authority with responsibility for administering a single all-Island standard for camping sites.

12 Appendix 3 13 Appendix 4 7

V. URGENCY AND TRANSITIONAL ARRANGEMENTS: THE “FLOODGATES” ARGUMENT

23. When this Committee was established, the Department of Infrastructure anticipated that our Report might reveal that the Gentlemen’s Agreement is unenforceable. The Department therefore asked us to consider whether the publication of such a Report might precipitate increased numbers of caravans being brought to the Island.14 By lifting the lid on the inadequacy of the Gentlemen’s Agreement, are we going to open the floodgates to a rapid influx of towed caravans?

24. The Department advised further that a possible interim measure, which could mitigate against the risk of a rapid influx of towed caravans, would be for the Department of Infrastructure to make a Temporary Traffic Restriction Order to prevent caravans being towed on the roads around the Sea Terminal. The Department has indicated that an exemption could be included for people with an outbound boat ticket and we would be supportive of this.15 The effect of such an Order could be to close the Island to new caravan arrivals. This approach would be somewhat extreme but could be acceptable as a short term interim measure.

25. In these circumstances, we invited the Department to draft legislation for a new permit scheme in advance of our Report being made public. If this had been done, then the Department could have been in a position to put in place new controls as a matter of urgency as soon as our Report was published. The Department’s response to this proposal was:

The Department cannot therefore provide any undertakings in respect of when either regulations or primary legislation can be prepared.

In addition, Hon P Gawne MHK, Minister for Infrastructure, has identified a number of legislative priorities for the Department which will themselves fully occupy all available legislative resources within the Department and all time allocated to the Department by HM Attorney General’s Chambers. Whilst sympathetic to the intentions of the Committee, the Minister is not willing to authorise the preparation or progression of legislation other than Traffic Restriction Orders until such time as the Committee’s report has been debated and Tynwald approval for revised measures for the control of caravans has been confirmed.16

14 Appendix 2 15 Appendix 2 16 Appendix 2 8

We conclude that the preparation of legislation for a towed caravan permit scheme will take time. It is likely that the numbers of towed caravans in the Island, if unregulated, would continue to increase during that time.

Recommendation 4 That Tynwald would accept a temporary Traffic Restriction Order as an interim measure to prevent towed caravans being brought to the Island until the new permit scheme is in place.

VI. TOWED CARAVANS AS AN ECONOMIC OPPORTUNITY

26. The majority of members of the public who wrote to us were not in favour of caravans. Some, however, thought that caravanning represented an economic opportunity for the Island.17

27. The Isle of Man Steam Packet Company advanced a similar point of view, arguing in its written evidence that a 100 pitch caravan park would bring:

Over 8,000 extra tourists to the Isle of Man

Additional spend of over £3.0 million p.a.

Tax revenues to IoM Government of £500,000 p.a.

Diversification of economy.18

28. We agree with the Steam Packet Company that there could be an opportunity here. It might be appropriate for support to be given for the development of a camping site as a tourist destination in the manner outlined by the Steam Packet Company. This would involve caravans being towed by a specified route to the designated camping site and left there for the duration of the visit. Such a holiday package could therefore only be marketed once the caravan permit scheme was in place.

29. The towed caravan market is listed as a “new market” in the Department of Economic Development’s Visitor Economy Strategy of 2012.19 However, the Department’s approach to this market has not been especially energetic. In its written evidence to us the Department said:

A Cross-Government Group, including representatives from Department of Infrastructure, Department of Environment Food & Agriculture and Department of Economic Development, has been investigating both caravans and motorhomes to assess the issues and options relating to the use of, keeping of,

17 Appendix 12A 18 Appendix 10 19 Q14 9

control of, and potential encouragement of caravans and motorhomes on the Island.20

30. In his oral evidence to us, Mr Cretney explained further:

From a historical perspective, I was Minister for Tourism between 1996 and 2006. At that time there were discussions ongoing in relation to a properly controlled, properly regulated possibility of there being… at that time they were talking about Glenlough and roads specifically, and the Steam Packet, who have spare capacity on overnight sailings, bringing towed caravans over in conjunction with the Caravan Club, properly regulated using only the main road. The caravans would then be parked for the duration of the period of stay and would not be used on the roads. They would use the vehicle that was towing the caravan.

I do not know what happened after I left, but that was the discussion that was taking place at that time. As I say, I have been back since April and we have not considered the matter since then, but as I say I am aware that officers in the background for some considerable time have been looking at it.21

31. The Department’s Head of Tourism, Ms Byrne said:

I appreciate that things may not have moved on as quickly as people would like, but we have to look at the legislation and also the regulations of both the Tourism Act 1975 and also the DoI legislation for planning and highways. So there is work going on behind the scenes, but it is going to take a bit of time to pull it all together.22

32. The Chamber of Commerce agreed that towed caravans represented an opportunity. They told us that the Steam Packet Company had developed their presentation on the subject around ten years ago and had re-engaged in discussions on it in the context of the Visitor Economy Strategy in August 2013.23

We conclude that the towed caravan market represents a potential economic opportunity for the Isle of Man. The tourism authorities have been aware of this since at least 2006.

20 Appendix 5 21 Q1 22 Q14 23 Q49 10

We conclude that the towed caravan market cannot be developed until the regulatory framework has been updated. The planning and highways authorities have been aware of this since at least 2006.

We conclude that, although the tourism, planning and highways authorities have been discussing towed caravans since at least 2006, no Department has applied sufficient energy to the issue to drive through the necessary change.

Recommendation 5 That the towed caravan permit scheme should be developed in co-operation with the Department of Economic Development so as to maximise the potential economic benefit of promoting the Island as a destination for toured caravans.

VII. THE WAY FORWARD IN SUMMARY

33. To summarise our findings, it may be said that the approach of the Isle of Man Government to towed caravans has been going round in circles for many years. The regulatory authorities (planning, highways and environmental health) have been aware of an emerging issue but have been under no particular incentive to act, because there has been no drive from the Tourism Division. The Tourism Division has been aware of a potential business opportunity but has been unable to exploit it because of the lack of a proper regulatory regime.

34. The evidence we have presented in this Report shows that, while this discussion has been going on, there has been a dramatic increase in the number of caravans in the Island. There is now a need for action. That action can be implemented in three stages.

35. As a first stage a temporary ban should be put in place on inward caravan traffic, to prevent any further increase in the number of caravans in the Island for the time being. This is the subject of our Recommendation 4.

36. As a second stage, a new permit scheme should be put in place which would make it possible to re-introduce caravans on a controlled basis. This is the subject of Recommendation 2.

37. As a third stage it would then be possible, if Tynwald so chose, to promote the Island as a destination for towed caravan holidays.

38. Tynwald does not need to decide today how much effort should go into Stage 3, the promoting of the Island as a destination for towed caravan holidays. However, even if Stage 3 was never reached we believe that Stages 1 and 2 need to be implemented in order to achieve a properly controlled regime for Manx residents and for existing regular visitors including those who bring their caravans for the TT and Manx Festival of Motorcycling.

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VIII. CONSOLIDATED LIST OF CONCLUSIONS AND RECOMMENDATIONS

39. The conclusions and recommendations of this Report are reproduced here for ease of reference.

40. We conclude that the number of towed caravans in the Island is increasing. Towed caravans may not amount to a serious problem today. However, as the numbers increase, so do the risks. (paragraph 7)

41. We conclude that there is a widely held view that towed caravans are not allowed in the Isle of Man but this is a myth. The “Gentlemen’s Agreement” between the Isle of Man Government and the Isle of Man Steam Packet Company is an anachronism. Under the Agreement, people wishing to bring a towed caravan to the Island are advised that they must seek permission in the form of a “caravan letter”. However, neither the Steam Packet Company nor any Department of Government can actually prevent anyone from bringing a towed caravan to the Island. (paragraph 13)

42. The Agreement may in the past have deterred some people from bringing a caravan to the Island. The rising number of “caravan letters” being requested and issued shows that any deterrent effect of the Agreement on caravanners is on the wane. (paragraph 13)

43. We conclude that many forms of potential towed caravan abuse are already contrary to existing planning, public health and highways controls. (paragraph 14)

Recommendation 1

That the Department of Infrastructure should make regulations under the Road Traffic Regulation Act 1985 restricting the routes on which caravans may be towed. (paragraph 16)

44. We conclude that to control all the risks associated with towed caravans would require new primary legislation. Such legislation would clearly be a prerequisite to promoting the Island as a destination for towed caravans. However, even without such promotional activity, the number of towed caravans in the Island is increasing to the extent that the legislation is now necessary. (paragraph 19)

Recommendation 2

That the Department of Infrastructure should legislate for a towed caravan permit scheme. (paragraph 20)

Recommendation 3

That consideration should be given to the introduction of a central licensing authority with responsibility for administering a single all-Island standard for camping sites. (paragraph 22)

12

45. We conclude that the preparation of legislation for a towed caravan permit scheme will take time. It is likely that the numbers of towed caravans in the Island, if unregulated, would continue to increase during that time. (paragraph 25)

Recommendation 4

That Tynwald would accept a temporary Traffic Restriction Order as an interim measure to prevent towed caravans being brought to the Island until the new permit scheme is in place. (paragraph 25)

46. We conclude that the towed caravan market represents a potential economic opportunity for the Isle of Man. The tourism authorities have been aware of this since at least 2006. (paragraph 32)

47. We conclude that the towed caravan market cannot be developed until the regulatory framework has been updated. The planning and highways authorities have been aware of this since at least 2006. (paragraph 32)

48. We conclude that, although the tourism, planning and highways authorities have been discussing towed caravans since at least 2006, no Department has applied sufficient energy to the issue to drive through the necessary change. (paragraph 32)

Recommendation 5

That the towed caravan permit scheme should be developed in co-operation with the Department of Economic Development so as to maximise the potential economic benefit of promoting the Island as a destination for toured caravans. (paragraph 32)

A F Downie

C G Corkish

D J Quirk

October 2014

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ANNEX 1: PHOTOGRAPHS

Photograph 1

2013 Peel Richard Crane Photograph 2

19 June 2014 Curraghs Alex Downie MLC 15

Photograph 3

19 June 2014 Curraghs Alex Downie MLC Photograph 4

19 June 2014 Curraghs Alex Downie MLC

16

Photograph 5

19 June 2014 Curraghs Alex Downie MLC Photograph 6

19 June 2014 Curraghs Alex Downie MLC

17

Photograph 7

31 July 2014 Glen Mooar Richard Crane Photograph 8

31 July 2014 Glen Mooar Richard Crane

18

Photograph 9

31 August 2014 Glen Mooar Richard Crane Photograph 10

October 2014 St John’s Alex Downie MLC

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ANNEX 2: PAPER BY THE TYNWALD CHAMBER AND INFORMATION SERVICE ABOUT OTHER JURISDICTIONS

TYNWALD INFORMATION SERVICE Telephone: 01624 685520

Tynwald Library, Legislative Buildings, Facsimile: 01624 685522 Finch Road, Douglas, Isle of Man, IM1 TYNWALD E-mail: [email protected] 3PW Tinvaal

For: Select Committee on Towed Caravans Date: 10/07/14

From: Kirree Ronan

Re: Controls in other jurisdictions

Contents

Page 2

England, and

Guernsey

Jersey

Page 3

Northern

Anglesey, Bornholm and Isle of Wight

21

England, Scotland and Wales

No restrictions found with regards to visiting caravans.

However, The Caravan Club – Getting Started24 leaflet provides advice on legal matters in relation to driving licences, with regards to towed caravans and motorhomes, and also parking of the same.

The following legislation covers the ownership of caravans and mobile homes and caravan sites.

Caravan Sites Act 196825

Caravan Sites and Control of Development Act 196026

Mobile Homes Act 197527

Mobile Homes Act 198328

Mobile Homes Act 201329

Mobile Homes (Wales) Act 201330

Guernsey

Towed caravans are not allowed in Guernsey.

Since March 2011, motor homes have been able to travel with a pre-arranged permit and stay at one of three authorised sites. A limit of up to 14 motor homes is allowed on the island at any one time.31

Jersey

Visitors can bring a caravan to the island provided –

 It stays on a registered campsite  A permit is sought prior to arrival

24 http://www.caravanclub.co.uk/media/968584/getting%20started%20guide.pdf 25 http://www.legislation.gov.uk/ukpga/1968/52/contents 26 http://www.legislation.gov.uk/ukpga/Eliz2/8-9/62/contents 27 http://www.legislation.gov.uk/ukpga/1975/49/contents 28 http://www.legislation.gov.uk/ukpga/1983/34/contents 29 http://www.legislation.gov.uk/ukpga/2013/14/contents 30 http://www.legislation.gov.uk/anaw/2013/6/contents/enacted 31 http://www.visitguernsey.com/motor-caravans

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 A letter of authority is sought prior to arrival

While on the island –

 Caravans are restricted to one journey to, and one journey from, the campsite to the port  Caravans must remain on the designated site for the period of the permit  Maximum stay at a site in one month  Maximum width of towed caravan, including the towing vehicle, is 2.3m32 The legislation with regards to the use of caravans in set out in Chapter 7 of the Planning and Building (Jersey) Law 200233

Northern Ireland

No restrictions found with regards to visiting caravans. The Caravans Act () 196334 and 201135 contain legislation relating to caravan sites only.

Anglesey, Bornholm and Isle of Wight

No Restrictions found

32 http://www.gov.je/Travel/InformationAdvice/Travellers/Pages/Caravan.aspx 33 http://www.jerseylaw.je/Law/display.aspx?url=lawsinforce%2fconsolidated%2f22%2f22.550_Planningand BuildingLaw2002_RevisedEdition_1January2013.htm 34 http://www.legislation.gov.uk/apni/1963/17/contents 35 http://www.legislation.gov.uk/nia/2011/12

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ANNEX 3: PAPER DATED 1ST AUGUST 2014 BY COMMITTEE CLERK

Proposed regulatory reforms: request for further advice and drafting

Background

1. The Committee understands that, while there is a widespread perception that caravans are not allowed in the Isle of Man, this is a myth. By longstanding convention the Steam Packet Company advises visitors that they must obtain a “caravan letter” from the DoI. The DoI issues such letters in accordance with planning law. But the repercussions of travelling without a “caravan letter” are precisely zero. There are a number of permanent and temporary campsites where visitors can take quite legitimate caravan holidays already, including for the TT and Festival of Motorcycling. Meanwhile there are some people who live in the Isle of Man who quite legitimately keep a caravan at or near their home for use in caravan holidays off the Island.

2. DoI has advised that there has been an increase in the numbers of requests for caravan letters, from 73 in 2007 to 238 in 2013. Members of the Committee perceive an increase in the number of caravans being seen in what they consider inappropriate places in the Island. The Committee thinks there is a potential market to be developed in caravan holidays to the Isle of Man, but believes that this cannot be developed until there is an effective regulatory regime in place to prevent caravan abuse.

Caravan abuse

3. The abuse the Committee would seek to prevent consists of (in roughly descending order of potential impact):

(a) Manx residents and/or itinerant communities living in caravans in beauty spots or other non-residential areas off the highway contrary to planning and/or public health controls, “putting down roots” and therefore being difficult and/or costly to move on (cost being of particular concern when the landowner is DEFA or another public body);

(b) holidaymakers living in caravans in unauthorised campsites off the highway (such as beauty spots) contrary to planning and/or public health controls. Even if the individuals do not stay long enough to “put down roots”, planning enforcement action may become more difficult over time as a change of use becomes established;

(c) visitors and/or Manx residents living in caravans on the highway contrary to planning, public health and highways controls;

(d) abandoned caravans on public or private land detracting from the beauty of the countryside with no way of the landowner establishing who is responsible for them; 25

(e) visitors with towed caravans “clogging up the roads” and provoking irresponsible overtaking, road rage etc.

(f) Manx residents keeping a caravan on their driveway and living in it as a substitute for an extension to their house, contravening planning and public health controls and resulting in a “spillover” impact on the highway through them parking their car in the road when they otherwise would not have to;

(g) Manx residents keeping a caravan on their driveway, not living in it, but nevertheless still causing a “spillover” impact on the highway through them parking their car in the road when they otherwise would not have to;

(h) decaying caravans being used on private land for agricultural purposes to the detriment of the beauty of the countryside

(i) Manx residents keeping a caravan on the public highway near their home, contrary to local authority bye-laws in Douglas, Braddan and Ramsey but not everywhere;

(j) caravans abandoned on the highway, contrary to highways controls.

Countering caravan abuse: enforcement of existing controls

4. It would appear that most of the above abuses are already contrary to some form of regulation. Countering these abuses, therefore, is not so much a regulatory matter as a question of enforcement methods and resources.

5. The Committee has been advised that the relevant public health controls are the responsibility of local authorities under the Local Government Amendment Act 1929, with DEFA operating as an agent of the local authority in each enforcement case. DEFA has suggested that there would be merit in transferring this responsibility to it, so as to ensure a consistent Island-wide approach.

6. The Committee would welcome further advice on the proposed transfer of responsibility. What disadvantages are there in the current approach? What practical advantages would the transfer deliver? Would the transfer produce enforcement savings/efficiencies or would it need to be accompanied by an increase in resources to DEFA in order to have a practical impact “on the ground”? If so, where could those resources come from? Could the transfer be effected by secondary legislation or would it need primary? Whichever type of legislation is needed, if the Committee is to recommend the transfer the Committee would wish the necessary legislation to be drafted for inclusion in its report.

7. In terms of planning and highways controls, the Committee would like further advice on the effectiveness of the existing enforcement arrangements. Is there anything it can recommend to Tynwald which would help?

Countering caravan abuse: introduction of new controls

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8. There would appear to be just four elements of caravan abuse which would need new controls: (d), (e), (g) and (h).

9. As to abuse (e) (caravans “clogging up the roads”), the Committee has been advised that this can be addressed by regulations under existing highways legislation, restricting the roads on which a caravan may be towed. The Committee would like such regulations to be drafted for inclusion in its report.

10. The Committee has not worked through the issues in detail but something along the following lines is likely to be consistent with the Committee’s thinking.

 A visitor should only be allowed to tow his caravan on a specified network of roads and only at the beginning and end of his stay. In the first instance the specified network should allow for access from the boat to all existing permanent campsites.

 Ultimately the Committee would like to move towards Manx resident caravanners keeping their caravans in designated “caravan parks” around the Island rather than at their homes (see comments below on permit scheme). However, until the permit scheme is in place and a “caravan park” has been established, it may be necessary to allow a Manx resident to tow his caravan on the specified network plus any other reasonable route from the network to his home. He should only be allowed to tow his caravan on the Island’s roads if he is towing it to or from the boat, or to or from a campsite.

11. As to abuses (d), (g) and (h) (caravans either abandoned or in use for purposes other than residential) the remedy would appear to be a permit scheme for the caravans themselves, similar to the “tax disc” which must be displayed on motor vehicles. The Committee expects that the caravan permit scheme which it envisages would require new primary legislation. Assuming this is confirmed, the Committee would like such legislation to be drafted for inclusion within its report.

12. The Committee has not worked through the issues in detail but something along the following lines is likely to be consistent with the Committee’s thinking.

 No caravan should be allowed to enter or remain in the Isle of Man without a permit.

 Short-term permits (up to three weeks) should be able to be issued by people in the tourism industry, e.g. private sector campsite operators, under the authority of DoI.

 Manx residents or people wishing to visit for longer than three weeks should be able to obtain a longer-term permit from the DoI.

 The DoI should be able to issue a Manx resident with a permit for up to 3 years.

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 In all cases the permit should specify where the caravan may be towed, where it may be kept and where (if at all) it may be lived in.

 Where the permit is issued to someone who lives in the Isle of Man, the permit may allow him to keep his caravan at his home but it need not do so. It should be possible for the DoI to specify one or more “caravan parks” around the Island (eg at Balthane) and to use the permit system to get Manx resident caravanners to keep their caravans in such “caravan parks” rather than cluttering up suburban driveways.

 A long term permit issued to a Manx resident caravanner will say where he is to keep is caravan and will generally prohibit him from living in it. However, it should be possible for him to get permission to tow his caravan to a campsite in the Island and live in it there for a short holiday, just as a visitor could.

 It should be possible for the DoI to place a requirement on the Steam Packet Company (or any other carrier) that they may only carry a caravan to the Island if the customer has a permit, and if it is a short-term permit they may not sell a single ticket, only a return.

 If a person fails to obtain a permit, or to abide by the conditions of the permit, the DoI should have a power to enter private land, remove and impound the caravan, then release it on payment of a fee or, after a suitable time delay, sell or destroy it.

 There may be no need for a criminal sanction against abusing the permit scheme but the Committee will be happy to take advice on this.

Countering caravan abuse: procedures which may be abandoned

13. As indicated above, the existing “caravan letter” system is almost entirely pointless, given that there are no consequences to travelling without a “caravan letter”. Its only purpose is to continue propping up the myth that caravans are not allowed. It follows that, if an improved regulatory regime is put in place, the “caravan letter” system can be abandoned. Would this generate any quantifiable administrative saving to DoI?

Transitional matters

14. If the Committee’s report is approved by Tynwald, the recommended secondary legislation could be laid at the sitting immediately after the Committee’s report. Even if already drafted, the recommended primary legislation could not be enacted and brought into effect until several months later. Should the Committee recommend any transitional measures to cover the intervening period?

Jonathan King

1st August 2014

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ORAL EVIDENCE

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Monday 13th October 2014 Evidence of Mr David Cretney MHK and Ms Angela Byrne, Department of Economic Development, and Ms Jane Dellar and Ms Sara Richards, Chamber of Commerce

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S E L E C T C O M M I T T E E O F T Y N W A L D C O U R T O F F I C I A L R E P O R T

R E C O R T Y S O I K O I L B I N G V E A Y N T I N V A A L

P R O C E E D I N G S D A A L T Y N

TO W E D C A R A V A N S

HANSARD

Douglas, Monday, 13th October 2014

PP2014/0126 TCV, No. 1

All published Official Reports can be found on the Tynwald website: www.tynwald.org.im/business/hansard

Published by the Office of the Clerk of Tynwald, Legislative Buildings, Finch Road, Douglas, Isle of Man, IM1 3PW. © High Court of Tynwald, 2014

33 SELECT COMMITTEE, MONDAY, 13th OCTOBER 2014

Members Present:

Chairman: Mr A F Downie MLC Mr C G Corkish MLC Mr D J Quirk MHK

Clerk: Mr J D C King

Contents Procedural ...... 3 EVIDENCE OF Mr D C Cretney MHK, Member of the Department of Economic Development and Ms A Byrne, Head of Tourism ...... 3 The Committee adjourned at 3.09 p.m. and resumed at 3.10 p.m...... 14 EVIDENCE OF Ms J Dellar, Chief Executive, and Ms S Richards, Chair of Tourism Committee, IOM Chamber of Commerce ...... 14 The Committee sat in private at 3.37 p.m...... 22

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Select Committee of Tynwald on Towed Caravans

The Committee sat in public at 2.33 p.m. in the Legislative Council Chamber, Legislative Buildings, Douglas

[MR DOWNIE in the Chair]

Procedural

The Chairman (Mr Downie): Right, well, good afternoon everybody. Welcome to this public meeting of the Select Committee on Towed Caravans. My name is Alex Downie MLC and I am the Chairman of this Committee and with me are David Quirk MHK and Geoff Corkish MLC. First of all could we please ensure that your mobile phones are off and not just silent as it 5 interferes with the Hansard equipment. Also for the purposes of Hansard, I will be ensuring that we do not have two people speaking at once. Just to give you some background, the Committee was established by Tynwald on 17th June 2014 and it was resolved on that date that a Committee of three Members be appointed with powers to take written and oral evidence pursuant to sections 3 and 4 of the 10 Tynwald Proceedings Act 1876, as amended, to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park and the need for regulating the entry on the Island and the overall use of caravans. 15 So today is our first opportunity to take evidence in public. Now we are taking evidence from Mrs Angela Byrne and Mr David Cretney MHK and in the second session we will be taking evidence from Jane Dellar and Sara Richards.

EVIDENCE OF Mr D C Cretney MHK, Member of the Department of Economic Development and Ms A Byrne, Head of Tourism

Q1. The Chairman: So if I can open the proceedings then by asking Mr Cretney for his view. We have had some correspondence from him and the Tourism Division and so if you would like 20 just to set the scene for us, Mr Cretney, please.

Mr Cretney: Well, thank you very much, Chairman. Since I have been back involved in Tourism, which is the back end of April, we have not given this any consideration at all. There were a number of other priorities leading up to the TT etc 25 and so between then and June, when the resolution was passed in Tynwald, no consideration had been given. We then decided that given that the Committee had been established we would await the outcome of the recommendations of the Committee.

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I am obviously aware that in the background for some considerable time now a committee of officers across various Departments has been looking at the feasibility or otherwise of doing 30 something in relation to towed caravans. From a historical perspective, I was Minister for Tourism between 1996 and 2006. At that time there were discussions ongoing in relation to a properly controlled, properly regulated possibility of there being… at that time they were talking about Glenlough and roads specifically, and the Steam Packet, who have spare capacity on overnight sailings, bringing towed caravans 35 over in conjunction with the Caravan Club, properly regulated using only the main road. The caravans would then be parked for the duration of the period of stay and would not be used on the roads. They would use the vehicle that was towing the caravan. I do not know what happened after I left, but that was the discussion that was taking place at that time. As I say, I have been back since April and we have not considered the matter since 40 then, but as I say I am aware that officers in the background for some considerable time have been looking at it.

Q2. The Chairman: Right. So outside of TT and the Manx Motorcycle Festival then you are of the opinion that there was 45 potential to develop this type of business, but in very controlled circumstances?

Mr Cretney: That was what we were looking at at that stage and I think things have altered since then. I have been looking round about the Island and if you look round about the Island you will see there are a number of caravans in residential areas presently. So I do not think it is 50 being policed to the extent it perhaps once was. I think there is a more lax approach now, or certainly it appears so, because there are a number of caravans that I have personally seen in residential areas owned by residents.

Q3. The Chairman: Yes, and that leads me on to the next point, which is our concern that 55 they at the present time are unregulated –

Mr Cretney: That is correct.

Q4. The Chairman: – and other than the parking of one on the highways overnight, which is 60 an offence, and then there are planning issues that are thrown up. I personally do not think it will be long before one is left at a beauty spot and there is virtually nothing in the Government's armoury to try and prevent that. One of the objectives of this Committee is to make sure that we can come up with legislation that is both fair and equitable, but is also effective as well, because we are under the impression that there are probably 150-plus caravans here on the Isle 65 of Man now. The other question that I want to ask you about is what do you know about this letter of comfort that is provided to the Steam Packet by your Department?

Mr Cretney: I am sorry, I do not know about the – 70 The Chairman: Right.

Ms Byrne: It is not our Department. It is DoI.

75 Q5. The Chairman: DoI?

Ms Byrne: DoI, yes.

Q6. The Chairman: But have you had any knowledge of that or any views of that or…?

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80 Ms Byrne: As far as I am aware, it is like a gentleman’s agreement between the Steam Packet and DoI, but we do not get involved in that in the Tourism Division.

Q7. The Chairman: So how do all these caravans come in for TT and the Manx Festival then?

85 Ms Byrne: They come in through –

The Chairman: Because I am told that they do not need a letter of comfort then.

Ms Byrne: Well, on our website, on Visitisleofman.com, for importing caravans, that is part of 90 the regulations, that if they book with the Steam Packet, the Steam Packet notifies DoI and DoI issue the letter.

Q8. The Chairman: So when the letter is given then, where does it go? Do we know?

95 Ms Byrne: I genuinely cannot answer that.

The Chairman: Right, because we not aware that this system is actually in place, and that is another concern for us because it is presenting a falsehood really because people on the Island think that there is a system in place when really it could be described as something of a sham. 100 If we are looking to protect the countryside, but still not be unreasonable and allow caravans to come and go from the Isle of Man, it has to be within a tightly controlled regime so that we are not finishing up with a mess, really. Mr Corkish, have you –

105 Q9. Mr Corkish: Yes, thank you, Chairman. I think we have an admission from the Department that the letter of comfort is now pointless anyway because if you apply for a letter you do bring a caravan in with permission, or you do not apply for a letter and the caravan comes in and nothing is done about it. So the actual gentleman’s agreement is no longer there, which is why the question was asked in the first place 110 and the motion put down to explore the advantages and disadvantages, that is all, as to whether caravans were useful to us here on the Isle of Man or not. I know you have said that you had limited talks about this, but would the Department of Tourism… in the talks that you already had is there any view that a pukka caravan park on the Isle of Man would have any impact to our advantage here on the Isle of Man, from a Tourism 115 perspective?

Mr Cretney: I am sorry if you have misunderstood. There have been no discussions since I have been back involved in the Department. What I was relaying was the previous experience I had, and what I tried to say was I think things have changed since then inasmuch as there are 120 caravans on the Island. I have seen them at the Claddaghs, as well you know.

Mr Quirk: Yes, they are –

Q10. Mr Corkish: Well, we have photographic evidence of caravans in, what we would term, 125 ‘beauty spots’ on the Isle of Man now, which is why the motion was put down to this in the bud, rather than leave it and leave it, and leave it and leave it, and then you will find you have got hundreds and hundreds of caravans, and what do you do about it then? Now is the time to act and that is what pre-empted the motion.

130 The Chairman: Mr Quirk.

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Q11. Mr Quirk: Can I ask, David, as a Member of the Department, does the Department, now you are in DED, see this as a priority if there is a tourism element; and, if so, how are we going to lead that forward? You are given a delegation to do certain things, and so is that on your top 10 135 list, top five list?

Mr Cretney: No, it is not, because as I indicated when I became involved again towards the end of April until the time that the Committee was established in June, it was not considered by ourselves, by the officers and myself in relation to tourism, but I was aware that for some 140 considerable time there has been a committee of officers from various Departments looking at it. So, no, it has not been on my top five or top 10 list.

Q12. Mr Quirk: Can I just ask the officer from DED too, have you ever seen any of the letters from… even from Manx Grand Prix week or TT week? 145 Ms Byrne: I have not, no.

Q13. Mr Quirk: No. You have seen no exchanges of letters at all to it?

150 Ms Byrne: No.

Q14. The Chairman: I just want to ask Mrs Byrne if the Department has actually done any financial modelling of what, say, an organisation like the Caravan Club of Great Britain could do? They are investing multi-million pounds in sites throughout the UK and throughout Europe. 155 Obviously, some years ago they were quite keen to come to the Isle of Man on a very restricted basis to come to an approved site… certain times of the day move the caravans off. There must be some mileage in that for us, the spend in the local economy, and of course the more traffic we can get through the Steam Packet, the cheaper the fares might be for the other sailings. 160 Ms Byrne: You will have to ask the Steam Packet about the cheaper fares. It is on our Visitor Economy Strategy, which was released in 2012, and it is down as what we call a diversification part of the growth matrix, which basically means it is a new market and a new product for the Isle of Man; therefore it can be perceived as more risky because we are 165 going into new territory. So what we have done, which I think we have shared with the Committee, is some of the research that we have pulled together from Mintel, which is the basic research that we have started to do on that actual product and looking at what our competitors are doing, which includes enforcement… 170 We have been working with DoI and DEFA on this and we have been looking at the standard of the caravan parks that are in the UK and also the standards and lawfulness of some of the campsites in the Isle of Man and so there is quite a lot of work going on to do that as the first step. The second step: we are looking to bring in new common standards for what is called ‘parks’. 175 Now that covers caravan parks. It would cover log cabins, as an example. It would also cover alternative camping, and so your yurt campsites, your camping pods and things like that. That is under our secondary legislation within the Tourism Act. So that is going to take a bit of time to come together. I appreciate that things may not have moved on as quickly as people would like, but we have 180 to look at the legislation and also the regulations of both the Tourism Act 1975 and also the DoI legislation for planning and highways. So there is work going on behind the scenes, but it is going to take a bit of time to pull it all together.

______6 TCV 38 SELECT COMMITTEE, MONDAY, 13th OCTOBER 2014

Mr Quirk: Chairman?

185 The Chairman: Mr Quirk.

Q15. Mr Quirk: So can I ask then if you work in partnership with the Department of… DEFA and DoI, has it ever been a concern to you too that some of the premises getting used now for either towed caravans or motorhomes are actually Government land? 190 Ms Byrne: I do believe it is a concern of planning, yes. Obviously, if there are any issues with that, the complaint would go direct to DoI; it would not necessarily come to the Tourism Division.

195 Q16. Mr Quirk: No, but if I could say to you that if you are working in partnership with them when you are building up this policy for the future to say there will be the strengths, the weaknesses and the possible difficulties because… Can I ask you to comment on a scenario then if somebody brings… I bring a caravan to the Isle of Man and come through the system and then it just disappears off the map and I can put it 200 in a field somewhere. Would that not be a concern to Government itself?

Ms Byrne: It is a concern to us, yes, because most of our visitors come here because of our natural environment and our natural landscape. So obviously that is a concern if we find that there are going to be caravans dotted around the Island and some of them at the beauty spots 205 of the Island.

Q17. Mr Quirk: A couple of years ago we did have a person who lived in a caravan and then subsequently got homed by the Government. Would that be a concern if people started using them as temporary accommodations? 210 Ms Byrne: It would be a concern from a personal point of view because I live here, but under our legislation we have no enforcement or regulatory scheduled powers that we would… if we got a complaint of that nature at the Tourism Division we would automatically send that through to the planning enforcement officer. 215 Q18. Mr Quirk: So when you indicated to us today the Acts were 1975 and… really that is probably an old Act now that wants reviewing. Is there a –

Ms Byrne: It is under review as part of the Scope of Government. 220 Q19. Mr Quirk: Can I just ask then on that particular point, on the review elements of the 1975 Act (Ms Byrne: Yes.) is it just… I do not know… tourism? What are the elements in that Act?

Ms Byrne: It is mainly down to tourism. What we are trying to do is… as you say, it was 1975 225 when it was brought in and there have been an awful lot of changes over the years. Some of the changes have not been repealed properly and so what we are doing at the moment within the Department is a big exercise to tidy all of that legislation and regulation up, and we will hopefully be going out to consultation on that very soon.

230 Q20. Mr Quirk: So apart from the assessment, if I can ask you, there would only be several places, I would think, in the Isle of Man to actually bring a towed vehicle to a destination. Has the Department looked at maybe a north, south, east and west, or are we looking at one site, because when you say you are upgrading the sites for camping you have included… I do not want to bring in motorhomes, but at the end of the day there are a number of motorhomes that

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235 do come for TT and they are quite large – some of the American jobs are quite big as well – so does that factor into that as well?

Ms Byrne: Yes, the campsites are regulated under the Tourist Act, in terms of registration and grading, and that is the enforcement and the schedule of powers that we have. 240 Of the permanent campsites on the Isle of Man that operate mostly from March through to September/October time, they all have provision for what we call ‘pitches’, which could be for a motorhome or for a caravan, where they would have electric hookups and obviously they would use the recreational facilities that are there.

245 Q21. Mr Quirk: So regarding pick-up sites, does that mean that I bring my caravan in and approach one of the sites and say, ‘I want to place it there forever and a day’ and that would be alright with the Department?

Ms Byrne: It has – 250 Mr Cretney: When it was previously looked at this was on a strict time regime that the vehicles would be brought and then taken away again, rather than being here for an extended period.

255 Q22. Mr Quirk: So the difficulty we have got at the minute is, if I am a citizen and I bring a towed caravan, a 40 feet or something – some of them are huge, to tell you the truth… the towed ones – and place it somewhere, I can leave it there as a citizen who lives in the Isle of Man, and it would not half be a concern if everybody started to do that.

260 Mr Cretney: Of course it would be a concern and we have all seen the worst examples on coastlines and exposed areas where there are streams and streams of caravans, static caravans, and they do nothing to add to the environment. So it would be important, if this were to be pursued, that it would be in areas that were more secluded, and that is why I had felt previously that Glenlough fitted that purpose, really. It would be one that would not cause so much 265 concern. But in talking about motorhomes, again, local people… I have seen a number of local motorhomes at Langness and I have seen them at Smeale, and so they are already an issue with more people using those vehicles in what we would term ‘beauty spots’, and it is in the eye of the beholder as to whether those cause concern or otherwise. 270 Q23. The Chairman: Would it concern you to know then that there are only four local authorities in the Isle of Man who have any sort of rules or guidelines which would have any bearing on caravans? Because although they have got the licences for pitches and so on, they themselves have extended that and now they are allowing caravans to park in these areas, but 275 there is no national policy. It is still the policy of a particular local authority in a particular area. Would you not agree that one of the things that we should be doing is coming up with a national policy so that whatever part of the Isle of Man, either camping, motorhomes or caravanning takes place, there is some generally agreed and understood policy which protects both the general public and provides surety for those people using the site and proper 280 standards?

Mr Cretney: Yes, for that reason alone we welcomed the establishment of the Committee and no doubt you will be looking at all those matters, and that is why we have put on hold any further work as a Department that we are doing, pending your investigations.

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285 Q24. The Chairman: Right. Okay. Just moving on then, obviously we have got caravans on the Isle of Man that have arrived here and we have got them now. I just want to see if you would consider it would be useful to have some sort of a registration process where a disc or something could be applied, so that there is a contact e-mail address or a mobile phone number and we actually know who the 290 caravan, through Government systems, is owned by. Would you report something like that?

Mr Cretney: Whether it would be our Department who would issue such or whether it would be the DoI… but, yes, the principle of there being control and able to follow up where caravans are placed is certainly something… with their being no registration or whatever or that could be 295 removed, then it would be much better if there were some kind of recognition that could be followed up on.

Q25. Mr Quirk: Can I just ask – through you, Chairman – would you see that identify and cut to the chase a DoI issue or a police issue? 300 Mr Cretney: Well, I think first and foremost a DoI issue. Then the enforcement of that, again, all depends on who has got the resources to properly enforce, as applies to all sorts of legislation which –

305 Q26. Mr Quirk: Sorry, Chair. You would probably agree with me anyway that the Police themselves have enforced powers on the highway.

Mr Cretney: Yes.

310 Q27. Mr Quirk: So that would be a simple matter to extend regulation over to there?

The Chairman: Not on private land.

Mr Cretney: Not on private land… on the highway certainly. 315 Q28. Mr Quirk: Sorry, Chair, would you not agree then – and I will put words in your mouth here – that environmental health officers could do that, because one of the concerns for me would be, would you not agree, the disposal of grey water, the disposal of sewage that is in these vehicles? One would not like people just to have these places in the countryside and just 320 empty the ‘grey matter’, as we call it, into the watercourses, which eventually end up in our reservoirs.

Mr Cretney: No, the principle of regulation is something that I certainly, and I am sure the Department, as a matter of principle, support. 325 The Chairman: Right. Mr Corkish.

Q29. Mr Corkish: Thank you, Chairman. 330 I am well aware, of course, that there was a committee formed some time ago in my time in the Department to look at this. I have to say I am disappointed that that work had not progressed as much as it had, especially in hard times, where Tourism needed more arrows in its quiver. From the information supplied, which I thank you for, from the UK Domestic Caravan Tourism 335 Research, that the Camper and Caravan Club recently invested £29 million in a five-year plan to redevelop its network by 2015, and due to planning constraints the supply of available UK

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camping and caravanning pitches has remained relatively static. They are looking for new places to develop and I would have thought perhaps, because we are in hard times and looking for…. I am out of touch now with the Department. What new streams of business you are looking for? I 340 am a little surprised that we have not pressed on further with this particular issue, which could or could not have been of benefit to the income of the Isle of Man, which we are all charged with looking at.

Ms Byrne: The work that has been ongoing for about the last two years has grown into a big 345 animal, if you like, because you have got the DoI involved, of which there is quite a lot of their legislation. It is not just one primary legislation that covers the towed caravans and the motorhomes, you have got the motorhomes or caravans coming in by visitors, you have got them for residents that are owned, you have also got the lawfulness of campsites, which is where this all went back to. So DoI Planning Division have actually gone through and checked all 350 the campsites to make sure that they all have the correct planning permission. Some of them did not. Some of them were historical. Some had got permission through being campsites for the last 10 or 15 years. The campsites are what we regulate, in terms of registration and grading. So, from a Department’s point of view and a resource point of view, that is where we have been 355 concentrating our time and making sure that the campsites are lawful and that they are checked by both Fire and by Environmental Health. The temporary campsites that come up for TT and Festival of Motorcycling have to be checked every year. Again, they have to go through the planning process and so we have to, basically, go back to the beginning with DoI and start working through each of the stages of the 360 mire that is legislation and regulation, which is taking a bit of time to do, I have to say.

Q30. Mr Corkish: Chairman, can I just say –

The Chairman: Yes, sure. 365 Mr Corkish: – that from the outset the whole point of this Committee being formed and the motion that was put before Tynwald was that we were seeking knowledge of likely advantages and disadvantages, and whilst I have no preconceived ideas… we have no preconceived ideas, apart from the risk of caravan abuse here on the Isle of Man. 370 Would it be fair to say then that Tourism see no easy advantage or impact advantage to caravans coming onto the Isle of Man?

Ms Byrne: Our main objectives are to grow visitor numbers and increase visitor spend, and so if that means that there is an economic benefit for the towed caravan market to the Isle of Man, 375 then obviously we would look at that very seriously. At the moment, the research we have done, which was shared… there is a very basic spot analysis that we have covered off on the back of that paper. So what we would then do is look at that in more detail, and we have every plan to because it is in our strategy. So we have got every plan to look at it in more detail, along with the other areas that we stated in the strategy. I 380 cannot view that outcome until we have done more research and we have got more in-depth figures and information that we can give you.

Q31. Mr Quirk: Can I just ask, Chairman, and just supplement that? Regarding then, if we move, say, from towed caravans to static caravans, would the 385 Department have a policy on that?

Ms Byrne: The only cases that I am aware of have been turned down due to development in the countryside and planning.

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Q32. Mr Quirk: So you rely on planning then to fulfil an obligation? 390 Ms Byrne: Well, no. Someday a private sector individual came to us looking to develop a… it was not a static caravan site as such, but it was a similar-type model, but it was actually the land that they wanted to do it on that planning would not allow.

395 Q33. Mr Quirk: Was that not log cabins?

Ms Byrne: They were going to look like log cabins, but not log cabins as in a woodland area. It was out in a field they were going to be pitched.

400 Q34. Mr Quirk: In other jurisdictions they have these static ones where you can actually –

The Chairman: A prefabricated house.

Mr Quirk: Yes, they will actually transport them, if you will. Get a transporter to come and lift 405 them up and put them in another location. They are actually virtually homes on stilts.

Ms Byrne: Yes.

Q35. Mr Quirk: The Department has a view on that? 410 Mr Cretney: Well, my own personal view is that I would resist the introduction of such. I do not think that would add anything. And, as Angela said already, one of the principal reasons that people come to spend time with us on the Island is the beauty of the countryside, and so we have an obligation to maintain 415 that wherever possible.

Q36. The Chairman: Yes. Can I ask if you are still in regular dialogue with the Caravan Club of Great Britain?

420 Ms Byrne: No.

Q37. Mr Quirk: Should you be?

Ms Byrne: Once we have done the research and everything, yes. 425 Q38. Mr Corkish: But you have already said that it is not a priority within the Department anyway and so the chances are that that dialogue with the Caravan and Camping Club is not going to take place for some considerable time.

430 Ms Byrne: Well, it is in our strategy, which is due to expire in 2015. So we need to take it to a level in 2015 and then we will review it to see whether it continues in the strategy from 2016 onwards. Again, that will be based on research. It will not be based on personal opinion; it is based on research and economic –

435 Q39. Mr Corkish: It may well be, Chairman, that the overall decision would be that we do not want caravans at all (Ms Byrne: Yes.) on the Isle of Man. The whole question came about because caravans are already here and what are we going to do about it? Are we going to let it escalate and compact itself into a bigger problem or are we going to use that opportunity to the benefit of tourism here in the Isle of Man and as a matter of

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440 hard times and how we need to increase the visitor spend here and the visitor economy that may have been given a little bit more priority.

Mr Cretney: As I say, the way that we were looking at it when I was previously involved was in conjunction with the Caravan Club and on the basis that people who take holidays in 445 caravans… generally it is the principal holiday they will take and they do not do other things. So, as such, we were missing out on a potential market and we were looking to see whether there were opportunities, under strict control on the Island, for that to happen.

Q40. Mr Corkish: Protecting the Island. 450 Mr Cretney: Yes.

Q41. Mr Quirk: Can I ask if it would still be worth just touching base with the caravanning organisations to see if they are still interested in the Isle of Man as a destination, because if we 455 are doing all this work and we cannot engage with another partner off Island, because there is a big draw… I forget, and Mr Corkish may know the figures, but the Caravan Club, as far as I know, when you research it, is a massive organisation. They encourage people, not only on the caravan side but the motorhome side, to get involved in their clubs and they have a big draw. So if we were even the best site in the world and we encouraged somebody to do something, 460 if they are not going to come across we are wasting our time.

Q42. Mr Corkish: I think they also… just a point on that from my interest in it, of course from my time in Tourism, that not only is it the Camping and Caravanning Club, it also represents the ‘motorhomers’, and Mr Cretney has already said this afternoon that there is an increased use of 465 motorhomes here on the Isle of Man. Does that itself create a problem with the environment here? Would it benefit from a specific park here on the Isle of Man?

Ms Byrne: Well, the campsites that we have do take motorhomes as well and would all have hard standings and electric hookups for the motorhomes. So it is not that we actively discourage 470 motorhomes or towed caravans, it is just we do not actually promote them as, say, we would the accommodation in the hotels, B&Bs and self-catering… the diversification of that type of accommodation. But as I say, we need to do the research to find out (1) if there is a market and (2) would the Caravan and Camping Club be interested in coming over and talking to us and seeing if we can 475 work together. But we need to do the research before we can get to that stage.

Q43. Mr Quirk: Sorry, would you not agree though that if you were going to run a new market you would touch base with the players? So the first thing I would do if I was going to run a business would be to say to a particular 480 person, ‘Are you interested in coming to the Isle of Man?’ They would have done all the research themselves. I am sure they must be aware that something might be happening in the Isle of Man… not like other jurisdictions that we are aware of now who do not accept them at all and they just say, ‘No, the doors are shut to it.’ A simple phone call to say whether you are interested in the Isle of Man… is it a location 485 people want to go and is it a good connection to the boat travel?

Mr Cretney: All I would say is I think it is very important, for something as potentially sensitive as this, that not only the Department but also the Committee does the research to see if this is something that can be properly managed and controlled – 490 Q44. Mr Quirk: Well, I can say we have been –

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Mr Cretney: – rather than perhaps inviting the Caravan Club to just have a discussion when you have not got the facts upon which to base such discussion. And in answer to your previous thing, I would certainly have concerns about indiscriminate 495 parking of any type of vehicles in inappropriate areas, which, as I say, would be detrimental to the environment and it is something that we would be very unhappy about.

The Chairman: Right. Okay. Mr Corkish? 500 Mr Corkish: That is fine from me, Chairman.

The Chairman: Mr Quirk?

505 Q45. Mr Quirk: On the last statement from Mr Cretney, there are concerns because if you go around the Island, even in your own constituency there are a couple of them parked up in local authority curtilages and one of them has been there for about… it must be nearly 10 years, and so I would think the chassis has probably rotted to death on that one. When you say there is a concern, how are we expressing that concern? 510 Mr Cretney: How are we expressing that concern?

Q46. Mr Quirk: Sorry, how are you expressing that concern (a) to the local authorities who are letting this permit, and would you…? 515 One of the concerns I do have then is that it becomes an extension to the property. (Mr Cretney: Yes.) Then, of course, like it is in other jurisdictions, mainly the UK, people drive them up onto their driveways if they are big enough. They jack them up, take the wheels off and then they become an extension to their dwelling.

520 Mr Cretney: Yes, well, there were issues going back even further to when I was Chairman of the Planning Committee, when people made application to park vehicles, such as you describe, adjacent to their property. I do not know whether that still happens, but I remember people being refused that because of the detrimental effect it might have in terms of the curtilage, but I do not know whether that system is still being enforced at the planning area or not. They are 525 probably busy with big issues.

Mr Quirk: We will get DoI here.

The Chairman: Right. 530 Well, it is obvious from our findings thus far that there is no framework in place, and come what may I think one of the recommendations that this Committee will have to make is as to what we are going to do about the caravans that have crept into the Island now. We are often given examples of places, like Fenella Beach, where it is almost impossible to go down there over the weekend because people are going and parking either their mini caravans 535 or their campers down there and that is starting to become an issue, and before long we will find that that is spreading throughout the different other parts of the Island. So I think we have got to try and address that because then if somebody comes here on holiday and they cannot get to those places because somebody has beaten them to it, as it were, and gone and left their facility there, which is wrong… I am told already by DoI that there is no overnight parking in 540 these places, but they do not seem to be bothered about doing anything about it. But I am sure you will agree with us that there is lots more to do in this area (Mr Cretney and Ms Byrne: Yes.) and we would just like to take this opportunity of thanking you both for coming in today and letting us have your views. Okay.

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Mr Cretney: Okay. Thank you very much. 545 The Chairman: Thank you very much.

The Committee adjourned at 3.09 p.m. and resumed at 3.10 p.m.

EVIDENCE OF Ms J Dellar, Chief Executive, and Ms S Richards, Chair of Tourism Committee, IOM Chamber of Commerce

Q47. The Chairman: Good afternoon, welcome to the Committee. For the benefit of Hansard, would you just introduce yourselves to us and give us a little bit of background to what you do. 550 Ms Richards: I am Sara Richards. I am here with two hats on, really. At the current time I chair the Chamber of Commerce Tourism Committee. That has representatives from all sectors of the industry: accommodation providers, hoteliers, and also people who run activity businesses for tourist activities. Then aside from that, I also chair an Association of Self-Catering 555 Accommodation Owners, and that is a representation of 40 members at the current time, with about 60 properties and about 250 bed spaces. I sit on the Chamber of Commerce in my personal capacity as an accommodation provider; I have got three self-catering cottages on a farm in the north of the Island. The Association are not members of the committee, so it is just important to make that distinction, because 560 obviously I can answer various questions with one or both hats on.

Q48. The Chairman: Okay, and Miss Dellar please.

Miss Dellar: Jane Dellar. I am the Chief Executive Officer at the Isle of Man Chamber of 565 Commerce. I deal with the cross sectors: we have eight committees representing different sectors of the business, of which tourism and the visitor economy is one of them.

Q49. The Chairman: Right, could we start then by asking you if the Tourist Committee has a view on this particular issue? 570 Ms Dellar: Yes. Back in August 2013 the Steam Packet provided us with the presentation that they had done back at the original time it was talked about – was it 2005, I think? We were talking about how we could improve the visitor economy, how we could get more visitors over here, and that was one of the strands that we had on our table for consideration. 575 I think when they first brought up caravans there were many of us who went, ‘Aaargh!’ – you know, getting stuck behind a caravan on the way to work and everything. Then they actually went through the presentation in terms of having controls over it so that towed caravans would come over, go to a site, park on the site, unhitch their caravan and then drive round the Island in their cars. 580 Previously, discussions with the Caravan Club had demonstrated that would bring a considerable number of visitors and a considerable economic benefit for the Island; a way of increasing capacity during the peak times of TT in the summer when most of the beds are fully booked or oversubscribed, but also to bring in a whole new set of people to the Island that would never come here because caravanners go caravanning, and they are not going to leave 585 their caravan at home. They take an average of seven trips a year apparently, a lot do short

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stays, and they just simply would not come here if we would not let them. So on that basis I think most people think that caravans are not allowed on the Island. That is the general perception.

590 Q50. The Chairman: Does the Chamber have a view on whether caravans have crept in and are here already?

Ms Dellar: I think that our focus is primarily to do with the business sector and the generation of business in terms of the visitor economy. We have not discussed the domestic 595 situation other than generally looking at having visitors in a controlled situation, not just freedom to drive round and park wherever. I think as a personal resident of the Island I would also support any initiative that was taken to make sure that there were controls in place to avoid having 200 caravans parked at the Point of Ayre on a Sunday. That is a personal view; that is not a Chamber view. 600 Mr Corkish: Thank you, Chairman.

Ms Richards: I think it is fair to say that –

605 The Chairman: Can we just deal with Miss Dellar for a minute, and then we will let you have a go, Miss Richards. Don’t worry, we will get round to you. Mr Corkish.

Q51. Mr Corkish: Thank you, Chairman. 610 Can I just repeat the statement I made to our previous visitors here, that we are seeking knowledge of likely advantages and disadvantages to caravanners coming to the Isle of Man. No preconceived idea whether they should be here or not be here, but does the Chamber have a view on what likely benefits or otherwise a caravan-designated park could have on the hotel, guesthouse, self-catering community on the Island? 615 Ms Dellar: I am working off information that has been provided by our member firm, which is the Steam Packet, when they did their presentation to our committee, and the new market: a 100 pitch caravan site could bring an extra 8,000 tourists to the Island, with an additional spend of £3 million per annum, with tax revenues to Government in the region of £500,000, and 620 obviously diversification of the economy.

Q52. Mr Corkish: Perhaps Miss Richards would have a better view? No disrespect to Jane Dellar, but as a practitioner, if you like.

625 Ms Richards: I think the committee saw the potential of the extra numbers in terms of visitors spending money in the cafés, the activities, heritage, in the same way that people coming to self-catering accommodation, for instance, do. Some of them arrive with their food in their car, others go straight to the supermarket, and in that respect the two groups are probably pretty similar. But our view was that this was an entirely new stream of people that, as my 630 colleague has said, would not probably have considered the Isle of Man, and it was that potential to grow visitor numbers that really we thought was worthy of support. I think it is fair to say though, that the committee did… it came as a surprise to most of us that there was so little control over it. I think this perception that caravans just are not allowed… it was quite a surprise to find out – 635 Q53. The Chairman: I think, sadly, when the media reported on the debate in Tynwald they only gave one side of the story, and it was as if we were pushing this. That really was not the

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view, because we were aware that there was not a level of control and we were worried that the situation would get out of control. But saying that, there are, as I said, 150 caravans here at the 640 moment; plus would we be cutting our nose off to spite our face if we said, ‘No we are going to declare them illegal,’ or whatever, and really that is not the right thing to do. So we are trying to come up with a solution that would improve the tourist product, and also help us to regulate what is here already and make sure that they do not get left or deserted, or cause a nuisance in the future. And that was the idea of it. 645 You are right, there was a lot of mystery about what had been going on. But just to come in again there, do you think that the industry itself has any preconceived concerns about bringing caravans? Do you think that would be detrimental to the B&B?

Ms Richards: When this issue came up, as chair of the Self-Catering Association I decided to 650 send the Steam Packet presentation slides out to all of our 40 members so that I could gather some views. I have to say I was quite surprised that I only had three responses from members, because I was bracing myself for a lot of reaction. Of those three it might be quite interesting for you to know that one was really a query, a lady wondering whether potential visitors with caravans would be prepared to live with the 655 proposed limitations, on travelling to one site. That was only really her concern. The second one was a mild objection based on experience of having visitors to stay in this lady’s self-catering accommodation, who were caravan owners, and apparently they have booked to come next year. So, clearly she felt that if they could bring their caravan, then we might lose visitors from the self-catering sector. 660 I have had a similar experience with having guests in my own accommodation, who were quite interesting to talk to, but my research with that group revealed that clearly there are groups of caravanners who would weigh up the costs very carefully – of fares and pitch fees – before deciding whether or not to take their caravan. So that was quite interesting. The third view came from self-catering owners of very long standing who had previously 665 been very keen caravanners in the UK, and they were very much opposed to the idea on the basis they would not bring economic benefit. But I have to say I think that needs putting into context: visitors who might come with caravans are not that much different from visitors who come to self-catering accommodation. They still have the potential to add to the economy by spending in the cafés, going to heritage attractions and all those other activities, and that is 670 where we really need to be successful in order to benefit the economy generally.

Q54. Mr Corkish: Would you – sorry, Chairman – perhaps agree then with Jane Dellar that the people who are caravanners, are caravanners; people who have come on holiday to stay in hotels, come and stay in hotels? 675 Ms Richards: I would guess – and we have not done research – but I think it is probably... We all know people who are very keen caravanners and they tend to be very dedicated. So I would think that is probably the majority of caravanners.

680 Q55. Mr Corkish: And a caravan is quite expensive. You are not going to leave it parked on your front drive while you go and stay in somebody else’s hotel –

Ms Richards: Yes, and that is what they enjoy –

685 Q56. Mr Corkish: So you would not think they would be robbing the existing –

Ms Richards: No, I think there will be a few people who might leave it at home, but I think the majority would be dedicated caravanners –

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Q57. Mr Corkish: And there may be a balance, of course, that if there is increased use of such 690 traffic on the Steam Packet, the Steam Packet might not have an excuse to put fares up as much?

Ms Richards: We need the Steam Packet to be successful (Mr Corkish: Absolutely.) We need their numbers to grow as well. 695 Q58. The Chairman: So how would you feel then, having listened to the representatives from the Department earlier on? How would you think the industry would feel if there was a dedicated park for caravans, run by somebody like the Caravan Club of Great Britain, where people could go, they could leave the caravan there, but they had to be cleared by a certain time 700 in the year and so on? The reason I ask you that is we face a huge hiatus with accommodation around TT and the Manx Festival. If somebody came in, say, two weeks before the TT and set up in the designated park, they could have their family there through the TT period, there could be an arrangement made where other family users could come and use it, and then they would use it themselves at 705 the Manx Grand Prix Festival, and then the caravan is gone. Surely that has got to be a boost to somebody?

Ms Richards: I think once people in the industry understand the mechanics of how it could be controlled properly, and if they can understand that a site can be provided in the right location 710 so that it is not visible from all directions, at that stage I do not think this will cause us as much concern as we might all think. And I think people are coming to understand the economic benefits of tourism a lot better. Certainly, members within the industry are better able now to understand just how it is interlinked. So I think if the message gets out there that it can be controlled properly on a really 715 good site, then I think people are likely to see it as an advantage.

The Chairman: Right, Mr Quirk.

Q59. Mr Quirk: Can I just ask you, in your organisation do you have any representatives from 720 the… not the tourism side, but the camping side, the campsite owners?

Ms Richards: We have one campsite member in the Self-Catering Association –

Mr Quirk: I do not need to know his name, do not worry. 725 Ms Richards: Just one, and they did not express a view on this at all.

Q60. Mr Quirk: No? Could I ask too, as an organisation with the Chamber of Commerce – maybe asking both of 730 you on that, from your side and maybe your administrative side too – do you meet regularly with Economic Development, Tourism, to say, ‘We think this is a great idea, we want to put yurts…’ I remember people talking about yurts in the Isle of Man, and all sorts of other things that would happen. Don’t worry, they are in Glen Vine, so they do exist. Do you meet the Department to explore those? I wonder how that gets legs and carries on? 735 Ms Richards: Yes we do. We both sit on the Visitor Economy Steer Group, which is chaired by Mr Cretney, so we have regular monthly meetings with the Department and we have fairly recently, in the last few months, more or less agreed strategy proposals for carrying the current strategy forward into the next phase. So we are actively engaged in looking at all of these ideas 740 and developing them.

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Q61. Mr Quirk: So the current strategy which is jointly put together…?

Ms Richards: The current strategy was not jointly put together, no.

745 Q62. Mr Quirk: No? So it has been given to you on a tablet of stone?

Ms Richards: Well, the steer group was only formed last year so it is a fairly new initiative, working together with the Department. So we are trying to get input into the strategy which will overtake the current one. But that is in early stages at the moment. 750 Q63. Mr Quirk: If you are creating strategy with the Department… The Chamber is always asked to give views, as a stimulating organisation. So if your top five would be… for enhancing the tourism experience in the Isle of Man, would a licensed caravan site be 1 to 5? 1 to 10? 755 Ms Richards: Well it has not been, I think, because–

Q64. Mr Quirk: Why not?

760 Ms Richards: We have listened to the Steam Packet very carefully on their experience of 10 years ago when they were trying to get some traction for the idea, and by the sound of it the climate just was not the right time at all. And despite the fact that they were then in close contact with the Caravan Club, they could not really seem to get any progress with advancing the idea, so an awful lot of work was put to one side in mothballs. 765 Q65. Mr Quirk: Is it an initiative, though, that the Chamber could take on themselves?

Ms Richards: I am not sure that that would really be appropriate. Yes?

770 Ms Dellar: I may take that. I think with the work that was done previously by the Steam Packet, we would find it very hard to get members to actually invest the time into it again, given that it all collapsed after an awful lot of hard work. I think on that basis it would be something that we would be very comfortable with as a joint initiative, but not to lead it. 775 Mr Quirk: Okay, so the –

Ms Dellar: We are not new business development, we are existing member support.

780 Q66. Mr Quirk: So is the Chamber waiting for this Committee to make its decision and report?

Ms Dellar: I think that we were working with DED on the strategy. It was one of our submissions for the strategy as a specialist group, which is one of the areas – like Dark Skies, 785 trying to think of other different areas. And on that basis –

Mr Corkish: As we should.

Ms Dellar: I think this group came after the proposals had been submitted, and on that basis I 790 think it is always reasonable to say that the private sector always thinks that Government could be a bit quicker. But equally we do appreciate that there are a lot of regulations and controls that need to be considered at the same time so –

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Q67. Mr Quirk: So if I could ask if the Chamber gets the 1 to 10, magic words? Where is Dark Skies in 1 to 10? Where are caravans in 1 to 10? 795 Mr Corkish: Could I – sorry, Chairman – frame it a little bit differently for you –

The Chairman: Go on then.

800 Mr Quirk: Can I ask a question?

Q68. Mr Corkish: Just to clarify: would the Chamber see any economic benefits to the Isle of Man being part of the caravan network and sites, with a facility that is comparable to UK and European sites? 805 Ms Dellar: Yes, I think already we stated they are spending money in –

Mr Corkish: I am not cutting across. We are just trying to clarify.

810 Ms Dellar: – shops and restaurants, yes.

Mr Quirk: I can see it in my own –

Ms Dellar: Putting it in a top 10, it is not as straightforward as that: you look at what resource 815 you have got, what you can do with it and what you could enable. The Chamber of Commerce cannot enable this, we have to just work and support, and work with. There are things we can enable, where our own members are involved and concerned; the rest we can only hope to influence and assist –

820 Q69. Mr Quirk: Well, virtually the Chamber itself… every consultation I see, the Chamber’s name is down there, plus other people, so you must have organisations which discuss issues, send things up to them. I do not know how the Chamber works to tell you the truth, but I presume you have sub-committees and then you pile it up to the top, and then they make a massive decision? 825 Ms Dellar: Yes, the Chamber’s name appears on every consultation by default. We do not always respond – that is just as standard. We get consulted on matters that are of no impact to the business community which we do not partake in, so we are just on the papers as being a consultee. 830 In relation to how the Chamber works: we have two part-time staff employed by the Chamber, myself and an administrator; the rest is by volunteers in industry. We have 150 people participating in the different sector committees, and we focus on issues and relevancy to our members – supporting the visitor economy is relevant through our membership. We have no individual members who are involved in Dark Skies, we have no individual members who are 835 involved with caravans or campsites, but we work with all of them in relation to the visitor economy as a whole, because improving the visitor economy as a whole improves for all of our members and all of the residents. If you have got more visitors using our events and activities… A population of 80-something thousand could not support the facilities that we enjoy. They rely on the visitors using them as 840 well. We have seen, with Manx National Heritage extending their opening months, that it has made a significant difference to what is spent in shops and pubs and restaurants, and other places.

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Q70. Mr Quirk: Could I ask your colleague, then, regarding this particular issue itself: is there an opportunity for an out-of-season effort? 845 Ms Richards: Yes, that is where really we are trying to concentrate our efforts. It is not difficult to fill July and August for any of us, probably. We are working with the Department to try and look at the shoulder months really, and try to focus effort on those. Coming back to the 1 to 10 question, I think we all recognise that there is not a single mass 850 market answer to our quest to grow numbers. It is a raft of niche markets, and caravans could be one of them. So I do not think any of us could list 1 to 10, but it is there on a level with things like Dark Skies and walking holidays, cycling; (Ms Dellar: Railways.) yes, a whole raft of them. I would also support what Angela Byrne had to say about the need for doing some more research. Yes, certainly the Caravan Club is one source of information, but I think probably if the 855 idea is to progress there needs to be some independent research.

Q71. Mr Quirk: So, wouldn’t you expect the Department to do that research?

Ms Richards: Yes, I think they are – 860 Mr Quirk: I mean, they are charged with –

Ms Richards: – really in a position to do that, to see whether it is worth taking forward to get into the next strategy to have work done on it, yes. 865 Q72. Mr Quirk: So if you have – sorry – monthly meetings with the Department, that could be an agenda item. Even if discussion took place, something came out of it, even if the Chamber took an element of it and the Department took an element, that would be the way forward for all sorts of things? 870 Ms Richards: Yes, well, we have already taken some initiative by supporting the Steam Packet, because really, at the stage where we were considering that in our meeting last year, the idea was not a live one at all. So we have tried to breathe some life into it in that way to at least get it looked at. 875 Q73. Mr Quirk: So could I ask the Chief Executive then: the issue was debated within the Chamber, the sub-committee had views on it, and it was accepted by the Chamber as a whole?

Ms Dellar: By the Tourism Committee, yes. 880 Q74. Mr Quirk: But the Chamber accepted that as a whole, as a potential way forward?

Ms Dellar: Yes, the sector was working their own sector development. It is not… so, yes.

885 Q75. Mr Quirk: So you have given it the green light?

Ms Dellar: It is part of the strategy document that we have put forward to the Department of Economic Development, yes, it is one of the...

890 Q76. Mr Quirk: Okay. Just for the record then, that development document is called…?

Ms Richards: The Chamber strategy proposals –

Ms Dellar: The Chamber of Commerce Strategy –

______20 TCV 52 SELECT COMMITTEE, MONDAY, 13th OCTOBER 2014

895 Mr Quirk: Just the Chamber strategy?

Ms Dellar: – for the Visitor Economy.

Q77. Mr Quirk: I presume it is on your website? 900 Ms Dellar: No.

Q78. Mr Quirk: Not yet?

905 Ms Dellar: No, we do not put –

Mr Cretney: Strategies on there.

Ms Dellar: – things like that our website. We have just got a working website, that is – 910 Q79. Mr Quirk: Not even Facebook?

Ms Dellar: I do not use Facebook.

915 Q80. Mr Corkish: I think this is just a final from me. If I could just repeat what I said earlier on, that the Committee was set up to look at the advantages and disadvantages. What we need to know is what the likely impact, right or wrong, would be on other associated businesses within the Isle of Man, because we have a potential ‘abuse’ of caravanning on the environment. That is where we are trying to go. 920 Ms Dellar: Yes, and I think that we would fully support you in that aim. I think it is reasonable to say the Chamber is not pushing for this. We are here because we were asked to come and talk to you. New initiatives to bring new visitors to the economy are going to benefit everyone and we are happy to work, as I said, with the Department. There are 925 plenty of other things the Chamber can work on if it does not get traction. We would like to see it in respect of increasing the visitor numbers to the Island, and I think that is where the tricky part is. When you get them here, what we can offer them is probably more down to our members in terms of the offering that we can offer. But actually bringing them here is the difficult bit, so if there is a completely new market that we have not got access to at the 930 moment, I think generally that is supported.

Q81. Mr Corkish: And there may be a downside to that initiative, and that is what we have to explore, and the purpose of us doing that.

935 Ms Dellar: Exactly, but it has always been on the basis of controlled towed caravans, not the great big monster mobile homes.

Q82. Mr Quirk: What do you mean, static or motor homes?

940 Ms Dellar: No, this is just towed caravans so that they can be unhitched and they are not on the roads.

Q83. The Chairman: Could I ask you both, then: if there was one thing you would like this Committee to recommend to Tynwald on this issue, what would it be?

______21 TCV 53 SELECT COMMITTEE, MONDAY, 13th OCTOBER 2014

945 Ms Richards: Well, I certainly feel that an overall measure of control over caravans generally would be a thoroughly good idea, having discovered that there is so little and it is so piecemeal. I think it is quite a worry for the future that there is so little that can be done with caravans which may not belong to bona fide tourists, or if they pop up in places which are going to cause a blot on the environment, because it certainly is very important, as Mr Cretney said, to preserve the 950 environment which is the attraction to our visitors.

Mr Corkish: Absolutely.

Q84. The Chairman: And? 955 Ms Dellar: I think, try and get the Departments to work together. It is pretty difficult when you are trying to work with three or four different Departments and it is on a different level of importance with the different Departments. So whilst it might be very important to the development side, sometimes it is not so important to the planning side – for quite 960 understandable reasons, I am not saying that. But sometimes it is very difficult when you have got different Departments that are responsible for certain elements of the same thing.

The Chairman: Well, we have got Tourism and Leisure – it is a strategic responsibility of theirs – we have got Environmental Health, and then we have got Infrastructure. So there are three 965 strands to all this. And then there is enforcement and all the other things that have to be brought to bear. But that is one of the tasks that this Committee will have to deal with. If there are no further questions from my colleagues, I would just like to thank you both for coming along and talking to us today and giving us the Chamber’s view.

970 Ms Dellar: Thank you very much.

Mr Corkish: Thank you. Good to see you.

The Chairman: Yes, finished. Our thanks to Hansard and the press. 975 Mr Corkish: Thanks for that.

The Committee sat in private at 3.37 p.m.

______22 TCV 54

WRITTEN EVIDENCE

55

56

Appendix 1 Submission dated 11th July 2014 from the Department of Infrastructure

57

58 59 60 Select Committee on Towed Caravans

Caravan Use on the Isle of Man Consideration of advantages and disadvantages

At the 17 June 2014 sitting of Tynwald a motion was put forward by the Hon Member for Council, Mr Corkish and accepted by Tynwald, that a Committee should consider and to report to Tywnald of the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park, the need for regulating entry on to the Island and usage of caravans.

The Select Committee on Towed Caravans has asked the Department of Infrastructure to submit written and oral evidence to the Committee by 10 July 2014 with any comments regarding:

What, if any regulation and enforcement arrangements are in place, what complaints the Department receives from the public, and what work has been underway on this issue in the Department.

This response is submitted by the Department based on the professional advice of officers in its Highway Services and Planning and Building Control Divisions.

Existing Legislation and the ‘Gentleman’s Agreement’

Planning Legislation

The Town and Country Planning Act 1999 gives power to control ‘development’. The meaning of development is set out as being ‘the carrying out of building, engineering, mining or other operations in, on, over or under land, or the making of any material change in the use of any buildings or other land.’

The control of towed caravans in planning occurs when their use involves a material change of use of land.

Planning can therefore control inter alia:  the change of use of land to a campsite;  the storage of caravans on land; and  the use of caravans as permanent living accommodation.

Planning cannot control, inter alia:  The parking of a caravan in the curtilage of a house if the caravan belongs to the owner/occupier of that house;  The siting of a caravan on any land where a change of use of the land does not occur (keeping one on a farm where it is being used by the farmer for purposes incidental to the farm for example).

Where development occurs without the requisite Planning Approval, the Town and Country Planning Act 1999 provides for the ability to serve an enforcement notice to cease the use, or allows for prosecution. However, evidence needs to be compiled to prove that a breach of planning has occurred. It is often difficult to prove a breach of planning, particularly when a specific caravan may only be present or occupied on an intermittent basis and often outside normal working hours. The courts are unlikely to entertain a case for prosecution based on a single incident or occurrence. Evidence needed is likely to take some months to collect (as

61 an example, the parking of a caravan on a piece of land and even stopping overnight in some areas of the Island would not in itself involve a breach of planning approval).

In situations where an enforcement notice is served, it must be served on the landowner. If land has been used in breach of planning for a period of 10 years or longer, then, under the current Act, no enforcement notice may be served in respect of it.

Highways Legislation

Under highways legislation there are controls relating to:  Overnight and weekend waiting regulations (under Section 2 of the Road Traffic Regulations Act 1985) which restrict the parking of large vehicles on the highway and are enforced by the police;  Parking of unhitched trailers (which includes touring caravans) is covered under Section 45 of the Highways Act 1986.  Where the Department has provided off street parking spaces under S10 of the Road Traffic Regulation Act 1985 these spaces can be regulated under S11 of the Act to control the use of the parking spaces by large vehicles.  Use of towed caravans on the highway network can be controlled by the use of Traffic Regulation Orders (under Section 1 of the Road Traffic Regulation Act 1985).  The use of towed caravans to sell refreshments is covered in Sections 78 and 81 of the Highways Act 1986.

The Local Government Amendment Act 1929

This requires any land owner to obtain a licence from the Local Authority to use land as a camp site. The Department of Environment, Food and Agriculture has power to inspect such camp sites and apply model standards for campsites. Sites are usually inspected every year in preparation for TT.

The ‘Gentleman’s Agreement’

An attempt to control the importation of touring caravans has occurred through a long standing verbal ‘Gentleman’s Agreement’ between the Government and the Isle of Man Steam Packet Company. Anecdotal evidence suggests this agreement, which has no basis in legislation, has been in place since the 1950’s.

Highways legislation is limited in that it only controls the use of vehicles on the highway. A vehicle could legitimately be brought to the island and provided it is not on the public highway, these Acts cannot control any use.

Current custom and practice is that any person wishing to bring a touring caravan to the Island using the Isle of Man Steam Packet Company requires a ‘Caravan Letter’ agreeing to the visit from Planning and Building Control. Requests for such a letter generally require the person wishing to bring the caravan to the Island to specify the reason for visit, the duration of visit and the intended location of the caravan. Planning officers are able to respond to requests of this sort when the location of any caravan is specified and can then advise as to the acceptability of usage in planning terms. If no location is given, no advice can be provided.

The conditions of carriage applied to the Isle of Man Steam Packet Company are of course a matter for that company.

62 In recent years there has been a dramatic increase in the number of requests for caravan letters. Statistically, the following number of requests, have been agreed since 2007 (breakdown only available since 2012).

2007: total = 73 2008: total = 55 2009: total = 51 2010: total = 55 2011: total = 92 2012: total = 101 (TT 8; MGP 43; S100 11; Holiday 17; Storage 22) 2013: total = 238 (TT 69; MGP 86; Pre/Post TT 16; S100 23; Storage 15; Holiday 26; Dog Obedience 3)

Current Situation Regarding Campsites

The Planning & Building Control Division has carried out an assessment of campsites on the island, some of which have received planning approval and others which have become lawful over time. This shows that there are:  11 permanent sites (lawful for all year round – although they may not operate as such);  11 more that operate only during the TT and GP; and  a further 3 that are seasonal.

These sites provide for 119 caravan / motorhome pitches, with a further 66 during TT.

Complaints Received

Planning matters: The types of complaints received by Planning fall into the following categories:

 illegal use of or storage of caravans in the countryside;  use of caravans in association with small holdings/’lifestyle land’;  use of caravans and motorhomes as permanent living accommodation either within the countryside on land not designated for such purposes, or in residential gardens;  the use of caravans and motorhomes for overnight, or longer stays on public or private car parks.

Highways matters:

The types of complaints regarding caravans received by Highway Services fall into the following categories: - Towed caravans – no record of complaints - Unhitched caravans parked on highway – One in last 12 months

Work in Progress

The Department of Infrastructure’s Planning and Building Control Division has begun collating factual information regarding campsites on the island, with a view to regulating existing long standing activity.

63 The Division has also begun preparing a Draft Permitted Development Order to allow for the temporary use of land for campsites during the island’s motorcycling festivals. Following public consultation on this, the Department will determine whether or not to pursue this and if so will need to bring forward secondary legislation.

The Department contributes to the Department of Economic Development’s working group on the Visitor Economy and is aware that a collaborative approach on towed caravans and motor homes is a matter for the group to consider when resources are available.

Advantages/Disadvantages

Advantages of encouraging towed caravan use on the island:

To meet an identified tourist need (the evidence of need, its benefits and the impact it may or may not have on the provision of existing tourist accommodation should be sought from the Department of Economic Development); To meet a domestic recreational need.

Disadvantages in Planning and Highway terms of encouraging towed caravan use on the island:

Planning:

 Potential impact on quality and appearance of island’s landscape.  Lack of legislation to effectively control length of stay of caravans.  Lack of legislation specifically directed at the control and use of caravans whilst on the island.  Lack of definition (under planning law) of a caravan and its difference (if any) from a static caravan, a motorhome or a log cabin.  Lack of ability to enforce against the owner of a caravan regarding its unauthorised use, rather than the owner of the land.  Lack of control of the parking of caravans and motorhomes on private driveways.  Lack of sites that are suitable for the storage of caravans when not in use.

Highways:  Cost of assessing routes to existing and proposed sites.  Implementation of any necessary Traffic Regulation Orders and highway realignments.  Enforcement of Traffic Regulation Orders; publicity and management of these routes.  The parking of caravans on driveways may result in displacement of resident’s vehicles onto the highway causing localised congestion and access issues on the highway network.  The ability to enforce the S45 of the Highway Act 1986, if the caravans are used by persons classed as travellers or gypsies as their permanent place of residence as there may be human rights legislation implications. There are large travelling communities in both the North-West of England and in Ireland. Specialist advice would be required on this issue.

64

Appendix 1A E-mail dated 24th October 2014 from the Chief Executive, Department of Infrastructure

65

66 From: Black, Nick Sent: 24 October 2014 17:12 To: Jonathan King Subject: FW: Caravan letters

Dear Jonathon

I have the following from my colleagues in Planning:

We have been keeping a spread sheet since 2007 and I can see immediately how many requests we have received.

In some earlier instances we asked for more information about the intended use and location for the caravan (duration etc) and the person applying being asked to elaborate did not reply. Also in 2007 we had a log for a particular camp site where we’d had a long running breach of planning control for unauthorised caravan use/storage. That count makes up part of the 73 total.

There has been an upturn in requests as more customers are being directed to us by the steam packet. Please also note that the bulk of requests are from persons/competitors attending the TT or Grand Prix, so to store the caravans in the paddocks at the Grandstand.

Of those requests where a Planning Application was required or further detail requested 2007 73 2 2008 55 7 2009 51 7 2010 55 12 2011 92 26 2012 101 5 2013 251 4 2014 237 3 (to date)

So it appears to me that we have had increasing numbers and that most are accepted without the need for further information.

Trust this assists.

Nick

From: Jonathan King Sent: 23 October 2014 12:43 To: Black, Nick Subject: Caravan letters

Nick

67 In your Department’s submission of 11 July to the Select Committee on Towed Caravans you provided figures for the number of caravan letters requested each year since 2007. Can you tell the Select Committee for each year how many such letters were issued, please?

Thank you.

Jonathan

68

Appendix 2 Letter dated 8th October 2014 from the Department of Infrastructure

69

70 71 72 73 74

Appendix 3 Submission dated 11th July 2014 from the Department of Environment, Food and Agriculture

75

76 Written response to Tynwald Select Committee

It was resolved in Tynwald on 17th June 2014:

That a Committee of three Members be appointed with powers to take written and oral evidence pursuant to sections 3 and 4 of the Tynwald Proceedings Act 1876, as amended, to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park and the need for regulating the entry on to the island and usage of caravans.

The committee approached DEFA on the 19th June 2014, clarifying that

“The Select Committee on Towed Caravans would be grateful for a written submission from DEFA by 10th July with any comments on the remit quoted below. The Committee thinks there may be environmental health issues arising from unregulated use of caravans as living accommodation.”

The Department wishes to make comment in respect of the encouragement of tourism and the creation of a non-residential caravan park and the usage of caravans on the island.

Encouragement of Tourism

The Department has two relevant perspectives with respect to this matter, which are identified below from the Department Plan.

1) Regarding economic development:

“The Department will work with the offshore energy, food, forestry and outdoor amenity business sectors to facilitate economic growth and support the wider economic development.”

2) Regarding protecting the environment from people:

“The Department has a significant role in protecting the public from the external environmental factors and agents that may harm them in their normal lives. In particular we have a significant role to ensure that everyone has a safe and healthy home and operates in a safe and healthy work place. This is often undertaken in partnership with Local Authorities, other Government Departments and other public and private sector partners.”

The Department seeks to sensitively manage and encourage recreational and commercial activity across its Forestry and wider estate for the benefit of the public whilst ensuring that the plantations, National Glens and other land that it manages are not detrimentally affected by an increased pressure on informal camping with a resultant need for regulatory control.

77 Current Legislative Control

The Legislation controlling the use of land for camping purposes is the Local Government Amendment Act 1929 (Section 3) which requires that the occupier of any land before erecting or ‘placing’ on said land any tent van (caravan) shed or similar structure used (or intended to be used) for human habitation shall make application to the relevant Local Authority for a Licence to use the land for this purpose.

Under the provisions of this legislation each of the islands 24 Local Authorities has the power to create By-laws to enable them to Licence camping sites or grant Exemptions & apply operating restrictions/conditions upon the use of any land as a camping site. The Department acts in an advisory capacity to of each of the Local Authorities concerning the creation of camping sites with the additional duty, as the inspecting body, for the monitoring of operational standards within these sites.

In an attempt to ensure minimum standards of safety and consistency the Department has produced Model Standards relating to both Permanent and Temporary Camping sites (temporary means those sites operating less than 2 months/year) which seek to set-out the minimum standards for the creation and operation of such sites.

(Model Standards reflect the ‘best practice’ as operated by the major camping & caravanning organisations in the U.K. - The Caravan Club, The Camping & Caravan Club & The Motor Caravanner’s Club.)

Additional information

The operation of a camping site is considered to be a work activity for which the Department has an additional responsibility under the provisions of the Health and Safety at Work etc. Act 1974 (as applied to the Isle of Man) where by further controls exist to safeguard the health safety & welfare of those persons both operating and occupying the sites.

Summary

It is the Department’s view that the current Model Standards relating to the creation and operation of camping sites (including use by caravans) is satisfactory, however, it is considered that the arrangements permitting each Local Authority to grant Licences or Exemptions, as they consider appropriate, has resulted in a ‘piece meal’ approach to camping site standards which may only worsen if the demand for further caravan parking facilities grows.

It is therefore we believe that any review of Legislation should take into consideration the benefits of establishing a single Licencing authority and that the Department could be well placed to undertake this function, as it’s officers currently inspect these premises under both the Licencing legislation and the broader remit of the health and safety at work legislation relating to the operation of these sites.

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Appendix 4 Submission dated 7th October 2014 from the Department of Environment, Food and Agriculture

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80 Camping Sites - Regulatory Reform DEFA - Proposals

The Department of Environment, Food and Agriculture would like to submit the following additional observations in response to the consultation on Camping Site regulatory reform.

Existing Legislative Control - disadvantages

The legislation controlling the use of land for camping purposes is the Local Government Amendment Act 1929 (Section 3) which requires that the occupier of any land before erecting or ‘placing’ on said land any tent van (caravan) shed or similar structure used (or intended to be used) for human habitation shall make application to the relevant Local Authority for a Licence to use the land for this purpose. Under the provisions of the current legislation this power is vested in each of the islands 24 Local Authorities whereby they have the power to create by-laws to enable them to licence camping sites or grant exemptions or impose whatever operating restrictions/conditions they consider appropriate on the use of any land as a camping site.

It is at the discretion of each Local Authority whether it wishes to introduce by-laws to control camping sites or interpret the standards relating to such sites and impose their own variations/exemptions on how the sites may be operated.

This scenario has resulted in Local Authorities introducing their own camping site standards with the potential for all 24 local Authorities introducing different licensing standards across the island with further discretional variations between camping sites being permitted within their areas

With the responsibility for enforcement also resting with the individual local authorities variations in enforcement policies may result in further discrepancies in enforcement consistency which at a minimum could be embarrassing to the islands reputation.

Furthermore such variations/exemptions could give rise to conflict with DEFA and other Government Departments and Agencies who are seeking to administer other relevant pieces of legislation e.g. DEFA administering the relevant health and safety legislation.

This Department currently acts in an advisory capacity to of each of the local authorities concerning the creation of camping sites, the formulation of By-Laws (in collaboration with the Local Government Unit in the DOI) and the inspection of camping sites for the monitoring of operational standards

The need to refer to each local authority in these circumstances can and does lead to the same advice being given over and over again resulting in a significant administrative burden setting up these controls and subsequently reporting to each local authority for the consideration of any enforcement action. In an attempt to ensure reasonable standards of safety and consistency the Department has produced Model Standards relating to both permanent and temporary camping sites (temporary means those sites operating less than 2 months/year) which seek to set-out the minimum standards for the creation and operation of such sites and as and when the need arises each affected local authority is briefed by Officers from this Department.

81 Proposed change to Legislation - Advantages

It is proposed that a central licensing authority be introduced with responsibility for administering a single all-island standard for camping sites (see Model Standards) This would bring a level of consistency in standards to this sector as well as ensuring that where enforcement action is required it will be applied in an even handed manner across the island.

The single authority administration of the licensing scheme would enable the creation of a central database containing all licences, exemptions and variations granted, enabling the inspecting officers’ ease of access to the relevant operational conditions applied to each site. (Model Standards reflect the current ‘best practice’ as operated by the major camping & caravanning organisations in the U.K. - The Caravan Club, The Camping & Caravan Club & The Motor Caravanner’s Club.)

Additional information

The Governments Agenda for Change aim “to encourage sustainable economic activities in harmony with our natural resources” is fully supported by the Department and in its capacity as one of the Departments with responsibility for ensuring the sustainable management of the Islands natural environment it will make every endeavour to combine its advisory and enforcement functions to enhance the economic and amenity value of land while protecting its diverse and interactive natural systems.

Caravanning and camping activity at formal and informal sites can have an impact on the ecology and biodiversity of the locations in question and the Department would support the inclusion in the proposed legislation (or associated guidance) of links to the information and advice that is available on how to comply with existing legislation in place to protect our environment (by their nature caravan sites are often located in areas of significant landscape value or areas of special scientific interest).

DEFA officers will be pleased to work with landowners to enhance the economic and amenity value of their land through the adoption of good environmental practices.

The operation of commercial camping and caravan sites is also considered to be a work activity for which the Department has an additional responsibility under the provisions of the Health and Safety at Work etc. Act 1974 (as applied to the Isle of Man) where by further controls exist to safeguard the health safety & welfare of those persons both operating and occupying the sites.

Summary

It is the Department’s view that the current Model Standards relating to the creation and operation of camping sites (including use by caravans) is satisfactory, however, it is felt that the arrangements permitting each local authority to grant licences or exemptions, as they consider appropriate, has resulted in a ‘piecemeal’ approach to camping site standards which may only worsen if the demand for further caravan parking facilities grows.

82 It is therefore recommended that the legislation should take into consideration the benefits of establishing a single licencing authority and that the Department would be well placed to undertake this function, as its officers currently inspect these premises under both the current licencing legislation and the broader remit of the health and safety at work legislation relating to the operation of such sites.

It is envisaged that the efficiencies associated with creating a single licensing and enforcement authority would result in savings by removing the need to brief individual local authorities and reduce the legal burden by eliminating the need to introduce by-laws within each local authority area.

83 84

Appendix 5 Submission dated 14th July 2014 from the Department of Economic Development

85

86 Department of Economic Development

MEMORANDUM

To : Tynwald Committee

Cc : Chris Corlett, Chief Executive, DED

From : Angela Byrne, Head of Tourism, DED

Date : 14th July 2014

Subject : Motion: Use of towed caravans

It was resolved in Tynwald on 17th June 2014:

That a Committee of three Members be appointed with powers to take written and oral evidence pursuant to sections 3 and 4 of the Tynwald Proceedings Act 1876, as amended, to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park and the need for regulating the entry on to the island and usage of caravans.

A Cross-Government Group, including representatives from Department of Infrastructure, Department of Environment Food & Agriculture and Department of Economic Development, has been investigating both caravans and motorhomes to assess the issues and options relating to the use of, keeping of, control of, and potential encouragement of caravans and motorhomes on the Island.

The Group has and is currently investigating the impact of the use of caravans due to conflicting views and an unclear legislative background relating to caravans. A report is being drafted with the intention of presenting to the relevant Departments for approval by March 2015.

Caravans and motorhomes also give rise to a number of issues and it is appropriate to consider these from the viewpoint of each Government Department.

The aim of the report is to gain cross government agreement on the approach to caravans and motorhomes and determine whether or not new legislation is required and if so, what form that legislation should take.

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87 It is important that the work undertaken is with the agreement of all the relevant Departments and that any legislation supports each of the Department’s functions and helps to deliver their goals.

The Department of Economic Development have set out their strategic aims in the Visitor Economy Strategy 2012-2015. While camping and caravanning does not feature specifically in the key performance indicators, increasing visitor numbers and their spending does feature, as does event-led tourism.

The Strategy does recognise the need to be sensitive over the environmental impact of activities and developments in the countryside. Appropriate Planning policy and processes will be necessary in relation to potential sites for camping, caravans and motorhomes.

The popularity of camping, caravans and motorhomes in the UK has increased, and thus may present an economic opportunity for tourism in the Isle of Man to capitalise upon, particularly during peak periods when other forms of accommodation are at or near capacity. Given the popularity of camping in recent years it is important to the tourism industry to improve the standards of existing campsites and encourage further development. It would also be beneficial to set out clear guidance for campsite owners and also those visiting the Island. The development of log cabins and caravanning is seen to be a potential new product that could encourage new types of visitors.

As this cross Government work is ongoing an opportunity to provide further information can be made available at the private hearing.

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88

Appendix 6 Market research paper submitted on 13th August 2014 by the Department of Economic Development

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90 ISLE OF MAN GOVERNMENT

U.K. Domestic Caravan Tourism Research An brief analysis into the market size and motivations of U.K. domestic caravan consumers

Games, Sam 17/07/2014

91 Contents UK Domestic Camping & Caravanning Holiday Market ...... 2 Volume & Value ...... 2 Motivations ...... 5 Market Needs ...... 7 Sustainability ...... 8 Price ...... 8 Market Demographics ...... 9 UK Holiday Parks ...... 10

92 UK Domestic Camping & Caravanning Holiday Market

Volume & Value Mintel estimates that “domestic camping and caravanning experienced a disappointing year in 2012 with the number of trips falling by an estimated 6.5%, wiping out the 6.6% growth seen between 2007 and 2011 (as shown in figure 1). Volumes therefore returned to pre-recessionary levels with 15.9 million trips taken during the year.” The overwhelming factor believed to be the poor UK weather in 2012, which experienced the 2nd wettest weather since records began.

However due to the economic downturn in 2008, the UK domestic camping and caravanning holiday market experienced a rapid growth during the year with domestic camping and caravanning trips increasing by 21% compared with overall domestic stays which increase by 17%. Although demand has levelled it is unlikely that the overseas market will fully recover, giving way to new opportunity to attract the local UK market.

Mintel says that “Expenditure on domestic camping and caravanning trips was around £2.5 billion in 2012, a 1.8% drop from 2011 (as shown in figure 27). Despite the sharp fall in trips, and some heavy discounting by some sites to boost occupancy during wet weather, average spending increased to £159 (from £152 in 2011), driven by inflationary factors. Since 2007, although volumes have stayed flat, expenditure has risen by 15%: rising petrol prices have been a key factor. However, the market has not been able to press home the advantage of the surge in trips seen in 2009 and the value of domestic camping and caravanning in 2012 remained at around 2009 levels.”

93

According to the NCC, the UK national trade body for the caravan & motorhome industry, there are an estimated 1.1 million ‘leisure caravans’ in use in the UK, consisting of 525,000 touring caravans, 174,000 motorhomes, 327,000 holiday homes and 112,000 park homes. Furthermore there are around 2,000 licensed holiday/touring parks in UK.

However, new supply has been sharply impacted by the credit crunch and long economic downturn, and the production of new touring caravans and holiday park homes dropped 40% between 2007 and 2012. Meaning future markets could potentially be very low, as less and less people are purchasing caravans and motorhomes.

The NCC forecasts that the UK caravan industry contributes around £6 billion p.a. to the UK economy. It also estimates that 1.5 million people regularly take touring caravan / motorhome holidays with a recorded 69.9 million nights away spent on camping and caravanning trips in the UK in 2010. This amounts to 19% of all nights away from home (including business as well as leisure trips) spent in the UK.

The survey by Mintel (as shown in figure 5) found that 1/5 UK consumers had stayed in a static caravan or mobile home between 2010 and 2012. A further 6% had stayed in a friends or relatives caravan/ mobile home. 5% of consumers had stayed in a towed caravan and 3% in a motorhome/campervan. Overall Mintel research found that between 2010 and 2012, a total of 34% of all consumers had stayed in some form of caravan, motorhome or vehicle accommodation.

94

Mintel research (figure 1) broken down further revealed that between 2007 and 2011 there has been 3% fall in the number of domestic towed caravan trips, a 29.3% increase in rented static caravan stays and a 1.8% increase in owned static caravan trips (as shown in figure 28). The small decline in towed caravan trips and the large increase in rented static caravans may show that customers are more prepared to rent a caravan or motorhome, rather than buy a vehicle due to the high purchase costs. The survey may also reveal there is a higher demand for static caravans rather than t, as a result of a higher perceived level of comfort and luxury.

The survey also found that the value of the UK domestic towed caravan market has increased by 6.6%, whilst the rented static caravan holiday market increased further to 29.9%, the holiday market for owned static caravan holidays decreased by 3.4% (as shown in figure 29), as mentioned before and shortly below, the increase in the value of towed caravan UK domestic holidays maybe directly associated with the rise in petrol prices, causing the cost of travel to rise.

95

According to Mintel the “industry opinion suggests that high petrol prices are helping to reduce the numbers of trips taken and the mileage travelled by regular caravanners. Between 2009 and 2012 the annual average price of a litre of petrol rose by 36% (as shown in figure 3). The first quarter of 2013 saw a further 7p per litre rise in the price of unleaded petrol, reaching 139.9p in March 2013.” This may adversely affect the decision making process of UK caravan and motorhome holiday consumers when deciding on a location, as destinations considered far away maybe believed too costly to reach.

Motivations Mintel research on the attitudes of camping/caravanning holidays with UK consumers (as shown in figure 10) reveals that the top motivation for taking such a trip is being in nature, with just under 7/10 believing the form of holiday is “great for spending time outdoors and feeling closer to nature”, this could indicate that products aimed at this market should focus on the beautiful landscape within the destination or even offer activities related to nature, such as hiking, cycling & coastal tourism.

96 The second largest motivation for taking a camping or caravanning holiday with consumers was being with family, as just under 6/10 felt “they’re great for bringing the whole family together”, this could imply that future caravanning products should specify the safety and security of the park area, and again promote unique activities for young families which focus on togetherness and nature such as beach picnics, rock pooling and glen walks.

The third largest motivation with consumers is price, with 56% agreeing “they offer great value for money”, this may be linked with a further 45% who believe “camping & caravanning are ok for an extra break but not for a main annual holiday” and 44% who say “they are fine for a short break but not a long holiday”, Indicating that the overall market aren’t willing to spend a large amount of money on a camping or caravanning holiday and are more motivated for short stay trips, therefore products aimed at this market should promote free activities such as those experienced in nature i.e. walking, cycling.

The fourth largest motivation by 55% of consumers is that “camping/caravanning gives you a real sense of freedom”, this shows that just over half of UK consumers wish to feel a sense of detachment from modern society whilst they take such a trip, which could again relate to the idea of feeling closer to nature. Future caravanning products could identify this motivation by offering a sense of exclusivity within their sites to customers, and creating a more traditional/natural product.

The data also reveals that 36% of consumers believe “caravans/mobile homes are fine but camping is a step too far”, and a further 31% believe both are “too basic for a good holiday”, demonstrating that some consumers wish to feel a sense of comfort whilst taking such a trip, therefore should offer an element of luxury.

In brief Mintel says “those who take static caravan holidays are especially likely to value the family bonding potential of holidays, whilst those who holiday with a towed caravan are the most likely to value the sense of freedom of these holidays, those who have been camping in a tent over the past three years are more likely than caravanners to agree ‘they’re fine for a short break (eg 1-3 days) but not for a longer holiday’.

97 When looking at the facilities camping and caravan consumers would pay extra for at sites (as shown in figure 9), Mintel research revealed that; almost 1/2 of consumers would be most willing to pay extra for private toilets, showers or bathroom facilities, 43% would require an electric hook-up within accommodation, 37% would want an on-site restaurant and 32% would pay extra for an on-site swimming pool.

In terms of the active market, 23% of respondents revealed within the survey they would be willing to pay extra for cycle hire facilities, and a further 17% wish for other sporting activity facilities. This represents there is a potential to promote active tourism to this market, aligning with current Isle of Man tourism initiatives.

Market Needs The report by Mintel examines that “C2s, Ds and Es are more likely to holiday in statics than in tents, reflecting their preference for a more packaged type of holiday park experience where the focus is on park activities and facilities more than exploration of the surrounding area. At the more developed end of the holiday park spectrum, these breaks overlap with the traditional holiday centre experience provided by Butlins or . Where resources are available, smaller holiday parks can best compete in this space by offering, where possible, an indoor pool and an entertainment programme. Mintel’s research shows that 40% of campers/caravanners with children would pay extra for a site offering an indoor pool, and almost a quarter would pay extra for a site offering children’s entertainment or kids clubs.”

“ABs (and to a lesser extent C1s) have a clear preference for camping over static caravans, reflecting an independent, outdoor, active holiday ethos, but ABs are more likely to be attracted to more premium forms of static caravan holiday – for example lodge parks, often in rural/forest settings. To some extent the forest lodge park and holiday centre sectors also intersect in the Center Parcs experience, the holiday centre brand with the clearest ABC1 demographic. There is a market opportunity for forest lodge parks offering outdoor activities (and perhaps in a position to invest in some indoor facilities) to compete more in the Center Parcs space, albeit on a smaller scale, offering a more intimate and less holiday centre-type atmosphere.”

98

In general research shows that static owned caravans are most likely to travel for short breaks than longer holidays – 60% of trips were 1-3 nights in 2011, whereas towed caravan usage is the most mixed – 48% of trips were 1-3 nights long in 2011, rental statics are the most likely to be used for longer holidays. Some 71% of trips were 4+ nights long in 2011. Research also shows the most popular months to take a camping or caravanning trip are April to October with 94% of nights being spent during those months.

Sustainability Mintel says in terms of camping and caravanning holidays “almost seven in ten adults agree that ‘they are great for spending time outdoors and feeling closer to nature’. As contemporary life becomes ever more urbanised and mediated by technology, many people experience some of their closest connections to the natural world as tourists. For parents of ‘screenagers’ in particular, the outdoor life of a camping or caravanning holiday can be an attractive antidote. Some UK tourism authorities (such as Cumbria) are aiming to raise the appeal of domestic holidays to a younger generation brought up on cheap overseas travel, by trying to reposition themselves as adventure tourism destinations. These active ‘back to nature’ aspects are strong cards for the camping/caravanning market to play – such holidays feel much closer to the natural world and the great outdoors (despite the disadvantages of weather that entails). At the more extreme end of the spectrum, there is the potential for more off-grid trips to the remoter ‘wild places’ of Britain and continental Europe.

“But should camping or caravanning be promoted as explicitly ‘green holidays’? Over 600 UK holiday parks, for example, have won David Bellamy Conservation awards for their work in wildlife habitat management, energy use and recycling. It is unlikely that many consumers will choose a camping/ caravanning holiday specifically for reasons of sustainability. A sustainability approach can, however, help to enhance and sell this style of holidaying by emphasising the connection with the local destination. Holidaymakers are more likely to choose sites where localism and sustainability translate directly into a better visitor experience, for example by partnering and promoting regional produce such as offering organic breakfasts for campers – especially now food provenance is of more interest to consumers than ever in the wake of the horsemeat scandal.”

“Site operators targeting an eco-conscious, perhaps younger, following can also offer green discounts for those arriving by train or coach, promoting local transport use and cycling in partnership with local tourism boards, particularly in car-congested ‘honeypot’ areas.”

Price According to Mintel “in terms of spend per night; in 2011 people spent £41 per night on static rental trips, £37 on camping trips, £31 on towed caravan trips and £27 in owned statics. All of these forms of accommodation are significantly cheaper than the overall domestic holiday average of £62 per night. But despite the ongoing stagnation of the economy and decline in real terms of household spending power, camping and caravanning holidays have not managed to reap much reward from their status as budget holidays, with the exception of 2009.”

“It may be that many people see these trips as playing second fiddle to a ‘proper holiday’. Mintel’s research shows that nearly half of adults agree that ‘camping/caravanning is OK for an extra break but not

99 for your main annual holiday’. The budget message is very important, particularly for those who are excluded from other holiday types for financial reasons – likely to be a growing group in the current climate of austerity. Budget domestic camping trips can be promoted as the most affordable holidays for those on low incomes. Groups who are often less able (for financial and other reasons) to go on holiday include single parent families. TGI data shows that, during the 12 months ending June 2012, almost half of single people living with children aged under nine (mostly mums) did not take a holiday.”

“At the same time, for many consumers, an association with being ‘cheap and cheerful’ may be unhelpful. Better perhaps, to cultivate an aesthetic based around ‘simple pleasures’ and the uncomplicated enjoyment of free natural resources (fresh air, woodland, sea, etc.), subtly communicating the affordability of camping and caravanning. At the same time, the advantages of buying a towed or static caravan outright can be more explicitly trumpeted: these trips cost half as much per night as the average domestic holiday, perhaps enabling people to go away twice as often.”

The Mintel survey found (as shown in figure 30) that the estimated expenditure on UK domestic towed caravan trips has increased by 9.7% during 2007-2011 to an average of £147 per trip, rented static caravans have also marginally increased by 0.5% to an average of £212 per trip, expenditure of owned static caravans have decreased by 4.9%.

Market Demographics Mintel describes within its report that “holidays taken in static caravans have less of a youth orientation and are more likely to attract a broader spread of those aged 25-54, peaking amongst those aged 35-44 and families. Static caravan holidays have a C1/C2 peak with a slightly lower proportion of ABs.”

“The distinction between different accommodation types is less about budget than holiday type preference. ABs (and to a lesser extent C1s) have a clear preference for camping over static caravans, reflecting an independent, outdoor, active holiday ethos; C2s, Ds and Es are all more likely to holiday in statics than in tents, reflecting their preference for a more packaged type of holiday park experience where the focus is on park activities and facilities more than exploration of the surrounding area. At the more developed end of the holiday park spectrum, these breaks overlap with the traditional holiday centre experience provided by Butlins or Pontins. ABs are more likely to be attracted to more premium forms of static caravan holiday – for example lodge parks, often in rural/forest settings. To some extent the forest

100 lodge park and holiday centre sectors also intersect in the Center Parcs experience, the holiday centre brand with the clearest ABC1 demographic. There may be a market opportunity for forest lodge parks offering outdoor activities (and perhaps in a position to invest in some indoor facilities) to compete more in the Center Parcs space, albeit on a smaller scale, offering a more intimate and less holiday centre type atmosphere.”. “Stays in towed caravans show a fairly even age spread and, unlike other camping and caravan holidays, do not taper off in the over-55 group.”

UK Holiday Parks Mintel says “the leading operators of holiday rental parks (by number of sites) are Park Resorts, Haven (the largest in terms of revenue and customers), Parkdean and Park Holidays (as shown in figure 4). The larger corporate groups dominate the market for holiday letting, and their sites typically offer a wide variety of holiday facilities and services.”

“However, the vast majority of UK holiday parks are smaller sites owned by local operators. These sites typically offer relatively few opportunities for static caravan holiday letting and earn most of their revenue from touring pitch fees for camping and caravanning and static caravan sales. They tend to have more basic amenities, though these can still vary significantly.”

“The largest networks of smaller sites are owned by The Caravan Club (200 sites) and the Camping and Caravanning Club (110 sites plus 20 sites under its Camping in the Forest brand). The Camping and Caravanning Club has recently invested £29 million in a five-year plan to redevelop its network by 2015.”

“Due to planning constraints the supply of available UK camping and caravanning pitches has remained relatively static for many years. Although there is little land available for new development, there is a trend in some rural areas towards diversification away from a declining agricultural sector, with more farmers seeking to develop alternative revenue streams, including tourism-related businesses such as small campsites offering local/organic food and services”

101 102

Appendix 7 E-mail dated 8th August 2014 from Mr Mike Kelly, Isle of Man Post Office

103

104 From: Mike Kelly Sent: 08 August 2014 09:54 To: Jonathan King Subject: RE: Towed caravans and postal addresses

Dear Jonathan

I would like to thank the Select Committee for consulting with us on the issue.

The Post Office would treat a non-residential caravan park in a similar way to existing campsites. As long as there was a registered address within the postcode system, we would deliver any mail addressed to an individual care of (c/o) the park to a central point. This is usually the site reception or office. Onward distribution of mail to short stay residents or return of uncollected mail would then be the responsibility of the park operator and the scope of service provided after the Post Office had completed the initial delivery would be at the discretion of the individual park operators.

In practice, we believe because of the short term nature of the stays, a mail service is not one which would be widely called for or used. History shows that the small volume of mail addressed to visitors at campsites mainly consists of “suitcases” posted to bikers during the motor cycling festivals. Caravan users should not have the same transport restrictions on their luggage.

Post Offices around the world offer a “Post Restante” service for genuine travellers with no fixed abode in the destination area and can have mail addressed to themself c/o the local Post Office. This mail is held on receipt for a specified time pending collection. This is a service we provide already and may be appropriate in the circumstances under consideration.

Because of the transient nature of residency, a postal service beyond that outlined would not be possible.

I hope the Committee will find this information helpful in their considerations and please do not hesitate to contact me if they wish further information.

Kind regards

Mike

From: Jonathan King Sent: 07 August 2014 16:44 To: Mike Kelly Subject: Towed caravans and postal addresses

Dear Mr Kelly

I am writing on behalf of the Select Committee of Tynwald on Towed Caravans. This Committee was established in June 2014 with a remit to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park and the need for regulating the entry on to the island and usage of caravans.

The Committee would like to know please what is the Post Office’s approach to the use of a towed caravan as an address? If a person asks for post to be delivered to a towed caravan in a particular location, does the Post Office accept this and are there any formalities attached to registering a new postal address?

105 The Committee next meets on 13 October so a response by 6 October would be much appreciated.

Many thanks.

Jonathan

Jonathan King Deputy Clerk of Tynwald and Clerk of the Legislative Council Legislative Buildings, Douglas, Isle of Man IM1 3PW

106

Appendix 8 E-mail dated 8th August 2014 from Mr Jim Rowles, Director of Planning, States of Guernsey

107

108 From: Rowles, Jim Sent: 08 August 2014 15:35 To: Jonathan King Cc: Smith, Steve - Env Subject: Towed caravans in Guernsey

Dear Jonathan,

Your email has been forwarded to me for response and I hope the following information is helpful.

In the 1960s and 1970s there was concern about the possible development of caravan sites on the Island, based primarily around the potential impact of such development on the natural beauty of the Island and the potential traffic issues, having regard to the small scale of the Island, the particular environmental sensitivity of its rural and coastal areas and the restricted nature of its road network. I believe that there were also concerns about possible residential use of caravans and difficulties of controlling such use, in the context of otherwise quite strict housing controls. These concerns led in the 1970s to amendments to the then Planning legislation, the Island Development (Guernsey) Laws, to bring caravans within planning control. The planning definition of ‘caravan’ included both trailer caravans and motor homes.

In 2009, the Island Development Laws were superseded by the current planning legislation, the Land Planning and Development (Guernsey) Law of 2005.

Under both Laws, the general policy position until fairly recently was that although visitors (and indeed local residents) could bring motor homes to the Island, they were not allowed to sleep in them. However, it was increasingly recognised that this was not a sustainable approach, and a scheme was recently developed in conjunction with three local campsites to allow a limited number of visiting motor homes to be accommodated through the tourist season. This scheme does not however include trailer caravans, and this restriction was agreed by the campsites concerned at an early stage in developing the scheme.

The upshot of this is that although not actually banned, trailer caravans are rarely brought to the Island. However motor homes, although still not especially common, are now welcomed as a form of tourist accommodation, albeit in a fairly limited way consistent with the scale of the Island.

The scheme referred to above operates successfully and with positive feedback from the campsite operators. I am not aware of pressure for trailer caravan facilities on the Island. This may partly be due to the relative costs of ferry travel.

I hope this is of interest and assistance.

If you would like any further information please do not hesitate to contact me.

With kind regards, Jim

Jim Rowles Director of Planning

Environment A States of Guernsey Government Department

109 From: Jonathan King Sent: 07 August 2014 16:41 To: Nicolle, Adrian Cc: Library User Subject: Towed caravans in Guernsey

Dear Adrian

I hope you will forgive me using you as a “postbox” and I would be grateful if you could direct this query to an appropriate person in Guernsey.

I am writing on behalf of the Select Committee of Tynwald on Towed Caravans. This Committee was established in June 2014 with a remit to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non-residential caravan park and the need for regulating the entry on to the island and usage of caravans.

The Committee has been advised that towed caravans are not allowed in Guernsey. The Committee would be grateful for further information on why this is? When was the current policy put in place and what was the rationale behind the decision?

The Committee next meets on 13 October so a response by 6 October would be much appreciated.

Many thanks.

Jonathan

Jonathan King Deputy Clerk of Tynwald and Clerk of the Legislative Council Legislative Buildings, Douglas, Isle of Man IM1 3PW

110

Appendix 9 E-mail dated 17th September 2014, and attachment, from the Chief Constable

111

112 From: Roberts, Gary Sent: 17 September 2014 08:13 To: Jonathan King Subject: Towed caravans Attachments: towed caravans.docx

Jonathan

Further to your email of 7th August concerning towed caravans, please find attached a short report from Detective Inspector Dobbie, who is responsible for the roads policing unit.

The questions posed by the committee were particularly narrow and this is reflected in the short answers provided in the report. I think there is a broader issue: whether encouraging greater use of towed caravans would lead to complaints about caravan users setting up home on areas of , or indeed on privately owned land. It is reasonable to predict that towed caravans might easily become static caravans if owners were minded to try to live in them. Powers to move people in such circumstances would be very limited.

Gary

Gary Roberts Chief Constable Isle of Man Constabulary Police Headquarters Dukes Avenue Douglas ISLE OF MAN IM2 4RG

113 114

INTERNAL MEMORANDUM

To: Chief Inspector Drowley From: DI Dobbie Date: 12th September 2014 Subject: Towed caravans – Select committee question

Sir,

In relation to the questions asked about towed caravan use on the Island, I have the following observations.

Although the question asks about the response if the caravan was to be found abandoned, there are potential issues surrounding the general use of the caravans too.

There are regularly complaints registered with the parking of motor homes in and around built up areas on the Island. This issue has been ongoing for a number of years. The legislation that is used to deal with the majority of these issues is the Road Traffic (motor cars) (overnight and weekend waiting) regulations 2012.

The parking of trailers (a towed caravan would fall within this category) is covered under The Road Traffic Regulation Act 1985, which restricts the waiting of these vehicles on a restricted road in the following circumstances; (a) on a Saturday or a Sunday; or (b) before 7.00 a.m. or after 6.00 p.m. on any other day This obviously raises concerns that if there are insufficient designated parking areas for the caravans, whether they are attached to the towing vehicle or not, more complaints will be received by the Police in relation to the inappropriate parking of these vehicles.

In relation to the situation of an abandoned caravan on a highway, I cannot recall or find any incidents where this situation has arisen. However, if this situation was to occur, then the process for dealing with this would be similar to the method in which abandoned motor vehicles are dealt with.

If a motor vehicle is located on the road and is abandoned, it is normal that attempts are made with the last known owner to arrange the removal of the vehicle. Depending on the circumstances, further action in relation to offences will be considered. However, when attempts to trace the owner prove fruitless, the vehicle is referred to the Department of Infrastructure, who place a notice on the vehicle. After a period of time, the vehicle is then removed by that Department.

115 In cases where a caravan was abandoned other than a highway, the process for dealing with this is similar to the situation with motor vehicles being abandoned on a highway, the Department of Infrastructure will deal with it. Unlike the previous situation, the Police will not investigate these matters, unless there is a criminal allegation into the vehicle.

I hope that the above clarifies the potential issues that the Police may face. There are potential other issues in relation to the traffic management around a dedicated non-residential caravan park, but without further details of where this / these would be planned for, it is difficult to make comment.

Detective Inspector Dave Dobbie

116

Appendix 10 Presentation submitted on 1st July 2014 by the Isle of Man Steam Packet Company

117

118 IoM Steam Packet Company Submission to Select Committee on Towed Caravans July 2014

119 Introduction - ‘Visitor Economy’

 Dramatic tourism decline in 1970’s/1980’s  Modest growth in tourism since 1992  Growth of ‘Short Breaks’ and ‘Special Events’  Tourism helps to diversify economy – over £100m annual spend, plus supports wider economic development  Uncertainties about traditional finance sector  Government financial constraints, reductions in marketing spend

120 Steam Packet Company services  Improved speed, capacity, frequency of sea service - capacity around twice that of 1996  Steam Packet passenger carryings up by c. 30% since 1996, vehicles up by c. 50%  Latest £20.0 million investment Manannan 2009  Substantial reduction freight income since 2010 period of Mezeron competition  Reduction 50,000 sea passengers to air (but NO overall market growth) in last 3 years. Future maintenance of, and investment in, services needs passenger growth

121 Passenger sailing frequency 1948-2013 Sailings per annum

1200

1000

800

600

400

200

0 1948 1958 1968 1978 1988 1998 2013

122 ‘Visitor Economy’ today  £100 million spend but significant decline in hotel capacity; DoED recognise need for accommodation investment  Relatively low numbers visitors staying 7 or 14 nights  Meanwhile the Island is completely ignoring 25% of the tourism market:

THE TOWED CARAVAN MARKET!!

 Currently no laws preventing/controlling Caravans (see later)

123 New market potential (1)  What could the controlled development of the touring caravan market be worth to the Isle of Man?  100 pitch caravan park would bring:-  Over 8,000 extra tourists to the Isle of Man  Additional spend of over £3.0 million p.a.  Tax revenues to IoM Government of £500,000 p.a.  Diversification of economy

124 New market potential (2)

 How would this new market potential be sourced and contacted?  Easily targeted market in the UK through the Caravan Club, Camping & Caravan Club and caravan magazines  Could be promoted also by SPC Holidays, Regency Travel (TT/FoM period) and others

125 The Caravan Club in the UK

 Represents the interests of over 1,000,000 caravan owners (members and families)  Three quarters of CC members are from the upper or middle social grades  Many take 7 or more caravan trips per year  Over 20% tour abroad annually  Many of interests and activities enjoyed are actively promoted now by IoM

126 Island-wide beneficiaries

 Government – enhanced tax receipts  Steam Packet Company – utilise spare capacity  Island-wide businesses / service providers:-  Restaurants, hotels and bars  Public Houses  Shops and retail outlets  Museums and National Heritage sites  Visitor attractions

127 Current caravan controls

 No legislation preventing travel/short stays  A long-standing unwritten ‘gentleman’s agreement’ is in place between SPC and DoI regarding the importation of caravans  SPC takes a return booking, and payment, on request for a caravan BUT advises DoI consent must be gained and provides contact details  SPC has no basis on which to refuse to transport a caravan so is acting as an ‘unofficial gatekeeper’  SPC do not monitor consent received or removal

128 The Island’s concerns

 Let’s look at islanders’ possible concerns about this potential new market…

 Road congestion ?  Competition for hotels ?  Negative impact on the environment ?

129 Would there be road congestion?

 Over 50,000 registered vehicles in IoM  Approx. 750,000 journeys/week  One park would only generate on average 100 caravan journeys/week  Journeys primarily off peak if mandated(06:00 arrival)  DoI new legislation could be introduced to permit short stay caravans only on approved sites using approved access routes

130 Road congestion (2)

 Caravan journeys would only be to and from the Douglas Port, subject to DoI licensing  Steam Packet could assist with new licensing arrangements by issuing maps/short stay documentation at check-in  Caravans would be parked at an official park and cars would be used for touring the Island. In contrast IoM does allow motorhomes which do create some extra road traffic

131 Competition for hotels ?

 Caravan owners investing over £10,000-£20,000 in a caravan do not stay in hotels anyway so no loss to hoteliers  If caravan owners aren’t allowed to bring their caravan here, then they will not come to the Island - they will seek an alternative destination which welcomes them

132 Competition for hotels ? (2)

 This would be NEW business for the Island  Steam Packet has exactly the same requirements as Island hoteliers - it wants new business, not abstracted business  Island doesn’t have sufficient accommodation for many events  Island has 1,700 fewer beds than 10 years ago  DoED policy to encourage extra beds

133 Competition for hotels ? (3)

 Steam Packet has doubled frequencies and increased capacities - it needs new traffic  The Island needs more visitors and more accommodation  Island tourism should only gain - increased spend in hotels, bars, attractions etc  Caravan visitors will recommend the Island and encourage more visitors  Supported by IoM Chamber of Commerce

134 Perceived environmental impact

 Well screened caravan park will be hidden  We have all seen ugly UK sites - but the good ones are never seen!  No-one wants an unattractive eyesore - least of all Steam Packet which depends on tourism  Island can ensure any caravan park is first rate  Caravans will be left in the park for their limited stay

135 So what should a park look like?

 The UK has many caravan parks in areas of outstanding natural beauty  Well screened parks are welcomed in UK  Correctly screened parks can be an asset for local residents, not an eyesore

136 Examples of UK caravan sites

 Coniston, Lake District  Chatsworth  Peak District

137 138 139 140 141 Island site requirements  Well screened, perhaps by trees, shrubs etc  Valley location perhaps - with good road access, and preferably close to the port  Ideally some camping space for special events?  Site would require first rate amenities and play facilities - follow UK best practice  For touring/towed caravans, not ‘static’

142 Conclusions

 Congestion will be non existent/minimal  Licences would provide control  Environmental impact should not be a concern  8,000 extra visitors  Over £3.0 million spend annually  We can all control the carriage of caravans in the Island’s best interest  For further info on Caravan Club and benefits to UK tourism see www.caravanclub.co.uk

143 144

Appendix 11 E-mail dated 10th July 2014 from Mr Martin Stringer, Caravan Club of Great Britain

145

146 From: Martin Stringer Sent: 10 July 2014 12:28 To: Jonathan King Subject: Re: Towed caravans: request for written submission

Dear Mr King

Thank you for your email to The Club dated 19 June. Unfortunately our ‘Enquiries’ department forwarded it to a member of staff who was away on leave and it came to light only this week, hence this is a rather hasty response when perhaps a more in depth reply would have been preferable. That said, we are not entirely clear as to what you are expecting The Club to submit in response to the resolution that was passed on 17 June.

From a specific Club perspective, we have 355,000 full members across the UK and Ireland, which is getting on towards 1 million people when taking into account other family members. Our members are predominantly caravan and motorhome users. We also welcome members who have trailer tents, but not those engaged in mainstream camping. We do have some members (in the hundreds) who are resident on the Isle of Man, but more research would be required in order for us to ascertain their caravanning activities. I daresay that they are owners of motorhomes, unless they keep caravans off Island for use elsewhere. We operate and manage nearly 170 of our own caravan sites across England, Wales and Scotland, but also have some commercial sites that are affiliated to The Club, which brings the total to more than 200 across the UK. In an average year, we ‘sell’ around 2.5million pitch nights, all of which serves to demonstrate the significant contribution that we make to local tourism economies, when the off-site spend by our members can be in the order of £40 per day.

In addition to these sites, The Club ‘licences’ Certificated Locations (CLs) under our exempted status, e.g. the exemption certificate granted to us by Natural England under the 1960 Caravan Sites and Control of Development Act. We have approx, 2,500 of these small sites on our books that are managed and run by the owners. Many are on farms and are allowed to have a maximum of 5 outfits (caravans/motorhomes) on site at any one time. Whilst we advertise the sites to our members, all bookings are made directly with the CL.

The Club also operates a travel service for members, selling ferry crossings and pitches on overseas sites. We work closely with ferry operators, although have no particular relationship with the operator of the routes to the Isle of Man. This brings me onto a key point about any decision you may make to develop caravanning activities. On the assumption that you are considering inbound, rather than domestic tourism, the availability of ferries and, most importantly, the cost of those ferries will be a key factor. You have only to look at the cost of Irish Sea crossings to Rosslare, and Belfast to understand the negative impact on caravan tourism brought about by the high cost of travel. This certainly needs to be factored in to any business case for establishing a non-residential park, which will not be a cheap development given the standards of facilities expected by caravanners. Recent developments carried out by The Club have been in the order of £2 million excluding costs of land, although will vary depending on the number of pitches. Seasonality will also impact on the financial viability depending on the length of a site’s opening season. As for the roads on the Isle of Man, at this stage it is impossible for us to comment on their suitability or otherwise for caravans. Our limited knowledge of the infrastructure on the Island suggests that you would need to regulate entry onto the Island. Without doing so, you might be in a situation, for example, with motorhomes engaging in ‘wild camping’ activities, which is not something that we as a Club support.

The Caravan Club has a considerable depth of knowledge in the sector and would be happy to offer further advice, but would appreciate some more specific questions and objectives.

Yours sincerely

Martin Stringer

147 Martin Stringer Executive Secretary THE CARAVAN CLUB

www.caravanclub.co.uk

From: Jonathan King Sent: 19 June 2014 17:16 To: Enquiries Subject: Towed caravans: request for written submission

To: Caravan Club of the

Tynwald, the parliament of the Isle of Man, has established a Committee to look at the use of towed caravans in the Island. Further information about the Committee including its full remit is below. I am writing to invite the Caravan Club of the United Kingdom to make a written submission to the Committee. If the Club would like to make a submission this should be sent to me by Thursday 10 July please.

It was resolved in Tynwald on 17th June 2014:

That a Committee of three Members be appointed with powers to take written and oral evidence pursuant to sections 3 and 4 of the Tynwald Proceedings Act 1876, as amended, to consider and to report to Tynwald about the likely advantages and disadvantages of encouraging towed caravan use on the Island, with special reference to the possibilities for the encouragement of tourism, the utility or otherwise of creating a non- residential caravan park and the need for regulating the entry on to the island and usage of caravans.

The Members elected to the Committee by Tynwald are Mr Geoff Corkish MLC, Mr Alex Downie MLC and Mr David Quirk MHK. The Committee has elected Mr Downie as its chair.

Many thanks.

Jonathan

Jonathan King Deputy Clerk of Tynwald and Clerk of the Legislative Council Legislative Buildings, Douglas, Isle of Man IM1 3PW

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Appendix 12A Submissions from members of the public in favour of caravans

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SELECT COMMITTEE ON TOWED CARAVANS Responses to public call for evidence: full text Submissions received are unedited except for the removal of personal details

Appendix 12a

Submissions in favour of caravans

Submissions Bayley, Alastair ...... 1 Boyle, Liam ...... 1 Brindle, Irene...... 2 Brown, Sandra ...... 3 Callister, Adrienne (1) ...... 3 Callister, Adrienne (2) ...... 4 Elliott, John...... 4 Gelling, Kevan ...... 5 Kelly, Mike ...... 7 Miller, Carrie & Les ...... 8 Norton, Tim ...... 8 Oates, Bob & Maureen ...... 9 Phoenix, Allan ...... 9 Pollock, Alexandra ...... 11

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Bayley, Alastair From: ABR Moto Sent: 10 July 2014 16:56 To: committees Subject: Caravans on IOM Hi, Just a very quick note as only just seen this. You are missing out on a lot of tourism by restricting caravan travel to the IOM, but also wasting money on the planning permision hoops needed to get over, I understand it keeps out the gypsy elerment and fault you on that. But main problem is the ferry prices, needs to be looked at to get cheaper rates, very caravan on say a 2 week holiday will spend say £1-2000 on a stay on the island, worth few quid over a year even if you get 30 caravans a week over. Ferry pricing full stop need looking into. I race and holiday on the IOM but cant afford to holiday with caravan, cost me £1400 to get car and caravan over for TT last year, thats a joke!! regards Alastair Bayley Boyle, Liam From: liam boyle Sent: 07 July 2014 17:35 To: committees Subject: Towed Caravans Dear Sir or Madam, I’ve lived on the Isle of Man all my life, born and bred and have watched the character of transportation, tourism and leisure activities diminish, evolve and change over the years. It is the nature for things to change or even die. Some of us resist it irrationally and blindly at first, but we always adapt and accept in the end, we have to. Every day I drive on the Manx roads and I have no problem sitting in a queue of twenty or more cars following a public bus with little or no people on it or be trapped behind a horse tram on Douglas promenade – but honestly, what is the rush? Our buses naturally restricts the speed of most cars anyway already at rush hours, the school run, whatever. Given the narrow nature of most of our roads there are very few overtaking places. My point is that we accept that when we are behind a bus, we are following its timetable and we do it without question or fuss right now. I don’t believe any towed caravan would be as slow as our buses and just yesterday I followed one going my way from Douglas to the airport which did not exceed 28 miles per hour for the entire journey.

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The pace of life on the Island is, shall we say, gentler and I think sedate calm caravanning to enjoy our beautiful countryside is a great plus along with gentle electric and steam railways and buses. Numbers will naturally be controlled by market forces anyway via the cost of the ferry too by supply and demand economics. I do not own nor have I ever towed a caravan. I have at one time had a camper van though and can say that it never held sensible drivers up in traffic here or on the motorway. A caravan is just a box of air, not a slow juggernaut or a ten ton bus. Most modern cars have easily got the horsepower to pull a caravan at least as fast as a bus. The only people likely to take issue with caravans – aside from the die-hard Clarkson fans out of reflected angst – are people who generally drive too fast anyway. Caravans are an easy target for vocal minority of bandwagon self-proclaimed aficionados who so expertly and ruthlessly shoot down every suggestion or new thing that comes their way – they are the digital luddites of the digital era. I suggest caravans would be a healthy addition to our roads and a cheap traffic calming measure. Some planning might be required to control where caravans pitched of course and some more sites may be needed but say for example - given the scale of the destruction caused by ash dieback, what about our plantations - I’m sure we could accommodate a few hundred caravans somewhere. Why don’t we have a trial period, see how it takes. Don’t worry about ‘travellers’ that’s just mischievous scaremongering, the cost of the ferry will filter potential abusers out. I hope these unbiased words add some value to this discussion. Yours sincerely Liam Boyle Brindle, Irene Dear Sir Please don’t dismiss caravans just yet. Some forty plus years ago my husband and I bought a static caravan in the South Lakes. Our children aged four and five spent many years coming and going there. Meeting and socialising with the locals – attending local sports days and markets etc. - visiting local attractions and over the years spending lots of money dining in the local pubs and restaurants, and spending money in the local good quality gift shops and clothes shops. We then had another son who also liked the caravan scene. All three children have travelled the world and had wonderful ‘high end’ holidays. During the past twelve months two of them have purchased caravans in the South Lakes with their children and my daughter bought a camper van for her – her children and grandchild. My husband & I have also followed suit and bought one. They have all owned towing vans at some stage. Drivers who don’t have patience to follow a caravan won’t have patience to follow a bad driver or a bus, lorry, or tractor. Maybe they should learn. Please give it a chance. With hope Irene Brindle

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Brown, Sandra From: Sandra Brown Sent: 02 July 2014 10:46 To: committees Subject: Caravans on the island With regard to towed caravans being allowed on the island, with certain restrictions being put into force, I think it would be a major step forward in boosting tourism to the island. Restrictions on very tight country lanes etc could easily be enforced. Though most of the roads on the island are good and can be accessed by lorries - so I don't see a problem. Parking the caravans on sites accessible only from the main roads, so as not to cause traffic jams, and a rule that they must not be allowed to park anywhere other than a registered camp site. I suppose the only big hurdle would be the ferries and space available on them. Why not contact the caravan club of GB to see what sort of response in terms of numbers wanting to visit that you are likely to get? Sandra Brown Callister, Adrienne (1) Dear Mr Quirk, Mr Downie and Mr Corkish, As the press has stated that you are accepting people’s thoughts regarding the proposal to allow caravans on the island, I am writing to let you know the views expressed by myself, and other Manx born folk who now live in England. I left the island to train as a teacher in 1970. It was always my intention to return, now retired, I am desperate to ‘come home’ but grandchildren ties in England have not enabled this...yet! However we have caravanned all over the UK and Ireland for the past 30 years. Last week we returned from 4 weeks in . How I would love to to make regular caravan trips to the island. At present we come over once a year, usually towards the end of September, and can only afford to stay for a week in a cottage, cost about £400. This sum would pay for over 3 weeks if we could bring the caravan, at about £15 per night out of high season. Caravanners certainly contribute to the local economy. Mainly by using local shops and supermarkets, buying petrol, pub-lunches and eating out in general, visiting the theatre and cinema, visiting sites of interest and culture, especially the brilliant museums. Contrary to opinions expressed on Social Media sites, we do not bring all our food with us! That is impossible for a lengthy stay, and if folk pay the boat fare to the island, they will probably wish to stay for at least 2 weeks. I understand the opinion, expressing concern, regarding caravans on some narrow roads and accessibility to camp sites. However to remedy this I suggest that caravans are limited to travelling on the ‘midnight’ boat, arriving on the island about 6-00 a.m. that gives the driver at least an hour to reach the designated caravan site, before the locals set off for work.

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The site area would have to be pretty flat, and not too far from Douglas, Peel or Ramsey, to access local shops. Perhaps somewhere in the Port Soderick area. Tromode would be perfect, but I doubt if locals would accept that. Somewhere quiet. Jurby way? Or is that too far from the boat? Knackaloe, with it’s internment camp history would also be ideal. Being guided by the Caravan Club of GB is a great idea. We only use their sites as their facilities are always clean and well run. They allow dogs, which is also vital for economic success, as many ‘out of season’ caravanners are retired, with dogs. Out of season visitors would make a tremendous boost to the Manx economy. I can’t imagine a better place for a holiday than the Isle of Man. So many of my English friends have heard me praising the island’s beauty in the Spring time, it’s culture, and way of life. However once they start looking into visiting themselves they are put off by the two costs....the boat, then the cost of hiring a cottage, or a week in a hotel. Our trip to France cost us the shuttle fare, petrol and site fees. You have to buy food and essentials wherever you are. Hopefully a caravan trip to the island will be just the same in the not too distant future! I am so pleased that you are looking at this proposal, we know people are generally living longer, and look for a hobby in their retirement years. Many folk buy caravans, and spend their time exploring new shores. There is a wealth of tourists here ready to be ferried to the island. I long for the day I can bring my two sets of grandchildren over for a long spell, to see and enjoy the land of my birth. My Best Wishes to you regarding this project, I do hope you are successful. Yours sincerely Mrs Adrienne Callister (nee Quayle) Callister, Adrienne (2) Dear Sirs I contacted you about 5 weeks ago regarding touring caravans being permitted onto the Isle of Man. My husband has recently forwarded this Isle of Wight advert from the Caravan Club, and I think that you might find it interesting, in relation to similar advertising for the Isle of Man, hopefully in the not too distant future. https://www.youtube.com/embed/YUiV7SQ_gu8?rel=0&fs=1&autoplay=1&enablejsapi=1&origin=ht tp://www.caravanclub.co.uk Kind Regards Adrienne Callister Elliott, John From: John Elliott Sent: 29 June 2014 21:53 To: committees Subject: Towed Caravans

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Sirs. I note from the "Isle of Man Courier" that you invite people to share their views on the use of towed caravans on the Isle of Man. I declare an interest as the owner of a touring caravan, although I store it in England just outside Lancaster and only use it in the UK and on the continent. My opinion is that touring caravans could be allowed on the island and would certainly pose less of a problem than the numerous camper vans that are already on or visiting the island. My reasons are as follows:- Towed (touring) caravans would arrive by the Steam Packet and immediately be towed to a caravan/camp site where they would be left for the duration of the holiday. The owners would then be able to visit the attractions of the island in their own cars. They would leave the island at the end of a holiday by being towed directly to the Ferry Terminal. This would mean that visiting towed caravans would only make two journeys on the island. On the other hand, campervans (regardless of size) can snarl up our roads willy-nilly, can and do park up in some of our wonderful beauty spots often spoiling the views for other visitors. They can and often do even park over night in some of our car parks regardless of regulations and rules. Please note Fenella Beach in Peel as just one example. A way of regulating both visiting towed caravans and visiting campervans is for their owners having to have booked into a recognised camp site before they can obtain a boat ticket for their vehicle. This does not, of course, solve the problem of locally owned campervans. I hope that my views could be of some help to the debate. John H Elliott Gelling, Kevan From: Kevan Gelling Sent: 10 July 2014 14:04 To: committees Subject: Towed Caravans comments Dear Sir/Madam, I'd like to provide some comments for the upcoming Select Committee on towed caravans. (I have been a caravan owner for 2 years. I brought the caravan to the Island once but keep caravan off-island now because of cost of the ferry). Isle of Man will not become a popular caravan destination 1. Travel Cost The cost of a caravan on the Steam Packet is very expensive. It effectively doubles the price of the ticket. 2. Facilities With the exception of Glen Wyllin, the campsites on the Isle of Man have very poor facilities. Most UK caravan owners are members of Caravan Club or Camping and Caravanning Club will be used to excellent facilities.

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3. Not Caravan Friendly Caravans cannot come on the Liverpool ferry because they cannot negotiate the gang-plank at low tide. Many of the Island's roads, such as the Douglas promenade, are in a bad state. Caravans will not be a road nuisance 4. Not towed around The caravan will be taken from the boat to the campsite and then left there for the duration of the holiday. Whereas a motorhome has to be driven from campsite to attraction whenever the tourist ventures out. The poor state of the Island's roads will restrict travelling too. 5. Not slow Towed caravans travel between 50-70 mph. This may be an issue on motorways but the Island does not have any motorways or dual carriageway roads. On the Island's roads, towed caravans will go as fast as motorhomes and faster than any tractors or other towed trailer. Caravan = Motorhome 6. Eyesore A caravan parked in the street or on a drive could be considered an eyesore. However, the same is currently true for motorhomes. I live on an estate for which the deeds state that motorhomes must not be stored on the driveway. Yet I have 2 neighbours who do just that. 7. Same rights Caravans should be treated the same as motorhomes. It is quite frankly ridiculous that caravan need a permit to board the ferry whereas motorhomes (or other towed trailers do not). 8. Scapegoat The myth that caravans are banned has led many to believe that somehow caravans are a bad thing. Tourism 9. Great Holiday I have camped, motor-homed, caravanned, hostelled, self-catered, 'B&B'ed and stayed in hotels. Caravanning is my favourite, especially combined with sunny weather and my children. The Isle of Man's tourist industry is not doing great. I don't believe caravanning will be the "next big thing" for the Island, but every little helps. Over-regulating caravans will make the Island look parochial and out-of-touch. Summary I'm a firm fan of caravanning so I was disappointed to hear many of the comments from MHKs in Tynwald. I suspect many have a) never caravanned, and b) watched too much Jeremy Clarkson. Caravans are no different to motorhomes and regulation, if required, should be applied to both equally. Regards, Kevan Gelling

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Kelly, Mike From: Mike Kelly Sent: 29 June 2014 21:37 To: committees Subject: Caravans on the Island Hi, I would like to register my interest in the caravan debate Allowing Touring Caravans on Manx roads would open up the debate to allow for regulated camp sites to be created on the Island. This would be a boon for Farmers & land owners increasing their income and utilising unsuitable fields for farming etc. The sighting of these campsites would be subject to the usual planning permission as I'm sure they are in the UK and elsware. The idea that they would detract from the holiday trade existing on the Island is a nonsense as the people staying at a campsite would not have considered the option of a B&B or Hotel they are campers first & formost! I have owned Motorhomes for the past 6 years and living on he Island would never consider a towed caravan, mainly for the cost of getting across and the other reasons being put forward in the press already, however so long as the site access roads are wide enough for the 'van there shouldnt be a problem, after all once on site towed caravans usually stay-put for the length of the holiday and the folks can use their towcar to get around the Island. We take our van "across" a couple of times a year, when in the UK it is mandatory to pitch up at designated camp sites, we use the two most popular clubs to find suitable sites - The Camping & Caravaning Club [http://www.campingandcaravanningclub.co.uk/] and - The Caravan Club [http://www.caravanclub.co.uk/] Most of the club campsites offer pitch availability for Caravans, Motorhomes and Tents. Facilities on all sites include- Fresh water supplies, Grey water disposal, Chemical closet emptying points, Dry rubbish disposal. Facilities on some sites- Near public houses, Near beaches, Electric hook-up. On club sites the extra facilities can be extensive. What I would like to see is the Island open up to regulated camp sites franchised from the above clubs The great majority of campsites are small Certified Locations (CL) sites run by the land owner with facilities which are inspected by the club at regular intervals & published on the club website & in the club's handbook. The classic photos shown to degrade caravan sites are typically aerial shots of sprawling static caravans & Holiday Homes along headlands in Devon & when the truth is most of the touring sites are small well planned & tastefully laid out. I hope this gives you an idea of my thaughts. Best Regards Mike

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Miller, Carrie & Les Sent: 10 July 2014 13:13 To: committees Subject: Caravans Dear All I am a proud owner of a caravan living here on the Isle of Man, It is parked on my OWN drive and is used frequently for race meetings as my husband competes at Jurby and in the MGP. We also have weekends away at the one of the many camp sites on the Island which generates revenue, as we treat these weekend's as holidays and enjoy what the Island has to offer spending monies in the Islands restaurants and pubs, we also try to get away once a year via IOMSPC which again. I do think there is a 'Huge untapped Market' as many times we have been approached by campers from the UK saying they were unaware they could bring their Caravans to the Island. As for the comments regarding being stuck behind a caravan I don't think this differs from being stuck behind a bus or a DOI lorry. I hope to able to continue caravanning on the Island. Yours sincerely Carrie & Les Miller Norton, Tim From: Tim Norton Sent: 02 July 2014 00:32 To: committees Subject: Towed caravans Sir, I would like to express an opinion about the Government’s proposal to encourage towed caravan use on the Island. I do not have first-hand experience of towing a caravan, but I own a small campervan and a static caravan (park home) in Portugal, so I have some related experience. I have heard and read a lot of comments in the media and on internet forums about the likely disadvantages of encouraging towed caravan use on the Island. Many of these comments have used highly emotive language and they seem to be based on ignorance or prejudice. Predictions of doom - of the Island being flooded with caravans, of roads being blocked by irresponsibly towed caravans, of an invasion of gypsies/travellers, or of ugly high-density caravan parks (like they have in North Wales) – are scare-mongering and basically unhelpful. Let us face it - the high cost of transporting a car-plus-caravan to the Island will deter many people, so I do not foresee a massive influx. I personally do not have a problem with Island residents owning towed caravans, as long as there is legislation in place to prevent them being parked on the road in urban areas. I would also have no problem with visitors bringing towed caravans onto the Island, subject to certain restrictions – for example, they should need a permit to bring a caravan onto the Island, and

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this permit could be time-limited. They should have to use established campsites, and should not be able to “wild camp”. I would also support the establishment of a high-quality, low-density, discreetly located and well- landscaped campsite/park, certified by either the Caravan Club or the Camping and Caravanning Club, for towed caravans, motorhomes and static caravans. Fallbarrow Park, on Lake Windermere, is a good example of such a campsite. I believe that a superior campsite/park would attract the more responsible tourist, and could be a real asset for the Island. To summarise, I think that towed caravans should be allowed, if not actively encouraged, to come to the Island, with appropriate checks and balances At the very least this could be done on a trial basis, say, for three years. I would also like to see a top-of-the-range site established. Tim Norton Oates, Bob & Maureen From: Mr & Mrs R Oates To: [email protected] Dear Sirs Caravans on the Isle of Man We would like to put forward our view for bringing caravans to the Island. Nobles Park is an ideal site, it has electric hook-ups and shower and toilet facilities and with some upgrading could be brought up to the standards to be found on UK caravan sites. There is a park for children, a restaurant and cafe on site. There is also Glen Wyllin and Peel, both excellent sites. We have a caravan and when we go to the UK we park our caravan at our chosen destination for the duration of our holiday. We got out in the car, we certainly do not tow the caravan round with us. We shop in the local supermarkets, buy fuel, eat in cafes and restaurants and buy gifts etc in the shops. To say caravans would block the roads and landscape is utter nonsense as people bringing their caravans park up and leave it on site for however long they are here. It could be stipulated that caravans are to be sited on specific caravan sites, not on spare land, lay-byes etc. With a little thought put into this area of tourism much can be gained for the economy of the Island, jobs could be created for site wardens etc. Our Island has so much heritage, walking, golf etc to offer and we have often been asked why caravans are not allowed on the Island to which we reply but they are. Please do not dismiss the opportunity to bring and encourage caravanners to our lovely Island – think of all the “fors” and not the “against”. Obviously the TT period would have to be taken into consideration. We look forward to hearing further on this matter. Yours faithfully Bob and Maureen Oates Phoenix, Allan Dear Sir/Madam Consultation on Trailer Caravans being permitted on the IOM

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1)..Introduction I have a been a caravanner for the last 25 years, and would like to give my input from a caravanner’s perspective. When we moved to the Island 7 years ago, we left our caravan in storage in the UK and have used it for holidays over there. This suits us well as we can do everything we want to do on the Island without needing the caravan, and have somewhere to stay when we go across. 2)..Practicality issues relating to caravans on the IOM 2.1)...Towing, and Suitability of Roads In view of the significant number of narrow roads and steep gradients, it would be important for roads to be clearly classified as suitable or unsuitable for caravans, and clearly labelled. I think that it would also be advisable for people coming to the Island to be given a map showing approved routes, and warn about relying on Satnav. The Sloc road and the road from the Round Table to Dalby are good examples of roads which have a number of sections where it would be impossible for caravans to pass vehicles coming the other way, and where the gradients would be unsuitable for caravans. In a really tight spot caravans or oncoming vehicles sometimes have to reverse, or even unhitch to get out of a sticky situations, but I can think of at least one place where even this would not be an option due to gradients and tight corners. 2.2)..Passage Many daytime sailings are already struggling to cope with demand, and if no new boats are to be provided, careful thought would have to be given to the conveyance of caravans. Whilst Mannannan could probably accommodate a car and caravan, I think that attempting to board or disembark at Liverpool landing stage would be a non starter, for example. I therefore imagine that it would be necessary to confine caravans to the Heysham or Birkenhead routes, utilising the Ben-my-Chree as the preferred vessel. Thought would also have to be given to the arrival times in Douglas, so that arrivals would coincide with light traffic conditions at this end .. e.g. the 0215 sailing from Heysham. 2.3)..Site or sites ?? There seems to me to be no point in caravans travelling further than necessary, and I would suggest that a minimal number of sites around Douglas would be the most practical option. Nobles Park is underused outside TT and MGP, so this could be a contender, and other sites near to the Capital on or near the main roads would also be a good choice. I have seen caravans at Castletown for the pre-TT and Southern 100 and so clearly this is possible, and no doubt there are others, but Douglas is more convenient for the ferry. Having sites scattered around would tempt caravanners to tour with their vans, but I think that it would be mistake to encourage this, as on an Island of this size it isn’t really necessary, and could be a headache for other road users. It would be far better to park the caravan up at a suitable and accessible site and then tour the Island by car since any part of the Island is easily reached in less that an hour from Douglas. 3)..Conclusion I am not against trailer caravans being brought to the Island, although I do think that motorhomes are a much more practical means of taking a holiday here. They only take up one space on the boat,

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can travel on all the ferries from Liverpool, Heysham and Birkenhead (subject to size limitations), and can tour the Island without causing traffic problems. The cost of bringing a caravan across, added to the site fees would pay for a comfortable rented cottage, so it may be that only true caravan enthusiasts will want to ignore these sort of issues for the benefit of staying in their own van. So, given sufficient thought and forward planning, the existing ban could be lifted. If this were initially for a trial period, then any unforeseen issues would quickly become apparent, and thereby allow future policy to be shaped by the practical issues identified in the trial. Yours sincerely Mr Allan Phoenix Pollock, Alexandra From: alexandra pollock Sent: 29 June 2014 21:23 To: committees Subject: caravans on island I have been a regular visitor to the island for over 20 years and think towed caravans should be allowed to come over. I have friends who have one, and they would be delighted to visit. They did come over several times to a guest house, but much prefer their caravan. The ferry cost would bring revenue to IOM steam packet co., holiday spending money, groceries, site fees etc., would also bring much needed revenue to the island. Caravan sites also will provide funds, and jobs as well, and I feel overall it is a very positive sign for tourism, and future generations will benefit. Take a positive step and allow this for five years then re-assess the situation, financial and tourism, and work, and I think you will agree it will be very positive. Yours sincerely, A POLLOCK

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Appendix 12B Submissions from members of the public against caravans

165 166 SELECT COMMITTEE ON TOWED CARAVANS Responses to public call for evidence: full text Submissions received are unedited except for the removal of personal details

Appendix 12b Submissions against caravans

Submissions Allen, Geoff ...... 1 Bleasdale, Ian & Elizabeth...... 1 Bool, John & Hilary...... 2 Brown, P. H., J. & C...... 3 Bryden, Peter & Janet ...... 3 Cain, Michael...... 4 Caine, Peter...... 5 Caley, Sandra...... 6 Callister, Alison...... 6 Carden, Bill & Jill ...... 6 Carine, Michael ...... 7 Carter, David ...... 7 Challis, Darren...... 7 Challis, Sharon...... 8 Chatel, David...... 8 Clarke, P...... 9 Colley, Vaughan ...... 9 Corrin, John...... 9 Cowin, Irene...... 10 Crane, Richard (1) ...... 10 Crane, Richard (2) ...... 12 Crane, Richard (3) ...... 12 Crane, Richard (4) ...... 12 Daniels, Keith ...... 12 Darnill, Richard...... 13

167 Dowling, John ...... 13 Dugdale, Hilary ...... 13 Edge, Christine ...... 14 Edwards, D. & P...... 14 Ginns, Paul ...... 15 Grahame, Pat ...... 16 Green, Andy ...... 16 Green, Eddie...... 16 Green, Gabe ...... 17 Hisscott, Alan ...... 18 Howell, Martin & Suzanne ...... 19 Jolly, Neil (on behalf of the Federation of Sulby Commoners) ...... 21 Jones, Lynne ...... 23 Keggin, John & Heather ...... 24 Kennaugh, Norman ...... 25 Kent, Russ ...... 25 Kewley, M.J...... 26 Kinrade, Geoff ...... 26 Kneale, Alastair ...... 26 Lennard, Bertie (1) ...... 27 Lennard, Bertie (2) ...... 27 Lockett, Gill ...... 27 Mallon, C.B...... 28 McArdle, Fiona ...... 28 McEvoy, N.R...... 29 Muir, Susan ...... 29 Mulvey, Anita ...... 29 Murray, Pauline ...... 30 N, Janice ...... 30 Nall, Maxine & Trevor ...... 31 Nicholls, June ...... 32 Nicholls, Maurice ...... 32 Oram, Ann ...... 32 Pattinson, Nicola ...... 33 Pearcey, Joanna ...... 33 Pennington, John ...... 34 Price, Steve ...... 35 Quayle, Peter K...... 35

168 Quirk, Rosalind ...... 36 Randall, Carol ...... 37 Redhead, Keith ...... 37 Reed, Barbara ...... 38 Reynolds, Brenda ...... 38 Richmond, Phil ...... 39 Robinson, C...... 39 Roome, Laurie ...... 39 Scarffe, Patricia ...... 40 Shimmin, B.S...... 40 Smith, Ron P...... 41 Stembridge, Sylvia ...... 41 Stowell, Brian ...... 42 Sullivan, Ursula ...... 42 Tawney, Alex ...... 43 Taylor, Nigel (1) ...... 43 Taylor, Nigel (2) ...... 44 Teare MHK, Eddie ...... 44 Wade, John ...... 45 Walls, N...... 46 Warren, Matthew ...... 46 Watterson, David ...... 46 Waugh, Jim ...... 47 White, Diane ...... 47 Wilson, R. & J.E...... 48 Wilson, Wendy ...... 48 Woodland, Noel ...... 48 Woodman, John ...... 49 Name Withheld (1) ...... 50 Name Withheld (2) ...... 51 Name Withheld (3) ...... 51 Name Withheld (4) ...... 52 Name Withheld (5) ...... 53

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170 Allen, Geoff Sent: 01 July 2014 10:22 To: committees Subject: Caravans Dear Sirs I am the owner of a motorhome which I am able to park off road at my home. I mention this because I am aware of the problems associated with motorhomes being parked on a road, particularly within housing estates. I also mention it because I travel extensively within the UK and Europe and meet many hundreds of people who own caravans. I would like to make a number of points for the benefit of the debate, They would apply to the vast majority of caravanners:- They are retired/semi-retired and have a high disposable income. They do not stay in hotels or 'freecamp'. They stay on caravan parks or campsites. Drivers towing a caravan always take direct routes and stay on main roads wherever possible. Those who have ever tried to turn a caravan on a narrow road will understand why. Once they arrive at a location they spend up to 3 hours setting up the caravan (levelling, water, electricity, awning, tables, chairs etc.) They do not carry with them 1 or 2 weeks supply of food as the extra weight affects the stability of the caravan when being towed. I am not a lawmaker so it is not my place to suggest how you can prevent some of the concerns presently being displayed in the media regarding travellers, street parking and people living in caravans in fields but I would hope would not present too many difficulties. Finally, if the island wishes to attract caravanners as tourists there would have to be a dramatic improvement in available facilities. The swamp at the rear of the Grandstand would be most unsuitable. Thank you for taking the time to read this submission. Geoff Allen Bleasdale, Ian & Elizabeth From: Ian K Bleasdale Sent: 28 June 2014 18:23 To: committees Subject: Permission for towed caravans? To the Committee Secretary, Committee to consider the admission of towed caravans to the I.o.M. As a one-time caravanner, you might expect me to welcome them here, but no! I have held forth on this subject before, in particular when considering the Island Strategic Plan and I think it is one import we should strongly resist.

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171 Caravans bring with them a number of problems. They obstruct the roads when being towed, obviously, but they have to stop somewhere and they will only worsen the current problem with the parking of motorhomes on the highway. Where else are the to go? In people’s front drives? Many people erroneously think that they have a right to park their vehicles in the public highway outside their homes. They do not. The public’s right over a highway is to pass and re-pass; nothing more. Anything else is technically (and, oh so often!) obstruction. Obstruction of other peoples right to pass & re-pass over that portion of the public ‘highway’. (The position might be slightly different in un-adopted, private streets.) So, if not on the highway, where else? One has only to travel along the coast of North Wales to see what happens: fields and fields of row upon row of parked caravans. Do we seriously want that here? People other than holidaymakers come in towed caravans. I don’t wish to deride the Gipsy or ‘Traveller’ community, I have known some friendly and trustworthy ones but they are not all like that, alas. I have worked for District and County Councils in England and well know the never-ending problem of gipsy sites. The Council has a duty to provide some – but where? Nobody ever wants them as neighbours. Do we really want to enter that hiatus here? Please, please, please don’t go down this road and don’t let the Steam Packet Company do so either (however profitable it might be to them!) There was a Caravan Rally near Douglas a couple of years ago – how did that come about? Sincerely, Ian K Bleasdale MRICS., DipTP., DipLI Elizabeth Bleasdale – Planning Technician Bool, John & Hilary From: Hilary Bool Sent: 30 June 2014 14:46 To: committees Cc: Subject: Re: allowing towed caravans on the Island To the committee on Caravan access on the Isle of Man We strongly endorse the comments on this issue made by the Speaker of the House, Mr Steve Rodan who speaks with the authority of experience. We are opposed to allowing towed caravans on Manx roads for the following reasons:  Road congestion: many Manx roads are not wide enough, and many have blind bends. Overtaking is a hazard. Manx roads already carry excess traffic especially over TT and MGP fortnights.  Safety hazard: many Manx road surfaces are rough and uneven - this presents a real hazard for the stability of towed caravans.  Disfigurement of the countryside: by the establishment of purpose built caravan sites, and the difficulty of controlling and policing these sites.  Wild camping is a clear, and unwelcome, possibility - Fenella beach car park this June?

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172  Business is likely to be taken from existing guest houses, hotels, and self catering establishments.  Business is likely to be taken from local food providers and retail outlets as many caravanners stock up before going on holiday.  Existing transport infrastructure would need to be changed - adding to the costs for the taxpayer e.g port facilities for loading and offloading caravans and the existing onboard parking facilities are unsuitable.  Possible increase in island residents owning caravans leading to even more problems of caravan and motor homes parking in residential areas and camping locally in areas of natural beauty on the island. There is already a recognised problem with this and a call for regulation - as was made in Tynwald when this issue was aired.

For these reasons we do not believe it would be a wise decision to permit and actively encourage towed caravans on the island. John and Hilary Bool Brown, P. H., J. & C. 3 July 2014 Three of us are writing to protest against the proposal to lift the ban on caravans. Our reasons are as follows:- 1. The charm of the island lies in its unspoiled coastline and countryside; Caravanners mostly prefer a seaside site. This would be an eyesaw here as it is in many areas of the U.K. 2. Caravans would occupy a large space on the ferry and would need to be charged at a much larger price than a car or the ferry company's revenue would go down. It would also mean much less space for car travellers. 3. What revenue would caravan sites raise? If they were on farm land only the farmer would benefit. If on government run sites maintenance etc. would ensure that the financial benefit would be small. And can the island's roads cope with them? 4. The idea of caravaning holidays is to be largely self-sufficient. Therefore most caravaners will cook for themselves and probably bring with them staple foods. Therefore cafes, restaurants, supermarkets etc. would hardly be in for a bonanza. 5. If caravaners have an accident of get ill during their star, will the island's health service cope? 6. A caravan offers an ideal hiding place for drugs or stolen articles were criminals to take advantage of this. Can the island's police force and customs cope with this? The original ban was enforced after serious consideration of the above points I am sure and there are no plus signs for lifting the ban nowadays. Yours sincerely P.H. Brown, J. Brown and C. Brown Bryden, Peter & Janet From: Janet and Peter Bryden Sent: 04 July 2014 19:16 To: committees Subject: Caravans To The Committee considering rules on towed caravans on our island roads. Thank you for inviting comments on relaxation of rules on caravans on IOM roads.

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173 We have no objection to residents importing caravans for their own use under our existing planning laws and other controls. We are strongly against encouragement of “touring” caravans on the following grounds in no particular order:- 1. Economic Our view is that the principal benefactors from increased touring caravan visits would be the foreign owners of the Steam Packet Company. We understand the economies derived from using caravans is taking your “home” and pre-purchased provisions with you e.g. the Asda call at Heysham before boarding the ferry. At peak travel times during the summer season a caravan and car would take up the ferry space of three other potential holiday cars the occupants of which would yield a far greater input to our economy. 2. Tourism Policy We understand that Manx Tourism policy is driven in part by use of our public roads for a successful variety of wheel based events. If this is so then we should not add low net contribution road users to the mix who are notorious for causing congestion and eyesores in the countryside. At very best we could try using a caravan event to extend our visiting season where we relax regulations for say one week of the year only and encourage caravan clubs to use this as a “rare” and novel opportunity to use a touring caravan on the island. This would have the advantage of being a test bed for the effects of introducing caravans to our roads without causing major long term disruption provided we select an appropriate place in the tourism calendar. 3. Island Ambience in Support of Tourism Policy We need to stick to a specific tourism policy to maximise economic returns. We cannot be all things to all tourists. Clearly our present and increasing range of vehicle and cycle based events would not be enhanced by the introduction of towed caravans to roads already being enjoyed by event users and those exploring this aspect of our tourism and perhaps training for the events we promote. If we promote ourselves as the road racing capital of the world and then say touring caravans welcome what sort of confused thinking would that be? 4. Safety Those of us using our roads at present are already aware of the tailbacks caused by our buses and larger lorries waiting to pass a pedal cyclist. By and large these vehicles are driven by experienced HGV licence holders familiar with our narrow roads and the hazards they present. Why introduce more hazards and driving frustration in the form of towed caravans and the variety of drivers using them. Turning them loose on an ageing Manx population unfamiliar with the overtaking problems etc presented by towed caravans does not seem to make road safety sense either. Yours sincerely Peter & Janet Bryden Cain, Michael From: Michael Sent: 24 June 2014 11:43 To: committees Subject: Caravans on the Isle of Man Hi.

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174 I understand you are seeking views to allow caravans on the Isle of Man. These are my views. I think it is a bad idea on several fronts to allow Caravans on the Isle of Man. The roads are narrow in many areas and towns. During TT and Manx Grand Prix fortnight they would be a nightmare for bikers and could easily compromise safety especially stuck behind them or in overtaking. Here on the Isle of Man there is a very large number of 4x4s and Suvs and people carriers and huge transit vans plus a large number of lorries and add caravans to the equation and it will be a nightmare to drivers of smaller vehicles including motorbikes and bicycles. In general large vehicles are a danger to smaller vehicles and their occupants in that when you are stuck behind them it is difficult to see around them. In reality i would like to see a reduction in large vehicles such as 3 tonne 4x4s etc. but i know this consultation is not about this, but something to bear in mind. The streets are too narrow even for these types of vehicles. If you decide to allow towed caravans on the Isle of Man, then it should be only allowed for that vehicle to be driven once to a given campsite and not towed all over the Isle of Man, say they stayed for 2 weeks. They could still visit areas of the Isle of Man in their cars. Regards, Michael Caine, Peter From: P Caine Sent: 04 July 2014 11:28 To: committees Subject: Towed caravans. Hello, Please register my objection to relaxing rules to allow towed caravans on the Isle of Man. I would advocate changing "the gentleman's agreement" with IOM Steam Packet to making a law to forbid transportation of towed caravans to IOM, full stop. It is surely obvious that the advantage of some extra tourists, who may or may not bring all of their supplies with them, is very clearly outweighed by the mountain of disadvantages caused by the fatal mistake of once more trying to copy the UK, but take a closer look at the UK with towed caravans, a shambles in some areas. Towed caravans would be an unsightly eye sore in our Island of natural beauty no matter if on the roads or parked up; traffic hold-ups; prevention of in-coming "travellers" would be uncontrollable; There would have been traffic problems here with "bendy buses", some of the towed caravans would potentially be the same length as a "bendy bus". I think that the IOM committees should concentrate on finding solutions to the many problems that the IOM has already got instead of this diversion. A good idea would be to advise Tynwald, in a time of financial restraint, to stop spending money on silly projects that could easily wait until the economy is stable.

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175 Regards Mr Peter Caine Caley, Sandra Dear Sirs, Re: Towed Caravans Towed Caravans are unsuitable for our beautiful island for the following reasons: They would cause further congestion on our narrow roads. Their owners would bring little income to our economy as they would stock up at cheaper supermarkets in the U.K. before travelling here. Caravan owners tend to be self-sufficient. Caravan sites are a blot on the countryside. Once established they could proliferate, with the possibility of site owners providing static caravans. This would also be detrimental for our hotels. Island residents would presumably also be permitted to bring in caravans to be parked on driveways etc. Motor homes are enough of a problem. The only businesses to benefit from allowing towed caravans on our Island would be the Steam Packet and perhaps those that ‘land bank’. Yours faithfully Ms Sandra Caley Callister, Alison From: Alison Callister Sent: 10 July 2014 15:31 To: committees Subject: Caravans Dear Sirs I am strongly against allowing caravans for probably all the same reasons other people will be:- Our roads are too small Caravan parks are unsightly blemishes on our beautiful countryside. They are not financially effective as caravans from the uk will often bring their own food and drink, and obviously won't be paying for bed accommodation. I can not think of any positive reasons for allowing them Yours faithfully Alison callister Carden, Bill & Jill From: billcarden Sent: 10 July 2014 13:01 To: committees Subject: touring caravans on the IoM

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176 To all concerned, We would like to state that, for a number of reasons, that we strongly oppose the introduction of the right to use touring caravans on the Island. We would gladly expand our reasons should it be required. Regards Bill & Jill Carden Carine, Michael From: Michael Carine Sent: 10 July 2014 14:27 To: committees Subject: Caravans I object to caravans because they will spoil the general vista of every bit beautiful landscape we have. Visitors and unsympathetic local residents will have fields of caravans on every bit of coast before this decade is out. Don't let it start! I say Mike Carine Carter, David From: David Carter Sent: 29 June 2014 07:55 To: committees Subject: Towed caravans The island is unsuitable for towed caravans. They would block roads & car parks. They would bring little income to the island as hotel beds would not be used, and owners would stock up on food & drink before sailing from the UK. Caravan owners may be pleasant & friendly people but they pride themselves on spending little in the areas that they visit. The inconvenience of towed caravans is not outweighed by the limited revenue they would bring to the island. David Carter Challis, Darren From: Darren Challis Sent: 15 July 2014 21:49 To: committees Subject: Towed caravans. I would be opposed to caravans on Manx roads. Caravans are a nuisance to all other road users, cyclists, motorcyclists, motorists & pedestrians. Some of our roads are just not big enough for the extra width. They would cause problems. Imagine trying to get one through Kirk Michael. They

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177 would park where they were not allowed. There would inevitably be extra litter in our beauty and conservation spots. There would be extra RTC casualties. There would be extra wear to our roads and verges. How would you be able to legislate against the traveller types, they would find their way to the island and cause havoc amoungst our wonderful trusting community and leave a devastating mess just as they do in the UK. Please do not even consider changing the legislation. We do not need touring caravans on the Isle of Man. Darren Challis Kitchen Installation Services Ltd Challis, Sharon From: Sharon Challis Sent: 16 July 2014 20:35 To: committees Subject: Caravans on Manx Roads Considering how motorbike friendly the Isle of Man is, I am greatly concerned about caravans being allowed on our roads. I feel that they would be a hazard in terms of: 1. the overall vehicle length when pulling out of junctions (especially onto de-restricted roads) & 2. Other road users WILL become impatient when stuck behind them & end up dangerously over- taking putting themselves & the on-coming traffic at risk. My family moved to the Island in 2005 from Kent where caravans (of a certain type) were a regular feature of any unguarded slither of land. They always left behind an eyesore in the form of litter, dog waste & debris from door to door 'odd-jobbing', which had to be cleaned up at the cost of the local authority. How will you prevent these unwanted visitors invading our beautiful fields & verges? I hope you will give public concerns careful consideration before making your decision. Many thanks. Chatel, David Sent: 01 July 2014 21:30 To: committees Subject: Towed caravans I'm totally opposed to the introduction of caravans on the roads in the Isle of Man. The roads are bad enough with ignorant cyclists who think they own the roads anyway and the DoT with their "traffic calming measures", ie digging holes everywhere. There are enough Eastern Europeans on our island already, filling up the place with sponging gypsies and their caravans will be the final straw! David Chatel

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178 Clarke, P. After reading in the IOM Courier this week of our politicians considering to allow Caravans on our beautiful Isle, I do hope the reasoning answer will be NO-NO-NO! We can do without Caravans on our already congested roads Motor Homes are bad enough, apart from which you will be taking the living away from our own Hoteliers and B&Bs - and also very unfair to the Islanders. Also consider the side effects i.e. waste, bad maintenance (with some) and neglect with the Island picking up the bill for the inevitable clean up and removal of what would be left here in our Island. Lets hope common sense prevails!! Best regards P. Clarke Colley, Vaughan From: Vaughan Colley Sent: 27 June 2014 18:45 To: committees Subject: Allowing Caravans on the Island Dear Sir It seems madness to me that the manx government are thinking about allowing caravans on the Island. The vast majority of roads on the Island are narrow and twisting, making it difficult, if not impossible, to overtake slow moving caravans. Not only will they clog our roads, we face the prospect of sprawling caravan sites blighting our countryside, as they have in many parts in the UK. Any small economic gain would be far outweighed by the burden the Island would have to bear by allowing these vehicles onto our Island. Let them remain on the broad open roads of the UK and off our narrow country lanes. Let them continue blight the rest of the UK, but please, please don’t let them do the same here. Yours, Vaughan Colley Corrin, John From: John Sent: 21 June 2014 14:41 To: committees Cc: Steve Rodan Subject: Caravans Good Day Gentlemen I believe that the Right Honourable Speaker spoke for the majority of people on the Island when he eloquently denounced any attempt to introduce towed caravans here.

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179 Anybody who has seen the disfigurement of beauty spots such as the Gower Peninsular by sprawling caravan parks or has sat behind a towed caravan for an hour or so on a narrow road in Cornwall will be quite sure that it is madness to even consider bringing caravans to the Island. Driver frustration on our already congested roads will inevitably lead to more accidents. Would you seriously consider permitting caravans to be towed during TT fortnight, for example? I have never in my lifetime known a Manx Government to be held in such general contempt by the voting public as this present one is - and I am 68 years old. Rank stupidity such as this proposal will do nothing to improve the situation. The various Authorities seem completely unable to control the current aggravation caused by inconsiderate parking of mobile homes - why make things many times worse? Mr. Downie and Mr. Corkish, you are not elected by the public and you certainly do not speak for me nor - I suspect - for a considerable majority of the . The only winner if this came to pass would be the Steam Packet - and maybe pressure from this company is what is really behind this ill- considered proposal. I have no objection to my submission being published. John Corrin Cowin, Irene Sent: 11 July 2014 12:31 To: committees Subject: Tpwed caravans on the Isle of Man To Mr. Jonathan King re;above message not received by your office yesterday. I wish to object most strongly to the idea of towed caravans on the Island - apart from coming across them on narrow roads. We lived for 40 years at Greeba, for the last two decades a camp site sprang up with little or no planning. It went from a few tents and campers for TT and Grand Prix weeks,to become a permanent site storing Motor Homes and providing homes in towed vans for unfortunates subsidised by the NHS (One being an alcoholic who visited us regularly for a number of years, and another, a drug addict who came to us for lifts to a unit at the Strang to obtain his methadone!) I cannot see how this cannot happen on other sites. This particular site was closed by new owners of the propeerty and no longer operates. It must be impossible to police if you have an owner who will not abide by any rules. The Island is not large enough to sustain the amount of caravanners needed to make any noticeable difference to the economy. vanners are notorious for arriving on holiday stocked with all they need, and left in rows over acres for most of the year empty in the UK. Please do not allow this to happen Yours faithfully Mrs Irene Cowin Crane, Richard (1) From: Richard Crane Sent: 10 July 2014 16:10

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180 To: Enquiries Subject: Touring Caravans on the Island Dear Sirs I wish to register my opposition to the introduction of legislation to encouraging and formalizing the use of touring caravans on our Island. As it stands, I believe that there is no effective control whatsoever. In theory you need planning permission to site them but in practice there has hardly been a single planning application in places such as Sulby Claddaugh and Glen Wyllin where the majority are sited on a semi-permanent basis. I also understand that there is no effective control via the Steam Packet company as they as for people to get in touch and get a letter but do not insist on it. I am not privy to any arrangements that Mezeron may have in place but I very much doubt that they will turn business away either. I understand the principle of having fixed dedicated routes from the boat to a site but it will not be policed and will just result in even more signage in the countryside. As has been said many times, our roads are not up to it anyway and it will doubtless lead to risky overtaking at the least. Also, please consider that to select a given number of sites that might be ‘allowed’ caravans will mean that those that currently take them i.e. all sites, that some will be excluded from taking them in future, so losing income while other profit, hardly a fair approach, unless compensation is paid out(of tax payers funds perhaps !!) Far better to strike whilst the iron is hot and ban them officially which in my opinion would actually benefit tourism in all other forms and could and should be promoted as an Island without the blight of caravans perhaps. I have for many years corresponded from time to time with DEFA (DAFF) as regards the use of caravans in Glen Wyllin Kirk Michael as I have lived overlooking the northern part of the site favoured for their summer installations. People do reside in the ‘permanently’ throughout the summer, despite what you may be told otherwise. I have letters stating that only a specific number of towing caravans will be allowed on in this National Glen (also a conservation area) but when I press for numbers, none has ever been forthcoming. I have also made it my business to record the various parking places for caravans, such as on the road up to Peel power station, quarry bends pullin etc etc…anywhere that they should be and most are devoid of the legally required registration plates. The vast majority of housing developments on the Island in the last 50 years have a covenant against keeping caravans either anywhere on the property or they must be behind a building line, which is a difficult rule to abide by given the limited spaces available. It also means that companies might be called upon to enforce covenants that they might normally expect not to have to address. In conclusion, I still consider that it will a retrograde step attempt to formalize the legal introduction of towing caravans on the Island at this time, that in practice we are better off without them altogether but I recognize that having allowed this to not be addressed for years that there are now a good number of towing caravans on the Island and their future will need to handled carefully and diplomatically. Yours faithfully Richard Crane

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181 Crane, Richard (2) Thank you..see attached* taken last year in Shoprite car park Peel!! Regards *Photos referred to can be found at Annex 1 Crane, Richard (3) Sirs Further to my submission ref above, and as this matter is of course ongoing, I attach photos* taken yesterday evening of a touring caravan, locally registered, in the car park at Glen Mooar, Kirk Micheal. If you know the area, you will be aware that the access road is extremely narrow and quite steep and in my opinion, most unsuitable for a touring caravan. Also, the small family hatchback which is parked next to it is highly unlikely to be legally able to tow the 4.8m caravan due to weight limitations- it has a trailer braked system on the caravan tow bar (although I didn’t witness it actually towing it). I would imagine that it would have great difficulty in getting back up the hill again and out onto the main Peel to Michael coast road. Regards Richard Crane *Photos referred to can be found at Annex 1 Crane, Richard (4) Sirs.. the caravan at Glen Mooar remains in place as at today (Tuesday 5th August 2014)…see attached another photo* of it taken on Sunday 03.08.14 Regards *Photos referred to can be found at Annex 1 Daniels, Keith From: Keith Daniels Sent: 30 June 2014 15:19 To: committees Subject: Caravans on Manx roads To the members on the committee on towed caravans, I understand that Tynwald is considering allowing caravans onto Manx Roads. Personally I would be against this-I think the inconvenience of their congesting the Man Roads would far out weight any small benefit to the Manx economy that might accrue. Most of us who go across will recognise the frustration of being in a long queue go cars behind a caravan, unable to overtake them. The next problem would then be the secondary problem of local people buying caravans and parking them in their drives and up the side of their houses-the problem is great enough with neighbours motor caravans. This proposal seems to have raised a lot of discussion the vast majority of opinion against allowing them on Manx roads.

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182 Sincerely Keith Daniels Darnill, Richard Date: 10 July 2014 12:20:50 GMT+1 To: "[email protected]" Subject: Against Towed Caravans After experiencing the delays that Motor Homes can cause on busy days I think the addition on towed caravans would make things worse. The overall length of the car and caravan would cause overtaking problems on our roads, causing frustration and impatience for other road users, I think it could also become a blight on our beauty spots as some people already stop and camp where they like. I was surprised to see a Manx registered towing caravan parked on the grass at Langness yesterday, so even before anything is relaxed the law is being ignored. Please don't ruin our Island by giving these vehicles access. Also how would it affect people in the accommodation industry? Would it also open us up to members of the travellers community invading the Island, with all the problems that would bring. All in all it is a bad idea and I think we need to think carefully of the implications of any changes. Once allowed there will be no way back. Richard Darnill Dowling, John Sent: 10 July 2014 15:10 To: committees Subject: Towed caravans I feel that towed caravans should be discouraged on the IOM as they would cause considerable congestion on our narrow roads, leading to road safety issues as people try to overtake, reduce demand for our hospitality industry and take up considerable space on our ferries that could impact Manx travellers. Lhuish John Dowling Dugdale, Hilary Sent: 10 July 2014 17:35 To: committees Subject: NO CARAVANS ON OUR ISLAND Dear Sirs I am writing to record my strong objections to the possibility of Government permitting visiting caravans - self-propelled or towed - on the Isle of Man. The alleged tourist benefit would be minimal

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183 and the obvious impediments to pedestrians and other road users would be considerable, on our already congested and badly maintained roads. As a life-long Manx tax-payer I sincerely hope Government listens to the public majority who object to this completely ludicrous suggestion and consign this daft idea to the bin. I would be grateful if you would confirm receipt of this email. Many thanks. Regards Hilary Dugdale Edge, Christine From: Edge, Christine Sent: 11 July 2014 14:58 To: committees Subject: Caravans Hi I think allowing caravans would be detrimental to the Isle of Man. There are no caravan parks set aside for them to be parked up on. Mobile homes have enough problems finding places to park and they are fully mobile. Caravans would cause a problem on the road. Vehicles pulling trailers always seem to cause traffic to slow down and to lead to delays getting from A to B. Caravans would be much worse. Yours sincerely Christine Edge Edwards, D. & P. From: David Edwards Sent: 11 July 2014 10:18 To: committees Subject: Caravans A VIEW ON CARAVANS We write this as for some 20 years, we have extensive experience of towing a caravan, both in the U.K. and throughout mainland Europe. We feel that allowing caravans on the island is a most unsound and ill-considered idea, with regard to both the suitability of the island’s roads and provision of suitable sites, and the island’s way of life. As concerns the former, at UK and continental ports, disembarkation from the ferry leads onto roads of the right type, including motorways and dual carriageways, which dissipate vehicles reasonably quickly away from the port. Also, there are often parking areas where caravanners can organise themselves prior to moving on. At Douglas, there would be immediate queues created from the port onto the Promenade or towards the harbour. The roads on the island are patently inappropriate for vehicles towing caravans, which would create movement problems affecting both the vehicles of other tourists and those of people on business.

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184 This would be exacerbated by the various road closures and diversions required for the programme of events on the island. Also, access issues would be likely to arise as caravans enter and leave sites. As a further point, the public consultation document (Proposed Changes to Public Transport and Parking Provision - June 2014) implies that school children and others are to be encouraged to use bicycles, which again would not seem to sit well with the caravan proposal. Furthermore, the provision of land for caravan sites could conflict with demand on land for residential and commercial use. Also, if as a result of such a decision, island residents were themselves to purchase caravans, this would create additional problems in local communities. Already, there are difficulties with regard to the parking of campervans. And what would be the policy with regard to permanent caravan dwellers, such as travellers? To summarise, although it may be tempting to conceive of possible benefits to the island by attracting a new type of tourist, surely it is more important to consider the practical needs of the increasing resident population and how the special characteristics of the island may be best sustained. Allowing caravans on the island and thereby inviting severe practical problems, would hardly seem a positive contribution to the welfare and lifestyle of the resident population, nor to the qualities of quietness, convenience and comfortable sharing of the island's facilities, traditions and pace of life, which visitors come to experience. D. & P. Edwards Ginns, Paul Sent: 01 July 2014 14:51 To: committees Subject: Consultation on Towed Caravans Dear Sirs, I write to object very seriously to the possibility of allowing towed caravans on our Island. You may be surprised for my main reasons, as possibly you might not have even thought about the before, which are Ten years ago I was taken in by some Irish travellers who agreed to carry out some tarmac work in Leicestershire. When I did not agree to pay for a very poor job, my wife and I were threatened with some very serious threats. The Police were unable to cope with them, although we did have an armed Police unit guarding our house for two days, and the Police knew where these people had parked their caravans. I had to resolve the matter by sending some unpleasant and large men to threaten them. The travellers later received a custodial sentence of three years. Shortly before that I owned a development site in Derby City centre. The site was broken into by travellers who used bolt croppers to break the chain holding the gate, and the Police were unable to prosecute as they did not know which one had done it. When I spoke to one of these people he said that they would leave if I paid them one thousand pounds as it would cost us that to get a court to remove them. Again, the Police appeared to be powerless. The church next to our site was broken into several times and although the Police could not prove that these people were responsible they thought that they were. Although these travellers had several vehicles which were untaxed and possibly uninsured the Police again appeared powerless. The travellers then just left after three weeks, leaving us with a six hundred pounds bill to clean up their mess. Shortly before that, I had a business vehicle parked quite legally in a small village, Anstey, in Leicestershire, when it was damaged by a lorry driving past which did not stop. This lorry was traced by the Police to an illegal caravan site. The Police were unable to take any action, although the lorry

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185 was not taxed, it was not parked on the road, and they were unable to determine who owned it. Our insurance company paid out three thousand pounds for the repairs which were not recoverable. You may feel I have an unreasonable attitude to travellers, and should treat them with the respect a recognised ethnic minority deserves. I can only say that over the years I have had some very bad experiences with them and I strongly feel that any possibility of allowing caravans on our Island might well lead to them appearing here. Once here, they will be impossible to remove. Please contact me if you require any further information. Please feel free to publish this email or any part of it. Paul Ginns Grahame, Pat From: Pat Grahame Sent: 09 July 2014 23:21 To: committees Subject: Caravan issue Feel the roads are congested enough, many too narrow, create havoc and hold up traffic even in the UK , so would be more of a hazard on the Island. Would deprive hoteliers and guest houses of much needed business, so would object to any changes. Maurice and Pat Grahame . Green, Andy From: andygreen Sent: 27 June 2014 11:35 To: committees Subject: Caravans I would like to register my view against relaxing the rules on caravans on the Island. To me they reflect a down market destination. Picture the North Wales Coast, with it's headlands and towns characterised by caravan parks. Our roads are typically narrow, not ideal for towed vans. Mix that also with the Motor Sport culture and I think there is a fatal clash awaiting. Please NO. From:- Andy Green Green, Eddie From: eddie green Sent: 01 July 2014 13:59 To: committees Subject: Towed Caravans

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186 In response to the advertised request to comment on allowing towed caravans on Manx roads; Relaxing existing rules to allow towed caravans on the island's roads would be sheer folly. I understand this exclusion already exists because it was recognised that our roads are not built for and are therefore unsuitable and dangerous for this type of traffic. Due consideration must be taken re Manx motorists who already have to contend with heavy goods vehicles, buses, horse boxes, farm traffic etc on narrow, twisting badly surfaced roads. Imagine motorists travelling to and from work having to contend with one, two and more of these ungainly slow moving (by law) vehicles in transit to and from the ferry terminal!!!!!! These vehicles would frustrate and (rightly or wrongly) encourage other motorists to dangerous practices thus placing unnecessary burdens on the (reduced) police force and already overworked, cash strapped hospitals and medical staff. There is talk of providing special caravan parks. Has any thought been made as to locations, public or private land costs, provision costs, insurance costs, maintenance costs, manning costs, safety aspects and a whole raft of other considerations? Where will the money come from if this in itself is yet another diabolical exercise to raise funds? Within government, there are desperate minds searching for sources of revenue...... the introduction of towed caravans is really a non-starter...... a definite NO. REG Green, Gabe Sent: 26 June 2014 00:03 To: Jonathan King Subject: Re: Should we allow towed caravans in the Isle of Man Good evening Mr King I have been advised to forward my recent correspondence to various MHK/MLCs re the above article printed in the Manx Independent. Follows for your information: I have been reading with alarm that Tynwald is considering allowing towed caravans in the Isle of Man. I am pleased to see a few objections on the basis of 'road rage, congestion and general nuisance' by Mr Rodan. Mr Corkish has voiced concern and has picked up on the lack of legislation, but unfortunately this would only be the tip of the iceberg. If towed caravans were to be allowed into this island without control, it would be a decision you would deeply regret. True it is an untapped market, and I have no objection to visitors from members of a caravan club, but allowing the foothold of the most undesirable residents you can imagine into our economy, would be your worst nightmare multiplied by 100! I am not racist by any stretch of the imagination, but I have lived through this nightmare which affected my own home and business whilst living in the UK. Allowing in caravans would invite every gypsy from the UK and further afield, to run riot with every business, pub, farm, shop and hotel on the island, especially those who handle cash and are stupid enough to leave large floats in the tills overnight. To gypsy families the Isle of Man is 'an untapped

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187 market'. In the UK many buy up land to turn into their own illegal gypsy camps - without planning permission, others just park up and carry on. They will cost this Government and Police Force many millions of pounds dealing with their crimes and clearing up the mess they leave behind. You can say goodbye to the low crime rate - more police will be needed, so you can forget about closing police stations. Wave goodbye to the recovering economy - the legal processes Government and landowners would have to go through to remove the unwanted residents would be lengthy and financially crippling. They intimidate many businesses and home owners, especially the elderly, calling door to door 'offering forcibly' to tarmac drives, offering building and gardening services, then demanding exorbitant amounts in payment - dumping the waste anywhere in the countryside afterwards. Of course they also have their own country sports - hare coursing, dog fighting (and badger baiting in the UK). The levels of theft - diesel and equipment from farms is a favourite, as well as tack and horses from equestrian centres, tools, equipment and materials from building sites. Theft of scrap - copper cables, memorial plaques - even railway lines and manhole covers, the list goes on and on and would spiral out of control in no time at all. The safety and security we enjoy here in the Isle of Man would become a dim and distant memory - do you really want that when it is so easy to prevent? I find it difficult to believe that our Government has not done it's homework before suggesting something which would affect each and every resident of this island. I'm sure a call to any police force across would confirm my warning - try Essex, Norfolk, Northamptonshire or Lincolnshire to name a few. There have been thousands of complaints to Trading Standards Offices and the Office of Fair Trading. Of course there are also many hundreds of landowners and councils still battling to have illegal gypsy camps removed from their land, having settled without permission or planning consent. If you want to discuss this face to face, do not hesitate to contact me, but please heed this warning - you really need to wake up and face reality before it is too late. Regards Gabe Green Hisscott, Alan From: Alan Hisscott Sent: 06 July 2014 11:50 To: committees Subject: Towed Caravans Good morning, In response to the request for views on the proposal to allow towed caravans into the Island I do not think it is a good idea, for several reasons: Firstly I fail to see how it would be desirable in terms of tourism: the whole idea of taking a holiday in a caravan is to be virtually self-sufficient. Caravan owners would fill up with fuel before leaving the UK (since it’s cheaper there) and bring most of the food required for there stay with them from the UK (since it’s cheaper over there). They would bring little or no trade for local shops, pubs, restaurants, food producers, etc. probably only purchasing perishable items such as milk (and then probably choosing the UK-imported types because of brand-familiarity). Towed caravans would cause severe problems on our already often-congested roads. The Island is frequently a windy place, even in summer, with our rugged terrain often causing very gusty conditions on exposed roads, with obvious hazards for both the caravan owners and other road

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188 users. Also, in my experience, many caravan owners are not skilled drivers in terms of reversing reasonable distances between passing-places on single-track roads (in fact many of our passing places are only long enough for large vans anyway and would require extending). There is very little, if any, suitable parking in any of our towns and villages, either for visiting caravans or for local residents who might also join the towed-caravan community. The development of caravan parking sites would require extremely strict supervision. I know several land owners in the UK and Ireland who have had gypsies move onto their land overnight and stay for several years, with the local police forces unable to shift them. The Island does not really have a good record at controlling long-term occupancy of tourist accommodation, for example at Mount Murray and Groudle as well as many other individual dwellings around the Island. In Eire, there are several large caravan encampments on the outskirts of cities which form part of the housing culture, with young couples purchasing static caravans as a stepping-stone to their first ‘proper’ house, but many never manage to move on. Regards, Alan Hisscott, Howell, Martin & Suzanne Sent: 29 June 2014 23:33 To: committees Subject: Views about Caravans on the island. Dear Sirs Possibility of towed caravans being allowed on Isle of Man roads. We believe you wish to hear from people if they have a view about the possible lifting of the ban on towed caravans being allowed on the Isle of Man. We feel a change of the current restriction would be a disaster, for several reasons.

1. The most obvious issue is that the roads on the island are totally unsuitable for slow moving car/caravan combinations. The main roads are not wide enough to allow overtaking and it is therefore likely that drivers in following cars would, rightly or wrongly, take risks to overtake as a lack of patience gets the better of them. This could have fatal consequences. However, once away from the main roads, the side roads leading to locations caravan owners are likely to favour are even more unsuitable for cars with caravans (eg Point of Ayre, Ayres National Nature Reserve, access to Glen Wyllin camp site, access to Sulby Claddagh camp site, etc), in many cases being virtually single track.

2. Prior to coming to live on the Isle of Man, we owned a motorhome in the UK (we sold it before moving to the island) and therefore spent a great deal of time on camp sites alongside caravans. If the belief is that to allow an influx of caravans will help the Isle of Man economy then we strongly disagree: go to any caravan site and you will see that most owners eat inside or al fresco alongside their caravans, depending upon the weather. They do not frequent local bars and restaurants. As any owner of a caravan will tell you, they seek more and more sophisticated vehicles, equipped with the latest cookers, fridges, microwaves and satellite televisions...because they wish to remain self- contained for their food/drink and evening entertainment. And as most caravan owners are by nature very frugal, in light of the cost of living on the island being higher than in the UK, it is most likely that visiting caravanners would stock-up before leaving the UK, so there would not be a big increase in income for stores on the island.

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189 3. Having, prior to relocating to the island, come here in our motorhome to investigate houses to buy, we are au fait with the different campsites such as Sulby, Glen Wyllin and Peel. To be cruel but honest, they are all extremely poor in terms of facilities, the quality, scope and age of equipment. Other than Peel, they are bereft of hard-standing space for pitches during wet weather. Therefore any caravan visitors are likely, as we did, to leave with a somewhat negative and therefore damaging impression of camping on the island rather than a positive view. This is likely to reduce repeat visits, lead to negative comments on caravan web forums and dissuade recommendations.

4. Indeed, the lack of facilities at unofficial camping areas on the island is already a problem. For example, we walk with our dog every day on the north west coast of the island: the different access points (eg Blue Point, Rue Point, etc) and camping areas (eg Point of Ayre, Ayre Reserve) are already heavily littered by rubbish left by weekend campers in tents and motorhomes. What is even worse is that many of these campers leave human waste in the areas, some motorhome owners emptying their chemical toilets in the wild hedges. Bins are always overflowing. There is a need to stop this, not further add to the problem by increasing campers.

5. At the moment there are a few motorhome owners on the island and unfortunately neighbours of these vehicle owners often have their light and views restricted by the motorhomes parked on driveways (I hasten to add that when we had a motorhome in the UK we had no neighbours and therefore when parked it was out of view of anyone). By lifting the ban on caravans it would leave the way open for many more people and neighbourhoods to be blighted by the appearance of caravans parked on driveways.

6. Another big problem will no doubt be, in due course, the influx of permanent towed caravan dwellers: ie ‘travellers’. It will not be possible to differentiate between the genuine holidaymaker and ‘gypsies’. You do not need to look far in the UK to see the problems caused by this sector of society: their forceful if necessary trespass on common land, often play fields or community greens; the waste they leave on departure; the increased crime rate that accompanies their presence in an area; local communities’ discomfort with their presence; the temporary strain on schools where places are demanded; the illegal tapping into local utility supplies; etc. The island has a wonderful reputation for the beauty of its countryside, safety and low crime rate: to allow caravans and therefore owners of all kinds including ‘travellers’ would be a disaster at a time when the island’s police resource is being cut back.

7. Go up to the Point of Ayre (and further south on the coast) during the weekend and instead of beautiful views of the area and across to Scotland/The Lakes one is already faced with a wall of white motorhomes that are parked right along the edge of the greenery, overlooking the beaches. At least these vehicles move on. Caravans would be left there, to blight the area, whilst their owners go wandering off in their cars.

8. Finally, outside the TT and GP events, there are many under-utilised hotels, B&Bs and holiday cottages. Rather than considering the lifting of the ban on caravans to increase tourists and tourism income, there are many other initiatives the Government could launch to bring more people to the island.....people who would stay in our hotels, B&Bs and holiday cottages and who would therefore eat and drink in local bars and restaurants. In fact, when considering the lifting of the ban we cannot think of one good properly considered fact-based reason or benefit to support the proposition. We hope you find the above helpful. Feel free to contact us if you would like to discuss any of our points. Martin & Suzanne Howell

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190 Jolly, Neil (on behalf of the Federation of Sulby Commoners) This evidence is written on behalf of the Federation of Sulby Commoners and neighbours whom since 1988 have close experience of abuse by a significant ratio of caravan owners on Public Open Space. There is sufficient evidence to suggest that if rules were relaxed for towed caravans the same abuse could happen at other Public Open Spaces around the Isle of Man. We are aware about the present regulation which has been recently confirmed by DEFA Warden Peter Knowles; namely the letter through the Department of Infrastructure. Alas this has not prevented many caravans from abusing the countryside in Lezayre. The basis of the general concern is that it has taken 22 years from 1988 until 2010 for the authorities to introduce byelaws to help stem the tide of abuse. Which had turned the Sulby Claddagh Public Open Space from a peaceful green into the Wild West, the latter being the description of a Ramsey Police Inspector! Moreover although the Byelaws have given the “Landlord” DEFA a starting point, they are not sufficiently robust to stop a dozen or so, an easy opportunity to exploit the system. For example a dozen repeatedly stay longer than the permitted 14 days and use the Public Open Space as a Trailer park throughout four months of the year, leaving unoccupied caravans abandoned for night after night. For instance in 2014 from the 1st of May to 16th June and excluding TT weeks many of the neighbours have witnessed abuse on a total of 117 nights. Where contrary to DEFA’s associated rules, which permit holders have agreed to uphold, caravans in particular have been left unoccupied on Sulby Claddagh Public Open Space. Whilst this may not be a breach of the Byelaws per say, it is a breach of DEFA’s rules which are issued with the permit. Nor is it in the spirit of the privilege that has been extended to the permit holders, because according to the Attorney General camping is not a public right or a right of Common on Sulby Claddagh. Camping is just a permitted privilege. We are aware that DEFA is not certain whether they can act to recall permits for rule rather than Byelaw abuse. Consequently they are seeking the advice of the Attorney General’s Chambers on the matter. But whether an opinion from the Attorney General’s office or action from the Department is taken before the end of the 2014 season remains to be seen. In any event we know from twenty years’ experience, that measures to stop abuse are rarely achieved in a short space of time. A Warden’s log has been kept by DEFA for the last four years with contributions from G4S Security. The Warden Peter Knowles has many field duties to attend to and in the main takes records on a Monday or Tuesday, whilst a second warden from the Ayrs Louise Samson records permits on a Thursday and G4S on a Friday and Saturday night. However following a donation of time to Care in the Claddagh by the Federation of Sulby Commoners, permits recorded on a Wednesday revealed discrepancies in the official log. Thankfully all parties are now working together to try and achieve a complete record from which the Department can more fully administer the site to prevent overstay and caravan trailer parking. One glaring problem remains that the 2014 permits issued to applicants did not in themselves contain the relevant information of tenure such as the 14 day limit and not leaving camping

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191 equipment overnight. So it is hoped that these omissions are addressed before 2015, following a proposal by the Federation of Sulby Commoners. Moreover a major obstacle for DEFA to overcome, is the 2010 Byelaw definition of an over-night stay being set between Midnight and 6.00am. We are told this was to accommodate day trippers, but the reality is that a Court could contest all the Department’s log entries. Because the reality is neither Warden nor Security collect Permit numbers in the dead of night and nor should they be expected to do so. Thus that byelaw is a non-starter and does not help DEFA prevent abuse. Notwithstanding the recent 2010 Byelaws, managing caravans and the like on Public Open Space is nigh on impossible for DEFA to manage on just 16 acres in Sulby let alone 35,000 Island wide. DEFA do publically acknowledge that Sulby Claddagh does not comply with the Tourist Board’s requirements for a campsite; the definitive period being over two months of the year. In fact if falls woefully short on hygiene and fire prevention standards. Nor does Sulby Claddagh have the formal planning permission to host camping for over two months of the year. Subsequently the five month Permitted season is not fully compliant. So basically Sulby Claddagh is just like other Public Open Space. Obviously camping does take place and no major disaster has thankfully yet occurred, but this may not continue to be the case if there were limitless caravans on the Isle of Man. Please bear in mind that a canny camper can legally occupy Sulby Claddagh costing the tax payer £30,000 per annum for four months of the year, by rotating times of 14 days on 4 days off. We have witnessed and understand why a single warden or indeed a security guard are reticent and reluctant to deal with the more aggressive occupants of Public Open Space at Sulby Claddagh. So there is evidence to believe that they are not equipped or trained to deal with serial abusers or indeed seasoned Travellers. Again from experience we are also aware that specialist Bailiffs are required to deal with the not uncommon infringements by Travellers in the UK. Please consider that even if moved from Sulby Claddagh abusive caravan owners could then descend on say the Ayrs, or even a place closer to you the reader and unless there is a local Bailiff on hand with the experience, then a long term problem could ensue. Travellers are not unknown to the Island. The record states that “The first settlement of gypsies came to Man in 1864 when Fred Boswell set up his encampment on Todds Lane and Little . He was known as the King of the Manx Gypsies and is buried with his wife in Braddan Cemetery. His son succeeded him as “King” but was drowned in 1920.” We have further grounds for concern as there is no limit to the amount of camping permits issued by DEFA, apparently currently between 700 to 900 per annum. In fact the only defining limit to occupancy on Public Open Space at Sulby Claddagh is the available ground area. Unfortunately because occupancy is free this causes general overcrowding on some Bank Holidays but most definitely at TT and MGP time. DEFA’s own publication for Sulby Claddagh - the Future stated that guidance contained within the Tourist Act 1975 equates to safe occupancy of 50 tents / camper vans and up to 80 people. But the Omnibus test suggests that four times this amount is the norm for the motorbike festivals. Security G4S figures could no doubt confirm the occupancy rates on Friday and Saturdays at least. Although caravans are not as prolific as tents at TT, further relaxation of regulations could alter this, at a time of general non-compliance for safety matters, where fewer would be safer than more. Caravan owners are however the main culprits of number plate deception. The permit owners remove plates, display illegal plates and even attach brand new plates with UK numbers for reasons

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192 best known to themselves. The Police are powerless to act, because when off the highway a caravan is merely another trailer. Hence providing the towing vehicle brings a matching number plate and lights and attaches them before leaving, no crime is committed. Witnesses can attest that not surprisingly this rarely happens. The number plate deception in itself is petty, but it does demonstrate that certain caravan owners who can be identified by permit, game all the rules they can get away with. We can only give evidence on Sulby Claddagh but we trust the Committee will respect that similar abuse could happen to other areas of Public Open Space throughout the Isle of Man. It took twenty years to start robust action in Sulby Claddagh, five years on sadly even with new byelaws some abuse continues. The promised tweaking of rules is still a long and laborious process requiring patience and persistence of volunteers. Consideration for DEFA should be made as they are probably the largest landowner of property where unlimited Caravans could pitch. Their estate comprises circa 35,000 acres but they have only one main Warden for land excluding the Ayrs. We hope this evidence highlights a status quo that cannot cope with caravans on Public Open Space even on one quasi regulated site, Sulby Claddagh. In our experience deregulation without appropriate checks and balances could raise serious Health and Safety issues possibly all over the Isle of Man. There could be other precious sites that suffer like Sulby and we hope that can be avoided. A final frightening prospect is the collection of highly inflammable substances on Sulby Claddagh at TT, this could be another potential Summerland waiting to happen! Because if further caravans and awnings, combining fibreglass, canvas, gas bottles, and petrol in tow vehicles were allowed there or on any other overcrowded campsite, then it is entirely possible with a single spark that the authorities would have a very grave case to answer, following a flash fire. To any who may think that the last paragraph is melodramatic, please consider that there are absolutely no fire- fighting measures at Public Open Space at Sulby Claddagh. All the fire stations are the other side of the course and the two nearest Kirk Michael and Ramsey would require stopping a race or practice. Please note the Public Open Space at Sulby Claddagh is in breach of all 12 Fire Safety Guidance Note 7 for fire precautions for Camp sites. Now that DEFA issue permits for camping it is also hard to see how the authorities could claim the exempt status from Health and Safety rules it previously alluded to. We respectfully request that the Committee do not relax any regulations concerning Towed Caravans with reference to evidence from Public Open Space at Sulby Claddagh. We trust that DEFA will also submit evidence of their experience particularly in view the limited resources they have to protect our 35,000 acres of land including many Public Open Spaces. However if the Committee do decide to recommend relaxing regulations regarding Island access for Towed Caravans, we would like them to consider only making changes subject to robust protection for Sulby Claddagh and all other Public Open Space. Jones, Lynne From: Lynne Jones Sent: 08 July 2014 22:43 To: committees

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193 Subject: Caravan debate I find it quite disturbing that we are even considering allowing caravans on the Island. Since the publicity over this Committee being set-up to look into the feasibility of allowing them in the Island they can be seen in several places already. For instance on the St Marks road A26 there is one parked-up outside the large garage/workshop there at the side of the road (near to where the St Marks Nurseries used to be, proceed to St Marks and carry on straight ahead on the road B30 that comes out at Ballamohda Straight and there is another parked up in a field amongst the rubbish and old container dumped in the field. Likewise on the Poortown Rd at Peel there is another in a field near the cattery. The countryside is already being desecrated by the ridiculous lack of planning control and allowing High Net Worth individuals to make hundreds of acres agricultural land into private gardens, land that will never be recovered for agricultural use. If we desperately need to make money make them pay a tiny percentage more tax, that they wont even notice, they will still stay here as the tax rate is significantly lower than the UK and they get other advantages, like a nice private air terminal paid for by us. Make them respect this Island and appreciate that they are privileged to be allowed to live here and should cherish it. You need to stop the rot now, Caravans are unsightly and always seem to attract further eyesores and rubbish surrounding them. Any income the island could achieve would be far outweighed by disadvantages of allowing them on the island the Steam Packet may make a nice profit out of them and not to mention the possibility of travellers setting up camp on some beauty spot, remember that cost the UK taxpayer around 7 million to eventually evict them do we really want that risk? and with cuts, we will not have the police resources to cope with something on that scale. I just hope the suggestion is yet another smokescreen to keep the voters distracted, like the mention cannabis cafes, whilst other things are going on in Government? If you are proud Manxmen, start looking after this beautiful Island or it will pay the price for years to come. Keggin, John & Heather Sent: 02 July 2014 20:52 To: committees Subject: Caravans Dear Sirs Our opinion on allowing caravans in the Isle of Man is as follows: 1. Little economic value to the Isle of Man except for the Steam packet. 2. Caravan sites are a blot on the landscape, one only has to look at Cornwall, North Wales and Pembrokeshire to see this, don't let our beautiful scenery be spoiled. Many visitors to the island comment on the fact that we do not have caravans and are very pleased that we do not allow them. 3. Mobile homes are now camping up overnight in unsuitable areas, I am sure that caravans will follow this trend. The powers that be do not seem to have any control over this and are unable to police it. We will find overnight parking at every beauty spot. Is that what the island wants? Yours John and Heather Keggin

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194 Kennaugh, Norman From: norman kennaugh Sent: 30 June 2014 12:40 To: committees Subject: TOWED CARAVANS Dear Committee members, I am of the view, that Towed Caravans should not, to be allowed on the Isle Of Man. I believe that allowing them here, will lead to allowing Static Caravans and then allowing, Static Homes. Please stop it now. Thanks, Norman Kennaugh Kent, Russ From: Russ Kent Sent: 30 June 2014 14:34 To: committees Subject: Caravans Dear Sirs This is the first subject that I have felt motivated enough to respond to a consultation. In short, in my opinion, the introduction and encouragement of caravans to visit the Isle of Man is one of the worst ideas I have ever heard. I cannot express my opinion on the matter strongly enough. In my mind, the fundamental reason why people buy a caravan in the first place is because they are unwilling to pay for accommodation in the places they visit. People with that mindset are not people who would bring a tremendous local economic benefit to the places they visit having stocked their caravan prior to their trip. It is my view that the only economic benefactor from their introduction would be the ferry company. Caravaners would of course not be using existing hotels, bed and breakfasts, holiday lets etc, and with the ability for them to cook in their caravans, the local restaurant trade will also not be significantly boosted. 2) Caravans are mobile road blocks. Many locals probably haven't experienced the horror of driving round Cornwall or the Lake District on a bank holiday weekend and getting stuck behind a convoy of caravans. 3) Caravan parks are an eyesore - take a drive along the North Wales or Devon/Cornwall coast for proof, indeed I recently met some tourists over from Plymouth recently on the steam train and they said they were delighted that the countryside and the coastline was not blighted by unsightly caravan parks. 4) The IOM roads are entirely unsuitable for the bigger caravans nowadays available, there are only two dual carriage ways on the island (up Richmond Hill and down Santon dip) and therefore passing cars with caravans attached will be nigh on impossible leading to inevitable frustrations and it’s consequent implications for drivers taking un-necessary risks to pass. Of course for some certain events or times they should be allowed temporarily, perhaps subjected to a special permit. E.g,

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195 - TT/MGP periods for the race teams - Film production companies - Other special events It is my opinion that the Island should be actively marketed as a place where caravans are NOT welcome, the couple on the train said this was in their guidebook and acted as encouragement for them to visit. The resulting controversy from an outright ban on them, other than by special permit, would generate enough publicity that more people would be encouraged to visit. Thanks for taking the time to consider my opinions on the matter. Best regards Russ Kent Kewley, M.J. Committee Secretariat In reply to your request in the Courier for views on the idea of bringing static caravans to the Island. I wish to state that I am strongly against it, as I feel they would spoil our lovely landscape. Yours faithfully (Mrs) M J Kewley Kinrade, Geoff From: Geoff Kinrade Sent: 27 June 2014 17:49 To: committees Subject: Caravans Please, please, no relaxation of the rules regarding towed caravans on Manx roads. Mobile homes are enough to contend with. Kneale, Alastair From: Alastair Kneale Sent: 10 July 2014 13:23 To: committees Subject: Towed Caravans consultation Hello. This is my view on Towed Caravans in regard to the consultation process now underway. I think it would be disastrous to allow towed caravans on the Isle of Man. They would cause traffic chaos on our narrow roads which would pose increased risk. When there is an accident involving caravans, which is quite common in the UK they cause logjams and take ages to clear. They are also a dreadful eyesore and have spoiled many places of beauty in Britain. They would do the same on this Island

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196 There is also a problem with illegal parking of caravans or groups of caravans and this has caused major problems to many authorities in England. I think they should not be allowed on the Isle of Man. Yours Alastair Kneale Lennard, Bertie (1) From: Bertie Lenard Sent: 11 July 2014 04:28 To: committees Subject: Caravans As an experienced touring caravaner who regularly toured United Kingdom and Europe, I make the following comments, although I wonder whether the Politicians who have thought up this idea have ever used a touring caravan. Traffic on the Isle of Man has certainly increased in recent years for cars, vans and lorries and allowing caravans on the Island can result in many problems. Traffic slowdown. Parking More accidents. Overtaking cyclists. Kind regards, B. Lennard Lennard, Bertie (2) From: Bertie Lenard Sent: 11 July 2014 23:45 To: Jonathan King Subject: Re: Caravans Thank you for the email. I inadvertently sent this before completion, therefore I give below further comments. My daughter and husband have sent you an email (D. & P. Edwards) and I totally agree with the comments they have made. However, I would like to add that one of my serious concerns which is the possibility of travellers arriving on the island and creating permanent illegal sites with all the problems which could arise and could cost the island a considerable amount of money. Kind regards, B. Lennard Lockett, Gill From: Gill Lockett Sent: 01 July 2014 09:47 To: committees Subject: Issue of caravans

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197 To whom it may concern, As a resident of Port Erin I feel strongly that caravans, and indeed I would include campervans and motorhomes in this argument, should continue to be excluded from the island. The roads are too small / narrow and new parking areas and amenities would have to be created for them. Travelling would become more difficult and potentially dangerous for overtaking. Creating suitable parking areas would mean yet another blot on the landscape, as these would need to be in attractive areas, which inevitably means spoiling their beauty. Even a privately owned motorhome located on the cliff top has already had a negative impact in Port Erin as its prominent shape and size prevented a house sale! This certainly has not benefited the community, given that it stays put 80% of the year. Do we really need more of these? I am certain caravans would be a matter of annoyance and irritation for all concerned, not just the locals. I do not believe they would be a good source of revenue for the Isle of Man, as they would most likely bring their own provisions. Given the size of the vehicles, this would mean on ferry crossing there would be less space available for ordinary sized vehicles. I cannot see that the island as a whole would gain from this move to allow caravans entry to the island. Please do not spoil this island further by allowing caravans onto our soil. Kind regards, Gill Lockett Mallon, C.B. Dear Sirs I am totally against the caravans coming to the I.O.M. reason how do you stop the Gypsy coming here? I look forward to your reply. C. B. Mallon McArdle, Fiona Sent: 11 July 2014 14:50 To: [email protected] Subject: Towing caravans committee submission Please submit this to the Committee. Dear Sirs I wish to state that since coming to live in the Isle of Man from a very scenic area of Scotland over 40 years ago, the one thing which has made the Island the beautiful place it still is for me has been the lack of towing (and static) caravans. The roads are totally unsuited to them, especially the 'scenic' routes, where they block roads and where, if any accident has occurred, they cannot easily (or at all) extricate themselves from a traffic jam. Indeed accidents on main roads in the Isle of Man often leave only very narrow roads as an alternative through road for traffic. Caravans also blight the scenic landscape where they park - and no doubt some enterprising landowners with sea views would be only to delighted to have them paying to blight everyone else's pleasure in the landscape.

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198 No doubt IoMSPCo. will favour the introduction of such long (and expensive) vehicles as it would increase their revenue. I hate to think what the charge would be in peak periods! Perhaps enough to deter their owners. Caravan owners are not noted for benefiting the local economy once they are in a 'beauty spot' - they load up with cheaper provisions and fuel before coming to their destination - ask any . Please retain the status quo. I would be interested to know why the Committee has been set up to review the matter at this time. Perhaps your Committee might inform me of the reasoning behind it. Yours faithfully Fiona McArdle McEvoy, N.R. From: richmond Sent: 30 June 2014 14:38 To: committees Subject: Re. proposal to relax the rules on towed caravans. I think this is a mistake and will create problems in a number of areas. 1) I can imagine chaos on the ferries. 2) Isle of Man roads generally are unsuitable. 3) We already have a problem with camper vans belonging to residents parking inconsiderately. 4) We do not want to import the problem they have across, i.e. illegal camp sites. N.R. McEvoy Muir, Susan Sent: 27 June 2014 16:43 To: committees Subject: Towed Caravans on the Isle of Man Following the piece in the 'Isle of Man Courier' newspaper inviting opinions about towed caravans, I think they should not be allowed on the island's roads. When I travel around the island I feel the roads are too crowded already and caravans will only add to road users problems. The island has many small, narrow country roads used by cyclists and walkers and caravans would be a major hazard for these groups. Kind regards Susan Muir Mulvey, Anita From: Anita Mulvey Sent: 28 June 2014 18:19

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199 To: committees Subject: towed caravans Dear Committee I am emailing to register my OBJECTION to the proposed plans to allow towed caravans on the Isle of Man. I believe that they should NOT be allowed here. They will cause more traffic congestion and may lead to more road accidents as car drivers attempt to pass them unsuccessfully. It is already difficult for drivers with roadworks, farm vehicles, horses, pushbikes etc. Allowing caravans would be a regressive step! Yours faithfully, Anita Mulvey Murray, Pauline From: Pauline Murray Sent: 09 July 2014 16:53 To: committees Subject: Towing Caravans I would like to register the fact that I am totally against relaxing the rules to allow towed caravans on to Manx roads. One only has to see parts of Cornwall where hours can be spent sitting in traffic jams. Just imagine if we relaxed this rule what it would be like in TT fortnight! The roads are congested during that period anyway, and this would really add big problems to that. Anyone who has sat behind a queue of towing caravans on B roads or even some of the smaller A roads in the UK will support the side of the argument, because the pleasure of going for a lovely drive in the countryside is completely spoiled. I am pleased to hear that you are willing to hear our views on this matter, and sincerely trust that you will actually 'listen' to the replies. Mrs P Murray N, Janice From: Janice N Sent: 10 July 2014 14:14 To: committees Subject: Towed Caravans I think allowing towed caravans into the island would be very unwise. Little or no revenue would be produced, as most caravaners stock up for there trip prior to leaving home, so their purchases would be minimal. The experience I have had of being stuck behind caravans on roads in the west of England which was a thoroughly irritating experience leads me to think that the same scenario would occur on Manx roads. I would also hate to see the blight of caravan sights both temporary and fixed. One has only to look at those in the UK to realise how daft it would be to allow these on the island.

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200 Another thing to bear in mind is the colossal expense that many seaside towns e.g. have been put to to move on Gypsies with their towed caravans and clear up the rubbish left behind by them. The above is surely obvious to anybody except seemingly a certain MHK !!! Nall, Maxine & Trevor On 25 Jun 2014, at 14:02, "Maxine Nall" wrote: Dear Mr Rodan, Trevor and I were very pleased that you spoke out against the suggestion that towed caravans should be allowed on the Isle of Man. We also viewed the suggestion with great concern. People have made many good points in the Isle of Man Examiner this week, which we would endorse. In deed we feel it is true that Caravaners are not likely to contribute much to the Islands economy. The only gains coming from The Steam Packet and a few land owners who would plan to offer suitable sites with hook ups etc. Caravaners are likely to spend some money in the supermarkets, but that will be largely all. It is not our belief that Restaurants, cafe’s etc will benefit much. Many of our lanes are unsuitable for cars towing caravans, very narrow with few passing places. Extra signage would need to be provided on all roads unsuitable for such vehicles. We once got stuck in Sulby Glen for over an hour, with cars backing up behind us, because a coach driver had decided to take his passengers on a scenic route, needless to say he had to back the coach out for about 2 miles. At peak times there might be insufficient room for all motor vehicles wishing to use the ferries because of towed caravans taking up twice the space , but, with probably less passengers on board. How would caravans be policed i.e. People who chose not to use designated sites who choose to stay where they wish and possibly indefinitely? Could towed caravans be used as a Trojan Horse to allow groups of “travellers” to come to the Island? Coming from the UK we have seen and experienced the misery travellers cause. It cost’s local Governments 10s of thousands of pounds in taking out lengthy eviction orders and clearing up sites once finally abandoned sometimes being re occupied only weeks later. Once travellers have arrived usually the crime rate suddenly peaks. Then there is the cost of trying to make any piece of spare ground Traveller proof, even public car parks, private land nothing is safe from opportunist tendencies. Does the Isle of Man Government already have legislation in place which could cope with this? We are of the opinion that there is already too much bed capacity on the Isle of Man with the exception of TT weeks. There are 4 new hotels in the process of being built at present to our knowledge. We are not sure what the occupancy of the larger hotels in Douglas enjoy, but we would say most hotels, guest houses ,B&B’s and self catering units probably achieve a little over 50 % occupancy overall. If we need these places to remain open to take up the surplus at busy times, we need to provide less options not more. We trust you will continue to strongly voice your concerns and those of your constituents. Assuring you of our continued support in this matter. Maxine and Trevor Nall

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201 Nicholls, June Sent: 10 July 2014 13:35 To: committees Subject: Towing Caravans Dear Sir, I think it would be completely wrong to allow towing caravans on the Island. The roads are just not big enough and they would cause some bad road problems. Also if residents started to buy them there will be caravans parked in roads when they are not in use. There are enough complaints now about all the motorcaravans being parked in the streets. The present system whereby caravans are allowed if just kept in the one campsite for the duration of the holiday is adequate. After all if you have a caravan then you have a car with you and the Island is just not big enough for the need to tour in a caravan. People can just tour the Island in their car and the caravan will not be too far to go back to at the end of the day. That is my opinion. Kind regards, June Nicholls Nicholls, Maurice Sent: 10 July 2014 13:51 To: committees Subject: Towing Caravans Dear Sir, Regarding the proposal to allow towing caravans on the Island I am against this. The roads are just not right for this and it would cause lots of frustration on the part of all the other drivers. The Island is just not big enough for people to need to tour in a caravan. Nowhere is far enough away to not be able to use the car to get back to the campsite each night. There are always lots of moans about the amount of motorcaravans left parked in the road for weeks on end and if residents decided to buy caravans to tour the Island where would they keep them when not using them. I think the present system of allowing caravans on the condition they stay on the one campsite is the best and it should be kept this way. Regards, Maurice Nicholls Oram, Ann From: Ann Oram Sent: 29 June 2014 11:59 To: committees Subject: Towed caravans To whom it may concern A resounding NO to the suggestion of towed caravans on the Island.

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202 It is bad enough with the amount of the horrible motor homes clogging up roads and taking up parking places also being parked outside peoples homes. It is totally wrong to even suggest the idea. They would be impossible to monitor and they would end up parking in the most unsuitable areas. There is absolutely no monetary value to traders or hoteliers as these vehicles are self sustaining. Only the Steam Packet would profit providing the caravanners could afford the outrageous fares!!!! So to this stupid idea,so again NO NO NO NO never. Yours sincerely Ann Oram Pattinson, Nicola From: Nicola Pattinson Sent: 10 July 2014 13:00 To: committees Subject: Caravans on the Island Dear Sirs. I write to this committee as a B&B proprietor and a former resident of Bowness-on-Windermere. As the latter, I have first hand experience of working on a campsite, a local shop owner and as a resident. Caravaners as a group do not tend to spend in the area in which they holiday. Their caravans and cars are loaded before they leave home with everything they need from clothing to food to entertainments. They do not use public transport as they have their cars with them; they don't use local restaurants because they have their own kitchens and food with them; they don't frequent local pubs because their fridges are packed at their cheaper local supermarkets before they leave home. What they do bring is a burden to waste disposal, traffic congestion, ugliness to the landscape and presumably if you have to open new sites, more land removed from agricultural production, further decreasing our food security. The average cost for a non-member at a caravan club site is £10 per night. This could well be a family of 4. It would be better for the Island if they instead, rented a self-catering cottage, bought their food on the Island and caused no more congestion than anyone else. As a final note, I don't believe that Mr and Mrs Caravan family are potential B&B guests, so in this instance, I am not concerned with self-interest but the negative impact that these ugly tin boxes would have on the community and the landscape, Yours faithfully Nicky Pattinson Pearcey, Joanna From: joanna pearcey Sent: 10 July 2014 21:20 To: committees

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203 Subject: Against caravans I agree with static caravan sites which are great for tourism, but towable ones a big no. It would make it too easy for travelling gypsy's to come to the island and after seeing the damage and destruction and the total disregard for people's property in the uk, there would be no way to evict them from farm fields they take over, as the only way is to go back on the boat which will be near impossible. Ms Joanna Pearcey Pennington, John Sent: 22 June 2014 20:12 To: committees Subject: Caravans Dear Sirs, I am pleased to submit, for your consideration, my views on the possibility of allowing trailer caravans on the Isle of Man. From 1974 to 1997 and living in the UK, I owned a trailer caravan, with which my family toured extensively throughout the UK, Ireland and continental Europe. We used sites of varying standard, from the very basic to the high standard sites operated by the Caravan Club. Ferry Travel To IOM: The layout at Liverpool Landing Stage does not appear to be suitable for trailer caravans, and the vehicle lanes on the Mannanan are barely adequate for large cars, let alone for the width of caravans. Thus, it appears that Heysham and the Ben my Chree would be the only suitable route. Currently, loading of the Ben can be time-consuming, and I suspect would be even slower if significant numbers of trailer caravans were to be conveyed. Roads on the IOM: I am sure that others will be expressing concerns at delays to other road users. A major concern is the narrow width of many roads (such as Port Erin to Cregneash), and I suggest that a network of 'approved' routes would have to be compiled and enforced. Sites: Caravanners have come to expect a high standard of sites, with adequate entrances, hard standings, electric hook-ups, water points, and chemical toilet disposal facilities. Despite most modern trailer caravans having toilet/washroom facilities, these are often cramped, and so modern toilet blocks with shower facilities are expected. These would be expensive to provide, and any potential site owner would need to be convinced of sufficient patronage before committing to the cost of investing. If high standard sites were not available, caravanners could be tempted to find their own informal locations such as near Port Erin breakwater, Langness, Peel's Fenella Beach car park, Ramsey Mooragh Promenade, or the Point of Ayre. Potential problems include disposal of rubbish, and emptying chemical toilets. This is currently not a major issue with motorhomes, as the owners generally drive home after a short period. However, with trailer caravans, these can be left in-situ for lengthy periods whilst the tow-vehicle is used to explore the island. How would trailer caravans be confined to holiday makers, such that less desirable categories of caravan users were excluded? In the UK it has been found necessary to place height barriers at the entrances to picnic areas and rural car parks. It has been necessary to construct ditches or rows of posts to keep out such categories from village greens and from sports grounds. In Ireland, I recall the absence of lay-bys in order to dissuade informal use by caravan dwellers. Would such measures be possible or acceptable to motorhome users on the IOM?

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204 Shopping: In order to save money and reduce holiday time spent shopping for provisions, many caravanners shop at their home supermarket, and fill their caravan lockers and fridge with food supplies. Thus the main food supplies bought on holiday could be limited to milk and bread. Clearly some meals can be taken at restaurants, but modern caravans have well equipped kitchens. In summary, you will gather that I am not in favour of allowing trailer caravans on the IOM. If they were to be allowed, I trust that you will ensure that adequate safeguards are first put in place. Yours faithfully John Pennington Price, Steve From: Steve Price Sent: 14 October 2014 08:31 To: Downie, Alex (MLC) Subject: Caravans Hi Alex Just heard on Manx radio about the consideration of allowing caravans on Manx roads. How do members of the public object - this is the stupidest idea I have heard in a long time. Our roads are not suitable - they will be a menace. Frustrated drivers will take risks and we will get more accidents. I used to live in a part of Essex that had many small country roads much like the roads here and touring caravans were a nightmare. As an island we try to attract motorcycles here and in that we are successful. I think we will end up losing some of this income if touring caravans are allowed. If this idea goes ahead then at the very least they must be banned during TT and Classic TT/MGP. Cheers Steve Quayle, Peter K. Sent: 28 June 2014 10:45 To: committees Subject: Touring Caravans in the Isle of Man Sir With reference to your requests for views on touring caravans on the Island, I would like to submit my thoughts which I hope you will find useful in your considerations. We have lived on the IOM for about 5 years, having moved over here to retire as I am of Manx stock. We were living near Epsom in Surrey, which, as you probably know, is the home of The Epsom Derby Horse race, held every year in June. This event also attracts hundreds of 'travellers' with their caravans and they treat it as an annual holiday. They are usually parked up on Epsom Downs for 3/4 weeks around the times of the race meeting. A specific site is set up for them which they use, but it is a known fact that the crime rate in the area rises quite dramatically during this period. When it is time for them to go, they start looking elsewhere in the area to pitch up. This causes more problems because any open land which is not secured seems to be a target for them. They are not fussy where

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205 they pitch up, eg. football pitches, playing fields, parks and common land are all used, and the mess that is left when they go is absolutely disgusting and a health hazard. The problem then arises of trying to evict them which is a very long and complicated system, sometimes culminating in violent confrontations with the authorities. Then the whole problem starts again for someone else. If we were to allow touring caravans on to the IOM, what safeguards would be put in place to avoid situations such as these? We are also caravan owners and store our caravan in the UK. We normally use proper caravan sites of which there is no shortage. There are a few sites over here but in my opinion not suitably equipped for a large number of caravans. Most caravan users are responsible people, but you only need the odd few! Free camping (caravanning) would become a massive problem and it could result in some of our beautiful and picturesque locations becoming unofficial sites. Our roads are not really suitable for a long towing unit and it is not easy to reverse in a small space. I also feel that the charges that would be levied on cars towing caravans by Steam Packet would be exorbitant. I strongly feel that it would be a massive mistake to allow caravans on the Island for these reasons and hope you consider these points in your deliberations. Thank you Peter K Quayle Quirk, Rosalind 25th June, 2014 Dear Mr Corkish CARAVANS I wish to register my objections to the proposed addition to the caravans already on Island. As a member of Sulby and Lezayre Heritage Trust I was their representative on the Sulby Claddagh Liaison Group, who met, over a number of years, to try and resolve the problems associated with motorhomes and caravans parking indefinitely on Sulby Claddagh. The matter has been favourably resolved, but at a yearly cost to the Taxpayer. Recently, viewing For Sale properties, I was constantly put off many by the fact that the outlook would be a neighbours motor home sitting on their driveway. The idea of caravans moving around our roads is a step too far. Living on the T.T. Course as I do, every year, over the Race periods I leave my car in the garage and try not to use the roads at all. My concerns proved right, this year a neighbour lost his life in a collision on the Course, half a mile from my home on open roads. A purpose built caravan site would need to be well screened, and vetted yearly by Government. I have seen some very seedy sites elsewhere. Caravan owners are not big spenders, The Steampacket will be the only group to benefit. Within the past month the National newspapers, carried horror stories and photographs, of Travellers taking over well kept local Parks and when moved on, with difficulty, leaving behind a mountain of rubbish.

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206 I am fully in favour of all vehicle owners paying for their ROAD parking spaces. Long overdue. Garage owners usually use them and pay for the privilege on their local Rates. Travelling from Ramsey to Foxdale I witness the difficulties of driving through Kirk Michael and Foxdale due to parked cars. When are these areas going to have off street parking? Too much focus on T.T. Cater for those who want luxury. A high class hotel in the South of Island would be welcomed. Replacement hotel in Ramsey very basic. Yours sincerely Rosalind Quirk Copies to: Mr C. G. Corkish. Mr A.F. Downie. Mr D.J. Quirk. Mr W. E. Teare. Randall, Carol Sent: 22 June 2014 13:24 To: committees Subject: Caravans The roads are clogged enough already they will bring their own food and it won't be worth the expense of running a site with all the showers toilets etc. The joy of this Island is that there are no caravans. Please don't do it!! Carol Randall Redhead, Keith From: Keith Redhead Sent: 10 July 2014 21:09 To: Roger Phillips; Geoff Corkish Cc: Laurence Skelly; Phil Gawne; Subject: Caravans Dear sirs, Please find below the text from a recent e-mail that I sent to the our MHKs relating to caravans. Unfortunately I was unaware of the timescale for the submission of views from the public and missed the 17.00hrs deadline earlier today. I do however believe that my views, base on real experiences, are valid and worthy of consideration by the committee and trust that they will be considered. Yours faithfully, K E Redhead. Caravans:- There is I understand a committee looking into the possibility of bring towed caravans to the Island. As an ex-caravaners in the UK let me firstly say that our family loved our caravan and enjoyed a number of holidays in the UK and Europe. However in the context of the Isle of Man one has to look a little deeper. We loved our caravan because it was cheap. We had no hotel bills, we took a great deal of our food and clothing with us and what we were short of we bought at the

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207 cheapest local Tesco, Safeways, etc. The children played in the caravan park pool or play park and occasionally we visited a local attraction. Whilst our journeys were thankfully incident free we held up our fair share of traffic negotiating towns, villages, and inclines. We struggled through the narrow country roads and we saw our fair share of unfortunate caravaners who's journeys were not so smooth. We have seen caravans on fire when the owners drove off without turning off their gas supplies, on their sides when the wind caught them, with the bodies completely separated from the chassis due to collisions, trapped in dead ends unable to reverse out, trapped in a narrow road when two caravans approached each other from opposite directions, and we have seen tow cars on their roofs when the units snaked uncontrollably. We have seen frustrated car drivers and motorcyclists perform some horrendous and risky overtaking manoeuvres attempting to get past caravans. In reality I don't believe they will bring anything to the Island in terms income from hotel bed nights or restaurant covers but they have the potential to wreak havoc on our roads, stretching the RPU, and causing accidents costing hard earned tax payers money to sort out. The only beneficiaries would be a few land owners and the Steam Packet Company. I trust that my comments will be accepted as intended which is to be questioning, constructive by adding to the debate, and based on my own experiences. Reed, Barbara From: barbara reed Sent: 30 June 2014 15:17 To: committees Subject: NO to caravns on the island I have had a discussion with several people over whether towed caravans ought to be allowed on the island and it was a resounding NO, the comments were as follows. We do not have dual carriageways or motorways over here so if you get stuck behind a caravan being towed you are going to find it very difficult to overtake which in turn can lead to long streams of traffic, causing chaos on the roads. It can also lead to unwanted travellers venturing over here ( we are as near to Ireland as Britain) and setting up camp where they please, this would mean we would need to do a Reactive Legislation which could take months to get rid of them. I have lived across and seen first hand a gipsy camp set up on a grass verge by a motorway so any green space will do!! Lastly, have we got sites to accommodate caravans, I know we have camping sites but surely if people want to visit our lovely island is it not better for them to fill our hotels and get revenue for the island rather than bring their accommodation with them? regards B. Reed Reynolds, Brenda From: Brenda Reynolds Sent: 11 July 2014 17:44 To: committees Subject: Caravans on Isle of Man

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208 The purpose of this email is to register my opposition to the government changing the current status of caravans in the Isle of Man. while I understand the governments desire and need to generate funds to keep the islands economy healthy, this idea is a non starter. The cost to the island residents and lovely landscape in terms of caravan parks, congested roads etc far outway any minimal tourism benefits given that by their nature caravans are self sufficient and the idea is not to need hotels, restaurants etc. In addition, the people who are currently attracted to live and holiday on the island due to its beauty and fairly uncluttered roads will certainly be put off after being stuck behind caravans on the island roads. We also have not had problems like some small villages in the uk with caravan squatters, which may change once the doors are open. I think a better use of the committee on caravans time is to draft some lesgislation on controls for caravans already here and owned by residents to ensure the rights of the few do not infringe on the rights of the majority to enjoy the manx countryside as has been the complaint at Fenella Beach. Thanks for your time and consideration of my comments, regards Brenda Reynolds Richmond, Phil From: Phil and Kathie Richmond Sent: 10 July 2014 16:37 To: committees Subject: No to caravans I wish to register my view regarding towed caravans on the Isle of Man. I am against them mainly because they are likely to cause more congestion on the roads. The island's roads are not suitable for such vehicles. P Richmond Robinson, C. 7/7/2014 Sir I would like to strongly object to having caravans on the Manx roads. Yours sincerely C Robinson Roome, Laurie From: laurie roome Sent: 27 June 2014 11:35 To: committees Subject: Caravans on the island.

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209 Dear Sirs I own a motorhome and have an interest in camping on the island. This month I already spent 3 nights in the excellent site at Peel. I am a member of the Manx Motorhome Club and we meet once a week at selected sites around the island. I have not wild camped on the island yet, but may do some time in the future, for a single night and like most if not all responsible campers make sure that I take everything away and leave no sign that I have stopped anywhere. On the face of it caravaners are a similar breed and are responsible people, but I do have concerns about the congestion and the suitability of most of our smaller roads. However, being a comeover some 8 years ago, what is a major concern to me is the travelling community .If caravans were allowed without restriction then the island is ill prepared for them . I have experienced myself what impact they have on a community both with low level crimes increasing ten fold over night, rubbish being left, large uncontrollable dogs running around and kids with no schooling on the loose.etc .Believe me locals will long for the days when dog poo was their only concern.I have seen them pitch up in laybys, farmers fields and car parks, not moving on until they run out of space for their rubbish or court injunctions are made and then only move on a few hundred yards when the whole lengthy and expensive procedure starts again. The island community particularly outside Douglas will be reach pickings. If you go across you will notice most farms now have huge concrete blocks at their more isolated entrances, to deter them and for some councils like my old one in Essex it is a constant process of litigation and moving them on. Dale farm when finally cleared cost £18 million pound according to Wikipedia and the problem did not go away just moved onto several other smaller areas. It will be like foxes, once we get them them we will never loose them and life will never be the same. I know this may not be politically correct, but I have seen what can happen, speak to Councils across. Mr L.Roome Scarffe, Patricia From: Patricia Scarffe Sent: 08 July 2014 09:29 To: committees Subject: Caravans I came to the island from Wales in 1997, and was delighted that the beauty of the Manx countryside and coastline had not been scarred by caravan parks. Welsh countryside and coastal beauty has been destroyed by the spread of caravan sites. Caravans will add nothing in economic advantage to the island - caravan owners load up with essentials before leaving home. They will deter the tourists who come here for the unspoilt (largely) beauty of the island. Island roads are not suited to caravans. Sad to say, I believed the Corkish hype before the last election only to find that he was not interested in his role as a MHK. A mistake that sadly can not be rectified. Patricia Scarffe Shimmin, B.S. 27th June 2014 Dear Sirs,

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210 Regarding towed caravans, I cannot imagine why this proposition is even being considered. Our roads are already congested beyond belief and to allow towed caravans to come to our lovely island would be, in my humble opinion, a great mistake. I feel you should be trying to reduce the amount of traffic we have, which I am sure is not beyond the realms of possibility. It just needs someone with the will to do it. Yours faithfully B. S. Shimmin (Mrs) Smith, Ron P. From: Ron Smith Sent: 27 June 2014 16:09 To: committees Cc: Ron Smith Subject: Opinions on Caravans (Courier) I am against any relaxation of rules allowing towed caravans on Manx roads. The reason is that I believe the island's roads are already difficult and unsafe enough. I also do not believe it is appropriate that the islands road system should be significantly extended / enlarged - just maintained. I would like to see more done to discourage rather than encourage large and long vehicles of all types. The least I would find acceptable is that these larger vehicles whether towed caravans, campers, RVs or even large trucks etc., whether visiting the island or resident, are subject to some sort of extra charge for the privilege of taking more road space on a very limited road network. I would like to see more done to discourage the bringing of any large vehicles to the island also by encouraging more appropriate local transport alternatives. regards Ron P Smith Stembridge, Sylvia copies to David Quirk....Alex Downie 22nd June 2014 Dear, Geoff, I cannot believe that you are even contemplating introducing static caravans on the Island. It does make you wonder how far you are all prepared to scratch .the bottom of the barrel! I cannot believe that any Manx man would want to see the riffraff and foreigners that would be depositing themselves here, then claiming benefits etc. demanding their human rights, while we Manx indigenous population have no rights to work or services in the EU. To say it would be only for a period of time each year, really is rather naive, you would have human rights fanatics down on the Goverment like a ton of bricks. We used to visit a beautiful spot in Devon called Blue Anchor, then almost overnight the head and was covered in these static caravans, dogs, didycoys..the lot. Even beautiful Mousehole in Cornwall did not escape.

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211 Where are you going to put them? Douglas Head? The lhen? Bradda Head? Noble.s Park? Onchan Park Golf range. Or a Dandara field..which appears to be half the Island anyway.! It is bad enough having so many Poles and Philippines people added to the population. We are certainly going to run against the once proud slogan of the Island."its our differences that make us different." I think, for once, I agree with a Scot. The Speaker of the '. It is ludicrous in my estimation....Will not make a scrap of difference to me but I have Grandchildren and G Grandchildren as you probably have, it would be a sad inheritance to leave them without a sense of belonging ,as this will only fuel disrespect and fuel another Nigel Farage to raise a head. To even contemplate such an action, is to me, an insult to my father, and your Grandfather who we are supposed to be remembering with respect and thanks this particular Year...their sacrifices to enable us all to enjoy, freedom of speech, word and deed. It is really insulting to their memory.. Quite hypocritical in fact. The enclosed is what the House needs to concentrate on, it has never been revoked, just ignored. If you let these people in, then under this same document....you have to give equal treatment. And the ones who take advantage of this non-compliance, will be the ones who will have done their homework. They will never shift, then we will not be counting pounds we will be scratching for pennies. Then we really will become a suburb of Liverpool! I find it all very sad they had a gang of five in China, they shot them!! We have a gang of eight.!!! who appear to rule the roost. If you want something to sort sort that lot. Sylvia Stembridge Stowell, Brian From: Brian Stowell Sent: 10 July 2014 14:15 To: committees Subject: Towed caravans I'm completely opposed to allowing towed caravans in the Isle of Man. It would be an act of madness to go for this - increasing danger on Manx roads and damaging to the environment. Don't do it! You can publish my response. Dr Brian Stowell Sullivan, Ursula Sent: 01 July 2014 15:41 To: Jonathan King Subject: Re: Towing caravans Thank you for the opportunity to respond. I am very concerned that the Isle of Man would be open to the problems of Migrant 'Travelors'. Having lived in the United Kingdom for many years and seeing first hand the huge financial cost in removing them from land squatting, the crime on surrounding farms and houses and the Wholesale

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212 rubbish of these squats, I would think it wholly irresponsible to even contemplate any excuse where such 'visitors' are legally allowed to bring their caravans on to this island. Mrs Ursula Sullivan Tawney, Alex From: Alex Tawney Sent: 28 June 2014 18:14 To: committees Subject: Towed Caravans 1.There are very few roads on the island that lend themselves to unlimited overtaking so the initial problem will be frustration and probably ensuing dangerous driving actions as traffic builds up behind one or several towed caravans. 2. The problem at roundabouts will not be unsimilar to the Bendy bus situation where it is impossible to exit a roundabout safely whilst a double length vehicle is astride both carriageways. 3. Many caravan sites are not on main roads so there will be ensuing problems if people get lost and cannot turn in the standard road width. 4.Most towed caravans are driven at considerably higher speeds on motorways in the UK and Europe 5. In a sudden braking situation, it is possible that the caravan will twist on the tow bar and overturn and very likely disintigrate. This will cause a major road closure for several hours along with need to provide suitable recovery vehicles. I have driven a towed caravan on both motorway, main and country roads so am aware of the impending problems. As such, I hope this idea is put to bed immediately The islands roads are already over choked with traffic and the back roads are as bad as the main roads. The permission for towed caravans would exacerpate the situation, particularly in the summer months and around TT fortnight. Towed caravans parked in off street parking will increase problems for emergency services. The government would be better considering reducing the numbers of cars per household to ease up both road travel and parking before it adds to the problem. The islands roads cannot cope now, never mind an unwelcome increase of traffic. Alex Tawney Taylor, Nigel (1) On 29 Jun 2014, at 19:58, "Nigel Taylor" wrote: Gentlemen, I understand you to be a committee tasked with reporting on the advantages and disadvantages of permitting towed caravans on the island, with one specific point of reference being the encouragement of tourism. Mr Downie is reported in the press as suggesting that these may be a huge untapped market. This implies that the caravan fraternity will make a significant contribution to visitor spending. I suggest that nothing could be further from the truth. Most caravan users bring with them not only their accommodation, but also their food, drink, etc.. Being self sufficient is part of the charm of the caravanning experience. The only beneficiaries would be the Steam Packet and the operators of caravan sites that would be a serious blot on our beautiful countryside. Make no mistake about this, there is no such thing as an attractive caravan site. As a business owner in the hospitality sector I very much welcome the encouragement of quality, niche tourism that can have a positive impact on our economy. Allowing towed caravans on the

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213 island will at best make only a marginal financial contribution and this is far outweighed by the negative consequences that would result. In addition, caravans are notorious for causing traffic congestion and have a negative impact on road safety. Our road network is ill equipped to deal with an influx of caravans towed by motorists who are not familiar with our roads. A further and seriously detrimental consequence would be the inadvertent opening of the door to 'travellers'. The unlawful development of traveller sites is a serious problem in the UK and a constant battle ground that wastes untold time for local authorities, the Police, the Courts and affected residents. The unlawful development of traveller sites is a common and hugely controversial issue for many communities. The problems can arrive all too easily, but be extremely difficult to deal with effectively in an environment were 'human rights' often trumps common sense. Anyone who has suffered from such problems will confirm that objections motivated by prejudice will not find favour and that the local authority will likely be under pressure, or even a legal obligation, to provide housing for travellers. The legal issues can be quite complex, not least when travellers make a strategic purchase of a small plot of land. Are we confident that these problems could not arise on the Isle of Man and that we have all the laws in place to guarantee our protection? Would are planning authority have the powers and the ability to act with the speed that may be required? Why open the door to such problems? For as long as the island prevents caravan access we can avoid such painful and costly issues. Please let's not make a make a serious mistake that we will all regret for many years to come. Kind regards Nigel Taylor Managing Director Rock Food Concepts Limited (owners/operators 14North restaurant, Little Fish Café and bath & bottle. Taylor, Nigel (2) Gentlemen I refer to our recent correspondence and wish to revisit the subject in the light of a report in the press that Rushen Commissioners have given their approval to a planning application filed by one of the Commissioners who seeks to create a motor home park and camp site on agricultural land at Rushen. If the Commissioner concerned secures his planning approval the new facility will no doubt be made available to towed caravans. One wonders whether the planning application is in anticipation of the floodgates being opened to more motor homes and towed caravans. I am firmly of the view that this would be a seriously retrograde step for our beautiful island. I do hope that the select committee will taken an interest in such planning applications. Kind regards Nigel Taylor Teare MHK, Eddie 4th July 2014 Dear Sir, Caravan Consultation I feel that it would be a most unwelcome intrusion if towed caravans were allowed onto the Island's roads. My wife's family lives in the Lake District and when we visit them during the summer months,

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214 the roads are congested with caravans which impede the traffic flow. Long tail backs of vehicles ensue and some drivers feel that they have to take unnecessary risks out of frustration. We value the quiet, uncomplicated rural nature of the Island and I feel that caravans would adversely affect our quality of life. Additionally I feel that we should encourage visitors to use paid for accommodation as the main beneficiaries of caravans would be the ferry operator not the local economy which would have to deal with the impact of their presence. There were some towed caravans parked on Sulby Claddagh, when I drove through the area earlier this week, and I was disappointed with the general appearance of the caravans which looked shabby. In all it detracted from what is a place of outstanding natural beauty. Surely we would not wish to increase the adverse environmental impact associated with their presence? Yours faithfully, Eddie Teare ACIB MHK Wade, John From: John Wade Sent: 27 June 2014 13:45 To: committees Subject: Caravans on Island Roads Dear Sirs I wish to put forward my objections to the possibilty of the acceptance of caravans on the Island’s roads for several reasons which are as follows: Any site where caravans would be located will ruin our beautiful Island – one has only to look at the sites for example in North Wales such as Rhyl, Talacre etc which are a complete blot on the landscape. The Island’s roads are simply not up to having them – again look at areas such as North Wales, Devon, Cornwall etc where miles of tailbacks occur behind caravans with those following drivers becoming frustrated and hence usually taking risks to overtake them which can result in accidents – many of which are severe and result in fatalities; do we want that? Motorised “mobile homes” should also be banned – the roads around any housing estate are also presently festooned with such contraptions meaning they are parked on the road making it extremely dangerous – certainly now children are unable to play in the street because of these dangers. If towed caravans were also to be allowed, further parking of them in the streets would make it even more dangerous. What advantage do they offer to the Island – hoteliers and such would lose out on revenue. I trust you will take my objections and comments into account when you are undertaking your deliberations. Kind regards John W John Wade

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215 Walls, N. 21st June 2014 Dear Sir In regard to the recent consultation surrounding the introduction of legislation to allow ‘Towed Caravans’ into the Island I am firmly against such proposals. The road network on the Island is too narrow for safe negotiation by these vehicles; and the countryside is too attractive to be despoiled by these monstrosities. The likelihood is increased in favour for gypsies and other vagrant groups to spend time camped out around our Island. Yours faithfully N Walls Warren, Matthew From: Matthew Warren Sent: 20 June 2014 17:16 To: committees Subject: Caravans I would like to object to Towed caravans on the Isle of Man. There are major issues in the UK with caravans stopping at illegal sites, antisocial behaviour and dumping rubbish. Fixed caravans with a Special permit for Holiday use would be acceptable. I would not like to see caravan parks used as cheap living accommodation. It should not be a permanent address. If fixed caravans are agreed, then laws for their use need to be set and enforced. Holiday lets would be the best worst option. If people were able to buy a caravan on a holiday park, laws concerning rouge landlords need to be covered. As the market in the UK seems to be upgrading, to log cabins & “Glamping” in Yurts a move to use caravans seems like a backward step. Log cabins in the forest environment would seem like a better option – perhaps in the ‘new forest’ planned for the north of the Island? Thank you Matthew Warren Watterson, David Sent: 23 June 2014 12:01 Subject: caravans Dear committee, Surely you have more important tasks than wasting your time,and our money,on considering whether trailer caravans should be allowed on the Island ! The idea is as ludicrous as having "bendy buses " NO to the suggestion.

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216 If you are desperate to have caravans ,have a discreet, landscaped static trailer park in the north of the Island .A park with about 40 government bought trailers which can be mortgaged only to first time buyers, as a way of getting them on the housing ladder. The scheme would of course have inbuilt caveats to avoid it being abused . Oh , no private wind turbines ,even for the filthy rich ! Regards, David Watterson. Waugh, Jim From: Jim Waugh Sent: 30 June 2014 08:39 To: committees Subject: Towed caravans on the Island Im a caravaner and have been towing for 20 years. I beg of you please do not spoil your lovely island by allowing caravans to be towed around it. Your roads are simply not built for them. The island will come to a grinding halt and you will have a permanent traffic jam at Ramsay Hairpin as idiots try to tow oversized vans over the mountain.. Part of the charm of your lovely island is the lack of traffic and the free flow of the little that there is.. If you want to increase tourism do something about the monopoly that the Steam Racket company has and reduce the cost of getting across. As a non resident I’m not sure that my opinion will have much sway but I thought Id give it anyway regards Jim Waugh White, Diane From: Diana White Sent: 29 June 2014 20:26 To: committees Subject: Caravans Caravans are a nuisance and a danger to other road users they are not built for our roads and the roads are getting congested enough as it is, we don't want or need them. I understand that they are allowed here as long as they take them to their final destination that's fine but we dont want them trundling along and have you thought about where they are going to park, parking is getting a problem now, what is it going to be like then. NO TO CARAVANS

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217 Wilson, R. & J.E. CARAVANS Since touring on holidays in the Lakes, Scotland and Devon & Cornwall in 1967 onwards we have been thankful that NO CARAVANS were allowed on the Island. They caused massive congestion on the small roads (similar to the Island) and major blots on the beautiful areas of the above places. KEEP CARAVANS OFF THE ISLAND. R Wilson J E Wilson Wilson, Wendy From: Wendy Wilson Sent: 21 June 2014 10:13 To: Enquiries Subject: Caravans With respect may I make the following points regarding caravans on the IOM Presumable they would be restricted to remaining on site during the visit and not allowed to tour. Our roads are far too small for caravans to be moved about The traffic is already a cause for concern Our roads are deteriorating fast and in serious need of repair around the countryside. The movement of caravans around the island would impact on this It is known that owners and holiday makers of caravans bring over their own supplies of food as much as possible as this is easier and cheaper than provisioning on an island where all is imported. Part of the charm of the IOM and its uniqueness is its culture – a caravan culture is vastly different So far the few motorhomes on the IOM have caused little disruption and environmental issues this may not be the case with caravans. One would hope that should caravans be allowed on the IOM the ferry costs would not be subsidised –if they were it would be scandalous! How would it effect tourist accommodation on the island? Or is the government thinking of having its own caravans on site and spoil some of the best coast and countryside in Britain? Logistically and financially probably it would not be worth it. Wendy Wilson Woodland, Noel 4 July 2014 Dear Sirs, Towed Caravans to be Accepted on the Isle of Man I have just become aware of the proposition that towed caravans be permitted to visit the Isle of Man. Unfortunately I have not heard any specific discussions on the subject of why such a proposition has been made.

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218 I am a permanent resident of the Island and one of the many advantages discovered after moving here is that, apart from some rare exceptions, caravans are not permitted. I find the idea that this restriction be rescinded or relaxed to be quite bizarre. If I were to list all the reasons I can think of for not allowing caravans on the Island you would not bother to read this letter further. If you care to acknowledge this letter, you could correct me if I am wrong in saying that anyone can come from across via the Steam Packet by simply paying the correct fee, with no requirement for a reason, or to produce identification. Least of all a passport. Even a false name and address might not be detected. What would prevent so-called "New Age Travellers" from simply arriving and not going back. Even the most law abiding caravan club members, if they arrived in any numbers above a few, could cause chaos on the Island's country roads. Many of which, as you know, are totally unsuitable for towed caravans. Imagine two caravans meeting on a bend, and wonder how, and which, would reverse, even if it could. Think about towed caravans coming for TT fortnight or the Manx Classic. No don't. I could go on but I won't. PLASE, PLEASE don't do it. Yours faithfully, Noel Woodland Woodman, John Sent: 06 July 2014 18:52 To: committees Subject: TOWED CARAVANS I am writing to express my dismay at the proposal that towed caravans might be permitted on the Isle of Man. My objections to the proposal may be summarised as follows: The inevitable congestion which would result from towed caravans on the island’s many narrow roads The appalling impact on the island’s natural beauty. Any static caravan park would be an eyesore. Inevitably individual caravans would be parked illegally at scenic sites, with a terrible visual impact. The adverse effect on non-caravan tourism. Walkers and lovers of the island’s current caravan-free status would be unlikely to continue to visit. Ferry travel and loading times would be adversely affected by the need to manoeuvre towed caravans. I was shocked when I first read of the proposal. The absence of towed caravans was one of the major delights when we moved to the island several years ago. I truly hope that the proposal will go no further. If it does, it will be a very sad day for those who love the Isle of Man. I am happy for my comments to be published. John Woodman

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219 Name Withheld (1) Sent: 08 July 2014 12:50 To: committees Subject: Re: Select Committee on towed caravans To:- Chairman, Select Committee on towed caravans I note that the public have been given the opportunity to give opinions on the issue of allowing towed caravans on the Island, and I would ask that consideration be given to my views opposing the approval of caravan use as below. a) Regarding the potential encouragement of tourism I find it unlikely that there would any great benefit. From my contact with caravan owners in the UK one of the main attractions for them is that it is a very cheap way of taking a self catering holiday. For example it is likely that all food stuffs and other consumable will be purchased in the UK before arriving here. As they will have their own transport available they will primarily utilise that rather than making use of the local public transport other than perhaps the odd trip on a tram and train. I can forsee that the caravans will also be sited at at areas such as the Ayres, Langness, The Cladaghs etc where there is currently unregulated access. I have personally witnessed a number of caravans already using these sites this year. Why would anyone choose to pay for a site if these are free? If these areas are to be regulated who will police them and at what cost? Unless there is some form of enforcement available up to midnight 7 days a week all around the Island then it will be impossible to enforce. Obvioulsy this would not be possible. Should we not be encouraging tourists to utilise the hotels, restaurants etc. throughout the year to help maintain their viability. In my opinion the only limited financial benefit will be to the IOM Steam Packet Co. In the longer term I can forsee that people will find ways around using the ferry services as well by leaving caravans on the Island and letting these out with any revenue going off-island. Secondhand caravans can be purchased for as little as a few pounds in the UK. If these are brought to the Island and abandoned after a period of use who will fund the removal and disposal. b) Increasing traffic congestion - Increasing the number of slow moving vehicles on the Island's narrow and winding roads with limited opportunity for overtaking will only increase the likliehood of accidents. Given the high cost in emergency services time and resources anything that increases the potential of accidents should be be avoided. The costs involved in one serious accident could potentially wipe out any financial benefit for a period of years. c) Visual nuisance. A complaint raised by many people about caravans is the problem created by siting caravans where they can be seen by others. One of the main visitor attractions is the unspoilt beauty of the Island, particularly viewed from the hills. Any caravan site will be able to be seen from the islands favourite viewpoints and must be detrimental to the majority of visitors and residents alike. I must admit that I am already dissapointed at the number of caravans that I see on the island parked up permanently in fields around the Island. d) For IOM residents who wish to avail themselves of a caravan I would make the point that one should consider where these are likely to be kept for the majority of the year. It is likely to be primarily people living in the towns around the Island that would want a caravan. These then would either be kept on driveways at the home or as seen with motor caravans these are left on the road at various places. These can be both a physical as well as visual nuisance leading to complaints to government departments, once again increasing costs. In summary I and many of my friends are strongly opposed to permitting caravans onto the Island. Thank you for permitting me to submit my views to the Committee.

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220 Name Withheld (2) Caravan Survey July 2014 NO! My comments/submissions may be published but not my name or address. A dreadful suggestion road and lanes too narrow and little profit except for Steam Packet. I have endured towed caravans in Scotland and Southern England esp. and try to leave ‘bad’ areas immediately. Mr Quirk is correct – it is an easy step to ‘live’ in them – and what if one way ferry tickets are bought on ferry and stop travelling and stay forever on our most beautiful, peaceful places. There are also problems with the largest motor-homes. I saw one some time ago imported from U.S.A. – as long as a single deck bus – inc 2 double beds. I was relieved to hear it was destined for a ‘permanent’ park in . These long vehicles including towed caravans may explore our narrowest lanes – single track. The only large vehicles in those places should be the larger trucks etc servicing homes – essential traffic only and closely supervised. LIVING IN CARAVANS – needs to be regulated even on own land AND in motor homes. This happens in the streets of Douglas from time to time – I saw one case (neighbours now have left) some time ago. THERE ARE FEW ADVANTAGES to towed caravan tourism except for ferry company/ land owner of rented space – OTHER TOURISTS MAY STAY AWAY. TOWED CARAVAN owners travel with their own cheaply bought food inc. meat (seen on a t.v. prog. about IOM in the past). ESSENTIAL CARAVANS. I have no objections to permitted access of towed caravans for all essential purposes inc T.T. grandstand trade etc. Name Withheld (3) Sent: 29 June 2014 10:32 To: committees Subject: Towed Caravans on the Isle of Man Dear Sir or Madam, I understand that the appropriate committee is seeking public views on the above. It is self evident that this island's roads are totally inadequate for a major annual influx of towed caravans. Part of the great charm of our roads is that they are gently sized and mostly of a traditional rural flavour. The cost of island-wide upgrading would be immense and far outweigh any increase in tourism revenue. If anyone is in doubt what the roads would be like if towed caravans are permitted here, I suggest a visit to Devon or Cornwall in UK any summertime. Conditions there are hellish in summer and have been so for half a century.

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221 Further our infrastructure budgeting is constantly under pressure to keep up with existing highway maintenance requirements, to permit a surge of increased traffic would push the programme yet further behind and costs beyond reason. May be quoted if anonymised ie not for named publication. Name Withheld (4) Sent: 01 July 2014 11:38 To: committees Subject: Tynwald Select Committee on Towed Caravans Submission to the Tynwald Select Committee on Towed Caravans I am concerned at, and opposed to, the recent proposal to allow towed caravans on Manx roads. I write as a private individual. Several of my family members have lived or are living in the English West Country: Somerset, Dorset and Devon. Visiting them, particularly at weekends, I encountered many towed caravans on the roads, usually with a slow moving queue of traffic behind them on small country roads; these roads were, however, wider than most roads on the Isle of Man. This part of England was able to provide caravan sites for towed caravans only because it was a much larger area than the Isle of Man. The landscape was large and hilly enough to conceal many of these, to protect rural and coastal views, a situation quite different from our small island. Even on wide English motorways and dual carriageways, I have seen towed caravans create traffic congestion. In my opinion, allowing towed caravans onto the Isle of Man will have only a limited effect on tourism as the likely high cost of bringing a caravan on the ferry will discourage many owners of touring caravans. Furthermore, tourists bringing caravans will not be staying in Manx hotel accommodation, thus reducing the income to hotels and guest houses. It is in the nature of those taking caravan holidays to bring their own supplies of food etc. Once stocked up in Asda, Lancaster, with food and fuel, they will spend little on the island. For the above reasons, allowing towed caravans will contribute very little to the economy. Those that do come on to the island will be driving on narrow roads, often unfamiliar to the driver. Towed caravans are usually wider than the towing vehicle and my experience from England is that other, frustrated, drivers will overtake a slow moving lengthy caravan and towing vehicle in risky situations, often misjudging how long it takes to overtake the entire length of the combination. Also, caravans and towing cars will overtake slower tractors. The turning circle of a car and caravan combination is large and the island’s roads may have to be modified, particularly at junctions, to allow the safe movement of car and caravan combinations. Wide towed caravans will be particularly hazardous to cyclists and pedestrians on roads without pavements, as the combination of caravan width and limited vision in the mirror will make safe clearance of the nearside verge difficult. It is unrealistic to expect towed caravans to arrive on island and stay in one caravan park; it is the nature of those using towed caravans to move between sites, for example in the north and south of the island, with resulting road journeys. Caravans are particularly prone to sudden sideways movement or overturning in gusty winds, which are not uncommon on the Isle of Man. Climate change predictions from the UK Met Office suggest that extreme weather events such as gales will become more common. This is hazardous when moving and also when static. The safe towing of a caravan depends on the towing vehicle and the caravan being properly equipped and maintained, with the correct weight distribution and tyre pressures. For example, figures from the UK Highways Agency showed that between April 2013 and June 2013, there were

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222 1,408 incidents involving caravans on the UK’s roads. The Highways Agency found that these towing incidents were often caused by overloading the caravan or trailer, a mismatch with the towing vehicle, tyres which have burst because they have not been checked or replaced where needed, and poor towing technique from drivers. How will caravans and towing vehicles be safety-checked if these are to enter the island’s road network? Monitoring and checking caravans will carry a cost, probably exceeding any extra income unless a sizeable charge for a caravan permit is made; however, this would be a further disincentive to caravan owners to visit the island. How will caravans, normally equipped with a large bottle of gas, be transported on the ferry? The Steam Packet Terms and Conditions currently do not allow flammable liquids or gases. Are caravan owners expected to travel without a gas bottle and purchase one here; how do they return? How would numbers of towed caravans be manoeuvred on the ferry and what effect would this have on loading times and capacity for cars? There are many logistics problems for towed caravans getting to the island. Allowing towed caravans on the island may lead to Manx residents purchasing towed caravans, which will be parked in drives or on roads in residential areas. This has already occurred with motorhomes and many large motorhomes are parked for most of the year in residential areas. The proposal allows a route to bring caravans to the island and leave them here, either as a holiday home or as cheap residential accommodation. It will also be seen as a way of setting up accommodation to rent to visitors during TT, Manx Grand Prix and other sporting occasions. This will lead to the development of permanent or temporary caravan parks on agricultural land, brownfield sites or coastal parking areas; these will need utility services provided and refuse collected. For example, during the 2014 TT, motorhomes used Fenella Beach car park in Peel as if it were a caravan park, with the resulting complaints from local residents. In summary, I consider that the many disadvantages of allowing towed caravans on to the Isle of Man will considerably outweigh any advantage in terms of additional tourist income. Name Withheld (5) Sent: 29 June 2014 10:36 To: committees Subject: Consultation on towed caravans Sir, We would like to make the following comments in response to the issue of towed caravans on the the IOM; -many of the roads are unsuitable and may lead to congestion on the arterial roads -the logistics of loading/unloading and vehicle capacity on the IOM Steam Packet (e.g. if caravan becomes unhitched exiting boat then this will cause long delays to passengers or even delay sailings) -the possibility of opening up the IOM to the traveller community (which may impact on the NHS, schools and the Police) Myself and my partner are happy for our comments to be used but we wish to remain anonymous. Thank you.

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Parliamentary Copyright available from:

The Tynwald Library Legislative Buildings DOUGLAS Isle of Man, IM1 3PW October 2014 Tel: 01624 685520 Fax: 01624 685522 e-mail: [email protected] Price: £23.65