Improving access to reliable and affordable energy for park home residents

Introduction

Latest figures suggest there are 8,500 people living permanently in residential park homes on sites across Scotland.[1] These consumers face a number of challenges in accessing reliable and affordable energy. [2] They are also more likely to be older and to have long-term health conditions or disabilities. [3],[4],[5]  This briefing provides insights into particular issues that park home residents face in relation to:

• Energy supply and resale of energy
• Energy support and consumer protections
• Resolution and redress for energy and wider issues

It draws on Consumer Scotland engagement with a range of stakeholders including the Scottish Confederation of Park Home Residents Associations (SCOPHRA) and a small group of individual residents, as well as the existing policy and academic literature. The briefing also highlights potential opportunities for action, and Consumer Scotland plans to convene a workshop with relevant stakeholders to discuss what more can be done to improve outcomes for park home residents.

Background

During 2025 and 2026 Consumer Scotland undertook scoping work to better understand issues that consumers living in park homes permanently (as opposed to those using park homes on a temporary basis and as holiday homes) were facing in accessing the energy they need at a price they can afford.

We reviewed the existing evidence base and engaged with a range of stakeholders including SCOPHRA, government officials, those working in trading standards, regulators and the third sector. SCOPHRA also connected us with five residents from five local authorities across Scotland who had experienced a range of challenges, including around energy-related issues. We are particularly grateful to these residents and SCOPHRA for their contributions. These experiences should not be treated as representative, but we have included them to illustrate the nature and impact of energy-related issues that can be experienced by park home residents. 

While the objective of our work was energy-focused, it also surfaced some additional consumer issues for park home residents linked, for example, to the management of park home sites and communication between site owners and residents. We have outlined these points in the briefing as they can have a bearing on how energy problems manifest and can be resolved.

Challenges and opportunities for action

Energy supply and the resale of energy

Many park home sites in Scotland are not connected to the mains gas grid. Residents often use a combination of heating oil or Liquified Petroleum Gas (LPG) and electricity to heat and power their homes. In an unpublished SCOPHRA survey of its members in 2023, most respondents indicated that they purchased energy for home heating via their site owner.[6]

One consequence of residents being resold energy by their site owner is that they do not have a direct relationship with suppliers and have limited influence over contracts and tariffs.

Under Ofgem’s Maximum Resale Price (MRP) arrangements, site owners cannot charge residents more than they pay for the electricity and gas that they resell. They are allowed to apply reasonable charges for administration costs (e.g., meter readings, invoice preparation) so long as these are set out in the written agreement, which is a form of contract between residents and site owners. Heating oil and LPG and are not regulated in the same way as electricity and gas, so site owners can impose additional charges and profit from the resale. Residents can request an explanation of how charges are determined under the terms of the written agreement with their site owner.

SCOPHRA and the five residents that we spoke to indicated that transparent, accurate and timely invoicing can be a key challenge. The following example illustrates this: 

Example 1: Problems with invoicing of resold energy

One park home resident told us that they stopped receiving invoices for electricity after residents raised concerns about how much the site owner was charging them. Despite multiple attempts by the residents to reach the site owner there was no communication, and residents feared they could be thousands of pounds in debt and at risk of disconnection. 

Residents managed to contact the relevant supplier, despite not having a direct relationship with them. The supplier informed them that a bill had not been paid by the site owner for over six months but could provide no further assistance.

Separate advice provided to the residents said they should take the matter up with the site owner, and if the issue could not be resolved they would need to take it to the Sheriff Court.

When a site owner arranges the energy supply and resells to residents then the owner is responsible for the contract with the supplier and for paying the bills. If bills remain unpaid, debt mounts, and supply could be potentially disconnected and the contract terminated. Ofgem provides guidance to non-domestic suppliers on good practice around debt and disconnection which clearly states that suppliers should have approaches that “identify sites within their non domestic customer base which have domestic residents (who may also be vulnerable), for example care homes, heat networks, or mobile parks, and to treat them in an appropriate manner.”[7]

The lack of communication reported in the example above highlights the importance of the relationship between site managers and residents. It illustrates the lack of agency that consumers can experience when the site owner is responsible for dealing with third party contracts, such as for energy supply, on their behalf, and highlights the negative implications for consumers’ energy supply and billing that can occur as a result of difficulties in the owner-resident relationship.

The example below, provides a further illustration of these issues.

Example 2: Difficulties with challenging site owners on energy charging

A park home resident told us that when a number of residents on the site requested details of how electricity bills were calculated, the site owner reacted badly and was verbally abusive to a number of residents. This led to the police being called.

The resident told us that police had been called to the site on several occasions, for a variety of issues.

The resident reflected that although several residents across the site had experienced issues with the owner, they were not prepared to speak out about it, adding that residents approached the site owner in pairs due to concerns for their safety.

These issues are not new. Research examining the wider set of challenges faced by consumers living permanently on park home sites, and published in 2013 by Consumer Focus Scotland, highlighted problems around electricity, gas and water supply and billing.[8] A briefing produced a decade later in 2023 by the Scottish Parliament Information Centre (SPICe) for Members of the Scottish Parliament (MSPs) identified problems with the overcharging of residents by site owners for utilities including electricity, gas and water.[9]

Both the research and the briefing also highlight problems associated with poor site management and raise questions about the process for determining the suitability of some site owners to own and manage park home sites.

Opportunities for action

A key potential area for action is around the MRP arrangements, which Ofgem are currently reviewing. Consumer Scotland has submitted evidence as part of this process. [10],[11] While Ofgem are the lead body driving this work, other stakeholders have a variety of roles to play in shaping and implementing outcomes that could make a real difference to park home residents.

The MRP review presents an opportunity to:

• Raise awareness of revised resale rules among site owners, park home residents and agencies, including local authorities, who may interact with both residents and site owners on these and a wider set of park home management issues. Consumer Scotland and its consumer and advice partners are well placed to support this activity. Any information circulated to residents and site owners on the resale of energy could also signpost to information and advice on a broader range of energy issues.
• Improve transparency around resale charging with clearly presented and regular tariff and consumption information made available to end users such as park home residents. Consumer and advice bodies, as well as resident and site owner representative groups could work with Ofgem to develop enhanced minimum requirements and standardised formats regarding charging.
• Strengthen accountability, including through Ofgem being granted enforcement powers relating to the MRP by the UK Government, considering bringing the MRP into scope of the Energy Ombudsman, and exploring the viability of a resellers register.

Energy support and consumer protections

In cases where park home residents do not have a direct relationship with their energy supplier, the support available in relation to their energy supply and/or bills can be more limited or more complicated to access than it would be for consumers living in traditional bricks and mortar homes. This is not ideal given, as highlighted previously, park home residents are more likely to have one or more vulnerabilities.[12] The unpublished 2023 SCOPHRA survey indicated that worries about heating homes and levels of fuel bills were common amongst residents. 2013 Consumer Focus Scotland research also found residents experiencing problems with fuel poverty.[13]

Park homes residents can fall into what Age UK defines as the ‘commercial supply trap’, i.e. where domestic users are supplied their electricity and/or gas through non-domestic contracts and as a result miss out on the protections that other domestic consumers enjoy, including the energy price cap and debt support. [14]

If they don’t have a direct relationship with a supplier, irrespective of the type of contract, eligible park home residents could also potentially find it more difficult to access or not be aware that they can register for the Priority Services Register (PSR). The PSR is free to join and means that energy suppliers and electricity and gas networks operators are aware of, and can provide additional support to, vulnerable consumers at particular moments in time. This includes, for example, when there are power outages, and more general services such as tailored communications and assistance with meter readings.[15]

Energy bill support can also be more difficult to obtain for residents. In Scotland, most eligible consumers now automatically receive the Warm Home Discount (WHD), which provides a £150 reduction in their energy bill. Residents living in park homes still need to apply through a separate WHD scheme run by Charis. This relies on residents being aware of and applying to the scheme, which operates on a first-come, first-served basis.[16] While recognising the importance of the Charis Park Homes Warm Home Discount Scheme in making energy bill support available to residents, SCOPHRA also noted that some residents find the application process difficult and that decisions on eligibility can vary from year to year.[17]

More generally, accessing support by application rather than automatically receiving it can create barriers for consumers. This was borne out by evidence in the UK Government’s own evaluation of the energy bill support made available to those without a direct relationship with their energy supplier during the 2022-23 energy crisis. The evaluation highlighted how low awareness of the support available limited the uptake amongst eligible groups including those living in park homes.[18]

Opportunities for action

Discussions about if and what further support might be provided to energy consumers in the face of high energy prices as a result of the conflict in the Middle East and how this can best be targeted are ongoing. The Energy Independence Bill, with its provisions for consumers without a direct relationship with a supplier and/or on a non-domestic contract (such as those living in park homes), also potentially provides a framework to help achieve this.[19] It is therefore timely for governments, Ofgem, suppliers, network operators, consumer and advice bodies, grant administrators and third sector organisations to consider what more could be done to support and protect park home residents. Actions could include:

• Assessing and strengthening the evidence base around levels of, and barriers to, take-up of different forms of energy support including the PSR, WHD and heating oil schemes. Future research and analysis could look at eligible park home consumers specifically or more broadly at groups of consumers who do not have a direct relationship with their supplier and/or are an end user of a non-domestic contract.
• Using existing and new evidence to identify and design solutions to overcome barriers for these consumers in accessing support, with mechanisms for continuous and effective monitoring, evaluation and learning built in.
• Exploring how protections for these consumers, including around fair value, accurate information and reliable products and services, could be strengthened in outcomes-based regulation currently being designed by Ofgem.

Access to resolution and redress

The fact that some park home residents do not have a direct relationship with their energy supplier limits the routes to resolution and redress that are open to them when things go wrong. Unlike electricity and gas consumers with a direct relationship with their supplier, they do not have access to the Energy Ombudsman. Problems with energy supply need to be resolved with the supplier or network operator via the site owner. Where issues arise around the resale of energy, such as overcharging, if residents cannot resolve the issue directly with the site owner, the only course of action left to them is to take the dispute to the civil courts. Example 1 above illustrates this, with residents who had not received an invoice for their energy supply from their site owner for some months advised that they would have to pursue the matter through the Sheriff Court if they could not resolve it with the site owner.

Pursuing cases through the Sheriff Court can be time consuming and expensive, requiring the services of a solicitor. According to SCOPHRA and the residents that we spoke to, the availability of lawyers with expertise in the particular circumstances of park homes residents is limited. This was also a problem highlighted by 2013 Consumer Focus Scotland research.[20] Scottish Government are working to implement legislative changes made through the Housing Act (Scotland) 2025 that will mean disputes can be taken to the First-tier Tribunal for Scotland (Housing and Property Chamber). These changes aim to make the process less onerous and less costly.[21], [22]

It is worth underscoring the point made earlier relating to the tensions that can exist between site owners and residents and potentially pose additional barriers to resolution and redress. Concerns about the behaviour of site owners towards park home residents have been raised in the Scottish Parliament, with questions raised about the adequacy of the existing site licencing regime and the ‘fit and proper’ test undertaken by local authorities to assess the suitability of site owners to own and manage sites. Scottish Government has committed to undertaking a review of the regime. [23], [24]

Opportunities for action

Action is already underway to implement changes to provide park home residents with access to the First-Tier Tribunal to pursue civil disputes and this is a welcome and important step forward. Other areas where there may be scope for action include:

• Granting Ofgem MRP enforcement powers and bringing the MRP within the scope of the Energy Ombudsman, in order to strengthen resolution and redress options specifically around the resale of energy.
• Bringing together different stakeholders to discuss the practical implementation of the Scottish Government’s site licencing review, once this has been completed.
• Strengthening the evidence base on the issues facing park home residents, including developing a better understanding of their ability to secure redress when things go wrong, which organisations they turn to when they need advice and information, and the availability and quality of that advice and information.
• Consumer and advice bodies working with other agencies and organisations, as well as residents and site owners, to understand how advice and information available to park home residents could be improved.

Conclusion

Park home residents are often an after-thought in the context of various policy initiatives, not least in an energy setting. And they are disproportionately more likely to have one or more vulnerabilities. Ensuring there are adequate protections and support in place for this consumer group is therefore vital. The intention of this briefing is to highlight several ways in which this group of consumers receive a lower standard of service than others, and to identify potential opportunities for action that can improve their experiences.

As an immediate next step Consumer Scotland will be convening a workshop inviting relevant stakeholders to discuss what more is required to develop the evidence base and advance solutions that can ultimately make a material difference to outcomes for this group of consumers.

While this briefing has focused on the experiences of consumers living on park homes sites in Scotland, a number of the insights and policy implications are also relevant for improving outcomes for residents across Great Britain.

Endnotes