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Energy Support – Park homes DRAFT GUIDANCE
Background
In response to the unprecedented rise in energy prices, the government has introduced
energy price support to shield households and businesses from spiralling prices.
This document is a simple guide and summary of how the support will apply to the park
homes sector only.
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Q. What support will apply to the park homes sector?
• The three types of support that will apply to the sector are the;
➢ Energy Bills Support Scheme-Alternative Fund (EBSS-AF);
➢ Alternative Fuel Payment (AFP): and
➢ Energy Bills Relief Scheme (EBRS)
Q. What about the Energy Bills Support Scheme (EBSS)?
• The EBSS only applies to those households with direct domestic electricity contracts
with energy suppliers. Those households will automatically receive the £400 discount
in six instalments between October 2022 and March 2023 to help households through
winter.
• Households without a direct domestic contract will receive equivalent support through
the EBSS Alternative Fund.
1. Energy Bills Support Scheme – Alternative Fund
Q. What is the Energy Bills Support Scheme-Alternative Fund (EBSS-AF)?
• This scheme is intended to provide the £400 of support for households who do not
have a domestic electricity contract such as park home residents.
Q. How will park home residents receive this support?
• The £400 support will not be delivered to park home residents through site owners.
• It will be delivered by a designated body. An announcement on this will be made in
due course.
Q. When will residents receive the support?
• The full support will be provided this winter. An announcement will be made in due
course.
2. Alternative Fuel Payment (AFP)
Q. What is the Alternative Fuel Payment (AFP)?
• The Alternative Fuel Payment (AFP) will provide a one-off payment of £100 to UK
households who are not on the mains gas grid and therefore use alternative fuels, such
as heating oil, LPG, coal, and biomass to heat their homes.
• This £100 payment will ensure that all households who do not benefit through the
Energy Price Guarantee to heat their homes, receive support for the cost of the fuel they
do use.
The £100 payment has been calculated to ensure that a typical customer using heating oil will
be offered support broadly in line with that offered by the Energy Price Guarantee for those
using mains gas to heat their homes.
• The government will continue to monitor the prices of alternative fuels, such as heating
oil, and will consider further intervention if required to protect UK households from
extraordinary fuel prices.
Q. How will park home residents receive this support?
• Households including park home residents, eligible for these payments will receive £100
as a credit on their electricity bill this winter.
• Households who are eligible for but who do not receive the Alternative Fund Payment
because they do not have a relationship with an electricity supplier, will receive the £100
through an Alternative Fund which will be provided by a designated body. Details of the
AFP Alternative Fund will be confirmed shortly.
Q. When will residents receive the support?
• Park home residents who are eligible will receive the payment this winter. More detail
will be set out shortly.
3. Energy Bills Relief Scheme
Q. What is the Energy Bills Relief Scheme?
• This scheme will provide a discount on energy bills for eligible non-domestic customers
such as businesses, schools and charities. Where those businesses and organisations
act as intermediaries and purchase electricity or gas on behalf of an end user, they will
be required to pass on the discount to the end user.
• Park home site owners act as intermediaries and will be required to pass on any
discounts received to their park home residents (end users).
• Discounts will be applied to energy usage initially between 1 October 2022 and 31
March 2023.
Q. How will park home residents receive this support?
• Energy suppliers will apply reductions to an eligible site owner’s bills between 1 October
2022 and 31 March 2023.
• The site owner will be required to pass on either all or some of any discount that they
receive to their residents in a reasonable and proportionate way.
Q. How will you ensure the reductions are passed on to park home residents?
• The legislation requires site owners to pass on any benefit to park home residents
where they act as intermediaries and procure energy on their behalf.
• If site owners do not act in accordance with the legislation, residents may be able to
recover this discount through the civil courts.
Q. Are there any exemptions for park home operators from the requirement to pass
on any discount?
• There are no exemptions, and as an intermediary, a park operator will be required to
pass on any discount in line with the regulations and guidance published on gov.uk.
There may be situations where the park home operator is already shielding the end user
from the cost of energy [see below] or not actually receiving a discount themselves,
such as if they are on an energy contract agreed before 1 December 2021 or have a low
cost contract, in which case they have nothing to pass on.
Q. How long will the scheme last for?
• The scheme will last until the 31 March 2023. The Government will publish a review into
the operation of the scheme in 3 months’ time, to inform decisions on future support
after March 2023.
Q. What are the Pass-through Requirements on site owners?
• Site owners who are intermediaries must pass on a just and reasonable proportion of
the discount to residents. They can adjust the amount they pass on based on their
charges to residents and must demonstrate to residents that this amount is just and
reasonable.
• Site owners must pass on the discount irrespective of how the resident pays for their
energy use. This includes if the site owner charges an “all inclusive” pitch fee.
• Site owners can take into account the extent to which they have increased their charges
to end users as a result of the energy crisis. For example, if the site owner has shielded
residents from the impact of increased energy prices it may be just and reasonable for
the site owner to retain some or all of the scheme benefit.
Q. Where site owners use electricity themselves to keep lights on, maintenance of
the commons areas etc, will they benefit from any discount even though they hold
a non-domestic account and are an intermediary?
• Yes, site owners will benefit from a reduction in the cost of energy through the Energy
Bills Relief Scheme. If the cost of this electricity is not passed on to the end user, and it
is deemed just and reasonable, the site owner can retain this discount for themselves.
Q. Will Ofgem’s maximum resale Price still apply?
• Yes. Site owners must also comply with the maximum resale price (MRP) set by Ofgem.
The MRP is the most anyone can charge for reselling gas or electricity which has
already been bought from an authorised supplier.
• The current maximum resale price is set at the same price as paid by the person
reselling (site owner), including any discounts such as the EBRS.
Q. How is the pass-through requirement calculated?
• An illustrative example of how the pass-through requirements apply in hypothetical
scenarios in relation to park home sites is below. Each individual case should be
considered in line with the Pass-through Regulations. The figures provided below for the
discount the site owner receives are provided as an example. The discount the site
owner receives in real life will depend on the site owner’s contract.
Illustrative application of ‘just and reasonable’ test
Example 1
.
Scenario
A park home resident buys their electricity from a site owner, who has a commercial
electricity supply contract. The site owner has five residents on their site who all pay
equal costs for the same amount of energy.
The site owner passes 100% of the full amount of its energy cost onto its park home
residents.
The site owner receives a £100 discount in November for its electricity bill from the
electricity supplier.
Result
It is just and reasonable for 100% of the benefit that has been provided to the site owner
to be passed on to the residents who will each receive a portion of the benefit.
Each resident will receive a £20 discount (£100 divided between five residents) as soon
as is reasonably practicable and in respect of their November electricity bill.
Example 2
Scenario
A park home resident buys their electricity from a site owner, who has a commercial
electricity supply contract. The site owner has five residents on their site who all pay
equal costs for the same amount of energy.
The site owner passes 50% of the full amount of its energy cost onto its park home
residents.
The site owner receives a £100 discount in November for its electricity bill from the
electricity supplier.
Result
It is just and reasonable for 50% of the benefit that has been provided to the site owner to
be passed on to residents who will each receive a portion of the benefit.
Each resident will receive a £10 discount (50% of £100 divided between five residents) as
soon as is reasonably practicable and in respect of their November electricity bill.
Q. When must the benefit be passed through to residents?
• The benefit must be passed on by the site owner as soon as reasonably practicable. If
the benefits have not been passed on when the scheme ends, the expectation is that
they will still be passed on in accordance with the pass-through requirements.
Q. How will the benefit be provided to residents?
• The pass-through benefit must be provided to residents through the following methods:
➢ application of a credit in the next invoice, statement of account or similar document
provided by the relevant intermediary to the end user
➢ a payment in cash or by any other means, including a bank transfer
➢ tariff adjustment on tariff equipment
➢ adjusting the amount of money taken from a direct debit or a standing order
➢ set off against an amount or part of an amount which was owed by the resident to the
site owner at the time at which the scheme benefit was provided to the site owner
➢ or a combination of the methods set out above
Q. What information must the site owner share with residents regarding the benefit?
• It is the responsibility of the site owner to take reasonable steps to notify residents in
writing that they have been provided support and how much they are intending to pass
on. If the site owner will not be passing any benefit they have received to residents, they
must still notify the residents.
Q. What do you mean by reasonable steps?
• These reasonable steps could include a letter, email, by text or instant message,
in a newsletter or other type of message sent directly to the resident. This must be done
using existing methods of communication with end users and in so far as possible,
via the method of communication used customarily with end users.
• A general notice on a website would not normally be sufficient unless that is the primary
method that the site owner and residents communicate.
Q. When must the information be shared?
• This information must be shared within 30 days of the site owner receiving the benefit or
within 30 days of the regulations coming into force for the scheme benefits provided to
relevant intermediaries before the Pass-through Regulations came into force.
Q. What must the information set out?
• The information must set out:
➢ how much benefit has been provided to the site owner
➢ how much will be passed through to the resident
➢ if applicable, when and how this will be passed on
➢ if applicable, any steps the site owner is taking to correct an error in previously
passed-through scheme benefit
➢ how residents can appeal to the site owner
➢ that if residents do not receive the scheme benefit they are entitled to recover it as a
civil debt
Q. What can residents do if the pass-through requirements are not met?
• Residents should not need to take action to receive this benefit as the obligation is on
the site owner to pass through the benefit and provide the information necessary to do
so.
• If a resident believes that they should have been provided a benefit, did not receive
enough benefit, or reasonable steps weren’t taken to inform them of their eligibility to
benefit, the resident would be advised to raise this with the site owner in the first
instance.
Q. How should a resident contact the site owner?
• A template letter has been provided to assist residents in their communications with
site owners. The template letter is only illustrative, and site owners should refer to their
obligations as set out in the Regulations.
• The site owner is under an obligation to demonstrate that the pass-though is just and
reasonable and therefore must provide justification for their calculation of the amount
passed on.
Q. What can a resident do if a site owner fails to meet any of their obligations?
• If a site owner fails to appropriately pass on the payment or fails to provide necessary
information to the resident, the resident may bring civil proceedings and may seek to
recover sums due as a civil debt. There are no fines for site owners in such cases.
• Should a court rule in the resident’s favour, they will be entitled to the payment, plus
interest which is set at 2 per cent above the Bank of England’s base rate and will begin
to accrue from 60 days after the intermediary first receives the relevant scheme benefit.
To find support on civil debt proceedings or further guidance visit: Make a court claim for
money.
Useful links
https://www.gov.uk/government/publications/pass-through-requirements-for-energy-pricesupport-provided-to-intermediaries/guidance-on-the-pass-through-requirements-for-energyprice-support-in-great-britain-provided-to-intermediaries
https://www.gov.uk/government/publications/energy-prices-bill-how-households-andbusinesses-will-be-supported/how-households-and-businesses-will-be-supported-by-theenergy-prices-bill
https://helpforhouseholds.campaign.gov.uk/help-with-your-bills/
https://bills.parliament.uk/bills/3341/publications.
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