Caravan Parks - Public forum - Planning Advisory Service (PAS)

I am currently looking at preparing a brief for our Viability Assessment. As part of this work, I've been considering the range of development types that we should be testing through the assessment. A discussion with colleagues led to the question - "are caravan sites eligible to be charged CIL?" This led to the following argument: 1. Proposals for caravan parks require a change of use which largely rules CIL out. 2. Individual caravans are not often over 100sq.m in size Points 1 and 2 above clearly suggest that caravan parks are not eligible to be charged CIL. However: a. Overall caravan parks take up a large area and incorporate many separate habitable buildings (although temporary) as well as ancillary buildings (which are more permanent) such as offices/reception areas. b. the change of use has an impact upon infrastructure services including roads, water supply etc. The points above suggest that caravan parks should be charged CIL, I'm just not sure there is any guidance to support the reasoning set out in a. and b. I have looked through a number of questions discussed through this forum to see whether a similar question has arisen. One interesting thread, which discussed whether garages should be charged CIL as part of a dwelling, made me think about this further. If garages are detached from a house but are still eligible to be charged CIL as part of the total floorspace of a residential dwelling, does this mean that the total number of caravans on a site should be charged as one development? Does anyone have any experience of caravan parks in their authority area, and if so, how have you dealt with the use through the preparation of your CIL charging schedule? Many thanks, Nicki