Pitch fees - maximum rent (social sector) rules

Our housing association has a Gypsy & Traveller site which charges residents pitch fees for a plot for a caravan/mobile home. Residents either have their own caravan or rent one from another landlord. The local authority has applied the ‘bedroom tax’ to one resident’s housing benefit claim for the pitch fees. My reading of the regulations is that the determination of maximum rent (social sector) rules do not apply to caravan site fees as per reg A13(2)(c). Is that correct? Also, would it not be an excluded tenancy anyway unless the local authority deems the pitch fees to be unreasonably high?

Definitely agree with you on the former i.e.  reg A13 excludes pitch fees.