Senedd Cymru | Welsh Parliament
Y Pwyllgor Cyllid | Finance Committee
Bil Llety Ymwelwyr (Cofrestr ac Ardoll) Etc. (Cymru) | Visitor Accommodation (Register and Levy) Etc. (Wales) Bill
Ymateb gan Cytun – Eglwysi ynghyd yng Nghymru | Evidence from Cytun – Churches together in Wales (Welsh only)
(We would be grateful if you could keep your answer to around 500 words).
We understand the first two objectives, but have taken a neutral stance on them. However, we are concerned that the bureaucratic requirements of the registration regime, and the threat of a penalty for failure to comply, could mean that the operators of some contributions to sustainable tourism – such as affordable accommodation for walkers, religious retreats and so on – may decide that they are unable to meet the administrative requirements and would, therefore, cease operation, undermining the relevant policy objective.
The Regulatory Impact Assessment is set out in Part 2 of the Explanatory Memorandum (https://senedd.wales/media/g5ipwvwh/pri-ld16812-em-e.pdf). This includes the Welsh Government’s assessments of the financial and other impacts of the Bill and its implementation.
(We would be grateful if you could keep your answer to around 500 words).
The Regulatory Impact Assessment notes that Cytun and the Inter-faith Council for Wales have been consulted, and we are grateful for this opportunity and for the inclusion of a restriction on the requirement to register to accommodation provided “in the course of trade or business”. Despite this, we continue to be concerned about the regulatory impact on accommodation such as retreats operated on a charitable basis. We are also concerned tha the Impact Assessment does not adequately recognise the onerous regulatory impact on these retreats, especially if they are dependent on volunteers for their administration.
(We would be grateful if you could keep your answer to around 500 words).
The main potential unintended consequence would be to hinder the work of charitable providers.
(We would be grateful if you could keep your answer to around 500 words).
No comments further to the above.
The powers to make subordinate legislation are set out in Part 1: Chapter 5 of the Explanatory Memorandum (https://senedd.wales/media/g5ipwvwh/pri-ld16812-em-e.pdf).
The Welsh Government has also set out its statement of policy intent for subordinate legislation (https://business.senedd.wales/documents/s155951/Statement%20of%20Policy%20Intent.pdf).
(We would be grateful if you could keep your answer to around 500 words).
We are concerned about the extent of the powers given to Welsh Ministers in Section 2, clauses 2(5), 4(5), 7, 9(5), and in Section 3 to amend the text of the Bill itself. Shifting the responsibility for legislating on this matter from the legislature to the Government, particularly where additional burdens in terms of administration and taxation are placed on small businesses, is not appropriate, in our view.
(We would be grateful if you could keep your answer to around 500 words).
We would like to see more provisions being included on the face of the Bill rather than being left to subordinate legislation. Legislation that has hidden impacts when debated at the Senedd is not good legislation.
(We would be grateful if you could keep your answer to around 500 words).
We regret that these provisions were not part of the Bill that was introduced. We are concerned about the threat of significant penalties for charities and small businesses for minor administrative errors, particularly when there is no recourse to a hearing in a court of law.
(We would be grateful if you could keep your answer to around 500 words).
No