VAB11 Plas Dol y Moch Outdoor Education Centre, Coventry City Council

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 Canolfan Addysg Awyr Agored Plas Dol y Moch, Cyngor Dinas Coventry | Evidence from Plas Dol y Moch Outdoor Education Centre, Coventry City Council

General principles

1. What are your views on the general principles of the Bill and the need for legislation to deliver the Welsh Government’s stated policy objective, which is to:

§    ensure a more even share of costs to fund local services and infrastructure that benefit visitors between resident populations and visitors;

§    provide local authorities with the ability to generate additional revenue that can be invested back into local services and infrastructure to support tourism;

§    support the Welsh Government’s ambitions for sustainable tourism?

(We would be grateful if you could keep your answer to around 500 words).

Whereas I can appreciate the potential value in providing local authorities additional finances to support visitors the notion that parents or schools of young people attending adventure education courses in Wales would now have to pay an additional fee is deplorable. As a Centre delivering Outdoor Education, like many others are tasked to be cost neutral to our authority. The reality on the ground is that historic funding for these invaluable courses has been removed, and schools are having to use the limited grant or other funding options to ensure they can deliver core curriculum provision. As a Centre I struggle to recognise where the additional monies taken from us could be used to benefit our groups as we make use of our natural resources with high consideration to sustainability.

The Bill’s implementation

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.

2. Are there any potential barriers to the implementation of the Bill’s provisions? If so, what are they, and are they adequately taken into account in the Bill and accompanying Explanatory Memorandum and Regulatory Impact Assessment?

(We would be grateful if you could keep your answer to around 500 words).

3. Are any unintended consequences likely to arise from the Bill?

(We would be grateful if you could keep your answer to around 500 words).

We are, and have been post COVID running at a deficit due to the increases in various services, food and fuel costs. We are committed to setting our course fees well in advance to be fair across the academic year for our educationally focused courses. Should this bill include educational residential courses such as ourselves we will have to push that cost onto parents. We are already seeing an reduction in course participants due to the cost of courses. A result of this bill will inevitably mean those families who cannot afford to send their children to these invaluable courses which have significant beneficial impacts on young people, specifically in terms of character development which have broader positive impacts on society as a whole, will increase. Meaning the young people who arguably would benefit the most from these courses will have those opportunities reduced.

4. What are your views on the Welsh Government’s assessment of the financial and other impacts of the Bill?

(We would be grateful if you could keep your answer to around 500 words).

Whereas the Government consider the fee a modest amount for ourselves this would be significant. As a Centre we operate 7 days a week during the school term (39 weeks). Based on 55 people a night our annual costs would increase by over £15k. for a Centre trying to remain cost neutral this would have a massive impact on us

Subordinate legislation

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).

5. What are your views on the balance between the information contained on the face of the Bill and what is left to subordinate legislation? Are the powers for Welsh Ministers to make subordinate legislation appropriate?

(We would be grateful if you could keep your answer to around 500 words).

The notion that local authorities may have discretion with regards this tax, and potentially wave this tax to educational groups is ridiculous. There need to be contingency within the bill granting exemption to children on educational school trips and greater recognition from the Senedd for the value of school residential as set out in the narrowly defeated Residential Outdoor Education (Wales) bill.

Other considerations

6. Do you have any views on matters related to the quality of the legislation?

(We would be grateful if you could keep your answer to around 500 words).

no

7. On 26 November, the Cabinet Secretary wrote to the Finance Committee with some indicative additional registration and enforcement provisions (https://business.senedd.wales/documents/s155952/Letter%20from%20the%20Cabinet%20Secretary%20for%20Finance%20and%20Welsh%20Language%20Indicative%20Stage%202%20amendments%20that%20.pdf) he intends to bring forward at Stage 2 of the legislative process (https://senedd.wales/NAfW%20Documents/Assembly%20Business%20section%20documents/Guide%20to%20the%20Legislative%20Process/Guide_to_the_Legislative_Process-eng.pdf).

Do you have any views on the indicative additional registration and enforcement provisions the Welsh Government intends to bring forward at Stage 2?

(We would be grateful if you could keep your answer to around 500 words).

no

8. Are there any other issues that you would like to raise about the Bill, the accompanying Explanatory Memorandum and Regulatory Impact Assessment, or any related matters?

(We would be grateful if you could keep your answer to around 500 words).

To highlight. If the Senedd is broadly supported core aims of the Residential Outdoor Education (Wales) bill then an additional tax on Outdoor Education Centres, which is what this levy is, an exemption for schools residential education courses should be included.