VAB32 Carmarthenshire Tourism Association

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 Cymdeithas Twristiaeth Sir Gâr | Evidence from Carmarthenshire Tourism Association

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).

The CTA do not believe that this is a fair and equitable method of raising revenue for the stated aims as 90% of the visitors to Wales are day trippers who will contribute nothing and they bring less income than those who stay in overnight accommodation. Visitor numbers are down and the Welsh economy is sluggish. Wrong tax at the wrong time which will harm businesses and the Welsh economy. This is seen as a business tax not a tourism tax as most businesses will have to absorb the costs of the levy.

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).

The Economic Impact Assessment carried out on the Welsh Government's behalf identifies that the best case scenario the introduction of the levy will cost a minimum of 250 jobs and hit the economy to the tune of £16 Million plus a further £9.1 Million GVA. Estimated revenue return of £33 Million if all 22 authorities participate in the scheme.  All we will see is a transfer of jobs from private to public sectors which is unsustainable.

The worst case scenario identifies losses to the economy of £47.5 Million plus a further £26.8 Million GVA.  This is economic madness.

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).

As Above - The loss of hundreds of jobs in the sector and damage to the Visitor Attraction and Activities sectors as well as the retail and hospitality sectors who are dependent upon quality operating businesses attracting customers from all over the globe. Damage to the growth of the Welsh economy which is already producing the second lowest individual GDP per head in the U.K.

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).

It is perceived by our members that the Welsh Government has failed to listen to the businesses operators and professionals within the sector as well as paying scant regard to their own sponsored and financed commissioned Economic Impact Assessment. As stated this will result in further damage to the poorly performing Welsh economy and is viewed as an act of self destruction.

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).

Upon examination the delegated powers give enormous opportunity for vast changes to the Bill as it currently stands. It is appreciated that tweaks etc. will have to be made but in essence the whole design of the levy could be changed over time including the intention of the registration system turning in to a permissive licencing scheme a few years down the line at as yet undetermined costs to the businesses who are already facing severe financial challenges.

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).

Several concerns as to the possibility of a patchwork effect of councils choosing to operate the levy or not.  Confusion to the consumer.  Concerns over the council's ability to control, manage and police the registration scheme and also the ultimate use of funds raised. The definition offered at present allows for much of these funds raised to fulfill the current rolls of a council and little if any benefit will be seen to the improvement in quality and service levels throughout the sector. There are not enough words in this section to highlight the many unresolved issues that this Bill raises.

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).

Only that the government and local authorities ensure that there is a level playing field and that all appropriate businesses are registered and enforced not just those bone fide, above the radar, visible businesses.

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).

As yet there is no indication of the structure that will be put into place to scrutinise the collection and the spending of the levy monies collected. Until that is established and communicated there will be suspicion. It has been suggested that a joint board of both council officials and the business community be formed in each area chosing to introduce the levy.  This way, appropriate monitoring of the funds can be achieved and accountable to the sector collecting the funds.