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 Cadwch Gymru’n Daclus | Evidence from Keep Wales Tidy
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Keep Wales Tidy believes the general principles of the Bill significantly support the policy objectives and that legislation is needed to achieve these objectives. A visitor levy is an appropriate method of additional revenue generation due to familiarity across the world with the concept, and the good practice case studies available for visitor levies in places like the Balearic Islands. The introduction is timely and Wales-wide approach is practical considering the numerous local scale introduction of visitor levies across English and Scottish cities.
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.
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The Bill lacks any provisions for the levy revenue to be an “additionality” to existing local authority budgets designated to tourism purposes. This raises concerns that it will end up replacing existing funding and result in the tourism sector and development of sustainable tourism being no better off than before the levy.
Within the Bill in its current form, the revenue from the levy will be designated for “destination management and improvement”. Without the levy being used as an additionality (and with the risk of it simply acting as a replacement to current funding), it is unlikely that improvement can occur as current funding levels have been insufficient to achieve this. Therefore, the levy is not just about visitors contributing to funding tourism-related infrastructure etc., but about enhancing tourism as whole, including through additional funding needed for conservation and enhancement of the local environment, maintenance, reopening and expansion of important services such as public toilets, transport and more.
We would strongly recommend including an additionality provision in the Bill as it is one of the most essential aspects of a palatable and effective visitor levy. Furthermore, this provision is much more likely to receive public and business support as a result.
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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).
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Keep Wales Tidy is concerned about the potential for a disproportionate response rate from tourism-related businesses that could bias local consultation outcomes on whether to introduce a levy in each local authority. The general public may be less likely to respond to a local consultation than businesses due to unfamiliarity with the legislation, the legislative process as a whole or lack of awareness about its potential introduction. On the other hand, businesses are more likely to be aware and knowledgeable about the process through the extensive engagement done by the Treasury throughout the initial consultation process and due to recent changes in related law such as the change in non-domestic rates for holiday accommodation. Tourism-related businesses are also likely to receive help in developing and submitting their responses to local consultations on mass via bodies like Destination Management Organisations.
We would recommend that the Bill or accompanying guidance for local authorities considers this and provides advice on a consistent weighting of responses to ensure a fair approach across different stakeholders. We would suggest that this can be taken further by providing a local consultation template to local authorities (which could be modified to fit local circumstances) to ensure fairness and transparency for all views, to avoid questions that could promote one-sided narratives and to include questions that highlight the benefits of a levy to ensure more local buy-in. Keep Wales Tidy would be happy to support in this process if desired.
In the case that a Local Authority consultation concluded in NOT introducing a levy, this may create unfairness and / or resentment as their ability to raise much needed funds in the future may be curtailed. For this reason, whether implemented or not, an additional provision is suggested to ensure that the consultation process should be revisited every 5 years (or other stipulated timeframe) to determine if attitudes have changed, rather than shutting down the conversation for the foreseeable future.
Ideally, local consultation should be about what the levy should be spent on, rather than the concept itself which has already been addressed by Welsh Government in the national conversation