VAB75 Events Manager  

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 Rheolwr Digwyddiadau| Evidence from Events Manager

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).

Whilst Visitor Levies work in many European city destinations, there is a risk that this will be seen to our largely domestic visitors as Wales being unwelcoming to visitors (further building on widely held but largely untrue stereotypes of a host population who change to speaking Welsh when a visitor walks into the shop, and who support the trebling of council tax on holiday properties)

Any scheme that is not adopted Wales wide is confusing to visitors where they might have to pay a levy to stay in Gwynedd but not in Powys.

No mechanism has yet been suggested that charges a levy to day visitors (despite these being far more numerous to the North Wales area than staying guests) so we are focusing the charge on that portion of our visitors who are already contributing the most to our visitor economy, whilst letting off the higher number of day visitors who utilise the infrastructure and roads but bring a packed lunch with them from home meaning spend per head in our communities is minimal.

The financial benefit to local authorities is at best going to back fill some of the reduction in funding that this area of work is seeing year on year due to local government settlements so any attempt to suggest to the trade that this will create additional investment is at best disingenuous.

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 huge amounts of work in establishing a list of all accommodation providers and ensuring they are registered.

The set up costs for businesses to collect and remit levy payments to Welsh Government Revenue Authority.

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).

Wales loses domestic visitors to other regions in the UK not because of the real cost of the levy (which will be marginal) but because headline news/social media will be talking about additional costs to visit Wales which will influence buying decisions

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).

The variance between low and high estimates clearly show that this is little more than guesswork with too many assumptions having been needed for the calculations.

The estimated £4m-£5m cost for the WRA to administer this (on top of the cost to thousands of small businesses) is a massive proportion of the potential revenue gain.

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).

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).

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).

As visitor economy businesses already feel this legislation is being 'Done TO them' rather than being 'Done FOR them' then more incentives to ensure registration and less focus on penalties for failure to do so might have gone a long way to carrying an industry that already pays a significant tax burden with ministers.

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).