VAB81 Bannau Brycheiniog (Brecon Beacons) National Park Authority

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 Awdurdod Parc Cenedlaethol Bannau Brycheiniog | Evidence from Bannau Brycheiniog (Brecon Beacons) National Park Authority

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 Bannau Brycheiniog (Brecon Beacons) National Park Authority wishes to support the Visit Wales strategy to:

"Grow tourism for the good of Wales – generating economic, environmental, cultural and health benefits that enrich the lives of our visitors and local communities.”

88% of our visitors are day visitors, relying heavily on the Bannau Brycheiniog National Park to access nature and the outdoors.  Our proximity to South Wales enables a wide range of socio-economic groups to enjoy the beautiful landscapes here. 

As a National Park Authority, we have no levers to ensure that levy collected by the eight Local Authorities (i.e. those with communities within the National Park boundaries) will be spent to the benefit of visitors and residents within the Park.   we receive far more day trippers than either of the other National Parks in Wales. Staying visitor days in Bannau Brycheiniog (1.87 million) compare very unfavourably with both Eryri (9 million) and Pembrokeshire (6.8 million). This means that even if Local Authorities agree to pass over an appropriate percentage of the levy, unfortunately we would receive significantly less than the other two Parks, despite receiving overall visitor numbers of 4 million in Bannau Brycheiniog,  much higher than Pembrokeshire (2.41 million people) and similar to Eryri (4.89 million people). 

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).

In principle, Bannau Brycheiniog National Park Authority welcomes the introduction of a visitor levy across the eight Local Authorities with responsibilities within the National Park boundaries. 

These eight Local Authorities are responsible for communities and some of the rights of way within the Bannau Brycheiniog National Park.  88% of the four million visitors we receive annually are day visitors.  The proposed levy delivery would mean only 12% of our visitors contributing to local services and the infrastructure to support tourism

Under the current proposals the National Park Authority will not be able to influence any of the decisions to implement the levy and will not directly receive any of the income from collection of the levy.

As a National Park Authority, under the current  legislation we do not have any legal powers to compel Local Authorities to work to our management plan for land and communities within the National Park.

We ask that Wales’ National Park Authorities should be allocated that proportion of income generated within their boundary to improve the infrastructure and staffing to address visitor hot spots, in particular where high numbers of visitors are impacting the local communities. 

We also ask for a review of the bill to consider the impacts of day visitors - many of whom come from within Wales - and consider how to fairly engage with these visitors to mitigate their impacts.

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).

One of our key concerns arises from the impact of optional levy introduction.  For example, if Local Authorities on the periphery of the National Park chose not to implement the levy this could attract additional visitors to stay in their region, but to travel into the National Park.  The impacts of these visitors would be felt inside the Park, but there will be no income generated to deal with those impacts.   As is already the case with council tax supplements on second homes, we could have a situation where some of the eight Local Authorities choose to charge the levy while others do not, resulting in neighbouring businesses within the Park boundaries, but in different Authorities being asked to charge different rates.  This would lead to inequity between businesses within the Park.  This situation would be unsatisfactory and would not meet the principle of fairness which the Welsh Government has set out. 

We ask that all Local Authorities with any land within a National Park boundary are required to work together to agree whether to charge a levy and if a premium is to be added, to set the same rate for it.

A further unintended consequence may be to increase numbers wild camping across all the National Parks in Wales, where low-income individuals, families and groups feel that they are unable to afford/do not want to pay the levy.

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).

Assessing the financial costs and benefits of this Bill has been difficult, as the range of outcomes clearly demonstrates.  The financial impacts of this Bill will depend on the reaction of tourists (will it deter them from the coming to Wales,  a fear raised with us by accommodation providers within the Park), the accommodation providers who are required to collect it, and the take up of the levy by Local Authorities. 

A key question for us is what happens to levy collected from visitors to the National Park? Can it be collected equitably and spent to the benefit of communities within the Park’s boundaries?

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).

Subordinate legislation should include the power to instruct

1. All impacted Local Authorities to agree between them whether and how much to charge when they have communities within a National Park area

2. Instruct Local Authorities to pass an agreed percentage of the income from the visitor levy to the National Park Authorities to engage with the impacts of visitors.

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).

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).

Our Chief Executive - Catherine Mealing-Jones - requests the opportunity to address the Committee on behalf of all three of Wales' National Parks, if possible.