VAB86 Neath Port Talbot 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 Cyngor Castell-nedd Port Talbot  | Evidence from Neath Port Talbot 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).

We support the general principles of the Bill which will result in visitors contributing to the cost of an area hosting their stay.

However, as in previous consultations we must express concern on the inability of Local Authorities to raise revenue from day visitors, in particular in areas with low numbers of staying visitors and high levels of day visitors (such as Neath Port Talbot).

We appreciate the complexity of designing a taxation scheme around day visitors which makes this option unfeasible. However, there are no details that we have seen within the consultation confirming how local authorities such as ours, which experiences higher proportions of day as a result of visitors staying in neighbouring ‘honey pot’ areas, will benefit.

Waterfall Country is a good example of this, whereby the local community experience significant impacts from day visitors, but have low number of accommodation bed spaces, as such, areas like this have no feasible way of benefitting from the levy.

Visitor levies in the UK have been largely based around city stays whereby, we presume that, the corporate hotel chains experience the highest throughput of visitors. 

We would therefore have been more confident in the ability of the scheme to have a positive impact upon our communities if there were more UK examples where a visitor levy has worked for more traditional tourism destinations and up and coming destinations.

In NPT we would expect that around 80% of local economic tourism value comes from the 12% of visitors who stay overnight, whilst 80% of the problems in an area (litter, traffic etc) come from the 88% of day visitors who only contribute 20% of the local economic impact.

There is nothing within the proposed levy that addresses this disparity, in fact it could help to reinforce it by only focusing on staying visitors. Furthermore, because of individual county level decision making, rather than regional decision making, around how the funds are allocated, the levy will be unlikely to have an impact upon the areas already experiencing unsustainable levels of footfall (such as Waterfall Country, due to limited bed stock within the county where it sits).

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).

Whilst the cost of implementation has been considered in detail from the perspectives of all parties within the memorandum, the capacity and availability of staff (and associated budget) to undertake the required consultation within local authorities has not been fully considered and could present challenges in undertaking comprehensive consultation within the timescales noted.

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).

Yes, as noted previously, unless provisions are made for local authorities with high levels of day visitors coming from neighbouring honey pot areas to benefit from the levy, there will be an imbalance which results in ongoing damage to communities and natural assets in these areas. There is a risk that the levy could cause additional costs in areas with low bed stock and where the introduction of the levy may not be financially viable, and would therefore result in adverse impacts of tourism in these communities/ locations as no funding will be available to deliver the destination management measures required.

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 assessment of financial and other impacts is comprehensive.

As noted above whilst the cost of implementation has been considered in detail from the perspectives of all parties within the memorandum, the capacity and availability of staff (and associated budget) to undertake the required consultation within local authorities has not been fully considered and could present challenges in undertaking comprehensive consultation within the timescales noted.

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).

No comments

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 comments

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 comments

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).

All comments have been accounted for in previous questions.