VAB88 Children in Wales

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 Plant Yng Nghymru | Evidence from Children in Wales

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 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).

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).

We have particular concerns about the negative consequences resulting from the Bill on the provision of residential school trips organised by schools and other education establishments.  The Welsh Government’s Children’s Rights Impact Assessment (CRIA) published alongside the Bill accepts that a Visitor Levy will have a negative impact on children’s right to education and learners ability to take part in a range of educational activities (Article 28 of the UNCRC).  The CRIA states that “there will be indirect impacts due to increased cost of residential school trips arranged by schools, sports, social clubs and/or other educational providers.” (pp 15).

Learners engaging in organised residential school trips in support of their education are not ‘tourists’ or ‘holidaymakers’ and should not be classified as such.

We are calling for educational school trips to be fully exempt from any Visitor Levy introduced by local authorities. This will require small changes to Part 1, Section 2.3 of the Bill as laid.

Should a local authority choose to introduce a Visitor Levy, then there will be an increase in the cost associated with educational trips organised by schools and other education settings.  This additional cost could result in a reduction in the number and type of residential educational opportunities being organised, adversely impacting on children’s wellbeing and opportunities to travel, learn and play, develop new and lifelong social skills, friendships and competencies, as well as all the other well documented benefits school trips provide. Any reduction in the provision of educational trips would also undermine the ambitions set out in the new curriculum for Wales.

Additional costs from a Visitor Levy would either have to be covered by the organising school or be passed on directly to the learners family. This would place additional pressures on families budgets at a time when parents are already struggling with cost-of-living increases, many of whom would not be eligible for any financial support to help with any extra costs.  Inevitably, there will be an increase in the number of learners being excluded from educational opportunities due to the added financial burden from a Visitor Levy being imposed on residential school trips.

Whilst the proposed Visitor Levy rate has been described as being ‘modest’ and a ‘small contribution’ to pay, there is plenty of evidence that a growing number of families are already facing financials barriers, as learners miss out on educational residential school trips due to existing prohibitive costs. Learners who are excluded due to financial barriers typically face additional social pressures and educational disadvantages, at a time when schools are already facing a crisis in attendance levels post-pandemic.

Many learners are already being denied opportunities to take part in residential school trips due to costs.  The spirit of ‘fairness’ advanced by the Welsh Government in support of the Bill must be applied fully, with educational school trips becoming fully exempt from any Visitor Levy introduced by local authorities

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).

Please see our response to Question 12 in regard to points made in the CRIA.

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).

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).