VAB89 Individual

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 Unigolyn | Evidence from Individual

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).

My views on the first and last bullet pointed general principles are only to fully back them. There are, however, inherent flaws in the second one – “provide local authorities with the ability to generate additional revenue that can be invested back into local services and infrastructure to support tourism;”

            This will need rigorous planning and oversight in order that it is implemented to truly support the other two principles. More often than not Gwynedd Council has used income streams to ‘prop up’ existing services or preferred projects or sectors. Examples of this include levelling up funding used to prop up Eryri Mynydd a Môr, or the use of article 4 funds to support statutory requirements in the housing sector around Caernarfon and Bangor, instead of using the funds raised to alleviate the negative effects of second homes in the communities and areas where the additional funds have been generated.

            Dependent on which models are adopted for consultation by the council, and distribution. Examples that may mitigate the kind of shortcomings mentioned above are for example, a “grant-making” model used in the Balearics and Iceland to fund various projects. These can be aimed at improving aspects of tourism while also mitigating its effects, Such as this unique Welsh example- http://croesocymraeg.cymru/croeso/ that promote Welsh speaking, sustainable and responsible tourism.

            Or, as in South Tyrol, Italy, 70% of revenues are spent by community-level cooperatives. The remaining 30% goes to a regional organisation.

            If Gwynedd Council continues to promote business’ that have English only websites (90% of those on the Eryri Mynydd a Môr website), with the additional revenue, without trying to influence them to adopt or use more Welsh (our USP), or adopt more sustainable and responsible tourism practices it will be a lost opportunity.

 

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).

Unless the method for redistribution of the additional funds is directed in the most part to mitigate the negative effects of Tourism in Welsh speaking rural communities, one of the unintended consequences may be to adversely affect the Cymraeg 2050 policy.

The best way that I can show this is using the points from the Impact assessment -

            At 7.2 it states –Current research relating to the impact of tourism on the Welsh language is sparse and empirical evidence is limited. Respondents to the consultation provided little or no factual evidence on this topic. 

            The Dr. Dylan Phillips’ detailed and comprehensive research mentioned in 7.3 is demonstrably correct and the negative impact of the tourism industry laid out in 2001 has continued and deepened.

            The positive ‘relationship’ of the Dr Dyfan Powell blog article mentioned in 7.4 is tenuous at best, it states “This is only a statistical relationship, and more research and data will be needed to enhance the understanding of this relationship, but it is possible to suggest a theory to explain it.” It even continues to say – “But turning to the language, there is no data to suggest that Phillips’s argument isn’t still valid today and the long term impact of the tourism industry should be considered on migration patterns and house prices – two important factors as regards the viability of the language.”

            7.5 “Based on the research noted above, a visitor levy could support the aims of Cymraeg 2050” ‘Could’ and ‘possible to suggest a theory’ are extremely ‘feeble’ statements under heading 7. “Describing the impact of the proposal on the Welsh Language…”

There is current research (from 2023-4) that includes empirical evidence. - http://llyn.co.uk/llyn/wp-content/uploads/2024/12/Perthyn-Houshold-and-Language-Syrvey-part-1a.pdf

The evidence in the above research not only confirms the continued tendency of the Phillips research of 23 years ago but also amplifies the statement at 13.6 from Llanberis. The 2021 Census Data on Welsh Language speakers is 70.16% in the OA W00000602. The Perthyn research from Llŷn (above), in 2023 shows the actual figure to be 40.1% for the W00000602 Output area.

“7.6 Welsh Ministers may revise the policy via regulations which would need to be approved by the Senedd should adverse impacts materialise.” – This will unfortunately be necessary.

 

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).

as above

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).