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 South Wales Mountaineering Club | Evidence from South Wales Mountaineering Club
(We would be grateful if you could keep your answer to around 500 words).
The South Wales Mountaineering Club (SWMC) is a registered Community Amateur Sports Club (CASC) established in 1960 and aims to encourage interest in mountaineering in all its forms and to bring together like minded people interested in mountaineering. The club’s activities range from mountaineering and rock climbing to scrambling and hill walking, catering for all level of experience including total beginners.
With approximately 120 members, most living between Carmarthen and Chepstow, and Cardiff to Brecon, the club facilitates beneficial exercise and outdoor recreation across a wide region every week.
The club owns a mountaineering hut (hostel) in Deiniolen, just outside the Eryri National Park, providing a basic level of accommodation in Alpine-style bunks for up to 18 people across 2 rooms. Costs are kept very low (currently £5 per night for members) to enable participation by those on low incomes.
As a club involved in mountain activities, especially in a honeypot area, we recognise the challenges from the comparatively recent explosion of interest in outdoor activities, and broadly support the principle of revenue from tourism being reinvested into infrastructure to support tourism, on the proviso that any taxation of tourism is ring-fenced for this purpose.
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.
(We would be grateful if you could keep your answer to around 500 words).
(We would be grateful if you could keep your answer to around 500 words).
Yes, due to the very broad definition of visitor accommodation defined in the Bill, there will be a significant and disproportionate administrative burden placed on those organisations led entirely by volunteers – especially where the provision of accommodation is not the primary, but a secondary supporting purpose of an organisation.
Given the increased challenges in recruiting and retaining volunteers across the volunteering sector post-pandemic, there is a real risk that already hard-pressed volunteers will struggle to find time to commit to the additional administration and give up. This would ultimately lead to closure of the accommodation provision.
We are particularly concerned about the requirement to file returns within 30 days of a financial year, and the prospect of quarterly reporting. This will create a deplorable impact on volunteers. We note for comparison that Charity Commission returns have a 10-month period for those required to report.
A specific issue arises in defining whether the hostel rate is to apply – in SWMC’s instance our understanding is that the vast majority of stays would be at the hostel rate as rooms may be shared by people on different bookings (contracts) – but we would like to see clarity as to whether a whole-hut booking, which are usually placed by schools supporting the Duke of Edinburgh’s Award, or Scout groups, remain at that rate of if a different rate applies. Requiring volunteers to determine different rates to apply to each booking would be yet another administrative burden.
(We would be grateful if you could keep your answer to around 500 words).
The financial aspects disproportionately affect low-cost accommodation. The proposed rates, exclusive of any discretionary rate added by local authorities, would see an increase of 15% on top of our bed fee assuming the hostel rate applies, or a 25% increase for the full rate.
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).
(We would be grateful if you could keep your answer to around 500 words).
The proposed powers feel very unbalanced and create wide-ranging powers for Welsh Ministers. In the interests of democracy these powers should be scaled back to allow provisions to receive the full scrutiny of elected representatives.
(We would be grateful if you could keep your answer to around 500 words).
The draft legislation appears to have been written with commercial full-time accommodation providers who have a commercial level of booking, payment, and accounting systems in place. It takes little to no account of small organisations led entirely by volunteers.
(We would be grateful if you could keep your answer to around 500 words).
We are gravely concerned about the punitive nature of the fines for late registration and late returns. For an entirely volunteer-led, non-profit organisation, losing a volunteer, or delays changing bank signatories (banks are notoriously slow at processing these), fines from a late return or payment would be catastrophic.
(We would be grateful if you could keep your answer to around 500 words).
We are concerned that the Regulatory Impact Assessment has not sufficiently assessed the impact on small, non-profit, entirely volunteer-led organisations.
We are further very concerned about the intentions to introduce a statutory licensing scheme, and the further burdens on volunteer time, and potential application/license costs that may be involved.
We note also that the first page of the form asked if the response was being submitted in a professional or personal capacity – neither of these are correct for volunteers.