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 Arfordir Penfro | Evidence from Pembrokeshire Coast National Park Authority
(We would be grateful if you could keep your answer to around 500 words).
The Authority is supportive of the principles of the Bill as outlined above. Growing tourism for the good of Wales and using the economic benefits of tourism to improve life for all, is consistent with the Authority’s commitment to Regenerative Tourism.
The current proposal does not give National Park Authorities (NPAs) any role in either the decision to implement a visitor levy or in the process of allocating funds from the levy.
NPAs contribute significantly to the tourism economy in Wales, providing the backdrop for the millions of tourists who visit Wales each year. Much of the costs of dealing with tourism are borne by National Park Authorities however, the proposals provide no means for NPAs to receive money from the levy unless they come to an agreement with a Local Authority. While there are current good examples of co-operation between NPA’s, Local Authorities and the tourism trade, with Pembrokeshire being one of these, unless the legislation ensures that there is a guaranteed role for NPAs in the allocation of funding it is likely that some of the services provided by NPAs to support both the tourism industry and the local use of services will disappear.
The Pembrokeshire Coast National Park Authority is responsible for protecting and managing this special landscape which includes dedicated teams from areas such as Nature Recovery, Decarbonisation, Engagement & Inclusion and Regenerative Tourism. Offering a broad array of work to protect and enhance the landscape, wildlife and cultural heritage of the National Park.
For the Welsh Government to meet the aims of this Bill, it is imperative that National Park Authorities are involved in the decision to implement a levy within their local authority areas, and that they are allocated a share of the subsequent income. This will ensure an equitable distribution of the generated funds, ensuring it goes to where the impacts of tourism are seen most significantly.
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).
Working closely with the local trade and local communities to ensure 'buy-in' will be pivotal along with a sense of inclusion and ownership of how the associated visitor levy funding will be spent. The fact that no specific allocation of funding will be made to National Park Authorities runs the risk of alienating key businesses and communities who experience the greatest pressures from tourism growth (i.e. in National Parks), in turn, potentially undermining tourism investment in key visitor locations associated with the Wales brand.
To meet the aims of the Bill and to ensure National Park Authorities are able to meet the increasing needs of visitors and communities, alongside nature recovery and decarbonisation targets, it will be important to ensure funds from the levy are allocated to National Park Authorities where applicable.
(We would be grateful if you could keep your answer to around 500 words).
As Local Authorities become increasingly stretched, there is a concern that income from the levy will be used to support statutory services. Levy income should therefore be ring fenced for the purpose of improving the tourist offer.
Where a levy is introduced, there may be disagreement on how the funding should be allocated which would lead to conflict in the delivery of the levy and will impact on the proposed positive outcomes. Clear messages around the purpose of the funds should be communicated.
We ask that National Park Authorities are key partners in the decision to implement a levy and are involved in decisions around how the funds will be spent, as well as ensuring NPAs receive a proportion of the income from levy.
(We would be grateful if you could keep your answer to around 500 words).
The Welsh Government's assessment of the financial and other impacts of the Bill seems balanced and robust. Much will depend on the willingness of the trade to 'play ball' and the accuracy of the proposed register of accommodation providers. As a result, thought will need to be given during Stage 2 of the legislative process as to how issues of non-compliance will be resourced including any associated enforcement action(s). To this end, data from early adopters of the visitor levy will need to be disseminated widely so that the WRA business model can adapt accordingly. In addition, it would be useful to include the costs for an associated communications campaign and any specific costs for change and training activities, as these will underpin delivery.
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 National Park Authority considers the balance between the information contained on the face of the Bill and what is to be clarified and/or augmented via subordinate legislation to be appropriate. The powers for Welsh Ministers to make subordinate legislation also seem appropriate but it will be vital for any potential decisions to be fully scrutinised by the Senedd and any proposals should be implemented through close consultation with key bodies such as the Wales Tourism Alliance (WTA), Regional Tourism Forums and local tourism bodies such as Visit Pembrokeshire.
(We would be grateful if you could keep your answer to around 500 words).
No comment
(We would be grateful if you could keep your answer to around 500 words).
We assume that the additional registration and enforcement provisions will be subject to consultation, mirroring the engagement process to date. In addition (as referenced above), thought will need to be given during Stage 2 of the legislative process as to how issues of non-compliance will be resourced including any associated enforcement action(s). The issuing of a penalty fine is often the first stage of enforcement action and ensuring that relevant bodies have the necessary powers and resources to ensure that they can fully address non-compliance will be essential.
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The three National Park Authorities in Wales contribute significantly to the visitor economy of Wales whilst protecting the natural and historic environment.
Welsh Government research, presented in the Explanatory Memorandum for this Bill, states that visitors are attracted to Wales for the “rich offering of nature and scenic landscapes” and further explains that people visit Wales for “our history, language, environment and scenery…”, research also shows that the most popular attractions for those visiting Wales are “wildlife/nature reserves”.
National Park Authorities in Wales play a key role in ensuring Wales’s natural beauty, landscapes, language, heritage and culture are protected for future generations. National Park Authorities maintain, manage and protect the special qualities within our National Parks, and are host to the majority of visitors who come to Wales. This comes at a cost and the continuation of these services is dependent on securing sustainable sources of funding.
Despite the economic impact of tourism to the Pembrokeshire Coast National Park (£558.31 Million in 2023), the negative impacts of tourism on the natural environment and communities are increasing, whilst the National Park Authority is experiencing increasing costs and pressure to mitigate these impacts.
National Park Authorities work hard to maintain a strong visitor offer for tourists and are continuously improving upon this. Initiatives such as ensuring our destinations are open and accessible to all, continually upgrading and improving visitor centres and historical attractions, providing sustainable public transport options, maintaining and upgrading public rights of way, (including the exemplary Welsh Coast Path) and working with local and community councils to improve the visitor experience, are all within the remit of NPA’s.
Welsh National Parks are also expected to significantly contribute towards nature recovery and decarbonisation over the next decade and alongside increasing visitor numbers, this will be a challenge.
As this Bill currently stands, National Park Authorities will not directly receive any of the economic benefits of the levy, nor will they have any say in if a levy is introduced in the area or how the revenue raised is spent.
Alongside our colleagues at Eryri and Bannau Brycheiniog, we ask that, the Bill recognises the vital contribution that National Parks make to the Welsh Visitor Economy by ensuring the following:
1. National Parks are part of the decision-making process on the implementation of a visitor levy in their local authority areas.
2. Where a National Park Authority is within the boundary of a Local Authority, that there is a mandatory percentage of allocated funds from the levy allocated to the National Park Authority.
These amendments will ensure that the Bill recognises the important role National Park Authorities play in the visitor economy of Wales and will help National Park Authorities to face the many challenges brought by the impact of tourism on our unique and special landscapes.
Additional statistics regarding tourism in the Pembrokeshire Coast National Park (STEAM, 2023):
- Economic impact: £558.31 million
- Total visitor days: 7.87 million