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 Gloucestershire Mountaineering Club | Evidence from Gloucestershire Mountaineering Club
(We would be grateful if you could keep your answer to around 500 words).
While the Bill’s objectives have the potential to ensure costs for local services are shared more equally between those using them, our club has significant concerns about the impact the bill may have on facilities run by volunteers, non-profits, and in the outdoor education sector. The flat-rate levy disproportionately affects low-cost accommodations, which will have a heavy impact on accommodation types which have little or no profit margins, and for which costs are kept as low as possible. This threatens to make tourism, outdoor recreation, and outdoor education less inclusive and accessible, and pushing people towards the use of more infrastructure-intensive forms of accommodation which can have a negative impact on Welsh communities such as AirBnb accommodation. For this reason, we are calling for the scope of the bill and the way fees are applied, to be reconsidered, alongside the potential impact of reporting and registration requirements on volunteers. It is far more productive to the Welsh Government’s ambitions for supporting sustainable tourism, for these types of low impact, low-cost tourism, however in its current form, the levy and its impact threatens their continuation.
We own and let out a mountaineering hut in Eyri. This provides basic but good value accommodation for outdoor groups and contributes to sustainable tourism by offering an affordable option for those who wish to explore the mountains.
If revenue can be effectively ring-fenced for reinvestment in key areas, revenue from the levy could feasibly contribute towards sustainable tourism goals.
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).
• Scope: ambiguities within the definition of ‘visitor accommodation’ make it unclear whether the bill is targeted at non-commercial providers, causing confusion and unintended consequences.
• Administrative burden: our club is run entirely by volunteers. The resource, time, and financial requirements involved will have a significant impact on us.
• Finance: we do not have the accounting expertise or financial resources that a commercial provider would hold. This means that the cash-flow requirements of the levy can create burdensome and complex conditions for volunteers who are not trained to create or maintain the procedures needed to correctly report and collect the levy fees.
• Equity of levy rates: The flat-rate structure disproportionately impacts low-cost accommodations without sufficiently accounting for their limited revenue generation compared to higher-end providers
None of these are adequately addressed in the Regulatory Impact Assessment, which focusses primarily on commercial providers. We content that the impact of this bill will be felt most heavily by providers which operate with little or no profit margins and for whom the task of administering the levy would fall on those with the least capacity.
A more detailed impact assessment is needed to measure the impact on volunteer run facilities particularly considering the administrative burden and its impact, and the risk to the viability of these important facilities.
(We would be grateful if you could keep your answer to around 500 words).
Volunteer-run accommodations and non-profit facilities such as ours will be most severely affected. We will have to pass on the cost of the levy directly to users as there is no profit margin and this will impact the number of bed nights. With less people there will be less spending on local shops.
(We would be grateful if you could keep your answer to around 500 words).
While the financial assessment highlights the potential for increased revenue, it underestimates the impact on small, volunteer-run, and low-cost providers such as ourselves. The costs of compliance, especially for non-profit organizations, and the inequity of a flat-rate levy are not sufficiently addressed. Additionally, there is limited discussion of how funds will be transparently managed and reinvested.
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).
In our view the bill does not accurately reflect the diversity and unique needs of all of the varying types of visitor accommodation providers in Wales, nor does it appropriately consider the capacity of all of them to deliver revenue via the visitor levy.
(We would be grateful if you could keep your answer to around 500 words).
The balance leans too heavily towards subordinate legislation, leaving significant aspects, such as levy exemptions and premium caps, to future determination. This creates uncertainty for clubs such as ourselves. Clearer definitions and guidelines should be included in the Bill itself to ensure fair and transparent implementation.
(We would be grateful if you could keep your answer to around 500 words).
The indicative additional provisions will increase the administrative burden on our club and make it more difficult for voluntary run organisations. Without specific exemptions or support mechanisms for non-commercial facilities, these amendments could exacerbate existing challenges rather than resolve them.
An additional concern is that local authorities may introduce registration/licensing fees – we ask that non-profit accommodations be given an exemption from these.
(We would be grateful if you could keep your answer to around 500 words).
Considering all factors, many types of accommodation are currently potentially captured within the scope of the bill which could result in negative impacts on the Welsh Government’s sustainable tourism goals, limiting access to the Welsh countryside, and having a disastrous impact on outdoor education. Commercial and non-commercial accommodations are treated as the same when their impacts could not differ more. This should be resolved in future drafts of the bill.
The impact of this bill on young people and our type of accommodation specifically catering to those developing outdoor skills, are also likely to be considerable. We ask that the decision to include children within the scope of the levy be reconsidered, and for those under the age of 18 to be excluded in all instances.
We would like changes to the bill to support non-commercial, volunteer-managed facilities, to avoid potentially disastrous unintended financial and administrative burdens. We ask for extended administrative deadlines. If fees are to be applied to volunteer-run accommodations, then we would like administrative processes to be made as easy as possible for non-commercial accommodations, and for reporting windows to follow the convention set by existing charity commission rules.