VAB109  Clogwyn Mountaineering Club

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 Clogwyn Mountaineering Club | Evidence from Clogwyn Mountaineering Club

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 proposals are bureaucratic, and therefore time consuming and expensive

The proposals ignore the wide variety of accommodation, properties used and individuals and organisations offering that accommodation.

Far from generating revenue, they will discourage tourism.

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).

The enormous burden of paperwork on individuals, under threat of criminal proceedings, is unjustified.

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).

The proposals ignore the unique contribution of mountaineering club huts in giving access to the mountains.

These huts are not generally run for commercial profit, and charges for accommodation are only levied for maintenance and running costs. 

The clubs who run them are run by volunteers, and do not have administrative capacity for the paperwork involved.

The huts are not occupied for long periods each year, and are only used by experienced users of the uplands who are committed to the idea of Leave No Trace.  The clubs are on the side of the environment, and they have a positive impact on the maintenance of the mountain environment.

If the proposals are implemented without due allowance made for Club Huts, Bothies and other simple forms of shelter, it is very likely that these will face closure, and an important part of the life of the mountainous regions of Wales and their communities will be lost.

Please enter negotiations with the British Mountaineering Council on these issues, and make special arrangements for these unique and valuable forms of shelter for hill-users

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).

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).

The proposals are not nuanced enough take account of special cases and circumstances.

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).

Registration and enforcement are not the way forward across the whole of visitor accommodation in Wales.  Indeed, the effect of the government trying to micromanage businesses, voluntary organisations and charities must result in the smothering of initiative, and impoverish local communities.

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).