VAB115 Ramblers Cymru

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 Ramblers Cymru | Evidence from Ramblers Cymru  

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).

We support the general principles and the need for legislation, on the proviso that the Levy’s defined purpose, of enabling better destination management and improvement, encompasses recreational walking infrastructure and services of benefit to walkers.   This will include: path and access infrastructure, ranger services, associated infrastructure like toilets, waste collection and transport.

The use of funds derived from the Levy should be in addition to, and not replacing, core funding for walking and access. 

Levy proceeds should be part of a mix of funding to increase investment in walking infrastructure and services, which benefit both visitors and residents.  Investments of the type that we believe should be priorities - path infrastructure, public toilets and public transport, for example - are of equal value to visitors and residents and therefore improvements to these facilities should increase support for the Levy. 

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).

no comments

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).

Welsh Government will need to be mindful of the risk that proceeds from the Levy displace existing resources which are currently allocated to meeting access-related statutory obligations.  Highway authority maintenance of Rights of Way and their undertaking of enforcement action which secures the public right to access the path network, have not kept pace with need. 

Budgets for fulfilling statutory duties related to public access have been inadequate for decades.  Most local authorities have substantial backlogs of physical improvements, path blockages and legal casework which leave our paths networks in a vulnerable and substandard condition.  In some parts of Wales, up to two thirds of the path network is in a poor or inaccessible condition.  Consequently the usability of our path network and people’s understanding of how to access it responsibility and safely has suffered.   

Without adequate oversight, there is a risk that local authorities may substitute existing core allocations with Levy funds, maintaining the status quo of inadequate investment and low levels of delivery.  

Also, Welsh Government and authorities will need to be mindful of location displacement effects.  It is possible that a levy will displace people into non-site camping such as roadside camping / camper van parking where facilities to deal with waste etc are not present. The scale of such effects depend on the cost of the levy and also perception of its legitimacy and benefits.

Particularly in early stages, in advance of revenue being realised as investment, strong messaging is needed. Over time, impactful annual reporting, including highlighting on social media and on the ground, the improvements which have been funded by the Levy will help with how it is perceived and supported.

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).

While flat rates are simplest, they are not progressive given that people of all income backgrounds pay the same applicable rate, whether in a 5 star hotel or campsite. 

Ramblers Cymru want to see more people accessing the outdoors more often, especially from communities with the most barriers.  We do have some concerns that, for those people on lower incomes, who are more likely to use lower cost accommodation, the flat rate approach will have a disproportionate impact on the overall cost of their trip.   For example, a family of 4 on a week-long £25 per night camping holiday would pay 14.4% more (£25.20), whereas a family of 4 staying in a £125 per night hotel for a week would pay 4% more (£42).

While we understand the importance of striking a balance between simplicity and targeting (e.g. exemptions, seasonality, geographical coverage) and acknowledge that the Welsh Government favours a focus on simplicity, we would urge that, over time, as revenue becomes more predictable and delivery systems bed in there may be opportunities to revisit and make the system more progressive.

It will also be of great importance that the users of accommodation attracting the lower rate benefit from enhancements to their visitor experience as a result of the levy.  This will be crucial if it is to be perceived as legitimate and appropriate.

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).

no comments

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).

no comments

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).

no comments

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).