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 Royal Yachting Association Cymru Wales | Evidence from Royal Yachting Association Cymru Wales
(We would be grateful if you could keep your answer to around 500 words).
As the National Governing Body for sailing and boating in Wales our members, clubs and training centres engage in activity – principally sport and recreation - which can also be considered to be part of the [marine] tourism economy.
We are supportive of the third principle – ambition for sustainable tourism - and recognise the characterisation of the pressures visitors can put upon communities.
We would further note that there is work ongoing to encourage more marine tourism – Pwllheli for example – to help to secure the benefits of visitors whilst easing the pressure on key infrastructure that other visitors cause (congestion, toileting and landscape damage).
To expand on this point and noting the Government’s stated objectives is to support ‘sustainable tourism’ we would urge the Committee to consider the negative impact the Bill could have on recreational boating and the positive role it could play in alleviating the very pressures this Bill is seeking to address.
Unlike land-based visitors travelling and staying overnight in Wales, people participating in recreational boating – which is both a sport and leisure activity - have very little impact on the services and infrastructure the VL is designed to help fund, i.e. local authority roads, car parks, public conveniences etc. This is because boaters are largely self-contained when cruising at sea or along inland waterways which is far more sustainable form of transport. Whilst moored they do not add a burden to local authority services, such as waste management, but remain self-contained or use paid for private facilities e.g. provided by a marina, club or by the Canal & River Trust.
Moreover, boaters themselves are passionate about the environment, with many having adopted sustainable boating practices encouraged by the Green Blue initiative which was jointly set up by British Marine and the Royal Yachting Association over 15 years ago.
This group is already part of the solution so do not need to be in the scope of the Bill.
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 are aware of British Marine’s – the Marine Industry body - objection to the Bill provision in Part 4, Section 40 – “Power to extend Act to berths and moorings” and entirely supportive of that position noting a several technical and practical issues which would likely confound application of the Bill as/when enacted.
Without its deletion, or further clarification as to its meaning, it will inadvertently draw sport into a fundamentally different policy area with cause undue concern for the Welsh recreational boaters and undermine the role this sector can play in nurturing sustainable tourism.
We would also specifically note that our view (that only vessels that are moored or berthed in a “permanent place” with the primary purpose of providing overnight visitor accommodation on a commercial basis, such as AirB&B type boats or floating lodges should be charged the visitor levy) was accepted by Scottish Parliament last year during early scrutiny of the Visitor Levy (Scotland) Bill and later by the Scottish Government.
We urge the Committee to recommend the deletion of Section 40, or to amend it so it excludes leisure berths and moorings as there is no justification for this and run contrary to the ambitions stated in the policy objectives.
(We would be grateful if you could keep your answer to around 500 words).
The Bill draws sport – in the form of sailing - into a different policy area and immediately surfaces challenges of definition and differentiation between the purpose and use of a vessel, whose primary purpose is navigation, and accommodation providers. By retaining a scope of application for the Bill which may include boats and vessels (aside from those designed as floating buildings rather than to navigate) poor policy fit and unintended consequences will continue to emerge.
The Bill also acts as a disincentive for a form of sustainable tourism (marine) which communities in Wales, like Pwllheli, (drawing on emerging good -practice from Scotland’s marine tourism strategy and activity along the North Coast 500 including Skye) are looking to for support to alleviate the impacts of car-based tourism whilst retaining the positive impacts of visitor economic impact.
The inclusion of boats in the scope of application of this Bill would appear to fly in the face of the third policy aim and is surely an unintended consequence that can be addressed at this stage.
(We would be grateful if you could keep your answer to around 500 words).
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).
RYA defers to the Recreational Craft Regulations for the definition of recreational craft, namely as “any watercraft of any type, excluding personal watercraft, intended for sports and leisure purposes of hull length from 2.5 metres to 24 metres, regardless of the means of propulsion”. Note the RCR definition does not include any mention of recreational craft being “designed or adapted for habitation” which is phrasing in the Bill and that we believe would be open to many interpretations and apply to many different types of boats from those with the most basic limited amenities which makes habitation possible, to floating lodges which include plumbed in / linked to shore utilities and house like accommodation.
For the purposes of this legislation, RYA would recommend the current definition in the Bill is amended / expanded to make it clear that vessels which are permanently or predominantly situated in one place primarily for the purpose of providing visitor overnight accommodation should be in scope, whereas other recreational vessels that are primarily for the purpose of navigation and should kept out of scope.
We are also concerned about the quality of the Bill’s accompanying Explanatory Memorandum and Regulatory Impact Assessment which, in reference to Section 40, and “the appropriateness of the delegated power” incorrectly describes moorings and berthings as “a specific type of accommodation”. As explained above recreational berths and moorings are simply a safe space for a boat, more akin to a car park than a campsite or hotel. The Yacht Harbour Association’s Code of Practice, which is used by marinas worldwide, defines a ‘berth’ as “an area of water that has been allocated to the customer to moor his/her boat (sometimes referred to as ‘slip’)”.
(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).
(We would be grateful if you could keep your answer to around 500 words).