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 London Mountaineering Club | Evidence from London 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, we are concerned about the impact the bill may have on facilities run by volunteers, non-profits, and in the outdoor education sector.
The London Mountaineering Club is an entirely volunteer run, not-for-profit organisation that owns a hut in Nant Peris for the use of our members. A bed night costs £8. Day use costs £5. The hut does not make a profit. In fact, the costs of running the hut are heavily subsidised by our membership fees.
If we raise the hut fees to take account of the levy and the increased administrative burden (which would be immense), we risk excluding members from less affluent backgrounds from using it. It would also mean that members using the hut have significantly less disposable income to spend in the local community.
The hut is a really low impact form of accommodation. If it becomes too expensive, it is likely that members will decide to move towards Airbnb or that they will simply wild camp. In fact, we may have to close the hut altogether.
The volunteers running the club all have very busy full time jobs and many have families.
The scope of the bill and the way fees are applied, should 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, if huts like ours are encouraged rather than stifled, suffocated and basically demolished through the backdoor by the proposed levy.
Mountaineering huts, scout huts, mountain bothies, campsites, and outdoor education centres already contribute to sustainable tourism goals through environmental and outdoor education and sustainable outdoor practices.
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).
A number of concerning barriers to implementation exists:
Scope: it is not clear what ‘visitor accommodation’ means. [redacted – named Welsh Government official], Visitor Levy Policy officer, clarified that that the levy applies to overnight stays provided ‘in the course of business or trade’, irrespective of the type of organization (e.g., private companies, charities, or non-profits). It is still unclear what constitutes operating 'in the course of trade or business'. Does that affect our hut? The fees we charge are nominal and do not even cover the costs of running the hut.
Administrative burden: if our hut is captured within the bill, we will not be able to meet the 30-day return and payment deadlines. Our organisation is not set up to deal with such a burdensome duty. We note that charity commission timescales (which usually have full time employees) have 10 months for reporting. The resource, time, and
financial requirements involved will be prohibitive for our club and cause us to close.
Seasonal and irregular use patterns: our hut is not in constant use, in contrasts to commercial facilities. Current reporting requirements mean that the work of administering the levy is not correspondent to the accommodation services provided.
Finance: We do not hold the accounting expertise or financial resources that a commercial provider would hold. This means that the cash-flow requirements of the levy would be burdensome and too complex for our 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 such as ours without sufficiently accounting for the fact that they do not generate a profit.
(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 have to close or increase our costs, pushing members to pursue less sustainable forms of accommodation. Our accommodation model, in contrast to others, is low impact and sustainable. Members sleep in rooms with bunkbeds occupying minimal space per person, sharing sanitation facilities and transport (usually 3 people per car, sometimes more).
We are already struggling to attract volunteers, because the administrative burden for clubs like ours has increased significantly over the last decade. Having to deal with a levy means a lot more work. In addition, the cost of administering the levy means that it is likely that the price of accommodation would rise by more than the £0.75 or £1.25 fee that is proposed.
We are also concerned by the huge fines referenced in the bill for getting something wrong. We have no significant funds. We do not make a profit. We cannot pay a full time or part time accountant.
At present, like many other mountaineering clubs, we often visit Wales and contribute to the income in the tourism industry there. If this becomes punitive, we would have to shift our trips to North England or Scotland instead.
(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. 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).
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 providers and stakeholders. 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).
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 indicative additional provisions may increase the administrative burden on providers, especially small or volunteer-managed accommodations. 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, young people and people from less affluent backgrounds.
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 people with less disposable income and accommodation specifically catering to those, are also likely to be considerable.
The administrative deadlines are shockingly short. 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.
We ask that the Welsh Government reconsider its plans for a flat-rate levy. A proportional levy based on accommodation cost/ actual profit margins would be more equitable and ensure fairness across all types of providers.