VAB132 Mynydd Climbing 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 Mynydd Climbing Club | Evidence from Mynydd Climbing 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).

While the Bill’s objectives have the potential to ensure costs for local services are shared more equally between those using them, we have 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 to be exempt however in its current form, the levy and its impact threatens their continuation.

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.

If revenue can be effectively ring-fenced for reinvestment in key areas, revenue from the levy could feasibly contribute towards sustainable tourism goals.

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).

N/A

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).

N/A

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).

N/A

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).

N/A

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).

N/A

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).

N/A

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).

N/A