VAB137 Dark Sky Escapes  

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 Dark Sky Escapes | Evidence from Dark Sky Escapes

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).

I am writing to strongly object to the proposed tourism tax of £1.25 per person per night as outlined in the Visitor Accommodation Register and Levy (Wales) Bill. As a tourism provider in the Brecon Beacons, whose family business relies on farm diversification, I am gravely concerned about the damaging financial and reputational consequences this policy, combined with the 182-day rule, will have on Wales’ tourism sector and the livelihoods of those who depend on it.

Our family business hosts approximately 16,250 visitors per annum. Imposing an additional £1.25 per person per night would result in a collective financial burden of over £20,000 annually on our guests. For visitors traveling with families or staying multiple nights, this additional cost is significant and could deter them from choosing Wales as a destination, especially when neighboring regions or countries do not impose such a levy.

At a time when the cost of living is already squeezing household budgets, this added expense will make Wales a less attractive option compared to destinations that offer better value for money. Tourism is a competitive industry, and introducing barriers such as this levy risks Wales losing its share of the market to regions perceived as more welcoming and affordable.

The introduction of the 182-day minimum occupancy rule has already created immense pressure on small tourism operators. Meeting this threshold is difficult in areas like the Brecon Beacons, where tourism is highly seasonal and affected by external factors like weather and travel trends.

For a small family business like ours, operating in a rural area, the consequences of this rule are severe. The inability to meet this threshold forces operators onto punitive council tax rates, resulting in significant financial losses that can threaten the viability of businesses that have been cornerstones of their communities for generations. Combined with the tourism tax, this creates a double blow to operators, many of whom are already struggling to remain competitive.

Policies like the proposed levy and the 182-day rule risk painting Wales as unwelcoming and closed for business.

The media narrative is likely to amplify this negative perception. Headlines portraying Wales as a destination that taxes tourists and penalises small businesses could have far-reaching consequences, discouraging both domestic and international visitors. This is a self-defeating approach that could undo years of hard work by tourism operators and Visit Wales to promote the country as a vibrant and welcoming destination.

As someone who left a successful corporate career in London to return home and run my family’s tourism business, I am finding it increasingly difficult to feel confident about the future of tourism in Wales. Decisions like the introduction of this tax make it harder for small businesses like ours to succeed and make us question whether the Welsh Government truly values the contribution of tourism to the economy and local communities.

Recommendations

1. Postpone the Levy: The levy should not be implemented until a full impact assessment is conducted, including the cumulative effect of the 182-day rule.

2. Transparent Use of Funds: Clear guidance is needed on how the revenue from this tax will be spent, with a guarantee that it will directly benefit local tourism businesses and infrastructure.

3. Engage Stakeholders: Tourism providers must have a voice in shaping policies that directly impact their businesses.

4. Control the Narrative: The Welsh Government should invest in a nationwide campaign to ensure that visitors feel welcomed in Wales, counteracting any negative perceptions.

Thank you for considering our concerns, I would welcome the opportunity to discuss this further and provide input as a business directly impacted by these policies.

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).

As above

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).

As above

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).

As above

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).

While I understand the need for sustainable tourism policies, the combination of the 182-day rule and this proposed levy risks long-term damage to Wales’ tourism sector. I urge the Welsh Government to reconsider these measures and work with operators to find a more balanced approach that supports both the economy and the businesses that are its lifeblood.

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).

As above

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).

As above

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).

As above