Month: January 2020

MAC report on Point Based Systems and salary thresholds

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The Migration Advisory Committee (MAC) was commissioned in June 2019 to report and make recommend around the possible role of a Points Based System (PSB) for skilled workers and for the appropriate salary threshold associated with this (two commissions subsequently delivered as one report).

Their report was published on 29 January 2020.  It is a very thorough and detailed piece of work at around 272 pages.  The executive summary can be found from pages 5 to 11 and the summary of individual recommendation at page 260 to 271.

The main concerns raised by representatives of the tourism industry have been around maintaining access to a supply of workers for what may potentially be categorised as lower skilled, lower salaried front and back of house employment (my definition not the industry’s), a general concern shared by a number of other industry sectors.  This concern, and tourism specifically, is not directly referenced to any great degree within the main body of the report but there are a numerous reference to the impact of maintaining a supply of lower skilled, lower paid migrant workers, that combined tends to suggest that MAC are not that supportive of the principle and certainly not within a PBS. There key, specific comment on the subject in the executive summary is:

“Some of the largest expected impacts are in sectors that primarily employ lower-skilled workers that would not be eligible under the proposed restriction to medium-skilled and higher-skilled workers in TIER 2 (General).  If the Government is concerned about these impacts, it could address this through another route; for example, something like the temporary worker route which was proposed in the Immigration White Paper, or via a sector-based scheme which were mentioned during the election campaign.  Doing this will be of benefit to these sectors, but at a cost of reducing the likely overall benefits of moving to the new system.”

and in the main-body:

“7.76, There are currently two occupations which are in the lowers kills ONS category (1 out of 4) but which are listed as RQF3/lower-skilled in the current codes of practice.  ‘These are Fishing and other elementary agricultural occupations n.e.c.’ and ‘Waiters and waitresses’, we recommend that these are not made eligible for Tier 2 (General).  The large majority of workers in these occupations are in low-wage positions that require little training.”

The other references dotted throughout the report are not explicitly directed toward any particular sector but simply refer to general principles that would it seem to me to logically apply to a significant proportion of the entry level tourism workforce.

Clearly the publication of the report is significant for those tourism sectors and individual tourism businesses that have become more reliant on migrant works.  Importantly, between commissioning and publication we have had an election, a change of administration and potentially a change in emphasis regarding what our future migration policy may or may not look like?

It is now very much in the lap of Government to design and implement a new system, taking into account as much or as little of MAC report’s recommendations as they see fit.  Given the pre and post-election comments from senior figures it is now almost unthinkable that this will not now be based around “an Australian type points-based system”. The exact style and the degree to which it influenced by the MAC recommendations on a PBS remains to be seen.

Given the MAC recommendations, the tourism industry may be well advised now to focus on developing proposals for the other routes mentioned in the quote above, like the “temporary workers route”.  My understanding is that some of the relevant trade bodies may already have this in hand and it is, or will be more widely discussed via the Tourism Alliance.

See the full report at:



Important update

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I attended a very good British Tourism Industry Group (BITG) quarterly meeting yesterday Wednesday 29th.  This is the VisitBritain (VB) Group that looks primarily at international inbound tourism but does of course reflect VisitEngland’s (VE) role within VB for managing both international and domestic tourism in England.

A number of strategic subjects were discussed and I was able, as you would expect, to get a number of our positions on issues both domestic and inbound international across.  More observations on key issues aired to follow in a separate note.

The immediate feedback I need to pass to you now is that I was able to make a plea on behalf of domestic tourism interests in the event of the coronavirus impacting on UK tourism, something that seem increasingly likely.  So much so, that a Tourism Industry Emergency Response (TIER) group meeting was called to follow on from the BTIG meeting. The points I raised were recognised by VB and supported by other trade groups and major business representatives around the table. I am therefore reasonably confident that it would have been reflected in the TIER group discussions that followed.

The coronavirus is such a fast-developing issue that it is difficult to comment on it with any lasting accuracy.  At this point I just want to reassure colleagues that its potential implications for UK international inbound, domestic outbound and domestic tourism are being weighed and considered at the very highest levels.  If and when it becomes appropriate, we will all be informed of any action to be taken nationally on our behalf, or any actions requested of us all to assist the National Tourist Boards to manage any difficulties arising from the coronavirus outbreak.

Meanwhile, please do consider making it clear in any local, regional or national discussions that you are involved in that the factors, perceptions, fears and attitudes that might depress international inbound tourism to the UK are equally likely to depress the much larger UK domestic industry as well. The simple point I am try to get established is that if at any point the international inbound market warrants additional support then in all likelihood so too will the domestic industry.  Indeed, in terms of its scale and economic impact the domestic industry may have an even greater need?


Tourism issues in the news

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Aviation, Gig economy, vehicle controls, inland bathing water and Coronavirus:

1. Aviation. The Government’s rescue plans for Flybe which in essence involves deferring £100m plus of Air Passenger Duty (APD) owed to Government, to help ease cash flow during this the off-peak travel period have not only been criticised by the environmental lobby for sending out mixed messages about aviation and its environmental impacts but also, perhaps more surprisingly, by other major airline operators on the grounds of its impacts on competition. It may be over simplistic but this could suggest that the UK/European aviation is even more competitive and, by necessity, more cutthroat than perhaps many of us, not directly involved on a day to day basis in aviation would have presumed? The reaction may also have come as a bit of a surprise even to some in Government?

If it has come as a surprise, then it is even more likely to make Ministers think again about strongly hinted suggestions that APD on internal UK flights should now be reviewed and reduced, with a view to encourage internal, UK regional connectivity.  These early, possibly knee-jerk, potential solutions may have to be reassessed or dropped in light of the subsequent wider reactions? The alternative of reviewing and reducing ADP across the board for all flights, to and from all destinations seems even more fraught and perhaps even more so now given the industry’s own negative reaction to a well-meant offer of deferral on Flybe’s ADP payments.

Meanwhile, there is conflicting information about whether the demise of Flybe would result in the closure of certain regional airports and/or whether other carriers could, would or would not be willing to take on Flybe’s UK routes on a commercial basis. Clearly both the threat and, if it ever came to it, the reality of the loss, even briefly of internal UK flights and regional airport is an issue of serious concern for a wide range of interests at both end of all routes served by the regional airport network.

From a tourism prospective that is especially the case for the many more remote UK destinations and perhaps none more so than for some of our well-loved but vulnerable smaller Island destinations. The reality is that they generally have far fewer, much longer and more complex alternative means of moving people, the essential raw material of tourism a (in some instances the) vital socio-economic driver for their communities.

More on the industry’s position on the Flybe bailout at:

2. Gig Economy. Birmingham have decided to delay their approval of a 5-year extension on Ubers licence until the outcome of the Uber appeal against Transport for London’s decision not to renew the licence in the Capital. That London appeal is going through the courts.  While it is Uber continues to operate in London, as they will also be allowed to do so in Birmingham, until the decision of the courts are known.  The speculation is that other Cities are likely to follow the TfL lead, so there is a lot riding for Uber on the outcome of this appeal.

And for balance today, Uber announce a potential ground breaking deal with Nissan to allow drivers in London to accesses all electric cars.  The stated aim is to ensure that all vehicles using the Uber App in London are all electric by 2025. A bold and commendable ambition, but one which I can’t help feeling is, on the face of it at least, currently at odds with the ongoing TfL Uber dispute about their fitness to hold a licence.  See articles on both at:

3. Vehicle controls. Brighton and Hove have taken the first steps towards a potential fossil fuel car ban in their City centre by agreeing to commission a feasibility study. They are one of the first, if not the first, “traditional coastal resort” town/City to do so, joining popular inland destinations like Oxford and York in considering the need to limit vehicle emission.  They are doing so alongside a raft of other larger core Cities, including City destinations like Birmingham and Bristol, who may have a more urgently need to take robust action to start meeting their legally binding air quality and omissions targets.

For any destination of any type or size already blessed with a generally adequate rail, bus and other public transport infrastructure, curtailing private car usage is less of an immediate problem.  For those destinations not so well blessed, it is a more difficult economic conundrum, especially when one of their major industries, by its very nature, is utterly reliant on customers making a discretionary journey to the destination, before they can engage in any form of economic exchange with your business community.

However much of a conundrum it maybe, it is now more a matter of how long can destinations afford to put off addressing the problem of maintaining (creating?) the viable, sustainable means by which visitors can visit and not a question of whether there is a looming need to do something.  New and yet to emerge technology may still save the status quo, but waiting to see is a hell of a gamble.  More on the Brighton and Hove decision at:

4. Inland bathing waters. The Times continues to support campaigns around bathing and other water quality issues with a new focus on the state of many of England’s rivers. They are supporting a campaign group who have identified the previously, less than transparent fact that the designation of a body of water as a bathing water comes with greater obligation to meet and maintain standards and ultimately, if the risk to public health warrants it, greater investment in amongst other thing waste water treatment and management of storm overflow.

The catalyst for potential action in rivers and inland waters is in part the exponential growth in individual and competitive wild water swimming, alongside a perceived increased in casual leisure usage of rivers and lakes, during our apparently warmer summers.  The current EU and presumably future UK regulation demands that where the risk, based on the peak number of users in the May to September UK bathing season justifies it, the water should be regularly tested and bathers advised of its quality and where necessary when and in particular when not to “bath”.  The argument goes that if lots of people are bathing in these rivers they should be designated as bathing waters and, by default, that will mean more will have to be done to improve their quality or ban bathing.  Many years of experience on the coast shows that will there are elements of truth in that approach it tends to be way more complex and necessarily nuanced than that.

The campaign is fraught with difficulties not least because the local councils involved have to provide a range of facilities at a bathing water and actively manage it. If that is to happen the relevant Council has to see both a public health need and in constrained times, clear socio-economic merit in supporting, funding and managing the designation.  The process of designation and/or removal from the list on grounds of lack of usage have to be robustly evidence over a period of time.  It can’t be done on the basis of a large single event, nor on of a small number of regular users.  The number of users that would represent a public health risk in any given circumstance to justifying designation is not, as far as I am aware, actually even quantified.

The point of pointing this development out is to make inland destination manager aware that there is complex issue potentially looming for anyone with a major body of water that is attracting increased usage.  Based on the experience of their welcome and sometime less than welcome interventions over decades on coastal bathing water issues, the Times are unlikely to drop their objection to riverine pollution and support for wild water swimmers anytime soon. Just as they have consistently supported the work of Surfers Against Sewage and campaigned for what was much needed coastal water improvements, they are likely to routinely champion the cause of improved river quality until it is somehow achieved.  More at:

5. Coronavirus. I have been loathed to mention this for fear of needlessly inflaming a worrying situation. However, the evidence seems to support the fact that this the second major avian to human virus transition in less than twenty years has the potential to seriously impact on world travel and by default on travel and tourism. Indeed, today those early warning signs have more or less been confirmed.  The situation and advise is changing hourly but hopefully this outbreak may not be as serious as previous incidents and the risk to human health in real terms, relatively small, albeit no risk can or should be deliberately played down.

The natural instinct in these circumstances is to assume that such incidents, if they impact on our industry, will do so primarily through the loss of international visitors.  There may even be a popular presumption that any disincentive among the domestic population to travel abroad will automatically serve to benefit the domestic tourism industry.  All the evidence from previous incident of this or of a vaguely similar nature, point to the fact that the damage to the UK tourism industry will come as much from a downturn in domestic tourism as it will from any, often higher profile and more immediately noticeable decline in international visitor numbers.

This is not an invitation to feed the fire, but a plea to make sure that internally destination managers and key local businesses are looking at the potential of a downturn as appropriate to you markets in both international and domestic tourism and doing the appropriate scenario planning.  Far more importantly, please also ensure that any industry response to Government management planning you are involved in makes the critical point that, although the initial cause and immediate focus of any impact may be on international travel, there is likely to be potential for even more significant damage to be done to the domestic industry and to places that are not heavily reliant on international visitors. If this does develop into a serious issue for tourism then the domestic tourism industry and the domestic market will need just much carefully considered PR and other support as the international markets.

I am happy to point you to the historic evidence base for this stance, if it is needed to support the argument you may need to make.

Latest news as at early Friday evening by way of illustration of the very serious potential for concern is at:

Retail and tourism

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High Street issues.  As a significant number of their 23 stores are situated in popular inland and coastal destinations, the news that Beales is following Debenhams into administration is not simply bad news for the UK’s troubled High Streets and traditional bricks and mortar based retail industry.  It also adds to what is becoming an increasingly problematic issue for significant sections of the UK visitor economy and tourism industry.

Retail has traditionally been a significant part of the product mix in many built destinations and one or more traditional department stores, often the largest, anchor retailer in many of our popular medium to larger coastal resorts, market, historic town and smaller to larger City destinations. Where retail is part of fabric of the place there are bound to be serious issues when existing retailers suddenly begins to fail and there are equally suddenly far fewer, if any new retailers waiting to grab prime sites and other contenders, like casual dining, may be less forthcoming than they were in previous years.

The Beales sites are by nature centrally positioned and substantial in scale.  Many are unlikely to be simply filled by an equivalent retail operation, whilst finding positive alternate use for such large and very often older, organically developed buildings will not be easily or quick done. This is especially true in those towns that may already be facing the loss of a Debenhams and/or are wrestling with the future use of a former BHS, House of Fraser or any one of a number of other larger scale casualties of recent retail retrenchment.

For popular urban destinations, of any scale, the problem isn’t simply about retaining the viable purpose of the High Street, largely for the immediate benefit of the local population.  It is about retaining the quality of the product, the attractiveness of place, the experience and range of activities and attractions, that combined will continue to attract entirely discretionary, day and staying visitors in the sort of numbers, needed to sustain infrastructure and business activities, typically provided well in excess of that required to cater for local demand alone and increasingly doing it on a near 365 day basis.

The alternative to fixing the High Street is at worst obvious dereliction and decay in key central areas, or at best slow managed contraction towards a smaller more manageable retail hub. The latter is seldom achievable in the short to medium term or without unintended collateral damage to otherwise successful neighbouring businesses.  Witness the impact of the long, slow and generally socially and economically painful restructuring of the small hotel and guest house sector, in key areas of many coastal resorts during the late 1980 and 1990s onward.

Repurposing retail and the High Street in popular destinations is as much about sustaining existing and future hotels, accommodation businesses, restaurants bars, theatres, cultural and entertainment attractions and so on, as it is about saving some semblance of a retail offer itself.  Not all urban destinations rely on a strong retail offer now and in future other popular destinations may not necessarily need a strong retail offer to attract leisure and other visitors.  However, in the interim as we move towards a different future, empty shops, underutilised or poor utilised buildings in prime sites and a confused presentation and proposition, resulting from the loss of existing retail, will undoubtedly act as a direct disincentive to visit and an even strong barrier to return trips.  Such reputational damage, once established, tends to outlives the original cause and is, where possible, better avoided rather than painstakingly repaired after the event.  Again, witness the time lag between effective regeneration measures and the resurgence of popular appeal in many of our best loved coastal resorts and inland destinations.

The immediate focus for destination development and regeneration may need to be deliberately switched away from developing accommodation, attractions and public realm, etc. across the destination as a whole, towards a major, short sharp repurposing of their core, town centre (High Street) retail areas. Albeit that this repurposing may, almost certainly must, include elements of accommodation, attractions, entertainment, public space and services, housing, offices and work space, business services etc. within it.

In parallel a root and branch review of the purpose, structure and effect of business rates, rather than just more regular reviews of charges levied under the existing system is urgently required.   Repurposing our High Street without repurposing one of the most significant cost of doing business in them makes little practical sense.   Leaving a known fiscal and practical barrier to business success in place while trying to restructure the physical business environment would only serve to limit the likelihood of success.

The type of radical changes to business rates that may be needed will almost certainly have significance for both Central and Local Government resource and thus by default potentially for destination management, maintenance and development.  An eye to the law of unintended consequence is also therefore needed when debating the merits of any replacement for business rates.

At the same time some of the old financial certainties around private and public sector retail property holdings and rental returns are also being called in to question.  This too may have financial ramification that go well beyond a simple readjustment of the base cost of doing business from traditional High Street premises. The dynamics and the interrelationship, intended or otherwise, between rates and rents also need to be interrogated and fully understood if are to find a truly sustainable future for our all  High Streets and especially for those outside Central London and the core Cities.  They too have issues with retail but almost certainly of a differing nature due in part to the scale of footfall and their potential customer base that they typically now enjoy.

More on the specifics of Beales at:

VisitBritain VisitEngland 2020, 5-year strategy published

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Today VisitBritain published its new 2020, 5-year strategy for itself and VisitEngland within it.  In addition to continuing to look to disperse international visitors there is a welcome new emphasis on support for the domestic market in England (Visit England strategy  is at page 19 onward).

Find the report at:

Changes to the coastal team and CCF

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I have had a very positive response from colleagues in Ministry of Housing, Communities and Local Government (MHCLG) assuring me that in practice the Cities & Local Growth Unit has always been a joint unit between MHCLG and BEIS.  The recent notification about the redeployment of the small but specifically coastal focused team was simply to let stakeholders know that they were taking  action to better joining up work on coastal areas with that on their wider inclusive growth agenda, in the light of Government’s commitment to supporting and levelling up areas across the country.

To achieve this there’s been some internal movement between departments but this we are assured doesn’t mean MHCLG and other departments won’t continue to support coastal areas as part of their work.  Indeed, one of the objectives of the moving staff is to ensure that MHCLG work better with those other departments. MHCLG also retain a dedicated community’s team within it.

There is no link with the changes in structure and personnel and any future plans for the Coastal Community Fund (CCF), which the coastal team helped administer.

The future of the CCF remains a matter for the forthcoming comprehensive spending review (CSR). Coastal interests can wait to see what the review recommends and then respond accordingly, or they may wish to continue to voice the critical importance of the fund, in order to ensure this is taken into account within HMCLG’s, wider Government and in particular Treasury’s CSR planning.

Better surely to work to have the continuance of a specific CCF written into the responsible departmental and wider Government CSR plans than to risk any potentially for having to fight to have it reinstated after the individual department and wider Government plans are announced?

Why the concern? CCF is a unique fund set up in recognition of the scale of difficulties and the unusual conditions experienced at the coast, unusually funded from a set percentage of Crown Estates marine revenues (current 33% down originally from 50%).  Those unusual conditions common to coastal communities have previously made it more difficult for them to compete successfully, on merit, in open competition for funding with all comers; hence the need for their own specific additional funding mechanism.  The post Brexit creation of a new “Shared Prosperity Fund” could easily be seen as an opportunity to simplify arrangements, possibly reverting to a single funding stream for all, in which case the coast may again find itself inadvertently disadvantaged?

What’s occurring?

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Three points of recent interest on coastal communities, short-term let licencing and tourism levies and on greening tourism for promotional advantage:

1. Coastal Communities Team. The Coastal Communities Team at the Ministry of Housing Communities and Local Government (MHCLG) have announced a reorganisation:

“We are emailing to let you know that with the increasing focus on towns and regeneration, we are looking to integrate our work on coastal policy more deliberately with our approach to regeneration.  This will ensure a more joined-up approach going forward and avoid the risk of duplicative effort in engaging with similar issues through multiple channels.  By integrating our work this way, the coastal team in MHCLG has been assigned new roles within the Cities and Local Growth Unit”.

The full implications of this move and whether this, as we have feared for some time, may herald the potential loss or integration of the Coastal Communities Fund (CCF) in to the emerging “Shared Prosperity Fund” is as yet unclear.

The fund was originally created in recognition of both the scale of need and the unusual conditions found in coastal communities which often precluded regeneration initiatives gaining funding in open competitive bidding against all comers. The loss of a dedicated CCF would be a direct blow to coastal interest and would remove a potentially useful precedence for a similar funding mechanism for other similarly disadvantage areas, for example, rural destinations.   We are seeking further guidance from MHCLG on the full implications of the reorganisation.  Hopefully they are no more than an efficiency measure that will genuinely allow coastal interests to better represented within MHCLG and wider Government.

2. Short-term accommodation licencing and Transient Visitor Levy. After much debate and public consultation Local Authorities in Scotland will be able to introduce their own short-term accommodation licence schemes from spring 2021 onwards. The Scottish Government announcement made last week outlines an adoptive licencing scheme approach with what currently appears to be a significant degree of local flexibility about what and how the scheme will cover in any given local authority area. The proposals do not seem to stipulate conditions like guaranteeing grandfather rights to existing businesses, or any of the other typical caveats often centrally directed. This may change as the proposals emerge.

Beyond the near certainty that a scheme will be adopted in Edinburgh and potentially some other key City destinations there is growing speculation about what will or will not be embraced by this.  Will it cover all Airbnb style accommodation or only, for example, full property lets? Will it conceivably include more traditionally let holiday homes, self-catering or even some or all B&Bs?  The devil will lie in the detail and our reading of this is that it is largely up to each Council to decide what that might be?  The announcement mentions new mandatory safety requirement, the ability to designate control areas to allow appropriate planning controls to be applied and the consideration of appropriate future taxation for short-term lets, complementary to the Transient Visitor Levy, the legislation for which they state will be introduced later in the year. More to follow as the detail emerges.

The Scottish Government’s announcement is at: and typically more speculative media comment at:

3. Greening tourism. Following claims made last Autumn about its apparent green credentials Ryanair have now launched their spring and summer advertising campaign using much the same greenest, cleanest European airline as the central claim, appealing presumably to an ever increasingly environmentally conscious (guilty?) public.

The Ryanair business model has allowed them to produce a novel measure of CO2 emitted based on a per passenger per km flown.  As a short haul, high volume, full/near full flight operator using a new, lower CO2 emitting aircraft fleet they are by this, their own measure, the best performing airline in Europe. However, environmental groups and others point out that in terms of total CO2 emissions Ryanair are the 10th most polluting individual business of any kind in Europe. Some would argue that total impact is a far better measure of the company’s environmental credentials.

In addition, it is worth noting the other interesting snippet that their high-profile voluntary carbon offset donation scheme was only been supported by 2% of all Ryanair passengers.  The voluntary offset approach, lauded by some in the airline industry as the most appropriate way forward, may have some considerable way to go before it proves its true worth?

It is all too easy to view Ryanair’s approach as a cynical attempt to exploit the now more broadly held, but often shallowly based public interest in the environment and their own personal environmental impacts.  Whether or not it is just promotional hype, there is little we can do directly about Ryanair’s claims, other than to quickly learn lessons about what might be exercising some consumers’ minds and what highly successful commercial businesses are doing, right now, to influence consumer attitudes and behaviour.

I can’t help thinking that UK destinations, singularly and jointly, might be well advised to think more deeply about how to promote their own very real environmental advantages and benefits, especially to the UK domestic audience.  Any thoughts on novel joint messaging or potential joint campaigns that we might help facilitate, would be appreciated.

The Irish Times’ take on the Ryanair claims are at:

In the news

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News and articles of potential interest that you may have missed over the 2019 festive period include:

1. May Bank holiday. The movement of the early, May Bank Holiday from the Monday 4th to the Friday 8th May to celebrate the 75th anniversary of VE (Victor in Europe) day may have, or still come as, a surprise to many. The date has been widely published as the 4th in diaries and calendars or, in the absence of much advanced national publicity, some will have simply assumed the normal pattern. For many this will not present a problem, but for others who have already made firm plans based around the wrong date there may well be issues? Although the change/error has now been more widely reported it is still worth checking detail locally and taking action to ensure that both the industry and potential customers are fully aware of the altered dates.

2. Transport and pollution. A report by Bristol’s University of the West of England as part of an EU programme gained traction around 20 December with the headline news that research (in Bristol) showed that travel for “ shopping trips and leisure” ( at 51%) was contributing more than travel for commuting (at 20%). The broad use of the term “leisure” in the retelling is slightly worrying as it could easily be interpreted as meaning leisure and tourism and be projected in the public’s minds well beyond the specific and often very different traffic patterns and conditions found within major cities.

On reflection it probably isn’t that surprising that the intense but short peaks of commuting to and from work are less polluting than the totality of shopping and leisure trips of all types made by everyone else throughout the majority of the rest of the day, in a typical major city, that are all well served by rail and other public transport. Other activity including business travel (the movement of people, goods and services) presumably makes up the other 29% in Bristol’s case?  Outside the typical city the mix of road usage is likely to be very different (dependant on local circumstance) and the national figures, as a snap shot/average of all usage across the UK, different again.

We know from Government’s own transport figures that nationally road transport, and principally the private car, is the most significant means of transport for day and staying “tourism” activity, especially for the many destinations outside the Core Cities.  We also know that commuting and business travel combined are by far the greatest component of both rail and road travel within the UK as a whole.

Going forward toward a carbon neutral future it is vital that leisure and, in particular, tourism’s impacts are not misidentified, overestimated or seen as an easy, discretionary and less economically impactful, sacrificial lamb.  The latter may seem a potentially extreme concern but past and indeed current national policy, for example, network rails deliberate targeting of school and Bank holiday periods for major maintenance works are indicative of the current policy leaning. For more on the UWE’s reports and typical media coverage see:

3. Sharing accommodation. The Eu Courts of Justice have ruled that Airbnb do not have to comply with French property law by holding an estate agent’s professional licence and by default comply with the regulation that this would require. The finding that Airbnb is an “information society service” means that Airbnb and other similar platforms have narrowly avoided increased regulation in France and by implication, in some other parts of the EU where it seems likely that, had the precedence been set, others would have looked to follow.

The finding follows on from a similar case against UBER in 2017 where a very different determination was made.  The difference in determination is interesting and helps establish in EU law the degree to which control or, “decisive influence” of the product sold by the platform is seen as the key factor.  There has been speculation that this isn’t the end of the issue in France as there are option left open to the French Government and others who are concerned about lack of corporate responsibility for the products sold and the disparity caused between what is seen as necessary regulation for traditional bricks and mortar based trade and little or none for those operating as web based distributors “selling” much the same or identical products.

Unsurprisingly, Airbnb appears to remain keen to avoid any issues that may reduce growth, dampen consumer demand or increase their own compliance costs ahead of their planned public offering later this year.  The BBC take on the issue can be accessed at:

4. Unauthorised school absence in England. Despite efforts to discourage unauthorised school absence DfE have recently reported that unauthorised absence for holiday purposes is still running at c 10% of all reported absences. This follows on from reports in both early and mid-2019 that fines for unauthorised absence in England was at record level.  The issue is likely to keep running for some time to come and may well be picked up again at a policy level by the new Conservative administration?  Typical media coverage can be viewed at:

Our position has been and remains (until you direct otherwise) that we don’t support absence for purely financial reasons.  If you can physically holiday as a family within the designated school holiday period then you should, even if it means cutting your holiday cloth and your holiday expectation accordingly.  We do however recognise that modern working pattern make family holidays within school holidays a near impossibility for some families with members working in some sectors; most notably for us within the tourism and leisure sectors themselves, where holidaying in peak periods may not be permitted by employers, or not be practical for small business owners who predominate within some parts of the industry.  We would continue to urge that headmaster are given and them employee discretion based on known individual family circumstances (as per the approach adopted in Wales).  We also appreciate that applying a discretionary system may be far easier said than done; being open to potential parental abuse and producing a potentially significant local administrative burden an schools.

5. The CEO of the Lake District National Park has been quoted as saying that: “the park must change and diversify to attract a greater range of visitors” or “lose its relevance and justification for being called a National Park and receiving public funding”. The comments are almost certainly prompted by the National review published in September which makes recommendations for both National Parks and Areas of Outstanding Natural Beauty (ANOB) in England. The report is critical of the lack of diversification in usage, users and in governance and proposes that National Parks and AONBs in England become part of “the same family”, served by a single National Landscapes Service.  For destinations that are or include National Parks and AONBs, including those outside England, the report is significant.  See the detail at:

Some of the subsequent reporting of CEO’s comments leans towards criticism of what some see as “political correctness” and/or the issues of perceived or existing over tourism:

6. Included in the Queen’s Speech were proposed measures to reduce the burden of risk to the state from the collapse of UK tour operators. The headline measure includes consideration of changes to legislation to allow the use of aircraft and other assets of the collapsed company in any future recovery operation, which is currently banned under existing insolvency regulation. Given the scale of demands made on it in the last few years, it also seems increasingly likely that the amount paid by the companies and recovered from the cost of each holiday taken to build up a recovery fund (Air Travel Organiser’s Licence [ATOL]) may now have to be increased.

There been a number of articles in media in recent weeks referring to the cost of the Thomas Cook collapse.  The figure involved are big but as yet it is still far from clear what if any of those costs will ultimately be carried by the public purse.  What is clear is that the impressive value of the out bound travel industry in terms of UK employment and direct UK earnings, for example via UK carriers, may now need to be reassessed.  It is unlikely to be as significant as it in 2016/17 when the last piece of major research on the subject was published:

Surly in future the hidden costs of potentially underwriting the risks of the package travel business model should also be a policy consideration, particular when debating the relative national value and policy support for domestic v domestic outbound travel?

7. There was also a good deal in the press about water quality and beach management from reports on toxic plastic bead pollution on UK beaches from UK and European water treatment plants, through the sewage pollution-based perils of the increasingly popular wild swimming in English rivers, to the disruptive behaviour of jet skiers and other leisure users, on this occasion with an emphasis on their impact on bird and marine life, including the deliberate disturbance of dolphins and seals. More detail on these bathing waters and beach management issues will be notified via the UKBMF (UK Beach Management Forum) website and blog: .