Accommodation Registration in England, enlightening Parliamentary oral evidence session and new youth travel research published

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1. Accommodation Registration in England. The long-awaited consultation or, as it transpires call for further evidence, on the development of an accommodation registration scheme in England has now been published with a 12 September 22 deadline for responses.   Although a DCMS consultation about England, comment from other home nations and, in particular, Scotland and Northern Ireland where registration is now in force, is sought. Wales doesn’t get a specific mention but the consultation already ongoing there may be equally informative for England?

The online consultation consists of 13 main question areas including a catchall, anything we should have asked or you wish to comment on section.  I would urge colleagues to consider responding and/or to pass details to other relevant agencies like the local fire service, licencing department etc. for their consideration. The consultation document contains a lot of detail. I would recommend it is read or scanned for now to get an understanding of DCMS’s starting position, of what’s required and to allow you time to assemble thoughts and critically any local evidence (anecdotal or more substantive) before any consideration of the response can be undertaken. Evidence of whatever type, where it is available, is going key to influencing the content of the next stage a consultation on the recommended options which will to follow (hopefully) later this year.  The current consultation will be critical in dictating what option(s), if any, we will be given, so don’t miss the opportunity to shape them.

Initial observations from me include:

  • I am surprised that electrical safety isn’t considered as essential, alongside Gas Safety Certification?  The logic seems to be that it isn’t a legal requirement as such but that even the most rudimentary risk assessment would conclude that Electrical Installation Condition Reports and regular Portable Appliance Tests would be needed (not least because c 25% of all domestic fires are caused by electrical distribution or appliance faults). If this is the logic behind treating electrical safety as less critical than any other safety issue, then I think that is a heroic assumption on someone’s part and it is precisely why we need registration to ensure what logically we would hope should be happening, is actually happening. Hope, particularly when you are dealing with what by new circumstance is often now untrained, unsupervised, non-professional provision simply no longer cuts it.
  • The narrative appears to imply that non-safety critical legislation like TV or PRS licensing are somehow potentially less importance.  However, I would argue that they may be missing the key point in this area which is that the established, transparent accommodation sector, presumably justifiably, carries the burden and costs where applicable, of complying with all these rules and regulations, while the opaque or currently hidden new part of the sector may, or arguably, does not.  It can’t be right that one set of businesses pays because they choose to trade openly, while another may not, simply because they currently operate below the public and regulatorily radar.  If applying these regulations and licencing cost are justified then ensure it can be fairly applied to all. Alternatively, if they aren’t justified, then remove the requirement(s) entirely from the whole accommodation sector.
  • Given my recent communications on the unintended consequences of short-term holiday letting on the housing market and in some areas, therefore by default, on the ability of the tourism workforce to both live and work in an ever-growing number of destinations, I would have liked to have seen more emphasis on this counterproductive issue in the DCMS narrative.  The impact on the housing market in a small number of destinations is highlighted but not the “so what?”, specifically for tourism.  Instinct also tells me that that the change from long to short-term let is a relatively new phenomenon and is only now just starting to impact on a much larger number of both rural and urban destinations. It may also have been highlighted by a concurrent combination of post Brexit and the emergence from Covid-19 inspired staff shortages, the combination of which now appear to be longer-term structural issues and not something that will fix itself if left well alone.  If this is the case then self-inflicted impacts on “tourism” and not simply on the wider communities needs, to be evidenced by a much larger number of destinations raising it as a growing concern. If not, as I read the DCMS narrative, a critical, part of chicken and egg, tourism dimension of the bigger issue of hollowing out of communities, could be missed. If DCMS as the tourism sponsors department miss it, then what hope of DLUHC who control wider housing policy recognising, let alone dealing effectively the problem?

While you ponder whether you can or can’t respond directly, warn off others agencies and department and/or look to gather in more local evidence, I will give the consultation more thought, with the view to coming back to you all well before the deadline in order to prompt some more debate and discussion on where we would jointly like to see this heading. Currently I am firmly in the registration camp and leaning heavily away from light touch, as they describe it: ” ……. a similar model to the’ We’re good to go’, covid-19 industry standard”, and much more toward, again as they describe it, a “licencing scheme with physical checks of premises”. I suspect that somewhere between the two lies room for a robust registration scheme that isn’t a self-assessment scheme, totally open to abuse and bereft of any credible level of of external assessment and enforcement (or regulation as I think we all still tend call it!).

Need I remind you all that statutory registration has been on this Association’s radar since at least 1959, on the statute books but not yet enacted since 1969 and off and on the agenda, in some form or other every c10 to 15 years since then. This isn’t new, just a new, fleeting and for once serious opportunity of identifying who is providing what accommodation where and then having a fighting chance of ensuring they do it safely, legally and to an acceptable, modern standard. If registration is accepted in England, the chosen solution will almost certainly be with us in the form it is adopted for at least the next decade and in all likelihood much longer. In essence if it is going to happen, now is the time and we will then have to live with whatever we get for the foreseeable future, so nearly right isn’t really isn’t an acceptable option.

Developing a tourist accommodation registration scheme in England: call for evidence – GOV.UK (www.gov.uk)

2. Select Committee Oral Evidence Session 21 June. For a master class in diplomacy and diplomatic, yet still enlighteningly frank responses, for a full and proper understanding of the typical barriers VB/VE now routinely labour under and a little more information and understanding of where the DMO review might or might not be heading, I would recommend you view the Parliamentary TV recording of the evidence given to the Digital Culture, Media and Sports Select Committee by Patricia Yates (then interim now hurrah) CEO VB/VE and Nick de Bois, Chair VE advisory board and author of the independent DMO review for England.   The session is a little long but still well worth listening to, even if just play it in the background and focusing in when you hear one the numerous little strategic gems scattered throughout its c 85 minutes duration. A fantastic effort on behalf of both, responding honestly to some hard questioning but yet without being seen to overtly bite the hand that feeds. Parliamentlive.tv – Digital, Culture, Media and Sport Committee .

3. New youth travel research. I have added a YouGov piece: Travel report 2022: Youth of today, travel of tomorrow to the British Destinations research and statistics library. Some interesting insights on a generation who most of us don’t necessarily know that well, unless it is in the form of someone who lives or until recently lived upstairs and may occasionally visit for food, funding and laundry purposes.  As with a number of recent reports I have reverted to using the research and statistic and not the separate “c-19” covid-19 specific menu tab:  https://britishdestinations.net/research-and-statistics/

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