Month: January 2023

Environmental news and tourism implications.

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Three environmental development of operational if not strategic importance to tourism:

1. In September 2022 a Bill to ban a range of single use plastics in Wales, including some items previously banned in England, was laid before the Welsh Government.  On 6 December the Senedd approved the Bill, effective from “Autumn 2023”.  The outline can be found:  here.   On 14 January Defra announced, via its response to an earlier consultation and the mechanism of the recent Environmental Bill, its intent to ban the use of a further range of single use plastic items in England from 1 October 2023.  The outline for this can be found: here

Although not identical in the use of definitions or in its precise application, the two now cover much, if all the same main items, with exactly the same intent to reduce the unnecessary use of environmentally damaging single use plastic including: plates, bowls trays, cups, some types of cup lids (polystyrene in Wales at least), cutlery.  All of which are widely used, especially in food and beverage, hospitality, leisure, tourism and events and the visitor economy in general.  The ban doesn’t preclude the use of such single use item themselves; it just proscribes that in future they can’t be made primarily of plastic or polystyrene type materials.

Consequently, we can reasonably expect to see far more use of replacements, predominately wood and wood fibre-based card products. Some of the latter are necessarily coasted with liquid proof plastics, like the now ubiquitous cardboard coffee cup and still can’t be easily or economically recycled;  a subject and a problem worthy of an essay in their own right. There will of course be instances of a return to, for example “proper” crockery and cutlery but it is unlikely to be practical, nor without significant staffing and other costs, in most typical scenarios. 

The implementation in both Nations has been delayed to allow the dissemination of more detail and for a significant range and number of retail businesses and the wholesale supply train to adjust.  Nonetheless, destination mangers might wish to be aware of the impending changes and communicate them to what is likely to be a potentially large range and large number of businesses.  At this point it probably needs to be no more than: it is happening post peak season, formal guidance has (as far as I am aware) not yet to be issued, when it is we will ensure it is passed on.  

From a destination management prospective it is worth noting that the ban on single use plastic items, however worthy an objective, does not in itself significantly reduce public littering and the unpredictable peaks, troughs and ever-growing pressures on the public waste stream. In essence while it does reduce the opportunities for plastics to enter the natural environment, it largely acts to substitutes one non-biodegrade form of litter and waste with a more biodegrade form of litter and waste that then still has to be litter picked and /or collected from public bins and then disposed of.  By default, much of it from the public domain at public expense, rather from the private businesses that generate it, at their own expense.

2. A week later Defra then announced the outline of the long awaited and already long delayed deposit return scheme for England, Wales and Northern Ireland, for which Westminster retains some significant responsibility.  HMG are duty bound to consult and obtain agreement from those two Home Nations, neither of which have to replicate or adopt the Defra solution. Whereas it is an entirely devolved issue in Scotland. 

The main, immediate issues to note are that the implementation date has slipped again, this time from 2024 to October 2025, a good seven years after the scheme was first promised. Perhaps more importantly, glass bottles have now been explicitly excluded from any version to be adopted by the current administration in England and therefore may or may not now excluded in Wales and Northern Ireland. The combination of placing an artificial value on an essentially individually valueless items (plastic, steel, aluminium or glass drinks containers) and the proximity of England to Wales along, a long heavily inhabited administrative boarder, may be problematic, if for example, Wales were to choose to include glass and England doesn’t?  That said Scotland is pressing ahead with plans to implement a 20p deposit on all drink’s containers, including glass, from August 2023.  In the Scotland’s case the  issue artificial value on all existing containers and, once running, all containers from outside the geographic area is dealt with by a requirement for manufactures and producers to label or barcode those products included within the scheme. That presumably still leaves some interesting logistic issues particularly for a town like Berwick on Tweed.  They have also excluded on-sale containers in bars, restaurants and other licenced premises, a solution that seems highly likely to be replicated in those schemes yet to be introduced elsewhere.

To be unkind or is it just being frank, some of the attendant comments made by the Westminster Government suggest that, despite several consolations and 5 years’ worth of preparation, the multifaceted complexities of introducing an effective and efficient deposit return scheme are coming home to roost and that they need a further two to three years to develop a practical and (hopefully) workable solution.  A genuinely unkind comment, of the type being made by many environmental interest groups, would be that: HMG are quite literally kicking the can down the road, leaving it to the next Parliament to sort out, the literal, mess surrounding the growing use of single use drinks containers.

The additional delay could well still result in the deposit return scheme being significantly amended, further refined or indeed delayed again (outside Scotland) but the key observation remains that at some point it is coming. Just not as soon as we had anticipated or as soon as many destinations would have wished to see as an effective means of physically reducing a major source of litter and a major ever-increasing strain on the local waste stream. Unlike the ban on certain single use items, about to come into effect later this year, a well-designed deposit return scheme will act to significantly reduce littering and the strain on the public waste stream.  For that reason alone, such schemes represent a significant operational, if not strategic development for tourism development, quality of consumer experience and destination management in the UK.  The fact that they will also help reduce the opportunity for harmful plastic to entering the land and, especially, the riverine and maritime environment is a major bonus.

My immediate personal assessment, is that the decision to leave glass bottle out of any English scheme is almost certainly a major mistake or more accurately an unintended flaw or loophole, likely to result in the use of more glass containers, more glass litter and more glass in the general public waste stream. All of which would in my view negates at least two of the primary purposes and much of benefit of the having the scheme in the first place. 

Giving almost two year’s notice of intent, may well allow container manufactures, drinks producers, the wholes and retail chains time to adjust to an as yet very vague scheme but it also inadvertently allows more than ample time for them, if they so wish to switch back towards the use of glass containers.  That may not be logistically or economically feasible in all cases but it certainly could be in others, for example, beer or soft drinks in tins requiring a deposit v beer or soft drinks in bottles that won’t.   This Government has declared its intent, now only time will tell if I am right or wrong. 

3.   Not necessarily new news but rather the latest addition to a torrent of news items, reports, Select Committee inquires, Ofwat regulatory and Environment Agency (EA) enforcement regarding the current and recent historic state of the UK’s waste water and sewage systems.   Taken together they paint a picture of system that is failing and is now and routinely has polluted the UK’s rivers, waters lakes and coastline and which has been doing so largely under the public and regulatory radar, probably since the privatisation of what was admittedly then an already failing publicly owned system. Without trying to over simplify the situation, it would appear that after a burst of investment to secure adequate standards, mainly at relatively few, high profile, failing designated coastal bathing waters, investment profile has gradually fallen away and has been inadequate to maintain or comply with existing legally binding standards.  Many of the privately owned water companies stand accused of favouring profit, shareholder dividends and, in some instance, senior employee’s bonuses over and above legal and moral environmental obligations and their obligations to consumers, essentially by default almost everyone.

Whatever the truth of it, there is now little doubt that there has been an over reliance on self-regulation, monitoring and reporting which has, it seems, been regularly and deliberately abused by many, if not all water companies. In some instance to a criminal degree, as witnessed by recent and ongoing enforcement and regulatory actions. EA has gone as far as to ask for future powers to prosecute, fine and if necessary jail senior executive found to guilty of continuing to do what they have been proven to have done in the recent past. That in itself speaks volumes.

Meanwhile, Ofwat, the industry’s primary regulator, stand accused of favouring the interests of the companies over that of ordinary customers and of the general public’s interest. Put simply, how else under their watch was it allowed to get so bad for so long? The EA stands accused of, on the one hand  failing to adequately monitor, police and enforce existing regulation and on the other, of not having the desire or resource to do so.  Both equate to much the same thing, the only real difference being where the real fault, if any, lies.  In parallel there are also similar reports on the failure to educate, monitor and enforce compliance within agriculture, another primary source of riverine, lake and coastal waters pollution. Many of the issues that apply to EA and the water companies are broadly replicated within EA’s relationship with agriculture. 

One senior EA officer recently confided that they personally, seriously doubted the ability of any English River to ever routinely meet the bathing waters standard, despite those standards being half as stringent as those used for coastal waters (the latter bit being real news to me).  The first two UK riverine bathing waters, likely to be the first of many more hoping to follow, are already well on their way towards being declassified and “permanently signed” with advice against bathing. (4 fails in row and you’re out).  The inclusion of rivers and growing public interest in riverine bathing waters and water quality in rivers marks a “watershed” in the long running UK water quality debate. Recognising that it is now a major strategic and policy level issue and a major new potential reputation minefield for tourism is now vital.  Hoping that the problem might either go away or improve largely on its own without proactive tourism industry intervention, as we arguable did in the early decades after coastal bathing water were adopted, is simply no longer a safe or acceptable option.

Having spent the much of my first decade in tourism defending what I now recognise as being the indefensible poor standards of many coastal bathing waters during the 1990s, I now have no appetite for spending my last decade in tourism trying to defend what I already recognise to be utterly indefensible standards in rivers and much of the coast not yet covered by designated bathing waters (small point areas often in much larger bodies of water).  To find that there is strong evidence that I and many others were deliberately deceived about the amount of effort many water companies were putting in to maintaining and improving water qualities standards is frankly painful.  Especially when many of us then unwittingly went on to publicly defend those same companies and their sterling efforts to make every possible improvement. 

It is indisputable is that riverine standards and those of significant stretches of coastal waters, primarily outside the point designated bathing waters are inadequate. That is in large part due to failures of the UK’s private water companies to invest, alongside some significant poor practice within agriculture.  The latter might be quickly resolved in part, if the EA were adequately funded and sufficiently focused on the agricultural education and enforcement task, among a host of other competing environmental priorities that they are expected to deal with. 

The water companies’ issues can only be resolved if they now investing in their assets, some of which have clearly been neglected for some considerable time and preferably doing so at the expense of their own profits and not at an additional cost to customers.  That is down to Ofwat and Government to resolve.  Having effectively ignored their known problems for so long and now having frankly been belatedly found out, the water companies now have a mountain entirely of their own making to climb. Better enforcement in itself can’t immediately fix what is effectively broken, unless of course anyone is saying that the illegal discharges are actual driven purely by profit and not to problems of physical capacity within the system, as the water industry currently claim. There is no obvious cheap or quick fix given the number of assets that it transpires are involved and the scale, cost and time needed to make the improvements likely to be required.  

If your destination includes a problem designated bathing water then the issues that you will be only too well aware of are likely to grind on for years to come.  If you have non-designated coastal waters, rivers or lakes, often used for leisure purposes, then watch this space.  Bathing, leisure and associated water quality issues are almost certainly going to get more publicity while getting far worse, for some considerable time to come, before they get gradually better. So long a time that I can confidently predict that it won’t be my problem to explain residual issues or celebrate the eventual success of all the improvements yet to come. I can say that with confidence because Government have already  quietly move the target compliance dates for river water standards to the right, well beyond the likely retirement date of the majority of people currently working in tourism management.

If you have water on your patch then I would advise that if you haven’t already done one recently, a brief audit to assess whether those waters (public and private) are being used for leisure at any scale and especially for anything vaguely associated with emersion like bathing or wild swimming may be needed.  That is information may well already be held for water safety reasons but it may not be something that either local government or private sector-based destination management proactively engages with?  If nothing else such waters are increasingly becoming both a marketing opportunity and a potential PR pitfall which should give genuine reason to keep them on the tourism radar.

As I sign off the BBC news is carrying more news and comment on the breakdown of plastics in the marine environment and the resulting presence of microplastics in fish and seafoods in the human food chain.    If that does make the point that there is a genuine, direct and strategically important link between a range of dull old environmental issues and the future of exciting and vibrant hospitality, leisure and tourism, nothing else will.


New Year, same old problems?

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Apologies for the delay in the first British Destinations’ general update of 2023 which I have held back on in the forlorn hope of accessing a lot more upbeat news. Much like the closing months of 2022 it is in relative short supply, all though at least this note does ends with news of the approval of a second major Accommodation BIDs. But even that may presents some potential new national policy issues?

1.  General reports still be firmed up for the much-needed Christmas and New Year bounce have been relatively poor for the domestic market, with lacklustre performance in most if not all destination. As ever there will of course be exemptions and outriders.  However, these seldom negate the unpalatable truth that good or bad, performance still typically measured again the same period in previous years, current equates to, at best OK and in many cases dire performance largely because of the additional factor of unrecoverable increased input costs.  I have not yet had the chance to speak directly to all destination managers in membership and therefore would welcome any comment that confirms, denies, expands on, or further informs this thumb nail assessment.

Last week’s confirmation of the nature of the plans to restructure the UK’s business energy support scheme has not been particularly well received among potential recipients, essentially because it significantly reduces the levels of support and, thus, increase the amount to be paid for the energy consumed from 1 April 2023 onward. There are already a range of other issues, particularly for those where existing contracts have fallen due or new contracts are being sought for any other reason.   There would never be a good time to reduce the level of support but for some (many?) in “tourism” who have struggled through the last three plus month and who had been hoping to hang on through the next three, always very difficult months of the off season, for spring and the first flush of the new main season, the timing seems particularly cruel. Just as the demand side should be picking up a major component of the supply side costs seem set to rise again.

The news could be the last nail in an already well nailed coffin for those yet to recoup and recover from the deep scaring of the 2020-21 pandemic.  That said, despite ongoing and potential new international instabilities, wholesale prices for gas have, we are told, fallen back to pre-Russian invasion crisis levels. This is due in large part to relatively mild weather and larger than anticipated storage in Europe. As yet that, admittedly potentially fragile prices relief has not been reflected in the energy cost to UK domestic and business customers.    Only the events of next 12 weeks or so, as the playout across numerous destinations will tell whether a trickle of permeant closures and an unusually high proportional of temporary, off-season closures and curtailments, will turn into an avalanche of business failures.  More on business support scheme at:   If you have seen or start to see firm evidence of unusual or unexpected closures please let me know, so I can continue to report it upwards.

2. On the flip side reports on domestic outbound bookings suggest these have been strong and rapidly returning towards 2019 levels of booking.  Mindful that late December early January headline travel trade pronouncements can be as much part of the promotional hype as an accurate assessment, it does genuinely appear that much of last year’s attitudinal and intentions research regarding a strong outbound market recovery is indeed proving to be true, regardless of current UK economic conditions.  It is of course telling that the vast majority of these early sales are now based on ever more generous no or very low deposits, with payment often not due until a month before travel.  Whether all that booked business comes to fruition is therefore yet to be seen.   The most worrying aspect of last year’s research being comments on the growth of the intention to preserve the “main holiday” (often shorthand for an overseas holiday) regardless of the cost-of-living crisis and to do so often at the expense of savings on other leisure, tourism, short break and other holiday activity. The baulk of which, in practice, fall largely on domestic tourism and the wider local UK visitor economy. 

I have yet to hear an expectation from any destination manager that the staycation effect of 2021 (a largely captive audience) and the OK but generally weakening summer of 2022 will be replicated in 2023.  The general view being that the domestic market, as a whole, will be weaker than 2022 with of course some winners and a lot of losers, both of which, if standard pattern pertain, are reasonably predictable.   Again, any and all views, opinion and any hard and fast evidence, either way, would be most welcome.

3. Is there anything to be done about the potentially double whammy and the resulting perilous state of the domestic market? There are a number of potential opportunities on the horizon to reinvigorate the stalled and always contentious debate about the relative value and importance to UK Plc of domestic v domestic outbound tourism.  My feeling is that simply surviving the unprecedented ubiquitous impacts of the pandemic rightly took centre stage during the last two to three years. In practice this also meant that inbound international and out bound domestic travel, became a low priority and all but an irrelevant positive or negative factor to the performance of domestic tourism.  As we endured and then slowly emerged out of the pandemic the roles, value, power and purpose of domestic tourism has becomes far clearer to all, unobscured as it usually is by the other two legs of the UK tourism triumvirate.  There has never been a better time to evidence that domestic tourism underpins the economy of many communities and is critical to that of almost of those places’ disadvantages by dint of their location and the nature of the locality. It feels very much to be something that should chime with levelling-up if levelling-up or whatever it may become is still genuinely a key policy objective? Making that case might not do much to change the fortunes of 2023 but it might start making a difference in future years with this and other administrations yet to come. 

More contentiously, it has never been easier to demonstrate that, while outbound tourism may generate significant income within the UK, it also represents a major exports/imports cost and that it does so in direct competition to UK domestic tourism. Recent national statistics show a direct correlation between falling domestic and rising domestic outbound tourism volumes and values.  In another 12 to 24 months all the tourism lessons of 2020- 2022 will be history and have been forgotten.  Surely among the key lessons learnt, is that it is in HMG’s post BREXIT, best interests to look again at the major benefit of modest policy, if not financial support for domestic tourism, particularly in England where the support is by dint of previous policy direction especially sparse.  Again, that might not be something that would necessarily improve the immediate prospects for 2023 but it could have a significant influence on future performance.  If colleagues have thoughts, particularly on an immediate action that could influence 2023 directly or views on improving the support for domestic tourism over time, then please let me know.

4. A couple of colleagues have contacted me regarding an approach from STAA the short-term rental accommodation sector trade body putting the case for a light touch registration scheme in England and seeking further meetings, presumably to gain support for this.  As you will be aware DCMS are currently refining the option or options for a registration scheme with the intent to consult further on the option or options chosen.  I am assuming STAA are getting their ducks in a row before announcements are made?  Before supporting STAA plausible stance on light touch registration, I would urge colleagues to look again at the Airbnb “white paper” on this subject that recommends a very light touch approach indeed:  .  So light touch that in some people’s view (mine included) it would almost certainly be ineffective and serve in part to reinforce the erroneous but understandable consumer view that the UK already applies first world standard backed by first world checks, balances and many would assume full inspections, all obviously done before owners are allowed to trade.  As we know that simply isn’t the case, despite Airbnb and other platform and operators own light touch, self-assessment enrolment.  Simply having little more than a list of traders and trading addresses may be a considerable improvement on the current total lack of visibility but it may not do anything to address the fundamental issue that people can trade on a whim and, in many cases, with nothing more than the completion of a basic self-assessment form submitted to the third-party agent or platform providers.  

By all means engage with STAA (indeed I would urge you to) but do interrogate them about what is meant in detail by light touch and assess for yourself whether their vision of it would improve, make no meaningful difference or unintentionally serve to make matter worse, by for example, giving consumer further unjustified confidence that all accommodations provider must meet mandatory standards to trade. The potential pitfalls of issues like Airbnb’s proposed exclusion of “amateur” providers, no registration fee and therefore no funding for the necessary enforcement etc. should all be self-evident to you but may not be self-evident even to those genuinely wishing to bring all parts of the short-term rental accommodation sector under some (or is it the same?) level of necessary control.  

There are numerous examples of the abuse of various light touch regulation schemes in the UK by a small but persistent minority; often the self-same minority that regulation was created to control.  Light touch regulation not genuinely backed by the guarantee of robust enforcement, offers false promise to the consumer, to the majority of providers and to the wider industry.  The Westminster Government need to recognise that that current lack of regulatory control is a reputational disaster in waiting for tourism in England (and by inference the UK). This is a once in a generation opportunity to put things right, to do it properly and to do it before that currently inevitable disaster happens. Whatever scheme is adopted we are likely to have to live with it for many years before it will be reviewed or improved.

5. In the wake of Liverpool’s late November announcement of the UK’s first accommodation BID (now live), Manchester announced in December the successful ballot for the UK’s second and now largest ABID.  The new ABID is again based around and manged by an existing city centre BID company. The ABID will go live on 1 April 2023, in this instance helpful from the same day and concurrent to the existing BID’s own new 5-year term (unlike the Liverpool equivalent with its three BIDs with three different start/end dates and years).  

The Manchester ABID has some notable differences to those in Liverpool.  Those “short stay hotels and serviced apartments” in central Manchester and parts of Salford with a rateable value of £75k, subject to certain other criteria, will collect/pay a flat rate of £1 per night, per room or unit let.  The BID levy is therefore based on performance of each individual accommodation provider and not on a fixed annual fee set as a proportion of rateable value.  However, you try to present it, the Manchester model is far more akin to a traditional international “bed tax” mechanism but delivered via the only currently legal mechanism available to do so in England, the Business Improvement District legislation. 

Like the Liverpool model it will excite much interest from other destinations, particularly larger Cities in need of new sources of subvention funding for major events and conferences and other key promotional resources.  Like Liverpool’s ABID model I would caution that, in all likelihood, there will be key elements of historic happenstance that are not easily replicated elsewhere and for those outside major City Centre, issues around base costs and the necessary scale needed to overcome these to produce worthwhile deployable income, capable of generating measurable return to the levy payers that over time significantly exceeds any costs to them.  Detail like the prospectus for the Manchester ABID are proving difficult (for me) to access.  Rather than delaying any longer report this potentially game changing development I am doing so without more in-depth research or the usual links for you to follow-up on. I will find it and share it in due course.

Whatever the detail, this development is game changing and probably more so than the Liverpool ABID. Liverpool agreed something akin to an accommodation-based tourism tax and did so with the broad support of accommodation sector having had a formal request to Government to pilot a tourism levy/tax scheme declined.  Manchester have agreed, with the broad support of the accommodation sector, to adopt what is all but in name a nightly bed tax/levy, very much along the lines of those used in many other countries. The fact it is the accommodation businesses that have helped design and deliver both these initiative to my mind makes the opposition to such “taxes” from several major industry bodies and the current Westminster Government, somewhat if not totally unsustainable.  The answer to the question can we now revisit the case for a tourism levy/tax will almost certainly be: “what’s the problem? The mechanism clearly already exists”. My response to that is, well it might but because of the peculiarities of the BID legislation and BID process it isn’t anything near being a universal solution to an increasingly near universal problem experience across all major destinations; that of funding necessary and necessarily shared administrative, promotional and development expenditure.

I can confidently predict that a number of other Core Cities will quickly follow suit. There will probably be many other destinations of all types and sizes who will spend and potentially waste time and precious resources trying to make an ABID model work for them. I hope I am wrong but other than the few who have the volume of accommodation and the scale of businesses located in a relatively confined area and with a clear main purpose, most typically the need for subvention funding for major conference and events in venue of national or international standing, they will fail to make it fly. 

6. In the meantime, the ABID approach will be great news for the early adopters and the accommodation businesses within them who will by default have a major competitive advantage to their less well funded competitor destinations.  It will be reasonably good news for anyone able to follow suit thereafter but potentially very bad news indeed for everyone else who can’t follow suit because the model doesn’t allow it and therefore find themselves operating in an even more distorted UK market than we already were prior to 1 January 2023. 

Regardless of any commercial reticence on the part of many in the industry and any reticence, doctrinal or otherwise on the part of Government, the successful creation of the ABIDs I think now makes it more rather than less important that Government urgently revisits the whole issue of public funding for destination management.  Within that, as a legitimate alternative, there is an urgent need to look again at the newly altered case for a universally applicable, adoptive tourism levy mechanism that sit outside or alongside the current peculiar BID based mechanisms that Liverpool and Manchester have so skilfully adapted to their own, peculiar circumstances.

British Destinations has never opposed the principle of adopting tourism levies, if that is the only practical mechanism available to some or all destinations to fund necessary destination management.  That stance perhaps needs now to move on towards a more proactive campaign for a formal review in the light of the almost certain fact that ABIDs will serve to give competitive advantage to only the few, mainly if not exclusively major cities able to adopt them.  Again, views are sought, not least because I can’t simply decide I am right and that this is therefore the route our Association should now take. A senior managers meeting is probably urgently needed to bottom out this and several other emerging issues, for example proactively championing domestic over domestic outbound tourism.