Month: February 2023

Statutory accommodation scheme update

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The Welsh Government are undertaking the final consultation on their proposed statutory licencing scheme currently aimed at all accommodation types operating in Wales and not simply “short-term lets”. The approach proposed is far more robust than a simple registration scheme which, in the view of some, is little more than a list of those operating, with the weak sanction of potentially being removed from it, in the event of serious, proven failings.

The Welsh Government’s approach unashamedly aims to create a level playing field for all provides and offers consistent assurance to consumers in order to address issues surrounding standards in accommodation provision, whilst also helping to manage the wider impacts of short-term lets on housing and on host communities. Proposals include; the provision of evidence of conformity to various, mainly safety, provisions before the renewable licence to trade is first issued, backed by a proposed 1:50 confirmatory inspection regime.

The consultation and proposal will be of direct interest to members in Wales, to consumers living in, or visiting Wales. Beyond that it further informs the ongoing debate about DCMS’s, potentially quite different, proposed approach in England that we are still expecting to be published for consultation later this calendar year. The consultation also includes a useful annex summarising the current position in the other home nations and the approach used in the Channel Isles and Isle of Man

Even if you do not intend to respond, it is worth reading the short 36-page consultation to understand the proposed direction and rational being applied to the visitor accommodation sectors in Wales. Clearly, the proposals may be adjusted as a consequence of the comments received. However, having started from a relative robust position, the final version adopted is likely to be a long way from, for example, the ultra-light touch, self-assessed, instantaneous issue of a registration number proposed and subsequently widely promoted in the Airbnb “white paper” on the subject.

My view remains that whatever scheme is adopted, or not in Wales or England, it needs to meaningfully address all the main known issues It must, at all costs, also avoid unintentionally (?) reinforcing the entirely reasonable and widely held but erroneous public view that all commercial accommodation already must conform to the highest possible standards to trade, something achieved through the application of an existing, robust and well enforced system. The fact that that isn’t true is a potential national scandal, or will be the day after those failing are publicly exposed by some small but particularly unpleasant or some shockingly large incident, as they will inevitably be, unless and until Governments block old and more recently created loopholes.

Personally, I applaud the Welsh Government for taking the opportunity to apply their approach to all accommodation which has the advantage of genuinely levelling the playing field, establishing genuine consistency and dealing with potential problems in other established sectors which are not necessarily all operating without omissions or within the expected standard. I also tend towards supporting the argument for licencing rather than simple registration but I also appreciate others might not. Better to aim high and ease off later as necessary than aim low and find soon after that you have failed to actual achieve the intended objectives.

The consultation for Wales, open to all, closes on 17 March:


More on tourism insights, research and seminars

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1. During the latter part of 2022, we highlighted attitudinal research, most notably from BVA BRDC, indicating that domestic tourism and the associated wider visitor economy faced a double whammy from the consumer spending crisis, that reached into and potentially throughout much of the 2023 main season and beyond (see annual conference presentation for more detail). The double hit coming from reduced discretionary spend, in general, on one hand and, on the other, a strong expression of intent to protect the no longer discretionary main (often overseas) holiday by reducing other routine discretionary leisure, hospitality and second holidays and short breaks spending; all of which form the bread-and-butter business for much of the UK’s visitor economy.

Anecdotal evidence, principally reporting from outbound operators during the traditional peak of their forward, main season bookings in late December and early January, also indicated a return to, or towards pre pandemic sales levels. Initial caution (hope perhaps?) that some of that early reporting might be of the self-fulling promotional type, seems to be misplaced, as subsequent comment confirmed that bookings have indeed been very strong. Albeit that some of it has been of the back of very attractive terms, including zero deposit offers. If financial pressures continue as seems likely, at least into the main summer holiday period, that generosity could conceivably result in higher level of default or cancellation? Meanwhile, there is no substantive evidence that generous terms are being exploited for speculative or multiple, pick and mix bookings; a growing, and very unwelcome new (?) trend that has been seen in parts of the post pandemic domestic market.

Last week Nationwide published it January 2023 consumer spending report based on 250m plus actual credit card transactions and a more detailed survey of c 2000 customers. This report represents the first hard evidence of actual volumes and values that we are aware of. It is also about as oven fresh as you will get in terms of statistics in general, and for tourism related statistics in particular.

The reports figures and most of the consumer survey narrative, supports the premise that spending of holidays, much of presumably because of the period forward bookings (?), has indeed increased and that in parallel areas like eating and drinking out and leisure have declined, along with retail itself often a key driver for visits. It isn’t as clear cut as one might wish, since the yearly comparative spend isn’t adjusted for any inflation (the essence of the current financial crisis) and category “holidays” for example don’t differentiate between domestic and domestic outbound, although air travel (when not bought as part of a holiday package) is recoded separately. For me the number of transactions (last three columns) rather the total amount spent is as a far more stable comparative indicator than the total spend figures. While the figure may require some more thought and interpretation, the text consumer survey comments do not. They are fairly clear cut, even if based on a relatively small sample.

See the report at:

2. A coalition of coastal interest groups lead by the Coastal Communities Alliance, of which we are members, has commissioned and published a report by Pragmatix Advisory. The documents, “Communities on the edge”, makes the case for finer grain metrics, greater inclusion and better funding for coastal communities within the Westminster Government’s levelling up programme for England.

None of the issues raised will come as any surprise to those working in coastal destinations. However, the report adds to the growing body of work on coastal socio-economic and coastal tourism issues and critically updates the case and gives current data to evidence the common problems experience in all those communities physically on the edge of the nation and therefore often on the social and economic periphery too.

The report is worth scanning even if you are not a coastal or English coastal destination. The specific section on tourism can be found and read at page 102 to 111, although, as those in coastal destinations will recognise, all other social and economic consideration are inextricably entwinned and should be taken into consideration as part of the tourism mix. The report has been added to the British Destinations rolling “Research and statistic – by year” as a separate item under the adjacent + tab and under the themed coastal reports section for later reference. Or find it now as the first bold item at:

3. The Tourism Alliance is holding a Tourism Insights Conference on Thursday 23 March 0930 to 1400 (including lunch), to coincide with this year’s Industry Parliamentary Reception 1500 to 1700, to which all delegates are invited. The members rate (including for all British Destinations members) is £160 plus VAT. Please note this is not the Joint Tourism Alliance, Tourism Society, British Destinations Annual Conference which is due to be held later in the year details to follow.

There is an excellent array of sessions and speakers all giving insight and examining prospects for tourism in the coming year and beyond. More detail and booking links at:

Buy tickets – Tourism Insights Conference and Parliamentary Reception – Royal Over-Seas League, Thu 23 Mar 2023 9:30 AM – 5:00 PM (

Water Quality and tourism is now everyone’s business?

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Events in recent years have served to refocus of the “bathing waters” debate away from a relatively small number of designated, mainly coastal locations, towards a far broader debate about natural water quality everywhere, including, the vast majority of coastal waters that are not specifically designated as bathing waters, a wide range other inland bodies of waters and, in particular at this moment, on the nation’s major river networks.  As a consequence of this changing emphasis, the problems of physical and, especially, of reputational management, currently the niche preserve of a relatively small number of destinations, in practice, at no more than a few hundred, point locations, across Britain, is now likely to become the concern of many more destinations, at far more locations, whether designated as bathing waters or not.  The pace of that change of emphasis is accelerating and it has already acquiring the necessary momentum to continue on that course at ever increasing speed. 

Having spent over 45 years concentrating, because we had to, on getting the water quality up to at least the minimum acceptable standard at a few hundred, mainly coastal, designated bathing waters, it has belatedly become apparent that there are still and always have been thousands of miles of UK coast, hundreds, if not thousands of lakes and other bodies of water and thousands of miles of major rivers that could potentially require much the same consideration. The recreational usage of water other than for bathing has for many years been a grey area; at what point does or doesn’t that usage involve potential emersion and therefore a public health risk?  Similarly, the concept of bathing season is a grey area that has relied on the assumption than insufficiently large numbers of people would be “nuts enough” to voluntarily go into cold water between September and May.  Developments like the availability of protective equipment for use in all activities and the booming popularity of wild water swimming, protected from the cold or not, throughout the years has given renewed cause for some to question just how grey these areas really should be? 

If the public go in to a body of water, or arguably even on it, in any numbers, then there is both a PR/perception and, more importantly, an unavoidable public health issue to be addressed, if that water is known, or thought to be subject at some point to significant contamination, especially if the pollutant is untreated animal or human waste.  That is problematic, since for example, due to increased testing, we now know that few of the UK’s rivers meet the water framework standards (14% of English rivers met good ecologic standards, or more telling 86% don’t), while the only two riverine bathing sites in the UK, both recently designated, have now failed to meet minimum standard and look set, in due course, to be removed from the list of sites (four fails in a row and you’re out). A process that involves the sites being permanently sign with advice against bathing.

Of note, the riverine standard is half as stringent as that applied for coastal bathing waters.  Doubtless there are good scientific reasons for this but it is another one of those very interesting question: why is twice as much faecal load deemed an indicator of acceptable water quality in a river, than that found in a sample taken from the sea?

Over the last decade plus, a number of broadsheet newspapers, notably among them the Time/Sunday Times, have championed bathing water issues, often asking awkward questions of Government, the water industry and bathing beach/water operators.  More recently they have also reported, if not helped shape the debate around the poor state of riverine water quality. They have helped to expose the at best scandalous actions of some or all of the waste water companies in respect of untreated sewage and storm water discharges, way in excess of permitted levels. They have also helped alert us all to the perils of self-report and self-policing, including poor, in some cases false, recording and reporting of the frequency, volume and duration of discharges. They have highlighted the apparently ineffective monitoring, policing and enforcement by the Environment Agency (EA) and of Ofwat and questioned the alleged long-term prioritisation of profit over known but sometime disguised, necessary capital investment by some if not all of the privately owned water companies.  Agriculture and agricultural practices, animal husbandry and the disposal of animal waste and the associated levels of direct or indirect run off from farm building or farmland, together with alleged failings in monitoring and enforcement have also been increasingly highlighted by them.  

Two weeks ago, the Time unexpectedly upped the ante, changing its approach from that of occasional editorial comment to that of a branded, formal public campaign. Thus far this has taken the form of advertising the campaign itself on a near daily base and of regularly featuring related articles on and around the issues involved.  The campaign has a website and the half dozen or so article published to date are currently publicly available outside the Time’s normal subscription only restrictions. 

The campaign has four broad objectives: three principally aimed at the water industry (higher penalties, earlier target dates, hundreds more mainly riverine bathing waters) and one at agriculture (incentivise water friendly practices and products).  Not everyone of course reads the Times.  However, a good number do, including individuals who can directly influence and report in other newspapers and via other media channels, a process that we know from past experience can and does amplify the core messages and spreads the word more widely. 

The Times has both the resource and the incentive to continue, not only to report but also to investigate and publicly question past actions and inaction, future intentions and proposed direction.  Investigative journalism undoubtedly helped exposed the parlous state of riverine and other water quality issues and the part that the waste water and agricultural industries have played in it. The Times and more general media interest also now have the potential to keep industry and Government at all levels on their toes and both them and the public alert to depth and breadth of ongoing issues and the many competing difficulties involved. 

Government, the water and agriculture industries, consumers and recreational water users, all to some degree or other find themselves between a rock and a hard place; broadly everyone agrees that we want clean water, but there no coconscious yet on how to achieve that or who ultimately pays for it.  It is far too late to undo what has happened, or more accurately in many instances, what should have happened but didn’t over several decades, for example, arguably too much profit, not enough necessary long-term capital investment.  But it isn’t too late to influence what will happen in the future, albeit that much of what now needs to be done can’t physically be implemented overnight.  This is going to be a long haul, much like sorting out the few hundred designated coastal and inland bathing waters proved to be, from the instigation of the EU bathing waters directive in 1975 to getting towards full minimum level compliance with, the admittedly now more stringent, standards in the early 2020s.

In the coming months the Westminster Government have to make a number of critical decisions effecting England and in some cases Wales, that will shape water quality standards, levels of investment and practices in agriculture and waste water management. Something that ultimately may well be directly or indirectly reflected in increased consumer’s product and service costs.  These decisions ranging from confirming when certain key water quality standards must be met, to setting the upper level of civil fines applicable in the event of an EA prosecution for a pollution incident.   Proposals for the former keep changing by anything up to a decade, while the later, is for is now an ineffective £250k but could, we have been told, rise by a thousand-fold.  Recent turmoil within Government, effectively three changes of governance within one Government in under a year, has seen significant changes in priority and direction within environmental policy and much else besides.

Previous Ministers suggested an increase from £250k to £250m might be appropriate deterrent, from presumably past known reckless and proven criminal behaviours.  The new/latest Secretary of State apparently now views this figure as being “disproportionate”, although disproportionate to what or why has not necessarily been fully articulated.  They are probably right; the potential threat of a civil fines of up to £250m may well have unintended consequences. For example, on the willingness of private sector to engage in the waste water industry and the levels of future investment, whether that is via the addition of external investment funding or via reduced levels of profit taking?  Regardless, it may well have been far better if the bar and therefore expectation of some had not been set so (needlessly?) high, in what increasingly appears to have been a defensive response to public disquiet over the revelation of the number and frequency of pollution incidents.

Unless and until rationally explained, anything less than the headline grabbing £250m maximum fine, is a PR trap and a barrier to a sensible, well considered solution that’s entirely of government’s own making.  Even if the maximum fine was to be set at £250m, the principle of proportionality, as it applies to UK/EU civil and criminal law means that a civil case would only be brought, if it was deemed a proportionate administrative means of dealing with issue at hand and any punishment, in this case a fine, could and would be challenges unless it was deemed proportionate to the offence committed. I.E., as we all instinctively know, the level of punishment should fit (not exceed the severity of) the crime.  That is something the courts can do within the limits set by Parliament, provided of course they are set high enough, which at £250k recent events have shown they currently patently are not.

For me the four big takeaways from recent events and now the advent the Times campaign are:

1. Water quality and associated designated bathing water issues (which aren’t necessarily exactly the same things) are now, or is fast becoming, a mainstream tourism issue.  An issue that is likely to impact at an ever-accelerating pace on many more destinations and individual locations.  If you have substantial body of water in your product mix that isn’t yet a designated bathing water, it is no longer possible to simply ignore it, or its water quality. Water and its quality are now a potential practical PR and/or promotional problem for your destination, whether or not you actually manage or operate the body of water or the “product(s)” using it yourself.

2. The Times/ Sunday Times’ sometimes welcome sometimes not so welcome engagement has been effective in the past at raising awareness and in directly or indirectly helping to get results (necessary changes).  Their new formal campaign, however long it lasts, is likely at the very least to maintain, hopefully broadly welcomed, pressure for improvement, if not help increase it.  If and when the campaign ceases, their continuing engagement in environmental issues general and water quality in particular, isn’t going to cease, unless of course there are no longer any substantive issues to be addressed (all but inconceivable in the foreseeable future). So get used to the idea there is going to be greater public awareness and interest in water and other environments in all destinations and not just at the coast and in the countryside.

3. Defra as the leading department is in the process of making a number of critical decisions that will impact on those already actively engaged in designated bathing water management but also on a large number of destinations and locations that currently aren’t but could or will be involved over the coming years.  Destinations may wish to have some influence on those decisions.  Decisions that in many localities, could (almost certainly will) leave some with a growing public expectation or demand for better general water or bathing quality water but absolutely no prospect of delivering it, because the target dates, standards, investment profile, investment programme decisions, penalties, enforcement regime etc., all of which are then outside of your own control, don’t favour your particular circumstance. Of note this is pretty much the same sort of scenario that many coastal destinations faced pre-2000 before investment and associated improvement began to catch up with bathing water requirements.

I will endeavour to make sure tourism interests are made aware of any specific consultations or opportunities to influence future direction; hopefully other tourism representative organisations will try to do the same. It should be noted that tourism’s interests, beyond the current established designated bathing waters, doesn’t appear to register that highly on Defra’s radar.  All the more reason I would suggest for non-designated bathing waters and non-coastal destinations to start putting down a strong marker of interests and intent in issues that many have previously largely been able to ignore.

4. Whatever the outcome any significant improvement at the local level that is reliant on infrastructure and capital investment, will take years to come to fruition.  There isn’t going to be a ubiquitous, or instantaneous improvement and, therefore, there may be competitive advantage for those that recognise they have a potential problem early and make the earliest and best case to fix it.  Given the scale of the task facing the water companies there will, as there always has been, a need for prioritisation based on, among other things: the environmental, social and economic value attributed to any improvement being delivered.  Those that don’t make a case, aren’t likely to win any prizes and those that do but do it belatedly, will in all probability find themselves towards the back of the queue. Act now or pay a much higher price over a longer period later.

The time campaign and associated articles can be accessed at:

Three other developments of relevance: 

The campaign group Surfers Against Sewage (SAS) have recently won their case for a judicial review of the Governments plans to push back certain target dates for water quality improvements. A date for that review is not yet fixed but it adds another level of complexity to the question of target dates and therefore of investment planning and indeed on subsequent enforcement action if those targets aren’t met. 

A landmark court ruling from several years ago has made it possible for the public to access discharge date from the Water Companies which they previously were able to withhold. As a consequence, the water companies’ actions are now open to much greater scrutiny and challenge, regardless of any resource driven restrictions on EA’s monitoring and enforcement activities.  The activities of local campaign groups, privately funded water testing and local investigations are likely to become a growing feature of the water quality debate, particularly away from, or in response to trying to achieve official bathing water site status.  Keep local campaign groups close and understand their aims and objectives might be sage advise?

Another recent landmark case brought by the owners of Manchester Ship Canal against United Utilities (UU) found in UU’s favour.  The findings apparently sever to help blocks private companies and private individuals from seeking damages from the private utility companies for pollution from overflows.  This if anything increases the need for effective, efficient and meaningful monitoring and enforcement by EA, who can (but currently seldom do) prosecute on behalf of the public.  That in turn puts the onus on Government to give EA the legal tools, the direction to prioritise and the resources to undertake enforcement action. Essentially if EA, Ofwat and Government don’t effectively govern waste water discharges no one else can now help do so.    

What’s in a name, do words matter?

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As you will now be aware there have been some major departmental changes within the Westminster Government this week, resulting in the creation of new departments, a redistribution of responsibilities within some and a refocusing of priority within other existing departments.  The biggest looser by some margin has been DCMS which has lost its responsibility for digital.  This major loss of influence is described as “we will streamline and re-focus the Department for Culture, Media and Sport to support and celebrate the immeasurable richness those sectors bring to our national life”. More on the background can be viewed here.

Others in our sectors have already noted that DCMS’s new mission statement published with the No 10’s announcement and any accompanying text published to date, fails to reference tourism, visits or visitors or gives any priority to the tourism function, as to some degree previous iterations did.  The reformed Department’s tasks are now summarised as:

 “The Department for Culture, Media and Sport will focus on supporting culture, arts, media, sport and civil society across every part of England – recognising the UK’s world leading position in these areas and the importance of these sectors in contributing so much to our economy, way of life, and our reputation around the world. The department will champion sport for all at every level; support our world-leading cultural and creative industries; and enhance the cohesiveness of our communities.”

This compares with the previous mission statement, which in fairness wasn’t all that explicit and arguably pointed rather more towards international inbound than it did to domestic tourism:

“The Department for Digital, Culture, Media & Sport (DCMS) helps to drive growth, enrich lives and promote Britain abroad.  We protect and promote our cultural and artistic heritage and help businesses and communities to grow by investing in innovation and highlighting Britain as a fantastic place to visit. We help to give the UK a unique advantage on the global stage, striving for economic success”.

In earlier versions tourism/driving visits/visitors was sometimes expressed as a, unifying purpose, I.E., we will support culture, media and sport in order to make Britain a better, more popular place to visit, or words and phrases to that effect.

Does the absence of any reference in the new mission statement and priority areas really matter?  Yes and no.  No, it doesn’t matter, provided DCMS Ministers and officials continue to fight the tourism industries corners and have the power to influence all the other departments who largely hold the physical, policy and most of the financial levels of Government.  So yes, unfortunately it does matter. It matters because if tourism isn’t recognised by No 10, who apparently authored this new direction behind closed doors, as they did with the whole revamp, DCMS is far more likely to be left constantly on the backfoot when trying to represent tourism’s best interests to other, more powerful departments (arguably no huge change there then).

None of us really understand or know the ever-changing intricacies of inter-departmental and inter-ministerial relationships, to be absolutely certain of the implications. Nonetheless, it wouldn’t be unreasonable to suggest that it would certainly have been better all round had there been a passing nod to tourism and the visitor (economy) if not an explicate reference.  Its hard to defend a stance or argue a case if that stance as no official status and your remit to do so isn’t clear to all.

Where the lack of reference absolutely matter is in the intended or unintended messaging to the “tourism industry”.  Hopefully it is a bit of an unnecessary, or better still a totally unintended, own goal, that can and will be quickly rectified.  The next big indictor expected any day will be the confirmation of the division and titling of Ministerial responsibility.  Although already reconfirmed as a Minister of State within DCMS, Stuart Andrew MP the latest of a long line of Ministers for Tourism (always among a string of other responsibilities) has also been given a parallel equalities role in the new Department for Business and Trade, while his role(s) within DCMS have yet to be announced/reconfirmed.  There is currently no expectation or indication that Tourism will cease to be a Ministerial responsibility and certainly not simply just because it hasn’t been referenced in the latest mission statement. It could of course be one of a large range of competing responsibilities or given to a Minister sitting in the House of Lords responsible for all other DCMS functions within the upper house. Both would act as a distraction from what we at least might hope would be their priority task?

God forbid, but if Government were nuts enough to genuinely downgraded tourism. That would be a political open goal and one that would not be easily overlooked or ignored for long by the other main political parties.

With a General Election on the very near horizon (at the most now 23 months away), a little bit of me is mischievously hoping that HMG are that nuts.  Experience suggests to me that when the serving Governments mistakenly chooses to drops the tourism ball, it very quickly bounces and gets picked up by others forcing whoever retains or takes control to take tourism far more seriously that might otherwise have been the case. Perverse as it might be, a little pain now, securing a lot more hope for the future.  

While I am keen to see tourism front and foremost in DCMS’s roles and functions, I am actually rather keener to see someone, anyone the Westminster Government, recognising the absolutely vital role of domestic tourism in underpinning the social and economic wellbeing of major areas, significant urban communities hundreds of thousands of individual businesses and millions of individual workers and their dependants. Within that I am also keen to see Treasury start understanding that a holidays, breaks and days out not taken in the UK don’t automatically result in that money being spent or retained elsewhere within the UK economy. Unnecessary and avoidable leakage to overseas destinations is a serious economic issue and that deserves to be viewed, discussed and, if necessary, addressed as such. Names and words do matter, but nowhere near as much a well-informed action, where action is genuinely needed to secure both a healthy domestic and international inbound tourism market.   

Colleagues seek information

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I have put two requests for information under the “Forum: ask questions get answers” main menu tab of

The first seeks examples and associated information on wider holistic “place-making” strategies, rather than a tourism strategy. See the full request at:

The second seeks examples and associated information on supplementary planning documents relating to short-term lets. See the full request at:

If you can assist please do. If you don’t have access to the information sought yourselves, then please consider passing the request to those you might.

The electric vehicle revolution, rail and reasons to pause for thought?

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For very good reason in recent months and years the majority working to manage destinations, be that  local, sub regional, regional or national destination management, have been largely focusing on the here and now.  Horizon scanning has been necessarily restricted to the coming season, at best the one after that.  A number of recent snippets, rather than any one big news item have led me to conclude that there is now equally good reason to lift our gazes again to the seemingly far horizon or risk losing fleeting opportunities to tweak some fundamental strategic shifts.  In particular, I am thinking here of UK transport policy and especial, at this moment about the promised Electric Vehicle (EV) revolution.  A revolution that could so very easily be more akin to coup; a coup which could so very easily leave domestic tourism sat on the wrong side.

Three years ago, when HMG change the proposed target date for a ban on the UK sales of new fossil fuel vehicles (FFVs), largely in favour of EV’s, from 2035 to 2030, British Destinations began raising potential concerns from a general domestic tourism perspective. These were based on little more than the simple logic (often the best) that: in an industry that is totally reliant on people being able to travel and where broadly 80% on average travel to and from their voluntarily chosen destination(s) by private motor car, there is little room to leave it to chance that HMG, as a whole, and specifically DfT within it, are totally attuned to our particular needs and the implications of our arguably, unavoidable level of reliance on “the car”. In reality we know that that average of c 80% quickly becomes plus 90% for the vast majority of non-major city destinations, rising in the more remote, and consequentially more vulnerable popular and more niche rural and coastal destinations, to nearer 100%. 

Given the complexities involved ranging from: how the new and subsequently the used car market functions, through the current cost and operational lifespan of EV batteries, to where the strategic, policy and operational control of the UKs automotive industry actually lies (more Berlin, Beijing than Birmingham), the popular, entirely plausible presumption that this will involve no more than a simple one for one swap from FFV to EV is at the very least questionable, if not leaning towards the improbably. With good cause some may say, well of course this is the case: reducing unsustainable levels of car ownership and usage is an entirely legitimate objective and a welcome positive outturn.

This prompts subsidiary questions like: does fewer, potentially far few cars, necessarily equate to fewer, potentially far fewer visitor choosing or being physically able to get to all the popular UK destinations, historic houses, rural areas etc. that they get to now?  If they can’t get there by motor vehicle will rail, coach, bus or other forms of “public transport” really ride to the rescue? And if they do, will that serve everyone’s best interests or just those already currently reasonably connected? Or, faced with an additional barrier to domestic travel, will many more of us just choose the least line of resistance, hop on a train or take an EV taxi to the nearest airport and “save the UKs environment” by exporting the problem and flying off abroad?   To be totally frank I don’t really know, nor do I suspect does anyone else. What I do know is that collectively we do need to know ASAP the direction of travel, preferably long before there is absolutely no choice left for us in the matter and less time and fewer options to successfully adjust.

Three years ago, during the hight of pandemic, it was probably entirely acceptable to say things like: it’s a decade plus away, alternative power train technology, enhanced battery or charging technologies, government sales and manufacturing incentives, new automotive industry policy approaches or, whatever, will at the eleventh hour save the day. Three years later it isn’t as acceptable to keep saying much the same things. Moreover, in the last 6 months there has been a drip feed of events and Government and motor manufacturing news that combined suggest that the master plan for an EV revolution might be less a plan and more a lot of good ideas and unproven aspirations. My own hopes of a new alternative powered by fresh air and fun allowing the tourism industry to capture the lion’s share of both the domestic tourism and transport markets in a oner, are now rapidly fading!

My current “back of fag packet” assessment is that we have at best a couple of years to try and influence national strategic or policy direction in some small way, 3 or 5 years before levels of EV ownership starts to have real and meaningful consequences for domestic tourism and a little over 7 before a relatively rapidly escalating set of circumstances begin to set in, post the current target date for a ban on new FFV sales. A revolutionary set of circumstance that will undoubtedly have the potential to radically change how we do business, where and with whom and how, how often and by what means Mr and Ms average, travel to our destinations (or not) in the decade and beyond that follow the 2030 trigger point.

We can choose to either try and influence and/or begin proactively predicting and adapting to possible changes and starting doing that now.  Or alternatively we, the domestic tourism industry, can just carry on regardless, in the forlorn hope that DfT and the automotive industry get on and do a perfectly adequate job of it all. Leaving us all with no more to do that just worry about any unpleasant consequence, if and when they occur, with luck, a good decade or more away. I for one think the former albeit a difficult ask of and a difficult task for a disparate domestic sector is preferable to the latter, a high risk, if not utterly reckless approach. Hence, I guess my compulsion to write this piece now.

The recent reports I refer to include: the failure to meet, indeed come anywhere near the installation rates for public EV charging points, needed to achieve the 300k, 2030 target and serious doubts that this can/will now be addressed, combined with growing concern that some, particularly, seasonal or event-based scenarios will ever meet viable cost/benefit thresholds.  This year one very senior automotive source has gone on record saying that all manufactures are entirely focused on quality marks and high-end market production, with the least expensive EV’s on the UK market coming in at 1/3 more than the current least expensive FFV (c£30k v c£20k), with downstream consequences for who can in future afford to own/lease new and subsequently own a used car.  Of more concerning, they also doubt that EV production for the European/UK markets will ever move back into the popular, affordable market space. 

Meanwhile, motor manufacturers are currently asking Government to consider subsidising the sale of second hand EV’s to the middle-income market to the tune of upwards of £8k per unit.  The supply of second-hand EV lease vehicles is only now starting to ramp up but is apparently, already out of kilter due to insufficient demand in the used market. Excess supply of relatively new, relatively low milage used EV’s means an unexpectedly lower resale returns for the leasing market that dominates the new car market.  That in turn effects the value ratios of new to used, forcing up future leasing costs further destabilising the present leasing model.   If the used sale market for current EV’s isn’t functioning now (without heavy public subsidies), then potentially what hope for the yet to evolve second, the third and subsequent hand sales market? When there are fewer or no FFV alternatives the used EV market may of course stabilise, it may not.

Although, the predicted average life span of an EV and EV battery in a European climate (12 years 100k to 200k miles) is not that dissimilar to the proven average for an FFV (12 years and 200k miles), the former is still just that, a prediction and one with up to a 50% fudge factor applied. It will remain so for a good number of years to come.  Some sources serious doubt the claimed battery life span, not least because battery life is related to the number of recharge cycles and not use/mileage.  Poor charging practice, seriously effects battery life span. That in a country where one of the commonest FFVs failures remains the classic user error of wrong fuel type, there is not too much hope of the required care and good practices needed for longevity being universally applied. In addition, batteries tend not to die overnight but to gradually hold less and less charge, reducing range and reliability over time. Older cars will by definition be less efficient.  Battery repair or replacement, the only solution to that is also current prohibitively expensive. More in the order of an FFV engine replacement, than an engine repair or something manageable like a new exhaust system.  This makes second or subsequent hand EV purchases potentially far riskier and far less affordable and doing so to those who use the used market mainly for reasons of affordability. 

All of these  factors have a potential implications on the used motor market and increasingly so the more towards the cheap and cheerful end you progress.  Does a potentially radically changed second-hand market and a different ownership dynamic or model make any difference to a currently largely car using customer base?  Probably and does that matter to tourism? Almost certainly but who knows yet just how and by how much? I may be wrong but I do now think it is import to know quite a bit more, quite a bit sooner than if we just leave it to non-tourism interests to tell us in their own good time what the realities are or more accurately may possibly be.

In parallel the future of UK railways under the newly created direction of Great British Railways was set to undergo significant and, in rail term, a relatively rapid change in its own post pandemic revolution. That now seems more likely to be a rather more evolutionary process progressed at a slightly more leisurely pace.  Aspiration, practicalities and competing interests have hit head on in the last 12 to 24 months and halted, slowed or changed some of those original ambitions.  Changes will happen but whether they amount to a major switch away from a 9 to 5 Monday to Friday commuter driven network, to something that also proactively serves the needs of other markets, including within that leisure travel, remains to be seen. 

What is clear, or at least more readily predicted, is that if rail doesn’t already play a role in the destination, for example because there is no rail connection or existing connections are already inadequately serviced, then realistically things aren’t going to change much, if at all very soon. Other than the the trains themselves, nothing move fast in the rail industry at the best of times and these are far from the best of times for the rail network. It is also important to be mindful that rail travel involves connectivity at both ended of the process.   The destination may have adequate connectivity to adequate rail services but your potential customer base may not. Not everyone lives manageably near enough to a station to make rail the panacea that those who do have the luxury of living manageable near rail station, might naturally assume it to be.  

The nature of the rail service you have, or have not, has obvious read across to the issues of the future of the “family car”.  In short, if you have rail connectivity and good services then at least you have a potential alternative, should the EV revolution leave domestic tourism or your particular destination out on a limb.  If you haven’t got access to rail or your current services are poor, then as of today’s date, I am far from sure what the future holds for your destination. Or, to be frank, if indeed some will actually have a future, in anything other than more niche and/or high end, low volume markets.  For some that equates to no change and no problem, for others it equates to a manageable change. For some, probably larger destinations majoring in the popular, more seasonal family leisure markets, it could equate to a major challenge. A radical redrawing of how UK rail is owned, operate and run, for what purposes, can’t of course be ruled out, albeit again it would not result in a quick fix.

I would welcome views from both members and from wider domestic tourism interests other presentative bodies and anyone who might have an informed view.  Am I right to pause for thought, are there some genuinely serious issues here and do we jointly need to do something proactively about them?