Mull Community Council have many concerns over Argyll & Bute Council’s revised visitor levy proposal and the current consultation. While we support any investment in infrastructure that improves the visitor experience or relieves communities of the pressures of having high visitor numbers, we would like to see the council prove that the benefits outweigh the risks. Below, we make some arguments for the levy not going ahead as proposed and some comments for improvements if it decided to proceed.

We understand Argyll and the Isles Tourism Cooperative and Visit Mull & Iona have called for the process to be paused while an independent assessment is carried out.

The council’s Impacts on Island Communities risk assessment identifies many of the risks but fails to offer satisfactory suggestions for control measures. The islands are already disadvantaged due to ferry fares which increase the cost of virtually all goods and services to islanders and visitors alike. The added cost of ferries is a negative factor for visitors, and further fees may be enough to encourage them to look at holidaying on the mainland. The charge could shorten stays, reduce repeat visits and lower visitor spending across all sectors.

A levy designed for visitors should never impact on the residents of Argyll and Bute when staying in their own authority’s area. A resident being charged when staying on the mainland due to ferry cancellations, or for any reason at all, makes no sense. The levy charges will also be passed on to residents and business when using local accommodation providers for travelling workers. The impact will be greater than it first appears, and if a levy is introduced, we request an exemption is put in place for all residents of Argyll & Bute staying away from home for any purpose and those from outwith the area staying overnight for any purpose, other than recreation or when on holiday. Mull relies on healthcare workers from out of the area. For example, the Craignure surgery has a permanent arrangement whereby a pool of doctors from the mainland provide cover. Several of these Doctors live outwith Argyll & Bute. Locum workers are also permanently used for homecare.

The suggestion that a proportion of the levy income could be spent on marketing or encouraging a longer tourist season does not sit well with many. If the levy goes ahead, it should be spent on infrastructure alone and ringfenced for the area it was collected in.

The council’s harbour landing fees, which are already included in ferry fares on the Oban-Craignure route, already take £0.70 per adult, £0.45 per child and £2.20 per car, amounting to a profit of £1.2m pa. we see little of that spent on the infrastructure in Craignure, with failures happening more frequently, impacting on island residents, school pupils, workers and visitors. Collected charges are used to maintain piers throughout the council area, will this be the reality of funds collected in a visitor levy?

We would like to see more meaningful consultation carried out before this proposal goes further. The online form will only reach those specifically looking for it, and there are widespread concerns over the way the questions have been set out. The questionnaire fails to satisfy many of the Gunning principles for public consultation. Answers to an online form such as this cannot replace a more comprehensive consultation and the conducting of a proper Island Communities Impact Assessment, including a thorough economic impact assessment. This should be carried out by specialist contractors, not by council staff.

The suggestion that those camping outside licenced campsites would not be charged has the potential to cause severe harm. Mull has seen a large increase in the number of campervans / motorhomes visiting over the last few years. In response, several local businesses have invested in new campsite facilities or improved existing sites. If visiting vans are encouraged not to make use of these facilities, we may see businesses failing and jobs lost. The potential environmental issues of vans finding places to camp and the inevitable discharge of sewage from some worries us greatly. It would seem sensible for motorhomes to be charged a fee when they buy a ferry ticket. Perhaps this could be refunded if campsite receipts are provided, although, the administration of this may be prohibitive.

The failure to charge cruise lines for passengers is an issue. While small charter vessels may have little impact, large cruise ships land hundreds of passengers per day. While these passengers are paying harbour landing fees and spending in the local shops and attractions, they are a burden on toilet facilities for example. The council should negotiate with cruise lines to agree a share of the landing fee, even if not at a council pier.

It should be remembered that a flat rate charge is a higher percentage of low-cost accommodation. This may affect budget travellers and reduce their spend in local businesses. Serious thought should be put in to considering a reducing fee for longer stays. It seems unfair that a large self-catering house with multiple rooms, will pay the same charge as a one bedroomed apartment.

We are told the levy would bring a gross income of £10 million per annum. The administration costs, especially for exemptions will deplete this significantly. It is likely business support officers will be required. It has been suggested that the £10m collected as a levy, would equate to 10.4m if spent in the local economy in the absence of a levy.

Many small businesses strive to remain below the VAT threshold due to the increased administrative burden. As the levy would attract VAT, this may push many businesses over that threshold or encourage them to reduce their available nights or fees. This could have a negative effect on the economy as money normally spent locally may be lost or passed on in tax. It is felt that the proposed 2% administration fee which a business may retain from the collected levy is insufficient.

To summarise, considering the disproportionate issues faced by island residents and businesses, we request:

· The process is paused until meaningful consultation is carried out which complies with the Gunning Principles.

· A comprehensive ICIA and Economic Impact Assessment is conducted by an experienced consultant.

· Consideration be given to exempting islands from the visitor levy scheme.

· All Argyll and Bute residents and workers coming to the area are exempt from charges when staying within Argyll and Bute.