The Principles of a Local Discretionary Transient Visitor Levy or Tourist Tax

3. What activity should a visitor levy apply to?

This chapter begins with a brief section covering general issues raised in support of, or objecting to, a visitor levy. It then goes on to responses to the questions covering whether an overnight stay in commercially let accommodation is an appropriate basis for applying a levy on visitors and whether there are other activities to which a visitor levy could be robustly applied and enforced.

General support for, or objection to, a visitor levy

As noted in the introductory chapter, 1,202 of the responses received in response to the consultation were based on a Living Rent-related campaign. The vast majority of those supporting this campaign were Individual respondents. The issues they raised were that:

• A visitor levy should apply to holiday lets, and any revenue raised used to improve local housing, roads, or pavements or improve refuse collection and public transport services. Recent polling was reported to show that 84% of people in Scotland support the introduction of new taxes on holiday lets, with more than 60% saying that 'all' or 'most' of this money should be ring-fenced to improve local services.
• Investing any money raised through a visitor levy back into communities, and into improving local housing is critical. It was reported that over 13,000 people have signed a petition calling for a tax on holiday lets, and for that money to be ring-fenced for housing.

Some comments were in line with those who thought an overnight stay in commercially let accommodation is an appropriate basis for applying a levy on visitors (at Question 2 below). They included that many other European countries charge a visitor levy and that the majority of visitors will not be influenced by it. Based on experience of paying a tourism charge elsewhere, a small number of Individual respondents were amongst those suggesting that a levy is usually minimal and easily absorbed into the cost of any trip.

The potential benefits to local communities were also highlighted, including that charging a levy in areas currently experiencing very high numbers of visitors may help to alleviate some of the pressures on local services. The potential to spend the revenue raised via a levy to support services or facilities that would benefit the local community was also noted.

Other respondents took a very different view and made it clear (particularly at Questions 1 or 2) that they did not agree with plans to allow local authorities to introduce a visitor levy. Included within some comments was an objection, primarily from Individual respondents, to not having been asked (either as part of this consultation or in a prior stage), whether they agreed or disagreed with the general principle underpinning the current proposals.

Other concerns often reflected those made by respondents who thought an overnight stay in commercially let accommodation is not an appropriate basis for applying a levy on visitors (at Question 2 below). Views expressed by those who disagreed with charging a visitor levy included:

• It will be damaging to the competitiveness of Scotland's tourist industry. It was suggested that the UK is already not a competitive destination based on price, coming 140^th out of 140 in international tourism competitiveness terms.^[7] There was an associated concern that a visitor levy will add to the perception that Scotland is an expensive place to visit and will have a negative impact on Scotland's reputation as a welcoming country. A range of respondents, including Accommodation provider (hotel), Accommodation provider (other), Tourism and hospitality industry representative organisation and Individual respondents were amongst those commenting on competitiveness.
• A suggestion that the UK tourist industry is already operating in a high tax environment, including because the UK has the second highest VAT rate in Europe at 20%. It was also reported that many other EU destinations apply a reduced rate of VAT to accommodation and tourism services.
• A range of respondents, including Accommodation provider (hotel), Accommodation provider (other), Tourism and hospitality industry representative organisation and Individual respondents, argued that a visitor levy is likely to result in a decrease in the number of visitors coming to, or 'staycationing' in Scotland, or to visitors spending less or reducing the length of their stay. This was thought likely to have a knock-on effect on a wide variety of businesses servicing visitors as well as on accommodation businesses.
• A concern that the administrative burden and cost to tourism businesses and local authorities in collecting the levy is likely to be significant, particularly given the level of revenue likely to be obtained.

Overnight stays

The consultation paper set out the intention that a visitor levy in Scotland would apply to overnight stays in commercially let accommodation. During the National Discussion, a range of industry stakeholders highlighted the importance of ensuring a level playing field across all types of accommodation including hotels, bed and breakfasts, self-catering units and campsites. It is therefore suggested that the visitor levy would apply to overnight stays in all types of accommodation.

Question 2: Is an overnight stay in commercially let accommodation an appropriate basis for applying a levy on visitors?

Please provide a reason (or reasons) for your answer.

Responses to Question 2 by respondent type are set out in Table 3 below.

Table 3

Question 2: Is an overnight stay in commercially let accommodation an appropriate basis for applying a levy on visitors?
Respondent type	Yes		No		Don't Know		Not Answered	Total
	N	%	N	%	N	%	N	N
Individuals	150	56%	101	38%	17	6%	7	275
Accommodation provider (hotel)	2		46		1			49
Accommodation provider (other)	9		55		1		2	67
Business organisation	3		1				3	7
Community council or residents' association	4						1	5
Heritage or culture organisation	7		2		2		1	12
Local authority	15		3		1		3	22
Other	1		2				2	5
Other representative organisation	1		2				2	5
Other tourism or hospitality business or organisation	3		3		1			7
Port authority	1		2					3
Professional body	8		1				1	10
Public body	2						4	6
Tourism and hospitality industry representative organisation	5		3		1		1	10
Tourism development or promotion organisation	2		7		1		1	11
Trades union, political party or campaign organisation	3						2	5
Total organisations	66	33%	127	63%	8	4%	23	224
All respondents	216	46%	228	49%	25	5%	30	499

2.1. In total, 49% of respondents who answered the question did not think commercially let accommodation to be an appropriate basis for applying a levy on visitors, while 46% thought that it would.

There was a marked difference between responses of individual and organisational respondents: while 56% of individual respondents were in favour of a levy on visitors staying in commercially let accommodation, only 33% of organisational respondents agreed with this type of levy.

There were also differing views between organisational respondent groups. Both groups of Accommodation providers were very clearly opposed to a levy on commercially let accommodation as were the majority of Tourism development or promotion organisations, while other groups were evenly balanced or were in favour. The analysis of additional comments is broadly by the respondent's answer at the closed question, with points made by those who did not know or did not answer inserted where most appropriate. A small number of respondents questioned the design of the consultation and the lack of an option to disagree with the principle of a visitor levy.

Issues raised at Question 2 but relating to the basis on which the levy might be charged are covered at Questions 4 and 5.

Yes, an overnight stay in commercially let accommodation is an appropriate basis for applying a levy on visitors

Among respondents who thought that an overnight stay in commercially let accommodation is an appropriate basis for a visitor levy, two points were made very frequently:

• That this type of tax is widely applied elsewhere in Europe and worldwide.
• That it is the easiest way to collect a levy and will be simple for visitors to understand.

Some respondents commented that while they did not agree with the principle of imposing a levy on visitors at all, or did not consider a charge on overnight accommodation to be fair, they did agree it to be the most practical option or the only practical option. Others argued that it is fair that visitors should pay towards the cost of the facilities they use.

While agreeing a levy on overnight accommodation to be appropriate, some respondents argued that further consideration should also be given to a charge on other visitor activities or that a charge should be applied to other visitor activities. It was suggested the legislation should give local authorities powers to apply a levy to other visitor activities if appropriate.

Respondents who agreed a charge on overnight accommodation to be an appropriate basis for a levy also highlighted the need for clarity with respect to the definition of 'commercially let' accommodation or argued the importance of covering all accommodation, including booking made through collaborative economy accommodation platforms such as Airbnb.

Other points that were suggested to require further consideration included:

• The definitions of 'overnight stay' and 'visitor' and how an overnight visitor is distinguished from a tenant.
• The requirement for a register of addresses from which payments are expected and the current lack of a mechanism for enforcement in the short term let market.
• The position of second homes or holiday homes that are not advertised commercially but for which owners may receive compensation from family or friends when used.

Some respondents also suggested it would be appropriate to exclude some types of accommodation from collection of a levy including hostels, student campuses, campsites and small businesses operating below the VAT threshold. Concerns were also raised with respect to not-for-profit adventure centres for children where many of the adults present will be volunteers. Respondents questioned the impact a visitor levy might have on residential trips for schools.

No, an overnight stay in commercially let accommodation is not an appropriate basis for applying a levy on visitors

Respondents who did not think an overnight stay in commercially let accommodation to be an appropriate basis for a levy sometimes objected to the principle of introducing a levy. Reasons given included a concern that increased accommodation costs will make Scotland less competitive and damage the tourism sector. The impact of a levy on Scottish residents holidaying in Scotland was also noted as were other reasons that people may need to stay away from home, including on business or because of transport timetables. Potential exemptions to the levy are covered at Questions 11 and 12.

As noted in the general issues section above, accommodation costs in Scotland were suggested to be high already and subject to a heavy tax burden, with business rates and VAT levels highlighted in particular. VAT on tourism-related activities was noted to be lower in several parts of Europe where visitor levies are charged. An Accommodation provider (other) and a Business organisation respondent raised the prospect of VAT being charged on the levy, with a suggestion that small businesses that are not VAT-registered may reduce their turnover in order to stay under the VAT threshold^[8].

It was also argued to be unfair to target only one part of the tourism sector with a levy when a large proportion of tourism related spend is elsewhere – for example on food and entrance tickets. Further, it was noted that the proposed levy on overnight accommodation adds to costs for those visitors who are already contributing most to the local economy while failing to tackle issues associated with day visitors, cruise passengers and motorhome or camper van use which some respondents identified as presenting the greatest problems in their own area.

One Local authority respondent suggested that, in their region, a levy that excludes issues relating to parking, camper van facilities and coach tours associated with cruise ships might fail to carry broad public support. Another Local authority respondent argued a levy on overnight visitors would undermine growing the high value overnight visitor segment, a central objective of their tourism strategy. Increased numbers of day trips were predicted if potential guests decide not to stay overnight to avoid the levy, as was an increase in wild camping to avoid paying the levy at campsites. Potential negative impacts for farmers and crofters were suggested in the latter case.

Other comments focused on practical challenges respondents anticipated. . Collection of a levy was predicted to add to costs and administration for accommodation businesses with a disproportionate burden on small providers in particular. It was also suggested, including by a number of Accommodation provider (other) respondents, that there is unlikely to be sufficient incentive for software providers to develop tools to assist accommodation business in administration of a levy and that the proposals give no indication of how the Scottish Government will support smaller businesses. Some respondents, including Accommodation provider (hotel) and Accommodation provider (other) respondents, indicated that they would not be able to increase prices and would have to absorb the levy themselves, further squeezing narrow margins.

If local authorities are to be given powers to impose a levy on accommodation it was argued to be essential that there is a level playing field, with the levy applied to all accommodation types and, in particular, that the home share and short term holiday let market must be included. A range of respondents, including Accommodation provider (hotel), Accommodation provider (other) and Individual respondents were among those taking this view.

The need to provide a clear definition of what is meant by 'commercially let accommodation' was highlighted, particularly in the context of caravanning and camping where the site owner provides the pitch but does not own the accommodation, which is therefore not commercially let. A similar argument was made with respect to marinas. An Other representative organisation respondent suggested that marinas fall outside the definition of a 'tourist accommodation establishment' set out in EU Regulation 692/2011 and they argued they should be excluded from any levy on this basis.

Clarification was also sought regarding non-paying guests, for example, family members who might stay in, but not pay for commercial accommodation.

Rather than imposing a levy on accommodation, some respondents argued that, for islands, a levy added to travel tickets or charged at the point of arrival would be preferable. Potential benefits identified included: capturing all visitors including those making day trips; avoiding administration for accommodation providers; and reducing the burden on overnight visitors and encouraging longer stays. A Local authority respondent commented that islands are already expensive places in which to take a holiday and that many islands would benefit from attracting more visitors. They suggested a requirement for any scheme to be island-proofed in line with the Islands Act (Scotland) 2018.

For other parts of the country, suggestions as an alternative to a levy on overnight accommodation included:

• An entry or exit tax.
• A charge on tickets for tourist attractions and events.
• A tourism supplement to rates across a broader range of tourism businesses.

Additional taxable activities

The consultation paper noted that the National Discussion drew attention to interest in exploring whether other visitor activities could also be subject to taxation. It went on to explain that at this time the Scottish Government is not minded to expand the visitor levy beyond overnight stays, but that they wished to explore both the desirability and feasibility of applying a visitor levy other than in relation overnight stays before making a final decision. Other visitor activities that were suggested during the National Discussion were:

• Day visitors to a local authority area.
• Cruise ship visitors who disembark for a day.
• Wild or rough camping, including motorhomes or caravans parked and occupied overnight in places that are not formal campsites or parking places.

The consultation explored if it would be feasible for a visitor levy to be extended to other visitor activities, notwithstanding the challenges this might present.

Question 3: Which of the following activities do you think a visitor levy could be robustly applied to and enforced, and how?

a) Day visitors not staying overnight.

b) Cruise ship passengers who disembark for a day before re-joining the vessel.

c) Wild or rough camping, including in motorhomes and camper vans.

Please explain how a visitor levy could be applied and enforced.

Responses to Question 3 by respondent type are set out in Table 4 below.

While a majority of those who answered the question were opposed to a levy on day visitors or on wild camping, including in motorhomes and camper vans (65% and 60% respectively) a similar proportion (64%) were in favour of a levy on cruise ship passengers. These results at the closed question are discussed in more detail under the relevant headings below.

Table 4

Question 3: Which of the following activities do you think a visitor levy could be robustly applied to and enforced, and how?
Respondent type	Day visitors not staying overnight (n = 401)				Cruise ship passengers who disembark for a day before re-joining the vessel (n = 406)				Wild or rough camping, including in motorhomes and camper vans (n = 368)
	Apply		Do not apply		Apply		Do not apply		Apply		Do not apply
	N	%	N	%	N	%	N	%	N	%	N	%
Individuals	86	33%	171	67%	165	64%	94	36%	97	39%	150	61%
Accommodation provider (hotel)	5		8		7		5		6		6
Accommodation provider (other)	30		30		41		19		20		21
Business organisation	1		3		1		5				4
Community council or residents' association	1		3		3		1		4
Heritage or culture organisation			8		5		3		2		7
Local authority	4		13		9		7		5		10
Other	1		2		1		2				3
Other representative organisation	1		2				2	5	2		1
Other tourism or hospitality business or organisation	2		3		6				3		3
Port authority			3				3				2
Professional body	1		8		5		4				9
Public body
Tourism and hospitality industry representative organisation	3		2		4		3		2		3
Tourism development or promotion organisation	5		4		8		1		6		1
Trades union, political party or campaign organisation			1				1				1
Total organisations	55	38%	89	62%	93	63%	54	37%	50	41%	71	59%
All respondents	141	35%	260	65%	258	64%	148	36%	147	40%	221	60%

2.1. In general comments at Question 3 some respondents noted that, while agreeing with concerns set out in the consultation paper regarding how any levy on day visitors could be devised, they felt such a levy should be given further consideration before a visitor levy of any kind is introduced, or that any form of visitor levy should be applied across the board and not restricted to accommodation providers. As alternatives, a number of Accommodation provider (hotel) respondents suggested hypothecation of existing VAT payments and a Tourism and hospitality industry representative organisation respondent suggested hypothecation of an element of Non-Domestic Rate (NDR) payments.

The need for thorough research on the application and enforcement of a visitor levy was argued and also that, since the consultation focused on the practical implementation of a levy on overnight stays, a further consultation process would be needed before moving forward with a charge on any of the additional activities covered at Question 3.

Day visitors not staying overnight

As set out in Table 4, 65% of respondents who gave an answer thought a levy could not be applied to day visitors not staying overnight, while 35% thought it could. Individuals were marginally more likely to be opposed to such a levy than were organisations (67% and 62% respectively). While all Heritage and culture organisation and Port authority respondents opposed a levy on day visitors, as did a majority of Local authority and Professional body respondents, other respondent groups were fairly evenly balanced.

It should be noted that some respondents who argued a levy could not be applied to day visitors indicated that they were referring to the idea of a charge for entering an area. The majority of those who suggested a levy could be applied referenced additional charges on existing fees, such as for entrance to paid attractions, ferry tickets or car parking.

Apply a levy to day visitors

Among respondents who thought a levy could be applied to day visitors the most frequent suggestions were:

• A levy on the entry fee for paid attractions and events. Examples included the Edinburgh Festival, Fringe and Tattoo.
• A charge on ferry or air tickets to the islands or a toll on the Skye Bridge. It was argued existing concessionary travel schemes could be used to identify and exempt islanders. Other potential benefits of such an approach were covered at Question 2 and points relating primarily to day trips made by cruise ship passengers are discussed at Question 3b.

Other suggestions for charging a levy on day visitors included charges on:

• Car parking and public toilets.
• Vehicle hire.
• Companies running day trips and city bus tours.
• Restaurant meals.
• Road tolls.
• Entry to National Parks.

With respect to managing pressures in popular locations it was observed that some national parks overseas (such as in the US and New Zealand) limit car access to parts of the road network, restricting access to tickets on arranged bus services. It was argued that restrictions on access to places might be a positive step, provided that a managed solution is available.

Do not apply a levy to day visitors

Respondents who did not think a levy could be applied to day visitors expressed a view that to do so would be impractical, unworkable or too difficult to implement and enforce, or that collection would not be cost effective.

Some respondents thought there was a risk of discouraging day trips and of penalising local businesses. Difficulties experienced when implementing a levy in other countries were cited, including what were viewed as negative impacts on the tourist industry elsewhere. There was also reference to the delayed introduction of a day visitor tax in Venice. Difficulties in defining a day visit were also argued and the lack of a way to monitor day visitors, particularly from other parts of UK, was observed.

Other comments focused on potential impacts on local residents, including how they might be distinguished from day visitors. Regional issues, including daily commuting between local authority areas for work or school, were also highlighted, as were issues for island residents who may need to visit the mainland for a variety of reasons.

Further reasons given for opposing a levy on day visitors included:

• That multiple charges could be applied if visiting multiple attractions.
• That a charge on transport to islands would not capture those arriving in pleasure vessels or light aircraft.
• Pride in Scotland's Scottish Outdoor Access Code.

Cruise ship passengers who disembark for a day before re-joining the vessel

Of respondents who gave an answer, 64% thought a visitor levy could be applied to cruise ship passengers while 36% thought it could not. Although there was very little difference in views between organisational respondents taken together (63% in favour) and individual respondents (64% in favour), there was a marked divergence between different organisation types. While most respondent groups showed a majority in favour of a levy on cruise ship passengers, Business organisation and Port authority respondents were firmly opposed. Local authority respondents were fairly evenly divided.

Apply a levy to cruise ship passengers

In their further comments, those who thought a levy could be applied sometimes made comments explaining why they thought this appropriate – typically a view that cruise ship passengers may make little contribution to the local economy.

A levy on passengers at disembarkation was the most frequently suggested option. While some respondents envisaged that an individual charge per passenger might be levied on leaving the ship, it was also noted that cruise companies will have a record of those who go ashore and that a collective levy could be charged to cruise ship operators. It was suggested disembarkation fees could be included in the passenger's ticket price.

As an alternative to disembarkation fees charged per passenger an additional mooring tax was suggested and that this might be levied either according to the number of passengers on board, or on the size or capacity of the ship and could be regardless of disembarkation. Existing mechanisms for collection of berthing dues or harbour fees were suggested as a means of collecting a levy.

A Local authority respondent observed that charging of any visitor levy must respect the terms of the Harbours Act 1964, and the position of small yachts and private boats in relation to any levy was queried by a Professional body respondent.

Rather than charging either a disembarkation fee or specific mooring tax, some respondents argued that, while docked, a cruise ship could be considered as commercially let accommodation and a levy applied accordingly as for hotel guests.

As an alternative to fees charged at ports it was also proposed that a levy might be:

• Placed on excursion costs, on coach hire or on entry fees to heavily visited sites.
• Applied as an entry tax at borders or in the same manner as an airline tax.

For islands, it was argued that there could be an entry (or exit) charge on all visitors including, but not limited to, cruise passengers. This was suggested as an example of island-proofing in practice.

Respondents sometimes addressed the risk that, as witnessed in Amsterdam, a levy might act as a deterrent to visiting cruise ships. While it was argued that there should be care to avoid such an outcome, it was also suggested that such a possibility could be avoided if this approach to cruise ship passengers was applied consistently throughout Scotland.

Respondents who agreed and disagreed with a levy suggested that, where ships dock in one authority area for visitors to visit a different area, then any levy should be shared.

Regarding the level of charge, suggestions included that a per person levy should typically be very small – for example equivalent to a parking charge, or that a rate should be set so it would not be worthwhile for cruise companies to dock elsewhere and bus passengers over longer distances to tourist hotspots.

It was also observed that:

• Inter-relationships between cruise ships, port authorities, local businesses and communities are very complex and may not always be obvious. A Heritage or culture organisation respondent made this point.
• The Scottish Government might consider Scotland's cruise ship economy and the extent to which it contributes positively to wider policy objectives around growth and sustainability. A Local authority respondent made this point.

Do not apply a levy to cruise ship passengers

Respondents who did not favour a levy on cruise ship passengers sometimes suggested that it would be either too difficult or expensive to apply. It was also considered unfair to target only one sort of day visitors if others are not charged. It was noted that other options should at least be considered if the consultation is to be meaningful. Other reasons given for opposing a levy on cruise ship passengers included that:

• Cruise ship visitors do contribute to local economies and should not be discouraged. It was also argued that cruise passengers may return for a land-based holiday.
• The market is price-sensitive and, if faced with a levy, cruise ships may choose different ports or may not visit Scotland at all. The cruise industry reaction to a visitor levy being imposed in Amsterdam was noted by a Business organisation respondent, a Port authority respondent and a Professional body respondent. The proposal to give local authorities discretion regarding implementation of a levy was argued to risk creating disparity in the market if some ports make a charge and others do not. Reduced competitiveness of individual ports and damage to their income streams was identified as a potential consequence in addition to the wider losses to local economies noted above.
• Port authorities already charge berthing dues and that Scotland is already an expensive destination to visit in this respect. Some redistribution of existing mooring fees was also suggested.
• Both disembarkation times and passenger decisions on whether to go ashore could be impacted by levying a disembarkation tax. It was also noted that many of those on board could be crew and would need to be treated differently.

Finally, providing sufficient notice of any charge was seen as important since cruise bookings can be made up to three years in advance, and costs that the industry cannot pass on would create a tax on operator margins.

Wild or rough camping, including in motorhomes and camper vans

Overall, a majority of respondents (60%) did not think a levy could be placed on wild or rough camping, including motorhomes and camper vans. Although individuals and organisations collectively showed a good level of agreement, with 61% and 59% respectively against such a levy there were marked differences between organisations. All Community council or residents' association respondents were in favour of a levy as were a large proportion of Tourism development or promotion organisation respondents. While both groups of Accommodation provider respondents were evenly balanced, most other respondent groups were opposed on balance.

Apply a levy to wild camping

Responses tended to focus on issues associated with motorhomes and camper vans, with some respondents specifically arguing that use of these vehicles should be distinguished from what they saw as true wild camping, and that the latter should not be subject to a levy. For example, a Heritage or culture organisation respondent suggested that wild camping (as defined by the Scottish Outdoor Access Code) should be distinguished from motorhomes and caravans.

Negative impacts arising from excessive use of motorhomes and camper vans were suggested, both in terms of road traffic generated and problems associated their use as overnight accommodation when not on campsites. Issues raised included: damage and congestion on single track roads, particularly parts of the North Coast 500 route; space occupied on ferries; problems associated with abandoned rubbish and with toilets; and damaging wildlife viewing spots. Respondents sometimes expressed a general feeling that there needs to be some form of control of motorhomes and camper vans including a requirement to park only in designated areas. One Local authority respondent reported results from their own survey showing a high level of support for a levy on motorhomes not staying on paid sites.

In terms of specific suggestions on how a levy might be imposed the two most frequently raised points were that:

• For islands, a levy could be applied to ferry tickets or could be charged at the ferry terminal. It was also suggested that a levy could be charged according to the length of the stay or the size of the vehicle used.
• A levy could be imposed on hired motorhomes.

Although it was acknowledged that a levy could be hard to enforce under other circumstances, ideas for doing so (often with respect to motorhomes) included:

• A requirement for an annual pass or shorter-term permit to be displayed in the vehicle, and that this might be obtained from local post offices, service stations, tourist offices or from machines in car parks. Wardens would be needed to carry out spot checks or issue fines for non-compliance.
• Number plate recognition and charging on entering an area, as used for applying congestion charges.
• Honesty boxes placed in commonly used locations.
• Extension of Camping Management Zones requiring a permit to camp as currently in place in Loch Lomond and the Trossachs National Park. References were also made to access charges and camping permits required in national parks in other countries including the USA and Canada.
• Increased road tax for motorhomes and camper vans.
• Use of road tolls.
• An additional fee could be added where parking for motorhomes is already restricted to designated sites on croft land.

The need to provide proper facilities and rules for use of motorhomes as seen in other countries was suggested. However, it was also argued to be unfair to use revenue raised via a levy on other accommodation – including guests at formal campsites – to provide facilities for wild camping in motorhomes if users are exempt from a charge.

Do not apply a levy to wild camping

Respondents who did not think a charge could be applied to wild camping including motorhomes and camper vans sometimes took a view that its collection would be very difficult, impractical, or unenforceable. It was also argued that the difficulties associated with collecting a levy would be disproportionate to the revenue generated, but also that use of motorhomes and camper vans may proliferate if a levy is charged on other types of accommodation. A potential conflict with the Scottish Outdoor Access Code was also suggested by a small number of Individual respondents.

A privately-owned motorhome or camper van used for wild camping was argued not to fall within the definition of 'commercially let accommodation'. Although it was thought that a hired motorhome might do so, it was also observed that someone hiring a motorhome would be unlikely to stay overnight in the same local authority area as the hiring business.

Alternative suggestions were made in order to mitigate problems associated with wild camping – sometimes overlapping with ideas proposed by those who supported this type of levy. These included:

• A ban on roadside parking in motorhomes and camper vans and a requirement to use proper camping sites or designated areas.
• Provision of better facilities for motorhomes and camper vans that could be paid at point of use.
• Allowing overnight stays in car parks that are otherwise unused at night, including those belonging to supermarkets or to Forestry and Land Scotland, for example with gated entry made available to vehicles that have their own toilet facilities on board.
• As in New Zealand, inspection of all vehicles to ensure they are 'self-contained', coupled with a scheme that allows their use in some areas while restricting it in others.
• Licensing in areas where there is a specific problem or a permit system similar to the Camping Management Zones already in place in Loch Lomond and the Trossachs.
• Penalties for camping in unauthorised areas, although it was acknowledged that collecting fines would present difficulties.