Memorandum subitted by The Tussauds Group
1.1 This submission is in response to the announcement
made on 16 January, that the House of Commons Culture, Media and
Sport Committee is conducting an inquiry into the tourism sector
in the UK.
1.2 By way of background to our submission,
the Tussauds Group (TTG) owns/operates a number of major tourist
attractions within this country, including Madame Tussauds, the
London Planetarium, Alton Towers, Chessington World of Adventures,
Thorpe Park, Warwick Castle and the London Eye. Each site has
to contend with considerable challenges and constraints in terms
of their location, character and/or geography. For example:
— Thorpe Park is located within the
Green Belt, is within the River Thames floodplain and contains
two listed buildings. Part of the site is also located within
a conservation area; and
— Warwick Castle is located within
River Avon floodplain, is a Grade I listed building and the site
also contains a number of other listed buildings and a scheduled
ancient monument. The site is also located within a conservation
area.
1.3 In terms of the additional heritage constraints
noted on the above sites, the historic features referred to are
restored, maintained, enhanced and given new economic uses as
integral elements to the attractions.
1.4 All of TTG's attractions are major contributors
to the national tourism industry and to their local economies.
Indeed a recent economic study, prepared by Nathaniel Lichfield
and Partners (2006) in support of a planning application for development
at Alton Towers, identified that the Park:
1. attracts a total of £111 million of visitor
spending both on and off-site;
2. generates some £30 million of additional
income in the local economy, and up to £100 million nationally,
through the total visitor spending associated with the Park;
3. helps support some 200 local firms through
supplier spending;
4. provides 3,800 direct jobs on site (2,400
Full Time Equivalents), making it one of the largest private sector
employers in Staffordshire Moorlands District;
5. accounts for a total of 3,980 direct, indirect
and spin-off jobs in the local area, and 5,140 in the West Midlands
region;
6. supports the growth of the local tourism industry
and accommodation sector by creating a destination which raises
the profile of the area and encourages increased visitor spending,
and
7. provides a range of other local economic,
tourism and community benefits.
1.5 However, the Committee should also note
that the theme park sector is highly competitive and visitor numbers
at theme parks across Britain and Europe no longer show signs
of continued growth and, in certain circumstances, are actually
in decline. To ensure that tourist attractions retain their position
in the market and improve their reputation and standards, it is
necessary to improve the product continuously, to meet rising
expectations and standards. Such improvements often take the form
of new development.
1.6 For example, there is an increasingly strong
trend amongst European theme parks to supplement facilities through
the provision of theme parks hotels. From the early 1990s, with
the development of hotels at Disneyland (seven hotels), Efteling
(Netherlands, Europe's seventh most popular theme park with 3.2
million guests annually), Europa Park (Germany, fourth most popular
with 3.6 million guests), Liseberg Viking Hotel (Sweden, sixth
most popular with 3.2 million guests), Legoland (Denmark, 17th
most popular with 1.6 million guests), Alton Towers (10th most
popular with 2.5 million guests) and Parc Asterix (15th most popular
with 1.8 million guests), theme parks have begun to recognise
the importance of providing associated hotel accommodation for
the long-term economic benefit of the Park. In 2003 alone, over
2,000 rooms in seven hotels were added to Europe's top theme parks,
including Hotel Phantasia near Cologne; Tussauds' new water park
hotel Splash Landings at Alton Towers, three Disney Partner Hotels
and Blackpool Pleasure Beach's the Big Blue Hotel.
1.7 TTG has most recently secured planning permission
for a 150 bedroom hotel at its Chessington World of Adventures
(CWOA) theme park and a current planning application for a hotel
at Thorpe Park is being considered by Runnymede Borough Council.
This latter proposal is for a 250 bed hotel, which it should be
noted in relation to the penultimate issue raised by the Committee
of the practicality of promoting more environmentally friendly
forms of tourism, will deliver 14.5% of the annual energy use
of the hotel from renewable sources.
1.8 Given the importance of the tourism industry
at the macro and micro-levels, and in relation to the first and
fourth issues raised by the Committee, it is essential that Central
Government (in their policy advice, tax regime and local government
funding), as well as Government agencies, statutory bodies and
local planning authorities all strike a balance between: (i) the
objectives of conservation, protection and enhancement of the
environment; and (ii) the need for existing tourism facilities
to be enhanced, to allow them to respond positively to competition
and changing markets in the tourism sector. This balanced approach
would allow TTG's operations and the Group's development programmes
for upgrading and continuously improving its attractions to be
properly and fully taken into account, and implemented.
1.9 Existing tourism facilities, even those
in sensitive locations such as the flood risk areas within which
Thorpe Park and Warwick Castle are located, have to continue to
draw customers and TTG regularly reinvests in these and all the
other Group's facilities so as to maintain a product that meets
customers' expectations. TTG seeks to balance any environmental
issues arising from its development proposals with the economic
and operational issues resulting from the Group seeking to maintain
viable business operations that create employment and other wider-ranging,
associated benefits. It is not always clear to the Group however
that other stakeholders take the same approach, particularly in
terms of policy formulation at all levels of government and the
stance taken by various statutory and non-statutory bodies in
the process of determination of planning applications.
1.10 In the case of the TTG theme parks, the
primary function of each will continue to be that of a theme park.
However, with the majority of the visitors arriving in the main
tourist season (April to November), the Group is also looking
in the medium to longer term to establish the parks as year round
attractions. Although the activities will continue to be predominantly
"open air" and involve significant rides and structures,
a wider range of facilities has already been/will be proposed
and introduced to support a year round operation. While it is
often stated by local planning authorities in their development
plans and emerging Local Development Documents that they support
the development of a year round tourism industry, this is often
only in principle; the development that will be necessary for
operators of theme parks to provide to achieve this objective
is all too often not accepted by the authority at planning application
stage. In this context, there is no clear national policy guidance
on the subject, for LPAs to interpret and apply to their local
circumstances. In short, this is for the fundamental reason that
national policy guidance, previously set out in Planning Policy
Guidance (PPG) 21:Tourism, was cancelled in September 2006 and
it has only been replaced by a good practice guide (May, 2006).
1.11 We understand that it is still the case
that a new Planning Policy Statement (PPS) on Tourism is not to
be produced by Communities and Local Government; we consider that
this is unacceptable. Representations submitted at the time when
the proposed PPG21 cancellation was announced (made on behalf
of TTG by our planning advisors, Nathaniel Lichfield and Partners
to the then Office of Deputy Prime Minister) raised concerns that
the net effect of not replacing PPG 21 with a new PPS would be
that insufficient importance would be attached to the tourism
and entertainment industry, particularly in relation to facilities
in urban areas but also to those sited elsewhere. The comment
was made at the time that the consequence of there being no PPS
on tourism would be that the economic importance of tourism development
in such locations would be diminished. This is proving to be the
case, particularly in both development plan policy formulation
and in development control. Looking into the future, we continue
to believe that tourism will be perceived to be of lesser importance
than other uses subject of other PPGs or PPSs, and that there
will be no clear source of Government policy guiding and promoting
tourism uses when not in rural areas (PPS7 provides some guidance
on tourism in rural areas). These concerns are significant; we
consider that the economic and other planning, social and environmental
benefits of the tourism industry should be fully and widely acknowledged
at the national policy level in a new PPS.
1.12 We would therefore respectfully suggest
that in their recommendations, the Culture Media and Sports Committee
refer to the urgent need for new, clear national policy guidance
on tourism. This new PPS in particular should refer to the Government
recognising the economic, social and environmental benefits that
can arise from the tourism industry and proposals for its enhancement
eg through new development. The new PPS should also explain that
the Government encourages the expansion and enhancement of existing
tourist facilities, and that this encouragement should be interpreted,
promoted and applied by all of the other bodies involved at different
levels in policy formulation, development planning and development
control.
1.13 We trust that the Committee will find the
above information and responses to three of the issues raised
useful. We would also welcome the opportunity to appear before
the Committee, to answer any questions that members may wish to
pose as a result of this submission. Please also contact me, if
you wish to discuss any matter that we have raised further. In
any event, please note that we would now like to be kept informed
of each stage of the Inquiry's progress.
March 2007
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