External Affairs / Policy / Consultations Consultations
Adventure activities licensing regulations
4th March 2004
RESPONSE BY INSTITUTE FOR OUTDOOR LEARNING TO CONSULTATION ON CHANGES TO ADVENTURE ACTIVITIES LICENSING REGULATIONS
I refer to the above response on behalf of the
Institute for Outdoor Learning where we welcome the opportunity
to respond to the Department's proposals in respect of the Adventure
Activities Licensing Regulations, 2004.
The Institute for Outdoor Learning is the membership organisation
for outdoor learning in the UK. It represents over 800 individuals
and organisations, including outdoor and environmental centres,
local authority outdoor education advisors together with employees
and volunteers who work in the Outdoors.
The Institute was formed in 2001 through the merger of the Association
for Outdoor Learning, the Development Training Advisory Group and
the regional councils for outdoor education and training.
1 Local Authority: A technicality on your definitions of a local
authority where you should also include the newly formed 'Unitary
Authorities' otherwise city local authorities such as Plymouth,
Southampton and Portsmouth would be excluded.
2 Canyoning: We welcome the inclusion of an activity that can involve
injuries and whilst the definition is probably correct, we believe
that the title may mislead. We suggest 'Gorge Walking and Coasteering'
or if it has to be Canyoning then 'Canyoning and Gorge Walking'.
3 Responsibility: You will have to decide which body should lay
down the guidelines for good practice and training. It would appear
that the BMC and the MLT are the appropriate ones for this task
unless they believe that their present training and examinations
are sufficient for this purpose. Either way, time will be required
for these decisions to be made and implemented with consultations
with these bodies.
4 Fee Structure: Whilst accepting that there has been no increase
in fees to allow for inflation, the proposed changes of what, in
effect, will be a licence charge of £620 a year for some small providers
is unacceptable. Even if such small providers are fortunate to have
a two or three year licence it is still an increase of between 20%
and 35% and we would hope that your Minister would follow the example
of his ministerial colleague and 'cap at 5%'! Otherwise these small
businesses will be put at a commercial disadvantage.
5 Cost Effectiveness: We have compared the AALA fees with those
of other governing bodies. These are less than a third of the former's
cost and involve inspections that can be just as long and rigorous
with presumably similar administrative structures. We can only consider
that the reason is that AALA Inspectors either have very generous
conditions or are not fully employed throughout the year. It is
noted that you intend to tackle this, but an inspection a year ahead
for a Provider who is on a yearly inspection anyway seems illogical.
We would ask that you consider some 'Economies of Scale' that might
even result in a reduced fee!
6 The Inspectorate: In case of any misunderstanding we would also
point out that the Head of Inspection Services and his staff are
professional, helpful and a credit to the industry.
7 Appeals: Agreed and you may wish to consider using the expertise
of AAIAC within the appeals process.
8 Reporting: We agree that it should report to DfES, not only as
its paymaster, but with the demise by HSE of AAIAC, as the major
link between the customer (schools and children) and the Providers.
9 Non-Mandatory Scheme: We welcome the Department considering the
replacement of the licensing regime by a non-mandatory scheme. The
Institute for Outdoor Learning is probably the only organisation
that represents everybody across the industry, whether involved
on land, water or field studies. Our members include providers that
are local authority, charitable and commercial centres and include
management and staff.
We would consider playing a major role in developing such a scheme
but it would have to be in conjunction and with the consensus with
other Outdoor organisations. Obviously with proper safeguards to
protect the integrity of such a proposal. However, unlike many Governing
Bodies and other organisations we depend for our existence upon
the subscriptions of our members, gifts and sales of books. We do
not have a paid Executive and receive no government grant.
We would need resources to participate in such a scheme which we
are sure would be most successful and be on a par with other self-regulating
schemes of other professional bodies and institutes.
Yours sincerely
Allan Myatt
Chair Institute for Outdoor Learning
nb
Please note that this response is being dealt with by Brian Lamb,
to whom communications should be addressed.
Greystone Cottage, Bere Ferrers, Devon, PL20 7JX
01822 841309
Briankay1@talk21.com