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Response to the Cabinet Secretary for Rural Economy and Tourism

The following response has today been sent to the Cabinet Secretary for Rural Economy and Tourism, Fergus Ewing MSP:

Dear Cabinet Secretary,

Thank you for your email from last night. I have circulated this to our members for their information. In response to your comments, the ASSC want to remain key partners of the Scottish Government – a relationship based on trust, openness and cooperation – but the manner in which the changes to restrictions have been handled undermines our constructive engagement.

The self-catering industry is deeply concerned at the impact of the new changes and the means by which they were arrived at. We have set out the following timeline to illustrate the severe disruption and confusion the Scottish self-catering sector has endured over the past 48 hours:

22nd September 2020

  • In response to the First Minister’s statement to the Scottish Parliament outlining new rules to suppress Covid-19, the ASSC contacted the Scottish Government to seek clarity over the position of self-catering.
  • The ASSC received an assurance from Scottish Government officials via e-mail, following consultation with Scottish Government lawyers, that the ban on visiting other households indoors would not extend to self-catering accommodation.
  • After such a clear response, the ASSC duly informed its members who contacted us requesting detail about if the announcement would affect their business. Other key tourist stakeholders, such as the Scottish Tourism Alliance and VisitScotland, also distributed the message that self-catering accommodation would not be affected by the changes.

23rd September 2020

  • However, the National Clinical Director Professor Jason Leitch appeared on BBC Radio Scotland’s Mornings with Jackie Brambles programme and stated the following in response to a caller’s inquiry: “…you can’t have two households in self-catering so that would be like allowing them in your own home.” This contradicted the advice the ASSC received from the Scottish Government.
  • The ASSC then sought urgent clarification from the Scottish Government and spoke with the Director General at the Tourism Directorate. She confirmed that the regulations did not currently apply to self-catering and that the aforesaid Scottish Government legal advice was correct. The Director General also said it was not the policy intention for the new restrictions to capture self-catering.
  • After further correspondence, the ASSC received an email from you informing us that, following further consideration, the one household restriction would now apply to self-catering properties from Friday 25th

The ASSC are under no illusion that Covid-19 presents challenges to the Scottish Government on a daily basis and that restrictions may have to be introduced at relatively short notice, but we remain perplexed: what changed over the course of a few hours from the legal advice dispensed by Scottish Government, to the comments made by Professor Leitch the following morning on BBC Radio Scotland? Was the change in government policy attributable to the remarks made by the National Clinical Director?

Whatever the rationale behind the changed position, the new restrictions will have major financial implications for operators following an extremely difficult trading year – a year that most were reliant on business support grants for survival. Many travellers already cancelled bookings as a consequence of the rule of six. Economic modelling from SuperControl[1], the leading online booking and management system for holiday let businesses in Scotland, showed their clients have taken £1.1m of cancellations in the last 10 days. When this is extrapolated to the full market, the estimated loss is over £4m. In addition to the increased cancellations, the levels of new bookings have dropped substantially.

We would therefore expect a smaller proportion of these cancellations to be re-booked, especially for larger properties. SuperControl also estimated that around £70m of current bookings are for the last three months of the year. We cannot estimate what proportion of these will be lost as we do not know the number of households in each party and whether guests will now cancel due to the changes. Finally, this analysis does not consider the knock-on effects from the cancellation of self-catering bookings for the footfall that other businesses (i.e. pubs and restaurants) benefit from our guest spend.

Individual businesses are now in a state of upheaval dealing with traveller enquiries about the status of their bookings – that underlines the imperative of industry receiving clear and consistent advice from the Scottish Government. Our members have also received messages from guests expressing their dismay at what has occurred. Here is just one such example:

“From the elation we felt yesterday in hearing that we, being from 2 households, could come to Scotland and have our delayed and long awaited holiday, we now find ourselves deeply disappointed and astonished at the shambolic way the Scottish Government have dealt with this matter. We will now have to find somewhere here in England to have our holiday. We love our trips to Scotland and it is a shame we won’t be able to spend our money to the benefit of your tourist economy.”

While individual businesses will now incur even more financial hardship, the reputational damage to the tourism sector as a whole cannot be underestimated, and Scottish tourism will be disadvantaged compared to other parts of the UK. To help mitigate this, the ASSC believes that a financial support package to the industry must now be actively considered by the Scottish Government.

Throughout the Covid-19 pandemic, the ASSC and its members have consistently done the right thing: closing our businesses back in March 2020 in response to lockdown, offering up accommodation to key workers for free or at a reduced cost, producing robust government-backed cleaning protocols to assist with sectoral reopening in July, and then ensuring that the rule of six changes were implemented at short notice. Now the self-catering sector appears to be unfairly singled out from other related hospitality businesses while there remains no evidence of Covid-19 transmission within self-catering properties which are subject to rigorous cleaning procedures.

To compound the financial difficulties, our beleaguered sector will also face additional regulations with the introduction of a licensing scheme and planning control areas, at a time when other key pieces of legislation, such as the Transient Visitor Levy, have been postponed due to Covid-19.

The ASSC wholeheartedly supports Scottish Government’s efforts to protect public health, and in particular, we welcome your efforts to promote and maintain a constructive dialogue with industry during these challenging circumstances. The events of the past 48 hours have been incredibly disappointing and we hope that we can work with you and your officials to resolve them for the benefit of our members and Scotland’s vital tourist economy.

Yours sincerely,


Fiona Campbell

Chief Executive

Association of Scotland’s Self-Caterers


[1] SuperControl has 5,154 properties in Scotland.  Their data represents approximately 25% of the 19,500 properties in the market.


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