The Association of Scotland’s Self-Caterers (ASSC) has submitted a detailed briefing to Members of Argyll and Bute Council’s Economy and Infrastructure Committee ahead of consideration of proposals relating to a potential Planning Control Area (PCA) and the introduction of a Visitor Levy.
The briefing calls on councillors to carefully assess the evidence, proportionality and likely outcomes of both proposals before reaching a decision.
While recognising the very real housing challenges facing communities across Argyll and Bute, the ASSC argues that the existence of a housing challenge does not automatically demonstrate that self-catering accommodation businesses are the principal cause of that challenge, nor that a Planning Control Area will deliver the housing outcomes being sought.
Similarly, while acknowledging the Council’s desire to secure additional funding for visitor infrastructure and services, the ASSC has questioned whether now is the right time to progress a Visitor Levy before revised national guidance has been published and before any Scottish local authority has demonstrated the long-term economic impacts of implementation.
The briefing highlights the importance of Argyll and Bute’s visitor economy, which supports businesses, employment and community sustainability across mainland, rural and island communities.
Independent analysis estimates that self-catering accommodation alone contributes approximately £33.5 million annually in Gross Value Added (GVA) and supports around 1,136 jobs across the local authority area.
A central theme of the ASSC briefing is the lack of evidence demonstrating that existing Planning Control Areas elsewhere in Scotland have delivered measurable housing benefits.
Through Freedom of Information requests and engagement with local authorities, the ASSC has sought evidence that Planning Control Areas have increased housing supply, improved affordability or delivered measurable housing outcomes.
The briefing notes that limited evidence has been identified to date and asks whether Argyll and Bute should proceed with a further Planning Control Area designation in the absence of clear evidence that existing schemes have achieved their stated objectives.
The briefing also raises concerns regarding the interaction between Planning Control Areas, licensing requirements and planning law, noting ongoing legal uncertainty surrounding aspects of the current regulatory framework.
The ASSC welcomes the Council’s move towards a fixed-rate Visitor Levy model, recognising that fixed-rate charging can offer greater simplicity and transparency than percentage-based approaches.
However, the briefing questions whether sufficient evidence has been presented regarding the wider economic impacts of the levy.
In particular, the ASSC highlights previous modelling undertaken for Argyll and Bute which suggested that a levy generating approximately £9 million in revenue could be associated with costs to businesses of approximately £48 million and a reduction in economic activity equivalent to around £72 million in GVA.
The briefing also raises concerns regarding administrative burdens, compliance costs and potential VAT implications for small and micro-businesses operating close to VAT registration thresholds.
While the Planning Control Area and Visitor Levy are presented as separate agenda items, the ASSC argues that businesses and visitors will experience them cumulatively.
The briefing asks councillors to consider the combined impact of licensing, planning controls, potential Planning Control Areas, Non-Domestic Rates reform, rising employment costs, inflationary pressures and potential Visitor Levy requirements.
The ASSC argues that these cumulative impacts are particularly important in a local authority area where tourism remains one of the economy’s foundational sectors.
“These are significant decisions which could have long-term implications for businesses, communities and the wider visitor economy across Argyll and Bute.
“The ASSC fully recognises the housing challenges facing many communities and understands the Council’s desire to invest in visitor infrastructure and services. However, good intentions are not evidence.
“Before introducing additional planning restrictions and new visitor taxes, councillors are entitled to ask some fundamental questions. Where is the evidence that Planning Control Areas have delivered measurable housing benefits elsewhere in Scotland? Has the full economic impact of a Visitor Levy been properly assessed? And have the cumulative impacts on businesses and communities been fully understood?
“Argyll and Bute’s visitor economy is one of the area’s greatest strengths. Before taking decisions that may affect that success, we believe Members should be satisfied that the anticipated benefits are real, measurable and supported by robust evidence.”
The ASSC briefing has been circulated to all Argyll and Bute Council Councillors and Members of the Economy and Infrastructure Committee in advance of the meeting.