The Association of Scotland’s Self-Caterers (ASSC) has written formally to both Highland Council and Scottish Ministers raising serious concerns regarding the cumulative impact of Scotland’s short-term let planning and licensing framework, whilst reiterating the sector’s commitment to constructive engagement and collaborative solutions.
The correspondence follows growing evidence of legal uncertainty, inconsistent interpretation across Scotland, and mounting concern regarding the disproportionate impact of the current regulatory regime on established self-catering businesses and rural tourism economies.
In its letter to Highland Council, the ASSC highlighted the Council’s own Freedom of Information response confirming that no measurable housing benefit has yet been demonstrated from the existing Badenoch and Strathspey Planning Control Area (PCA), with no identified causal link between the Control Area and improvements in housing affordability or availability.
The ASSC has therefore requested that Highland Council suspend further PCA expansion pending clarification on a number of significant legal and evidential concerns, including the interaction between Planning Control Areas, Mandatory Condition 13 within the licensing regime, and the increasingly restrictive interpretation of National Planning Framework 4 Policy 30(e).
At the same time, the ASSC has written to newly appointed Scottish Ministers congratulating them on their appointments and calling for urgent engagement on wider reform of Scotland’s short-term let licensing and planning framework.
The letter sets out concerns that the cumulative operation of licensing, planning controls and associated guidance is creating significant uncertainty for responsible operators, local authorities, lenders and investors alike. It also calls for consideration of a national short-term let Use Class Order as a more coherent, proportionate and legally sustainable long-term solution.
Fiona Campbell MBE, Chief Executive of the ASSC, said:
“The ASSC has consistently sought to engage constructively and pragmatically with both local and national government throughout this process. We fully recognise the importance of addressing housing challenges, but regulation must be lawful, proportionate, evidence-based and properly balanced against the enormous economic and social contribution made by Scotland’s self-catering sector.
“We are determined to exhaust every reasonable avenue for dialogue, clarification and collaborative reform before considering further action. The new Scottish Government deserves the opportunity to review the current framework carefully, assess the growing evidence and work with the sector toward more workable and sustainable solutions.
“However, we must also be clear that significant legal concerns remain regarding aspects of the current framework and its implementation. Where necessary, the ASSC and affected operators reserve all rights in relation to potential legal challenge.”
The ASSC stressed that it is not seeking conflict, but rather a reset toward a more evidence-led and proportionate approach that supports both housing objectives and Scotland’s wider tourism economy.
The letter pointed to the success of recent collaborative engagement on Visitor Levy reform as evidence that pragmatic dialogue between government and industry can deliver more balanced and effective outcomes for communities, businesses and visitors alike.
The ASSC now hopes the new Scottish Government will adopt a similarly constructive and solutions-focused approach as discussions continue in the coming weeks.