The Association of Scotland’s Self-Caterers (ASSC) has submitted a detailed briefing to elected members of Perth & Kinross Council ahead of the Council meeting on 17 June, where councillors will consider proposals relating to a Visitor Levy and a Short-Term Let Planning Control Area.
While recognising the Council’s right to consider both measures, the ASSC is urging Members to focus on a fundamental question:
Will these proposals meaningfully address the problems they are intended to solve, and how will success be measured?
The briefing highlights the importance of ensuring that any intervention is evidence-led, proportionate, legally robust and capable of delivering measurable outcomes.
Perth and Kinross Council’s papers estimate that a Visitor Levy could generate between £6 million and £10 million annually. However, the ASSC notes that significantly less information has been presented regarding potential impacts on visitor demand, business turnover, employment, visitor expenditure and the wider visitor economy.
The briefing also questions whether the Council’s modelling fully reflects actual visitor behaviour and occupancy patterns.
Recent Key Data market intelligence indicates that paid occupancy across Scotland’s self-catering sector is approximately 42%, meaning properties are occupied by paying guests for an average of around 153 nights per year rather than the theoretical maximum of 365 nights.
ASSC Chief Executive Fiona Campbell MBE said:
“The question is not whether a Visitor Levy can generate revenue. It clearly can. The question is whether the net economic impact will be positive and whether the evidence demonstrates that the benefits outweigh any impacts on visitors, businesses, employment and local communities.”
The ASSC has also questioned whether accommodation providers should be expected to fund infrastructure that may primarily benefit visitors who do not contribute to the levy, such as motorhome users, campervan users and day visitors.
The Council’s report identifies approximately 1,767 secondary short-term lets across Perth and Kinross. According to National Records of Scotland data, this represents just 2.3% of the area’s housing stock.
The ASSC briefing highlights that the Council’s report does not identify:
The briefing also notes that Planning Control Areas cannot directly address empty homes, second homes, housing waiting lists or housing affordability, and asks what measurable housing outcomes are anticipated if the proposal is approved.
The ASSC further highlights legal considerations arising from recent Court of Session judgments, including Muirhead and Averbuch.
The briefing asks how the Council intends to treat existing licenced operators who do not hold planning permission or a Certificate of Lawfulness and whether designation could create retrospective costs and consideration without delivering any corresponding housing benefit.
According to the ASSC, the key issue is not whether a Planning Control Area can be designated, but whether it will operate in a manner that is fair, proportionate and capable of delivering measurable outcomes.
The ASSC emphasises that it is not suggesting Perth & Kinross Council should do nothing.
Instead, the organisation is encouraging councillors to ensure that any intervention is based on clear evidence and a robust understanding of likely outcomes.
“These decisions should not be determined by assumption, perception or political preference alone. They should be determined by the evidence available and by the likely impact on the people and communities Members represent.”
“That includes residents seeking access to housing, but also local businesses, employees, tourism operators, supply chains and the many families whose livelihoods depend upon a successful visitor economy.”
The briefing concludes by encouraging Members to ask a simple question before taking either decision:
What evidence demonstrates that these proposals will help achieve the Council’s vision, by how much, and how will the Council know if they have succeeded?