The following letter was sent from a self-caterer and ASSC member on Arran to the Minister for Housing, Paul McLennan on 8th June 2023. They have not received a response.
“PLEASE don’t preside over the destruction of self catering in Scotland – rethink the damaging STL Licensing legislation before it is too late.
“I am a self catering proprietor and smallholder on the Isle of Arran. I have a farm with livestock and have spent much of my life savings refurbishing some of the farm cottages into high quality self catering units. I have two cottages remaining partially refurbished and currently unused, but such is the difficulty being caused to us by the raft of impending new regulations and lack of government support, that I am weighing carefully whether the investment will be worth it.
“I am aghast at the damage being caused to my business and our local island economy by the actions of our own Scottish Government. The twin Hydra of the Ferries Disaster, coupled with the impending tragedy of Short Term Let Licensing is proving catastrophic.
“A quick (and positive) word on ferries: thank goodness for the MV Alfred, a charter long overdue. An excellent and pragmatic solution, and a clear illustration of how good decision making can make a huge difference in communities that depend on ferry services. I sincerely hope that finally government has got the message that small, simple vessels such as modern catamarans are ideal for a run of under an hour. At a cost of under £20 million to buy, these ferries offer excellent value for money for the taxpayer in both purchase and running costs. The value of these lovely boats to hard pressed island communities is clear in the much needed reliability and resilience that they can bring us. I hope that government can rethink the large ferry procurement strategy to include similar vessels in future.
“As for other government decisions that are impacting our island community:
“STL Licensing is simply the wrong policy at the wrong time. I have no issue with regulation based around health and safety for guests, which I regard as absolutely paramount in my own business, and I welcome the prospect of a level playing field for all operators. However, the dog’s breakfast of the STL Licensing regulations that we have been served in the name of health and safety for self catering is an anti-business burach.
“Every day I am hearing of Scottish holiday accommodation businesses, some long established, many still in post covid recovery mode, that are giving up in the face of an increasingly hostile business and legislative environment.
“For example, in my own small corner of Arran, there are around 50 houses. Many of those are let out as short term lets, and have been for many decades, some for over a century. Tourism has been a vital component of our island economy for well over 100 years. I know of at least three large houses in this small area that have been routinely let out to visitors for many years that have already closed to visitors, or will be closing to new bookings from 1st October 2023, the date by which a STL Licensing application must be made.
“STL Licensing has been blamed for the owners deciding to shut up shop. One house will be used as a second home for the owners, so will lie mostly empty. The other two have been sold, one to a couple from the south of England and the other to a family relocating to the island from the north of England. While these folks are of course welcome, the sale of these houses did nothing to resolve local housing shortages. As permanent residents, the new owners’ pattern of local spending is likely to be very different from groups of visitors staying a week at a time.
“When let for holidays, these three houses each slept up to 8 people, and were let for at least 26 weeks per year. At maximum capacity, that equates to 624 visitors to our island. The loss of these visitors is also the tremendous loss of the considerable amount of cash that these visitors would pour into our island economy.
“Even before the visitors arrive there are the local cleaners, gardeners, maintenance staff, the local florist for flowers, the local food producers for welcome packs – all of these people will lose business and income.
“During their trip, the patronage of our island cafes, bars, restaurants, shops and attractions by these visitors will be lost. From experience, I estimate that holiday let guests spend at least £500 – £1000 per week per couple on the island. Even a modest meal out for two won’t give much change from £60 on Arran, so the cash contribution to our local businesses easily adds up over a week long stay. Multiply that up and the loss of 24 people per week could equate to as much as £6000 – £12000 every week lost to our island businesses. It’s happening throughout the island, I have never seen so many houses for sale here, and will be replicated across Scotland at great cost to our local and national economy.
“I fear for our local businesses, many of them already on their knees due to rocketing cost increases and the post covid hangover. If the tourists stop coming because they can’t find somewhere to stay, the income for these island businesses will take a further hammering.
“I am fully booked for the rest of the summer, and could have sold some weeks several times over this year. That is a fine challenge to have, but not one that can be taken for granted. If the very things that people come to this island for (the nice hospitality businesses, the charming wee shops or exciting tourist attractions) are forced out of business because people can’t come, either due to the ferry having been cancelled, or because the self catering cottage they would have booked is no longer operating, then the entire island economy risks collapse.
“I urge you to rethink the STL Licensing scheme before it is too late. There are so many shortcomings in this legislation that it is simply unworkable in its current form. That is clear from the very small numbers of applications that have been made to councils so far. While North Ayrshire has adopted a more pragmatic approach than some councils, their policy still extends to 68 pages, with an 18 page form to complete. There is also a requirement to send 6 hard copies of layout plans. Where is that set out in the legislation as a requirement? I would rather be spending my management time on developing my business than reading through screeds of documents, and filling out endless forms, and paying fees simply to ensure I can continue operating exactly as I have been!
“There is no serious empirical evidence base for this legislation and the risk of destruction of a vital part of Scotland’s tourism offering is very clear. Many proprietors will simply give up, as it’s too onerous and too expensive to comply, and I reiterate, I am hearing of more examples every day in many parts of rural and urban Scotland.
“Regulating this industry could have been very straightforward – simply by using the existing registration scheme for long term let landlords and applying that appropriately to short term lets. It would have been cheaper, less onerous and would have provided an evidence base of the size and extent of the sector. It is not too late for government to properly revisit that option.
“What may prove to be the first of many Judicial Review challenges has been lost with the announcement today that Edinburgh Council’s STL Licensing policy is unlawful. Scottish Tourism
leaders are imploring the government to create the conditions in which our industry can thrive, this week Marc Crothall of the Scottish Tourism Alliance has told you very clearly
““This is entirely the wrong time for the Scottish Government to be piloting policies that will do limited good and risk maximum harm.”
“The STL regulations in their current form are ill conceived and are being poorly implemented by very hard pressed and cash strapped local authorities who are struggling with the complexity and volume of work being forced upon them, with the reviewed government guidance still unavailable nearly a month after it was promised.
“At the very least, please extend the deadline for applying for a licence and allow self caterers to continue to take bookings without risk of them being criminalised simply for doing what they have been without incident for years. Take heed of the sound advice you are continuing to receive from eminent industry experts such as the Association of Scotland’s Self Caterers.
“I love being a self catering proprietor, it is wonderful to see people arrive tired and stressed and watch them visibly relax and unwind during their holiday in a beautiful, tranquil place. Our guests appreciate what our business offers and regularly give five star feedback. Self Catering represents the majority of my income. Please value me and my business as much as I value my customers.
“I don’t want my business, or Arran’s island economy, or Scotland’s tourism industry, to fail due to my own Scottish Government’s intransigence.
“The First Minister recently promised a “reset” with Scottish Business. Prove your mettle.
“Your government has finally listened to communities and is starting to get it right on ferries with the charter of the MV Alfred.
“You have belatedly listened to industry and paused the Deposit Return Scheme.
“PLEASE will you also listen to Scottish Tourism? Pause this almighty mess that is STL Licensing and rethink before it is too late and we have all gone.”