The Association of Scotland’s Self-Caterers (ASSC) has written to Highland Council Councillors regarding the proposed expansion of Short-Term Let Control Areas in the Highland region.
Dear Councillor,
I write following the recent meeting of the Badenoch and Strathspey Area Committee to express serious concerns regarding any suggestion that the Council should consider the further rollout of Short-Term Let Control Areas (STLCAs) at this stage.
Having reviewed both the committee papers and the recorded discussion, it is clear that the current evidence base is incomplete, inconclusive, and insufficient to support any policy expansion. The report itself explicitly acknowledges that meaningful analysis of housing market impacts will not be possible until at least 2030, with only a limited interim update expected in 2028. During the committee discussion, there was repeated reference to “potential” impacts and the need to assess outcomes over a “longer time period”, which further underlines the uncertainty.
In that context, I would strongly urge councillors to question the rationale for extending a policy whose effectiveness cannot yet be properly evaluated.
While some members welcomed the report, it was notable and encouraging that Cllr John Bruce raised the important question of what action is being taken to address empty homes. This is a critical point. Evidence shows that the number of empty homes in the ward has increased since designation of the Control Area, suggesting that wider structural issues are driving housing pressures. These are issues that the STLCA policy does not address. I would strongly welcome further clarity from the Council on what targeted interventions are being pursued in relation to empty homes, as this is likely to yield far more meaningful outcomes for local housing supply.
The report invites members to note early indications that the STLCA may have slowed the growth of secondary letting. However, this is presented in isolation, without any robust assessment of whether such changes have translated into improved housing availability or affordability for local communities. Critically, the report concedes that key datasets required to make this determination are not yet available.
This concern is reinforced by findings from a recent Freedom of Information request submitted by the Association of Scotland’s Self-Caterers, published here:
https://www.assc.co.uk/industry-news/highland-foi-reveals-no-measurable-housing-impact-from-short-term-let-control-area
The Council’s response confirmed that:
Taken together, this raises fundamental questions about the evidential basis for continuing, let alone expanding, the use of Control Areas. The current approach risks relying on partial or selectively interpreted data rather than a rigorous, holistic understanding of housing dynamics.
At the same time, it is important to maintain balance. As acknowledged by the Committee Convener, short-term let capacity plays an important role in the local economy and visitor infrastructure. Self-catering alone contributes approximately £200 million to the Highland economy, supporting jobs, local supply chains, and rural sustainability. Any policy intervention must therefore carefully weigh housing objectives against the very real economic contribution of the sector.
Given that the Council itself anticipates that a “more comprehensive understanding” will only emerge over the next four years, it would be both reasonable and proportionate to pause any further designations until that evidence is available. I would welcome the cautious approach implied by calls to wait for stronger data, and would encourage the Council to formalise this position.
In policy terms, proceeding without such evidence risks not only ineffective intervention but also unintended economic consequences for rural and tourism-dependent communities.
I would therefore respectfully recommend that councillors:
A measured, evidence-based approach is essential to ensure that policy interventions genuinely address the root causes of housing challenges while safeguarding the economic contribution of the self-catering sector.
Background:
The Badenoch and Strathspey Area Committee on Highland Council met on Monday 27th April. Amongst other items on their agenda, they discussed the post year two review of the STL Control Area in that ward and councillors were invited to:
i. note the evidence presented regarding the local housing market within Badenoch and Strathspey in the period pre-designation and post-designation of the STLCA;
ii. note the early signs that the STLCA has slowed down the growth of secondary letting short term lets within Badenoch and Strathspey in the period post-designation;
iii. note that limited data is available covering the period post-designation, but once available will provide a stronger basis to assess how the local housing market is performing, and the role of the STLCA within this; and
iv. agree that future monitoring reports will be made to the Badenoch and Strathspey Area Committee, as set out at paragraph 10.4.
The meeting papers for this item can be found here: https://www.highland.gov.uk/download/meetings/id/86764/4.%2520Post%25202%2520Year%2520Review%2520of%2520the%2520Ward%252020%2520Badenoch%2520and%2520Strathspey%2520Short%2520Term%2520Let%2520Control%2520Area
Paragraph 10.4 states the following:
“It will be important to continue to monitor and review Short Term Let provision over the coming years to understand trends. It is only possible to do this effectively in tandem with the Housing Need and Demand Assessment process and associated housing market analysis. Accordingly, the next full update will not be available for a further 4 years, in 2030. [my emphasis] It is proposed an interim update report will be presented to the Area Committee in 2028, noting the restrictions on the information that will be available at that time.”
Recorded coverage of the Area Committee starts at approx 9mins 30 seconds here: https://www.youtube.com/watch?v=rECgDYr3wVU.
Fiona Campbell MBE, Chief Executive of the Association of Scotland’s Self-Caterers, said:
“We have significant concerns about the limitations of this analysis as there is no rigorous assessment of whether the short-term let control area actually improves housing availability or affordability in practice. As this remains incomplete, policymakers should be cautious about drawing any firm conclusions from it.
A recent ASSC FOI request to Highland Council confirmed that the policy has no comprehensive impact assessment, no defined success metrics, and no review of effectiveness since it was introduced. Key housing indicators remain either unassessed or inconclusive, and the Council has not undertaken any analysis of affordable housing supply.
Moreover, the number of empty homes in the ward has actually increased. This points to other drivers of housing pressure that this policy does absolutely nothing to tackle. Before any further control areas are designated, we call on Highland Council to undertake a proper holistic review of the control area rather than cherry-picking evidence.”