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Postponement of Regulations Sought

A letter was circulated to the Scottish Government from 38 leading business and tourism stakeholders in Scotland, including CBI Scotland, Scottish Chamber of Commerce, SCDI, UK Hospitality, FSB Scotland, and the STA on 26th October, underlining our concerns and calling for a postponement of the regulations.

During a call with the First Minister last week (11th November), Fiona Campbell, ASSC’s CEO, made the following points:

Concerns with Short-Term Let Consultation

  • The ASSC is extremely concerned at the speed and manner in which the short-term let consultation has been conducted given the changed context since the proposals were first unveiled earlier this year. Covid-19 has resulted in an extremely perilous set of circumstances for tourism – yet the consultation made no reference to the pandemic.
  • The truncated timeline for the consultation, coupled with the lack of a partial Business Regulatory Impact Assessment, which goes against governmental best practice, has heightened our fears about the entire process.
  • Our question is, are the proposals proportionate, and are they targeted?

Economic impact

  • Concerns over the short-term let consultation are not limited to those working in the self-catering/short-term rental industry.
  • The industry-wide letter was a recognition of the fact that self-catering is a crucial component part of Scotland’s tourism industry (and its recovery), generating approximately £723m per annum to the Scottish economy alone – and one which boosts related industries like hospitality through the economic footfall of our guests.
  • The introduction of short-term let regulations comes at a time when many self-catering businesses are facing financial devastation as a consequence of the ratcheting up of restrictions:
    • Our sector can expect to lose as much as £70m in the last three months of 2020 due to cancelled bookings.
    • In a recent ASSC survey, 94% of respondents have stated a negative financial impact of Covid-19 to their business.
  • Without a BRIA, we can’t tell what the negative impact may be. Given the uncertainties just now due to the pandemic, this further uncertainty is rendering the sector untenable. People are fighting for their livelihoods.

Request for Delay

  • Given the huge local and economic impact, and the challenging Covid-19 environment, it is only fair that any regulation must be properly considered and scrutinised. We would therefore respectfully recommend that the Scottish Government should pause their work on the regulations – mirroring the welcome approach taken with the Transient Visitor Levy – so that the industry has time to recover from the devastating consequences of Covid-19.
  • Such an approach would also enable a greater discussion of the consequences of the regulation and ensure that we arrive at a balanced solution that can benefit business and communities.
  • To emphasise, the ASSC are not anti-regulation – we have put forward a series of evidence-based alternatives that could meet your policy objectives in a more cost-effective and proportionate manner – and we remain absolutely committed to working with your government to ensure a positive outcome for Scottish tourism.

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