ASSC Responds to Urban Big Data Centre: How has licensing affected short-term lets in Scotland?

With reference to the recent Urban Big Data Centre article (UBDC article), the ASSC and others have significant concerns about the research underpinning it.

Agree:

• Licensing likely to have pushed on costs to consumers.
• Standardisation of terms of categories re status of applications across councils would be helpful.

Disagree:

• Research is limited to one accommodation platform, Airbnb, and is just ‘web scrapings’.
• Research is restricted to two Scottish cities, Edinburgh and Glasgow, and is not Scotland wide.
• “We see no sign of the collapse in supply predicted by some in the sector” / “…more active, professional landlords see no barrier to continuing” – a multitude of data contradicts those assertions.
• Tourism industry did not predict an 80% drop in STL listings in Edinburgh. This figure is from a report on the introduction of the Visitor Levy by City of Edinburgh Council.

Other points:

• Why was this commissioned and who is driving it? UBDC note they have been “monitoring” Airbnb for some time. For instance, see: https://www.ubdc.ac.uk/research-theme/housing-and-neighbourhoods/monitoring-and-analysing-short-term-let-activities
• The research from July 2024, which has been picked up by The Times Scotland, builds on an earlier articlefrom October 2023.
• Five researchers worked on this piece, including one professor, three doctors and one data scientist. One of the team, Dr Yang Wang, has research interests in “[t]he impact of the sharing economy, Airbnb, to the city’s neighbourhoods.”
• No specific source of funding for this piece has been listed.
• Near the beginning, researchers reference an ASSC survey from October 2023 and cite two pieces of media coverage from the Herald and STV News.
• The ‘data’ from Airbnb focuses on entire home listings, ignoring rooms in shared accommodation.
• Would that mean due to the filters that would be applied on the website, this would only include individual properties and exclude hotels/aparthotels etc? Does it assess suspended listings / multiple listings / caravans in trees etc?

By way of some very simple empirical data that has been unilaterally ignored:

Self-Catering Units (SCUs) on Non-Domestic Rates (NDR)

*This only accounts for self-catering businesses on NDR. It does not account for B&Bs, guest houses or ‘unconventional accommodation’ (glamping etc)

In addition, the ASSC membership has reduced by over 5% since October 2023 (from over 1,700). Similarly, the Scottish Bed & Breakfast membership has also reduced by 5%. We are contacted daily by people telling us that they have  either given up, or have had their businesses closed down by local authorities due to retrospectively applied planning considerations.

“This article shows a lack of adequate research, due diligence, empathy and concern for a vital component of Scotland’s visitor economy.

The Scottish Tourism Alliance (STA) noted in evidence provided to the Local Government, Housing and Planning Committee that: “Meeting visitor expectation and delivering a world-class experience encourages our visitors to stay longer throughout the year, see more of Scotland and spend more during their visit. This is all key to achieving the ambition of our national tourism strategy, Scotland Outlook 2030, to be the world leader in 21st century tourism.

Concerningly, since STLs regulations came into power in October last year, the STA continues to hear from across different parts of the tourism and hospitality sector that there is increasingly a knock-on impact on the wider visitor economy – with a noticeable shift in the availability and different types of accommodation on offer, and a significant rise in overnight stay prices” (see in the links below).

The Scottish Independent Tour Operators Association (SITOA) states that: “From a SITOA perspective STL has been an absolute disaster. The two most notable effects it has had on our sector are as follows:
1) guide accommodation. Whilst our guests are typically staying in the 5 star places, tour guides are staying in guest houses and b&bs. The effect of the legislation has both removed a lot of bed stock, especially in the highlands but has also meant that the cost of those accommodations has skyrocketed. In my own company we are regularly paying £250 per night for fairly bog-standard accommodation, whereas before the average cost was around £100-£150.

2) pressure on other accommodation providers. General availability of accommodation, especially in the hot spots is a nightmare as evermore tourists compete for less availability. Planning 4-6 months in advance is now commonplace and the costs have also increased due to dynamic pricing and providers taking advantage of the market pressure.

Other financial pressures in our sector coupled with the availability of good accommodation for guests and guides is making this an increasingly difficult business model to operate. I am hearing grumbles from many quarters, including younger members of SITOA, about the sustainability of our income, especially given the seasonality of international visitors.

The Scottish government needs to urgently reconsider this legislation as not only has the well publicised issues taken a huge toll on the industry, the knock on effect for sectors like ours is beginning to bite.

My concern is also that the self-harm Scotland is doing to itself is beginning to be noticed by international visitors. Notably North Americans are now questioning pricing, despite the exchange rate actually being in their favour.

The long-term ramifications of this will only be felt in years to come. We need to stop this now.”