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Former ASSC Chairman Writes to First Minister About ‘National Embarrassment’ of STL Regs

David Smythe MBE, former Chairman of the Association of Scotland’s Self Caterers, and operator of a short-term let for over 34 years, has written to First Minister, Humza Yousaf MSP, outlining his concerns about the impending scheme.

First MinisterScottish GovernmentSt Andrew’s HouseRegent RoadEdinburgh EH1 3DG                                                                                         

27 September 2023

Dear First Minister, 

For 18 years I was delighted to be the elected Chair of the Association of Scotland’s Self-Caterers (ASSC), a role which encompassed representing and promoting our members, but which also involved shaping the wider tourism industry.  ASSC was a founder member of the Scottish Tourism Forum, now the Scottish Tourism Alliance, and ASSC also worked closely with VisitScotland, especially helping develop the Quality Assurance ‘star’ scheme over the years.  ASSC was involved in the development of the succession of national tourism strategies since devolution.  But we also looked beyond Scotland and the UK – ASSC is a founder member of the European Holiday Homes Association.  

At ASSC’s 40th birthday event in the Garden Lobby at the Scottish Parliament in 2018, we celebrated the success of our sector especially in the quality of accommodation now being offered.  However, I took the opportunity (as we were in the Parliament building) to warn those present that self-catering was under threat from a political lobby founded on unreliable data and evidence – we called it ‘fake news’ back then. It has grown arms and legs since. 

On the eve of Scotland’s new Short Term Let licensing scheme, I am dismayed and shocked that the Scottish Government is set to dismantle a key tourism sector with a stream of unintended consequences running in its wake.  It did not need to be like this:  all sides agreed that a tightening up of compliance with existing regulations was required and that we needed to be able to count up self-catering businesses reliably.  A simple registration scheme would have done both effectively at low cost, but this suggestion was ignored by the Scottish Government. It is a pity, because it would have allowed tourism to continue to flourish. Registration would have given an accurate data base from which to consider any Planning Control Areas in the future.

As things stand, we have 32 versions of STL licensing and a Planning Control Area in Edinburgh with others set to follow.   We have 32 different levels of fees for a similar licence, in many cases far more expensive than the Scottish Government expected.  Other sectors have been dragged into this:  many Bed and Breakfasts, house swaps, mountain huts (though bothies are excluded), people taking in lodgers, and possibly house/dog sitters.  We are seeing businesses closing because compliance with the scheme is too onerous – something ASSC and others warned the Scottish Government about.  Whichever way you look at it, STL Licensing is a mess. 

Edinburgh is facing enormous problems as businesses are effectively being forced to close due to retrospective planning precluding a licence application.  In the capital, short term lets are not just used by tourists, but by a whole raft of visitors coming to the city for business reasons – setting up events, attending medical courses and so on.  Hotel accommodation does not suit these visitor types who seeking a homely environment as a base for short-term work or relocating to the city or simply to visit as a family.  These visitors need their own washing machine, their own kitchen, and their own living space.  The STL licensing scheme is a huge threat to the city’s economy, not to mention all the festivals and events.  As accommodation becomes scarce, prices of all overnight stays in Edinburgh will rocket skywards as dynamic pricing models kick in.

As someone who has tried to steer tourism over many years, I find it unbelievable that the Scottish Government through sheer stubborn intransigence is effectively dismantling a sector which makes up a significant part of our economic activity.   This is not a step backwards, but a whole downwards escalator being set in motion.   It is painful to watch, and frankly, a national embarrassment for Scotland. 

 We really did not need to do it this way.

David Smythe MBE

Former Chairman of ASSC and self-caterer.

Fiona Campbell, Chief Executive at the Association of Scotland’ Self-Caterers, said:

“David Smythe is a stalwart of the tourism industry in Scotland, and awarded an MBE in recognition of his services to this vital sector. He has operated his self-catering business for over 34 years, providing memorable holidays for families from within Scotland and further afield for three and a half decades without issue. Despite this lifelong service to Scottish tourism, David has had to pay £1590 in order to comply with the new licensing rules to continue operating as he has done so for decades. As David points out, the onerous bureaucracy and high fees are why so many are leaving the sector and it didn’t need to be this way. It is critical that the Scottish Government listens to people like David, if their New Deal for Business is to be taken seriously. The Programme for Government committed to supporting small businesses – short term rental operators can see no evidence of this.”                            


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