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City of Edinburgh Council Short-Term Let Licensing Consultation October 2024 – Submission from the ASSC

The ASSC has submitted a response to City of Edinburgh Council’s consultation on its licensing policy for short-term lets.

Overall, the ASSC asserts that the Council’s short-term lets policy – where licensing and planning is conflated – has resulted in the following:

  1. Legal Failures:
    • The Council’s licensing policy has been deemed unlawful twice by the Court of Session, resulting in costly requirements for STL operators.
    • Recent rulings also found the Council’s planning policy and the suspension of license considerations to be illegal.
  2. Data Concerns:
    • There are fewer than 2,000 secondary let applications, despite initial estimates of 12,000.
    • The housing crisis remains unresolved, with 9,275 empty homes in Edinburgh.
  3. Economic and Social Impact:
    • The STL regulations have led to a 22% drop in self-catering units on Non-Domestic Rates harming businesses that support tourism and other sectors.
    • Many operators, particularly women and older individuals, have been forced to close their businesses, impacting local economies.
    • The black market for STLs is growing, further undermining the licensing purpose.
  4. Policy Failure:
    • The STL regulations have not improved health and safety, reduced anti-social behaviour, or alleviated housing issues. Instead, they have imposed significant burdens on professional operators and led to ongoing legal challenges.
    • Mental health impacts on operators have been severe, with businesses facing existential threats.
  5. Recommendations and Questions:
    • The policy guidance is outdated and needs to be revised, especially regarding home swapping, licence transfers, and the outcomes of recent legal challenges.
    • The regulatory burden should be minimised and made proportional, balancing community and tourism needs.
    • This submission questions the Council’s economic development strategy and whether these policies have delivered their intended results.

In summary, the STL regulations in Edinburgh have not met their policy goals, causing economic harm and fostering legal disputes, while failing to address the underlying housing and safety issues.

Read the full submission:

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