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Evidence Submission to the Local Government, Housing and Planning Committee – October 2024

The ASSC has submitted written evidence to the Local Government, Housing and Planning Committee on the Scottish Government’s Short-Term Let Implementation Update Report. The Committee’s focus on this report is timely and will enable a closer examination of what has been produced.

Unfortunately, there remain a number of outstanding challenges relating to the Scottish Government’s short-term let licensing scheme. These have been repeatedly expressed to Ministers and officials but sadly to no avail. The self-catering sector faces the same issues that we have highlighted to the Committee on previous occasions, including most recently in February 2024 and May 2024, which the Implementation Update Report and its next steps will do nothing to address.

Executive Summary

  1. Awareness of Licensing Regime Feedback: The ASSC (Association of Scotland’s Self-Caterers) is aware of the Scottish Government’s initiative to gather views on the short-term let (STL) licensing regime and has actively participated by submitting their opinions.
  2. Concerns Regarding Review of Licensing Regime: The review has not adequately addressed key concerns. The ASSC criticises the government for downplaying the issues faced by small business owners, especially the detrimental effects of complex licensing and planning requirements. The conflation of these two areas is a significant barrier, and legislative amendments are needed to clarify their separation. The ASSC emphasises that future reviews must focus on evidence-based outcomes, addressing impacts on affordable housing, safety, anti-social behaviour, small business viability, local economies, and the tourism sector.
  3. Proposed Changes to Licensing Regime: The ASSC appreciates engagement with the government but is sceptical about the effectiveness of new expert groups formed to address STL regulations. We stress the need for these groups to deliver actionable outcomes rather than just engage in discussions. The focus should be on tangible benefits that directly address industry challenges.
  4. Impact of the STL Licensing Scheme:
    • Visitor Numbers: The self-catering sector is crucial to Scottish tourism but guests face challenges due to rising accommodation costs and reduced availability caused by the licensing scheme. This has affected both domestic and international tourism.
    • Number of Short-Term Lets: Reliable data on the number of STLs is lacking. The government estimated 32,000 STLs, but a significant number may no longer be operational due to regulatory burdens. Recent data shows a decrease in self-catering units across Scotland, especially in urban areas.
    • Safety and Quality of Short-Term Lets: Professional operators were already regulated, but unlicensed rentals have proliferated, undermining regulatory efforts. Blanket bans in other cities have led to black markets.
    • Community Impact: Professional self-caterers contribute positively to local communities and do not hollow them out as often alleged. The reduction in licensed STLs has economic implications and may lead to increased competition for limited accommodation, driving prices up.

Read the submission:

 

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