According to CEC, the data relied upon to determine the establishment of the PCA was from ‘Inside Airbnb’ and the number of entire properties listed in Edinburgh was 7,970, with 4,439 being available for more than 90 days as at March 2020 in their ‘Background Report’.
There are questions around the criteria used by CEC in this analysis. It is unclear, for example, if the analysis considered removing inactive or unavailable listings when coming up with the figure of 4,439. If not, this would have resulted in an overestimation. There also appears to be an inconsistency within the report, with a figure of 3,533 also provided for +90 days in other aspects of the report for April 2020, only one month after the figure of 4,439. The Table provided at Figure 2 in CEC’s Statement of Reasons Background Report appears to then show under 2000 entire properties in 2021. It is worth noting that ‘Inside Airbnb’ is a “mission driven project that provides data and advocacy about Airbnb’s impact on residential communities.” Therefore, placing reliance on such data without independent verification of the accuracy or methodology used to prepare this data is concerning.
Recent equivalent data from Inside Airbnb in May 2023 shows a significant decrease in these figures, with only 2,635 listings showing under the filter for ‘recent and frequently booked’, thus excluding inactive and duplicate listings. This implies a reduction of over 41% in Edinburgh’s listings since 2020.
The ASSC questions why a 90+ days criteria was applied, as this doesn’t align with any business threshold. However, it is noteworthy that Inside Airbnb does provide data on occupancy levels over the past year: based on a conservative occupancy rate of 57% or higher, the data shows only 1,178 ‘entire properties’ meet this criterion, significantly lower than the 4,439 figure used as a basis for the control area.
It should be noted that according to the Scottish Assessors Association, there are 1,353 Self-Catering Units on Non-Domestic Rates in Edinburgh (21st May 2023).
The City of Edinburgh Council (CEC) has made it clear in their background paper that “the designation of a short-term let control area does not equate to a blanket ban on such uses: each case will be assessed individually based on its own merits.”
However, there’s been a noticeable decline in the granting of planning permissions in Edinburgh recently, with not one planning permission being grated since the introduction of NPF4 in February 2023. Coupled with the absence of a clearly defined target from the City of Edinburgh Council, it raises uncertainty about what the council would deem a ‘reasonable’ number of short-term lets for Edinburgh.
The CEC background report also contains a table of report of enforcement cases raised, being 511 cases over a 5-year period (2016-2021). However, no context is provided against this number in terms of the relative nature of enforcement cases, context of materiality and the number of enforcement actions taken. At an average of 100 enforcement cases per annum, presumably due to neighbour complaints, this number would appear to be relatively low compared to the volumes of short term lets cited by CEC in their Background report.
Footnotes:
[1] https://consultationhub.edinburgh.gov.uk/sfc/short-term-let-consultation/supporting_documents/Statement%20of%20Reasons.pdf
[2] https://consultationhub.edinburgh.gov.uk/sfc/short-term-let-consultation/supporting_documents/Statement of Reasons Background Report.pdf
[3] https://www.saa.gov.uk/search/?SEARCHED=1&ST=advanced&SEARCH_TABLE=valuation_roll_cpsplit&TYPE_FLAG=C&STREET=&TPTLA=Edinburgh&POSTCODE=&ASSESSOR_ID=&CLASS=&CORE=SELF+CATERING&CORE2=Self+catering&FEFFECTIVE_DATE=&TEFFECTIVE_DATE=&MIN_RV=&MAX_RV=&searchtype