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20/01/2020

Joint letter to the Housing Minister Kevin Stewart MSP

The Association of Scotland’s Self-Caterers and Short-Term Accommodation Association have issued a letter to the Housing Minister Kevin Stewart MSP, following the Scottish Government’s announcement of forthcoming regulations for the short-term letting sector in Scotland.

Dear Minister,

As representatives of the short-term letting industry, we are writing to you to express our ongoing commitment to work with the Scottish Government, MSPs and local authorities on a new regulatory framework for short-term lets.

While the signatories to this letter differ in size and scope, our organisations are united in the belief that the short-term letting sector should be subject to updated regulation. We believe that clear, consistent and fair rules will strike the right balance between local communities where more control is necessary and the benefits short-term lets bring to Scotland’s tourist industry.

The ASSC and STAA have engaged positively and constructively with the Scottish Government over the past three years. We are fully committed to working with the Scottish Government on the details of the regulations to ensure that there is clarity for all those connected with, and affected by, short-term letting activity in Scotland.

Following your statement in the Scottish Parliament on 8th January we have identified five points where we would welcome further clarity from the Scottish Government:

  • A clear definition of what is, and what is not short-term letting activity – so that boundaries are clear for those operating in the short-term and long-term rental sectors, and we can properly understand the target of these regulations.
  • The proposed licensing regime – more details are needed on the criteria, the proposed duration of licences, the administrative processes that operators will need to follow, and the associated guidance that must ensure consistency and proportionality across Scotland.
  • The costs of the licensing and planning permission system – ensuring that these are truly proportionate to the costs of administration, and set at a level that does not unduly burden those who are renting very infrequently, or that layers further expense on established businesses who are already making a contribution to local authorities.
  • How control zones will be defined – what evidence will be needed to justify their introduction, and how they will be reviewed, and what policy responses to those zones are appropriate and proportionate.
  • The interplay between regulation and taxation – recognising the potential of the STR sector as a source of tax revenue for the Government, while also acknowledging that unduly restrictive regulation of the sector may discourage activity, leading to a reduction in tax revenues. Further analysis is needed to ensure that interventions like changes to business rates and new tourist levies and taxes do not result in unintended outcomes.

We believe that constructive dialogue between the industry, government and local communities can result in regulations that balance the needs of residents and support tourism, one of Scotland’s most important industries. We are here to help should you require any additional information from us.

Yours sincerely,

Association of Scotland’s Self-Caterers

Short-Term Accommodation Association

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