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Titanic Revisited? Health and Safety, or Housing?

The ASSC is being copied in to a constant stream of emails from ASSC members, and other small accommodation providers, who are receiving responses from their MSPs regarding the Short-Term Let Legislation that is due to be voted on this Wednesday. We are saddened to learn that this is clearly not about health and safety at all, as suggested by the Housing Minister, Kevin Stewart MSP.

Kevin Stewart’s letter to MSPs dated 9th February 2021 makes no reference to the harm this legislation will cause, and he certainly does not suggest any benefits, nor why it should apply across the whole country. In paragraph 2, he states that “The only aspect of our proposals that applies to all short-term lets across Scotland relates to basic safety” and in the same paragraph states “Many hosts will already be following the standards set out in our licensing scheme as a matter of compliance with existing law or best practice….”As we all know, ‘complaints’ are restricted to a very few locations and Kevin Stewart states in paragraph 3 of his letter: “Local authorities in areas where there are no complaints about short-term lets may wish only to require hosts to comply with the basic safety requirements”.

According to responses our members are receiving from cross-party MSPs, however, “it remains the case that the issues of hollowed out communities and party flats is a very real one for some colleagues”.

In recent times, the self-catering and short-term letting sector has been used as a convenient scapegoat for longstanding failures in housing policy. However, the challenges facing Scotland are far more multifaceted than the existence and growth of short-term and holiday lets alone: https://www.assc.co.uk/short-term-letting-and-the-housing-crisis-2/

Let me expand on some actual data (this relates to Edinburgh only, but given that this legislation was written for Edinburgh issues alone, I will not apologise):

On 1st January 2019, there were 13,200 listings on Airbnb in Edinburgh. 61% were entire homes, 38% private rooms and 1% shared rooms. 40% of all listings hosted for under 30 days per annum. 15% under 60 days. 37% over 90 days and just 18% over 180 days. For absolute clarity, a single property may relate to more than one listing. For instance, some hosts choose to offer both their home as an entire home when they are away, and also offer a private room (or rooms) when they are there. This would result in that host’s account displaying more than one listing on the Airbnb website.

Forgive the detail, but I think it is important. We need to go back to December 2019, when the world was ’normal’ and we were at peak “airbnb” and the 13,000 figure was being used widely by the media.

There is a company called Inside Airbnb: It is essentially a data scrape of all the listings in certain locations, Edinburgh being one of them. This is the same dataset that many, including Andy Wightman and the media use to get the “13,000” listing number.

If you open this with excel, and add the total number of rows up, we get 13,363 listings. So more than the aforementioned 13,000, and we have, so it seems a housing disaster on our hands.

If you assume that these 13,000 listings are properties that have been taken away from people to be used as a home, then we would have a problem. But that is simply not true.

As we know, Airbnb can also be used for room sharing. In this scenario the home is owned by someone and indeed they live there so you can’t count these properties in the total. They are still being used as a home. So, if we strip them out we are now left with 8,543.

Airbnb also lists hotels and ‘shared rooms’ too. These aren’t homes being stolen from the local population so let’s strip them out too. Now we have 8,315.

As of December 2019 there were 8,315 ‘entire properties’ being used on Airbnb, not 13,363.

However, how many listings on Airbnb are ghost listings? These are listings that someone set up, sometimes as far back as 2015 but still show as live, but hasn’t been used for months or even years. We can tell this by looking at the review date on the dataset. I am going to say that any property that hasn’t had one single review in 6 months is most probably no longer being used. If you remember this data set was as at Dec 2019 so going back 6 months would also capture any reviews around the festival time too. I feel going back 6 months is fair.

Now we are left with 5,819. So, when you hear a figure of 13,000 in relation to the “housing crisis”, what they actually mean is 5,819. That’s a big difference.

If we then filter that one more time, this time looking at those properties that have actually been let more than 140 nights a year (when you go onto Non-Domestic Rates and become a ‘business’) the number now drops to 2,704 in the whole of of Edinburgh.

Using that same filter set, if we look at just the Old Town, Princes Street and Leith, the real “hot spots”, we have 427. Take away the 140 nights filter and its still only 655.

Using the same dataset and methodology for December 2020:

  • Total listings = 6,597
  • Strip out everything bar entire listings = 4,238
  • Strip out Review >6m = 2,301
  • >140 nights = 1,205
  • Old Town/Princes Street & Leith = 232

I would urge you to take a look at the ASSC paper ‘Short-Term Letting and the Housing Crisis’: https://www.assc.co.uk/policy/short-term-letting-and-the-housing-crisis/. This paper from February 2020 specifically references empirical data regarding the impact of self-catering in Edinburgh (and Scotland as a whole).

On 15th February 2021, there are 1513 self-catering properties registered on Non-Domestic rates. The vast majority of these will use Airbnb as a route to market. There are 256,267 subjects on Council Tax in the City of Edinburgh. Can our sector really be to blame for the housing crisis, or indeed hollowing out communities?

Party flats? Anti-social behaviour legislation already exists. Mr Stewart himself has said repeatedly that Local Authorities have the power to deal with this behaviour, that we in no way condone. They simply aren’t doing so. Loss of residential amenity? The ASSC has provided solutions to deal with this: https://www.assc.co.uk/policy/forward-together-a-collaborative-approach-to-short-term-letting/

Or, is this indeed about health and safety as Mr Stewart repeatedly attests?

To suggest that we can amend these SSIs later is akin to suggesting that we send HMY Britannia off to sea, knowing it has holes in the hull. We all know how RMS Titanic ended.

This legislation is flawed, not fit for purpose and beset with unintended consequences.

Fiona Campbell

Chief Executive

Association fo Scotland’s Self-Caterers 

“The Irish Self Catering Federation totally understand what the Scottish Self Catering sector within Tourism are going through. Here in Ireland we have experienced the results and long-term damage that small minded and blinkered politicians can create, without proper research and non-cooperation between departments of Housing and Tourism. Self-catering providers are NOT responsible for Homelessness”

Peter Downey, Chair, Irish Self-Catering Federation

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