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25/09/2020

Short-Term Let Regulation: This is your last chance to make a difference

The Regulation of Short-Term Lets (your Self-Catering business) will have a direct impact on your business… A self-catering cottage in Argyll, a large holiday house in Dumfries & Galloway, an apartment in Edinburgh or a croft cottage in Orkney. Whatever the size of your business, or wherever you are in the country, this will affect you.

Aside from Covid-19, this is the single biggest threat ever facing our sector. We urge you to read the below email fully and engage in this consultation – it is hugely important.

Short-Term Let Consultation

The Scottish Government has published their consultation on short-term let regulation which focuses on the introduction of a licensing scheme and planning control areas.

This can be accessed here.

This consultation will have significant ramifications for our sector and the Association of Scotland’s Self-Caterers is engaging with officials and policymakers as part of the consultation process. However, we need you to get involved.

The consultation will remain open until 16th October and the responses will help inform the secondary legislation which will be laid in the Scottish Parliament in December 2020.

Licensing or Registration

The ASSC believes that a licensing system is a blunt tool to fix a perceived and localised problem of amateur operators in Edinburgh, rather than being a solution that is appropriate for the whole of the Scotland, nor is it one that makes a necessary distinction between different types of visitor accommodation providers.

The ASSC remains concerned that little differentiation is made between different types of operator in what is a diverse short-term letting landscape, with potentially dire unintended consequences to the professional self-catering sector that contributes £723m to Scotland.

The ASSC also believe that, due to the impact of Covid-19, the potential pitfalls and shortcomings of licensing come into sharper focus in two main respects: (a) the impact for resource stretched local authorities having to deal with an influx of tens of thousands of licensing applications; and (b) the impact any disproportionate licensing system could have on the recovery of Scottish tourism.

The ASSC has prepared a paper outlining the implications of registration and licensing: 
Read more here.

Consultation Briefing Note

The ASSC has prepared a briefing which condenses the Scottish Government’s sixty-page consultation document and highlights the main points of interest.

We appreciate that you will have numerous personal and business-related demands on your time but it is also important that professional self-caterers make their voices heard on these regulations.

The ASSC is in the process of compiling a detailed and evidence-based submission to the consultation and will share this with you as soon as it is finalised. This can be used to help inform your own response to the consultation and we will also be issuing guidance to assist with your response in due course.

In the meantime, please find attached briefing: Briefing on STL consultation

Autumn Talk: Regulation of Short-Term Lets – Video Available to Members

Our fifth Autumn Talk was held on Tuesday 29th September entitled REGULATION OF SHORT-TERM LETS, with the Short Term Let Delivery Group, Scottish Government.

We were delighted to welcome Fergus Ewing, Cabinet Secretary for Rural Economy and Tourism & MSP for Inverness and Nairn who welcomed attendees.

This Talk included a presentation by Andrew Mott, Chair of the Scottish Government’s Short-Term Let Delivery Group, Scottish Government and included a discussion around the proposed licensing scheme for short-term lets.

The video can be seen in the Member News Area.

Parliamentary Questions Tabled on the Subject:

Question S5W-32140: Oliver Mundell, Dumfriesshire, Scottish Conservative and Unionist Party, Date Lodged: 29/09/2020

To ask the Scottish Government for what reason its short-term let consultation document makes no reference to the impact of COVID-19 pandemic on the tourism sector. Current Status: Expected Answer date 27/10/2020

Question S5W-32141: Oliver Mundell, Dumfriesshire, Scottish Conservative and Unionist Party, Date Lodged: 29/09/2020

To ask the Scottish Government for what reason its short-term let consultation will be live for four weeks and not the standard 12, and what its position is on whether this timescale will allow stakeholders to properly engage with the process. Current Status: Expected Answer date 27/10/2020

Question S5W-32142: Oliver Mundell, Dumfriesshire, Scottish Conservative and Unionist Party, Date Lodged: 29/09/2020

To ask the Scottish Government whether it has considered piloting its proposed short-term let regulations before implementation. Current Status: Expected Answer date 27/10/2020

Question S5W-32139: Oliver Mundell, Dumfriesshire, Scottish Conservative and Unionist Party, Date Lodged: 29/09/2020

To ask the Scottish Government whether it will publish a business regulatory impact assessment to accompany its plans to introduce short-term let licensing and planning control areas. Current Status: Expected Answer date 27/10/2020

Question S5W-32143: Oliver Mundell, Dumfriesshire, Scottish Conservative and Unionist Party, Date Lodged: 29/09/2020

To ask the Scottish Government, in light of its Programme for Government advising that plans for the Transient Visitor Levy have been put on hold due to COVID-19, and that “future consideration of the levy will take account of the changed context the industry is operating in”, for what reason a similar approach was not extended to its proposals on short-term let regulation. Current Status: Expected Answer date 27/10/2020

Parliamentary Questions Answered:

Andy Wightman (Lothian) (Scottish Green Party): To ask the Scottish Government, further to the comment by the Minister for Local Government, Housing and Planning on 8 January 2020 that “we will review the tax treatment of short-term lets to ensure that they make an appropriate contribution to the communities that they operate in” (Official Report, c.37), what progress has been made with this review, and when the results will be published. (S5W-31815)

 Kevin Stewart: Due to the impact of the COVID-19 pandemic, we prioritised preparing the statutory instruments for the licensing scheme and short-term let control areas so that they can be considered by the Scottish Parliament in this session and deferred the review of the tax treatment of short-term lets. We are now considering how to complete the review in light of the evolving COVID-19 situation.

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