The Association of Scotland’s Self-Caterers (ASSC) has formally written to the City of Inverness Area Committee to highlight a fundamental deficiency in proposals by Highland Council to extend Short-Term Let Planning Control Area designations across Inverness City wards 12, 13, 14, 15 and 16.
Writing in her capacity as Chief Executive of Association of Scotland’s Self-Caterers, Fiona Campbell has warned that the Council does not currently hold the quantitative evidence required to demonstrate that the existing Control Area in Ward 20 has delivered any measurable housing benefit.
In the absence of such evidence, ASSC argues that further expansion of this significant regulatory intervention cannot be justified as proportionate, effective or responsible.
In the letter to the City of Inverness Area Committee, ASSC sets out clearly what the Council is presently unable to provide: quantitative evidence showing that the existing Planning Control Area has delivered material improvement in core housing indicators. These include overall housing availability, affordable housing supply, average house prices, private rents, levels of empty and long-term empty homes, second homes, or any causal or correlative link between designation and housing outcomes.
Crucially, the Council is being asked to extend planning controls without a baseline, monitoring framework, impact assessment or outcome evaluation for the existing designation in Ward 20. ASSC states plainly that this does not represent evidence-led policy making.
The Committee’s decision would amount to expanding a major regulatory restriction without knowing whether the current one in Ward 20 has worked. ASSC cautions that such an approach carries not only policy risks, but also governance and legal risks. As noted in the Council’s own papers, any decision to progress with a Short-Term Let Control Area may be subject to legal challenge if it cannot be robustly justified.
Alongside the letter, ASSC has submitted a case study from Lisbon, where restrictive short-term let policies were amended after evidence showed they had failed to improve housing affordability or availability. The Lisbon Municipal Assembly reversed a blanket moratorium on new licences after data demonstrated that prices and rents continued to rise, while tourism accommodation costs increased. The city has since moved to a more targeted, evidence-informed framework, including a monitored 10 per cent cap on short-term lets, acknowledging that structural housing supply constraints – not short-term letting alone – were driving affordability pressures
ASSC believes this international example is directly relevant to Inverness. It underlines the importance of measuring outcomes before extending controls, and of recalibrating policy where evidence shows that regulatory intent does not align with real-world results.
ASSC is calling on Highland Council to pause further expansion of Control Areas until robust evidence is available to demonstrate that the existing designation has delivered tangible housing benefits. Without that evidence, ASSC warns, the proposed expansion risks being ineffective, legally vulnerable, and damaging to local businesses and communities – without solving the housing challenges it is intended to address.