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17/02/2026

Planning Control Areas in the Highlands: why evidence must come before expansion

The Association of Scotland’s Self-Caterers remains deeply concerned about the growing momentum behind Planning Control Areas in the Highlands, particularly when there is still no clear evidence that existing control areas have delivered any meaningful housing benefit.

No evidence that Planning Control Areas work

The central issue is straightforward. There is no quantitative evidence demonstrating that a Planning Control Area improves housing availability or affordability.

Highland Council has been unable to provide evidence that its existing Planning Control Area in Ward 20 has delivered measurable improvements in housing supply, affordable housing provision, house prices, private rents, or reductions in empty or second homes, despite a Freedom of Information request sent on 5th January 2026.

There is no baseline data, no monitoring framework and no outcome evaluation. Proceeding with policy expansion in the absence of this evidence is not evidence led decision making and creates unnecessary governance and legal risk.

This position mirrors the situation in Edinburgh. A Freedom of Information response from the City of Edinburgh Council confirms that it holds no evidence that its Planning Control Area has delivered any measurable housing benefit. No impact assessments, evaluations or outcome analyses exist linking the policy to improved housing outcomes.

Edinburgh should be a warning, not a model

Edinburgh’s experience should act as a clear warning to Highland councillors.

Despite the introduction of a Planning Control Area, house prices and private rents have continued to rise. The policy has been implemented and enforced without proof of effectiveness, while imposing additional burdens on small businesses and the visitor economy. This is a clear example of regulation introduced without an evidence base and maintained without evaluation.

Replicating this approach in rural, island and fragile Highland communities would carry even greater risk.

Planning Control Areas target the wrong problem

Planning Control Areas are a blunt regulatory tool. They do not address the real drivers of housing pressure in the Highlands.

They cannot target second homes, long term empty properties, structural under supply of housing, workforce accommodation shortages or demographic change. Instead, they focus on licensed, regulated and economically productive self-catering businesses.

Evidence consistently shows that empty homes and second homes substantially outnumber self-catering businesses across the Highlands. National Records of Scotland data confirms the Highlands remain a hotspot for long term empty homes. Targeting self-catering will not resolve a structural housing challenge.

The economic risk to Highland communities is real

Self-catering is a cornerstone of the Highland economy. Independent analysis confirms that the sector supports nearly 7,000 jobs and generates approximately £200 million in GVA each year. These are local jobs and local supply chains, particularly vital in rural and island communities.

Undermining this sector without evidence of housing benefit risks reduced visitor capacity, lost income, job losses and weakened community resilience. These impacts are predictable and avoidable.

Lisbon shows why policy must change when evidence fails

International experience reinforces the need for evidence led policy. Lisbon introduced strict short term let restrictions, including moratoria, with the intention of improving housing affordability. The evidence demonstrated that these measures did not achieve their stated aims.

Housing costs continued to rise, availability did not materially improve and tourism accommodation costs increased. In response, Lisbon formally amended its policy in late 2025, lifting its moratorium and moving to a capped, monitored approach that recognised housing supply as the primary structural issue.

Lisbon’s experience demonstrates that when evidence shows a policy is not working, responsible authorities recalibrate rather than entrench failure.

Evidence must come before expansion

Scottish Government guidance requires robust, locally specific evidence to justify the designation of a Planning Control Area. That evidence does not currently exist for Ward 20, Edinburgh or any proposed expansion in the Highlands.

Extending a significant regulatory intervention without knowing whether it works is not proportionate, not responsible and not good governance.

What a better approach looks like

If the objective is genuinely to support sustainable communities, policy must focus on solutions that address root causes rather than displacing harm.

The ASSC believes priority should be given to:

  • Tackling long term empty homes through targeted enforcement and incentives
  • Addressing second home pressures with appropriate, targeted measures
  • Accelerating delivery of multi tenure housing aligned with local need
  • Investing in workforce accommodation
  • Working collaboratively with the tourism and self-catering sector

These measures are far more likely to deliver meaningful housing outcomes without damaging local economies.

Our position

Until there is clear, quantitative evidence that existing Planning Control Areas deliver measurable housing benefit and do not create unintended harm, there should be no expansion of this policy in the Highlands.

The experience of Edinburgh and the recalibration seen in Lisbon both point to the same conclusion. Evidence must lead policy, not follow it.

At a glance – the facts

Empty homes and second homes far outweigh self-catering

  • Highland had 3,900 long-term empty homes in 2024, making it one of Scotland’s largest empty homes hotspots
  • Across Scotland, empty homes account for around 3.6 percent of housing stock, compared with just 0.8 percent for short-term lets

Self-catering is a small part of the housing system, but a major part of the economy

  • There are 5,519 self-catering properties on Non-Domestic Rates in the Highland Council area, meaning they are already classified as businesses, not residential housing
  • Independent analysis confirms self-catering supports nearly 7,000 jobs and generates around £200 million in GVA each year in the Highlands

No evidence that Planning Control Areas deliver housing benefit

  • Highland Council has no quantitative evidence showing that its existing Planning Control Area in Ward 20 has improved:
    • housing availability
    • affordable housing supply
    • house prices
    • private rents
    • levels of empty or second homes
  • The City of Edinburgh Council has also confirmed it holds no evidence that its Planning Control Area has delivered measurable housing benefits

Housing costs continue to rise regardless

  • In Edinburgh, where a Planning Control Area is already in place, house prices and private rents have continued to increase, with no evidence of improved affordability linked to the policy

International evidence supports recalibration, not expansion

  • Lisbon lifted its short-term let moratorium in 2025 after evidence showed restrictive policies did not improve housing affordability or availability, shifting instead to a capped, monitored approach  – Lisbon case study

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