East Lothian Council has launched its formal consultation on a proposed Visitor Levy Scheme, providing businesses, organisations, residents and visitors with the opportunity to help shape the future of tourism in the region.
Following earlier engagement, the Council is now seeking views on its draft proposals before any decisions are made by elected members.
The consultation invites feedback on:
The Association of Scotland’s Self-Caterers (ASSC) has submitted a comprehensive response to the consultation, urging the Council to ensure that any decision is grounded in robust evidence, transparent governance and a clear understanding of the wider economic impacts.
While recognising the Council’s ambition to invest in tourism and enhance the visitor experience, the ASSC argues that the current proposals are not yet supported by the evidence necessary to demonstrate that a Visitor Levy would deliver a positive net benefit for East Lothian.
Throughout its submission, the ASSC responds directly to each consultation question, following the structure of the consultation document itself. Rather than taking a position for or against a Visitor Levy in principle, the Association has sought to engage constructively with the Council’s proposals, identifying where further evidence, analysis and clarification are required before any final decisions are taken.
A number of consistent themes emerge throughout the response.
The ASSC’s principal concern is the absence of a comprehensive Economic Impact Assessment examining how the proposed levy could affect visitor demand, business turnover, employment, Gross Value Added (GVA), destination competitiveness and the wider visitor economy.
Whilst the consultation estimates the revenue that could be generated, the Association argues that revenue projections alone are insufficient.
The key question is not how much money a Visitor Levy might raise. It is whether the overall economic, social and environmental benefits outweigh the costs imposed on visitors, businesses and East Lothian’s economy.
The ASSC also questions why the consultation proposes a single 5% percentage-based levy whilst simultaneously asking respondents whether they would prefer fixed-amount or tiered fixed-amount alternatives.
The Association argues that if these were genuine policy options, this consultation was precisely the opportunity to evaluate and compare them before identifying a preferred approach. No comparative modelling or Economic Impact Assessment has been published for the alternative charging models, making it impossible for consultees to make an informed comparison.
The ASSC highlights the significant administrative and legal responsibilities that would be placed upon accommodation providers, who would become responsible for calculating, collecting, accounting for and remitting the levy on behalf of the Council.
The response questions whether the proposed 2% retention adequately reflects the true costs businesses will incur and raises concerns about the cumulative regulatory burden placed on accommodation providers already operating within a highly regulated environment.
The ASSC welcomes the proposal to establish a Visitor Levy Forum but believes greater clarity is required regarding its membership, governance arrangements and role in overseeing levy expenditure.
Similarly, the Association argues that investment priorities should be more clearly defined and accompanied by measurable outcomes to ensure levy revenues are genuinely additional to existing Council expenditure and deliver demonstrable benefits for visitors, businesses and local communities.
“Tourism is one of East Lothian’s greatest economic assets and any investment that strengthens the visitor economy should be welcomed. However, introducing a Visitor Levy is a significant policy decision that deserves equally significant evidence.
“The key question is not how much money a levy might raise. It is whether the overall economic, social and environmental benefits outweigh the costs imposed on visitors, businesses and the wider local economy.
“Our response engages constructively with every question in the consultation and identifies areas where further analysis and greater transparency are needed before any final decision is taken.
“Ultimately, success should not be measured by the amount of levy revenue collected, but by whether the Scheme demonstrably enhances the visitor experience, strengthens destination competitiveness and delivers a positive net benefit for East Lothian.”
The ASSC encourages members, businesses and anyone with an interest in East Lothian’s visitor economy to take part in the consultation.
Whether you operate accommodation in the area, work within the tourism sector or visit East Lothian regularly, this is an opportunity to ensure your views are considered before elected members make a final decision.
The consultation is now open and can be accessed here:
https://eastlothianconsultations.co.uk/housing-environment/visitor-levy/
Feedback submitted through the consultation will be considered by East Lothian Council before elected members decide on the next steps for the proposed Visitor Levy Scheme.