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Individual holiday homes, which are rented out in their entirety, now require an Energy Performance Certificate in Scotland, despite advice until January 2017 that holiday homes did not require EPCs.
By 2018, any property being rented out must meet a minimum standard of an EPC rating E. By 2020, your EPC rating will have to be D, or possibly C.
Read more: Energy Performances Certificates – Background Briefing
The Scottish self-catering and holiday let sector has been the target of a recent campaign of misinformation led by some in politics and in the media. The hardworking professionals who make their living in the industry, many of whom are members of the Association of Scotland’s Self-Caterers, have been blamed for everything from housing shortages to anti-social behaviour. This is simply unfair.
Given that we live at a time in which wrong or inaccurate information is easier than ever to spread and truth is at a premium, we at the ASSC thought we’d address a couple of the inaccuracies surrounding the self-catering industry and set the record straight. Because, given that it accounts for over 15,000 Scottish jobs and £723million in consumer spending in Scotland, £470million of which comes from overseas visitors, the short-term letting sector is too important to have such damaging myths go unchallenged.
So, without further ado, here are some of the top self-catering sector myths – DEBUNKED!
It needs to be said clearly, for the avoidance of doubt, there is no substantive connection between short-term lets and anti-social behaviour. Anti-social behaviour occurs throughout society, in hotels, shops, private residences, and occasionally and regrettably in some short-term lets. It happens across society and impacts all of us. However, at the ASSC we have recently taken a major step towards addressing poor behaviour on the rare occasions that it does occur in our sector. We recently published our Code of Conduct for our members and our partners which provides a framework to ensure best practice. By abiding by the Code we can help stamp out inappropriate behaviour when it does happen and avoid such isolated incidents having a detrimental and disproportionate effect on the vast majority in our sector that do their jobs and do them well.
Similar to the argument around anti-social behaviour, the accusation that short-term and holiday renting is connected with shortages is a case of confusing correlation for causation. The short-term sector is not new – it has been operating in Scotland and across the UK and the world for many, many years and has seen housing shortages and surpluses over the years. Just because short-term letting exists alongside variations in supply within the housing market is not indicative of a connection between the two – to suggest so is only indicative of faulty logic.
The ASSC fundamentally disagrees with anyone who is looking to shirk their share of tax and takes pride in how much our members help to generate for their local economies and for the country as a whole. There have also been some grave exaggerations when it comes to this issue and a closer inspection of how short-term let hosts operate will show that they pay income tax on the income they accrue from letting as well as the appropriate levels of Council and other taxes. We have welcomed the publication of the Barclay Review of business rates and welcome the cooperation we have had with government aimed at making sure that the burden not only provides the best deal for taxpayers but is also fair to our hardworking and enterprising hosts.
Nobody in any industry genuinely believes that their industry is perfect – and the self-catering sector is no exception. However, across the sector, talented and enterprising individuals are working with those in government and the third sector to promote best practice and weed out unacceptable habits wherever they may be. The future for the sector is bright and it has an excellent legacy on which to build but this may be jeopardised if irresponsible agitators in the media and politics continue to spread false or misleading information.
7th November, Perth Concert Hall
Tourism in Scotland is generally doing well – national marketing campaigns are working successfully, helped by exchange rates favouring holidays in the UK for both our own residents as well as attracting overseas visitors. The rise of Online Travel Agencies (OTAs) has encouraged many new visitors to our sector, and made it easy to book. Many more people are discovering the advantages of self-catering, something ASSC has been working to promote since its formation almost 40 years ago.
For ASSC this has been a year of change as we became a Company Limited by Guarantee, run by a Board of Directors. For the Membership, we are continuing as we were, but the underlying legal framework and terms of business have changed. We started our successful Paws for a Break Growth Fund project last summer, and this came to an end in summer 2017 allowing us an opportunity to reassess staffing. My thanks to our Vice Chairman Linda Battinson for driving the project forwards and Ali Campbell for his marketing work – it is being showcased as a model campaign. The Association continues to grow, with membership numbers healthy and increasing. We continue to work with our Partners for Business whose support is vital to allow us to increase our activities in terms of member benefits and representation. ASSC commissioned the first ever independent comprehensive volume and value study of out sector, reporting in April 2017, an immensely valuable tool for us to use.
With all this success, there is certainly much to celebrate, but for us in the short-term letting business, there are more dark clouds on the horizon than we have ever faced. Globally, tourism is suddenly being seen as a scourge – heaving masses of visitors are accused of ruining the things they have come to see, stretching infrastructure and annoying the locals – open topped busses were attacked in Spain this summer. In Scotland, questions are being asked about ‘overtourism’: clogged roads on Skye, poor infrastructure on the North Coast 500, cruise liner passengers swamping Orkney and a full-to-bursting Edinburgh at Festival time raised the issue of numbers of visitors and whether a tourism tax should be levied to help pay for visitors’ needs. ASSC’s broad position is that Scotland is already expensive enough, so a bed tax would be unwelcome, but we expect increasing pressure to see this introduced. The recent announcement of a £6m rural infrastructure fund acknowledges the problem, and VisitScotland’s renewed drive to spread out visitors more evenly will be helpful steps.
On top of this, the rise of the collaborative economy is a major challenge to the lawmakers, with the Scottish Government well through its own inquiry (it reports at the end of the year). ASSC has been very active convincing Government that the traditional sector we represent is the ‘Black Cab’ of the short-term letting world – we run responsible tourism businesses, obey laws, pay our taxes and we don’t need further regulation. In reality, it is more complicated of course, with many self-catering businesses using the collaborative economy as one of several routes to market. We remain very concerned that any regulations to control the collaborative economy will impact us all, making it harder and more costly to do business.
Criticism of the number of short-term lets in some areas, like Central Edinburgh is mounting, with Andy Wightman MSP spearheading a campaign for a mechanism to control the numbers in an area. We are accused of reducing the housing stock, causing loss of residential amenity and generating problems of party flats and noise. There are increasing murmurings that short-term let businesses should not be eligible for the Small Business Bonus scheme. ASSC has launched a Code of Conduct for businesses to adopt to be good neighbours and avoid local problems. This has been well received all round, but we expect more pressure to be put on our sector in the Planning Bill coming up.
Rest assured, we are fighting tooth and nail on all these, and other fronts just now, including the withdrawal of the exemption for Energy Performance Certificates (EPCs) for holiday lets, the Scottish Government’s interpretation of the European Directive. The fact that short term lets are exempt in Denmark, Germany, Sweden and Italy – with approval from the European Commission, AND that there are exemptions in England seems to cut no ice in Holyrood: we are told that Scotland is right and the others are wrong, so go fight it in Europe!
The rates revaluation produced the highest average rise in rateable value in a tourism sector. Working with our colleagues at Scottish Tourism Alliance, British Hospitality Association and Scottish Licenced Trade Association, we immediately pushed for and received capped relief for 2017/18, and then extended to 2018/19. Many short-term let businesses have rateable values below the Small Business Bonus Scheme thresholds, but others are now over a cliff edge suddenly paying significant bills. The Assessors have been very helpful and we understand their methodology, but it is disappointing that the resulting rateable values do not seem to reflect reality. We were involved in the Barclay review, and welcome the proposed change to 3 year revaluations. We will be active in any reassessment of the SBBS.
While we remain concerned about political uncertainty and Brexit in particular, we can take heart that despite challenges ahead, self-catering was far and away the most confident tourism sector in the Scottish Tourism Alliance’s October survey. Visitors are intrigued and charmed by Scotland, and we need to work hard to future-proof our sector so that we can continue to welcome them through our doors.
Finally, thank you notes: to our Board for guidance, to our staff – membership secretary Eleanor, Linda and Ali for work on Growth Fund and webmaster duties, and to Chief Executive Fiona who has been a veritable powerhouse representing our sector with energetic dynamism. We would not be an organisation without our members, large and small right across the country. Thank you for your continued support to allow us to represent you. I wish you every success in 2018.
David Smythe
Chairman
11th October 2017