Category: Regulations

The Local Government Committee has published their report into their consideration of the STL six-month delay SSI. At the conclusion of the report, they note the following:

• “At the same time the Committee notes the concerns expressed to it by those representing short-term lets operators about the challenges they are facing in meeting the requirements being set by local authorities and the uncertainty of the meaning of some of these requirements.
• It is in the interests of both short-term lets owners and residents in short-term lets hotspot areas to have certainty about the application of the licensing scheme. It would be of considerable disappointment to the Committee to find itself in the position of considering a further extension in six months because of ongoing concerns about the operation of the scheme.
• The Committee welcomes the willingness expressed by the Cabinet Secretary for Social Justice, Housing and Local Government to use this six month period to respond to the concerns being expressed about the operation of the licensing scheme. The Committee hopes that the adoption of such an approach will obviate the need for a further delay.
• The Committee would also encourage existing short-term lets hosts to continue to apply for licences during this time period to avoid a rush of applications ahead of the September deadline.
• Notwithstanding that, the Committee would intend to return to look at short-term lets again in the context of the review to understand how it is affecting the operation of short-term lets and the experience of those living in proximity to them.”

Similarly, they have also published their report into their consideration of NPF4:https://sp-bpr-en-prod-cdnep.azureedge.net/published/LGHP/2022/12/21/81003168-a5d4-4a8c-a00d-113e25eef365/LGHPS062022R12.pdf.

On this, they highlight the following: “The Committee also notes the concerns expressed by the Association of Scottish Self-Caterers about policy 30 and its potential impact on the self-catering sector. The Committee will be giving careful consideration to the impact of policy 30 and the regulation of short-term lets more generally in the coming year.” (p14).

An open letter has been sent to the Scottish Government from a group of Destination Management Organisations in support of businesses being impacted by legislative changes.

Dear First Minister

We, the undersigned, wish to raise our concerns about the impact of the raft of regulatory legislation that is currently being introduced, at a time when increased business rates, energy bills and greater costs of operating in rural and island locations are already having a serious impact on business activity.

We wholly support our colleagues in the Association of Scotland’s Self Caterers, Scottish Tourism Alliance, Scottish Licensed Trade Association, Scotland Food & Drink and others, as they try to raise awareness of the impact of current and proposed legislation.  This includes Short Term Lets (STL), transient visitor levy (TVL), deposit return scheme (DRS), and ban on alcohol advertising. These regulatory proposals would appear to be based on a limited appreciation of their potential impact in the current operating climate.

Like other business, Tourism in Scotland has suffered greatly since COVID with staffing shortages and a well-documented drop in discretionary spend. To introduce further operating costs at this time is at best naive and takes little account of the financial impacts and mental health of business owners and their employees. The phrase ‘sledgehammer to crack a nut’ has been used frequently to describe the draconian nature of the pieces of legislation. We are not opposed to sensible, well-thought out regulation that improves the industry and the experience of visitors but we cannot stand back and see our industry decimated by legislation borne out of political horse-trading at Holyrood. We would request that the aims of Outlook 2030 are remembered and respected when developing policy, regulation and legislation.

At the launch of Scotland Outlook 2030, the First Minister stated:

“The (tourism) sector is vitally important to Scotland, supporting more than 200,000 jobs and contributing over £7 billion to our economy. We must work together to ensure our unrivalled tourism experience is sustainable and…. provide a strong basis for achieving the industry’s ambitions.” 

These ambitions are being thwarted and there seems little evidence of any ‘working together’. In addition, the overall Scotland Outlook strategy document, endorsed by the Scottish Govt states:

“The potential contribution that tourism can deliver must be understood and acknowledged with the right policy and regulatory landscape in place to support our vision of 21st century tourism”.

We reiterate that we recognise the importance and value of appropriately designed regulatory measures. However, we would request that an urgent review is carried out of the current raft of measures that will significantly affect our industry. We are all willing to provide advice, knowledge and support for appropriate legislation, delivered in an appropriate timeframe.

Kind regards

Argyll & Isles Tourism Co-operative

Destination Orkney

Outer Hebrides Tourism

SkyeConnect

VisitArran

Visit Moray Speyside

Venture North

Cc       John Swinney, Deputy First Minister

            Ivan McKee, Minister for Tourism

            All MSPs

Scottish Tourism Alliance

Association of Scotland’s Self Caterers

Scottish Licensed Trade Association

Scotland Food & Drink

UK Hospitality