ASSC Provide Evidence to the Local Government Committee on STL Licensing

The ASSC today provided oral evidence to the Scottish Parliament’s Local Government, Housing and Planning Committee as part of their scrutiny of the Scottish Government’s proposed short-term let licensing scheme.

Our Chief Executive Fiona Campbell was joined by other industry stakeholders including David Weston from the Scottish B&B Association, Amanda Cupples from Airbnb, and Shomik Panda from the UK STAA.

 

During the hour and a half evidence session, we stressed the importance of our £867m sector to the Scottish economy, how it was imperative to back Scottish businesses to recover from the pandemic, as well as bringing some much needed clarity about existing regulations the government have at their disposal and what we should be looking to achieve in terms of the regulatory framework for short-term lets.

 

The ASSC also highlighted the uncertainties for future bookings arising from licensing, how the fees are completely disproportionate, and that local councils in charge of administering the scheme will also be negatively impacted. The panel as a whole emphasised the benefits that a mandatory registration system could bring to all affected stakeholders and best practice seen elsewhere.

 

The Committee was also joined by SNP MSP Fergus Ewing who called the evidence provided by the panellists against short-term let licensing as “comprehensive, persuasive and compelling.”

 

MSPs will now hear from another panel of witnesses next week, before taking evidence from the Cabinet Secretary Shona Robison and her officials.

 

Recorded video coverage of today’s Committee session can be accessed here. Unfortunately, the first ten minutes of the session were not recorded, but will be covered in the Committee report which will be published in due course.

 

Following today’s session, the ASSC released the following press comment.

 

Association of Scotland’s Self-Caterers Chief Executive, Fiona Campbell, said:

 

 “These licensing regulations could not have come at a worse time for Scotland’s self-caterers, most of whom are still reeling from the devastating impact of the pandemic on our businesses and livelihoods.

 

 “It remains astonishing that the Scottish Government seems intent on kicking self-caterers while we’re down by imposing these damaging and potentially ruinous regulations on a sector that contributes £867m to the Scottish economy each year, as well as supporting 24,000 FTE jobs. 

 

 “Instead of an onerous licensing scheme with crippling operator fees, the ASSC have put forward a workable and proportionate mandatory registration scheme which has cross-industry and cross-party support.

 

 “The Scottish Government needs to change its course and show that it is on the side of thousands of small businesses across the country by giving them the room and flexibility they need to get back on their feet.”

 

The Official Report for the meeting of the LGHP Committee has now been published:

Url: https://www.parliament.scot/chamber-and-committees/official-report/what-was-said-in-parliament/LGHP-07-12-2021?meeting=13460&iob=122170

Pdf: https://www.parliament.scot/api/sitecore/CustomMedia/OfficialReport?meetingId=13460

Licensing: Industry Briefing Recording Published

On 2nd December, the ASSC was joined by industry leaders on a session to discuss the Scottish Government’s Short-Term Let Licensing Proposals.

Panelists included:

  • David Weston, Chair, Scottish B&B Association
  • Gordon Bulloch, Scotland’s Best B&Bs
  • Kay Wilson, Destination Leader, Scottish Agritourism
  • Joanna Millar, Legal Director, Gilson Gray

Apologies were sent by:

  • Simon Ovenden, Policy Adviser, Scottish Land & Estates
  • Marc Crothall, Chief Executive, Scottish Tourism Alliance

230 people registered to join the session in 36 hours, and 125 have watched the recording since the event.

Watch the video here.

On 7th December, the Local Government, Housing and Planning Committee will take evidence on the Town and Country Planning (Short-term Let Control Areas) (Scotland) Amendment Regulations 2022 and the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2021 from —

Witnesses:

  • Fiona Campbell, Chief Executive, Association of Scotland’s Self-Caterers
  • Amanda Cupples, General Manager for Northern Europe, Airbnb
  • Shomik Panda, Director General, UK Short Term Accommodation Association
  • David Weston, Chair, Scottish Bed and Breakfast Association (SBBA)

Meeting Notes

Licensing of Short -Term Lets – Analysis of Survey Responses

On 27 September 2021, the Local Government, Housing and Planning Committee launched an online survey to gather views on the Scottish Government’s plans to require local authorities to introduce a licensing scheme for short-term let accommodation. The closing date for submissions was Friday 29 October 2021.

The responses were published today. The analysis was undertaken by SPICe, the independent research unit at the Scottish Parliament.

1237 of the 2578 responses were from owners of short-term lets.

  • Most of the respondents opposed the licensing scheme.
  • When those who opposed the scheme were asked how it could be improved, some highlighted the ASSC’s registration proposal.

The largest single group of respondents within the “other” category, accounting for 60 (22.3%) of responses, were the owners/operators of bed and breakfast accommodation or guest houses. Of the 60 owners/operators of bed and breakfast or guest house accommodation that responded under “other”, 27 (45%) are strongly opposed to the proposed licensing system and 11 (18%) are opposed.

848 respondents who were opposed or strongly opposed to the proposed licensing system also gave additional reasons to support their view. The key themes were:

  • The proposed licensing system is wholly disproportionate to the problems it is trying to solve, which are mainly limited to a small number of urban locales (principally central Edinburgh).
  • There is no robust data to support the proposed licensing system.
  • The proposed licensing system should not apply to traditional Bed and Breakfast accommodation, including small Guest Houses, as these comply with relevant legislation and do not cause issues for neighbours or surrounding communities.
  • Many short-term let premises are already registered and inspected by Visit Scotland, the proposed licensing scheme introduces unnecessary duplication and cost.
  • The proposed licensing scheme should not apply to traditional self-catering accommodation, which already complies with the relevant health and safety requirements.
  • The proposed licensing scheme should not apply to properties built specifically as short-term lets.
  • The proposed licensing scheme places an additional burden on already stretched local authority budgets and staff.
    The loss of short-term lets caused by the proposed licensing scheme could limit choice for travellers and result in job losses amongst tourism businesses and companies that support short-term letting, such as cleaning, laundry, and property maintenance.

In response to the question regarding how the scheme could be improved, key themes included:

  • The proposed Scotland-wide licensing regime should be scrapped, as it is:
    o disproportionate to the problems it claims to tackle
    o duplicates work already undertaken by VisitScotland
    o unfairly penalises the vast majority of short-term let owners, who provide a high level of service and comply with or exceed current regulatory requirements.
    o unclear what problems the proposed scheme is actually trying to address.
  • The registration scheme suggested by the Association of Scotland’s Self-Caterers (ASSC) should be taken forward instead of the proposed licensing system.
  • The proposed licensing system should not apply to traditional Bed and Breakfast accommodation, including small Guest Houses, as these comply with relevant legislation and do not cause issues for neighbours or surrounding communities.
  • Any licensing or registration system must take account of the different challenges facing short-term lets in urban and rural areas.
  • A license should not be required for any property managed by a professional owner/agent and/or accredited by an established trade body such as Visit Scotland or the AA.
  • Licensing of short-term lets should only be introduced in those areas experiencing problems, principally central Edinburgh.
  • Licences should automatically renew, unless there is evidence of non-compliance with licence conditions.
  • Licensing fees should be as low as possible and set at a national level, preventing local authorities from using the system to raise additional revenue.

https://www.parliament.scot/chamber-and-committees/committees/current-and-previous-committees/session-6-local-government-housing-and-planning/correspondence/2021/licensing-of-short-term-lets-analysis-of-survey-responses