Comments on Short-term Lets Consultation

The untrammelled use of whole properties for short-term holiday and other accommodation is a serious issue in Edinburgh and some other parts of Scotland. Many cities across the world have experienced disruption to housing markets and community amenity by the expansion of STL provision.

In summary, the Cockburn supports the introduction of a registration and licensing system for Short Term Let properties. We believe that the secondary letting of whole properties is more disruptive than swapping (e.g. an exchange of houses between two families) and sharing (such as the letting of a spare bedroom to a student or occasion worker).

We also believe that tenements should be distinguished from detached or semi-detached properties due to their communal nature. If permitted at all, any licensing of STL in tenements should have other owners’ consent and a threshold put in place to avoid over-dominance of STL in any given stair.

We fundamentally disagree with the proposal the Edinburgh should have more permissive rules during periods of large tourist demand such as the Festival and Hogmanay. The current problem is due in part of over-tourism and the impact that this is having on the City overall, and especially on housing stock in the city centre. There is strong evidence to show that STL are displacing both normal letting and owner occupation stock, leading to significant and damaging shortages of housing for residential need. Instead the system should be less permissive during periods of large tourist demand. In Edinburgh, tourism extends through most of the year. This proposal would render any benefit of proposed regulatory useless to this City.

The consultation expires on 22 July 2019. Details can be found using this link to the Scottish Government/s consultation hub.
https://consult.gov.scot/housing-services-policy-unit/short-term-lets/