Edinburgh Short-Term Let Control Area Consultation

Posted on: November 2, 2021

Our statement of support for the City of Edinburgh Council’s proposed city-wide Short-term Let Control Area

Public Consultation By: City of Edinburgh Council

Overview: The Council is consulting on its recently approved proposal to introduce a Short-Term Let Control Area across the entire city of Edinburgh. The Council have produced this short presentation explaining why they support this measure.

Opened for comments: 2 September2021

Closing date for comments: 5 November 2021

Cockburn Response

We fully support the City of Edinburgh Council’s Short-term let Control Area (STLCA) proposals.

The purpose of the STLCA as set down in section 17 of the Planning (Scotland) Act 2019 is to allow local planning authorities to manage short-term letting if “the use of a dwellinghouse for the purpose of providing short-term lets is deemed to involve a material change of use of the dwellinghouse” and provided the property is not a Private Residential Tenancy or the property in whole or in part is the only or principal residence of the landlord or occupier.

The proposed Control Area covers the entire City Council area.  Both the “Short-term Let Control Area – Statement of Reasons” and the associated “Background Report” set out comprehensively why such a designation is necessary.  These explain the three objectives underpinning the STLCA proposal:

  1. to help manage high concentrations of secondary letting which affects the availability of residential housing and the character to neighbourhoods.
  2. to restrict short-term lets in places or types of buildings where it is not appropriate; and
  3. to help ensure that homes are used to best effect.

The Cockburn supports all these objectives and welcomes the city-wide approach. Our response to the consultation is simple and straightforward.

When asked if we agree with the proposed designation, we said:

The Cockburn Association agrees with the reasons as set out in the Council’s Short-term let control area for Edinburgh; Statements of Reasons, which provides a comprehensive set of arguments in support of the designation of a STL Control Area. There is no question that Edinburgh has one of the greatest densities of STL in Scotland, with over 30% of all Airbnbs listed being in the city. In relative terms, it also has one of the highest densities of any city.

When asked if we support the city-wide approach, we said:

The reasons for a Council-area wide designation are comprehensive and reasonable. Almost no ward has no holiday lets in it, and it is essential that any designation does not simply displace issues with Short-term lets (STLs) from one street onto another. We can see some merit in several areas being designated (providing whole authority coverage) as there may be different issues that need to be managed. For example, flats in common stairs present different issues so different policies might be useful for tenement areas, colony developments and for bungalow areas. However, this would add unnecessary complication.