Licensing of short-term lets – Scottish Parliament Consultation

Posted on: October 5, 2021

Our response to the Scottish Parliamentary Committee examining pending legislation on the regulation of short-term lets

Public Consultation By: Local Government, Housing and Planning Committee of the Scottish Parliament

Overview: The Scottish Government has told the Local Government, Housing and Planning Committee that it will be laying draft laws before the Scottish Parliament requiring local authorities to introduce a licensing system for short-term let accommodation.  The Committee wants to hear public views about the suggested licensing scheme for short term lets.   The Committee is particularly keen to hear about concerns anyone may have about the proposals and to receive suggestions as to how these could be solved.

Opened for comments: 27 Sepetember2021

Closing date for comments: 29 October 2021

Cockburn Response

Q) How would you describe your view of the proposed licensing system for short-term lets?

Cockburn Answer: Strongly support

Q) Why do you think this? (please tick all that apply)

Cockburn Answer

  • It will safeguard the amenity of people living alongside short-term lets.
  • It will protect existing communities in areas with high visitor numbers.
  • It brings short-term lets into line with other tourism businesses.
  • It will ensure short-term lets meet minimum safety and management standards.
  • It protects legitimate short-term let businessesOther reason(s) Please specify in the box below:

Q) Other reason(s) please specify in the box below

Cockburn Answer:

  • It offers the opportunity to rebalance housing provision in Edinburgh.
  • It allows for the effective management on STLs in tenements and areas where shared/community access is prevalent.
  • It will assist in the problem of reducing long-term let accommodation where there has been a displacement from long-term to short-term rentals.
  • It could form part of a toolkit of measures to help manage areas suffering from Overtourism.
  • It will help reduce the level of foreign and non-city investment in residential properties where the purchaser has no intention of living in the property but views it as an investment opportunity.
  • It will help manage direct and indirect impacts such as litter, waste management, anti-social behaviour, etc.

Q) Thinking about your response above, how do you think the proposed licensing system could be improved? Please set out how you think the system could be improved in the box below:

Cockburn Answer:

The key issue missing from the licensing system is the need for effective enforcement.

Firstly, in areas of over-provision such as Edinburgh, there is an urgent need for increased enforcement against unauthorised STL, especially whole-property STLs.

Secondly, the licensing system needs to ensure public confidence that non-compliance will be addressed swiftly and consistently. There are many circumstances where a STL landlord has ignored requests from the local authority to stop trading.

Thirdly, a Licensing system could make other actions such as compliance with tax laws easier as it simplifies data management and data sharing.

Q) Anything else? Is there anything else about the proposed licensing system, or its potential impact, that you would like to mention to the Committee. It would be helpful if you could keep any comments brief and provide evidence to support any claims made. Please set out any further comments in the box below:

Cockburn Answer:

In the City of Edinburgh, the issue isn’t what is coming but what has happened already. The current regulatory and enforcement regime is not fit for purpose. Many individuals and communities suffer from the expansion of STLs in their common stairs and neighbourhoods. The scale of the problem is so great that a substantial proportion of housing in central areas (and across the city too) has been given over to commercial short-term letting resulting in the depopulation of parts of the city.

We appreciate that those businesses and individuals who has operated STL may feel aggrieved but the proposed licensing system. However, their businesses seldom recognise the impact that they are having on individuals and on communities collectively. We accept that many STL businesses have operated for some time and that many have done so responsibly.

It is the total impact that needs to be addressed and we believe that the proposed licensing system will go some ways to dealing with it.