Short-term lets consultation: response analysis

Independent analysis of the responses submitted to the short-term lets consultation on a regulatory framework for Scotland.

Design Principles for a Regulatory Framework

173. The Scottish Government has set out 10 design principles, building on the principles in the Scottish Regulators' Strategic Code of Practice (which sets out five key principles of good regulation: proportionate, transparent, accountable, consistent and targeted). Question 16 asked,

Q16: 'Do you have any additions or amendments to the proposed design principles?'

174. A total of 377 respondents commented at this question. The following table provides a breakdown of those who chose to respond.

Table 20: Q16

Affected resident 190
Community organisation 31
Guest 23
Host with 1 property 78
Host with 2+ properties 42
Platform 2
Host intermediary 10
Hotel / B&B owner 5
Local authority 14
Other (non short-term let) landlord 6
Other business 16
Other 47
Total organisations 60
Individuals 317
Total respondents 377

175. The most common theme, across all sub-groups, in response to this question was agreement with the principles (cited by a large majority of respondents). A few respondents (cited by higher numbers of affected residents) commented on the need for the design principles to show greater consideration of residents and communities and housing needs, with less focus on the tourism sector, with a few respondents making specific reference to Edinburgh. A similar number of respondents noted that the framework needs to be well regulated and robustly enforced; this was mentioned by more affected residents and community organisations.

176. A few respondents identified additional principles that should be included:

  • Controlling the number of short-term lets, with suggestions to reduce or limit the number of short-term lets; limit short-term lets to specific zones or limit the number of short-term lets per year.
  • Having a balance between hosts offering short-term lets and long-term lets so as to make long-term lets more appealing to owners of properties; to be fair across all tenures.
  • Referring to rural areas separately.
  • For any design principles to be simple and not overly complicated.
  • For clarity so as to minimise any administrative burden and ensure compliance.
  • To include equalities, climate change and sustainable communities.
  • To be transparent.
  • To prioritise the quality of life over the economy, as place and housing affordability are both important.
  • Balance the needs of local communities and residents against the impact of short-term lets so as to contribute positively to the maintenance of vibrant local communities.
  • Supporting competition, consumer choice and innovation.
  • To avoid or minimise unintended consequences for the housing system.

177. Other comments made by small numbers of respondents included:

  • A need for a degree of compromise as it can be difficult to design a framework that will satisfy all 10 design principles.
  • There is no need for this framework as it will damage the tourist sector and introduce minimal benefits.
  • These principles do not need to be Scotland-wide and there needs to be regional variations. These would be more relevant in Edinburgh and Glasgow than in rural areas. Linked to this, there were a few calls for local authorities to have discretionary powers with a capacity to adopt different approaches to meet local needs.
  • There is a need for a licensing scheme, with a transitional phase for established operators.
  • All short-term lets should be banned.
  • Learn lessons from other European countries.
  • Exclude those who share their properties from any new regulations.
  • Local authorities need appropriate resources.
  • There was a degree of support for applying the existing landlord regulations to short-term lets as this infrastructure is already in place. However, some respondents felt that current legislative powers are not fit for purpose; with conflicts between licensing and planning; and the system is slow.



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