Short-term lets consultation: response analysis
Independent analysis of the responses submitted to the short-term lets consultation on a regulatory framework for Scotland.
1. Short-term lets are the subject of much debate, with short-term lets facilitated by collaborative economy digital platforms having grown rapidly and significantly in Scotland in recent years. On the plus side, this enlarges the range, choice and flexibility of available accommodation and there are benefits to the local economy and short-term let hosts and increased employment opportunities. On the down side, an increased number of short-term lets is seen to damage communities where local people can no longer afford to buy or rent residential properties, a loss of local shops and services, issues over the behaviour of some visitors in residential blocks, as well as complaints that short-term lets fail to contribute to services and infrastructure, and do not have the same tax treatment as traditional hotels and guesthouses. To exacerbate this issue, according to the consultation paper, there are also concerns that that increased numbers of short-term lets reduces the supply of available homes for longer term lets, which restricts supply for people who want to live and work in specific areas, and increase prices beyond the norms of the traditional housing market.
2. The Scottish Government's 2018-19 Programme for Government made a commitment to ensure that local authorities have appropriate regulatory powers to balance the needs and concerns of their communities with wider economic and tourism interests.
3. A Short-Term Lets Delivery Group was established in 2018 to assess the evidence base and the impact of short-term lets, identify the existing powers councils have and explore whether further measures are required. This Group comprises officials from across relevant areas of government including better regulation, community empowerment, consumer protection, housing, licensing, planning, tax and tourism.
4. On 28 April 2019 the Scottish Government published 'Short-Term Lets: consultation on a regulatory framework for Scotland'; which highlighted a regulatory approach that could involve registration and / or licensing of short-term lets, with the possible addition of a market-based mechanism to control numbers. The consultation asked for opinions on the regulatory framework, as well as on the types of short-term lets which should be regulated and the controls which should be applied.
5. The consultation contained 23 questions, all of which offered the opportunity for respondents to provide comments on specific issues in relation to short-term lets. Respondents could also answer seven optional questions about themselves; these included how they would classify themselves (affected resident, community organisation, guest, host, platform, hosting intermediary, hotel or B&B owner or other), how they heard about the consultation and the type of short-term let offered. There were also some specific questions for hosts about their type of let, whether they list their room/property(ies) on more than one platform, how many properties they had available for short-term letting in 2018, the approximate number of nights their room/property(ies) were occupied in 2018 and, for those with more than one property, whether these are in more than one local authority area in Scotland.
6. In total, there were 1,086 responses to the consultation, of which 111 were from organisations and 975 from individuals.
7. Respondents were assigned to respondent groupings in order to enable analysis of any differences or commonalities across or within the various different types of organisations and individuals that responded.
8. A list of all those organisations that submitted a response to the consultation is included in Appendix 1.
9. As Table 2 shows, the sub-groups with the highest number of responses were affected residents and hosts.
Table 2: Respondent Groups
|Host with 1 property||220|
|Host with 2+ properties||103|
|Hotel / B&B owner||16|
|Other (non short-term let) landlord||18|
10. Responses to the consultation were submitted using the Scottish Government consultation platform Citizen Space, or by email or hard copy. Seven respondents submitted a response which did not answer the specific questions; these responses have been analysed and incorporated into the report at the relevant sections.
11. The response received from the Association of Scottish Self Caterers (ASSC) was also submitted by another 34 respondents. Another response from PLACE Edinburgh was also submitted by another 14 respondents.
12. The Scottish Government also held a number of consultation events. Many of the issues raised at the consultation events were also raised in consultation responses, so these are not reported on separately; rather, they are referred to, where relevant, at each of the questions in this report.
13. It should be borne in mind that the number responding at each question is not always the same as the number presented in the respondent group table. This is because not all respondents addressed all questions. This report indicates the number of respondents who commented at each question.
14. Some of the consultation questions contained closed, tick-boxes with specific options to choose from. Where respondents did not follow the questions but mentioned clearly within their text that they supported one of the options, these have been included in the relevant counts.
15. The researchers examined all comments made by respondents and noted the range of issues mentioned in responses, including reasons for opinions, specific examples or explanations, alternative suggestions or other comments. Grouping these issues together into similar themes allowed the researchers to identify whether any particular theme was specific to any particular respondent group or groups. Where any specific sub-group(s) held a particular viewpoint, this is commented on at each relevant question.
16. When considering group differences however, it must also be recognised that where a specific opinion has been identified in relation to a particular group or groups, this does not indicate that other groups did not share this opinion, but rather that they simply did not comment on that particular point.
17. While the consultation gave all who wished to comment an opportunity to do so, given the self-selecting nature of this type of exercise, any figures quoted here cannot be extrapolated to a wider population outwith the respondent sample.
Structure of report
18. The chapters in this report follow the structure of the consultation paper. The following chapter looks at awareness of data on short-term lets. The next chapter examines the definition of short-term lets; and the final chapter considers views on the regulation of short-term lets in Scotland. The appendix to this report provides a list of organisations who responded to this consultation.
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