Short-term lets consultation: response analysis

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

The Impacts of Short-term Lets

64. Question 5 of the consultation paper asked,

Q5: 'Do you have any comments on the positive or negative impacts of short-term lets?'

65. A total of 979 respondents commented at this question. The following table provides a breakdown of those who chose to respond.

Table 9: Q5

Affected resident 543
Community organisation 59
Guest 56
Host with 1 property 197
Host with 2+ properties 95
Platform 2
Host intermediary 17
Hotel / B&B owner 15
Local authority 15
Other (non short-term let) landlord 16
Other business 28
Other 111
Total organisations 93
Individuals 886
Total respondents 979

66. Overall, views were split; affected residents, community organisations and other (non-short-term let) landlords cited mainly negative effects, and hosts, platforms and hosting intermediaries on the other pointed out predominately positive impacts. Guests, local authorities and other businesses not related to short-term lets gave a mix of positive and negative impacts. Overall, higher numbers of respondents made comments about negative impacts than positive impacts.

67. The negative impacts described by respondents to a large degree focused on problems accruing to the local community and long term residents of areas (particularly central areas of Edinburgh) where short-term lets are commonplace. A small minority of respondents (but large minorities of affected residents, community organisations and local authorities) commented on the following issues:

  • Damaging community effects including the loss or 'hollowing out' of communities due to a preponderance of visitors with no vested interest in the locality visited; a lack of care for resident communities by hosts was also mentioned.
  • An increase in antisocial behaviour including loud noise, smoking, drugs, alcohol and littering, and other disturbances due to 24 hour access of properties (comings and goings, suitcases clattering, etc.).
  • Negative effects on the lives of residents such as increased poor health and wellbeing, increased isolation, disturbed sleep patterns due to noise at unsocial hours, a general lack of privacy and security and safety concerns owing to the prevalence of strangers.

68. The issues above were particularly described in relation to the impact of short-term lets in tenements and other buildings with communal areas. Many other problems associated with short-term lets in tenement buildings or similar were reported, including the following:

  • Non-maintenance of common areas by short-term let landlords, including ignoring mutual repairs.
  • Residents being left with the burden of cleaning common areas.
  • Increase in wear and tear due to increased footfall caused by short-term let guests.
  • Inability to contact absentee hosts, owners or agencies.
  • Key safe or key box issues or problems associated with shared keycode numbers (e.g. perceived as a security risk, regarded as unsightly and frequently installed without residents consent).
  • Problems with obtaining home insurance, insurance validity or elevated costs of home insurance because of the presence of short-term lets.
  • Security issues related to common stairwells.
  • Noisy or disruptive conversions or renovations.

69. The other common theme expressed by those stating negative impacts was the effect on property pricing and availability in short-term let areas. In particular, a small minority of respondents, including the majority of responding local authorities, remarked upon the loss of long-term residential accommodation, making it more difficult for residents to obtain housing, both in terms of supply and affordability. Factors involved in this were pinpointed, including:

  • Rents for long-term residents being driven up.
  • Rising property prices, the latter particularly impacting upon first time buyers.
  • Instances of long-term residents being asked to move out of homes due to landlords changing to short-term letting; some respondents, notably a large minority of other (non short-term) landlords, cited regulatory burdens in favour of long-term tenants and the loss of tax relief on mortgage interest as being a motivation to change to short-term letting.

70. A small minority of respondents, spread across all sub-groups, focused on the above factors as applying to impacts on Edinburgh specifically; there was a general feeling that too many short-term lets were causing problems within the housing rental and purchase markets. Small numbers of respondents added that there was a loss of the genuine 'Edinburgh' experience for visitors, complaining that the city centre was becoming like a 'theme park' due to the high proportion of tourists. A few respondents, most notably including a small minority of hotel and B&B suppliers and other (non short-term) landlords, pinpointed similar negative effects in rural areas (e.g. Skye, Arran, NW Scotland) in terms of the loss of residents' housing or unaffordability for residents. As noted by a community organisation:

"… a property that is being let out to holiday-makers is not providing a permanent residential home. We are all well aware of the lack of housing in our city; we are aware of hundreds of households living in temporary accommodation because a sustainable home isn't available for them. We are aware of the complete unaffordability of the housing market in Edinburgh and the enormous challenges of getting a foothold on the property ladder. We are aware that the Scottish Government spends substantial sums of money supporting first time buyers on to the property ladder, and at the same time there are substantial numbers of properties that should be providing relatively affordable homes that are given over to holiday-makers."

71. Other negative impacts attributed to short-term lets were discussed by small numbers of respondents (mainly affected residents and community organisations) and included:

  • Additional strains on local infrastructure including transport, parking, policing and amenities generally.
  • Increased rubbish generation; particular issues mentioned included incorrect recycling by visitors, bad refuse management and overflowing bins.
  • Lack of regulations, or lack of enforcement of regulations, for short-term lets (e.g. health and safety checks, lack of consents obtained for change of property use); in particular cited by a small minority of local authorities.
  • Perceptions of unreliable taxation of short-term lets (e.g. undeclared income, reduced council tax for second home owners, no requirement to pay business rates due to owners applying for small business relief, and tax avoidance).
  • Short-term lets being over-occupied (i.e. being turned into 'party flats', with one or two-bed flats hosting too many people at once).
  • Concerns about properties being unoccupied seasonally or for large parts of the year.
  • Negative aspects attributed to online accommodation platforms; among more general comments about regulation being required, some respondents cited impacts on the commercial viability of B&B's, hotels, guest houses and more traditional holiday lets.

72. A small minority of respondents suggested remedies for the negative impacts; in particular there was a focus on the need for short-term lets to be well-regulated or subject to regulatory control, most notably by guests and other (non short-term let) landlords. Suggestions included that short-term lets should have the same regulatory requirements as long-term lets (to help level the playing field), health and safety checks should be carried out equivalently to any other type of accommodation, and that regulation should be tightened to be on a par with that of cities which have tight regulatory action such as Barcelona, Amsterdam and San Francisco. Furthermore, a few respondents (particularly affected residents) thought that there needed to be limitations or controls on the numbers of short-term lets. That said, a few respondents stated that they were unconcerned about people renting out a room in their own property and that this scenario should be treated differently. A small number of respondents also noted the need to clearly communicate requirements to short-term let owners.

73. Small numbers of respondents, spread across all categories, made the following other suggestions for improving the current situation:

  • The instigation or implementation of a licensing system and / or landlord registration system.
  • Greater accountability of, and better management by, those renting out short-term lets.
  • Regulation of online accommodation platforms, given their expansion from peer-to-peer arrangements and sharing to letting of entire properties.
  • Need for planning permission when there is a change of use of properties.

74. However, concerns about strict regulation were voiced by a few respondents, mainly by small minorities of hosts with more than one property and hosting intermediaries; arguments against regulation were that this would be to the advantage of the large commercial operators, it would result in a reduction in visitor numbers, the economics of short-term letting businesses would be negatively affected, jobs would be lost; and that educating hosts perhaps via industry accreditation would be a better approach to adopt.

75. A few respondents, particularly community organisations, cited general concerns about 'over-tourism' and its impact on the environment and infrastructure, whilst others in very small numbers saw a need for further research and analysis about the benefits of short-term let tourism against the displacements caused by it.

76. There were also some queries at events as to whether owners are aware of the need to have the appropriate insurance in place; as well as some suggestions of a need for owners to check their title deeds or mortgage documentation and ensure they are permitted to run a short-term let.

77. A large minority of respondents who described positive impacts focused on three main themes, each discussed by a small minority of those giving a response to the question. The key sub-groups to focus on these positive impacts were hosts, host intermediaries, and local authorities.

78. Firstly, short-term lets either lead to increased tourism and tourist revenue, or support an existing increase in tourism, e.g. by providing required extra tourist accommodation, particularly enabling larger visitor groups and families to stay together.

79. Secondly, short-term lets help to provide economic benefits, particularly at a local level, for example by providing business for small enterprises such as pubs, restaurants, cafes and grocery shops, and by providing employment for people such as agents, cleaners and tradespeople. As noted by another (non short-term let) business respondent:

"Holiday lets and short-term lets are an important part of Scotland's flourishing tourist sector and provide a significant economic boost to the country, as highlighted in [the] study by Frontline Consultants, 'Economic Impact Assessment of Short-Term Lettings on the Scottish Economy', which was commissioned by the ASSC. Overall, it demonstrated that there are 16,949 self-catering holiday and short-term let properties in Scotland. The self-catering sector represented 3.4million visitor nights per year where 1.8million are non-Scottish visitors. The annual direct visitor spend is equal to £723.3 million (£470.1 million from non-Scottish visitors). Traditional self-catering in Scotland supports 10,725 direct FTE jobs and self-catering/short-term rental provides £205.8 million in direct GVA contribution."

80. Thirdly, short-term lets provide an alternative positive experience for visitors, in terms of providing a 'home from home', enabling self-catering, its affordability compared to other options and by giving a chance to experience local culture; these points were highlighted roughly equally by respondents representing all short-term letting types, and notably by a large minority of guests.

81. Other positive impacts described by a few respondents included the following:

  • Benefits for rural or less populous areas (e.g. by ensuring housing that would otherwise lie empty is used, including both holiday homes and non-renovated housing that are brought back into habitable use, by providing valuable income for locals, and by helping to increase visitor spend). Areas specifically mentioned in this regard included the Highlands, Argyll & Bute, Eilean Siar and Arran.
  • Short-term let properties tend to be better maintained (than, for example long-term rentals); reasons for this included high visitor expectations for accommodation and the owner having a vested interest in them.
  • Provision of a flexible accommodation option for non-tourists such as short-term workers (e.g. film and TV workers), students, conference attendees and festival participants.
  • Advantages provided by online accommodation platforms (e.g. 'democratisation', in the sense of enabling mass participation, of short-term lets and the self-policing of short-term lets through online reviews).
  • Benefits for hosts including: host wellbeing (e.g. for mental health reasons and because of social aspects), the opportunity to meet new people, the opportunity to stay in the property themselves (e.g. for second-home owners visiting family), working flexibility (e.g. for carers and families with children) and the extra income (for home sharers or swappers) enabling the owner to continue living in their own home.
  • Perceptions that short-term let guests normally behave better (e.g. less noisy and more respectful of neighbours) than long-term renters or local people.



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