Short-term lets - licensing scheme and planning control area legislation: draft business and regulatory impact assessment (BRIA)

Annex E - principal concerns expressed by ASSC Members

Members of the ASSC expressed the following concerns at the Autumn Talk on 29 September 2020 and in written questions relevant to the BRIA:

• The timing of the regulations, in the context of COVID-19 and the impact of the pandemic on the sector, and the postponement of the Transient Visitor Levy.
• Concerns about the workload for councils and their capacity to manage licence and planning applications without delay or impact on this or other schemes or applications.
• Questions about the cost of compliance for hosts, including planning costs.
• Questions around how long the application process would take.
• Concerns about rising overheads (such as cleaners, day-to-day runners, general upkeep).
• Concerns about the effect of loss of income to local economies if there was to be a reduction in tourism.
• Questions about whether Scottish Government had considered running a pilot or an alternative form of regulation, such as a registration scheme.
• Questions about how the licensing scheme would relate to existing quality indicators and accreditation, including the ASSC’s code of practice.
• Questions about the cost and impact of some of the proposed discretionary conditions.

These questions are addressed in this BRIA and the report on the 2020 consultation.