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

Business and regulatory impact assessment (BRIA) relating to the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2021 (“the Licensing Order”) and the Town And Country Planning (Short-Term Let Control Areas) (Scotland) Regulations 2021 (“the Control Area Regulations”).

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.



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