Fife Council Consultation on Short-Term Let Licensing Additional Conditions

Fife Council seeks the views of people and organisations to help shape the Short-term Let Licensing Scheme. Our online consultation survey is now available at the link below. The purpose of the survey is to consider which discretionary elements of the legislation should be included to reflect the Fife context.

The discretionary elements include issues such as:

  • Anti-social behaviour
  • Privacy and security
  • Overcrowding
  • Noise and nuisance
  • Littering
  • Repairs and maintenance
  • Damage
  • Unlawful activity

The survey will take 10-15 minutes to complete and individual responses will be treated confidentially.

The consultation will close on Sunday 12th June.

Click on this link to be taken to the survey

This ASSC has responded to the survey, and you can access our submission here: ASSC Submission to Fife Council Short Term Let Consultation

What are the positives of short-term letting?

Self-catering provides a £867m per annum boost to the Scottish economy, benefiting local communities the length and breadth of Scotland, supporting 23,979 FTE jobs. Given the importance of this sector to the Scottish tourism industry, which has experienced such a challenging time due to the impact of Covid-19, an appropriate regulatory balance is a necessity, as is a supportive environment to help businesses recover and flourish. The recovery of Scottish tourism will benefit small businesses, while responsible and sustainable tourism can help communities to recover too.

For Fife alone, Frontline Consultants have estimated that the traditional self-catering industry provides a £26m annual boost to the local economy [1] and the sector important source of accommodation for major events within the local council area, but also for any overspill from those held in Edinburgh. Tourism in Fife contributes approximately £566m annually to the Scottish economy, providing 9% of all employment in Fife [2], and the ASSC are proud of our members contribution towards this.

Short-term letting also adds to the diverse range of accommodation available within Fife and responds to consumer trends towards more authentic local experiencesThe fact that consumer trends are shifting towards short-term lets and self-catering is illustrated by the fact that hotel chains are moving into this market and why they list rooms on popular booking platforms like Airbnb and Booking.com.

Traditional short-term letting activity, such as self-catering, is a small business like any other, with dedicated full-time professionals striving to provide positive experiences for guests and visitors. Given the competition to maintain standards, holiday let owners often spend money more frequently on additional property maintenance than they would on their own property. Their guests spend money in local food shops, cafes, gift shops, galleries, restaurants, tourist attractions etc – many of which would simply be unviable without visitor spending.

Therefore, the impact of STL regulations with the aim of reducing the number of properties, will not be limited to self-catering and short-term letting overall as there will be a significant negative impact to businesses in the wider supply chain. This emphasises the value that short-term letting provides to the wider economy (especially within the context of Covid recovery) from the operators themselves, with negative knock-on effects on hospitality, local activity providers and local attractions. There will also be a negative impact on laundry providers and cleaning services and guests, not to mention property managers, and the onward tech supply chain.

Finally, for Scotland, and indeed Fife, to remain competitive as a leading tourism destination, it needs to be responsive and adaptive to consumer trends, both in respect of the range of accommodation available, as well as for more environmentally conscious options. Holidaying within Scotland, rather than jumping on a plane to a resort overseas, should not only be encouraged during a global pandemic – but as an environmental, social and economic positive going forward. Self-catering properties can, therefore, be viewed as a solution to sustainability, not the problem.

Indeed, as one of our members – Louise Dickins (owner of Dickins Edinburgh Ltd) – so ably put it: “Quite often in our rural locations [self-catering units) are the main choice of where to stay. And they’re an opportunity to stay in the heart of nature. They’re affordable to families too. Scotland is one of the most beautiful countries in the world and so we’re so lucky across the UK to be able to holiday here and not damage the planet in the process.” [3]

We believe that traditional self-catering provides both economic and environmental benefits for communities and the country as a whole. However, in order to ensure benefits are realised, self-catering needs to be actively encouraged as a sustainable option for travellers and an enabling regulatory landscape, not a draconian one, is critical.

[1] Frontline Consultants, Economic impact of Self-Catering Sector to the Scottish Economy (2021). Url: https://www.assc.co.uk/policy/economic-impact-study-self-catering-worth-867m-to-scottish-economy/

[2] Fife Tourism Partnership, Fife Tourism and Events Strategy 2019-2029. Url: https://www.fifetourismpartnership.org/site/assets/files/6214/fife_tourism_events_strategy_2019_29_digital-1.pdf

[3] ASSC, ‘Short-Term Lets Vital for Sustainable Tourism in Scotland’, Jan 2021. Url: https://www.assc.co.uk/short-term-lets-vital-for-sustainable-tourism-in-scotland/

What are the negatives of short-term letting?

Tourism is a mainstay of the Scottish economy; and self-catering is hugely important to Scottish tourism in terms of jobs, revenue, and world-class experiences offered to guests. To be such an essential part of Scotland’s tourism mix is even more remarkable for our sector when most self-caterers operate small or micro businesses. Our professional self-caterers are diligent and considerate business owners who are too often unfairly maligned. They do not, for example, ‘hollow out communities’, as some have claimed, but rather are part of local communities across Scotland and have been for many, many years.

The ‘negatives’ concerning short-term letting are often based on hearsay. Sadly, in recent years, due to the rise of the collaborative economy and online accommodation platforms, negative attitudes have increased with a hostile media and political climate which has been detrimental to hard-working professional self-catering operators who have operated in Fife for decades with minimal complaints or issues. This climate has, in turn, impacted upon community cohesion and led to bad policy decisions where short-term lets are used as a convenient scapegoat for long-term failures to address housing challenges within Fife and the rest of Scotland. We would respectfully encourage an evidence-based approach to short-term letting – as well as a holistic approach to tackling housing challenges – and not one that relies on perception or anecdote.

Edinburgh City Council Licensing Consultation – Briefing for ASSC Members

Edinburgh City Council Licensing Consultation – Briefing for ASSC Members

City of Edinburgh Council have launched a consultation into their prospective short-term let licensing regime. This will be the first of two consultations: this one focuses on the principles of the licensing scheme where the council will seek to hear from a wide range of stakeholders – from residents, community councils and trade groups. The results from this will then help inform the second consultation on the draft policy and conditions, which is expected in June.

Given the demands on your time, the ASSC has provided a briefing and suggested answers to help inform your submission.

We kindly ask you that you respond to the consultation by 10th June 2022 and circulate it to any family or friends who live in the Edinburgh area so we can maximise the positive response for those who work in, value and enjoy our capital’s self-catering industry.

The consultation can be accessed here: https://consultationhub.edinburgh.gov.uk/sfc/short-term-lets-2022/

Download the briefing here: ECC licensing consultation – briefing for ASSC members

Thank you once again for your time and support.

Fiona Campbell, CEO, Association of Scotland’s Self-Caterers.

Updated Cleaning Protocols and Sectoral Guidance for Self-Catering Properties and Short-Term Lets

PHS have had the opportunity to review the Cleaning Protocols and Sectoral Guidance for Self-Catering Properties in light of the stage we are at in the pandemic, alongside colleagues from Antimicrobial Resistance and Healthcare Associated Infection Scotland (ARHAI).

“In response to an earlier request to review these protocols (July 2021), we noted the excellent work done by ASSC in producing such thorough guidance for their members to ensure that they could restart business as safely as possible.  At that time, we also advised on a number of relaxations that we felt could be made to the protocols, based on changes to government and PHS guidance, as well as the progression of the pandemic. 

“We now feel that we are at a point where businesses should not simply return to pre-pandemic practices, i.e. business as usual, but should aim to build back better based on our increased awareness of good infection prevention and control practices.  The pandemic has highlighted the importance of many of the mitigations that were put in place for COVID-19.  These mitigations, however, have also shown to be successful in reducing the risk of other health outcomes during the pandemic and we feel that these should continue to be highlighted as best practice as we move forward.”

Advice is, therefore, to “build back better” by embedding some key principles into practices, and by referring to PHS’s COVID-19 information and guidance for workplaces and community settings.  

Emphasised measures should include (but needn’t be limited to):

  • Ensuring that there is a cleaning protocol in place for their properties, detailed with responsibilities assigned
  • Ensuring that frequently touched surfaces and sanitary areas are cleaned regularly (where buckets of water are used for cleaning/mopping, ensuring that these are changed regularly and always after cleaning sanitary areas)
  • Ensuring the use of products in line with manufacturer’s instructions
  • Ensuring maximisation of ventilation of properties – also encouraging the same from guests during their stay and upon departure where safe to do so
  • Encouraging good hand hygiene by staff, as well as continuing with the provision of hand hygiene products for customers

All of these measures are already highlighted within the existing protocols so should already be familiar to hosts and operators.

Cleaning Protocols

Download the Cleaning-Protocols: 2022 Cleaning Protocols V1

Download a word copy of a Risk Assessment form: Risk-Assessment 2022

Download a word copy of a Cleaning Checklist: Self-Catering-Cleaning-Checklist

If someone develops symptoms of a respiratory infection, including COVID-19, while on site

The symptoms of COVID-19 and other respiratory infections are very similar. It is not possible to tell if an individual has COVID-19, flu or another respiratory infection based on symptoms alone.

Symptoms of COVID-19, flu and common respiratory infections include:

  • continuous cough
  • high temperature, fever or chills
  • loss of, or change in, your normal sense of taste or smell
  • shortness of breath
  • unexplained tiredness, lack of energy
  • muscle aches or pains that are not due to exercise
  • not wanting to eat or not feeling hungry
  • headache that is unusual or longer lasting than usual
  • sore throat, stuffy or runny nose
  • diarrhoea, feeling sick or being sick

Further information is available via NHS inform.

Guests should inform you immediately if they develop symptoms of Covid-19 or any other respiratory illness while staying at your property.

While the individual is on the premises, the general measures to prevent spread should be followed. The affected person should return home as soon as they notice symptoms, following the latest NHS inform guidance.

Advice on cleaning of areas after an individual with symptoms of a respiratory infection, including COVID-19, or a positive COVID-19 test result has left a workplace or community setting is set out in Section 3.4.

If required, NHS Board Health Protection Teams can be approached for additional advice. They may also make the decision to engage in the handling of any individual cases, clusters, or outbreaks at their discretion, if they perceive a risk to public health.

In the event of an outbreak, people on the Highest Risk List should follow any individual advice they have been given by their clinician

See PHS guidance -paragraphs – 2.3 – 2.5: COVID-19 information and guidance for workplaces and community settings (publichealthscotland.scot)

Disclaimer: The content of the cleaning protocols is based on guidance from the HSE (Health and Safety Executive), WHO (World Health Organisation), European Centre for Disease Prevention and Control (ECDC), Global Biorisk Advisory Council (GBAC), and Centres for Disease Control (CDC), NIH (National Institutes of Health), NHS (National Health Service). These agencies do not endorse this content. This is guidance only, and we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability, or availability with respect to this content provided for any purpose. Any reliance you place on such information is therefore strictly at your own risk.