Category: Policy

Local Government Election Manifesto 2022

The Association of Scotland’s Self-Caterers has launched its first-ever local government election manifesto.

Self-Catering: Local, Reliable, Sustainable: The ASSC’s Manifesto for Scotland’s Local Government Elections sets out the association’s four key priorities for Scottish self-catering as it recovers from the impact of the COVID-19 pandemic.

In the manifesto, self-caterers are urging local politicians to commit to minimising the burden of short-term let licensing by working closely with small business, monitoring the impact of the policy, and pledging not to impose additional conditions on already hard-pressed businesses.

The manifesto also calls for an evidence-based approach to the use of short-term let control areas and for such decision-making not to be based on crude hearsay and anecdote.

Additionally, the ASSC is asking those who find themselves in power to reject the introduction of local tourism levies, should the power to do so flow to them from Holyrood.

Finally, Scotland’s self-caterers are imploring local councils to promote self-catering as a sustainable tourism option in their areas, drawing particular attention to the role that the industry has in helping the environment, and local economies, flourish across Scotland.

In launching Self-Catering: Local, Reliable, Sustainable, the ASSC hopes to encourage a step-change in thinking around short-term lets, cut through the often-inaccurate rhetoric surrounding what self-caterers do, and help local governments across Scotland understand and appreciate that there is a bright future for tourism in their areas, with self-catering playing a vital role.

Download the Manifesto: ASSC 2022 Manifesto

Association of Scotland’s Self-Caterers Chief Executive, Fiona Campbell, said:

“I am thrilled to launch our manifesto ahead of these vital local elections.

“Hardworking and dedicated self-caterers across Scotland have had a really tough time throughout the pandemic and we need the help of our local politicians to get us back to doing what we do best.

“I would urge everyone standing in these elections to consider our moderate, sensible, and evidence-backed proposals and to think about the benefits that they will have for the communities they wish to represent.”

ASSC Response to the National Planning Framework (NPF4) Consultation

The Association of Scotland’s Self-Caterers (ASSC) welcomes the opportunity to respond to the Scottish Government’s consultation on the fourth National Planning Framework (NPF4).

We have restricted our submission to commenting on the following section – Policy: 17 Sustainable Tourism.

We would remind policymakers that the traditional self-catering sector is dealing with an increased regulatory burden – through the introduction of a mandatory licensing system as well as planning control areas – in what are already challenging circumstances for Scottish tourism. Taken collectively, we have already argued in numerous consultation responses that these policies will entail a materially negative impact for Scotland’s tourism sector, will cost jobs and livelihoods, and will reduce the number of short-term lets available without increasing housing provision.

The ASSC firmly believes that there should be no further short-term let regulations in Scotland until the cumulative effect of licensing and control areas has been fully analysed to ensure there are no unintended consequences and that they are clearly meeting policy objectives. There needs should be clear evidence that existing planning law, including control areas and local development plans, has improved access to affordable housing. To this end, the ASSC have submitted metrics to the Scottish Government’s Short-Term Let Working Group in respect of the upcoming review in Summer 2023 of short-term let licensing.

National Planning Framework 4 – ASSC response

18th March 2022

ASSC’s Rebuttal of Evidence Provided by Witnesses on 14th December 2021

The opinions provided on 14^th December to the Local Government, Housing and Planning Committee – for that is all they were; certainly not evidence – were extremely shocking both in terms of tone and content. The blatant hostility and antipathy levelled at small tourism accommodation providers was astonishing to behold. The self-confessed lack of evidence from supporters of the legislation provides nothing to back up their position, and yet is being given equal weight to the hard data and evidence provided by industry.

The Association of Scotland’s Self Caterers (ASSC) has received numerous comments from members across Scotland expressing their shock at the vitriol expressed by the witnesses towards small tourism accommodation owners. These are micro businesses caught up in the perfect storm of the damaging economic impact of COVID, in an already fragile rural economy – and now impacted by regulations whose aim has been expressly stated as being to ‘manage [them] down’; or, in other words, to put them out of business.

Due to the level of unsubstantiated claims, generalisations and misrepresentations of our sector, the ASSC were compelled to provide a rebuttal so that the Committee have a full appreciation of the facts.

Further to its consultation responses, as well as written evidence to the LGHP Committee, the  ASSC has provided evidence that short-term let licensing legislation will detrimentally effect thousands of operators, whether self-caterers or indeed home sharers, for no measurable benefit.

Our key concerns about the evidence provided by witnesses covers seven themes:

1. Lack of understanding of sector
2. Economic Impact
3. Lack of data
4. Impact on Local Authorities
5. Anti-social Behaviour
6. Housing
7. ASSC’s Registration and Exemption Proposal

Summary of Concerns

• There is a general consensus from witnesses that the vast majority of operators are professional and compliant, yet there is also an assumption that operators are “unscrupulous”, “poorly regulated or poorly managed”. These contradictory positions cannot hold.
• ASSC members, many of whom have been operating for decades, refute the allegation that the sector is the “Wild West” and at they are “unscrupulous”.
• The accusation of drug dealing, sex trafficking and puppy farming is offensive and unsubstantiated.
• The value of the sector has been undermined and witnesses suggest that is provides no value to the Scottish economy or local communities – our businesses will seemingly not be missed.
• Witnesses evidenced a lack of understanding of the traditional accommodation sector or short-term lets, with repeated discussion regarding one online platform as being ‘the industry’.
• Witnesses evidenced a lack of understanding of existing regulations – in relation to anti-social behaviour and health and safety, as well as evidencing confusion of what it is the legislation is attempting to address
• There is no evidence or data of the impact of short-term lets on housing
• There is no evidence whatsoever to underpin a “reason of general interest”, which is legally required when introducing licensing legislation
• Discussion regarding global corporations and large businesses does not reflect ASSC or Scottish Bed & Breakfast (SBBA) membership – they are micro businesses that have been part of communities for decades
• Contrary to assertions from the panel that industry has fought against regulation, the ASSC proposed registration, transparency and health and safety compliance in 2017
• Witnesses confirmed that the legislation will prove challenging to local authorities
• Only one local authority perspective (Edinburgh, a longstanding supporter of licensing) has been provided as oral evidence, while the Committee’s survey results and consultation responses show considerable concern from other local councils about the impact of licensing.
• Toxic comments from witnesses looking at cases in isolation have caused deep concern from professional legitimate businesses across Scotland

Read the Rebuttle in Full Here:

Rebuttal of Evidence Provided by Witnesses on 14th December 2021