Letter to the First Minister

20th December 2021

Dear First Minister,

THE SCOTTISH GOVERNMENT’S SHORT-TERM LET LICENSING SCHEME

These are challenging times for our country – for individuals, families, society, and the economy. As you appreciate, the Scottish tourism sector has been particularly badly affected by the pandemic. In recent days, the tourism accommodation sector has experienced widespread cancellations as a consequence of government announcements. Our industry has done all we can to support the Scottish Government throughout the pandemic – but so many of our businesses are now in survival mode.

While there will always be circumstances beyond the government’s control, there are options we can take – working collaboratively in this endeavour – which can ease the burden for those under pressure. Changing short-term let regulation can and will make a major and lasting difference to thousands of legitimate small and micro businesses throughout Scotland.

That is why we collectively welcomed the withdrawal of the Scottish Government’s short-term let licensing regulations in February 2021 as they were widely recognised as not fit for purpose. Sadly, the revised regulations remain unfit for purpose in December 2021 and come at the worst possible time. Even in the pre-Covid trading environment, a licensing scheme along the lines envisaged would pose major difficulties. But given the ongoing impact of the pandemic, with Scotland facing “a tsunami” of omicron cases as you note, this will be devastating for so many longstanding, diligent and professional businesses operating on small profit margins.

Right now, businesses offering short-term lets are facing a perfect storm: first, the looming imposition of licensing at a national level; second, the possibility of planning control areas at a local level; and third, the spectre of additional Covid-19 uncertainty and restrictions. To compound matters, the recent Draft Budget made reference to the resumption of work on a visitor levy. Those who have been treading water now fear being totally submerged.

Make no mistake, this onerous and costly licensing scheme will cause many traditional self-caterers and B&B operators to leave the sector – hitting the supply chain and local economies in the process – and reducing the diversity of accommodation available and Scotland’s capacity to welcome visitors to our country.

But it doesn’t have to be this way. There is a cross-industry backed, viable and legally sound alternative regulatory proposal for mandatory registration, devised by the Association of Scotland’s Self-Caterers and endorsed by VisitScotland, which can meet the government’s policy objectives in a more cost-effective and proportionate manner. Just to re-emphasise, industry is not averse to regulation; we simply question the timing and specific nature of your proposals. We want to work with the Scottish Government to get this right to protect jobs and livelihoods at this critical time.

This is an issue of significant importance to our industry and members operating businesses the length and breath of our country. We earnestly hope you share our commitment to helping Scottish tourism’s recovery from the pandemic and therefore urge you to listen to the united voice of small business and reassess this damaging licensing system without delay.

Yours sincerely,

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

Professional Association of Self-Caterers UK: Alistair Handyside, Chairman

Scottish AgriTourism: Caroline Millar, Sector Lead

Scotland’s Best B&Bs: Gordon Bulloch

Scottish Bed & Breakfast Association: David Weston, Chairman

Scottish Land & Estates: Simon Ovenden, Policy Officer