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.