If implemented, the scheme could cost a modest three-bedroom self-catering property £2,000, far in excess of the Scottish Government’s estimate.
The document points out that the heavy-handed scheme remains completely unfit for purpose even in its revised form and has been unable to convince the industry of the data supporting it.
It also highlights that only superficial changes have been made to support self-catering operators or B&Bs
The ASSC has also argued that the proposals will have a hugely detrimental impact on Scotland’s tourism sector, particularly in rural and remote areas, and form part of an ill-fitting and overreaching approach that fails to consider or address localised issues.
Self-caterers have also drawn attention to legal issues with the licensing scheme, suggesting that it is incompatible with the Provisions of Services Regulations, European Convention on Human Rights, and the Scottish Regulator’s Strategic Code of Practice on several serious points.
The licensing scheme, combined with the control area plans which may be imposed on operators in Edinburgh, would comprise the most restrictive framework in Europe which has the potential to scupper the industry’s recovery in the aftermath of the COVID-19 pandemic.
Rather than continuing along this path, which threatens the future of a key part of Scottish tourism, the ASSC has urged legislators to consider a mandatory programme of registration containing health and safety provisions, an approach that has near-universal industry support.
Association of Scotland’s Self-Caterers Chief Executive, Fiona Campbell, said:
“The Scottish Government’s licensing proposals continue to represent a real threat to Scottish self-catering and are comprehensively and demonstratively unfit for purpose.
“Rather than this blunderbuss approach, the government should listen to our concerns and evidence-based insight, and seriously consider the industry’s mandatory registration scheme.”
“While up until now this process has been a string of disappointments and let-downs, it is not too late for the government to change its course, stay to true to its pre-election promises to the industry, and back small business for a sustainable recovery from Covid-19.”
Read the Consultation Response: ASSC Consultation Response 13.8.21