Industry News: ASSC Urges Highland Self-Catering Operators to Respond to Planning Control Area Consultations

The proposals cover:

• the Highland Rural Short-Term Let Control Area; and
• the Inverness City Short-Term Let Control Area.

The ASSC has now submitted a detailed and substantive response raising serious concerns regarding:

• the lack of demonstrated housing benefit arising from existing Control Areas;
• the absence of meaningful economic impact assessment;
• the failure adequately to distinguish between self-catering accommodation and broader “STL” categories;
• and the significant legal uncertainty now facing existing lawful operators.

The organisation has also published a detailed operator briefing to assist businesses in responding directly to the consultations.

“It is vital that operators respond”

The ASSC is warning that organised campaign and housing advocacy groups are already actively encouraging supporters to respond in favour of expanded Planning Control Areas.

As a result, the organisation says it is essential that self-catering operators and tourism-dependent communities also make their voices heard.

Fiona Campbell MBE, Chief Executive of the ASSC, said:

“If operators do not respond, there is a real risk that the consultation becomes dominated by broad assumptions, negative narratives and generalised statistics rather than lived experience, evidence and local reality.

“Self-catering businesses are not abstract policy concepts. They are real Highland businesses supporting real Highland communities.

“Across the Highlands, self-catering accommodation supports local jobs, local supply chains, rural diversification and community sustainability in areas where tourism is often the economic lifeblood of the community.”

“The issue is not whether housing pressures exist”

The ASSC says its position is not opposition to regulation in principle.

Rather, the organisation argues that any regulatory framework must be:

• evidence-led;
• proportionate;
• legally robust;
• and economically balanced.

The ASSC submission argues that Highland Council has not yet demonstrated:

• measurable housing benefit arising from the existing Badenoch and Strathspey Control Area;
• sufficient causal evidence linking self-catering accommodation to wider demographic challenges;
• or that the economic costs of further expansion are proportionate to the public benefit claimed.

The submission also raises concerns regarding:

• the interaction between planning and licensing;
• retrospective procedural burdens on longstanding lawful operators;
• and potential implications under Article 1 Protocol 1 (“A1P1”) rights and the Provision of Services Regulations 2009.

Grandfathering and Existing Operators

The ASSC is calling for clear statutory protection for existing lawful operators, particularly those operating prior to the introduction of the 2022 STL licensing framework.

The organisation argues that many operators:

• commenced trading lawfully and transparently;
• were never previously advised that planning permission was required;
• and are now fully compliant with licensing requirements.

The ASSC says that:

• if existing lawful operators are properly protected through grandfathering arrangements, the industry can engage constructively with a future framework;
• however, if longstanding lawful businesses remain exposed to uncertain planning risk and retrospective procedural burden, the industry cannot support the proposals in their current form.

“Self-Catering” and “STL” Are Not the Same Thing

The ASSC briefing also highlights concerns regarding the increasingly broad and negative use of the term “STL”.

The organisation argues that:

• “self-catering accommodation” is widely associated with tourism, hospitality and local economic contribution;
• while “STL” is increasingly used as shorthand for housing loss and speculative investment;
• despite the fact that the same property may be described by both terms.

The ASSC says the consultation must properly distinguish between:

• hospitality-led self-catering businesses;
• home sharing and home letting;
• conventional secondary lets;
• and properties genuinely capable of contributing to mainstream residential housing supply.

Operator Briefing Published

The ASSC operator briefing includes:

• guidance on responding to the consultation questions;
• key evidence and messaging points;
• advice on making responses personal and locally grounded;
• and recommendations for uploading supporting PDFs containing photographs, reviews and evidence of local economic contribution.

Operators are strongly encouraged to:

• respond to BOTH consultations;
• explain their local contribution;
• and provide real-world evidence of how their businesses support Highland communities and economies.

Respond to the Highland Rural STLCA Consultation

Respond to the Inverness City STLCA Consultation