Festivals call for exclusion of residents’ homes from STL legislation

7 February 2023

Appearing today [07 February] before the Local Government, Housing and Planning Committee, the Edinburgh Festivals call for the Scottish Parliament and Scottish Government to look again at the inclusion of residents’ personal primary homes in the planned short term lets legislation.

The Festivals welcome plans by the Cabinet Secretary for Social Justice, Housing and Local Government to extend the licensing date for existing hosts, as a valuable opportunity to reconsider how the national framework is being interpreted across the country, and to adjust provisions at the margins to avoid unintended consequences.

Commenting ahead of her Committee appearance, Julia Amour, Director of Festivals Edinburgh said: “Edinburgh’s Festivals are frustrated at the extent of plans to regulate brief stays in residents’ personal primary homes - compared to commercial secondary lets where we understand the need for regulation - especially when the regulatory plans have no apparent regard to the collection of evidence or the assessment of impact.”

In speaking to the Local Government, Housing and Planning Committee, Ms Amour asked the Committee members to note the following:

Personal primary letting (home-sharing or home-letting) is being conflated with the more complex area of commercial secondary letting whereas it needs to be treated differently

  • Personal primary letting (home-sharing or home-letting) is being conflated with the more complex area of commercial secondary letting whereas it needs to be treated differently
  • Personal primary letting has no effect on the current housing crisis, given that it is simply individuals using their own homes rather than purchasing additional properties
  • Personal primary letting is being treated similarly to commercial lets, in terms of regulations and costs, having an effect on income opportunities for residents in their own homes during a cost of living crisis
  • The national regulation scheme excludes certain categories (eg visiting homestay students where arrangements have been approved by an educational institution) and so why not others (eg visiting homestay event workers)

The Committee are also asked to note that although the Cabinet Secretary has said temporary exemptions of up to six weeks do not need to comply with mandatory and additional licence conditions, the City of Edinburgh Council has decided to apply many such conditions to temporary exemptions for primary letting. “These local interpretations highlight that the provision in the framework for local temporary exemptions is not achieving its intended purpose, and we now have an opportunity to look at this again and apply an exclusion at national level”, said Ms Amour.

The Edinburgh Festivals are concerned that these developments will be a serious disincentive to city residents who want to open their own homes to guests for a brief period. Without the use of primary home lets, the Festivals estimate that 27% of people in the city for August peak season would not be able to find accommodation, with such lets of particular importance to the workers, artists and performers who transform Edinburgh into the world-leading festival city. The Edinburgh Festival Fringe Society estimates a third of their programme could be lost in 2024. This contraction would obviously have a negative impact on the 4,000+ jobs and over £200m in direct additional economic impact which the Festivals bring, as well as weakening the wider leisure and visitor economy employing 44,000 in Edinburgh alone.

In conclusion, Ms Amour said: “We ask the Committee to recommend that Scottish Government consider excluding primary residential letting activity (home-sharing and home-letting) for major festivals and events from the proposed legislation, in the knowledge that such activity has no effect on the housing crisis in the city and will safeguard the major economic, cultural and social opportunities that the festivals provide to city residents and to Scotland as a whole.”


Notes to Editors

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