NTBCC submitted the following in response to the consultation at Short-Term Lets 2024 – City of Edinburgh Council – Citizen Space on 14 October 2024.

Introduction

1 Your details

2 Who are you responding as?

NTBCC Licensing

General

3 Please give us your comments on the guidance on applying for a short-term let or exemption.

The guidance should make it clear that Temporary Exemptions may be granted for a period not exceeding 6 weeks in any period of 12 months; likewise for Temporary Licences.

The concept of temporary ‘exemption’ is misleading however. The guidance suggests that a STL licence isn’t required whereas exemption(s) refer to lighter requirements around obtaining a STL licence while the mandatory conditions still apply.

The concept of ‘secondary’ letting is misleading too. Secondary suggests that the property in question might not be the first one operating in that mode, which perhaps explains why some applicants are found to apply for Home Letting &/or Home Sharing instead of Secondary Letting in some instances?

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Adapted from the post on the Council’s Consultation Hub, the Council’s Regulatory Committee is interested in the public views on the short-term lets licensing policy since its introduction in October 2022.

Closing date for online submissions:  14 October 2024.

Should you wish to share your views/concerns with NTBCC, please contact us by email to licensing@ntbcc.org.uk

As a result of the Civic Government Scotland Act 1982 (Licensing of Short Term Lets) Order 2022 being passed by the Scottish Parliament, local authorities in Scotland were required to introduce a mandatory licensing scheme for properties operating as short-term lets. The licensing scheme opened on 1 October 2022, with all short-term lets required to be licensed by January 2025.

As part of the licensing scheme, the Council has published a licensing policy for short-term lets in the city. These properties have to meet a minimum safety standard. The Council also added additional conditions to licences to respond to local circumstances.

Four types of licence can be issued for short-term let accommodation. These are:

1. Home sharing;
2. Home letting;
3. Home sharing and home letting; or
4. Secondary letting

Home sharing and home letting happen in a host or operator’s main home, and secondary letting is where the property is not the host or operator’s main home. The licence types are defined in legislation and the Council cannot exempt certain types of STL accommodation from the requirement to obtain a licence.

Full details can be found here: Short-Term Lets 2024 Consultation – City of Edinburgh Council – Citizen Space

Since the introduction of a licensing scheme for short-term lets in October 2022, the Council has received over 4,000 applications.