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Agenda Document Pack - Economy and Infrastructure Committee - 28/08/2024

Perth and Kinross Council · 28 August 2024
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Securing the future…  Improving services
 Enhancing quality of life  Making the best use of
public resources
Council Building
2 High Street
Perth
PH1 5PH
21/08/2024
A hybrid meeting of the Economy and Infrastructure Committee will be held in the
Council Chamber on Wednesday, 28 August 2024 at 09:30.
If you have any queries please contact Committee Services on (01738) 475000 or
email Committee@pkc.gov.uk.
THOMAS GLEN
Chief Executive
Those attending the meeting are requested to ensure that all notifications are
silent on their device and other devices are in silent mode.
Please note that the meeting will be broadcast online and recorded.  The
recording will be publicly available on the Council’s website following the
meeting.
Members:
Councillor Eric Drysdale  (Convener)
Councillor Jack Welch  (Vice-Convener)
Councillor Hugh Anderson
Bailie Alasdair Bailey
Councillor Steven Carr
Councillor Stewart Donaldson
Councillor John Duff
Councillor Angus Forbes
Councillor Ken Harvey
Councillor Noah Khogali
Councillor Grant Laing
Bailie Claire McLaren
Councillor Willie Robertson
Councillor Frank Smith
Councillor Colin Stewart
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Economy and Infrastructure Committee
Wednesday, 28 August 2024
AGENDA
MEMBERS ARE REMINDED OF THEIR OBLIGATION TO DECLARE ANY
FINANCIAL OR NON-FINANCIAL INTEREST WHICH THEY MAY HAVE IN ANY
ITEM ON THIS AGENDA IN ACCORDANCE WITH THE COUNCILLORS’ CODE
OF CONDUCT.
1 WELCOME AND APOLOGIES
2 DECLARATIONS OF INTEREST
3 MINUTE OF MEETING OF ECONOMY AND INFRASTRUCTURE
COMMITTEE OF  29 MAY 2024 FOR APPROVAL
(copy herewith)
5 - 8
4 OUTSTANDING BUSINESS STATEMENT (OBS)
(copy herewith 24/232)
9 - 10
5 ROAD GULLY CLEANSING
Report by Strategic Lead - Environment and Infrastructure (copy
herewith 24/233)
11 - 28
6 PROPOSED WAITING RESTRICTIONS
Report by Strategic Lead - Environment and Infrastructure (copy
herewith 24/234)
29 - 48
7 SHORT-TERM LET CONTROL AREA PROPOSAL
Report by Strategic Lead - Economy, Development and Planning
(copy herewith 24/235)
49 - 184
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ECONOMY & INFRASTRUCTURE COMMITTEE
Minute of hybrid meeting of the Economy and Infrastructure Committee held in the
Council Chambers on Wednesday 29 May 2024 at 9:30am.
Present: Bailies A Bailey, C McLaren and M Williamson; Councillors H Anderson,
S Carr, A Chan (Substituting for N Khogali), D Cuthbert (Substituting for C Stewart),
E Drysdale, J Duff, A Forbes, K Harvey, D Illingworth (Substituting for F Smith),
G Laing, W Robertson and J Welch.
In Attendance: A Williams, Director – Economy, Place and Learning, F Crofts,
Strategic Lead – Environment and Infrastructure, D Littlejohn, Strategic Lead –
Economy, Development and Planning (up to Item 5), S Panton (up to Item 5);
S D’All, L Chiles, S Denyer, B Cargill; C Daly (all Economy, Place and Learning);
J Guild, S Hendry, A Brown and M Pasternak (all Strategy, People and Resources).
Apologies for Absence: Councillors N Khogali, F Smith and C Stewart.
Councillor E Drysdale, Convener, Presiding.
1. WELCOME AND APOLOGIES
Convener welcomed everyone to the meeting.  Apologies for absence were
noted as above.
2. DECLARATIONS OF INTEREST
There were no Declarations of Interests in terms of the Councillors’ Code of
Conduct.
3. MINUTE OF MEETING OF ENVIRONMENT, INFRASTRUCTURE AND
ECONOMIC DEVELOPMENT COMMITTEE OF 7 FEBRUARY 2024
The minute of the meeting of the Environment, Infrastructure and Economic
Development Committee of 7 February 2024 was submitted and approved as a
correct record.
Being the first meeting of this Committee, and in the absence of an
Outstanding Business Statement, it was agreed that the following outstanding
actions be brought forward to the August meeting of this Committee following
agreement by Environment, Infrastructure and Economic Development Committee in
November 2023:
1. Officers to conduct a review of the process of gully cleaning, open
discussions with SEPA and representatives of the farming and land
owning community and to bring any potential proposals for change
back the next meeting of the Committee. 
2. A report relating to the introduction of a short term let control area will
be brought forward to the next meeting of the Committee.
3
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4. PLANNING ENFORCEMENT CHARTER REVIEW
There was submitted a report by Strategic Lead – Economy, Development
and Planning (24/159) seeking approval of an updated version of the Council’s
Planning Enforcement Charter, following review, as required by The Town and
Country Planning (Scotland) Act 1997.
Resolved:
The recommended update to the Council’s Planning Enforcement Charter, be
approved.
5. EXTENSION OF ROAD MAINTENANCE PARTNERSHIP AGREEMENT TO
MARCH 2026
There was submitted a report by the Strategic Lead – Environment and
Infrastructure (24/160) updating the Committee on the period of the existing Road
Maintenance Partnership (RMP) agreement and proposing an extension to the
existing arrangement.
Resolved:
(i) An extension to the existing partnership agreement (Appendix 1) between
Perth and Kinross Council and Tayside Contracts to deliver the road
maintenance, winter maintenance and reactive emergency response service,
be agreed.  The agreement will be for a period of two years from 1 April 2024
to 31 March 2026, with a further two-year extension option subject to review.
(ii) The RMP to report performance to Committee annually as part of the
Council’s performance management framework.
THERE FOLLOWED A SHORT RECESS AND THE COMMITTEE RECONVENED
AT 10.45AM.
6. STREET LIGHTING PARTNERSHIP AGREEMENT
There was submitted a report by Strategic Lead – Environment &
Infrastructure (24/161) seeking approval to extend the existing partnership
agreement with Dundee City Council, Angus Council and Tayside Contracts for the
shared service delivery of Street Lighting across the geographical areas of all three
councils.
Resolved:
(i) The contents of the report and the continued method of service delivery by
means of a 5 year Partnering Agreement, be noted and agreed.
(ii) The SLP to report performance to Committee annually as part of the Council’s
performance management framework.
7. ACTIVE TRAVEL STRATEGY - CYCLING, WALKING AND SAFER
ROUTES (CWSR) PROJECTS 2024/25
There was submitted a report by Strategic Lead – Environment and
Infrastructure (24/162) (1) detailing the Cycling, Walking and Safer Routes (CWSR)
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projects implemented in 2023/24, and (2) seeking Committee approval of the
proposed list of active travel projects for 2024/25.
Resolved:
(i) The schemes implemented from the Cycling, Walking and Safer Routes Grant
Funding in 2023/24 as detailed at Appendix 1, be noted.
(ii) The list of works for active travel projects for the financial year 2024/25 as
detailed in Appendix 2, be approved.
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ECONOMY & INFRASTRUCTURE COMMITTEE
OUTSTANDING BUSINESS STATEMENT (OBS)
(Report No. 24/232)
Please note that this statement sets out outstanding decisions of this committee along with an update and estimated completion date.  Actions
which are overdue are shaded for ease of reference.  Where an update reflects that an action is complete then the Committee’s agreement will be
sought to its removal from the OBS.
No Minute
Reference
Subject Title Outstanding Actions Update Lead Officer
/Service
Action Due
/Complete
Action
Expected
14. 1 November
2023 (EIED
Committee)
Item 6
Short Term Let Non-
Statutory Planning
Guidance
A report relating to the
introduction of a Short
Term Let control area
be brought forward in
early 2024.
Strategic Lead –
Economy,
Development
and Planning
DUE 28 August
2024
15. 1 November
2023 (EIED
Committee)
Item 8
Policy and Level of
Service for Winter
2023/24
Conduct a review of
the process of gully
cleaning, open
discussions with
SEPA and
representatives of the
farming and land
owning community
and to bring any
potential proposals for
change back to a
future committee
before summer recess
2024.
Strategic Lead –
Environment and
Infrastructure
DUE 28 August
2024
4
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Perth And Kinross Council
Economic and Infrastructure Committee
28 August 2024
ROAD GULLY CLEANSING
Strategic Lead - Environment and Infrastructure
(Report No. 24/233)
1. PURPOSE
1.1 Remit from Environment, Infrastructure & Economic Development Committee
of 1 November 2023 to report on progress and performance on gully
cleansing over the last few years.
1.2 This report will cover the gully function/disposal mechanism/cleansing/
capacity/performance and costs. It will further detail issues and barriers to
achieving targets.
2. RECOMMENDATIONS
2.1 It is recommended that Committee: -
(i) Note the content of this paper in relation to the gully cleansing activity
performance, the actual purpose of a road gully, how it operates and its
limitations in mitigating flooding occurring.
(ii) Note no enhancement to the activity is recommended by officers but if
any enhancement is required, then additional labour and financial
resource will be required to achieve it.
3. STRUCTURE OF REPORT
3.1 This report is structured over the following sections:
 Section 4: Background/Main Issues
 Section 5: Proposals
 Section 6: Conclusion
 Appendices
4. BACKGROUND / MAIN ISSUES
4.1 There are 46,610 road gullies across the Councils 2481km of public road
network. This number increases annually as new residential and commercial
developments are adopted and gullies are found on the existing network and
added to the asset register.
5
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4.2 Gullies are designed to collect rainfall which falls onto the public road and
store that water to allow particulates to settle and separate out so reduced
amounts are conveyed into the pipe/watercourse network.
4.3 Gullies are not designed as storage for floodwater with each modern pot
having an approximate 90 litre/20gallon capacity. Their spacing is determined
by the road surface area being drained and they are not designed to take
water from surrounding land.
4.4 Gully cleansing aims to remove the particulates that have settled in the gully
pot, not to remove water.
4.5 Most gullies are what we describe as ‘trapped’ and sit with water in them
similar to a toilet, to prevent odours coming back out of the pipework. See
Figure 1 below for general detail of a road gully.
Figure 1
4.6 Gullies drain in a variety of ways:
 into the public sewer system (which is managed and maintained by 
Scottish Water)
 into a piped system managed and maintained by the Council that then
discharges into a burn/watercourse/sewer
 into a roadside ditch – which is there to take road water not drainage
from adjacent land
 into a soakaway, a stone filled receptacle or buried stone pile, that
naturally percolates into ground, and is maintained by the Council
(unless it is in private land)
 directly onto the surface of a verge/adjacent land and then just
percolates into the ground.
4.7 Scottish Water do not typically permit new gullies to be connected into the
sewerage system due to capacity issues and through National Planning
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Framework 4 – Policy 22(c)(ii) has a presumption against surface water
connections to combined sewers. SEPA must be consulted on any proposal to
discharge any new gullies to a watercourse/burn to determine any mitigation
measures required to prevent pollution entering the natural environment.
4.8 Further, NPF4 – Policy 22(c)(i) states that ‘Development proposals will: not
increase the risk of surface water flooding to others, or itself be at risk.’ In
simple terms, a neutral or better approach is required. Specific details on
acceptable designs of surface water management systems can be found in
the PKC ‘Flood Risk and Flood Risk Assessments’ document (adopted March
2021)1. This includes information about the scale of rainfall event that is
allowed to enable the system to surcharge, the scale of rainfall event that is
allowed to enable the system to flood, and what the developers should do to
manage the overland flows once the system is flooding.
4.9 Roadside drainage ditches, and those on private land, can be maintained
without seeking permission from SEPA but excavated material must be
disposed of appropriately due to the ‘contaminated’ nature of hydrocarbons
and grits that are washed off road surfaces. 
4.10 Gullies may often appear blocked in heavy downpours because the water is
lying on the road surface. This can happen for a number of reasons: the
capacity of the pipe system is exceeded (they are designed to take a certain
amount of water), the rate at which water arrives at gullies is beyond what the
gully can accept (so the water ‘skips’ over the top), or the gully is blinded by
leaf litter / debris / silt (typically washed off hard surfaces and fills the gully
pot).
4.11 Gullies are generally only blocked, and requiring a visit from the gully machine
when the rain has stopped and capacity has returned to the system but the
standing water does not drain away from the road surface.
4.12 Weed growth in the gully frame is not necessarily an indication that the gully is
blocked, nor indeed that it has missed a gully cleanse allowing the weeds to
grow.
4.13 Tayside Contracts (TC) carry out the gully cleansing operation across the
public road network utilising 4 machines based in Perth (2), Blairgowrie and
Aberfeldy.
4.14 The gully operative forces clean water into the pot to dislodge the sludge and
sucks out the dirty sludge until such time as the pot is clear. They then rinse
and flush the pot and outlet pipe.
4.15 Gully waste is deposited at a reed bed facility near Almondbank where the
water naturally cleanses as it drains through the reed beds, leaving the solids
to be uplifted and taken to approved landfill.
4.16 Gully machine operators are directed on a day to day basis by the local
Assistant Road Maintenance Officer (ARMO).
1 PKC - Flood Risk and Flood Risk Assessments: https://tinyurl.com/PKC-FRA
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4.17 Gully cleansing is recorded, in real time, on a tablet and since 2023/24 data is
stored within the Road Asset Management system (RMS).
4.18 In early 2000’s all gullies were cleansed annually however this was
considered unaffordable and unnecessary as not all gullies required this
frequency.
4.19 In 2015 an exercise using commercial software was undertaken to gather
information about gully location, type, and condition on arrival. It was intended
this data would enable a more targeted approach to cleanse only those that
showed up as exceeding 50% blocked on arrival.
4.20 The project had limited success for a number of reasons:
 Period of time taken to gather the data and establish trends
 No real pattern obvious around why and when a gully would fill with
debris
 Apparent requirement for example to cleanse 3 in a street and leave
other 36 yet need to return short period later to ones not cleansed
 Fielding complaints about not cleaning all gullies whilst in one location
 Time taken to travel between settlements/streets exceeding time taken
actually cleansing gullies
 Time taken “physically digging” gullies out due to debris build up over
longer period
 Issues opening covers to access the gully pot as it had been left so long
– with many requiring frame/cover removal and replacement
 System required manual interrogation to establish outputs, which could
be extracted by gully motor and month but not by ward as detailed in
Appendix 1
4.21 As targeted cleansing was not effective and global annual cleansing not
achievable, the following operational regime was implemented in 2019:
 A Class roads – annual cleanse
 Linear and channel drains – annual cleanse
 Flood susceptible – annual cleanse
 Manholes – every three years
 Chokes (gullies / manholes, linear etc) and observed high silt levels – as
known
 100% clean by ward – Biennially
4.22 Blocked gullies are routinely picked up by Assistant Roads Maintenance
Officer (ARMO) and a cleanse arranged and reports are also received via
MyPKC of blocked gullies.
Many of these reports are not blocked however it is not possible for the ARMO
to respond to every notification. ARMO will continue to monitor and arrange
cleanses as required without contacting the notifier.
4.23 In order to maximise outputs, each ARMO directs the gully machine operator
to a location to cleanse all gullies Monday to Thursday. Each gully takes a
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variable time to cleanse due to levels of siltation, but by cleansing in a specific
location (village/settlement/area) daily travel time is minimised and output
maximised. Fridays are used to attend to reported/observed blocked gullies,
again trying to target by location albeit this is not so efficient due to the
disparate nature of blockages.
4.24 Historic performance numbers for cleansing gullies is as follows: -
2018/19 2019/20 2020/21
(* figures from 1
July 2020 only)
2021/22 2022/23 2023/24
22,308 22103 *20,777 22,675 #18,922 22,208
# recording system down for several months requiring manual records to be kept
4.25 Flood susceptible areas have been identified and are included on an annual
cleanse. These can be on the A Class network and so would be cleansed
anyway but are often on other classes of road. Not everywhere that has
experienced flooding is included but those that are:
Alyth Rattray Pitlochry (nr
Co-Op)
Cargill Feus Rd
Marshall
Pl
Bridgend Queens
St/Windsor
Terrace
Back St /
Burnbank /
Earnbank in Br
of Earn
Invergowrie
(specific
streets)
Milnathort
4.26 Since April 2023 a cleansing monitor is available and outputs can be
measured by month (each gully cleanse is date/timestamped) across wards.
Appendix 2 details outputs across all wards for financial year 2023/24 and to
end July 2024, and this will enable yearly comparisons moving forward. As
can be seen outputs during winter are lower as the water in the gully motor
freezes, resulting in the machine operating less efficiently. Additionally, flood
events considerably reduce outputs as the gully machines are directed to
reactively deal with blockages which increases travelling (non-productive)
time.
4.27 A visual interrogation of the system also details gully location and cleansing
history. It is intended this be made publicly available when sufficient data is
held and when technically feasible/resources permit. Appendix 3 is an extract
from ward 11 with cleansing history shown.
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4.28 Ditch clearing was, until the early 2000’s, carried out on an approximate 10-
year cycle. Reductions in budget and staffing resource has resulted in no
proactive ditch clearing taking place and limited reactive cleaning since 2008,
with only problem locations cleared when resources are available.  This
prevents water discharging from gullies and channels cut through the verge
(offlets) from getting into the ditch and draining away. 
4.29 The RMP maintain some piped systems, mainly in the rural / village /
settlement contexts. These are not jetted or cleansed and are only attended to
if the system ceases to function as intended. This can be caused by a
blockage in the pipe or at the outlet from the pipe and these localised issues
will receive attention to get the system operational again. Other piped systems
are generally managed and maintained by Scottish Water and the Council is
not responsible / funded / resourced for any aspect of maintenance of this
asset. Pipes / culverts / drains and watercourses that run through private land,
that carry surface water are the responsibility of the property / landowner to
maintain; this is the principle of ‘riparian ownership’2. Where this falls to
private property owners, it is not always known to them that they have certain
responsibilities. The Council will assist by way of providing advice in these
situations where possible but are typically unable to act on private ground.
4.30 Typically, combined sewer and foul sewer systems are ‘adopted’ by Scottish
Water, and the maintenance of them is their responsibility. Some surface
water sewers are adopted by Scottish Water, but others are either the
responsibility of the landowner(s) or Perth and Kinross Council. This latter
aspect often involves a degree of research to identify the owner prior to
undertaking any works.
4.31 The Council area was previously split into 12 geographic areas each with a
Roads supervisor and 4 Road Superintendents managing them. From 2008
this has reduced to 2 Superintendents (now Road Maintenance Officers) and
7 supervisors (now ARMO). With the increased size of area for each ARMO
and increased workload, the opportunity to engage proactively and build up
relationships with adjacent landowners has been reduced.
4.32 Over the past few decades reduced manpower and increasing size of
agricultural vehicles has meant farmers have changed away from contour
ploughing / against the slope, which created furrows running counter to the
slope (which reduced the flow of water/soil downhill).
Much of the ploughing is now counter contour / with the slope of the land and
results in water cascading down the furrows and straight onto the
neighbouring land (road / gardens / properties), along with soil/stones/crops
etc.
2 Scottish Government – Clearance and Repair to Reduce Flood Risk: Local Authority Guidance:
https://tinyurl.com/SG-LAG 
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4.33 Landowner discussions have been restarted in neighbouring Council areas,
between them and the Council itself. The same approach is needed in Perth
and Kinross, to re-engage and restate responsibilities of landowners that
border private developments to minimise the impacts of runoff of water and
other material. It is acknowledged that the ‘Higher Owner’ is not legally
obliged to provide defence to the ‘Lower Owner’ by undertaking specific works
in this regard, however, it could be argued that by working the land, the
landowners may be considered to have ‘overstretched’ their rights and have
altered the route of natural drainage in the area3. The Council have no remit to
‘force’ landowner to adjust their practices (unless specific conditions are met
per the Flood Risk Management (Scotland) Act 2009), so are reliant on
understanding and informal agreements between all parties.
4.34 Other agencies involved here include SEPA and Scottish Water. The former is
the ‘warn and inform agency’ with regards to provision of flood alerts and
warnings for members of the public and the Council. SEPA is not permitted to
undertake any works to mitigate flooding impacts as they happen, but they are
a statutory consultee in the Planning process and provide comment on
flooding and surface water management.
4.35 Scottish Water are responsible for provision of potable water, and more
pertinently maintaining (many) sewerage systems. It is a common
misunderstanding that drainage systems (adopted by Scottish Water) must
take all water landing on it. In line with the Council guidance1 (derived from
Scottish Water’s Sewers for Scotland – v4 document4), surface water
drainage systems are designed to accept the 1:30yr magnitude event without
surcharging, and the 1:100yr magnitude event with surcharging but without
flooding, and the 1:200yr magnitude event plus a 35% allowance for climate
change can flood but the water should be managed in a way to not impact
gardens / finished floor levels of properties. Safe dry access and egress is to
be maintained at all times during flood events (see Section 7.2.1 of footnote
4).
4.36 The Gully Cleaning budget forms part of the wider Roads Revenue, 
Routine and Cyclic (R&C) budget. A general budget split and for monitoring
purposes approximately £340k per annum (35% of R&C) has historically been
aligned to gully cleaning. This is often insufficient to meet requirements with
other elements of the R&C budget (temporary defect repairs, lining, drainage,
signs etc) required to be reduced in year to balance the overall R&C budget.
4.37 The following table indicate spend on gully cleansing over the last 4 years.
20/21 21/22 22/23 23/24
Allocation (£) 334K 340k 436k 436k**
Spend (£) 252k* 437k 444k £443k
Number
cleansed 20,777 22,675 18,922*** 22,208
*Covid affected spend
**£42k R&C budget uplift all allocated to gully cleansing
*** recording system down for several months requiring manual records to be kept
3 Harper-Macleod – Common Law Flooding: https://tinyurl.com/CLawFlood
4 Scottish Water – Sewers for Scotland v4: https://tinyurl.com/S4Sv4
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5. PROPOSALS
5.1 Continue to cleanse gullies utilising the plant and workforce of TC in
accordance with current regime.
5.2 Continue to monitor and report against the target cleanse programme.
5.3 Budget and market availability permitting, hire in additional gully cleansing
capacity to achieve targets.
5.4 As a result of some structural changes in the Flooding team, newly
established Watercourse Inspector posts, once filled, will provide some
additional capacity to engage with landowners and farmers. Whilst inspecting
watercourses on private land these officers will discuss mitigations to prevent
uncontrolled run-off to neighbouring land, be that private or public land.
5.5 In addition the Flood Liaison Officer in the RMP will engage with landowners
and farmers at known regular overland flow locations that impact on the road
network.
6. CONCLUSION
6.1 Without a recurring increase in revenue budget allocation it is not possible to
proactively cleanse additional gullies, piped systems and ditches beyond the
existing levels highlighted in para 4.24.
6.2 Officers and TC road workers will continue to endeavour to cleanse as many
gullies as possible based on the most efficient and effective use of the
resources at the Council’s disposal.
6.3 It should be acknowledged that taking resources from planned works to travel
the Council area (lost travel time) to cleanse a gully that is potentially not
blocked impacts on the workforces’ ability to achieve targets. Support is
required for officers to use available resources efficiently and effectively.
6.4 It should be recognised that gullies are not in place to prevent flooding but to
collect routine rainfall in a controlled manner and despatch water as pipework
capacity allows. Gullies could be cleansed at an increased frequency however
ultimately the capacity of the drainage network will always be the limiting
factor for dispersing excess surface water.
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Author
Name Designation Contact Details
Stuart D’All Road Maintenance
Partnership Manager
01738 475000
ComCommitteeReports@pkc.gov.uk
Approved
Name Designation Date
Fraser Crofts Strategic Lead –
Environment &
Infrastructure
19 August 2024
APPENDICES
 Appendix 1 - Previous System Cleanse Monitor Outputs
 Appendix 2 – Cleanse Monitor 2023/24
 Appendix 3 - Visual Representation
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ANNEX
1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND
COMMUNICATION
Strategic Implications Yes / None
Community Plan / Single Outcome Agreement Yes
Corporate Plan Yes
Resource Implications
Financial Yes
Workforce Yes
Asset Management (land, property, IST) None
Assessments
Equality Impact Assessment None
Strategic Environmental Assessment None
Sustainability (community, economic, environmental) None
Legal and Governance None
Risk Yes
Consultation
Internal None
External None
Communication
Communications Plan None
1. Strategic Implications
Community Plan / Single Outcome Agreement
1.1 Gully cleansing is part of the Councils statutory duties as Roads Authority,
under the Road (Scotland) Act 1984, to manage and maintain all such roads
in their area as are for the time being entered in their list of public roads. 
1.2 Gully cleansing increases road safety by removing the potential of standing
water on the road and consequential road traffic accidents or other
loss/damage that could occur.
Corporate Plan
1.3 The Council’s Corporate Plan for Securing the Future 2018 and Beyond lays
out five Objectives which provide clear strategic direction, inform decisions at
a corporate and service level and shape resources allocation.  This report
impacts on the following:-
i) Promoting a prosperous, inclusive and sustainable economy
ii) Supporting people to lead and independent, healthy and active life
iii) Creating a safe and sustainable place for future generations
2. Resource Implications
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Financial
2.1 Gully cleansing is funded from an overall revenue budget for routine and
cyclic activities incurred in maintaining the road network.
2.2 An enhanced cleansing regime is not possible within existing financial
allocations. Additional non-recurring allocations will have minimal impact due
to nature of the activity and difficulty engaging 3rd party private hire
companies.
Workforce
2.3 The staff and the operatives of Tayside Contracts and the Council who
provide the service, have finite time to deliver this aspect of the overall
service. Any additional outputs required would need to be adequately
resourced.
3. Assessments
Equality Impact Assessment
3.1 No assessment has been carried out into this activity.
Strategic Environmental Assessment
3.2 No assessment has been carried out into this activity.
Gully arisings have been treated through a reed bed system to remove
pollutants prior to the water going back into the ecological system for in
excess of 15 years and no change is proposed.
Sustainability
3.3 No assessment has been carried out into this activity.
Risk
3.4 The Council as Roads Authority have a statutory duty as set out in Roads
Authority, under the Road (Scotland) Act 1984, to manage and maintain all
such roads in their area as are for the time being entered in their list of public
roads. 
3.5 This activity enables the Council to meet its statutory obligations and minimise
exposure to risk by cleansing gullies within the constraints of its finite
resources. During severe weather, the Council will endeavour to mitigate the
impacts by cleansing gullies likely to impact property flooding, as quickly as
possible.
4. Consultation
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Internal
4.1 Nil.
5. Communication
5.1 Nil.
2. BACKGROUND PAPERS
2.1 Well Managed Highway Infrastructure 2016
2.2 Road (Scotland) Act 1984
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Page 23

Appendix 1
PREVIOUS CLEANSE MONITOR OUTPUTS (2022/23)
5
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Page 24

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Page 25

Appendix 2
CLEANSE MONITOR 2023/24 and TO END JULY 2024/25
5
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Page 26

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Page 27

Appendix 3
VISUAL REPRESENTATION
5
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Page 28

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Perth And Kinross Council
Economy & Infrastructure Committee
28 August 2024
PROPOSED WAITING RESTRICTIONS
Report by Strategic Lead – Environment & Infrastructure
(Report No. 24/234)
1. PURPOSE
1.1 The purpose of this report is to advise Committee of the proposed Traffic
Regulation Order to introduce waiting restrictions on North Crofts in
Auchterarder. The Council received 5 responses to the consultation with the
majority being objections. The Committee is asked to consider the objections
and set them aside so that the Order can be made, in line with the Ward 7
members’ views.
2. RECOMMENDATIONS
2.1 It is recommended that Committee:
i) considers the objections received;
ii) notes the Ward 7 Elected Members views in paragraph 4.7 and sets
aside the objections; and 
iii) proceeds to make the Order to promote the Waiting Restrictions on
North Crofts, Green Crofts and Hannover Gardens in Auchterarder.
3. STRUCTURE OF REPORT
3.1 This report is structured over the following sections:
 Section 4: Background/ Main Issues
 Section 5: Proposals
 Section 6: Conclusion
 Appendices
4. BACKGROUND/MAIN ISSUES
4.1 The parking restrictions at the North Crofts, Green Crofts and Hannover
Gardens were requested by Local Elected Members, the Community Council
and residents. The waiting restrictions were requested due to access issues in
North Crofts by inconsiderate/obstructive parking on both sides of the
carriageway on North Crofts. Concerns were raised that due to the narrow
width emergency services vehicles would not be able to get through. 
6
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Page 30

4.2 Before progressing with the Legal Order, informal consultation on the
proposed waiting restrictions was carried out with residents to agree a way
forward. The proposal received 23 responses in support and 4 opposed to the
proposal. The responses opposed to the restrictions requested that waiting
restrictions were introduced on one side to maintain some level of resident
parking.
4.3 Following a site visit with Ward 7 members, the proposal was altered slightly
to allow some on street parking. However, it was agreed that waiting
restrictions should be introduced on both sides. The carriageway is not wide
enough to permit parking on one side and still maintain access for emergency
service vehicles.
4.4 As part of the legal process, officers were required to carry out statutory
consultation to promote the Perth and Kinross Council (Auchterarder) (Waiting
Restrictions) (Variation) (No 5) Order 2024, to introduced waiting restrictions
in the North Crofts area of Auchterarder. The Order seeks to introduce waiting
restrictions on North Crofts, Green Crofts and Hannover Gardens.
4.5 The proposed restrictions can be seen in Appendix 1.
4.6 During the statutory consultation process, 5 responses were received. Copies
of the full objections and response are contained in Appendix 2. A breakdown
of the responses are as follows:
 2 objections
 1 response in support
 2 responses noting concern with the proposal and suggesting alternative
measures
4.7 The responses were discussed with the Ward 7 members who agreed to
proceed with the waiting restrictions as shown in Appendix 1.
4.8 Following a meeting with one objector, Cllr Allen looked to undertake a trial of
introducing waiting restrictions on one side of the roads. However, later
advised to proceed with original proposal.
4.9 A summary of the reasons for objecting or having concerns are as follows: -
 Concerns over the availability of parking within the High Street and
Auchterarder as a whole.
 Visitors would not be able to park near North Crofts.
 Reduce available parking for pharmacy, local shops etc
 No available off-street parking for residents. 
4.10 One response supported the proposed waiting restrictions due to concerns
that emergency services would not be able to access properties in North
Crofts. 
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5. PROPOSALS
5.1 The proposed waiting restrictions agreed with the ward members is shown in
Appendix 1.
6. CONCLUSION
6.1 This report provides an update on the consultation for waiting restrictions
proposed for the North Crofts area of Auchterarder The report details the
responses received and provides an insight into the reasoning behind the
objections and support. The report recommends that the objections are set
aside and that the Order is promoted in part, to alleviate obstructive parking
on North Crofts, Green Crofts and Hannover Gardens.
Author
Name Designation Contact Details
Craig Daly Traffic and Network
Service Manager
01738 475000
ComCommitteeReports@pkc.gov.uk
Approved
Name Designation Date
Fraser Crofts Strategic Lead (Environment &
Infrastructure)
19 August 2024
APPENDICES
 Appendix 1 Drawings and Variation Order
 Appendix 2 Objections and Responses
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Page 32

ANNEX
1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND
COMMUNICATION
Strategic Implications Yes/No
Community Plan / Single Outcome Agreement Yes
Corporate Plan Yes
Resource Implications
Financial Yes
Workforce None
Asset Management (land, property, IST) None
Assessments
Equality Impact Assessment Yes
Strategic Environmental Assessment Yes
Sustainability (community, economic, environmental) Yes
Legal and Governance Yes
Risk None
Consultation
Internal Yes
External Yes
Communication
Communications Plan Yes
1. Strategic Implications
Community Plan/Single Outcome Agreement 
1.1 This report supports one of the priorities within the Community Plan 2022-27.
(i) Mental and physical wellbeing.
Corporate Plan 
1.2 This report supports the objectives within the draft new Corporate Plan:-
(i) Children and young people grow up safe, respected, well-educated,
and confident in their ability to realise their full potential;
(ii) People and businesses are increasingly able to prosper in a local
economy which support low carbon ambitions and offers opportunities
for all;
(iii) People can achieve their best physical and mental health and have
access to quality care and support when they need it;
(iv) Communities are resilient and physically, digital and socially
connected;
(v) Perth and Kinross is a safe and vibrant place, mitigating the impact of
climate and environmental change for this and future generations.
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2. Resource Implications
Financial
Capital
2.1 There are no capital resource implications arising directly from the
recommendations in this report.
Revenue
2.2 The financial implications of advertising and implementing the waiting
restrictions are covered within existing Traffic and Network revenue budgets.
Workforce
2.3 There are no workforce implications arising from this report.
Asset Management (land, property, IT)
2.4 There are no land and property, or information technology implications arising
from the contents of this report.
3. Assessments
Equality Impact Assessment
3.1 Under the Equality Act 2010, the Council is required to eliminate
discrimination, advance equality of opportunity, and foster good relations
between equality groups.  Carrying out Equality Impact Assessments for plans
and policies allows the Council to demonstrate that it is meeting these duties.
3.2 This section should reflect that the proposals have been considered under the
Corporate Equalities Impact Assessment process (EqIA) with the following
outcome:
(i) Assessed as not relevant for the purposes of EqIA.
Strategic Environmental Assessment
3.3 Strategic Environmental Assessment (SEA) is a legal requirement under the
Environmental Assessment (Scotland) Act 2005 that applies to all qualifying
plans, programmes and strategies, including policies (PPS).
The proposals have been considered under the Act and no further action is
required as it does not qualify as a PPS as defined by the Act and is therefore
exempt.
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Page 34

Sustainability
3.4 Under the provisions of the Local Government in Scotland Act 2003 the
Council has to discharge its duties in a way which contributes to the
achievement of sustainable development. In terms of the Climate Change Act,
the Council has a general duty to demonstrate its commitment to sustainability
and the community, environmental and economic impacts of its actions. 
3.5 The proposals contained within the report are assessed to have a positive
impact on sustainability, particularly with regard to encouraging road safety. 
Legal and Governance
3.6 The Order will be promoted in accordance with The Local Authorities’ Traffic
Orders (Procedure) (Scotland) Regulations 1999. 
Risk
3.7 There are no significant risks associated with the implementation of this
project. 
4. Consultation
4.1 The Strategic Lead, Legal and Governance and the Strategic Lead, Finance
and Business Support have been consulted in the preparation of this report. 
4.2 Police Scotland, local Elected Members, residents and Community Councils
have also been consulted.
5. Communication
5.1 None.
2. BACKGROUND PAPERS
2.1 Not applicable.
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Communities
NORTH
NTS
Executive Director - B.Renton BA Hons
© Crown copyright [and database rights] 2022OS 100016971. You are permitted to use this data solely to enable you to respond to, or interact with, the
organisation that provided you with the data. You are not permitted to copy, sub-licence, distribute or sell any of this data to third parties in any form.
NORTH
Site Location
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organisation that provided you with the data. You are not permitted to copy, sub-licence, distribute or sell any of this data to third parties in any form.
6
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Page 36

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1
Communities TRO
From: Communities TRO
Sent: 24 July 2024 09:45
To: Ainslie Warriner
Subject: RE: Waiting restrictions North Crofts Auchterarder
Attachments: North Crofts DWG - Legal.pdf
Dear Ainslie, 
Thank you for your email responding to the consultation for Auchterarder Traffic Regulation Order
regarding proposed Waiting Restrictions in the North Crofts area. Details of the proposal can be seen
in the attached plan.  
In total, 5 responses were received with 2 objections, 1 in support and 2 noting concerns with the
proposal. The responses were discussed with the Ward 7 Elected members in order to agree a way
forward. 
Following these discussions, I can confirm that a report will be submitted to the Environment and
Infrastructure Committee. The report will recommend the Committee considers the objections and
set aside objections to allow the Traffic Regulation Order to be made to promote the Waiting
Restrictions on North Crofts, Green Crofts and Hannover Gardens as per the attached drawing. The
report will include summarised version of your response and the full response, with personal
information redacted, will be included as an appendix.
I appreciate that this may not be the recommendation that you would have hoped for. However,
should you be unhappy with this decision then I would suggest that you to contact your Elected
Members to discuss your concerns. If you wish, you could make a deputation at the Committee to
allow them to consider your points. If this is an option that you would wish to consider then please
contact Committee Services at Committee@pkc.gov.uk for further information. Kind Regards
Kind Regards
Blair Watt | Project Officer
Road Safety | Traffic and Network | Housing and Environment 
Perth & Kinross Council, Pullar House, 35 Kinnoull Street, Perth, PH1 5GD
Phone: 01738 476944 Mobile: 07827 357105 Email: bwatt@pkc.gov.uk 
6
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2
From: Ainslie Warriner <ainslie.warriner@gmail.com> 
Sent: Friday, July 5, 2024 5:46 PM
To: CDS Legal Sevices <LegalServices@pkc.gov.uk>; Communities TRO <TRO@pkc.gov.uk>
Subject: Waiting restrictions North Crofts Auchterarder 
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe. 
Dear Sarah Stewart,
I received the notification  from the council today
I see once again the the requests and suggestions from the residents  go totally ignored . 
There has been no consideration to the needs of the local residents who have no choice but to park
on North Crofts road .
We elderly folk in Hanover Gardens can say goodbye to receiving visits from our families  as there will
be nowhere to park . Really sad . 
Lines on one side of the road would alleviate the severe congestion  and access for services but still
give us some access to parking 
PLEASE REVIEW THIS THOUGHTLESS PLAN 
Ainslie Warriner 
3 Hanover Gardens, Auchterarder PH3 1DJ, 
Page 38 of 184

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1
Blair Watt
From: Blair Watt
Sent: 24 July 2024 09:42
To: info@cafekisa.co.uk
Cc: Bridget Mitchell
Subject: RE: Waiting Restrictions North Crofts, Auchterarder
Attachments: North Crofts DWG - Legal.pdf
Dear Sam and Kirsty, 
Thank you for your email responding to the consultaƟon for Auchterarder Traffic RegulaƟon Order regarding
proposed WaiƟng RestricƟons in the North CroŌs area. Details of the proposal can be seen in the aƩached plan.   
In total, 5 responses were received with 2 objecƟons, 1 in support and 2 noƟng concerns with the proposal. The
responses were discussed with the Ward 7 Elected members in order to agree a way forward. 
Following these discussions, I can confirm that a report will be submiƩed to the Environment and Infrastructure
CommiƩee. The report will recommend the CommiƩee considers the objecƟons and set aside objecƟons to allow
the Traffic RegulaƟon Order to be made to promote the WaiƟng RestricƟons on North CroŌs, Green CroŌs and
Hannover Gardens as per the aƩached drawing. The report will include summarised version of your response and
the full response, with personal informaƟon redacted, will be included as an appendix. 
I appreciate that this may not be the recommendaƟon that you would have hoped for. However, should you be
unhappy with this decision then I would suggest that you to contact your Elected Members to discuss your concerns.
If you wish, you could make a deputaƟon at the CommiƩee to allow them to consider your points. If this is an opƟon
that you would wish to consider then please contact CommiƩee Services at CommiƩee@pkc.gov.uk for further
informaƟon. 
If you require any further informaƟon, please don't hesitate to contact me. 
Kind Regards
Blair WaƩ | Project Officer
Road Safety | Traffic and Network | Housing and Environment Perth & Kinross Council, Pullar House, 35 Kinnoull
Street, Perth, PH1 5GD
Phone: 01738 476944 Mobile: 07827 357105 Email: bwaƩ@pkc.gov.uk 
-----Original Message-----
From: CDS Legal Sevices <LegalServices@pkc.gov.uk> 
Sent: Thursday, July 11, 2024 3:50 PM
To: Blair WaƩ <BWaƩ@pkc.gov.uk>; Bridget Mitchell <BMitchell@pkc.gov.uk>
Subject: FW: WaiƟng RestricƟons North CroŌs, Auchterarder 
-----Original Message-----
From: info@cafekisa.co.uk <info@cafekisa.co.uk> 
Sent: Thursday, July 11, 2024 3:39 PM
To: CDS Legal Sevices <LegalServices@pkc.gov.uk>
Subject: WaiƟng RestricƟons North CroŌs, Auchterarder 
CAUTION: This email originated from an external organisaƟon. Do not follow guidance, click links, or open
aƩachments unless you have verified the sender and know the content is safe.
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Page 40

2
Dear Sir/Madam,
I am wriƟng to raise our concerns with regards to the proposed waiƟng restricƟons proposed for Green CroŌs, North
CroŌs and Hanover Gardens in Auchterarder. 
We have been on the Auchterarder High Street for over 20 years and know too well the car parking challenges that
face the local residents, local businesses and tourists. We receive regular feedback from customers with regards to
parking and so know it does affect our trade. We have lost customers due to being unable to park and have had
customers arrive late due to being unable to park which then has a knock-on effect.  We feel the above waiƟng
restricƟons in its current proposal would adversely affect the trade of our business and other businesses on the
Auchterarder High Street including the local chemist to which there is no direct parking or disabled parking available. 
As you know, High streets across the country are suffering and we are one of the lucky ones with a street filled with
small, independent businesses which rely on visitors and locals and would hate to see this being affected due to even
further limitaƟons to parking. 
We do however recognise that there is a need for some level of parking restricƟon on the above roads – we regularly
have issues accessing our car park for team members and deliveries. We would like to propose to yourselves that the
one side of Green CroŌs, North CroŌs and Hanover Gardens be restricted with double yellow lines and one side leŌ
to be used for parking. 
We appreciate you taking the Ɵme to read this – if you would like anymore informaƟon or to discuss this, please do
not hesitate to get in touch. 
Many thanks
Sam and Kirsty,
Café Kisa,
127-129 High Street,
Auchterarder
PH3 1AA
01764 663340
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1
Blair Watt
From: Blair Watt
Sent: 24 July 2024 09:43
To: grantymartin@msn.com
Cc: Bridget Mitchell
Subject: RE: North Crofts Waiting Restrictions
Attachments: North Crofts DWG - Legal.pdf
Dear Grant, 
Thank you for your email responding to the consultation for Auchterarder Traffic Regulation Order
regarding proposed Waiting Restrictions in the North Crofts area. Details of the proposal can be seen
in the attached plan.  
In total, 5 responses were received with 2 objections, 1 in support and 2 noting concerns with the
proposal. The responses were discussed with the Ward 7 Elected members in order to agree a way
forward. 
Following these discussions, I can confirm that a report will be submitted to the Environment and
Infrastructure Committee. The report will recommend the Committee considers the objections and
set aside objections to allow the Traffic Regulation Order to be made to promote the Waiting
Restrictions on North Crofts, Green Crofts and Hannover Gardens as per the attached drawing. The
report will include summarised version of your response and the full response, with personal
information redacted, will be included as an appendix.
I appreciate that this may not be the recommendation that you would have hoped for. However,
should you be unhappy with this decision then I would suggest that you to contact your Elected
Members to discuss your concerns. If you wish, you could make a deputation at the Committee to
allow them to consider your points. If this is an option that you would wish to consider then please
contact Committee Services at Committee@pkc.gov.uk for further information. 
If you require any further information, please don't hesitate to contact me. 
Kind Regards
Blair Watt | Project Officer
Road Safety | Traffic and Network | Housing and Environment 
Perth & Kinross Council, Pullar House, 35 Kinnoull Street, Perth, PH1 5GD
Phone: 01738 476944 Mobile: 07827 357105 Email: bwatt@pkc.gov.uk 
Page 41 of 184

Page 42

2
From: CDS Legal Sevices <LegalServices@pkc.gov.uk> 
Sent: Thursday, July 11, 2024 9:11 AM
To: Blair Watt <BWatt@pkc.gov.uk>; Bridget Mitchell <BMitchell@pkc.gov.uk>
Subject: FW: North Crofts Waiting Restrictions 
Legal Services
Perth & Kinross Council
Legal & Governance Services
2 High Street
PERTH
PH1 5PH 
Phone: 01738 475115
Help save paper - do you need to print this e-mail? 
From: Grant Martin <grantymartin@msn.com> 
Sent: Wednesday, July 10, 2024 2:46 PM
To: CDS Legal Sevices <LegalServices@pkc.gov.uk>
Subject: North Crofts Waiting Restrictions 
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe. 
To the Strategic Lead, 
Upon receiving the letter detailing your plans for the waiting restrictions in North Crofts, Auchterarder
I was dismayed and I wish to formally wish to object to them. 
Parking bays have already been introduced on the High St and as I understand it these pave the way
for pay and display machines and permits. 
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Page 43

3
North Crofts is directly next to my residence here at 143 High St, above Davidson's Pharmacy and
during the day there isn't a space to be found on the High St all along this main section and this
junction with North Crofts and the Co-op on the other side is the epicenter of busyness every day. 
People are parking here to visit the pharmacy, collecting their medications, using the shops or visiting
Cafe Kisa, all things which are keeping the High St alive. 
Making the proposed area no waiting at any time is going to reduce the number of availabile spaces in
an area which is already struggling for parking availability. Those people who park there still need to
use the pharmacy and other amenities and those of us who live here are going to struggle to park
anywhere near our residence on a daily basis a whilst people do park along North Crofts I have never
found a situation where the road was impassable or blocked. 
Where do you propose people who rely on those spaces go? The population of Auchterarder and
surrounding areas has been increasing, this situation was already getting worse and now this
proposal will accelerate the situation building anger and frustration in the local community. 
These plans will be detrimental to the local community and I know I'm not the only one who feels this
way, so please reconsider as there are many firmly against these plans. 
Kind regards, 
Grant Martin 
Sent from Outlook for Android
Page 43 of 184

Page 44

1
Communities TRO
From: Communities TRO
Sent: 24 July 2024 09:39
To: Iain MacDonald
Subject: RE: North Crofts Auchterarder - No objection, but a couple of questions
Attachments: North Crofts DWG - Legal.pdf
Dear Iain, 
Thank you for your email responding to the consultation for Auchterarder Traffic Regulation Order
regarding proposed Waiting Restrictions in the North Crofts area. Details of the proposal can be seen
in the attached plan.  
In total, 5 responses were received with 2 objections, 1 in support and 2 noting concerns with the
proposal. The responses were discussed with the Ward 7 Elected members in order to agree a way
forward. 
Following these discussions, I can confirm that a report will be submitted to the Environment and
Infrastructure Committee. The report will recommend the Committee considers the objections and
set aside objections to allow the Traffic Regulation Order to be made to promote the Waiting
Restrictions on North Crofts, Green Crofts and Hannover Gardens as per the attached drawing. The
report will include summarised version of your response and the full response, with personal
information redacted, will be included as an appendix.
I appreciate that this may not be the recommendation that you would have hoped for. However,
should you be unhappy with this decision then I would suggest that you to contact your Elected
Members to discuss your concerns. If you wish, you could make a deputation at the Committee to
allow them to consider your points. If this is an option that you would wish to consider then please
contact Committee Services at Committee@pkc.gov.uk for further information. 
Enforcement of the waiting restrictions will be carried out in accordance with the parking
enforcement policy, however, it is likely we will target this area during the first few weeks to ensure
drivers are aware of the new restriction. 
We will assess the junction at the High Street and come back to you. It is likely that to improve the
visibility we would be required to remove on-street parking which is unlikely to progress with the
Elected Members. 
Do you have a specific Order you would like to have a copy of? Is it the order relating to the double
yellows and drop off area or the car park and bus lanes?  
Kind Regards
Blair Watt | Project Officer
Road Safety | Traffic and Network | Housing and Environment 
Perth & Kinross Council, Pullar House, 35 Kinnoull Street, Perth, PH1 5GD
Phone: 01738 476944 Mobile: 07827 357105 Email: bwatt@pkc.gov.uk 
Page 44 of 184

Page 45

2
From: Iain MacDonald <imacdonald172@gmail.com> 
Sent: Monday, July 15, 2024 12:47 AM
To: Communities TRO <TRO@pkc.gov.uk>
Subject: North Crofts Auchterarder - No objection, but a couple of questions 
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe. 
Hi, 
I'm in receipt of your letter dated 3 July relating to the new waiting restrictions on the above road. 
Absolutely no objections to this, in fact, I positively welcome it as the parking in this area has grown
much worse over the time I've lived here. 
I do have a couple of questions though 
1. People ignore the existing waiting restrictions on a regular basis now, so are there any plans to
increase the presence of traffic wardens in the area? It's often more of a surprise to see no cars on
the double yellow lines when I pass by as things stand currently. 
2. Can anything be done about improving the visibility at the junction with the high street? Getting on
to the High Street is often the equivalent of trusting to luck as the traffic parked on the right does a
good job of blocking any view of traffic coming from the right. This might not be so bad if people
adhered to the 20mph, but they don't and it becomes a tricky junction to negotiate safely. 
What's also not helping just now is that someone has decided to restrict the visibility at that junction
still further by putting up a sign relating to future works. 
The proposed waiting restrictions are not going to help that issue. 
3. Could you tell me where I can get a copy of the order relating to the area around the school in
Auchterarder please? 
Page 45 of 184

Page 46

3
Finally, I do genuinely welcome this improvement as it does have the potential to improve road safety
for all local residents and gives some comfort that an emergency vehicle could get through those
streets because sometimes that's very much been open to question. 
Regards 
Iain MacDonald 
Page 46 of 184

Page 47

1
Communities TRO
From: Communities TRO
Sent: 24 July 2024 09:45
To: John Gilmour
Subject: RE: Waiting restrictions North Crofts ,Auchterarder
Attachments: North Crofts DWG - Legal.pdf
Dear John, 
Thank you for your email responding to the consultation for Auchterarder Traffic Regulation Order
regarding proposed Waiting Restrictions in the North Crofts area. Details of the proposal can be seen
in the attached plan.  
In total, 5 responses were received with 2 objections, 1 in support and 2 noting concerns with the
proposal. The responses were discussed with the Ward 7 Elected members in order to agree a way
forward. 
Following these discussions, I can confirm that a report will be submitted to the Environment and
Infrastructure Committee. The report will recommend the Committee considers the objections and
set aside objections to allow the Traffic Regulation Order to be made to promote the Waiting
Restrictions on North Crofts, Green Crofts and Hannover Gardens as per the attached drawing. The
report will include summarised version of your response and the full response, with personal
information redacted, will be included as an appendix.
I appreciate that this may not be the recommendation that you would have hoped for. However,
should you be unhappy with this decision then I would suggest that you to contact your Elected
Members to discuss your concerns. If you wish, you could make a deputation at the Committee to
allow them to consider your points. If this is an option that you would wish to consider then please
contact Committee Services at Committee@pkc.gov.uk for further information. Kind Regards
If you require any further information, please don't hesitate to contact me. 
Kind Regards
Blair Watt | Project Officer
Road Safety | Traffic and Network | Housing and Environment 
Perth & Kinross Council, Pullar House, 35 Kinnoull Street, Perth, PH1 5GD
Phone: 01738 476944 Mobile: 07827 357105 Email: bwatt@pkc.gov.uk 
Page 47 of 184

Page 48

2
From: John Gilmour <johngilmour090@gmail.com> 
Sent: Tuesday, July 9, 2024 9:20 PM
To: Communities TRO <TRO@pkc.gov.uk>
Subject: Waiting restrictions North Crofts ,Auchterarder 
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe. 
Dear Sarah.
I NO LONGER DRIVE.but am perfectly aware of the situation from Hanover Gardens, and the main
street towards the high Street,and find it often with difficult to negotiate between  vehicles which Park
there.
I am very much often quite scared to venture out.
I would suggest that perhaps the restriction  would  be only on one side of the street. 
Which would make me feel a little more safer as I at 77years of age might be.
Thank u for your letter and in kind notification 
Yours sincerely
John. J.Gilmour
31 Hanover Garrdens
Auchterarder 
PH3 1DJ.
Page 48 of 184

Page 49

Perth And Kinross Council
Economy and Infrastructure Committee
28 August 2024
SHORT-TERM LET CONTROL AREA PROPOSAL
Report by Strategic Lead - Economy, Development and Planning
(Report No. 24/235)
1. PURPOSE
1.1 To seek approval to commence the formal statutory process to introduce a
Short-term Let Control Area informed by the results of the 2023 non-statutory
consultation on the principle of a Control Area, and updated research by
housing experts Arneil Johnston using the Licence register of short-term lets
(STLs).
2. RECOMMENDATIONS
2.1 It is recommended that the Committee:
(i) approves the attached Statement of Reasons;
(ii) instruct officers to commence the statutory 28-day notification; and
(iii) agree that officers bring back a report that will set out consideration of
any representations prior to remitting to Scottish Ministers for approval.
3. STRUCTURE OF REPORT
3.1 The report is structured over the following sections:
 Section 4: Background
 Section 5: Proposals
 Section 6: Statutory Process
 Section 7: Conclusion
 Appendices
4. BACKGROUND
4.1 The Scottish Government and local authorities have recognised the need to
manage the number of commercial short-term lets to protect both the supply
of homes to meet local need (including key workers) and the amenity of
residential areas.  STL Control Area legislation was introduced in April 2021,
permitting local authorities to establish Control Areas where it considers it to
be necessary. Within Control Areas planning permission is required for the
Change of Use of residential properties to short-term lets ‘to allow
consideration of impacts on the availability of residential housing’.
Since the introduction of this legislation, two such Control Areas have been
established: across the entire City of Edinburgh Council area (Sept 2022) and
the Badenoch & Strathspey ward of the Highland Council area (March 2024).
7
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4.2 Feedback from the Highland Council is that since the introduction of the
Badenoch and Strathspey STL Control Area on 4th March 2024, 60 planning
applications have been submitted as a consequence of the designation. 
Currently 52 are under consideration, with 8 having been approved.
4.3 The Local Housing Strategy identified housing supply and affordability
concerns of communities, particularly in rural areas, resulting in an action to
consider the feasibility of a Control Area (Action 1.7.LHS_2022-
27_Action_Plan.pdf (pkc.gov.uk); to develop projects for key worker housing
funding in the action plan update (LHS_Annual_Progress_Report_2022-
24_tz54epk2hrlf.pdf (pkc.gov.uk); and to assist with the alleviation of
recruitment issues, highlighted on page 14-15 of the STL Evidence Report
(appendix 1).
4.4 The EI&ED Committee of 31st May 2023 (Short Term Let Control Area:
Proposals for Consultation - no.23/171,) approved the undertaking of public
consultation on the principle and agreed the potential boundary of a Short-
term Let Control Area, with an instruction to officers to report on the results
and to provide additional analysis based on applications for short-term let
licences. The consultation was completed in August 2023; however, the
Scottish Government extended the deadline for submission of licence
applications by existing operators to 1st October 2023, resulting in a delay in
completion of the analysis to late spring 2024.
4.5 Non-statutory planning guidance was also approved by Committee in
November 2023 (Short Term Let Non-Statutory Planning Guidance - no.
23/289) to support planning determinations for Change of Use of residential
dwellings to short-term lets across the entire Council area. Short-term Let
Control Area regulations apply to a particular short-term let, that is a
secondary residence which is not in whole or in part, a primary or main
residence.
4.6 Following a non-statutory consultation exercise in 2023, a total of 334
responses were received from residents (224), business owners (95), and
various organisations, both community trade (14). 53% of respondents agreed
with the proposal to designate an STL Control Area with 41% disagreeing and
5% having no strong opinion either way. In general responses from within the
proposed control area were more strongly in favour of the principle, at 76% of
residents and 57% of organisations.  However, businesses were generally not
supportive with 69% against the principle. Further detail is included in
appendix 2.
4.7 The STL Licence scheme had registered a total of 1124 existing secondary let
applications by the close of the register for existing lets in October last year,
with the majority in Highland Housing Market Area (HMA) at 53%, 17% in
Greater Perth HMA, 14% in Eastern, 13% in Strathearn, and 2% in Kinross.  A
distribution map is included in the Evidence Paper attached as appendix 1.
Table 1: Distribution of secondary existing lets across Housing Market Areas at 1st November 2023
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4.8 It is worth noting that there has been an 8% growth rate per annum of new,
secondary home STLs added to the licence register since the relevant
legislation was introduced in October 2022.
5. PROPOSALS
5.1 Following further analysis on housing affordability and market pressure;
distribution of registered STLs; the introduction of a short-term let Control
Area would help to achieve a better balance between supporting the provision
of visitor accommodation, and the protection of future housing supply within a
defined area. Protection of that future housing supply will also support the
sustainability of the visitor economy which helps sustain more than 8000 full-
time equivalent jobs across Perth and Kinross (STEAM, 2022). Short-term let
levels have been evidenced as a contributor to housing pressure within
specific areas (appendix 1) of Highland Perthshire and northern half of the
Eastern housing market areas.
5.2 Consequently it is recommended that a short-term let Control Area is
established in the above areas as delineated in the map attached as appendix
4.
5.3 The effects of a Control Area would be to:
 Allow the Council as planning authority to consider the best use of
residential properties in defined areas of higher concentrations of STLs
in areas of higher housing pressure, along with other relevant planning
matters such as character and amenity.
 Assist the Council in managing sustainable tourism development by
aligning the planning requirements for short-term lets with other forms of
tourism accommodation.
 Clarify to the tourism industry that proposals for new STLs may not, in all
instances, be considered by the Council as the most appropriate use of
residential dwellings within the Control Area.
 Create clarity around when planning permission is required for a Change
of Use by requiring it in almost all circumstances.
 Create parity across all forms of secondary STLs (currently only flatted
dwellings, which generally are smaller operations, are explicitly required
to apply for planning permission).
 Control any potential displacement impacts from the adjacent Badenoch
and Strathspey STL Control Area.
5.4 The specific features of a Control Area are that:
 It is not retrospective and does not apply where the change of use to
short-term let occurs prior to the Control Area coming into effect.
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 The requirement for planning permission only applies to secondary
dwellings (properties that are not part of a main, primary residence).
 The requirement applies only within the STL Control Area.
 It is not a ban on short-term lets rather, it enables full consideration of
each STL application through the planning process.
 It does not negate the need for a STL Licence.
 Planning permission, where required, is usually granted on a permanent
basis, whereas an STL Licence requires renewal every three years.
 STLs with evidenced operation of 10 years or more do not require
planning permission regardless of whether a Control Area is in place.
6. STATUTORY PROCESS
6.1 Should the Committee agree to the recommendation to establish a Control
Area, a statutory process is required to be followed:
 Publish public notification of the intention to designate a Control Area,
including a statement of reasons (appendix 3) and a map of proposed
Control Area (appendix 4). A minimum period of 28 days must be given
for public representations to be made. 
 A subsequent report to Committee on the outcome of public notification,
and any changes because of representations received, prior to
submission to Scottish Ministers for their approval.
 On approval from Scottish Ministers, the notice of designation of the
Control Area is required to be published including the date on which the
designation becomes effective, together with the finalised map.
6.2 Considering the time required by Scottish Ministers to reach a decision, it is
estimated that a Control Area could be established mid-2025.
7. CONCLUSION
7.1 The evidence from public consultation and additional Licence data research
supports action to allow the Council as Planning Authority to consider the
most appropriate use of residential properties in specific areas of housing
pressure. In these areas there are higher than average concentrations of
STLs. It is therefore recommended that the committee approves the
commencement of the formal process to designate an STL Control Area
across the Highland Perthshire Housing Market Area and the northern part of
the Eastern Housing Market Area. 
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Authors
Name Designation Contact Details
Stephanie Durning
Katrina Walker
Planning and Policy
Officer, Housing
Strategy Team
Planning Officer,
Development Plans
Team
(01738) 475000
ComCommitteeReports@pkc.gov.uk
Approved
Name Designation Date
David Littlejohn Strategic Lead, Economy,
Development & Planning
16 August 2024
APPENDICES
 Appendix 1 – Short-term Lets Evidence Paper
 Appendix 2 – Consultation Results
 Appendix 3 – Statement of Reasons
 Appendix 4 – Map of Proposed Control Area
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ANNEX
1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND
COMMUNICATION
Strategic Implications Yes / None
Community Plan / Single Outcome Agreement Yes
Corporate Plan Yes
Resource Implications
Financial None
Workforce Yes
Asset Management (land, property, IST) None
Assessments
Equality Impact Assessment
Strategic Environmental Assessment Yes
Sustainability (community, economic, environmental)
Legal and Governance None
Risk None
Consultation
Internal Yes
External Yes
Communication
Communications Plan Yes
1. Strategic Implications
Community Plan/Single Outcome Agreement
1.1 This report supports the priority within the Community Plan 2022-27 to reduce
poverty by recognising the need to consider the impact short-term lets can
have on the availability of affordable housing.
Corporate Plan
1.2 This report supports the objectives within the Corporate Plan 2022-2027 to
tackle poverty by recognising the need to consider the impact short-term lets
can have on the availability of affordable housing.
2. Resource Implications
Financial
2.1 n/a.
Workforce
2.2 The introduction of a Short Term Let Control Area would result in additional
planning applications being received by the Council. This will have an
associated increase in workload pressures. The Planning Service will monitor
and manage any increase, and at this time it is not anticipated that more
staffing will be required.
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Asset Management (land, property, IT)
2.3 n/a.
3. Assessments – Highlighted sections to be updated once the new IVA
process has been completed
Equality Impact Assessment
3.1 Under the Equality Act 2010, the Council is required to eliminate
discrimination, advance equality of opportunity, and foster good relations
between equality groups.  Carrying out Equality Impact Assessments for plans
and policies allows the Council to demonstrate that it is meeting these duties. 
The Equality Impact Assessment undertaken in relation to this report can be
viewed clicking here. Final STLCA EFIA.pdf
This section should reflect that the proposals have been considered under the
Corporate Equalities Impact Assessment process (EqIA) with the following
outcome:
(i) Assessed as not relevant for the purposes of EqIA
(ii) Assessed as relevant and actions taken to reduce or remove the
following negative impacts:  (add summary points only here)
(iii) Assessed as relevant and the following positive outcomes expected
following implementation:  (The proposal has the potential to have 
positive impact by increasing the number of homes in the Short-term
lets by with potential small impact on affordability. ).
Strategic Environmental Assessment
3.2 The Environmental Assessment (Scotland) Act 2005 places a duty on the
Council to identify and assess the environmental consequences of its
proposals.
3.3 Proposals have been considered under the Act and pre-screening has
identified that the PPS will have no or minimal environmental effects, it is
therefore exempt and the SEA Gateway has been notified. The reason(s) for
concluding that the PPS will have no or minimal environmental effects is that
the planning guidance will be non-statutory and sit within the framework of the
National Planning Framework 4 which has undergone full SEA.
Sustainability
3.4 Under the provisions of the Local Government in Scotland Act 2003 the
Council has to discharge its duties in a way which contributes to the
achievement of sustainable development.   Under the Climate Change
(Scotland) Act 2009 the Council also has a duty relating to climate change
and, in exercising its functions must act:
 in the way best calculated to delivery of the Act’s emissions reduction
targets;
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 in the way best calculated to deliver any statutory adaptation
programmes; and
 in a way that it considers most sustainable.
This section should reflect the steps that have been taken to assess the
proposals against the Council’s Principles for Sustainable Development. Click
here for further guidance.
Legal and Governance
3.5 If the Council decides to proceed to the formal designation of a control area
then input will be sought from Legal and Governance.
Risk
3.6 n/a.
4. Consultation
Internal
4.1 Advice and views have been sought from colleagues in Development
Management and the Communities – Place Development Team in the
preparation of this report.
External
4.2 Consultation has taken place with neighbouring local authority, the Highland
Council, and with the Cairngorms National Park Authority in respect of our
proposals to designate a Short-term Let Control Area. Neither has raised
concern. The Highland Council has also provided some information on
applications submitted post Control Area designation.
5. Communication
5.1 The formal notification regarding designating a short-term let control area will
be open to the general public across the whole of Perth & Kinross via the
consultation hub and a hard copy available for consultation in. It will also be
particularly targeted at:
 community groups;
 community development and housing trusts;
 the Association of Scotland’s Self-Caterers;
 local tourism associations in particular those within the potential control
area;
 HSCP
 neighbouring local authorities and National Park Authorities.
2. BACKGROUND PAPERS
2.1 The following documents were referred to or relied upon in preparing this
report:
 Perth & Kinross Local Housing Strategy 2022-27
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 Town and Country Planning (Short-term Let Control Areas) (Scotland)
Regulations 2021
 Planning Circular 01/2023: Short-term Lets and Planning
 National Planning Framework 4
 Perth & Kinross Local Development Plan 2
 Perth & Kinross Council STEAM Tourism Economic Impacts 2023 Year
in Review
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1
Appendix 1
Table of Contents
1.Introduction ..................................................................................................................................................................................................2
2.Evidence ......................................................................................................................................................................................................6
Tourism ........................................................................................................................................................................................................6
Short-term Let (STL) Licence Data ..............................................................................................................................................................8
Business Concerns .................................................................................................................................................................................... 10
Essential Services ...................................................................................................................................................................................... 11
Unmet Housing demand ............................................................................................................................................................................ 11
Housing Affordability and Pressure study .................................................................................................................................................. 14
Consultation Results .................................................................................................................................................................................. 17
Planning Applications ................................................................................................................................................................................. 20
Evaluation of all Evidence .......................................................................................................................................................................... 21
3. Proposals .................................................................................................................................................................................................. 23
4. Conclusion ................................................................................................................................................................................................ 25    
Appendix 1b Arneil Johnson AJ STL Research Report - appended
7
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1. Introduction
Through several strategies and plans, and direct engagement, communities have expressed concern that housing is
becoming more unaffordable and difficult to find in some parts of Perth and Kinross:
 the Local Housing Strategy (2022-2027) - 5._LHS_Consultation_Report.pdf (pkc.gov.uk) -
 the emerging Local Development Plan 3 - The Big Place Conversation - Perth & Kinross Council (pkc.gov.uk)
 the national park proposal Tay_Forest_National_Park_-_Consultation_Analysis_Report_Final_for_website.pdf (pkc.gov.uk)
 Community Action Plans:
o PH8_Community_Action_PLan_2022-2027_FULL_DIGITAL.pdf (dunkeldandbirnamnews.co.uk)
o PitlochryCAP-fin_al-document-with-printer-1.pdf (pitlochryaction.org.uk), PitlochryCAP-fin_al-document-with-printer-1.pdf
(pitlochryaction.org.uk)
o Highland___Strathtay_Local_Action_Plan.pdf (pkc.gov.uk).
Concern has also been expressed that lack of access to affordable housing is impacting upon the viability of local service
provision and the current and future growth potential of some businesses.  This includes the visitor economy, the positive
benefits of which cannot be fully realised due to staff accommodation shortages. The Council currently commits investment
Short-term Lets Evidence Paper         15th August 2024
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and resources, including direct provision of social housing, to
support the vitality of communities, however no single
intervention alone will address the issue, and a range of policy
responses are required, including the management of the supply
of short-term lets.
In evidencing the need for change, the following Perth and
Kinross Council corporate priorities are of relevance:
1) Tackling poverty - the most direct intervention to reduce
poverty is to enable access to jobs and there is a clear link
between affordable housing availability and ability to work,
particularly in rural areas.
2) Supporting a stronger and greener economy –
supporting sustainable growth by creating the right
environment to harness the potential of businesses and
communities, and again balancing the needs of residents
and visitors is important in this regard.
3) Working in partnership with communities – listening to
communities’ needs and supporting sustainable
communities is central to the Council’s mission and
communities have offered a clear view on the imbalance
between housing to meet local need and that needed
to support the visitor economy.
Figure 1: PKC Corporate priorities.  Source: Corporate Plan Introduction
- Perth & Kinross Council (pkc.gov.uk)
It is recognised that tourism is an essential part of the economy across large parts of Perth and Kinross, contributing over
£700m last year, and directly and indirectly supporting over 8,000 jobs (STEAM, 2022). As such a priority of the Council is to
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support economically, environmentally and socially sustainable tourism development. Emerging economic policies and
reviews at regional and local level are therefore supportive of a sustainable tourism economy. The Perthshire Tourism
Action Plan 2021-2025 includes four agreed strategic objectives towards the ambition to become a leading sustainable
destination in Scotland.
 To restore the value of tourism to pre-COVID-19 levels, with a particular focus on extending the season for year-round
visits.
 To establish Perthshire as a leading responsible tourism destination in Scotland
 To increase the impact and benefit of tourism across Perthshire’s communities
 To make Perthshire a digitally discoverable and enabled destination.
But this cannot be at any cost and while National Planning Framework 4 (NPF4) states that it wishes to encourage, promote
and facilitate sustainable tourism through Policy 30 Tourism it also references the need for balance:
NPF4 Policy 30 e):
“Development proposals for the reuse of existing buildings for short term holiday letting will not be supported where the
proposal will result in: 
i) An unacceptable impact on local amenity or the character of a neighbourhood or area; or 
ii) The loss of residential accommodation where such loss is not outweighed by demonstrable local economic benefits”.
The proposal to introduce a short-term let (STL) Control Area for planning purposes is one means by which the Council could
support a better balance of tourism accommodation provision and the housing needs of the local community in locations
where the current balance is not working to best effect for residents, businesses and services.
An STL Control Area would require planning permission to be sought for changes of use of all residential properties to
secondary (standalone) short-term lets. In those areas where there is clear evidence of both housing need and density of
short-term lets, it would give the council the opportunity to consider residential need along with other planning matters on
future applications, supported by the current non-statutory planning guidance and in line with NPF4.
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It would therefore not be a blanket ban on short-term lets and would not be applied retrospectively to existing properties
operating lawfully (in planning terms) as short-term lets. It would allow the planning service to consider the balance of benefits
to support sustainable tourism development within vibrant communities, by potentially protecting future new build housing
from being used for short-term letting.
As mentioned above, the proposal is only one of several tools supporting sustainable communities. Other initiatives include:  
Council Tax second homes supplement
 Legislation was introduced in April 2024 was introduced to allow Councils to increase the second homes supplement
to 100% to address second home ownership. Perth & Kinross Council has exercised this option.
Rural Homes
 Working with Scottish Government to release funding for homes for rural key workers
 Working to identify land suitable for affordable housing for short-term and longer-term land supply.
 This land supply will support Council and community led housing development opportunities.
Empty Homes
 Working with Empty Homes team and Housing Enablers to channel funding and efforts to bring suitable empty
properties into use.
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2.   Evidence
Tourism
The visitor economy has been impacted by recent economic challenges and although has not quite returned to the peak of
2019, recovery appears to be relatively strong in the face of current economic circumstances. Despite lower levels of visitor
numbers (2.32 million) and stays (397,000 non-serviced accommodation) than 2019, the economic value of the sector as a
whole and the value of the non-serviced tourism accommodation* in 2023, at £307million, was higher than 2019 (Figure.2).
Employment in the non-serviced accommodation sector has not returned to the 2019 peak with 2260 full time equivalent jobs
in 2023, 21% down on the 2019 peak.
Tourism growth strategies are focussing on actions to extend stays and out-of-season visits as well as higher per visit spend.
*Non serviced accommodation - Self-catering, lodges, glamping pods, camping (tent pitches), caravanning (static pitches) 
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Figure 2: Source: PKC STEAM REPORT FOR 2012-2023
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8   
Short-term Let (STL) Licence Data 
Analysis presented to Committee in May 2023 was reliant on proxy data from booking platforms and second home Council Tax
registrations. A commitment was made to update this using the short-term let Licence Register data. Applications for properties
already operating (existing) STLs were required to be submitted by 1st October 2023, although applications continued to be
submitted after this deadline. From this data the distribution of STLs is mapped in figure 4 below. The larger tourism “resorts” are
clearly defined and bigger clusters of individual STLs can be seen in locations such as Pitlochry and Perth city centre, with low
numbers in Kinross-shire. Across the Housing Market Areas, Highland has the largest proportion of STLs at 53% of all short-term
lets in Perth and Kinross and represents the importance of tourism in this area. 17% of all currently operating STLs are in
Greater Perth HMA, 14% in Eastern, 13% in Strathearn, and 2% in Kinross (HMA). 
Figure 3: Indicating the count of existing STLs in each Housing Market Area.
This data formed the basis of research conducted in by consultants in late spring 2024 into affordability and housing pressure
and the role of concentrations of short-term lets across Perth and Kinross and is discussed later in this paper.
According to licence registrations data there has been continued growth of new, secondary STLs, at a rate of 8% per annum
since the STL licence legislation was introduced in October 2022. This indicates that the introduction of the STL licensing
scheme has not had a downward impact on the number of STLs accepting its principal purpose is to manage amenity.
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Figure 4: Map of Short-term let applications on 1st Nov 2023 showing the distribution of
existing secondary, STLs including purpose-built premises but excluding
unconventional dwellings i.e. chalets, yurts etc.
Legend
STLs by
Postcode
Housing Market
Areas
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Business Concerns
Local Housing Needs Assessments conducted in 2021 and 2022 highlighted business challenges resulting from staff
recruitment and retention due to housing availability (figure 5 below). Business responses indicated concerns on current and
future business in locations where tourism a key part of the economy.
Figure 5: Business survey collated from HNAs 2021-2022  
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Essential Services
Since 2021, there has been several reports to various departments in the Council of essential services being temporarily
impacted by staffing issues linked to accommodation shortages, in these instances across Highland Perthshire, affecting: 
o NHS - temporary closure of Pitlochry Community Hospital Inpatient services
o Reserve fire services in Dunkeld – issue reported to Community Planning Committee
o Education service in Kinloch Rannoch – reported to Housing Services
Although the impacts were not permanent, these could be early warning signs of future longer-term difficulties.
Unmet Housing demand
Public and stakeholder engagement for the Local Housing Strategy showed that 71% of respondents in Highland Housing
Market Area (HMA) have concern over sufficiency and affordability of housing and 48% in Eastern (Strathmore & the Glens)
HMA, as outlined in figure 6 below.
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Figure 6 LHS Engagement concerns regarding housing 2022-02-15 PKC LHS Early Engagement Results.pdf
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These concerns were evidenced directly in a Local Housing Need Assessments that were conducted by the Community
Housing Trust between 2021-2022 as part of feasibility work for rural affordable housing (figure 7 below). The surveys were
completed in locations of concern over housing supply and affordability. The surveys have quantified significant housing
need, in market and affordable housing tenures. 
Figure 7:  Collated surveys of Housing Need surveys 2020-2022
Settlements Low Cost Rent LCHO
Market Rent
/Purchase
options
Total
Affordable
New Build
Aberfeldy and surrounds 55 71 71 197
Pitlochry 34 18 35 87
Blairgowrie & Rattray 34 17 not surveyed 51
Dunkeld & Birnam 22 19 40 81
Mount Blair/ Strathardle 19 12 14 45
Comrie 15 45 42 102
TOTAL 563
Affordable Housing Demand
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Housing Affordability and Pressure study
A Perth and Kinross wide study of affordability and housing pressure was conducted in spring 2024 as part of this STL
Evidence Research Report by housing research consultants Arneil Johnston (attached as Appendix 1a).  The study
assessed the role of various indicators including short-term lets and compared various factors of housing pressure across
Housing Market Areas and in targeted locations (hotspots) where concentrations of STLs suggested a targeted analysis
would be of value.
Analysis of affordability (graph 2.6,p.23) indicates that the lowest levels of affordability are Comrie, with 89% of resident
households unable to afford the average market house price, 88% in north Eastern HMA and 85% in Highland HMA. 
A summarised analysis across all the Housing Market Areas is outlined on page 70 (slide 20) of the appended report. The
table demonstrates in both weighted or unweighted scores that the highest pressure of all areas and on all indicators is in
Highland Market Area with STLs having the greatest impact in this market.  Housing pressure is twice as great in Eastern as
in Greater Perth HMA but more moderate, whilst the moderate pressure in Kinross-shire is not due to STLs. Pressure in
Strathearn is more significant but due mainly to affordability reasons with a more moderate impact from STLs. 
Housing pressure analysis on more targeted areas ‘hotspots’ also outlined on Page 70 (slide 20) indicates higher pressure in
the northern part of Eastern in both weighted and unweighted scores, scoring high in all indicators of pressure, including
Short-term Lets. This analysis in targeted locations explained that the unweighted score of 16 for the whole of Eastern HMA,
indicating lower pressure, is a result of the southern part of the housing market area, tempering the overall score for the
HMA. Scores on all indicators are low for Perth City hotspot including STLs, indicating that concentrations of STLs are too
low to contribute to housing pressure in Perth City.  In relative terms, it is noted that the housing pressure in Comrie and
Crieff is greater than the Perth city hotspot, and while this is not insignificant, these areas currently have relatively few STLs
which will have a lesser impact on housing pressure.  
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Having identified levels of housing pressure, the study also assessed the potential for future housing provision as a mitigator
of housing pressure in terms of unconstrained land available for housing. Figure 8 below, maps the distribution of
unconstrained land suitable for housing and Graph 3.3 on page 29 of the appended report, demonstrates the proportion in
each housing market area (mis-labelled Effective Land Supply). Greater Perth has 55% of suitable land whereas the
potential for areas outside Greater Perth to mitigate housing pressure through new build housing is clearly constrained
where Strathearn has 16%, the majority in Crieff at 10%, Comrie with 1%. Eastern has 13% of suitable land but none within
the north Eastern hotspot area.  Kinross has 9% of land and Highland has just 3% of unconstrained housing land. 
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16
Figure 8: Distribution of unconstrained housing land per Housing Market Area
Legend
HLA–
unconstrained
land
Housing
Market Areas
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17
The consultant’s STL Evidence Research report considered the contribution to housing market pressure of STLs and where
the intervention of a STL Control Area could protect future housing supply, reduce demand in the housing market from
commercial accommodation uses, and positively impact housing affordability. The consultants’ recommendations were to
include Highland, the northern part of Eastern, as well as Crieff and Comrie postcodes in a STL Control Area with their
justification being that all those areas have housing pressure and STLs are a contributor to even lower levels of pressure.
However, these recommendations have not been accepted in their entirety and the reasons are set out in the ‘Evaluation of
Evidence’ section below.
Consultation Results
The aggregate consultation results in figure 10 below illustrates that most responses were in favour of the principle of an
STL Control Area at 53% for, and 41% against not in favour.  When views were broken down by respondent type, there was
an almost equal split with 70% of residents agreeing and 73% of business owners disagreeing. Responses on behalf of
organisations were split equally between agree and disagree. The same pattern of responses was expressed for the
proposed location of the STL control area (Highland HMA and the northern half of Eastern HMA) with 46% supportive and
43% not in favour. 11% were uncommitted either way. 
The consultation asked for an indicator of location of the respondent with a postcode area. Over 200 (67%) responses came
from postcode areas within the proposed control area location. Of these, most responses were in favour of the principle at
76% of residents and 57% of organisations in support.  75% of residents and 80% of the 7 organisations representing the
control area were in favour of the location and are illustrated in the consultation report in appendix 2 of the 28th August
Economy and Infrastructure Committee Report, page 14. Again, business responses from postcode areas within the
proposed control area were not in support, with 69% not in favour of the principle.  
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18
Figure 10: Consultation responses to principle and location of the proposed STL Control Area
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Figure 11: Consultation responses to principle of the proposed STL Control Area by respondent categories
Organisations included
Community Councils (3)
Community Development Trusts (2)
Trade orgs (5)
Groups of residents (2)
Political Groups (2)
Q. To what extent do you agree with the principle of a short-term let planning control area?
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Planning Applications
Figure 12: Number of Short-term let planning applications 2021 - June 2024
Figure 12 relates to the planning applications for short-term lets since September 2021, when the STL licence scheme was
introduced. 15% were for Certificates of Lawful Use of existing lets for previous development with permission or continued
use over 10 years. 13% represented commercial or agricultural diversification, 9% for conversions and Change of Use for
primary residential properties and 73% for change of secondary residential properties. The evidence suggests there is a
significant number of STL owners who believe what they are using their property for is not a material Change of Use and
therefore they do not believe they require planning consent, have been operating as an STL for more than 10 years, or are
unaware of the need to consider Change of Use permission.
Wards with Approved  Refused  Certificate
of Awaiting
applications Applications Applications Lawfulness  Decision
Ward 1 Carse of Gowrie 1 1 1 2
Ward 2 Strathmore 1 1 0 2
Ward 3 Blairgowrie 15 1 4 0
Ward 4 Highland  23 14 18 4
Ward 5 Strathtay 10 5 4 1
Ward 6 Strathearn 14 0 4 2
Ward 7 Strathallan 17 1 2 0
Ward 8 Kinross-shire 11 1 2 1
Ward 9 Almond & Earn 2 1 0 4
Ward 10 Perth City South 1 3 0 0
Ward 11 Perth City North 3 0 0 0
Ward 12 Perth City Centre 33 8 3 0
TOTALS 131 36 38 16
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Evaluation of all Evidence
The evidence of the growth of STLs, locally evidenced housing demand, and business challenges suggests that the balance
of economic benefit of the visitor accommodation sector and housing need is not working without further intervention. The
consultation responses also demonstrate the extent to which tourism is a vital part of the economy in some parts of Perth
and Kinross and that a balanced approach is needed to manage the available housing stock more effectively.
Although the housing pressure study in the appended consultant's report recommends a comprehensive approach,
suggesting an STL Control Area in locations of both relatively high pressure (Highland HMA and the north Eastern ‘hotspot’)
and more moderate pressure (Crieff and Comrie) where the number of STLs play a part, the recommendations set out in the
research report are not fully supported. Closer examination of the concentrations of STLs (outlined in figure 12 below) in the
Comrie postcode area show a lower percentage of STLs at 2%. Second homes are a greater contributor to housing pressure
in this area at 3%.  As such, other controls such as the Council Tax supplement may be more effective. In the Crieff area
STLs are also not a significant contributor to housing pressure being approximately the same as the Perth and Kinross
average.  In contrast this is not the case with Highland and north Eastern HMAs, with STLs well above average
concentrations at 9% and 13% respectively. This is distinctly higher than in other parts of Perth and Kinross, as illustrated in
figure 13 below. 
The consultation on the principle and boundary of a control area found that most respondents from the Crieff and Comrie
postcodes areas were not supportive of a control area whether resident or business, with 40% in favour and 60% against
overall. More detailed analysis did not contradict the overall distribution of responses.
The Council’s strategic approach is for sustainable tourism development using a balanced approach, acknowledging the
benefits visitor accommodation can bring to local economies. It is therefore recommended that an STL Control Area would
be appropriate in the more limited geographic area of the Highland HMA and the northern part of the Eastern HMA to help
manage the future balance of availability of residential homes and short-term lets.
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Figure 13: Concentrations of STLs as % housing stock by study areas
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3.  Proposals
Following further analysis on housing affordability and market pressure and distribution of registered STLs it is proposed that
the introduction of a short-term let Control Area would help to achieve a balance between supporting the visitor economy and
housing supply within defined geographies. It is considered that the introduction of a STL planning Control Area for the
housing market areas of Highland Perthshire and the northern half of the Eastern housing market area, as illustrated in
appendix 4.  Short-term let levels have been evidenced as a contributor to housing pressure within this area. This area also
coincides with the area consulted on in 2023. 
Effects of a control area 
A Control Area would not be a ban on short-term lets, rather it would enable full consideration of every instance of a
residential change of use to an STL, allowing the planning authority to consider the best use of residential properties in areas
of housing pressure alongside other relevant planning matters such as character, amenity and parking. 
It would provide clarity that planning permission is always required for a Change of Use from residential to STL and would
create parity across all forms of secondary STLs. Currently, only smaller operations in flatted dwellings are explicitly required
to apply for planning permission. Further, it would align the planning requirements for STLs with other forms of visitor
accommodation.
The introduction of a Control Area would clarify to those who are considering entering the market in the future that proposals
for new changes of use to STL would be subject to planning permission and may not be considered the most appropriate
use of residential dwellings within that area, potentially impacting demand. 
Lastly, a Control Area within these parts of Perth and Kinross would have the potential to help reduce any displacement
impact from the adjacent Badenoch and Strathspey STL Control Area. 
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Features of a control area
The requirement for planning permission within a control area is not retrospective. It would not therefore apply where the
change of use occurs before the control area comes into effect. Nor would it automatically apply to changes of use of
residential dwellings to STL which are outwith the designated area. In such cases it would still be necessary to determine
whether the change of use was material. Any subsequent change to the boundary of an existing control area, or the
introduction of a new control area, would require the same justification and statutory designation process. 
The requirement for planning permission within a control area would be limited to secondary dwellings and therefore would
not apply to primary (main) residences. 
The legislation does not impact dwellings being used solely or primarily as second homes. 
The planning permission is usually granted on a permanent basis, whereas an STL Licence requires renewal every three
years.
Potential longer term unintended consequences
It maybe that some short-term lets are reverted solely to second homes for private use and therefore less economically
active; resulting in a deeper negative impact on locations where there is a high concentration of second homes as well as
short-term lets. The introduction of the council tax supplement for second homes may partially mitigate this impact, by
reducing the number of second homes through taxation.
Displacement of STL demand to locations outside the control area boundary but still within the PKC area is a potential
unintended consequence. This could increase market demand immediately outside the control area, therefore consideration
should be given to where the boundary is located.  This could be a positive in locations where concentrations of STLs and
where housing pressure is not a concern such as Blairgowrie, which could benefit from increased tourism accommodation
development. In locations where STLs are a lesser contributor to moderate housing pressure, displaced demand could
negatively impact housing pressure, such as Comrie and perhaps Crieff. As such it would be appropriate for the Council to
monitor the impact of the STL Control Area with regard to monitoring for displacement effects and, if necessary, seek a
variation of the Control Area where evidenced and appropriate. 
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4.   Conclusion  
In areas of high housing pressure there is evidence that this housing pressure is also impacting on local businesses and
services, evidencing the concerns of local communities. 
The Council is working to address other contributors to housing pressure:
1) Affordability 
 Working to deliver more affordable housing in areas of pressure through the affordable housing supply
programme, key worker homes funding, and community led housing.
2) Ineffective stock
 Impact demand for second homes via the council tax supplement.
 Channelling empty homes funding and efforts to bring properties back into use for homes for rent.
To supplement this work and investment, it is concluded that a short-term let Control Area will enable the planning authority
to consider the availability of residential homes and the concentration of short-term lets when making planning decisions. In
areas where unconstrained land is limited and therefore more difficult to build new homes, the ability to protect future new
homes where appropriate will be of value.
Appendix 1b - Ardneil Johnson AJ STL Research Report
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Donna Milton (MCIH)
Managing Director 
Elaine Byrne (CPFA)
Director of Housing Consultancy 
Perth and Kinross Council
Short Term Lets Evidence
Research Report
April 2024
7
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Table of Contents
Executive Summary .................................................................................................................................. 4
Housing Pressure Analysis Conclusions and Recommendations (HMAs) ............................................. 4
Housing Pressure Analysis Conclusions and Recommendations (Hotspots) ............................... 6
1 Introduction and Study Overview ................................................................................................... 8
1.1 Project Methodology ................................................................................................................. 10
2 Assessing Housing Affordability across Housing Market Areas .............................................. 11
2.1 Housing Cost Comparison ........................................................................................................ 11
2.1.1 Social Rent Comparison ........................................................................................................... 12
2.1.2 Market Rent Comparison .......................................................................................................... 12
2.1.3 Mid-Market Rent Comparison ................................................................................................... 15
2.1.4 House Prices Comparison ........................................................................................................ 15
2.2 Income Profile: CACI Paycheck Data ....................................................................................... 16
2.3 Model Assumptions: Income to Rent Ratios ............................................................................. 18
2.4 How Affordable are Perth and Kinross Market Rents when using a 30% to 35% Income to
Rent Ratio? ........................................................................................................................................... 19
2.5 How Affordable is the Perth and Kinross Housing Market? ..................................................... 21
2.6 Housing Affordability Outcomes by Tenure .............................................................................. 23
2.7 Key Findings: Perth and Kinross Housing Affordability Analysis .............................................. 24
3 Housing System Pressure Analysis ............................................................................................. 26
3.1 Housing Tenure and Dwelling Pressures ................................................................................. 26
3.2 Short Term Lets and Ineffective Housing Stock pressures ...................................................... 27
3.3 New Supply Pressures ............................................................................................................. 28
3.4 Household Income Pressures................................................................................................... 30
3.5 Housing Market Pressures ....................................................................................................... 31
3.6 Housing Affordability Pressures ............................................................................................... 33
3.7 Private Rented Sector Pressures ............................................................................................. 36
3.8 Social Housing Pressures ......................................................................................................... 39
3.9 Overall Housing Pressures by Housing Market Area ............................................................... 43
4 Research Conclusions and Recommendations .......................................................................... 46
4.1 Housing Pressure Analysis Conclusions .................................................................................. 46
4.2 Housing Pressure Recommendations ...................................................................................... 49 
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Perth and Kinross Council 
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Appendix 1:2024 Perth and Kinross STL Affordability Model (Data tables, available on request)
Appendix 2:2024 Perth and Kinross Affordability and Housing Pressures Slide-pack
(appended here)
Appendix 3 2024 Perth and Kinross Housing Pressures Dashboard (Data tables, available on
request) 
Arneil Johnston
Falkirk Business Hu
45 Vicar Street
Falkirk, FK1 1LL 
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April 2024 4
Executive Summary 
In February 2024, Perth and Kinross Council commissioned Arneil Johnston to carry out research
to evidence housing system pressures to inform policy consideration of short term let control
areas. This Executive Summary provides a summary of the research conclusions and
recommendations for each of the five HMAs across Perth and Kinross and the four proposed
hotspot areas. 
Short term let control areas are intended to help manage levels of short-term letting where this
affects the availability of residential housing or the character or amenity of a neighbourhood,
helping local authorities to ensure effective housing system operation and good access to
residential housing. To designate a short-term let control area, Perth and Kinross Council will need
to prepare a statement of reasons for their proposal, explaining to those affected by the control
area and to Scottish Ministers, why the designation is necessary. 
Housing Pressure Analysis Conclusions and Recommendations (HMAs)
Key indicators have been selected and synthesized to evidence housing market pressure in HMAs
to show that short-term letting may be affecting the operation of the housing system. These are:
This indicator considers the extent to which short term lets
are limiting residential housing supply. Highland has the
greatest proportion of short term lets stock limiting the supply
of residential dwellings in the area followed by Strathearn.
Kinross and Greater Perth have the lowest. 
This indicator considers households lower quartile (LQ)
incomes to house price ratios to assess the ability to access
the housing market. Access is challenging across Perth and
Kinross  with households required to spend almost 7 times
their LQ income. Access issues are greatest in Kinross and
Highland  with the least issues in Eastern and Greater Perth. 
Analysis of in-migration of house sales provides evidence of
the extent to which households purchasing homes from
elsewhere may be inflating prices. In the last 2 years the
average in-migration across Perth and Kinross was 41% .
High levels of in-migration in the Kinross, Highland and
Strathearn may be fueling house prices in these areas. 
Analysis of housing market affordability provides evidence of
households struggling to meet their housing needs in a HMA.
51% of households in Perth and Kinross cannot afford
market entry home ownership with Highland and Strathearn
having the greatest challenges. 36% of Perth and Kinross
households cannot afford LHA rents with affordability most
challenging in Eastern with 40% unable to afford LHA rate. 
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This indicator considers the extent new housing supply will
relieve housing pressures. Over the last 5 years house
completions range from 59% in Greater Perth to 3% in
Highland. The majority of land allocations in the Perth and
Kinross 5 year Effective Land Supply is in Greater Perth
(55%) followed by Strathearn (16%). The lowest is in
Highland (3%). Interventions will need to be considered to
maximize the existing housing stock.
The outcome of the weighted
scoring for each of the housing
pressures indicators shows that
Highland HMA has the highest
score (177) followed by Strathearn
HNA (139) and Greater Perth HMA
has the lowest (45). 
Synthesizing a number of key indicators as measures of housing pressure in each HMA area
would suggest the need for Short Term Let Control Area (STLCA) as follows. 
Eastern HMA: Clear evidence for the need for STLCA for hotspots within the HMA
• High levels of ineffective residential dwellings caused by short term lets with evidence they are
impacting on the supply of residential dwellings available in the housing market. 
• Evidence of house prices inflation caused by high in-migration impacting on local residents’
ability to access the housing market and to afford house prices 
Greater Perth HMA: No clear evidence for the need for STLCA for the HMA.
• Low levels of ineffective residential dwellings caused by short term lets
• No evidence of house price inflation being caused by short term lets or in-migration. 
Highland HMA: Clear evidence for the need for STLCA for the HMA
• High levels of ineffective residential dwellings caused by short term lets which are impacting
on the supply of residential dwellings available in the housing market. 
• Evidence of house prices inflation caused by high in-migration impacting on local residents’
ability to access the housing market and to afford house prices and private rents. 
Kinross HMA: No clear evidence for the need for STLCA for the HMA.
• Low levels of ineffective residential dwellings caused by short term lets impacting on the
supply of housing
• Evidence of house price inflation being caused by in-migration but this is not caused by
residential dwellings being used for short term lets. 
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Housing Pressure Analysis Conclusions and Recommendations (Hotspots)
Key indicators that short-term letting may be affecting the operation of the housing system in the
four proposed hotspot areas include: 
There are variations across the hotspot areas from the
Perth and Kinross average of 2% short term lets. The
greatest impact on limiting the residential market supply is
in North Eastern with 13% of the housing stock being short
term lets. There are lower supply  limitations in Perth City
Centre with less than 0.5% short term lets. 
Access to the housing market is extremely challenging
across Perth and Kinross with household on lower quartile
(LQ) incomes having to spend five times their incomes.
Households in North Eastern experience the greatest
mortgage multipliers  (9.2) while households in Perth City
experience the lowest (4.7). 
Analysis of in-migration of house sales suggests that high
in-migration levels in North Eastern (61%) and Comrie
(54%) may be fueling house prices in these hot spot areas
and creating housing market access issues. Perth City
Centre has low levels of in-migration (25%). 
Analysis of housing market entry affordability suggest that
households are struggling to afford market entry house
prices. Market entry difficulties are greatest in North
Eastern (74%), followed by Comrie (65%) and Crieff (55%)
and are least in Perth City Centre (44%). 
Analysis of the 3,354 completions (2019 to 2023) shows
that 40% of completions were in the Perth City Centre hot
spot and 4% of completions in Crieff. There were 7
dwellings completed in Comrie and none in North Eastern.
The majority of effective land supply is in Perth City Centre
followed by Crieff with limited supply in Comrie (1%) with
none in North Eastern. 
The outcome of the weighted scoring for each of the housing pressures indicators is detailed below
with North Eastern having the highest score (147) and Perth City Centre HMA having the lowest
(38). 
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Synthesizing a number of key indicators as measures of housing pressure in each hotspot area
would suggest the need for STLCA as follows: 
Overall Short term let Control Area Conclusions: Using the evidence based and scoring matrix
recommendations can be made for the  Council to consider STLCA in Housing Market Arears and
hotspots in Perth and Kinross. 
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1 Introduction and Study Overview
In February 2024, Perth and Kinross Council commissioned Arneil Johnston to carry out research
to evidence housing system pressures to inform policy consideration of short term let control
areas. In particular, support was sought to build the evidence needed to enable the Council to
consider whether pursuing an application for a Short-term Let Control Area would succeed in
relieving housing pressure and improving housing system operation in specific communities and
neighbourhoods.
Under Section 26B of the 1997 Town & Country Planning Act1, the approval of a short term let
control area means that if a residential property changes use for the purpose of offering short term
lets, this will be deemed a material change and will therefore require planning permission. Short
term let control areas are intended to help manage levels of short-term letting where this affects
the availability of residential housing or the character or amenity of a neighbourhood, helping local
authorities to ensure effective housing system operation and good access to residential housing.
To designate a short-term let control area, Perth & Kinross Council will need to prepare a
statement of reasons for their proposal, explaining to those affected by the control area and to
Scottish Ministers, why the designation is necessary. The Council must consider whether there
are: ‘systemic material planning considerations’ across one or more areas in the local area as part
of deciding whether to designate one or more control areas. A ‘systemic consideration’ includes
evidencing whether there is a cumulative impact from the use of residential homes as short term
lets, with indicators including a ‘lack of affordable and appropriate housing for local residents,
perhaps indicated by a high share of sale volumes to, and high prices paid by, non-residents’.
Therefore, the Council wish to evidence the housing system impacts of short term letting providing
credible evidence of housing system pressures including price inflation, housing affordability
pressures, affordable housing pressures and the impact of ineffective stock on access to
residential homes.
Analysis by the Council suggests that applications for a control area could be considered in the
following ‘hotspot’ areas: 
• Comrie,
• Crieff,
• North Eastern corridor
• Perth City Centre.
To support an application for designating a short-term let control area, a credible evidence base
will require to be assembled which shows the extent and nature of housing pressures experienced
by local residents in these hotspot areas, relative to other parts of the Perth & Kinross housing
system. In doing so, the evidence should show that housing system interventions (such as STL
control areas) would be beneficial in meeting housing need and could be justified within the local
development planning framework. 
1 As amended by The Town and Country Planning (Short-Term Let Control Areas) (Scotland) Amendment Regulations
2022
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Map 1.1 below shows the location of the five HMAs in Perth and Kinross (Eastern, Greater Perth,
Highland, Kinross and Strathearn)  and the location of the four hotspot areas to be considered as
part of the short let control area research study. 
Map 1.1: Perth and Kinross HMA and Hotspot Areas
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1.1 Project Methodology
The project methodology has been designed to build and deliver robust and credible evidence of
the impact of short term lets in each control area by delivering evidence on:
• housing affordability pressures across housing market areas (HMAs) and proposed hotspots in
Perth and Kinross
• income profiles and housing access barriers across each housing market/hotspot area
• tenure diversity and housing choice including the extent of ineffective housing stock including
short-term lets, second homes and empty homes
• the operation of the housing market including sales to in-migrating households and rising price
inflation
• the scale, operation and affordability of the private rented sector
• existing housing need and wider housing system pressures.
To achieve this, the research programme was executed around the following three stage
methodology:
• analytical modelling of housing affordability across hotspots and HMAs relative to local
incomes and range of housing options and tenures
• analysis of the extent and nature of housing system pressures across hotspots and HMAs with
a specific focus on market housing pressures
• assembly of an interactive data-book showcasing the housing system evidence, headlines and
insights assembled across each HMA and proposed hotspot. 
This research report details all aspects of the research, housing pressure analysis and housing
system evidence disaggregated to HMA and hotspot levels. 
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2 Assessing Housing Affordability across Housing Market Areas
Housing affordability analysis provides essential insight into the extent to which households can
independently access the housing market in each HMA/hotspot area or whether a wider range of
housing options is required to meet housing need. In particular, this analysis will establish the
proportion of households who can afford different tenure types across each of HMA/hotspot area to
support the evidence for short term control areas. Chapter 2 details the evidence of affordability
pressures across each housing market/hotspot rea in Perth and Kinross.
An analytical modelling tool and summary slide-pack detailing this analysis can be accessed by
clicking on the following links:
Appendix 1 PKC STL HNDA Affordability Model MASTER.xlsx
Appendix 2 Perth & Kinross STL slide pack HMA+HOTSPOT.pptx
As part of the Perth and Kinross Short-Term Let Research Study, Arneil Johnston developed a
modelling tool to comprehensively assess housing affordability by benchmarking the profile of local
incomes to housing costs across tenure. This analysis is disaggregated by the model so that
housing affordability can be tested at a housing market/hotspot area level. The following diagram
illustrates how the model works in practice:
The model is populated with data inputs and
insights on the costs associated with various
housing tenure options including:
• rent levels for Perth and Kinross Council
• rent levels for locally operating RSLs
• mid-market rent levels set at 100% of the
Local Housing Allowance
• PRS market rent levels
• housing market entry level prices
• average house prices.
Housing affordability is assessed by testing a range of income to rent ratios (the proportion of
household income to be devoted to housing costs) to assess the risks associated with housing
induced poverty in each tenure. Using a banded income profile from CACI PayCheck, the model
calculates the proportion of households who can/cannot afford housing costs across a range of
housing tenures and hotspot areas.
2.1 Housing Cost Comparison
The housing affordability model has been populated with housing cost benchmarks, including:
• social rent levels for Perth and Kinross Council and locally operating RSLs
• market rent levels established through a snapshot analysis of the number and value of local
residential vacancies, plus the Perth and Kinross dataset produced by Rent Service Scotland
• mid-market rent levels set at a threshold of 100% of the Local Housing Allowance (LHA) rate for
Perth and Kinross
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• house prices (lower quartile and average), sourced from analysis of house sale transaction data
provided by the Register of Scotland.
Benchmark housing costs for each tenure are profiled for each property size and housing
market/hotspot area below.
2.1.1 Social Rent Comparison
Social housing rent levels in Perth and Kinross have been calculated using data submitted by
Perth and Kinross Council and Registered Social Landlords (RSLs) to the Scottish Housing
Regulator (SHR) in 2022/23 as part of the Annual Return on the Charter (ARC dataset). This data
has been inflated to reflect the rent increases imposed by each landlord in 2023/24, as reported to
the SHR. Table 2.1 details social housing rent levels across Perth and Kinross Council by property
size as well as Local Housing Allowance rate for 2024/25 and average private sector market rents.
Table 2.1 Social housing rent levels and comparison with LHA and market rents for Perth & Kinross
Table 2.1 shows that average monthly Perth and Kinross Council rents range from £297 for a 1-
bedroom property to £386 for a 4-bedroom property. Overall, average monthly Perth and Kinross
Council rents (£321) are 17% lower than average RSL rents in Perth and Kinross (£376). RSL
rents range from £353 for a 1-bedroom property to £460 for a 4-bedroom property. 
Despite the higher rental values posed by RSL rents in Perth and Kinross, they are considerably
less than the Local Housing Allowance (LHA) rate for Perth and Kinross (the rate which subsidy
levels are set for the private rented sector). Set at an average of £744 per month in Perth and
Kinross, the Local Housing Allowance rate is 132% higher than Perth and Kinross Council rents
and 98% higher than RSL rent levels. For RSL rents, the margin between the LHA rate is
significantly above the RSL average rent by 98%, with LHA rates for 4-bedroom homes 171%
higher than RSL rents. The margin between LHA levels and Perth and Kinross Council rents is
also significant across all property sizes but most pronounced for 4-bedroom homes, where LHA
rates (at £860) more than Perth and Kinross Council rents are 223% higher.
This analysis showcases the extent of cost value between social and market housing costs in
Perth and Kinross. It should be noted that social housing rents and LHA rates will be consistent
across all housing market/hotspot areas in Perth & Kinross.
2.1.2 Market Rent Comparison
Average market rent levels by housing market area, hotspot area and property size were derived
from the monitoring dataset sourced from Rent Service Scotland to set the Local Housing
No. of Bedrooms P&K Council RSLs Local Housing
Allowance Market Rents
1 Bedroom £297 £353 £424 £452
2 Bedrooms £323 £383 £558 £613
3 Bedrooms £363 £419 £748 £836
4+ Bedrooms £386 £460 £1,247 £1,348
Average £321 £376 £744 £812
No. of Bedrooms Difference P&K
Council/RSL Rents % Difference
RSL/LHA Rents % RSL/Market Rents %
1 Bedroom -£56 -19% -£71 -20% -£100 -28%
2 Bedrooms -£60 -19% -£175 -46% -£230 -60%
3 Bedrooms -£57 -16% -£329 -78% -£417 -100%
4+ Bedrooms -£74 -19% -£786 -171% -£888 -193%
Average -£56 -17% -£368 -98% -£436 -116%
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Allowance (LHA) rate in Perth and Kinross The sample provided covered the period from 2019/20
to 2022/23 with the results outlined in Graph 2.1 below.
When analysing the Rent Service Scotland (RSS) data set it was agreed that market rent values
for Crieff would also be used for the Comrie hotspot area. This is due to a small RSS sample size
in the Comrie hotspot area, which created a significantly lower than average rent when compared
to the Crieff hotspot and wider Strathearn HMA. The North Eastern area also had a small RSS
sample size, however due to hotspot rents benchmarking well to the wider Eastern HMA, the rents
were deemed robust enough to be used as a credible benchmark.
In 2022/23, the average market rent in Perth and Kinross was £812 per month. Monthly rents vary
significantly across property size from an average of £452 for a 1-bedroom property to an average
of £1,348 for a 4-bedroom property. There is a high degree of variation in average rental market
prices across HMAs in Perth and Kinross. Strathearn is the HMA with the highest average rental
value at £868, followed by Highland at £850. In contrast, the Greater Perth HMA has the lowest
average market rental value at £789 and lower than the Perth and Kinross average market rent of
£812. 
The highest average market rents of all the four hotspot areas are found in Crieff and Comrie at
£823.00 per month, which is slightly lower than the Strathearn HMA average at £868, but higher
than the Perth and Kinross benchmark of £812. This suggests that there may be other areas
driving market rent values within the Strathearn HMA. The North Eastern hotspot has the second
highest average rent at £818 per month, which is slightly higher than the wider Eastern HMA
average rent at £801. The Perth City Centre hotspot has the lowest average monthly rents at £764,
which is £48 lower per month than the overall Perth and Kinross average. 
Graph 2.1: Average PRS rental values by HMA and property size
Table 2.2 shows that average market rents in Perth and Kinross are significantly higher than
Council rents, with the average Perth and Kinross market rent 153% higher than the average
social rent. This ranges from 146% in the Greater Perth HMA to 171% in Strathearn HMA. These
differentials follow a similar trend for hotspot areas, which range from 138% in Perth City Centre to
157% for Comrie and Crieff. 
The analysis also demonstrates a significant differential in rental values for larger properties as
Council rents in Perth and Kinross have a much flatter rental structure. As a result, the larger
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property size, the greater the differential between market rents and the average social rent levels
with an overall difference of 249% between 4-bedroom Council rents and 4-bedroom market rents. 
Table 2.2: Market rent levels and comparison with social housing rent levels for Perth and Kinross
To assess the affordability of the private rented sector for tenants who may be reliant on welfare
subsidies to meet housing costs, the Local Housing Allowance (LHA) for Perth & Kinross has been
compared with average PRS rents. Overall, market rents in Perth and Kinross are greater than
LHA levels, with average market rents (£812) 9% higher than LHA levels (£744). 
Table 2.3 shows that average market rents exceed average LHA levels across every housing
market and hotspot area. The margin between market rents and LHA is greatest in the HMAs of
Strathearn (15%), Highland (14%) and Kinross (12%) and greatest in the hotspot areas of Crieff
(11%), Comrie (11%), and North Eastern (10%). 
As market rents exceed LHA, for those households relying on welfare subsidies to meet housing
costs, shortfalls of between £20 per month in Perth City Centre hotspot, £74 per month in North
Eastern and £79 in the Crieff hotspot; are highly likely to make the costs of private renting
extremely challenging for lower income households who have may limited housing options
available to them. The difference is even greater for the Strathearn HMA (£124) and Highland
HMA (£106) suggesting there may be other market rent hotspot pressure within these HMAs. 
Table 2.3 indicates that the LHA exceeds average market rents for all property sizes across Perth
and Kinross as a whole with a notable margin in 2 bedroom properties by 10% and 3 bedroom
properties by 12%. 
Table 2.3: Market rent levels and comparison with LHA rates by HMA and hotspot
Property Size Market Rents P&K Council Difference %
1 bedroom £452 £297 £155 52%
2 bedroom £613 £323 £290 90%
3 bedroom £836 £363 £474 131%
4+ bedroom £1,348 £386 £962 249%
Average £812 £321 £492 153%
Area Market Rents P&K Council Difference %
Eastern £801 £321 £481 150%
Greater Perth £789 £321 £468 146%
Highland £850 £321 £530 165%
Kinross £835 £321 £514 160%
Strathearn £868 £321 £547 171%
Comrie £823 £321 £502 157%
Crieff £823 £321 £502 157%
North Eastern £818 £321 £498 155%
Perth City Centre £764 £321 £444 138%
Perth and Kinross £812 £321 £492 153%
Property Size Market Rents LHA Difference %
1 Bedroom £452 £424 £28 7%
2 Bedroom £613 £558 £55 10%
3 Bedroom £836 £748 £88 12%
4 Bedroom £1,348 £1,247 £102 8%
Area Market Rents LHA Difference %
Eastern £801 £744 £57 8%
Greater Perth £789 £744 £45 6%
Highland £850 £744 £106 14%
Kinross £835 £744 £91 12%
Strathearn £868 £744 £124 17%
Comrie £823 £744 £79 11%
Crieff £823 £744 £79 11%
North Eastern £818 £744 £74 10%
Perth City Centre £764 £744 £20 3%
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2.1.3 Mid-Market Rent Comparison
In addition to benchmarking to social rents, PRS rent levels are also assessed against the
affordability of rents in intermediate housing tenures. Table 2.4 below shows the differential
between market rents in Perth and Kinross where Mid-Market Rent levels (MMR) are set at 90%,
95% and 100% of the Local Housing Allowance rate.
As LHA rates fall short of market rent levels in every property size, Table 2.4 shows that in order
for MMR to make any contribution to housing affordability, MMR rents require to be set at the full
LHA threshold as a minimum. 
Table 2.4: Comparison between PRS rents and MMR rent scenarios by property size
Table 2.5 below highlights the difference that MMR would make across the HMAs and hotspot
areas to households who cannot afford market rents. There is evidence that MMR would make a
difference to households across all the HMA ranging from 6% in Greater Perth to 14% in Highland
and 17% in Strathearn. Across the hotspot areas only 3% of households would benefit from MMR
in Perth City Centre but significantly 11% would benefit in Crieff and Comrie and 10% in North
Eastern. 
Table 2.5: Comparison between PRS rents and MMR rent scenarios by HMA and Hotspot
2.1.4 House Prices Comparison
In 2022/23, the average house price in Perth and Kinross was £274,907 which is over £58k higher
than the Scottish average house price at £216,364. Highland has the highest average house price
at £327,130 of the five HMAs, while Greater Perth has the lowest average price at £242,468.
The highest average house prices in hotspot areas, are evident in Comrie and North Eastern at
£359,268 and £354,616 respectively, with the lowest average house price in the Perth City Centre
hotspot at £205,533. There was a £153,735 difference between the lowest and highest average
house prices in Perth and Kinross across the hotspot areas, providing an indication of the diversity
of properties available across the hotspot areas. 
Property Size Market Rents MMR 100% Difference 100%
Difference
95%
Difference
85%
Difference
1 Bedroom £452 £424 -£28 -7% -12% -25%
2 Bedroom £613 £558 -£55 -10% -16% -29%
3 Bedroom £836 £748 -£88 -12% -18% -32%
4 Bedroom £1,348 £1,247 -£102 -8% -14% -27%
Average £812 £744 -£68 -9% -15% -28%
Property Size Market Rents LHA Difference %
1 Bedroom £452 £424 £28 7%
2 Bedroom £613 £558 £55 10%
3 Bedroom £836 £748 £88 12%
4 Bedroom £1,348 £1,247 £102 8%
Area Market Rents LHA Difference %
Eastern £801 £744 £57 8%
Greater Perth £789 £744 £45 6%
Highland £850 £744 £106 14%
Kinross £835 £744 £91 12%
Strathearn £868 £744 £124 17%
Comrie £823 £744 £79 11%
Crieff £823 £744 £79 11%
North Eastern £818 £744 £74 10%
Perth City Centre £764 £744 £20 3%
Perth and Kinross £812 £744 £68 9%
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The market entry level house price in Perth and Kinross in 2022/23 was £155,385 with market
entry prices lowest in Perth City Centre hot spot (£117,250) which is lower than the Perth and
Kinross benchmark of £155,385. The highest market entry house price can be found in the North
Eastern hotspot (£255, 000), followed by Comrie (£202,488) and Crieff (£160,00) which are all
above the Perth and Kinross Bench mark (£155,385).  
When comparing the hotspots with their respective HMAs, lower quartile house prices are
considerable higher in North Eastern Hotspot (£255,000) when compared to the Eastern HMA
(£139,500) suggesting there are pronounced housing market pressures at market entry level in the
North Eastern hotspot. 
Analysis of average house prices between hotspots and HMAs evidence similar housing market
hotspot pressures with average house prices in Comrie (£359,268) significantly higher than the
Strathearn HMA (£313,241), and the North Eastern hotspot considerably higher (£354,616) than
the Eastern HMA (£228,176). This analysis would suggest exceptional housing market pressure
and inflation in these hotspot areas relative to the wider Perth & Kinross area.
Across the four hotspots only households living in Perth City Centre do not have to pay higher than
the Perth and Kinross benchmark for market entry, median and average house prices. Table 2.6
below provides a summary of house all house sales by HMA/hotspot for 2022/23: 
Table 2.6: Average, median and lower quartile house prices by HMA (2021)
2.2 Income Profile: CACI Paycheck Data
Establishing the income profile of local households is an important element of assessing the
affordability of each housing tenure in housing market areas and also in the proposed short term
let hotspots. To achieve this, analysis of CACI Paycheck data was performed to profile the value
and distribution of local incomes across a banded income profile. 
CACI Paycheck data also provides the lower quartile income levels at a Perth and Kinross level.
Analysis of Paycheck data reveals that the mean income in Perth and Kinross is £48,888 which is
higher than the mean income for Scotland at £44,445. The lower quartile income for households
living in Perth and Kinross is £22,662, which again is higher than is the case for Scotland (at
£19,565). Graph 2.2 below details the profile of incomes across Perth and Kinross by HMA/hotspot
and banded increments.
Area Average Price
2022/23
Median Price
2022/23
Lower Quartile
2022/23
Eastern £228,176 £219,975 £139,500
Greater Perth £242,468 £215,255 £133,390
Highland £327,130 £288,527 £187,000
Kinross £305,880 £283,000 £184,875
Strathearn £313,241 £270,000 £179,475
Comrie £359,268 £276,391 £202,488
Crieff £286,330 £249,450 £160,000
North Eastern £354,616 £280,000 £255,000
Perth City Centre £205,533 £187,886 £117,250
Perth and Kinross £274,907 £239,500 £155,385
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Graph 2.2: Banded income profile by Perth and Kinross HMAs (CACI Paycheck Data 2023)
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In Perth and Kinross, 20% of households earn less than <£20K per annum. There is clear
evidence of income inequality locally with just over half of households (51%) earning £40k+
annually.
Most HMAs and hotspot areas have a similar proportion of middle earners (£20k - £40k) to the
Perth and Kinross benchmark average of 29%, with more variation between HMAs and hotspot
areas on the proportion of high and low earners. In Kinross HMA, only 14% earn less than £20k
while 62% earn £40+k. Whilst Perth City Centre hotspot has 25% earning less than £20k and 44%
earning £40-+k. North Eastern hotspot has the highest proportion of households earning £40+k at
53% in contrast to 44% of households in Perth City Centre hotspot. 
2.3 Model Assumptions: Income to Rent Ratios
A key model assumption relates to the proportion of household income that an individual must
devote to meeting housing costs. Housing affordability analysis measures a person’s ability to pay
for housing. It is a complex issue influenced by local housing and labour markets as well as wider
economic, environmental and social factors.
The housing affordability model tests the interaction between housing costs, household incomes
and the proportion of income that households are typically willing or able to devote to rental
payments. When households struggle to meet the costs of housing because they are devoting
unsustainable levels of income to meet the costs, they are typically described as experiencing
housing induced poverty.
Measures of
housing
affordability are a
topic of debate. UK
social policy since
the 1980s has
typically used a
percentage of
income spent on
housing costs to
estimate the
number of
households
experiencing
difficulties.
Generally, those who require to spend more than 30-35% of their household income on housing
costs are regarded as experiencing affordability difficulties; although in highly pressured housing
market areas, housing consumers may opt to spend well in excess of this benchmark in order to
meet housing needs. 
A key aspect of model development has been to scenario test the proportion of household income
required to meet market rental costs at a 30% and 35% income to housing cost ratio. The PRS is
often a tenure of last resort for working age households who are not eligible for social housing and
who cannot access the housing market. For lower income households, the affordability of market
rents is a key indicator housing market pressure particularly where there is evidence of unmet
need for social housing.
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2.4 How Affordable are Perth and Kinross Market Rents when using a 30% to 35%
Income to Rent Ratio?
As shown in Graph 2.3, whilst Perth and Kinross PRS rents generally sit below Scottish average
rents; this in itself doesn’t prove rents to be affordable relative to local incomes. 
Graph 2.3: Cumulative changes in 2-bedroom market rents by Broad Rental Market Area 2010-22
(Scottish Government, PRS Statistics 2022)
In order to assess affordability, analysis has been performed which benchmarks PRS rents to local
income levels and assesses whether those earning minimum income thresholds (without reliance
on housing subsidies) could afford market rents and other rental tenures. To test this, analysis was
carried out to measure how much a household in Perth and Kinross would have to earn to be able
to afford PRS rents if 30% or 35% of their income is devoted to meeting housing costs. 
Based on the mean income, at a 30% income to rent ratio, annual average market rents in Perth
and Kinross would require to be no more than £12,369 per annum to be considered affordable at a
30% income to rent ratio. Calculated from the average monthly rent for Perth and Kinross at £812,
the average annual PRS rent equals £9,749. 
It could therefore be concluded that households earning the Perth and Kinross median income
could generally afford the cost of market rents when devoting 30% of their household income to
housing costs.
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However, based on the lower quartile income benchmark in Perth and Kinross (£22,662), at a 30%
income to rent ratio, annual average market rents in Perth and Kinross would require to be set at
no more than £6,749 per annum. As the average annual PRS rent in Perth and Kinross is 43%
higher than that amount at £9,749 the evidence suggests that PRS rents are not affordable to
households on lower incomes.
To assess the affordability of PRS rents to households on minimum income thresholds, the income
required to devote no more than 30-35% of earnings for each rental tenure has been benchmarked
to annual earnings under minimum wage (£20,821 for 21+) and living wage (£21,840). 
Graph 2.4 illustrates that based on both a 30% and 35% income to rent ratio, average PRS rents in
Perth and Kinross are clearly unaffordable to those earning minimum and living wage benchmarks. 
Graph 2.4: Minimum Income Affordability by Rental Tenures in Perth and Kinross 2023
Graph 2.4 shows that a single household earning around £18,083 would be able to afford the
average Perth and Kinross 1-bedroom market rent if they were devoting 30% of their income to
housing costs. This is marginally below the annual earnings of a single person reliant on Minimum
Wage (£20,882) or Living Wage (£21,840). 
For a low income household relying on the lower quartile income in Perth and Kinross (£22,662), a
1-bedroom market rent is within reach (£18,083), however a two bedroom market rent would
create affordability pressures (£24,526). Similarly households earning minimum or living wage,
would not be able to afford the cost of a 2-bedroom market rent (£24,526) at a 30% income to rent
ratio. 
This analysis provides evidence that households relying on lower income measures will struggle to
meet the costs of PRS rents, without devoting unsustainable proportions of household income.
Furthermore, analysis was performed using the CACI 2023 Paycheck data at an HMA and hotspot
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level to assess the proportion of households across each locality who can/cannot afford average
PRS rents in Perth and Kinross based on a 30% and 35% income to rent ratio.
Graph 2.5 below illustrates the proportion of households who cannot afford the average market
rents per locality using these rent to income ratios. This shows that on average across Perth and
Kinross, 48% of households cannot afford the cost of PRS rents when devoting 25% of their
income to housing costs. At a 30% income to rent ratio, on average 44% of households in Perth
and Kinross cannot afford PRS rents. 
Graph 2.5: % Households who CANNOT afford the average market rent per sub HMA
Using the 30% income to rent ratio, affordability of the PRS across the 5 HMAs affordability is best
in Greater Perth (42%) and worst in Strathearn (47%) closely followed by Highland (46%). Average
market rents are most affordable to households in the hotspot of Perth City Centre (41% cannot
afford) while 44% of households cannot afford market rents in the remaining three hotspot areas
where average market rents are higher than the Perth and Kinross average of £812 at £823 for
Comrie and Crieff and £818 for North Eastern.
Affordability pressures in the Strathearn and Highland HMAs are likely to be driven by the higher
than average Perth and Kinross market rents (£812) in these areas at £868 and £850 respectively.
This analysis suggests that there may be wider PRS hot spot pressures in the HMAs than the
proposed hotspot areas. This analysis shows that the relationship between household incomes
and housing costs is dynamic, with housing affordability more complex than simply benchmarking
the value of housing costs.
2.5 How Affordable is the Perth and Kinross Housing Market?
Accessing the housing market is clearly challenging across all the HMAs and hotspots in Perth and
Kinross, however there are some HMAs and hotspots with greater market access pressures than
average. Analysis of housing market access reveals that across Perth and Kinross, households
must spend up to 6 times the average local income to afford the average house price. Using the
Scottish Government’s methodology to test market entry (benchmarking lower quartile incomes to
lower quartile house prices), reveals that households must spend more than 7 times their income
to purchase a home in the Perth and Kinross area. Housing market access varies across HMAs
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and hotspots from 6 times households’ income in Eastern to 10.5 in Kinross, and from 5 times
household income in Perth City Centre hotspot to 7 in North Eastern hotspot. 
Required mortgage multipliers are even greater for market entry prices with households in the
Kinross HMA having to spend over 11 times their annual income to meet market entry house
prices and 8.5 times in Highland HMA. In hotspot areas, North Eastern households require to
spend over 9 times their incomes to meet lower quartile house prices, with Comrie households
having to spend over 7 times their incomes. 
This is in well in excess of the typical 3.2 X’s multiplier used for mortgage purposes. As well as
clear evidence of market access barriers from a loan to value perspective (LTV), this analysis
assumes that households will have at least a 15% deposit in place before income benchmarking
takes place. This is likely to be a further barrier to home ownership for many households seeking
to access the housing market in Perth and Kinross. 
Table 2.7: House price to income ratios for market entry and average house prices by HMA
In terms of the affordability of home ownership at market
entry point, further analysis evidences the challenges for
lower income households. Using the Scottish
Government’s methodology to test the affordability of the
market entry point to low income households, the lower
quartile house price in Perth and Kinross (£155,385) has
been benchmarked across lower quartile incomes
(£22,662). Assuming a loan to value ratio of 85% (based
on bank of England statistics for First Time Buyers in Q4
2022), and a mortgage multiplier of 3.2 times income; a
household would require earnings of £41,274 per annum
to be able to afford the cost of market entry home
ownership. This is well in excess of Perth and Kinross
lower quartile incomes of £22,662.
This analysis suggests that home ownership is therefore
out with the reach of local households on lower incomes,
which is challenging given the tenure dominance of
home ownership in the Perth and Kinross area. A more
diverse range of rental tenures which offer options to working households on lower incomes is
therefore likely to improve the ability of households to meet housing need.
HMA Eastern Greater Perth Highland Kinross Strathearn Perth and
Kinross
Lower Quartile Income £20,908 £19,002 £22,195 £16,267 £24,636 £22,662
Average Income £39,085 £35,069 £40,516 £29,169 £44,435 £48,888
Lower Quartile Price £139,500 £133,390 £187,000 £184,875 £179,475 £155,385
Average Price £228,176 £242,468 £327,130 £305,880 £313,241 £274,907
House price to income ratio (Lower quartile) 6.67 7.02 8.43 11.37 7.29 6.86
House price to income ratio (Average) 5.84 6.91 8.07 10.49 7.05 5.62
HMA/Hotspot Comrie Crieff North Eastern Perth City
Centre
Lower Quartile Income £28,748 £28,099 £27,713 £23,440
Average Income £52,453 £51,021 £50,122 £43,733
Lower Quartile Price £202,488 £160,000 £255,000 £117,250
Average Price £359,268 £286,330 £354,616 £205,533
House price to income ratio (Lower quartile) 7.04 5.69 9.20 5.00
House price to income ratio (Average) 6.85 5.61 7.08 4.70
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2.6 Housing Affordability Outcomes by Tenure
Graph 2.6 details the proportion of households per housing market area and hotspot who cannot
afford each housing tenure when devoting 30% of their income to benchmark costs. Council rents
are affordable to 9 out of 10 households across Perth and Kinross with just 9% unable to afford
rental costs without subsidy support. The analysis shows that on average, 13% of households are
unable to afford RSL rents (without subsidy) in comparison to 44% of households who cannot
afford market rents.
The analysis of Mid-Market rental values is interesting, as in some areas, this tenure clearly
improves PRS affordability outcomes. Whilst 44% of households can’t afford PRS rents across
Perth and Kinross, this drops to 36% if MMR rents are set using the Local Housing Allowance
(LHA), an improvement in affordability for 8% of households. Whilst this pattern is not consistent
across HMAs or hotspots, MMR would appear to improve affordability outcomes for households in
the Highland (12%) and Kinross HMAs (18%) and the hotspot areas of Comrie (12%) and North
Eastern (13%) when set at 100% of the Local Housing Allowance rate.
When analysing housing affordability within hotspot areas based on 30% income to rent ratio,
whilst pressure varies across the housing tenures, clear pressures are evident in the private
housing market. While market entry prices are least affordable in North Eastern hotspot (74%),
Comrie has the highest number of households who cannot afford average house prices (89%),
closely followed by North Eastern (88%). This is significantly worse than the 79% of households
across Perth & Kinross who cannot meet the average cost of purchasing a home in the housing
market. These outcomes are particularly challenging given the dominance of home ownership in
Perth and Kinross, which will restrict the range of accessible housing options available to those in
housing need. This is true for all housing market and hotspot areas in Perth and Kinross, where
the proportion of households who can’t afford the average house price ranges from 71% in the
Perth City Centre hotspot to 89% in Comrie. 
Graph 2.6: % households who CAN/CANNOT afford housing tenures by HMA
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In summary, the outcomes of housing affordability modelling across Perth and Kinross show that: 
2.7 Key Findings: Perth and Kinross Housing Affordability Analysis
Average monthly Perth and Kinross Council rents range from £297 for a 1-bedroom property to
£386 for a 4+bedroom property. Overall, average monthly Council rents (£321) are 17% lower than
average RSL rents in Perth and Kinross (£376). Despite the higher rental values posed by RSL
rents, they are considerably less that the Local Housing Allowance (LHA) rate for Perth and
Kinross (the rate which subsidy levels are set for the private rented sector). Set at £744 per month
in Perth and Kinross, the LHA rate is 132% higher than Council rents and 98% higher than RSL
rents.
The average market rent in Perth and Kinross in 2023 is £812 per month. Across Perth and
Kinross, market rents are more than double social rent values. Furthermore, LHA rates exceed
average market rent values across all housing market with the difference greatest in Strathearn
(17%) followed by Highland (14%) and Kinross (12%) and lower in Eastern (8%) and Greater Perth
(6%). Across the hotspot areas the difference ranges from  3% in Perth City Centre hotspot to 11%
higher in the Comrie and Crieff hotspots (slightly lower than the wider Strathearn HMA (18%) both
are located in. 
The mean income in Perth and Kinross is £48,888 and the lower the lower quartile income for
households living in Perth and Kinross is £22,662. In Perth and Kinross, 20% of households earn
less than <£20K per annum. There is clear evidence of income inequality across the region with
more than double proportion of households (51%) earning £40k+ annually. There are clear
variations in mean and lower quartile incomes across both HMAs and hotspots. In the Kinross
HMA, just 14% of households earn less than £20k while 62% earn £40+k. Whilst Perth City Centre
hotspot has 25% earning less than £20k and 44% earning £40-+k. The North Eastern hotspot has
the highest proportion of households earning £40+k at 53%, in contrast to 44% of households in
Perth City Centre hotspot 
To afford average market rents in Perth and Kinross, a household would require to earn £32,495
per annum. Overall, 44% of households in Perth and Kinross are unable to afford the average
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market rents at 30% income to rent ratio. Whilst 44% of households can’t afford PRS rents across
Perth and Kinross this drops to 36% if MMR rents are set using the Local Housing Allowance, an
improvement in affordability for 8% of households. 
Average market rents are most affordable to households in HMAs of Greater Perth (42% cannot
afford) but are least affordable to households in Strathearn (47% cannot afford).  Forthe hotspot of
Perth City Centre (41% cannot afford), whilst 44% cannot afford market rents in the remaining
three hotspot areas where average market rents are higher than the Perth & Kinross average
(£812) at £823 for Comrie and Crieff and £818 for North Eastern. 
The evidence for short term let control areas is most compelling in specific HMAs and hotspot
areas when considering and comparing the proportion of households who cannot afford the cost of
purchasing a home. Across Perth and Kinross 51% of households cannot meet the costs of market
entry point with 79% unable to afford the average cost of purchasing a home. Highland HMA has
the highest proportion of households who cannot afford average house prices (85%) closely
followed by Strathearn (83%). Comrie has the highest number of households who cannot afford
average house prices (89%) out of the four proposed hotspot area, closely followed by North
Eastern (88%) while Perth City Centre has the lowest number of households (71%). 
At market entry level three hotspot areas are above the Perth and Kinross benchmark of
households who cannot afford market entry prices, namely North Eastern (74%), Comrie (65%)
and Crieff (55%). Perth City Centre has the lowest number of households unable to afford market
entry prices at 44% similar to its HMA Greater Perth at 45%.  North Eastern is considerable higher
when compared to the Eastern HMA where 50% of households cannot afford market entry prices.
Comrie is considerable higher than the Strathearn HMA where 56% cannot afford market entry
prices. Out of the five HMAs, the largest proportion of households who cannot afford market entry
prices are located in Highland HMA (59%).   
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3 Housing System Pressure Analysis
Important contextual analysis informing the need for short term control areas, evidencing existing
housing need and housing system pressures was assembled by housing market area and hotspot.
This analysis was focused on identifying signals of housing system pressure which may indicate
the need for policy interventions, where the designation of a short term let area may ease housing
systems pressures and improve the operation of the housing system including:
• tenure analysis by HMA/hotspots and dwellings
• analysis of short terms lets and ineffective dwellings by HMA and hotspot
• housing market operation including sale volumes, prices and containment/migration patterns
• potential for future supply side interventions
• the outcomes of the disaggregated housing affordability model
• housing demand information from locally operating social landlords
• ratios of housing applicants to turnover.
To produce a holistic assessment of housing market pressure across each housing market/hotspot
area, a range of housing system pressure indicators were developed and synthesized into an
interactive data book and scoring model, producing a housing pressure dashboard for the Perth
and Kinross area. The dashboard produces HMA/hotspot level outcomes to determine evidence of
housing system imbalances, where housing or planning policy interventions could be considered to
relieve existing housing pressures. The interactive dashboard and summary slide-pack detailing
this analysis can be accessed by clicking on the following links:
Appendix 2 Perth & Kinross STL slide pack HMA+HOTSPOT.pptx
Appendix 3 Perth & Kinross STL Housing Pressure Dashboard.xlsx
3.1 Housing Tenure and Dwelling Pressures
According to the Council Tax Register in February 2024 there are 76,361 dwellings across the
Perth and Kinross area. Graph 3.1 below shows that homeownership dominates the tenure profile
across Perth and Kinross providing 62% (47,335) homes, with 17% of all dwellings (12,828)
offering social tenancies. The Private Rented Sector (PRS) provides the smallest proportion of
housing options at 14%, accommodating 2,856 households across Perth and Kinross 
Graph 3.1: % of Housing Tenure by HMA
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Graph 3.1 also showcases the diversity of housing options across Perth and Kinross housing
market and hotspot areas. The most diverse HMA is Greater Perth with 60% homeownership, 20%
social housing and 16% private rented sector homes. The most diverse hotspot area is Comrie
with 62% owner occupation, 17% social rent and 10% private rent. 
In comparative terms, the Kinross HMA and Highland HMA have a lower diversity of housing
options. In Kinross this is due the dominance of owner occupation which represents 80% of the
tenure profile, with social renting accounting for 9% and the private sector only 7%. North Eastern
hotspot has the lowest diversity of housing tenure out of the four hotspot areas with a lower than
average owner occupied (41%) and social rent (1%) sectors, but higher than average private
rented sector (24%).
The more limited tenure diversity in the Highland housing market and North Eastern hotspot areas
is due to a lower percentage of owner occupied stock, 47% and 41% respectively and higher
percentage of private rented at 17% and 24% respectively. Both these areas also have a higher
proportion of ineffective stock (short terms lets, second homes and empty homes) which will be
discussed further later in this section. 
The proportion of social housing also varies considerably across Perth and Kinross HMAs and
hotspots with the Greater Perth HMA and Perth City Centre hotspot offering the largest social
housing stock at 20% and 19% respectively. In comparison, the Kinross HMA offers only 7% of
stock as social rented while in the hotspot area of North Eastern only 1% of stock comprises social
housing. 
The outcome of the scoring dashboard for housing tenure and dwelling pressures across the four
Perth and Kinross hotspots identifies that for households who cannot afford market entry and
therefore have to rely on social rented sector options, there are more limited housing options in the
North Eastern hotspot (ranked 4) which has an overall rented sector (PRS and social housing) of
25%. Crieff is ranked third due to its higher proportion of owner occupation and lower social
housing. Perth City Centre has the least housing options pressures due to having a greater
proportion of market rent and social housing (37%)  compared to the Perth and Kinross benchmark
(31%).
3.2 Short Term Lets and Ineffective Housing Stock pressures 
Graph 3.2 highlights the proportion of short term lets and ineffective housing stock across Perth
and Kinross housing market and hotspot areas. Across the HMAs, the proportion of ineffective
housing stock is greatest in Highland at 24% with 9% second homes, 9% short term lets and 5%
empty homes, giving a total of 23% of all dwellings. This compares to an overall Perth and Kinross
Hotspot
% Owner
Occupied % PRS % Social
Housing Rank
Comrie 62% 10% 17% 2
Crieff 65% 15% 14% 3
North Eastern 41% 24% 1% 4
Perth City Centre 59% 18% 19% 1
Perth and Kinross 62% 14% 17%
Housing Tenure
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benchmark of 8% of ineffective stock, comprising 2% second homes, 2% short term lets and 4%
empty homes.
Ineffective dwellings across hotspot areas are greatest in the North Eastern corridor at 34%, with
13% of dwellings second homes, 13% short terms lets and 8% empty homes. This rate of
ineffective stock is substantially higher than in the wider Eastern HMA at 7%. Comrie has 10%
ineffective dwellings (including 3% second homes, and 2% short term lets) which is slightly above
the wider Strathearn HMA position of 8%. In comparison, Perth City Centre has the lowest
proportion of ineffective stock at 4% with less than 1% of short term lets and second homes and
3% empty homes. 
Graph 3.2 % of Short term Lets and Ineffective Stock
The outcome of the scoring dashboard for ineffective housing stock across the four Perth and
Kinross hotspot areas identifies that there is significantly higher proportion of short term lets,
second homes and total ineffective stock in North Eastern, which also ranks highest in terms of
poor tenure diversification. This further limits housing options for households who wish to meet
housing need in the area. Comrie ranks the second highest hotspot with 10% ineffective stock,
consisting of 3% second homes, 2% second lets and 5% empty. Crieff and Perth City Centre rank
the lowest with 7% and 4% of ineffective dwellings respectively. 
3.3 New Supply Pressures 
The extent of the potential supply side interventions and the availability of effective land supply is
also a consideration when considering housing system pressures and policy interventions required
to assist the operation of the housing market. 
Between 2019 and 2023 there were 3,354 house completions in Perth and Kinross. Graph 3.3
below shows that the majority of these completions were in Greater Perth HMA (57%) followed by
Kinross and Strathearn HMAs (14% respectively) and Eastern HMA (12%). Highland HMA had the
Second Homes Rank Short Term lets Rank Total Ineffective Rank
Comrie 3% 3 2% 3 10% 3
Crieff 1% 2 1% 2 7% 2
North Eastern 13% 4 13% 4 34% 4
Perth City Centre 0% 1 0% 1 4% 1
Perth and Kinross 0% 1% 7%
Hotspot
Ineffective Stock
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lowest proportion of competitions at 3%. Analysis of completions in the hotspots shows the
greatest proportion, 47% are in Perth City Centre which is part of the Greater Perth HMA. Less
than 0.5% of completions where in Comrie with no housing completions evident in the North
Eastern corridor. 
Graph 3.3 Land Supply and House Completions 
The Perth and Kinross Council Land Audit 2023, shows an effective 5 year land supply of 3,762
units of housing, with just over half (55%) in the Greater Perth HMA. Highland HMA has the lowest
effective 5 year land supply (6%). In comparison, there is no 5 year effective land supply in North
Eastern hotspot despite a wider 13% in the Eastern HMA. Perth City Centre hotspot has the
highest 5 year effective land supply (59%) and is part of the Greater Perth HMA. Crieff has a 10%
effective land supply and is just below the Strathearn HMA land supply of 16%, while Comrie has
only 1%. Hotspot areas such as Comrie and North Eastern do therefore not have the potential to
rely on supply side interventions to ease housing pressure, which could make planning policy
considerations more important in this context. 
Between the period 2023/24 to 2027/28 1,691 affordable housing units are projected to be
completed as part of the Perth and Kinross Strategic Housing Investment Plan (SHIP). The
majority of the affordable housing projects are located in Greater Perth HMA (59%) followed by
Eastern (19%) and Strathearn (10%). There are only two hotspot areas with affordable housing
completions projected in the next 5 years with the majority (36%) in Perth City Centre and a
smaller proportion in Crieff (6%). Both Comrie and North Eastern hotspots have no affordable
housing completion projected which aligns with the 5 Year effective land supply and previous
housing completions which are minimal in both these hotspot areas. 
The outcome of the scoring dashboard for new housing supply pressures across the potential
hotspot areas identifies that there is significantly higher proportion of new supply in the urban
centre of Greater Perth HMA and the hotspot area of Perth City Centre. In contrast there has been
a small number of new housing completions in Comrie, none in North Eastern while there has
been some new development in Crieff. It is unlikely that there will be any significant new supply of
housing in Comrie or North Eastern over the next five years with no effective land supply identified
and no SHIP completions projected for either of these areas. The majority of new housing supply
will continue to be in Perth City Centre with some provision in Crieff. 
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3.4 Household Income Pressures
Analysis of CACI Paycheck data, which provides a profile of annual household incomes across
each HMA and hotspot in Perth and Kinross, was performed to determine the extent to which
incomes may match evidenced housing pressures. Across Perth and Kinross, the average annual
income in 2023 was £48,888, which is above the average income for Scotland (at £44,445). 
Graph 3.4 below shows income benchmarks for annual average and lower quartile incomes across
HMAs and hotspots. Annual average incomes vary considerably across HMA with lowest average
incomes evident in the Kinross HMA (£29,169), followed by Greater Perth HMA (£35,069) with the
highest average income achieved in the Strathearn HMA (£44,435). 
In comparison, all of the hotspot areas have higher than the Perth and Kinross average income
with the exception of Perth City Centre (£43,733). The highest average income is in the Comrie
hotspot (£53,453) followed by Crieff (£51,021). Lower quartile incomes also vary across Perth and
Kinross HMAs and hotspots, ranging from £16,627 in Kinross HMA to £24,636 In Strathearn HMA
and from £23,440 in Perth City Centre to £28,744 in Comrie. 
Graph 3.4: Income by HMA
The outcome for the scoring dashboard for income pressure across the proposed hotspot areas
identifies that Comrie and Crieff rank the lowest in terms of pressure for both average income and
lower quartile income pressures, with Perth City Centre ranked the highest at fourth with both a
lower quartile income (£23,440) and average income (£43,733) below the Perth and Kinross
benchmark.
% of House
Completions 2019-
2023
Rating % of Effective
Land Supply Rating
% of approved SHIP
completions 2024 -
2029
Rating
Comrie 0% 3 1% 3 0% 4
Crieff 4% 2 10% 2 6% 2
North Eastern 0% 4 0% 4 0% 4
Perth City Centre 40% 1 32% 1 36% 1
Perth and Kinross 100% 100% 100%
Land Supply & completions
Hotspot Area
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Comrie hotspot has the highest average (£52,453) and lower quartile (£28,748) incomes and is
ranked lowest in both categories with Crieff ranked second which means some households may
find it easier to access the housing market to meet their housing needs. Analysis of the scoring
outcomes demonstrates that households in the Perth City Centre hotpsot and North Eastern
Hotspot have a higher proportion of households which may have difficulty accessing housing
options in the private housing market sector as a result of income pressures. 
3.5 Housing Market Pressures
Housing market pressures across Perth and Kinross can be measured by analysing the volume
and turnover of house sales in each HMA and hotspot area as well as the extent of pressure
associated with market inward migration. Over the last three years, on average there has been
3,176 house sales completed per annum across the Perth and Kinross area, providing a market
turnover rate of 7%. At an overall level, containment is higher than in-ward migration with 59% of
sales being made to local households and 41% of transactions made to households out with the
area. 
Graph 3.5: Housing Market Profile % Volume of House Sales
Housing market sales volumes vary across each of Perth and Kinross housing market and hotspot
area. Graph 3.5 shows that the highest volume of sales is in the Greater Perth HMA (52% or
1,667) with Perth City Centre hotspot located within the Greater Perth HMA having the greatest
volume of sales of the four hotspots (33% or 1,039 transactions). The Eastern HMA had the lowest
volume of transactions (14% or 441 transactions). 
The lowest levels of transactions are in the hotspot areas of North Eastern, located within the
Eastern HMA, where almost negligible transactions were recorded at 0.5% (14 transactions) and
Comrie at 1% (28 transactions). This is despite Comrie being located with the Strathearn housing
market area which had the second highest volume of HMA house sales (16% or 508 transactions).
Lower Quartile
Income
Rank Average
Income
Rank
Comrie £28,748 1 £52,453 1
Crieff £28,099 2 £51,021 2
North Eastern £27,713 3 £50,122 3
Perth City Centre £23,440 4 £43,733 4
Perth and Kinross £22,662 £48,888
Hotspot
Income Profiles
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Graph 3.6 below illustrates significant diversity in the level of market containment across each of
the Perth and Kinross HMAs and hotspots. The HMAs with the highest number of sales made to
local households is the Greater Perth HMA (69%) and the Eastern HMA (57%). The Perth City
Centre hotspot has the highest level of contained household sales (75%) of the four hotspot areas
followed by Crieff hotspot (56%). In migration is highest in Kinross HMA with just 38% of sales
made to people currently living in the area followed by Highland HMA with 43%. 
The North Eastern hotspot has the highest volume of sales to households living out with the area
(61%) followed by Comrie hotspot (54%). 
Graph 3.6: Housing Market Profile % Containment and Migration 
Using the scoring dashboard, housing market pressure outcomes were ranked for both house sale
volumes and market containment levels for each Perth and Kinross hotspot area. 
The hotspots of North Eastern and Comrie are ranked as having the highest housing market
pressures in terms of low house sales volumes at 14 sales and 28 sales respectively. Perth City
Centre hotspot ranks the lowest housing market pressures due to the high sale volumes. The
hotspot areas of North Eastern and Comrie were ranked as having the greatest hotspot pressures
in relation to inward migration. The levels of inward migration experienced by local households
from purchasers moving into the area suggest there is significant competition between local and
Volume of House
Sales
Volume of House
Sales (%)
Rank
Comrie 28 1% 3
Crieff 201 6% 2
North Eastern 14 0% 4
Perth City Centre 1039 33% 1
Perth and Kinross 3176 100%
% of P&K
Containment Rank % of Migration
(External) Rank
Comrie 46% 2 54% 3
Crieff 56% 3 44% 2
North Eastern 39% 4 61% 4
Perth City Centre 75% 1 25% 1
Perth and Kinross 59% 41%
Hotspot
Housing Market Profile
Hotspot
Housing Market Profile
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incoming households. Crieff hotspot experiences the lowest pressures in terms of market volumes
and to some extent this pressure may be relieved by a higher proportion of sales made to
households already living in the area than North Eastern and Comrie. 
The final indicator to consider when assessing market pressures across Perth and Kinross is
average house price levels. Using transactions data from the Register of Scotland, Graph 3.7
below shows that the average house price in Perth and Kinross in 2022/23 was £274,907.
Graph 3.7 Average, Mean and Lower Quartile House Prices
The average house price varies considerably when comparing each HMA and hotspot area to the
Perth and Kinross average. Highest average house prices are in Highland HMA at £327,130 and
Strathearn HMA at £313,241. 
In the hotspot areas the highest house price is in Comrie at £359,268 followed closely by North
Eastern at £354,616. It is worth noting that these hotspots also have the highest and third highest
average income profiles respectively in Perth and Kinross which may to some extent support
house price inflation given the relative low volume of market housing and sales in these areas.
In comparison, average house prices are lower than the Perth and Kinross average in the Eastern
HMA (£228,176) and Greater Perth HMA (£242,468). In the hotspot areas house prices are below
the Perth and Kinross average in Perth City Centre (£205,533) which is ranked as having the
lowest housing market pressures of the four proposed areas. Lower than average house prices in
these areas does not necessarily mean they are more affordable to local households as these
areas also have average incomes which are significantly below the Perth and Kinross average of
£48,888. More detailed analysis of housing affordability pressures is outlined in Section 3.6 below. 
3.6 Housing Affordability Pressures
To understand the extent to which housing affordability pressures may enable or limit access to the
housing market in each HMA and hotspot, analysis was undertaken of the proportion of
households who can afford lower quartile house prices (market entry housing), as well as average
house prices, at a 30% income to rent benchmark.
Across Perth and Kinross, 54% of households cannot afford market entry housing and 82% cannot
afford average house prices. Graph 3.8 below highlights variations across the five HMAs, with
Highland HMA and Strathearn HMA having the highest proportion of households who cannot afford
market entry housing at 62% and 59% respectively. Access to and the affordability of the housing
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market is even more challenging when average house prices are taken into account. The majority
of households (more than three out of four) cannot afford average house prices across all of the
HMAs in Perth and Kinross ranging from 73% in Greater Perth to 83% in the Highland HMA. In
comparison 52% of households in the Greater Perth HMA, and 57% in both the Eastern HMA and
Kinross HMA can afford market entry housing. 
Graph 3.8 % Housing Market Affordability Home Ownership
Graph 3.8 also highlights variations across the four hotspot areas, with North Eastern and Comrie
comprising 74% and 65% of households unable to afford market entry housing (respectively), while
55% of households in Crieff cannot afford market entry housing. In comparison, a higher proportion
of households in Perth City Centre hotspot can afford market entry housing at 56%. Access and
the affordability of the housing market is even more challenging in the three hotspot areas of North
Eastern, Comrie and Crieff when average house prices are taken into account with 90%, 82% and
84% of households respectively being unable to afford average house prices. 
Further analysis of house price to income ratios provides a greater understanding of barriers to
housing market access in each HMA and hotspot. Graph 3.9 below shows that the average
mortgage multiplier in Perth and Kinross is 5.62, which means that households will require to
spend 5.62 times the average annual income to purchase a house at the average price in 2022/23. 
The multiplier slightly improves at 4.70 for the Perth City Centre hotspot area. The Perth and
Kinross ratio is higher for lower quartile incomes and market entry house prices at 6.86, but slightly
lower for the hotspot areas of Perth City Centre at 5.0 and Crieff 5.69.
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Graph 3.9 Lower Quartile and Average House Price to Income Ratios
Analysis across HMAs suggests that the average house price to income ratio varies from 5.84 in
Eastern HMA to 10.49 in Kinross HMA. At market entry levels the variation is greater across the
five HMAs, with Kinross HMA the highest at 11.37 and Eastern HMA the lowest at 6.67. 
However within the Eastern HMA, the North Eastern hotspot has the highest average to house
price ratio (7.08) and highest market entry to lower quartile income ratio (9.2). The Perth City
Centre hotspot has the lowest average house price to income ratio (4.70) and market entry house
prices to income ratio (5.0). Comrie has the second highest house price to income ratio for both
lower quartile and average house prices at 7.05 and 6.85 respectively. 
Using the scoring dashboard, housing affordability pressures were ranked for each hotspot on
basis of house price to income ratios and housing affordability benchmarks, using a 30% income to
rent benchmark. North Eastern has the highest affordability pressures with 74% of households and
90% of households unable to affordable market entry and average house prices respectively.
Comrie hotspot also experiences similar pressures and is ranked at third with 68% of households
and 82% of households being unable to afford market entry and average house prices. 
The Perth City Centre hotspot experiences comparatively lower levels of pressure both in terms of
market access and affordability outcomes despite lower than average household incomes in this
Ratio: Lower
Quartile House
price to LQ
Income
Rank
Ratio: Average
House price to
Average
Income
Rank
Comrie 7.04 3 6.85 3
Crieff 5.69 2 5.61 2
North Eastern 9.20 4 7.08 4
Perth City Centre 5.00 1 4.70 1
Perth and Kinross 6.86 5.62
% Households
who cannot
afford LQ Price
(30%)
Rank
% Households
who cannot
afford Average
Price (30%)
Rank
Comrie 65% 3 82% 2
Crieff 55% 2 84% 3
North Eastern 74% 4 90% 4
Perth City Centre 44% 1 74% 1
Perth and Kinross 54% 82%
Housing Market Area/Hotspot
Housing Market Area/Hotspot
Housing Market Access & Affordability
Housing Market Access & Affordability
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area, presumably eased by below average housing costs. In contrast, the analysis suggests that
the North Eastern hotspot experiences the greatest pressure in relation to market affordability and
access, despite higher income profiles, followed by the Comrie hotspot. Households in these
hotspots are therefore spending higher proportions of their income to meet the costs of the market.
The Crieff hotspot has lower housing access pressures but greater affordability issues at average
house prices and is ranked second lowest.
Whilst the scoring dashboard suggests a need for more housing market options across all the
Perth and Kinross hotspots, housing market affordability pressures are most pronounced in the
North Eastern hotspot and Comrie hotspot. This is particularly problematic in the North Eastern
hotspot due to the higher than average proportion of short term lets and ineffective stock, limited
housing options in the social and market rented sector for those in housing need, with evidence
than high in migration to these areas could also be fueling house prices given the low volume of
sales. 
In Comrie there is a slightly higher percentage of ineffective stock than the Perth and Kinross
benchmark, however housing market affordability will also be problematic given the dominance of
home ownership in the area, the high level of incomes and in migration to the area, which in turn
could be pushing housing market prices up, and the very limited alternative housing options
available for those seeking housing. 
3.7 Private Rented Sector Pressures
Private rented sector housing can frequently be the default tenure for households who cannot
afford to access home ownership but who also cannot access social housing. Dashboard analysis
reveals that the proportion of PRS stock in each HMA and hotspot area and rental values vary
considerably on an area basis. Graph 3.10 demonstrates that there are 10,991 private rented
dwellings across Perth and Kinross, with a high proportion (60%) located in Greater Perth HMA,
offering 6,611 dwellings in total. Strathearn HMA and Eastern HMA have the second largest
proportion of PRS dwellings out of the five HMAs, 13% each, representing 1401 and 1377
properties respectively. Kinross HMA has the lowest proportion of private rented stock (4%) 458
dwellings. The Perth City Centre hotspot, located within the Greater Perth HMA has the greatest
proportion of private rented dwellings (41% and 4,544 dwellings) of the four hotspots, while both
North Eastern and Comrie have the lowest proportions (1%) representing 129 dwellings and 97
dwellings respectively.
Graph 3.10: % PRS Dwellings per HMA and hotspot
The average PRS rent in Perth and Kinross is £812 per calendar month with the margin between
the average Local Housing Allowance rate (£744) coming in at £68. Average PRS rents in the
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HMAs range from £789 Greater Perth to £868 in Strathearn. Average rents are slightly lower in the
hotspot areas ranging from £764 in Perth City Centre to £823 in Comrie and Crieff which are both
located within the Strathearn HMA which overall has the highest average rents. 
When comparing average rents to the average Local Housing Allowance (LHA) across Perth and
Kinross, rental values for all HMAs and hotspot areas are higher than the average LHA rate. The
difference between the average PRS rents and the LHA rate ranges from a shortfall of £20 per
week in the Perth City hotspot to £74 in North Eastern and £79 in Crieff and Comrie. This suggest
that there will be difficulties in some households accessing the private rented sector in the hotspots
of Crieff, Comrie and North Eastern due to the shortfall between the LHA and average rents. 
Table 3.1: Margin between PRS average rent values and the Local Housing Allowance rate by HMA
Housing affordability in the PRS is assessed by testing a range of income to rent ratios (the
proportion of household income to be devoted to housing costs) to assess the risks associated
with housing induced poverty in the sector.
Graph 3.11 below shows PRS rent affordability for each of the Perth and Kinross HMAs and
hotspots against the LHA rate and the average PRS rental value. In Perth and Kinross, 36% of
households cannot afford the average rent at the LHA rate unless subsidy is provided and 44%
cannot afford full market rents. This varies from 27% of households who cannot afford LHS rents in
Kinross HMA to 40% in Eastern HMA. A greater proportion of households within each hotspot
cannot afford LHA rents ranging from 31% in North Eastern to 42% in Perth City Centre.
Housing Market Area LHA Rate LHA/PRS
Margin Ave PRS Rents
Eastern £744 -£57 £801
Greater Perth £744 -£45 £789
Highland £744 -£106 £850
Kinross £744 -£91 £835
Strathearn £744 -£124 £868
Comrie £744 -£79 £823
Crieff £744 -£79 £823
North Eastern 744.21 -£74 818.3395
Perth City Centre £744 -£20 £764
Perth and Kinross £744 -£68 £812
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Graph 3.11 PRS Market Rent Affordability
Just over 44% of households in Perth and Kinross cannot afford the cost of the average PRS rent.
The proportion of households who cannot afford ranges from 42% in Greater Perth HMA to 47% in
Strathearn HMA. In the hotspot areas, the affordability of average PRS rents range from 41% in
Perth City Centre to 44% in Comrie, Crieff and North Eastern. This difference between the HMAs
and the hotspots is likely to be related to the higher average incomes in the hotspot areas. 
The PRS pressures for each hotspot area were ranked in terms of (i) average PRS rental values,
(ii) households who cannot afford the LHA and (iii) households who cannot afford average PRS
rents at a 30% income to rent ratio. 
Crieff and Comrie are ranked the highest in terms of average PRS rents due (£823) with North
Eastern ranked second with average PRS rents just slightly lower (£818). Perth City Centre is
ranked the lowest with average market rents at £764. The affordability of the LHA rate is lowest in
the North Eastern hotspot (31%) with Perth City hotspot experiencing the greatest pressures (46%)
and ranked fourth. 
Average PRS
Rents Rank
% Households who
cannot afford LHA
(30%)
Rank
% Households who
cannot afford
Average PRS rent
(30%)
Rank
Eastern £801 3 40% 8 43% 3
Greater Perth £789 2 38% 6 42% 2
Highland £850 8 34% 3 46% 8
Kinross £835 7 27% 1 45% 7
Strathearn £868 9 34% 3 47% 9
Comrie £823 5 36% 5 44% 4
Crieff £823 5 38% 6 44% 6
North Eastern £818 4 31% 2 44% 5
Perth City Centre £764 1 42% 9 41% 1
Perth and Kinross £812 36% 44%
PRS Market Rent
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However, the hotspot rankings for PRS affordability are different to LHA affordability rankings, with
Comrie, Crieff and North Eastern ranked with the highest pressures (44%), while Perth City Centre
has slightly lower pressure (41%).
Analysis of PRS affordability pressures suggests that average PRS rents are least affordable in the
hotspot areas of Comrie, Crieff and North Eastern while average PRS affordability is more positive
in Perth City Centre. LHA rents are least affordable for households living in Perth City Centre and
Crieff. This could suggest a need to deliver a wider range of social and below market rent options
in these areas, given the higher levels of private rented stock when compared to Comrie and North
Eastern. Given the very low number of market rents and market rented dwellings in the hotspots of
Comrie and North Eastern, the findings suggest that there may be a need to develop more
intermediate models, with consideration given to short term let controls to encourage more market
rented dwellings.
3.8 Social Housing Pressures
Analysis of social housing pressures across Perth and Kinross takes into account stock availability,
demand and the turnover of properties. Table 3.2 overleaf shows that there are 12,828 homes in
the social rented sector in Perth and Kinross, accounting for 17% of all dwellings which is lower
than the national average at 24%. The proportion of the total social rented stock varies significantly
across Housing Market Areas from 64% in Greater Perth to just 4% in Kinross. 
The proportion of total social housing stock in the proposed hotspots also varies with Perth City
Centre having the highest proportion (38%) followed by Crieff (5%). The North Eastern hotspot has
only 6 social rent dwellings therefore having very minimal housing options for households who are
unable to meet their housing needs in the rented market or housing market. 
Table 3.2: Social Housing Stock Profile by Council and RSL dwellings
A Common Housing Register (CHR) operates in Perth and Kinross consisting of the Council,
Caledonia Housing Association, Hillcrest Homes and Kingdom Housing Association. The Perth
and Kinross CHR has been used to determine the total number of social housing applications.
Overall, demand for social rented housing in Perth and Kinross is high with 2,735 live applicants
expressing demand for social rented housing. See Graph 3.12 below.
Social Housing in Perth & Kinross Eastern Greater Perth Highland Kinross Strathearn Perth and
Kinross Comrie Crieff North Eastern Perth City
Centre
Total Perth and Kinross Council Dwellings 1202 5191 421 362 784 7960 70 373 6 3909
Total RSL dwellings 524 3043 437 203 661 4868 92 252 0 1002
Total Social Housing Stock 1726 8234 858 565 1445 12828 162 625 6 4911
Total % Social Housing Stock 13% 64% 7% 4% 11% 100% 1% 5% 0% 38%
% Perth and Kinross Council Stock 70% 63% 49% 64% 54% 62% 43% 60% 100% 80%
% RSL Stock 30% 37% 51% 36% 46% 38% 57% 40% 0% 20%
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Graph 3.12: Proportion of Perth and Kinross CHR Applications by HMA
Demand for social housing from Perth and Kinross CHR applicants is highest in the Greater Perth
HMA by a significant margin, accounting for 63% (1,718) of all applications. Demand for social
rented housing is lowest in the Kinross HMA which accounts for only 4% (115) of applicants. 
Demand for social housing also varies across the Perth and Kinross hotspot areas with 48%
(1,302) of CHR applicants from Perth City Centre, 6% (168) from Crieff, 1% (18) from Comrie and
less than 0.5% (10) of applications from North Eastern. 
Table 3.3: Perth and Kinross CHR housing applications 
In comparative terms, Table 3.4 overleaf demonstrates that the turnover of social housing to meet
expressed demand is relatively low. Between the period 2018 to 2020 an annual average of 693
tenancies (excluding one bedroom shared tenancies) became available to let across Perth and
Kinross which means just over 5% of the social housing stock becomes available every year. The
highest proportion of lets (63%) are in Greater Perth HMA with the lowest proportion (4%) in the
Kinross HMA. 
The number of lets per annum available in the hot spots areas varies considerably, with Perth City
Centre seeing the greatest number of lets with a total of 87 dwellings (13%) while 18 dwellings
(6%) became available in Crieff, 2 dwellings in Comrie and none in North Eastern. The very limited
social rented options in Crieff, Comrie and North Eastern, means that it is very unlikely applicants
in housing need will meet their accommodation needs. This could increase their risk of presenting
as homeless to the Council or having to move to another area. 
Social Housing in Perth & Kinross Eastern Greater Perth Highland Kinross Strathearn Perth and
Kinross
Total CHR Applicants 408 1718 165 115 329 2735
% of Waiting List Applicant 15% 63% 6% 4% 12% 100%
Social Housing in Perth & Kinross Comrie Crieff North
Eastern
Perth City
Centre
Total CHR Applicants 18 168 10 1302
% of Waiting List Applicant 1% 6% 0% 48%
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Table 3.4: 3-year average turnover of Social Housing
The considerable pressures in the turnover of social tenancies by size should also be noted in the
hotspot areas. Only five three bedroom properties became available Perth City Centre, with 2
dwellings in Crieff and no turnover in the Comrie or North Eastern hotspots. There was no turnover
of larger dwelling with four or more bedrooms within any of the hotspot areas. It can therefore be
concluded that there are very limited social housing options available for households needing three
or more bedroom to meet their housing needs in the hotspot areas. 
Using data on the number of CHR waiting list applicants and turnover, the ratio of applicants to
available social tenancies can be calculated. Across Perth and Kinross there are 3.82 applicants
for every available social tenancy. Pressure ratios across HMAs are relatively consistent with the
Perth and Kinross benchmark ranging from 3.19 applicants per let in Eastern HMA to 4.67 in
Highland HMA. 
Across the four hotspot areas, pressure ratios are significantly higher due to lack of social housing
or lets becoming available. Comrie has the lowest ratio with 8 applicants for every property that
becomes available, however this is still more than double the Perth and Kinross average. Crieff
has 9 applicants while Perth City Centre has 14 applicants which is higher than the pressure for its
HMA of Greater Perth. The other hotspot outlier is North Eastern where no properties became
available to let, however it should be noted that there are only 6 social rent dwellings in this
hotspot. 
Further analysis was undertaken of the ratio of applicants to available lets for one bedroom and
three bedroom properties. Graph 3.13 below shows that across Perth and Kinross the HMAs and
hotspots areas the ratio of applications to available lets is lower than the average for all bedrooms
while the ratios are higher for three bedrooms. Across the hotspot areas the ratio is highest for
three bedroom properties in Perth City Centre at almost 31 applicants to every 3 bedroom property
that becomes available for let. 
Social Housing in Perth & Kinross Eastern Greater Perth Highland Kinross Strathearn Perth and
Kinross
Total Turnover 1 bedroom 44 200 17 11 39 311
Total Turnover 2 bedroom 63 174 8 10 39 293
Total Turnover 3 bedroom 17 42 10 5 10 84
Total Turnover 4+ Bedroom 1 3 0 0 1 4
Total 125 418 35 27 88 693
% of Turnover 18% 60% 5% 4% 13% 100%
Social Housing in Perth & Kinross Comrie Crieff North
Eastern
Perth City
Centre
Total Turnover 1 bedroom 1 11 0 46
Total Turnover 2 bedroom 1 6 0 36
Total Turnover 3 bedroom 0 2 0 5
Total Turnover 4+ Bedroom 0 0 0 0
Total 2 18 0 87
% of Turnover 0% 3% 0% 13%
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Graph 3.13 Social Housing Ratio of Waiting List to Turnover
Turning to affordability pressures in the social housing sector, Graph 3.14 highlights the proportion
of social housing tenants who cannot afford social rents without subsidy using a 30% income to
rent ratio. Across Perth and Kinross 10% of households cannot afford Council rents and 15%
cannot afford RSL rents without reliance on subsidy. 
There are variations in social rent affordability across HMAs, with affordability issues greatest in
Eastern HMA and Greater Perth HMA with 11% and 10% respectively unable to afford Council
rents and 17% and 15% respectively being unable to afford RSLs rents. This pattern is similar for
the hotspot area of North Eastern located within the Eastern HMA, with the highest proportion of
households who cannot afford Council rent (12%) and RSL rent (18%) without the need for
subsidy. 
Graph 3.14 Social Housing Affordability
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The social housing pressures for each hotspot area were ranked in terms of (i) waiting list to
turnover by bedroom size (ii) households who cannot afford average Council and RSL rents at a
30% income to rent ratio. 
Perth City ranked the greatest pressures in relation to total waiting lists, which is expected given its
urban context, while North Eastern ranked the lowest. However, North Eastern ranked the greatest
social housing pressures due to having no stock turnover (given its small proportion of social
housing). Perth City Centre also has high demand for social housing with significant pressure for 3
bedroom dwellings with a ratio of 31 applicants to every 3 bedroom property let. 
Turning to social rent affordability pressures, North Eastern ranked the highest with 12% of
households unable to afford Council rents and 18% unable to afford RSL rents. Affordability
pressures in the social rented sector were the least in Crieff with 94% of households able to afford
Council rents and 84% able to afford RLS rents. 
3.9 Overall Housing Pressures by Housing Market Area
The housing pressures dashboard has been assembled to profile and align a range of indicators in
each Housing Market Area and hotspot to demonstrate whether local housing system imbalances
are evident and there is evidence for the need for short term let controls. Assembling a range of
indicators from tenure diversity to market operation, inward migration, ineffective stock and short
terms lets; allows evidence of the extent and nature of housing system pressures and the need for
short term lets controls across HMAs and proposed hotspot areas to be considered. To ensure that
a specific focus on short term lets pressures was achieved, six indicators were selected with
weightings applied to those indicators which focused most on this issue. The short term let
indicators selected, were as follows:
1. Housing options diversity (owner occupation, market rent and social rent)
2. Percentage of short terms lets as a proportion of housing stock
3. Percentage of total ineffective stock (short term lets, second homes and ineffective stock) as a
proportion of total housing stock
4. Private sector housing market affordability
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5. Private rented sector market affordability
6. Percentage of inward migration for house sale transactions.
A maximum weighting of 10 was applied to indicators 2 and 3 by the Project Steering Group as
those which offer the most direct housing pressure measures of issues caused by short terms lets
and ineffective stock. The housing options diversity (indicator 1) and the proportion of households
who cannot afford market rents, often a default option for those who cannot access social housing
(indicator 5), and the proportion who cannot afford market housing (Indicator 4) received a
weighting of 5 (assuming that price inflation and affordability can be indicators of short term let
impacts). Indicator 6, % of inward migration was given a weighting of 3 as a measure of market
competition in each hotspot area. 
For each indicator, dashboard rankings were used to score pressure on a scale of 1 to 4, with 4
suggesting high pressure and a score of 1 low pressure. Without applying a weighting, overall
housing market pressure is ranked the highest in the North Eastern Hotspot, which scores a total
of 23 points, followed by Comrie with 15 points. The Crieff hotspot scores a close third with 14
points. Without weighting, Perth City hotspot is ranked as experiencing the lowest housing
pressure with a score of 6.
With the weightings applied to each
hotspot score, again the overall
housing pressure is highest in the
North Eastern hotspot with 147 points.
Whilst income levels are above
average in North Eastern, house prices
are also high rendering this the least
affordable hotspot in meeting the
average house price. PRS affordability
was ranked third highest for North Eastern, therefore making it difficult for households to access as
an alternative housing options if they cannot afford market housing.  Furthermore, ineffective
housing stock is exacerbating housing options diversity in North Eastern with a higher percentage
of ineffective stock, meaning there is lower available market housing or private rented stock
available. There are also very limited social rented options in the area with only 6 properties. The
demand for market housing for local residents is further exacerbated with higher inward migration
absorbing house sales in the area. 
With the weighting applied to the six indicators Comrie (99) scores higher than Crieff (88). This can
be attributed to Comrie’s higher proportion of short term lets and ineffective stock along with
greater inward migration pressures from house sales. Comrie has slightly lower pressures in terms
of tenure diversification however, the volume of housing options available across all tenures is
Comrie Hotspot Crieff Hotspot North Eastern
Hotspot
Perth City
Centre Hotspot
Mark Mark Mark Mark
1 Housing Options Diversity 5 2 3 4 1
2 % of Short Term Lets 10 3 2 4 1
3 % of Total Ineffective Stock 10 3 2 4 1
4 Housing Market Affordability (Ave 30%) 5 2 3 4 1
5 PRS Affordability (Ave 30%) 5 2 2 3 1
6 % of inward migration 3 3 2 4 1
TOTAL 15 14 23 6
Housing Pressure Indicator Weighting
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relatively low in terms of turnover, volume of sales and new supply making it difficult for
households to access housing options in the area. Comrie does score lower for the housing market
and market rent indicators, which can be associated with having slightly higher income levels.
However, it has the highest average house price at £359,614 and the same average rents as Crieff
at £823 pa. 
Whilst the Crieff hotspot area scored the second lowest total score when weighting is applied to
each of the indicators, this was only 13 points behind Comrie. Crieff has greater housing options
pressures due to higher owner occupation and lower social rented housing. However, Crieff has
lower housing pressures associated with ineffective housing stock with 1% of homes classified as
short term lets and lower level of ineffective stock than Comrie. Housing market affordability
pressures are higher in Crieff which may be attributed to lower incomes meaning these households
may find it harder to access the housing market. This is despite Crieff having a higher volume of
sales and new supply across the housing sector when compared with North Eastern and Comrie.
Crieff’s weighted score for inward migration was also lower due to having lower levels than North
Eastern and Comrie.
Finally, Perth City Centre hotspot has the lowest overall weighted housing pressure score of 38
scoring the lowest across each of the 6 indicators. Perth City Centre has the lowest rate of short
term lets and ineffective stock as well as a better diversity of housing options. Due to lower
average market house prices and average market rents, more households are able to afford
market housing options and there is lower pressure from house sale inward migration. Therefore,
there is no clear evidence that Perth City Centre would benefit from the Council pursuing an
application for a Short-term Let Control Area to assist in relieving housing pressure and improving
housing system operation. However, the area does have housing pressures in relation to demand
for affordable housing due to lower average and lower quartile incomes which can be further
evidenced in the high demand for social housing and low turnover. 
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4 Research Conclusions and Recommendations
Perth and Kinross Council commissioned Arneil Johnston to carry out research to evidence
housing system pressures to inform policy consideration of short term let control areas. 
To designate a short-term let control area, the Council must consider whether there are: ‘systemic
material planning considerations’ across one or more areas in the local area as part of deciding
whether to designate one or more control areas. A ‘systemic consideration’ includes evidencing
whether there is a cumulative impact from the use of residential homes as short term lets, with
indicators including a ‘lack of affordable and appropriate housing for local residents, perhaps
indicated by a high share of sale volumes to, and high prices paid by, non-residents’.
To achieve this, Arneil Johnston has delivered analysis and insight into the housing pressures
associated with housing system operation in both HMA’s and a series of proposed short-term let
‘hot-spot areas’. This evidence builds on analysis of housing affordability by synthesising wider
indicators of housing market pressure to define which hotspot areas could be recommended as a
short term let control areas.
4.1 Housing Pressure Analysis Conclusions
Key indicators have been selected and synthesized to evidence housing market pressure in
hotspot areas relative to wider Housing Market Areas. Key indicators that short-term letting may be
affecting the operation of the housing system in hot spot areas include:
• % of ineffective housing stock: This indicator considers the extent to which second homes,
short term lets and empty homes are limiting residential housing supply. North Eastern hotspot
has the highest proportion of ineffective dwellings at 34% with the highest proportion of
ineffective stock across all categories of short term lets (13%), second homes (13%) and empty
homes (8%). In comparison the Eastern HMA has a lower proportion of ineffective housing
stock across all categories, short term lets (2%), second homes (2%) and empty homes (4%).
Comrie hotspot has the second highest proportion of ineffective stock with a higher proportion
of second homes (3%) than short term lets (2%) and an even higher proportion of empty
homes (4%). This is higher when compared with the Strathearn HMA short term lets (1%),
second homes (2%) and empty homes (4%). In comparison Crieff and Perth City Centre have
lower proportion of total ineffective stock at 7% and 4% respectively with the majority of this
stock being empty rather than second homes or short term lets. 
• Access to the housing market: This indicator considers the evidence gathered on average
and lower quartile incomes  to house price ratios to assess households’ ability to access the
housing market. The evidence shows that access to the housing market is challenging across
Perth and Kinross. Households with average incomes require to spend almost six times (5.62)
their incomes to access the housing market rising to almost 7 times (6.86) for households with
lower quartile incomes. Perth City Centre is the only hotspot area significantly lower than the
Perth and Kinross benchmark with households earning average incomes required to spend
4.70 times on market housing rising to 5 times for lower quartile incomes. In North Eastern and
Comrie access to the housing market is extremely challenging, with North Eastern households
earning average incomes requiring 7.08 times rising to 9.2 times for lower quartile, while in
Comrie households with average incomes require 6.95 times rising to 7.04 for lower quartile
incomes. Crieff  differs slightly in that access to the housing market is similar for both average
incomes and lower quartile incomes at 5.61 and 5.69 respectively. Accessibility is therefore
extremely challenging at market entry level across the hotspot areas, with North Eastern and
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Comrie households required to spend the highest multipliers of lower quartile incomes to
access the housing market. This will add further pressures on local residents in North Eastern
and Comrie looking to access the housing market already constrained by higher numbers of
ineffective stock. 
• Inward migration of house sale purchases: Analysis of containment and inward migration of
house sales provides evidence of the extent to which high in-migration of households
purchasing homes from elsewhere may be inflating prices and therefore creating market
access/affordability issues. In the last 2 years the average containment across Perth and
Kinross was 59% with 41% in-migration. North Eastern has the highest in-migration out of the
four hotspot areas (61%) followed by Comrie (54%). Crieff inward migration (44%) is just above
the Perth and Kinross average (41%) while Perth City Centre is significantly lower (25%). 
Comparing hotspot inward migration with the relevant HMA shows that inward migration is
significantly higher in North Eastern (61%) when compared to Eastern HMA (43%). Comrie’s
in-migration rate is also higher (54%) than the Strathearn HMA (50%) while Crieff is lower
(44%). This suggests that high in-migration levels in North Eastern and Comrie may be fueling
house prices in these hot spot areas and creating housing market access issues. 
• Market entry affordability: Analysis of market affordability in both the private rented sector
and the housing market provides evidence of households struggling to their needs in the
hotspot area. Across Perth and Kinross 51% of households cannot afford market entry home
ownership. In all hotspot areas, except Perth City Centre (44%), the proportion of households
who cannot afford market entry level is higher than the Perth and Kinross benchmark. Market
entry difficulties are greatest in North Eastern (74%), followed by Comrie (65%) and Crieff
(55%). North Eastern is notably higher than the Eastern HMA where 53% of households cannot
afford entry house prices. Turning to market rents, across Perth and Kinross 36% of
households cannot afford LHA rate and 44% cannot afford market rents. Affordability of LHA is
most challenging in the Perth City Centre hotspot area with 42% of households who cannot
afford the LHA rate, whilst for market rents 44% of households in the North Eastern, Comrie
and Crieff hotspot cannot afford market rents. 
• Completions and pipeline supply: Analysis of the 3,354 completions between 2019 and
2023 show that 40% of completions (1,337 dwelling) were in the Perth City Centre hot spot and
4% of completions (124 dwellings) in Crieff. There were 7 dwellings completed in Comrie and
non in North Eastern. 
The Perth and Kinross Land Audit 2023 provides information on 5 year effective land supply,
with 42% of supply allocated to the hotspot areas. The majority of this (32%) is in Perth City
Centre followed by Crieff (10%) and Comrie (1%) with no effective land allocated for North
Eastern. The Perth and Kinross Strategic Housing Investment Plan (SHIP) is projecting 1,691
affordable units to be completed between 2023/24 and 2027/28 with 42% in the hotspot areas.
The majority are within the Perth City Centre (36%) with a smaller number in Crieff (6%). There
are no affordable housing projects anticipated for completion in Comrie or North Eastern. 
Therefore, interventions will need to be considered to maximise the existing housing stock
particularly in the areas of North Eastern and Comrie due to a lack of housing completions and
provision for future supply in the 5 Year effective land supply and the SHIP.  This could include
the consideration of short term control areas as well as interventions to try and bring empty
homes back into use where feasible. 
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Synthesizing a number of key indicators as measures of housing pressure in each hotspot area
would suggest that:
• The North Eastern hotspot has the highest total weighted housing pressure score of all the
hotspot areas of 147. This can be attributed to the area being ranked the highest for ineffective
stock (34%), including short term lets (13%) which is considerably higher than the Perth and
Kinross benchmark for short term lets (1%). The ineffective stock is also impacting negatively
on housing tenure diversity with no options in the social rented sector (6 units) and lower than
average levels of owner occupation (41%) compared to Perth and Kinross (62%).  Access and
affordability to the housing market and private rent sector is further exacerbated by North
Eastern having high levels of inward migration (61%) compared to Perth and Kinross
benchmark (41%).  Although the area benefits from higher than the average lower quartile and
average incomes it also has the second highest average house price and highest market entry
prices. This suggests that higher house prices are being inflated by inward migration. Housing
options challenges in relation to housing supply are further exacerbated by lack of house
completions in the past and no land supply for future completions or affordable housing
completions. The Eastern HMA weighted housing pressure score was lower than the North
Eastern at 111, due to greater tenure diversification and less overall inward migration. 
• The Comrie hotspot has the second highest total weighted score of all the hot spot areas of 99
due ranking second for inward migration and second on the housing pressure indicators for
higher levels of ineffective stock (10%). Although Comrie ranks lower for housing market and
private rent affordability when compared with North Eastern and Crieff this could be attributed
to the higher levels of income in the area. High levels of inward migration (54%) compared to
the Perth and Kinross benchmark (41%), could be fueling house prices from people moving
into the area which is further exacerbated by the small number of housing completions in
recent years and no identified land supply for future supply. There are some similarities when
comparing Comrie housing pressures with the Strathearn HMA in relation to ineffective stock
and tenure diversification, however, Comrie has a higher rate of in-migration (54%) than
Strathearn HMA (50%) and also higher market entry and lower quartile house prices.
Strathearn also has the second highest level of house completions (14%) along with Kinross
(14%) compared to zero house completions in Comrie. There is a 5-year effective land supply
of 616 units in Strathearn with just 24 units in Comrie.
• Crieff hotspot has a total weighted score of 86, which was just 13 points lower than Comrie with
both hotspots being located within the Strathearn HMA. Crieff ranks lower for the housing
pressures for ineffective stock with second homes (1%), short term lets (1%), significantly lower
than both North Eastern and Comrie and lower than the Perth and Kinross benchmark. Whilst
Crieff has a similar diversity of market housing options, owner occupation (65%) and PRS
(15%) to the Perth and Kinross benchmark, but slightly lower levels of social rented housing
(14%) compared to Perth and Kinross benchmark of 17%. Affordability is a significant
challenge in the private rented sector in Crieff, with 38% unable to afford LHA rents and 44%
unable to afford market rents. Affordability is also an issue at market entry and average house
prices with 55% and 82% unable to afford respectively compared to the Perth and Kinross
benchmarks of 44% and 71%. Crieff has lower house prices than Comrie which to some extent
may be assisted by new housing completions in the last five years (124 dwellings) compared to
Comrie (7 dwellings) with a substantial 5 year effective land allocation for Crieff (361 dwellings)
compared with zero for Comrie. Crieff also ranks lower for in-migration (44%) when compared
with Comrie (54%) but is slightly higher than the Perth and Kinross benchmark (41%). It should
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also be noted that Crieff has the second highest demand for social housing in Perth and
Kinross suggesting there is a need for the provision of more affordable housing in the area. 
• The Perth City Centre host spot has the lowest total weighted score out of the four hotspot
areas at 38 and ranks the lowest for all 6 indicators.  Perth City Centre is located within the
Greater Perth HMA and has similar housing pressures of demand for social housing, lower
income levels, and market access and affordability issues. Perth City Centre ranked lowest for
levels of in-migration (25%) compared to North Eastern (61%) while short term lets and second
homes make up less than 1% of the areas stock compared to North Eastern (26%). Demand
for social rented housing is high with CHR applications accounting for 48% with 14 applicants
waiting for every property. This compares to less than 1% of applications applying for North
Eastern. Housing completions and effective land supply also help to relieve housing supply
pressures with Perth City Centre accounting for 40% of recent completions across Perth and
Kinross compared to none in North Eastern and Comrie. 
4.2 Housing Pressure Recommendations
Synthesizing a number of key indicators as measures of housing pressure in each hotspot area
would suggest the need for STLCA as follows:
• Hotspot area 1: North Eastern: There is clear evidence of high house price inflation caused
by higher in-migration by non-residents and a very high proportion of short terms lets and
overall ineffective stock. This is causing affordability issues in the housing market and the
private rented sector with almost no housing options in the social housing sector. Without a
short term let control intervention housing pressures will be exacerbated in the future with no
effective land supply allocation or SHIP affordable housing completions allocated for North
Eastern in the next 5 years.  
• Hotspot area 2: Comrie:  There is clear evidence of high house price inflation caused by
higher in-migration by non-residents and a significantly high proportion of short terms lets and
overall ineffective stock. This is causing affordability issues in the housing market and the
private rented sector with almost no housing options available in the social housing sector.
Without a short term let control intervention these housing pressures will be exacerbated in the
future due to a very limited effective land supply and no programmed delivery affordable
housing completions allocated for Comrie over the next 5years. 
• Hotspot area 3: Crieff: There is some evidence of house price inflation and affordability
pressures due to short term lets and ineffective stock. However, the housing pressures in Crieff
are evident due to higher house prices, affordability and dominance of owner-occupation as a
tenure. Therefore an increase in provision of affordable housing as well as market entry
housing may also assist with relieving housing pressures, whilst short-term let control could
ensure high residency is maintained. 
A short-term let control area should not be considered in Perth City Centre due to lower levels of
housing pressure. Evidence of housing affordability pressures suggest a need for more market
entry, social rented and intermediate housing. Perth City Centre has a very low number of short
term lets and ineffective stock, with in-migration into the housing market also relatively low.
Therefore a short term let control area is unlikely to have any significant impact on Perth City
Centre housing pressures with no evidence that housing pressures are being caused by high
volumes of sales to non-residents or ineffective stock.
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Although the study is focusing on the proposed hotspot areas of North Eastern, Comrie, Crieff and
Perth City Centre, there is significant evidence of housing presumes caused by short term lets in
the Highland HMA where none of the four hotspots are located. Highland HMA has a high
proportion of ineffective dwellings (23%) with short terms lets accounting for 9% (593 dwellings). 
Highland HMA also has the highest housing market and access challenges out of the five HMAs
with 59% of household unable to afford market entry housing and 85% unable to afford average
house prices. Furthermore Highland HMA has the second highest level of in-migration (57%) with
Kinross HMA having the highest (62%), the lowest rate of completions (3%) and the most limited 5-
year effective land supply (6%) of all HMAs. 
This evidence suggests that there could be short term let hotspot areas within Highland which are
inflating house prices for local residents and are being exacerbated further by a high proportion of
short term lets. To determine the hotspots within the Highland HMA will require further analysis to
consider if short term let control areas are required to relieve housing market pressures and
increase the supply of housing in the area. 
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Slide 1 
: P C ST  Pro ect Group
: 1 th April 2 24
Managing  irector
Perth    inross Council
Short Term  ets Research Study
utcomes  riefing
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Slide 2 
P C ST  Research Study
The Perth    inross ST  Research Study aims to:
sing key
indicators,
evidence housing
system pressure
which could be
relieved by ST
control
uild a short term
lets affordability
model to analyse
affordability
relative to local
incomes and
housing tenure
efine the e tent
of Short Term
ets and other
ineffective stock
by HMA and
hotspot
2 3 4
Provide
recommendations
on short terms
control areas
based on the
analysis of
housing market
pressures
Assess housing
system operation
in each
HMA Hotspot
area
1
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Slide 3 
P C ST  Research Study
Stage 2:  uild an ST Affordability Model
Assemble housing cost data by Sub
HMA Hotspot
Assemble income profile by Sub
HMA Hotspot
Populate housing affordability model
Scenario test rent to income ratios
evelop affordability benchmarks for
affordable   intermediate housing
by Sub HMA Hotspot
https:  westscot.co.uk
Stage 1: Profile e isting need and demand
for all tenures
Analyse housing list, stock and
turnover data by HMA   Hotspot to
profile pressure
Synthesi e pressure outcomes
with primary research affordability
analysis
uild thematic data book detailing
housing market pressure by Sub
HMA Hotspot
SH RT TERM
ETS
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Slide 4 
P C ST  Research
Study
There are five HMAs
across Perth    inross
Eastern
Greater Perth
Highland
inross
Strathearn
The four hotspot areas
considered in the
research study are
North Eastern
Comrie
Crieff
Perth City Centre
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Slide 5 
Household income profiles
Rental market affordability
Housing market affordability
CAN CANN T afford by tenure
Housing Affordability Model
P C ST  Research Study
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Slide 6
Model  nputs
ncome profile Housing costs   rent
levels
Customer intelligence
CAC Paycheck
Salary benchmark
MMR rents
Market rents
CH
Market entry sale
Affordable rents
enchmark: ability to
meet
Shared Equity sale
Model Assumptions
% income devoted to housing costs
Rent to income ratio
%    market rents  HA levels
Rent to income ratio
Equity rent ratio
% equity stake
Mortgage multiplier
% who can cannot afford each housing tenure
P C ST  Research Study
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Slide 7 
n reality, some households will
spend more than this depending
on their household
circumstances   rental cost
Rents are considered to be
affordable if a household pays
no more than 2 % 3 % of their
income on housing costs
(HN A Guidance)
Most social landlords will test
housing affordability using an
income to rent test of 3 % and
3 %
How much income should be spent on rent                          
Housing Affordability: The latest thinking
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 58 
Slide 8
P C ST  Research Study
2 %
Households
earn less than
2 k
2 %
Households
earn
2 k  4 k
1%
Households
earn
4 k
Eastern Greater
Perth Highland inross Strathearn Comrie Crieff North
Eastern
Perth City
Centre
Perth and
inross
1  14% 13% 11% % 11% 13% 14% % 16% 12%
1  2 k % % % 6% % % % % % %
2  2 k % % % % % % % % % %
2  3 k % % % 6% % % % % % %
3  4 k 14% 13% 13% 12% 13% 13% 13% 14% 13% 13%
4    k 12% 11% 12% 12% 12% 11% 11% 12% 11% 12%
k 3 % 3 % 41%  % 41% 3 % 3 % 43% 33% 3 %
%
1 %
2 %
3 %
4 %
%
6 %
A
is Title
CAC  PayCheck Household  ncome Profile 2 23
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 59 
Slide 9 
The average market rent in Perth    inross is   12 per month
This varies from  422.   for a 1 bedroom property to   23 for a 3 bed property
Strathearn has the highest average market rent of all HMA s at   6  per month
Crieff and Comrie have the highest average market rent of all hotspots at   23 per month
P C ST  Research Study
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 60 
Slide 10 
P C ST  Research Study
22,662
ower  uartile Perth 
inross income 2 23
21, 4 
iving Wage
2 , 21
Minimum Wage  21
At 3 % income to rent, households require to earn  32,4   to afford the costs of private renting, significantly
above minimum income benchmarks
P C RS s RS s 1
bed
RS s 2
bed
Market
Rents
Market
Rents 1
ed
Market
Rents 2
ed
MMR
(1  %
HA)
MMR
(  %  HA)
MMR 1
bed (1  %
HA)
MMR 2
bed (1  %
HA)
3 % Affordability 12, 31.   1 ,  4.   14,1 1.   1 ,326.13 32,4  .6  1 ,  3.1  24, 26.2  2 , 6 .2  2 ,2  .   16,  3. 3 22,33 .2
3 % Affordability 1 ,   . 4 12,  3.43 12,   .4  13,136.6  2 ,  3.3  1 ,4  .   21, 22.46 2 , 1 .66 24,23 .   14, 31.   1 ,14 . 
Minimum Wage   21 2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 .   2 , 2 . 
iving Wage 21, 4 .   21, 4 .   21, 4 .   21, 4 .   21, 4 .   21, 4 .   21, 4 .   21, 4 .   21, 4 .   21, 4 .   21, 4 . 
.   
,   . 
1 ,   . 
1 ,   . 
2 ,   . 
2 ,   . 
3 ,   . 
3 ,   .   ncome Required to  evote 3 % to Meet Housing Costs
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 61 
Slide 11 
P C ST  Research Study
ower quartile house
prices in 2 23       
Minimum annual income
required to access market
entry point
Assumes  oan to  alue ( T  of   %) and
mortgage multiplier of 3.2 times income
ower quartile income in
Perth    inross
Market entry point is out of reach for lower
quartile income households in Perth and  inross
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 62 
P C ST  Research Study
Market affordability analysis reveals that households must spend over       the average local
income to afford the average house price.
sing the Scottish Government s methodology to test market entry (benchmarking lower quartile
incomes to lower quartile house prices), reveals that households must spend over      their
income to purchase a home in the North Eastern hotspot area and over        their income in
the  inross HMA. This is in e cess of the typical 3.2 X s multiplier used for mortgage purposes.
Home ownership is out with the reach of local households on lower incomes, which is particularly
challenging given the dominance of home ownership in the area
Affordability is
e tremely challenging
at market entry level
in some HMAs
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 63 
Slide 12 
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 64 
Slide 13 
P C ST  Research Study
Without subsidy,   % of households can
afford social renting in Perth    inross
To afford social housing, households must
earn between  12, 31  1 ,  4, below
lower quartile incomes at  22,662
Whilst social housing is affordable to   % of
households, it accounts for  ust 1 % of the
housing stock in Perth    inross
Households require to earn  32,4  to
afford the cost of market rents with  ust 66%
able to afford
Households require to earn       to
afford the average house price ( 2 4,   )
with  ust % able to afford
CAN T afford P C Rents  
can t afford
CAN T afford RS  Rents  
can t afford
CAN T afford MMR rents at 1  %  HA  
can t afford
CAN T afford Market Entry  evel  
can t afford
CAN T afford Average House Prices  
can t afford
CAN T afford Market Rents  
can t afford
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 65 
Slide 14 
P C ST  Research Study
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 66 
Slide 15 
welling and tenure profile
Housing market and affordability pressure analysis
Short term lets and  neffective Housing Stock
Social housing pressure analysis
verall pressure scores by HMA Hotspot
Housing Market Pressures:
What evidence do we have
P C ST  Research Study
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 67 
Slide 16 
P C ST  Research Study
Housing Pressure Analysis
Housing Pressure Headlines:
f the  6,361 dwellings in Perth    inross, 1 % (12, 2 ) offer social tenancies
Home ownership dominates the tenure profile at 62% (4 ,33  homes)
The PRS accommodates 14% of households (1 ,  1 homes)
The diversity of housing options is
best in:
Greater Perth HMA
Perth City Centre hotspot
Alternative options to home ownership
are e tremely limited in:
inross HMA
North Eastern hotspot
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 68 
Slide 17
P C ST  Research Study
Housing Pressure Analysis
Housing Pressure Headlines:
ver the last year 2 year on average 3,1 6 house sales have been completed
verall, the average market turnover rate is  %
Average containment rate is   %, with in migration driving 41% of sales
The level of containment per HMA Hotspot, with sales made to local households is
highest in Greater Perth (6 %)   Perth City Centre (  %) respectively
n migration is high in  inross HMA (62%) and North Eastern Hotspot (61%)
Eastern Greater
Perth Highland inross Strathearn Comrie Crieff North
Eastern
Perth City
Centre
Perth and
inross
% of P   Containment  % 6 % 43% 3 %  % 46% 6% 3 %  %  %
% of Migration (E ternal) 43% 31%  % 62%  % 4% 44% 61% 2 % 41%
%
1 %
2 %
3 %
4 %
%
6 %
% 
%                                                         
% of P   Containment % of Migration (E ternal)
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 69 
Slide 18 
P C ST  Research Study
Housing Pressure Analysis
The average PRS rent in
Perth    inross is   12
per calendar month
The  HS rate in Perth 
inross is   44 per
calendar month
HMA Private rent levels range from      per month in Greater Perth, to   6
per month in Strathearn
Hotspot Private rent levels range from   6  per month in Perth City Centre, to
23 per month in Crieff and Comrie
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 70 
P C ST  Research Study
Housing Pressure Analysis
There are 12, 2  homes in
the social housing sector in
Perth    inross
n average over the last 3
years,  1  tenancies have
become available for letting
(6% of the housing stock)
The scale of the social housing sector varies significantly , HMA s 2 % in
Greater Perth to  % in  inross, Hotspots 1 % in Perth City to 1% in North
Eastern
There are 2, 3  live applicants e pressing demand for Council housing in Perth
inross. The ratio of applications to available lets is four applicants to every
property available
Ratio: Waiting  ist to Turnover Ratio Waiting  ist Turnover (1 bedroom) Ratio Waiting  ist Turnover (3 bedroom)
Eastern 3.1 2.  3.12
Greater Perth 3.  3.2  .23
Highland 4.6 3.12 1. 
inross 4. 6 3.62 3.3
Strathearn 3.66 2. 1 4. 
Comrie . 1 3. 
Crieff .16 3. 4 11. 
North Eastern .   .   . 
Perth City Centre 14.1 1 . 6 3 . 4
.  
. 
1 . 
1 . 
2 . 
2 . 
3 . 
3 . 
Social Housing Ratio of Waiting  ist to Turnover
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 71
Slide 19 
Housing Pressure Hotspot Headlines:
verall housing pressure is lowest in Perth City Centre
verall housing pressure is highest in North Eastern
Comrie 
Crieff 6
North Eastern14
Perth City Centre3                         
Eastern HMA111
Highland HMA1 
Greater Perth
HMA4 
inross HMA 
Strathearn HMA13                
Housing Pressure HMA Headlines:
verall housing pressure is lowest in Greater Perth
verall housing pressure is highest in Highland
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 72 
Slide 20 
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 73 
Slide 21 
P C ST  Research Study
Weighted Score: 14
Recommendation: Short
term let control area will
reduce housing market
pressures
34% ineffective stock of which 13% are short
term lets with limited housing options
Highest    house prices ( 2  ,   )
62% in migration
% house completions in last five
%  yr effective land supply or SH P pro ects
.2       income required for a mortgage
4% cannot afford market entry house prices
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 74 
Slide 22 
P C ST  Research Study
Weighted Score:  
Recommendation: Short
term let control area will
reduce housing market
pressures
1 % ineffective stock of which 2% are short
term lets with limited private rent
Second highest    house prices ( 2 2,4  )
4% in migration
residential units completed in the last   years
1%   year effective land supply   SH P pro ects
. 4      incomes required for a mortgage
6 % cannot afford market entry house prices
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 75 
Slide 23 
P C ST  Research Study
Weighted Score:  6
Recommendation: Short
term let control area will
reduce housing market
pressures
% ineffective stock of which 1% are short
term lets with lower social housing options
Third highest    house prices ( 16 ,   )
44% in migration
4% of house completions in last   years
1 %   year effective land supply
6% of SH P pro ects
.6       incomes required for a mortgage
% cannot afford market entry house prices
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 76 
Slide 24 
P C ST  Research Study
Weighted Score: 3
Recommendation: Short
term let control area will
not reduce housing
market pressures
4% ineffective stock of which  .2 % are short
term lets. Good tenure diversity
owest    house prices ( 11 ,2  )
2 % in migration
4 % of house completions in last   years
32%   year effective land supply
36% of SH P pro ects
incomes required for a mortgage
44% cannot afford market entry housing
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Perth and Kinross Council
Short Term Lets Impact Research
Research Report   
April 2024 77 
Slide 25 
P C ST  Research Study
Weighted Score:  
Recommendation: Short
term let control area will
reduce housing market
pressures
1 % ineffective stock of which 2% are short
term lets with limited private rent
Second highest    house prices ( 2 2,4  )
4% in migration
residential units completed in the last   years
1%   year effective land supply   SH P pro ects
. 4      incomes required for a mortgage
6 % cannot afford market entry house prices
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1
Appendix 2
Short Term Let Control Area - August 2023 Consultation Responses
SHORT-TERM LET DRAFT NON-STATUTORY GUIDANCE
SUMMARY OF CONSULTATION RESPONSES
Acronyms used in this appendix
CLUD Certificate of Lawful Use or Development
CPO Compulsory Purchase Orders
HNA Housing Needs Assessment
LDP Perth & Kinross Local Development Plan
PKC Perth & Kinross Council
P&K Perth & Kinross
NPF National Planning Framework
STL Short-term let
List of tables/charts
Chart 1 – Breakdown of responses by respondent sector
Chart 2–  Breakdown of responses originating from postcode areas within the proposed control area 
Chart 3 – All responses to principle of a STL Control Area
Chart 4 – Breakdown of responses to principle of a STL Control Area by respondent sector
Chart 5 – Breakdown of responses to the principle of a STL Control Area by respondent sector from postcode areas within proposal
Chart 6 – All Responses on location of the proposed control area
Chart 7 -  Breakdown of Responses to location of proposed control area by respondent sector
Chart 8 – Breakdown of responses from postcode areas within proposed control area  on location
Chart 9 – Breakdown of responses from specific postcode areas on location of proposal
Table 1 – Breakdown of responses by respondent sector
Table 2 – List of organisation / group respondents
Table 3 – All responses to the principle of a control area
Table 4 – Comments summary on principle
Table 5 – All responses to the location of a proposed control area
Table 6 – Comments summary on location of proposed control area
7
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2
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3
Chart 1 Table 1 Table 2
Table 3 Responses originating from postcode areas within the control area 
(includes/ representative of that area) 
Chart 2
Relation to Control
Area Residents
Business/
Resident
Orgs/
Groups Total %
Postcode area
within proposal
(25 Eastern HMA) 156 69% 63 28% 7 3%
225 67%
Postcode area
out-with proposal
but in PKC 68 67% 30 29% 4 4% 102 31%
Postcode area
Out-with PKC 0 0% 2 33% 4 67% 6 2%
Undeclared 0 0% 0 0% 0 0% 1 0%
Total 334
Resident 224 67%
Resident and
business
owner
46 29%
Business
owner
49
On behalf of
organisation /
group
14 4%
Not stated 1
100%
TOTAL 334
 Aberfeldy Community Council
 Aberfeldy Development Trust
 Airbnb
 Association of Scotland's Self-Caterers
 Conservative Group on PKC
 Federation of Small Businesses
 Glenlyon and Loch Tay Community Council
 Glenshee & Strathardle Tourist Association
 Rannoch Community Trust
 Ristol Consulting Ltd representing estates providing STL
accommodation in Highland Perthshire
 Scottish Conservative Group on PKC
 West Carse Community Council
 Response on behalf of 12 residents
 Response on behalf of 30 residents
67%
14%
15%
4% 0%
Respondents
Resident
Resident and
business owner
Business owner
On behalf of
organisation /
group
67%
31%
2% 0%
Responses from within the
Control Area
Responses within
proposed CA
Reponses out
within CA but part
of PKCResponses outside
PKC
Undeclared
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4
Q. Principle - To what extent do you agree with the principle of a control area?
Response All
Agree /
strongly
agree 178 53%
Disagree /
strongly
disagree  138 41%
Neither agree
nor disagree /
don’t know /
no comment  18 5%
Total  334 100%
Table 3 
Chart 4: Results by respondents
70%
27%
3%
Residents
14%
73%
13%
Business
owners
50%50%
0%
Organisations
/ groups
53%41%
6%
Chart 3 : All Responses
Agree / strongly
agree
Disagree / strongly
disagree
Neither agree nor
disagree / don’t
know / no comment
Agree
18%
Disagree
69%
Neither
13%
From Control Area
Resident business
Agree
57%
Disagree
43%
Neither
0%
From the Control Area
Organisations
Agree,
76%
Disagree,
22%
Neither,
2%
From the Control Area
Residents
Chart 5 : Results by respondents from postcode areas within proposal
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5
The responses set out in the tables below are grouped by respondent sector i.e. resident, business owner (including those who are also
residents), or organisation / group.
Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
Agree /
strongly
agree
 housing costs increasing
beyond local wages
 property taken off the market
for use as a business asset,
deprives local residents of a
home
 now attractive to absentee
investors of portfolios of
property
 government rent controls make
long term letting less profitable
and so less desirable
 people unable to live here and
businesses unable to recruit
staff as no where to live
 wealthy, retired people are the
only ones able to afford even
the basic house
 desirable holiday locations
becoming hollowed out; my
hamlet 2/10 full time occupied-
impacts on school roll, bin
collections and bus service etc.
 Housing problems for young
people eg: couple with own
 too many holiday houses and second
homes, we counted at least 100 in
Strathardle and Glenshee. Lack of
homes for families and workers
 impossible for locals to buy housing, the
village of Dunkeld is suffering
 not good for the community not enough
for young people
 empty properties for significant parts of
the year - leading issues for year-round
financial stability of businesses in the
area
 Local school roll is decreasing due to
lack of affordable family homes
 Holiday houses do not pay council tax
therefore contributing nothing to the
local facilities
 I do believe that secondary letting
needs to be regulated and requires a
registration scheme. Currently this is an
 Glenlyon and Loch Tay Community Council
area has an abundance of short-term let tourist
accommodation including second homes and a
lack of affordable to buy or rent accommodation
 Aberfeldy Community Council believe that the
housing crisis is very acute locally, and
addressing this should involve a mixture of
increasing supply, and control measures to
regulate current and future use of suitable
properties. We see this as one of a package of
measures that could usefully be undertaken to
help
 Aberfeldy Development Trust support any
mechanisms to enable Councils to manage the
number of second houses/holiday lets, to
protect the local housing supply for long-term
residents; help safeguard our rural communities
for the future. We understand the importance of
providing accommodation for visitors. This
should be balanced with the housing needs of
local communities. We believe that change is
needed, robust and effective legislation will help
safeguard our rural communities for the future.
Surveyed demand for social housing was almost
4 times the level of supply. 45% stated that they
would like to set up a business in the area if
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6
Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
Agree /
strongly
agree
business and reserve fire
fighter having to house share.
 can’t afford to downsize locally
 Enough good neighbours is
invaluable support for many
people, particularly elderly and
disabled people
 availability of housing is a 
barrier employment including in
the hospitality industry 
 impoverishes localities and
reduces spending in the
peripheral areas of P&K
 workforce who wish to live
locally have to commute many
miles daily.
 Simply building more
affordable housing is
environmentally unsustainable
 Not moving fast enough or
going far enough to reduce the
housing shortage crisis 
 this proposal doesn’t impact
existing economic activity, in
fact could enhance current
holiday letting activities as the
number of such properties will
grow more slowly. 
unregulated market that takes away
from affordable housing and renting in
areas and is also competition for
serviced accommodation providers, 
 but they don't have the costs and
regulatory burden that this market
faces.
 As a local employer, I often have
difficulties finding accommodation for
my staff moving to the area.
 Action needs to be taken and this is a
good first step, however should be
expanded to the whole of
PKC/Scotland.
they were able to move into it. Average house
price in Aberfeldy (2021/22) was £344,326
 Rannoch Community Trust - there are not
enough houses available for locals, many
houses being used as holiday house, taking
houses out of housing supply; increasing local
house prices has led to a shortage of key
workers in the area, young families, numbers at
the school and a decrease in services
 one of a package of measures that could
usefully be undertaken to help housing supply
 ideally short-term lets should not be allowed to
operate in towns where there are flats and
houses are built close together.  There is plenty
of provision of hotels in towns. some local
hotels in Perth are struggling to survive 
 enough holiday homes/more permanent homes
 Glenshee & Strathardle Tourist Association self-
catering units in our area have moderate to high
occupancy all year round (50-80%); providing
employment for local residents – housekeepers,
laundry, gardeners, maintenance and trades.
Properties are generally maintained to a higher
standard using the services of local plumbers,
electricians, joiners and builders etc. Guests are
much more likely to use village/farm retail and
eateries, year round local attractions/sports
facilities etc. 
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Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
need to have workers needs
to be balanced against the
need to have tourists or we
kill our own golden goose.
Strongly
disagree/
disagree
 current legislation requiring
planning for flats for STL can
safeguard suitable housing as
residential if used correctly and
policed
 a control area will increase the
number of second homes
 council and developers need to
build more affordable housing
 the proposal won’t resolve the
issue
 Lack of housing needs a multi-
faceted approach
 there are laws to protect
tenants, but nothing to protect
landlords, so landlords are
giving up and so there are
fewer rental properties
 the area relies of the tourism
economy – has the potential to
remove hundreds of jobs-
disproportionate impact on
women and poorer paid
 the area has a large dependency on
tourist economics.  
 House availability is driven by other
demands, including the shift from
conventional hotel to self catering as
witnessed by the explosion of the
AirBnB business model; the area is
attractive to retiring professionals with
relatively high city house prices; home-
working was accelerated post covid,
leading to professionals moving into
more rural areas and pushing prices up;
the population is growing fast across the
UK. Given that these demand changes
are UK government policy issues the
thing the Council needs to focus on is
building sufficient capacity to meet
demand
 STL control is not the answer to lack of
affordable housing. It is another stealth
tax and admin burden
 all will be prevented from holiday letting their
property when they’re not there – the property
will make an average 6 x less economic
contribution to the local community (see below),
some owners won’t sell as don’t want to and
don’t financially have to and so will
become/remain empty second homes, some of
those sold may be suitable for long term living
but many won’t be due to their rustic appeal,
remoteness, market price or size, and so will be
bought as a second home again. Insufficient
data. Demand is for STLs. The STL sector was
worth £3.8bn to Scottish GDP and 65,500
Scottish jobs in 2021, so we need to protect the
ability of local economies to capitalise on the
staycation boom by meeting that demand, of UK
residents to holiday here and increasingly to do
so in short term lets as opposed to other types
of accommodation. We do not believe that
planning approaches to limit the short term let
(STL) sector is the best approach. Better use of
un-used and under-used buildings   If the visitor
demand is for STL accommodation we wonder
about incentivising the development of less
wanted accommodation and other under-used
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8
Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
Strongly
disagree/
disagree
 short-term lets will revert to
second homes; empty for part
of the year
 This proposal will limit ability
to local residents to raise
additional income,
 a total infringement of an
individuals rights 
 tourism brings business in to
our dying town, where
everything seems to be
closing due to lack of footfall.
 It should not be up to the
residents of Perth and
Kinross to provide suitable
and affordable homes 
 controls will incur increases in
both workload and expenses
both for the local authorities
and landlords, greater
expenses will also be passed
down to tenants both long
and short term
 the council should gather data
from its short term lets
licencing exercise to inform
policy 
 monitor progress of the
licensing scheme first 
 not enough consultation with local
business owners
 think trend in house purchases just for
short letting needs moderation, but
control area would damage existing
businesses
 tourism is vital for the area
 most of the local businesses would not
survive on resident expenditure only
 the council has existing powers via the
licensing scheme and planning to
control let property supply
 I don't trust the data.   Second
homes/STLs are being lumped together
and Air BNB is a marketing platform and
doesn't give an indication of suitable
properties available for housing needs
 many let a spare room to increase
income, often due to lack of work
or un-used buildings such as empty second
homes and empty retail units into homes.
 This is an attack on small tourist businesses
with no benefit
 I strongly believe that a Planning Control Area
should not be introduced at this time. The
impact of the new Short-term Let Licencing
regulations within northern Perthshire (and
Perth & Kinross as a whole) should firstly be
assessed over a number of years, and if they
are not having the desired impact, then a
Planning Control Area could be reconsidered
amongst other solutions
 Fundamentally disagree with this level of state
control over the use of private property. It is up
to the individual to do what they want with their
properties. Rather than state imposing
restrictions and a layer of bureaucracy would
rather see state providing affordable rental
housing
 The ASSC - disagrees with the principle of
establishing a short-term let Planning Control
Area, as well as its proposed location, as there
is an insufficient evidence-base to proceed;
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Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
Strongly
disagree/
disagree
 tourism is an important
industry and we have seen in
Edinburgh that hotels have
massively increased their
rates when a short term zone
was introduced; this has
reduced UK based tourism
which has built strongly post
pandemic
 the Glenshee area which is
heavily orientated to tourism
which is needed for the local
economy
 this will cause a drop in
affordable accommodation for
tourists during the short peak
season, so damaging the
local tourist industry as a
whole
 individuals should not be
penalised further for either
owning a business or having
a second home
 do something about second
homes
 second homes should pay
double council tax
opportunities nearby (living more
remote area). 
 employers need to be addressing their
staffing needs too, not just flinging the
issue back at hard working individuals
 I do not trust PKC to implement it fairly
or reasonably
 the problem is nuanced and needs a
nuanced solution not a blanket control
program which would need to be
based on an arbitrarily decided set of
criteria to determine which areas
would be covered and which would not
 a control area should only be
established where there is accurate,
evidence based data to support the
need
 believes that the Council should instead
undertake a comprehensive exercise in
gathering precise and verifiable data, providing
stakeholders with the necessary evidence to
make an informed decision and take forward
this consultation
 Argues that the draft planning guidance is not fit
for purpose and will be subject to legal
challenge.
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Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
Neither
agree nor
disagree/
Don't
know
 there are some good points to
it and some not so good
effects of it
 tourism matters very much in
Scotland
 controls now on rents, many
properties are for sale/ been
sold so less available for STLs
 the data is not sufficient to
make any meaningful
conclusions
 homes which will become
available for sale will go to the
highest bidder.
 potential that a control area
could have an adverse effect
on tourism.
 engage in real dialogue with self-
caterers and not just those lacking
objectivity on the benefits of year-
round local operators
 unconvinced by the evidence that STL
has a significant detrimental impact on
affordable housing stock. I believe
empty & second homes owned by non-
locals is more relevant to this issue
 while I agree in principle with the aims,
I cannot agree overall as it is unclear
as it affects our small holiday let
business. 
 planning permission should be
sufficient to determine if property can
be used as a holiday let or not
 some areas planning control would be
beneficial, however I do not believe it
will result in more availability of rented
or affordable housing.
 any designation should be subjective
to the specific area, not a blanket
 No comments made
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11
Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
approach over an entire local authority
area. 
 tourism is a significant income
generator and there is a significant
shortage of quality tourist
accommodation 
 stopping short term lets is not the
silver bullet to improving housing stock
availability tackle by providing
affordable housing/community housing
 the idea is reasonable, but depends
how the proposed powers are used
 the self-catering sector supports jobs
and livelihoods in the area 
 if it is housing that Council wants to
create/ preserve, then I believe the aim
should be to regulate all areas 
 STLs in residential areas seem to have
largely escaped planning
requirements? So far, the focus seems
to be on targeting existing STL
properties for planning in largely
commercial or a mix of commercial/
residential areas only. A good few
property owners who have created and
established lawful business
endeavours in areas where there is
little chance of disturbing residential
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PKC Officer Comments
The principle of introducing a STL Control Area drew support mainly from residents and some residents business owners who were concerned
about housing supply and affordability issues and in turn the sustainability of their communities. The main reasons businesses gave were that
they were not in favour of restrictions on businesses that brings employment to communities, and that the evidence provided did not justify the
proposal and could harm tourism growth and therefore employment opportunities. Organisations/ groups gave the same reasons as above 
depending on whether they were a community group or trade representative. 
The evidence has now been updated using the STL Licence register data and more thorough research into the housing market to bring about the
most informed decision possible. The proposal seeks to provide the planning authority with the opportunity to assess all future Change of Use
applications to STLs rather than for flatted dwellings which is currently the situation. This would allow the council to balance the needs of the
development of tourism accommodation and housing needs in a more sustainable way within the context of each application using the non-
statutory planning guidance, in place since Nov 2023. The proposal is only to introduce a STL Control Area where housing pressure is greatest
and STLs are a significantly larger contributor to pressure than the majority of Perth and Kinross. That has been evidenced to be in Highland
Housing Market Area and the north parts of Eastern Housing Market Area (north of Bridge of Cally). 
Table 4 - Q. Principle - To what extent do you agree with the principle of a control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
neighbours are being refused Planning
Permission.  
 Each application, no matter the
location, should be decided on its
individual merit.
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13
Table 5 Q2. Location of
control area
Strongly Agree/ Agree 153 46%
Disagree/ Strongly
Disagree 144 43%
Don’t know/ Not stated /
37 11%Neither agree nor disagree
Totals 334 100%
Chart 7 – Responses to location of proposed control area
Q. Location - To what extent do you agree with the location of the proposed control area?
46%
43%
11%
Chart 6 - All Responses on location of the proposed
control area
Agree / strongly agree
Disagree / strongly disagree
Neither agree nor disagree / don’t
know / no comment
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14
Responses originating from postcodes areas within the proposed Control Area
Responses originating from Crieff and Comrie areas and Blairgowrie and the Glens. The distribution of responses when broken down further, is
similar to the overall distributions.
Q. Location - To what extent do you agree with the location of the proposed control area?
Agree
75%
Disagree
19%
Neither
6%
Control Area
Residents
Agree
25%
Disagree
64%
Neither
11%Control Area - Resident
business
Agree
80%
Disagree
20% Neither
0%
Control Area
Organisation
agree
40%
disagree
60%
Neither
0%
Crieff (PH7) & Comrie (PH6)  All
responses
agree
37%
disagree
63%
Neither
0%
PH10 - All responses
Chart 9 : Results by respondents from specific postcode areas on locaon
Chart 8 : Results by respondents from postcode areas within proposal on locaon
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15
Strongly
agree/
agree
 I think this map covers the
areas under the greatest
pressure
 The data provided shows very
well where control is needed
 There will always be someone
who wants the area extended,
so hard to ever put an area
boundary in the right place.
 All of Highland Perthshire
should be included
 Should it not be even wider to
include Blairgowrie?
 Should also include
logiealmond
 Covers the areas i would expect and that
are most effected
 Pitlochry and Mount Blair areas have a
shortage of affordable housing
 I think the Blairgowrie area should be
included.
 The proposed control area has
been carefully aligned with the
parts of the Council area where
there are the higher numbers of
short-term lets/second homes and
which are suffering from the
negative impacts.  
 We live in Perth and strongly
believe that it too should be a
control area -there are plenty of
hotels and guesthouses for people
wishing to visit the city centre.
Table 6 - Q. Location - To what extent do you agree with the location of the proposed control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
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Strongly
disagree/
disagree
 PH6 Comrie, Perthshire has no
available housing. School roll is
rapidly declining
 Should extend to whole of Perth
& Kinross.
 Don't  think it goes far enough.
Blairgowrie/ Alyth should be
included. I do not believe any
areas should be included.
 I think all short term lets which
are not in the same residence as
the landlord, should require
planning permission to allow
adjacent residents the chance to
raise concerns 
 We should not be attempting to
disrupt the operations of the free
market
 Perth city centre to be included
 extra layer of cost and
bureaucracy which will damage
tourism to the area and cost jobs
in what is our largest industry! 
target the landowners who own
huge swathes of our countryside
and manage it for the purposes
of a few wealthy folk who want to
shoot our wildlife?
 Any location that is not a reasonable
commuting distance to centres of
employment should be excluded, as
these locations would not contribute
affordable homes to key workers anyway,
and the restrictions would  only serve to
damage the tourism potential
 Too big an area.  No public transport  or
good wi-fi for people, everyone would
need a car.
 I would be more interested in a map that
is more selective in the targeting of areas
that have no long-term rental property
available, rather than a northern PKC
boundary map that appears to have been
drawn for cartography convenience
 It is too early to determine the areas as
short term let numbers are not yet known
 Private property owners are not
responsible for shortage of long term
rented accommodation
 This should not be a planning issue, if the
STL Order is not suitable / robust /
enforced across the entire area then it
should be amended.
 With the reduction in hotel
accommodation and STL where do
tourist go to stay in Perthshire? Where
 We don’t believe in the principal
regardless of where it is
 At this stage there is no proper
justification for the location of the
Control Area.  
 Until accurate data from licensing
scheme is available we don’t think
it’s possible to fairly apply the
control let to a specific geographic
area.
 It has been brought to our attention
that the statistics for the PH8 area
published by PKC are incorrect.
Can PKC comment on this?
Q. Location - To what extent do you agree with the location of the proposed control area?
Response Respondent
Residents Business Owners (including those
resident)
Organisations / group
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 Leave all of it out.
 Again, there appears to be only
hearsay evidence of an issue.
The accurate data will come at
the end of the registration
process and the decision on
which areas are most impacted
by short term lets should have
waited until that evidence was
available
will P & K make up the short fall. Adding
another restriction will not increase
housing stock. it will deplete tourism and
only increase prices.
neither
agree or
disagree /
Don't know
 The whole of the council area
should be included to avoid
pressure on areas immediately
outside a controlled zone.
 Only hamlets should be included.
 Perth city centre to be included
 Looks OK to me.
 I am unconvinced of its significance in
Pitlochry. Each area’s challenges are
different.
 The short term rental properties appear
to be in very touristy locations which is a
massive positive to adding additional
accommodation to allow more visitors
into these areas and to increase tourism
to Perth and Kinross.
 When not running our short term let, we
also manage a small charitable project
helping vulnerable households.  This
area does have a major problem with
access to affordable, fit for purpose long
term lets.
 Pitlochry, Aberfeldy and simiIar quaint/
historic/ scenic towns. I would request
caution to over-regulate the very popular
Tourism Destinations (towns)
 Until accurate data from licensing
scheme is available, we don’t think
it’s possible to fairly apply the
control let to a specific geographic
area.
 Inconsistency of fees being charged
and requirements being put in place
within areas of a single Local
Authority is a major concern to FSB
members. 
 Wherever a boundary is put in
place, there will be issues of one
business being more tightly
controlled than another, creating
unfair trading conditions that are
detrimental to the economy as a
whole.  From the perspective of
FSB members, this is the use of a
sledgehammer to crack a nut. 
 could lead to a complex and
uncertain regulatory environment in
which to do business.
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PKC Officer Comments
Many of the comments went back to the principle of a control area being established in any location. Many who disagreed with the
area, agreed with the principle of a Control Area and believed that the area included should be larger, and include the locations
Strathearn, the area between Dunkeld and Perth city, Blairgowrie. Others suggested the control area should be far more targeted. 
The comment regarding the specific instance of data, was locally incorrectly publish figure that was corrected and correction notice
published at the time. at the time. 
The evidence has been updated and the impact of a control area evaluated on the basis of housing pressure and of Short-term Lets.
The proposal is only to introduce a STL Control Area where housing pressure is greatest and STLs concentrations are greater than the
majority of Perth and Kinross. In these areas a Control Area can be justified by having an impact on the balance of housing stock and
tourism accommodation.  The refreshed evidence indicates that this area is Highland Housing Market Area and the north parts of
Eastern Housing Market Area (north of Bridge of Cally) which coincides with the previously proposed area. 
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1
Appendix 3
STATEMENT OF REASONS
Introduction
Under the Town and Country Planning (Scotland) Act 1997, Section 26B(1), and in
line with the Town and Country Planning (Short-term Let Control Areas) (Scotland)
Regulations 2021 as amended, and Planning Circular 1/2023: Short-term Lets and
Planning, Perth and Kinross Council intends to designate a Short-term Let Control
Area covering Highland Housing Market Area, and northern parts of Eastern Housing
Market Area to allow full consideration of impacts of the change of use of
dwellinghouses to short-term lets on the availability of residential housing for the
reasons set out below. As a consequence of designation, the impact of a short-term
let on the character and amenity of those areas would be assessed through each
planning application.
Reason for designation
1. To enable consideration of impacts of short-term lets on the availability and
affordability of residential housing within the control area.
 Concerns have been raised by communities on the impact of decreasing
affordability and the role of short-term lets on housing supply and affordability.
Public and stakeholder engagement for the Local Housing Strategy showed
that 71% of respondents in Highland Housing Market Area (HMA) have
concern over sufficiency and affordability of housing and 48% in Eastern
HMA.
 There is evidence of higher levels of housing pressure in Highland HMA and
northern parts of Eastern HMA, with affordability analysis indicating that 85%
of resident households would not afford the average market house price in
Highland HMA and 88% in north Eastern HMA. Concentrations of short-term
lets are higher in these areas than in the rest of Perth and Kinross, with 9% in
Highland HMA and 13% in north Eastern HMA, and although important
economic contributors, the concerns of communities suggests that the
balance of economic and housing needs is not in equilibrium.
 Capacity is limited for new build housing in part due to availability of
unconstrained land, with 3% being available in Highland HMA and none in
north Eastern HMA. Oversight of future use of existing residential stock will
assist the planning authority in assessing the balance of a sustainable tourism
industry and housing need.
 Northern Perthshire is adjacent to the Badenoch and Strathspey STL Control
Area, which was designated in March 2024. There is the potential for demand
from that zone to be displaced into Perth and Kinross, in particular parts that
lie within the Cairngorms National Park. As these adjacent areas are
evidenced to be experiencing housing pressure, it would be beneficial for the
planning authority to be able to assess the concentrations of short-term lets.
7
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Conclusion
Community engagement has raised concerns among business and residents of the
impact of decreasing affordability and supply of homes on the sustainability of local
communities. Housing pressure analysis indicates that in Highland Market Area and,
northern parts of Eastern HMA there is significant housing pressure and short-term
lets have a role in this pressure. It is therefore concluded that the establishment of a
Short-term Let Control Area would provide the Council and the Cairngorms National
Park Authority with the opportunity to consider the impacts on the availability of
residential housing in future applications while also balancing sustainable tourism
development for the benefit rural communities.
A short-term let control area would also:
 provide clarity on the need for planning permission for the change of use of a
dwellinghouse to an STL within the designated area.
 allow the opportunity for the public to comment on the proposed change of
use of a dwellinghouse to an STL within the designated area, through the
planning application process.
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Appendix 4
Map of proposed Short Term Let Control Area
Legend
Control Area
HMA
boundaries
7
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