Agenda Document Pack - Economy and Infrastructure Committee - 28/08/2024
Perth and Kinross Council · 28 August 2024
Back to Economy and Infrastructure Committee — 28 August 2024 and its agenda
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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 Page 1 of 184
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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 Page 3 of 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 Page 5 of 184
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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) Page 6 of 184
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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. Page 7 of 184
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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 Page 9 of 184
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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 Page 11 of 184
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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 Page 12 of 184
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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 Page 13 of 184
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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 Page 14 of 184
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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. Page 15 of 184
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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 Page 16 of 184
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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 Page 17 of 184
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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. Page 18 of 184
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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 Page 19 of 184
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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 Page 20 of 184
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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 Page 21 of 184
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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 Page 22 of 184
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Appendix 1 PREVIOUS CLEANSE MONITOR OUTPUTS (2022/23) 5 Page 23 of 184
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Appendix 2 CLEANSE MONITOR 2023/24 and TO END JULY 2024/25 5 Page 25 of 184
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Appendix 3 VISUAL REPRESENTATION 5 Page 27 of 184
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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 Page 29 of 184
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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. Page 30 of 184
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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 Page 31 of 184
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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. Page 32 of 184
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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. Page 33 of 184
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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. Page 34 of 184
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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 © Crown copyright [and database rights] 2022 OS 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. 6 Page 35 of 184
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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 Page 37 of 184
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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. Page 39 of 184
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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 Page 40 of 184
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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
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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. Page 42 of 184
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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
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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
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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
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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
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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
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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
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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 Page 49 of 184
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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 Page 50 of 184
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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. Page 51 of 184
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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. Page 52 of 184
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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 Page 53 of 184
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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. Page 54 of 184
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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; Page 55 of 184
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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 Page 56 of 184
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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 Page 57 of 184
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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 Page 59 of 184
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2 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 Page 60 of 184
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3 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 Page 61 of 184
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4 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. Page 62 of 184
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5 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. Page 63 of 184
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6 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) Page 64 of 184
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7 Figure 2: Source: PKC STEAM REPORT FOR 2012-2023 Page 65 of 184
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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. Page 66 of 184
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9 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 Page 67 of 184
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10 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 Page 68 of 184
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11 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. Page 69 of 184
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12 Figure 6 LHS Engagement concerns regarding housing 2022-02-15 PKC LHS Early Engagement Results.pdf Page 70 of 184
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13 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 Page 71 of 184
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14 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. Page 72 of 184
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15 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. Page 73 of 184
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16 Figure 8: Distribution of unconstrained housing land per Housing Market Area Legend HLA– unconstrained land Housing Market Areas Page 74 of 184
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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. Page 75 of 184
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18 Figure 10: Consultation responses to principle and location of the proposed STL Control Area Page 76 of 184
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19 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? Page 77 of 184
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20 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 Page 78 of 184
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21 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. Page 79 of 184
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22 Figure 13: Concentrations of STLs as % housing stock by study areas Page 80 of 184
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23 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. Page 81 of 184
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24 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. Page 82 of 184
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25 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 Page 83 of 184
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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 Page 85 of 184
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Perth and Kinross Council Short Term Lets Impact Research 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 Page 86 of 184
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Perth and Kinross Council Short Term Lets Impact Research 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 Page 87 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report 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. Page 88 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 5 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. Page 89 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 6 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). Page 90 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 7 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. Page 91 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 8 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 Page 92 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 9 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 Page 93 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 10 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. Page 94 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 11 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 Page 95 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 12 • 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% Page 96 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 13 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 Page 97 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 14 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% Perth and Kinross £812 £744 £68 9%Page 98 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 15 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% Page 99 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 16 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 Page 100 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 17 Graph 2.2: Banded income profile by Perth and Kinross HMAs (CACI Paycheck Data 2023) Page 101 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 18 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. Page 102 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 19 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. Page 103 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 20 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 Page 104 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 21 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 Page 105 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 22 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 Page 106 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 23 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 Page 107 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 24 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 Page 108 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 25 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%). Page 109 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 26 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 Page 110 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 27 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 Page 111 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 28 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 Page 112 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 29 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. Page 113 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 30 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 Page 114 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 31 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 Page 115 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 32 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 Page 116 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 33 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 Page 117 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 34 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. Page 118 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 35 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 Page 119 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 36 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 Page 120 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 37 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 Page 121 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 38 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 Page 122 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 39 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% Page 123 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 40 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% Page 124 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 41 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% Page 125 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 42 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 Page 126 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 43 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 Page 127 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 44 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 Page 128 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 45 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. Page 129 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 46 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 Page 130 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 47 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. Page 131 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 48 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 Page 132 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 49 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. Page 133 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 50 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. Page 134 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 51 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 Page 135 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 52 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 Page 136 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 53 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 Page 137 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 54 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 Page 138 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 55 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 Page 139 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 56 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 Page 140 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 57 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 Page 141 of 184
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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 Page 142 of 184
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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 Page 143 of 184
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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 Page 144 of 184
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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 Page 145 of 184
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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 Page 146 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 63 Slide 12 Page 147 of 184
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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 Page 148 of 184
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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 Page 149 of 184
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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 Page 150 of 184
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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 Page 151 of 184
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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) Page 152 of 184
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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 Page 153 of 184
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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 Page 154 of 184
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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 Page 155 of 184
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Perth and Kinross Council Short Term Lets Impact Research Research Report April 2024 72 Slide 20 Page 156 of 184
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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 Page 157 of 184
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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 Page 158 of 184
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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 Page 159 of 184
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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 Page 160 of 184
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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 Page 161 of 184
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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 Page 163 of 184
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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 Page 165 of 184
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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 Page 166 of 184
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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 Page 167 of 184
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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. Page 168 of 184
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7 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 Page 169 of 184
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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; Page 170 of 184
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9 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. Page 171 of 184
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10 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 Page 172 of 184
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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 Page 173 of 184
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12 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. Page 174 of 184
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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 Page 175 of 184
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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 Page 176 of 184
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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 Page 177 of 184
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16 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 Page 178 of 184
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17 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. Page 179 of 184
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18 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. Page 180 of 184
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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 Page 181 of 184
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2 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. Page 182 of 184
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Appendix 4 Map of proposed Short Term Let Control Area Legend Control Area HMA boundaries 7 Page 183 of 184
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