Democracy Spraffa

Appendix 1 - Submission from Applicant

Perth and Kinross Council · 29 May 2023
Back to Licensing Committee — 29 May 2023 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

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For consideration by Perth & Kinross Licensing Committee
Ref: Civic Government (Scotland) Act 1982.  Application for Grant of a Short Term Let
Licence – Flat 1, Westwood, Station Road, Birnam. PH8 0DS.
Your Ref: FS-CASE-497070028.
STL Licensing Committee Meeting date: 29th May, 2023. 
Thank you for considering this submission relating to our application for a short-term-
let licence for the subject referenced property.
We are a retired married couple living within Perth and Kinross who have holidayed
and visited this area all our lives, enjoying its natural, historical, cultural opportunities
and resources.
Our property is a ‘C’ listed one-bedroom flat occupying the whole ground floor of a
three-storey flatted building.  The flat has direct independent access via a private rear
garden entrance door and is also serviced by a main front door that allows access to
the ground floor communal hallway and the flat’s front door.  There is a private rear
garden and a private parking space at the front of the property which allows one-step
entrance to the property.
As evidenced by Historic Environment Scotland, we understand that many buildings
in Station Road including ours were purpose-built for tourism and as such offer very
little in the way of storage to facilitate permanent residential living:
‘Probably built (1870) for let as lodgings for summer visitors as at Tower Buildings and
Murthly Terrace’.
See:  https://portal.historicenvironment.scot/designation/LB11081
We will use the property ourselves and, realising the continued importance of
protecting and encouraging tourism as originally intended, we seek to offer high-
quality, safe, legally compliant accommodation to visitors as a base to explore this
fantastic area of Perth and Kinross.
‘Westwood’ is a 3 minute walk from the train station and 2 minute walk to the Inverness
to Edinburgh bus stop and is across the street from the Birnam Arts Centre. The
walking, cycling and fishing opportunities on our doorstep are such a draw for us and
visitors alike.
We have fully complied with all STL mandatory requirements and prior to making this
STL licence application we applied to Perth & Kinross Council and have been granted
on 7Th March 2023 both Planning Permission for change of use to STL (22/02069/FLL)
and Listed Building Consent (22/02078/LBC).
We have enjoyed good communication during consultation with the Perth & Kinross
Council Conservation Officer to ensure our flat has been repaired and renovated in

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line with best practice and we will continue working with our neighbours to carry out
necessary repairs and maintenance, playing an active part in upkeep and
improvement of not just our property but the building itself so as to protect and
preserve the building as part of the local and Scottish heritage.
In relation to the STL licensing process; we have complied with all the mandatory
obligations including fire safety, gas safety, electrical safety, water safety – legionella
as well as safety and repair standards. We have increased our insurance liability in
line with STL requirements.
We have used, and will continue to use, local tradesmen to help with maintenance.  If
our application is successful, we intend to use a young, local professional
management company who will oversee all aspects when the property is let to ensure
professional standards, codes of conduct and compliance with ‘good guest’
procedures.  We wish to continue to support the vitality and success of the community.
We understand from Visit Scotland that there is a dearth in the area of ground floor,
small sized accommodation for guests with limited mobility or other limiting disabilities.
We have endeavoured to give consideration to this - our flat has its private parking
space directly outside, with one step to enter the property where the vestibule,
communal hall and whole apartment is floored using a single, level run of nonslip
flooring. Our toilet is a ‘higher’ seated loo, the shower is a low-rise walk-in shower with
a removable shower stool.  Throughout the property all electrical outlets have been
elevated.  If our application is successful we will continue our efforts to implement
further aids and assistance.
We have tried to make our flat as sustainable as possible through energy efficient
appliances, energy efficient light bulbs, weatherproofing, smart thermostats, using
sustainable household essentials and  low or non-toxic biodegradable products.  If the
application is successful, we will ensure clear recycling instructions, highlight public
transport and recommend local businesses such as the post office for farmer’s boxes
and eggs and the community growing garden ‘The Field’ for its locally grown produce. 
We will continue implementing sustainable practices and encourage our guests to do
so too.
We will keep up-to-date with changes in standards and legislation and would seek Visit
Scotland accreditation.
We have been welcomed into the community by our friendly neighbours and use the
local shops, cafés and facilities regularly and again we would actively promote
services and encourage guests to do likewise.
With reference to the two letters of objection, both parties, who are not our neighbours
but from the wider community, cover the same two points: insufficient housing stock
due to growth in numbers of holiday accommodation and the fact that a local person
is leaving their rented property and looking for an affordable long term rental property.

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Neither petitioner appears to make a complaint pertaining to the grounds for licensing
refusal, as per the Legal Position part of the Report to this committee by the Head of
Legal and Governance Services. 
As a former local authority Area Housing Manager I am aware, as you no doubt are
too, that the serious question of housing provision in Scotland and indeed the nation,
in the 21st century is challenging and multifaceted. Our housing problems include the
level of demand, demographic changes, changes in household structures, housing
stock levels not keeping a pace due to insufficient home building programmes, lack of
infrastructure, and empty houses.  In January 2023 there were 42,865 empty houses
in Scotland (ASSC 2023, Association of Scotland’s Self Caterers).
Likewise, many factors impact affordable housing and there are concerns about the
number of private landlords leaving the sector due to rising costs / mortgage rates and
the rate of return on investment proving unsustainable.  Social providers and housing
organisations face similar challenges.
Government, local authorities and social enterprises are considering how best to
address these difficult and emotive situations via strategies, policies and legislation
whilst balancing the needs and pressures of the economy in the modern world and
especially during this extended cost of living crisis.
The Scottish Government has introduced, via various Housing (Scotland) Acts,
protection for private residential tenants and limits the grounds on which eviction
orders can be acted on, in fact there is a current moratorium on evictions for all but a
few reasons.  Likewise, there are restrictions on rent increases and there are also
proposals for rent control areas.  Therefore tenants ‘having to leave’ properties is also
a complex and emotive subject.
These discussions need to have an evidence-based approach and not be based on
anecdotal comments - it is more complex than it all being the fault of holiday properties.
The ASSC states the self-catering industry delivers multiple benefits for local
communities ’providing a £867 million annual boost to the Scottish economy,
generating 2.4 million visitor nights and supporting 23,979 jobs’.  (ASSC 2023).  The
area of Birnam and Dunkeld is strongly reliant for its economic viability on tourism and
its associated revenue streams. 
Our small accommodation property, as detailed by Historic Environment Scotland, was
constructed for holiday visitor use and it is perfect for purpose as it was intended - as
a place for people to visit and enjoy whilst also contributing to the local community and
local economy.
We hope you will give positive consideration to our application and we thank you for
your time reading this submission.
Thank you.
Susan & Alistair Malcolm.

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1
Civic Licensing
From: Civic Licensing
Sent: 22 May 2023 11:17
To: Civic Licensing
Subject: FW: Short Term Let License Application - Flat 1, Westwood, Station Road, Birnam,
Dunkeld, PH8 0DS
Attachments: Senior Market .pptx
From: Marina DiDuca  
Sent: Monday, May 15, 2023 6:11 PM
To: Malcolm Family 
Subject: RE: Flat 1, Westwood, Station Road, Birnam. - Photos.
Hi Alistair,
Thank you for sharing images of your property with me.   Although the property would not be suitable for full-time
wheelchair users as your door would need to be a minimum 800 mm,  I can see that you are looking to make the
property more accessible for people with limited mobility and properties who cater for this market are definitely
in demand.
I have forwarded on some statistics which should help with you with your licensing application.
Please do keep in touch and let me know how things progress.
Best regards
Marina 
Marina Di Duca
Inclusive Tourism Manager
VisitScotland
Mobile:

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VALUE OF THE seniors market
In Scotland, 55 years old and over :
• 36% of domestic trips & spend are from the over 55’s
(4.3 million trips and £1 billion)
• 30% of international visitors are over 55
(1.2 million)
• Spend 20% more than average consumer on leisure and
hospitality
• In the last 12 years, 21% increase in domestic trips & spend
up by 45%
“86% of seniors will make a return visit compared with 18-34
year olds”(Source: Barclay’s Ageing Population Report)IPS
Source: GBTS and IPS

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DISABLED VISITORS, FRIENDS & FAMILY
• £249 billion annual spending
• 1/5 people are disabled
• 70% of disabilities are invisible
• 8% wheelchair users
• 1 in 3 people over 60 have
hearing loss
“75% of disabled people have
deserted a business because of poor
disability awareness or
understanding”

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3 reasons to engage with this market
Growth potential
(The market is set to increase as
the UK’s population ages. The
benefits for businesses and
destinations catering for
inclusive tourism are also
growing)
Loyal, repeat customers
(Inclusive businesses have higher
occupancy rates. 86% of this
market will make a return visit,
more loyal compared with 18-34
years )
Spend more
(disabled and senior travellers
spend significantly more on
holiday than other groups)