Short-Term Let Control Area Designation Proposal
Perth and Kinross Council · 17 June 2026
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Our vision is a Perth and Kinross where everyone can live life well, free from poverty and inequality ___________________________________________________________________ Committee or Board: Perth and Kinross Council Date of Meeting: 17 June 2026 Report Title: Short-Term Let Control Area Designation Proposal Report Number: 26/176 Report Author: Stephanie Durning, Planning & Policy Officer, Housing Strategy Organisational Lead: Serge Merone, Strategic Lead - Economy, Development and Planning ___________________________________________________________________ 1. Purpose 1. The purpose of this report is to present the outcome of the statutory consultation on the proposed designation of a Short-Term Let (STL) Control Area covering Highland Perthshire and the northern part of the Eastern Housing Market Areas of Perth and Kinross, and to set out the remaining statutory steps required to establish the Control Area. 1.2 Sections 1. Purpose 2. Recommendations 3. Background/Context 4. Proposals 5. Statutory Process 6. Conclusion 7. Impact Value Assessment 8. Appendices 2. Recommendations It is recommended that the Council: 2.1 Notes the contents of the report and the Statutory Consultation Report (Appendix 2).
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2.2 Approves the designation of a Short-Term Let (SLT) Control Area covering Highland Perthshire and northern part of the Eastern housing market areas as per map provided in Appendix 4. 2.3 Asks the Strategic Lead, Economy, Development and Planning to progress the remaining statutory steps to formally designate the Control Area. 3. Background 3.1 At its meeting on 7 May 2025 (Appendix 1), the Council approved the commencement of the statutory process to establish a Short-Term Let (STL) Control Area covering Highland Perthshire and the northern part of the Eastern Housing Market Areas. Previous report included consideration of a range of options for managing short-term lets, concluding that maintaining the status quo would not provide sufficient planning control, while a Council-wide approach would be disproportionate given varying local pressures. A targeted Control Area has been identified as the preferred and proportionate option, enabling improved oversight of future STL growth in high-pressure areas while balancing housing needs and the visitor economy. 3.2 The statutory process comprises four main stages. The following stages have now been completed: • Publication of a notice of intention to designate a Control Area, including a Statement of Reasons (Appendix 3) and a map of the proposed area (Appendix 4). • Provision of a minimum 28-day period for public representations. 3.3 Subject to approval of the recommendation in this report, the remaining stages are: • Submission of the Statement of Reasons and final map to Scottish Ministers for approval. • If approved, publication of the designation, including a minimum 28-day notice period and confirmation of the date on which the Control Area will come into effect, together with the finalised map. 3.4 The introduction of a Short-Term Let (STL) Control Area would require planning permission for any change of use from a residential dwelling to a short-term let. This enables the Council to assess proposals against relevant planning considerations, including the impact on local amenity and the character of the area, as well as the loss of residential accommodation, in line with National Planning Framework 4 and other material planning considerations. 3.5 For clarity, planning permission is already required for the change of use of a residential flat to a short-term let. The designation of a Control Area would extend this requirement to all residential dwellings.
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3.6 Since the introduction of STL Control Area legislation, two control areas have been established in Scotland: one covering the City of Edinburgh Council area (September 2022) and one covering the Badenoch and Strathspey ward of Highland Council (March 2024). Fife Council undertook consultation on the potential introduction of a Control Area in 2025 and is currently exploring the feasibility of designating areas within St Andrews and the East Neuk. Highland Council 3.7 Consideration has been given to the Highland Council Short-Term Let (STL) Control Area as a comparator more closely aligned to the geographic and market context of Perth and Kinross than that of the City of Edinburgh. Highland Council has recently reviewed the operation of the Control Area within the Badenoch and Strathspey ward. This review identified that 43 applications for change of use to short-term let were refused, representing approximately 13% of applications. This demonstrates that the designation of a Control Area does not constitute a blanket restriction on short-term lets, but instead provides a framework for assessed, case-by-case decision-making based on local circumstances. 3.8 Highland Council is now progressing proposals to extend STL Control Area designation to a wider area, potentially covering up to 80% of the Council area, including Inverness. While such developments provide useful contextual information, the approach taken by other local authorities does not determine the decision for Perth and Kinross Council, which must be based on its own evidence base and local circumstances. STL Licences 3.9 The number of Short-Term Let (STL) licences in Perth and Kinross continues to increase. Table 2 below provides an overview of the total number of licences and the rate of growth between 1 October 2023 and 14 April 2026. Table 2: Distribution of secondary STLs across Housing Market Areas and growth rate (1 October 2023 to14 April 2026). 3.10 As of April 2026, there were a total of 1,767 secondary STL licences across Perth and Kinross. This represents an overall increase of approximately 37% since the statutory deadline for the registration of existing STLs on 1 October 2023. Growth patterns vary across Housing Market Areas: - In the Highland Housing Market Area, licence numbers have increased by approximately 24% over the period. Housing Market Area Eastern Greater Perth Highland Kinross Strathearn P&K Total STLs 293 321 815 58 280 1767 63% 45% 24% 41% 50% 37%Growth rate
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Although the rate of growth has slowed, it remains significant. A total of 23 licences (3%) has been surrendered since the scheme was introduced. - In the Eastern Housing Market Area, growth has been higher at approximately 63%, with the northern part of this area included in the proposed Control Area. 3.11 Between 5 November 2021 and 16 March 2026, the Council received a total of 155 planning applications for short-term lets within the wards comprising the proposed Control Area, equating to an average of approximately 31 applications per year. Of these, 37 applications related to Certificates of Lawful Use, where properties had operated as short-term lets for more than 10 years. The number of planning applications is significantly lower than the number of licensed short-term lets. This indicates that a substantial proportion of properties currently operating as STLs do not require planning permission under the existing framework. The introduction of a Control Area would therefore increase the number of short-term lets subject to planning control. Properties with existing planning permission, a Certificate of Lawfulness, or confirmation that planning permission is not required would not be affected by the designation. Wards in proposed Control Area Applications Approved Applications Refused Returned / Withdrawn Awaiting Decision Certificate of Lawfulness Ward 3 Blairgowrie 17 1 6 0 6 Ward 4 Highland 43 10 32 4 26 Ward 5 Strathtay 23 5 14 0 5 Table 3: Planning applications relating to STLs by ward (November 2021 – March 2026). 4. Proposals 4.1 The evidence set out in this report and supporting appendices (Appendix 5) demonstrates a sustained and spatially uneven increase in short-term let (STL) provision across Perth and Kinross, with the most significant growth occurring in Highland Perthshire and the northern part of the Eastern Housing Market Area. This growth is occurring in areas already experiencing housing pressure, constrained land supply, and challenges in supporting local services and workforce retention. In the absence of further intervention, it is expected that these trends will continue, resulting in an incremental loss of residential accommodation, increasing pressure on local communities, and reduced ability for the planning authority to manage cumulative impacts.
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4.2 The Council recognises the important contribution of the STL sector to the local economy and tourism offer. The proposal does not seek to restrict this activity but to ensure that it is considered alongside housing need and residential amenity. Evidence from comparable areas indicates that the majority of applications for change of use to STL continue to be approved where impacts are acceptable, demonstrating that a Control Area supports managed growth rather than constraint. 4.3 Implementation and Monitoring If approved, the designation of a Control Area will: - Require planning permission for new changes of use from residential dwellings to STLs within the designated area - Enable assessment against the Development Plan, including considerations of amenity, character, housing availability and cumulative impact - Increase the number of applications subject to planning assessment, reflecting the current gap between STL licensing and planning control The Council will monitor the operation of the Control Area, including application volumes, decision outcomes, and housing and tourism indicators, to inform any future review of the designation. 4.4 The designation of a Short-Term Let Control Area should be considered as one element of a broader package of interventions being progressed by the Council to address housing pressure and support sustainable communities. This includes measures such as the implementation of the Council Tax premium on second homes, ongoing work to bring empty homes back into use, and investment in the delivery of new affordable and rural housing. The Control Area complements these actions by focusing specifically on managing future changes of use within the planning system, ensuring a more balanced approach to housing availability, economic growth, and community sustainability rather than relying on a single intervention. Consultation Report 4.5 The proposal was subject to an 8-week statutory consultation, which ran from 28 October to 22 December 2025. The full consultation report is provided at Appendix 2. 4.6 Responses were primarily collected through the PKC online consultation hub, with an option for submissions via email. In addition to issuing the statutory notice and directly notifying Community Councils, the consultation was promoted through a press release and PKC’s social media and LinkedIn channels. Targeted engagement was also undertaken, including direct communication with tourism associations and partnerships, promotion through PKC business networks, and direct contact with the Association of Scottish Self-Caterers.
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4.7 A total of 214 responses were received. The key findings from the consultation are summarised below: - 70% of respondents (150) either lived in or represented interests within the proposed control area. - Overall support for the proposal was 76%, increasing to 86% among respondents within the proposed control area. - The majority of respondents were residents, representing 87% of all responses and 85% of those from within the proposed control area. - Resident respondents were largely supportive, with 81% (152) in favour of the proposal. - The highest level of support was from residents within the proposed control area, with 84% (107 responses) supporting the proposal. - Businesses and service providers accounted for a relatively small proportion of responses—9% (18) overall and 10% (15) within the proposed control area. - Business responses were, on balance, not supportive of the proposal: 55% (10) opposed, 28% (5) supported, and 17% (3) were undecided. - The majority of business responses (83%) were from short-term let (STL) operators. - Six organisational responses were received, five of which related to the proposed control area; 67% supported the proposal, while 33% did not. 4.8 Feedback on the reasons for supporting or opposing the proposal was gathered in two ways: through selection of predefined statements (informed by the 2023 consultation), and through the provision of open-text comments. 4.9 The principal reason selected in support of the proposal from the predefined statements was: There are too many short-term lets (STLs) in the proposed Control Area, impacting the availability of homes, and the proposal would enable the Council to exercise greater control over the loss of residential properties to new STLs. 4.10 The main themes emerging from open comments in support of the proposal included: The need to improve access to affordable housing, particularly for single- person households, young families, key local workers, and those seeking to downsize, with STLs perceived as adding pressure to the housing system. 4.11 The primary reason selected from the predefined statements for opposing the proposal was: Concerns that additional controls on STLs could have a negative impact on tourism.
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4.12 The key theme arising from open comments in opposition to the proposal was: The view that the Council should instead prioritise and invest in the delivery of additional affordable housing. 4.13 A wide range of views were expressed both in support of and in opposition to the proposal; these are set out in full within the Consultation Report at Appendix 2. However, the statutory consultation demonstrated overall support for the proposal. 5. Statutory Process 5.1 The Council initiated the statutory process by publishing a Notice of Intent to designate a Short-Term Let (STL) Control Area covering Highland Perthshire and the northern part of the Eastern Housing Market Areas of Perth and Kinross. A period of 55 days was provided for representations to be submitted to the Council. The outcomes of this consultation are set out in Appendix 2. 5.2 The remaining stages in the statutory process are as follows: - Submission to Scottish Ministers of the Statement of Reasons, supporting evidence, and a map of the proposed designated area. - Subject to approval by Scottish Ministers, publication of the Notice of Designation, including the date on which the Control Area will come into effect, alongside the finalised map. A minimum notice period of 28 days is required. 5.3 Taking into account the time required for Scottish Ministers to reach a decision, and assuming no legal challenge is received, it is estimated that the Control Area could be formally established by 1 January 2027. 6. Conclusion 6.1 The proposed Short-Term Let (STL) Control Area would introduce a requirement for planning permission for all residential dwellings intended for use as STLs. While such permission is already required for flats, extending this requirement would enable the Council to assess the cumulative impact of STLs on residential amenity and housing availability across the designated area. 6.2 The designation cannot be applied retrospectively; therefore, existing STLs which are operating lawfully will not be affected by the proposal. 6.3 The statutory consultation demonstrated overall support for the proposal. Updated analysis of STL licensing data indicates that growth in new licences since October 2023 has been significant. Introducing a requirement for planning permission would enable a more balanced approach to managing further growth, particularly in areas with high concentrations of STLs or where residential amenity may be adversely affected.
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The proposal does not constitute a blanket restriction on STLs within the Control Area. Evidence from Highland Council’s initial STL Control Area suggests that the majority of planning applications for change of use to STL are approved. 6.4 The next step is to submit the proposed STL Control Area—covering the Highland Perthshire Housing Market Area and the northern part of the Eastern Housing Market Area—to Scottish Ministers for approval. Subject to Ministerial consideration and no legal challenge, it is anticipated that the Control Area could be established by January 2027. 6.5 Taken together, the evidence base, consultation findings and wider strategic interventions demonstrate that the proposed Control Area represents a necessary, proportionate and balanced response to managing housing pressure and supporting sustainable communities. 7. Impact Value Assessment Impact and Value Assessment 8. Appendices 8.1 Appendix 1 - Short-Term Let Control Area Council Report 7 May 25 Appendix 2 - Short-Term Let Control Area Statutory Consultation Report Appendix 3 - Statement of Reasons Appendix 4 - Map of proposed Control Area Appendix 5 - Evidence Report