Appendix 2 - STL Control Area Statutory Consultation Report
Perth and Kinross Council · 17 June 2026
Back to Perth and Kinross Council — 17 June 2026 and its agenda
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1 Appendix 2 STATUTORY CONSULTATION 2025 SUMMARY OF CONSULTATION RESPONSES Individual consultation responses are available to elected members upon request. Introduction 1. Format of Consultation This formal, statutory consultation sought views on the proposal to designate a single Short-term Let Control Area covering Highland Perthshire and northern parts of Eastern Perthshire. Background This second consultation built on the earlier, broader consultation in the summer of 2023 which asked for views on the principle and boundary of a Short-term Let Control area, as well as non-statutory planning policy to support decisions on Short- Term Lets (STLs). The non-statutory guidance was introduced after agreement of the November 2023 Environment & Infrastructure Committee. In this formal, statutory consultation, feedback was sought in two ways. 1) a set of statements was offered to select from – informed by common themes identified in the 2023 consultation 2) open comments This strategy was adopted to encourage participation by aiding quick, focussed responses as well as aiding those who wished to leave more detailed responses To enable conclusions to be drawn on the responses from different interest groups, questions were asked of the respondents regarding their interests: • Resident, Business/Service, Organisation, Other interest • Type of Business/Service • Whether they lived in or represented interests in the proposed control area. Consultation Promotion In addition to the statutory requirements of publishing a notice in a local newspaper, publishing a notice on the Council’s website, and direct notification to Community Councils, it was also advertised widely through social media and Linked-in. Hard copy versions of the proposal and supporting documents were made available at the Council Offices in Perth and at 3 locations within the proposed control area (Pitlochry and Breadalbane Libraries and Kirkmichael Village shop). Tourism associations and partnerships were emailed directly, and the consultation was promoted through PKC
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2 business networks. The Association of Scottish Self-Caterers were contacted directly and they provided a response. 2. Respondents There were 214 respondents in total from 187 residents, 18 businesses, 6 organisations and 3 with other interests (Chart 1 below). Chart 1- Respondents • Majority of responses were from residents • Only 9% of respondents were from businesses/services *rounded Chart/Table 1: Respondent categories to the consultation. The majority of respondents, 70%, lived in or represented interests in the proposed control area, Chart 2 below. Chart 2- Control Area respondents • 70% of all responses were from residents/ businesses/ services within or representing interests the proposed control area TOTAL 214 100%* Residents 187 87% Business 18 8% Organisations 6 3% Any other interest 3 1% Control Area 150 70% Outside Control Area 64 30% TOTAL 214 100% 70% 30% RESPONDENTS Control Area outside Control area 87% 8% 3% 1% RESPONDENTS Residents Business Organisations Any other interest
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3 Chart/Table 2: Respondent by proposed Control Area The proportion of respondents from within the proposed control area was similar to the overall proportion of respondents to the consultation itself, with 85% from residents, 10% from businesses, 3% from organisations and 2% from other interests, namely visitors or a friend of a resident (Chart 3 below). Chart 3- Control Area respondent breakdown • The spread of responses by category were fairly similar to the distribution of overall responses Chart/Table 3: Respondent categories by proposed Control Area. Of the 18 business responses, 12 were from STLs in the proposed control area. 2 were from a non-STL accommodation and a food and drink business, and 1 was from a service provider. Of the 6 organisations that responded, 5 represented interests within the proposed control area (Chart 4 below). The relatively low number of business/service responses was despite undertaking more to promote the consultation than the statutory requirement. Tourism associations and partnerships were emailed directly, and the consultation was promoted through PKC business networks. The Association of Scottish Self-Caterers were contacted directly, and they provided a response representing their membership. Residents 127 85% Business 15 10% Organisations 5 3% Other 3 2% Total 150 100% 85% 10% 3%2% RESPONDENT BY CONTROL AREA Residents Business Orgs Other
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4 Chart 4 – Business respondent breakdown • The majority of business/service responses were from STLs, 12 of those were from the control area Chart/Table 4: Business/service types. 3. Results Headline Chart 5 - Headline results The majority of responses, 76%, were in support of the proposal, 21% were not in support of the proposal and 3% were undecided (Chart 5). Similar levels of support for the proposal, 78%, were from those that either lived in or represented interests in the proposed control area (Chart 7 below). In the proposed control area, the majority of responses were from residents (Chart 3 above). The majority of business respondents whether within or outwith the proposed Control Area were not in support of the proposal with 53% of respondents from outwith the proposed control Area, and 55% from within (Charts 10 & 11 below). STL 15 83% Food & drink 1 5.6% Service providers 1 5.6% Accommodation (non STL) 1 5.6% Total 18 100% 83% 5%6%5.6% TYPE OF BUSINESS STL Food & drink Service providers Accommodation (non STL) 76% 21% 3% RESPONSES Agree Disagree Undecided
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5 Approximately one-third of business/services were supportive of the proposal whether within (34%) or outwith (28%) the proposed Control Area (Charts 10 & 11 below). Results Detail and Reasons The majority of responses overall, 76%, were in support of the proposal 21% were not in support of the proposal and 3% were undecided. (Chart 6 below). Chart 6 - Overall responses Table 5: Overall responses. Similar levels of support came from those that either lived in or represented interests in the proposed Control Area. Chart 7 - Control Area responses • 78% were in support of the proposal, 19% were not in support and, 3% were undecided (Chart 7 above). Agree 163 76% Disagree 44 21% Undecided 7 3% Total 214 100% Agree 117 78% Disagree 28 19% Undecided 5 3% Total 150 100% 76% 21% 3% RESPONSES Agree Disagree Undecided 78% 19% 3% CONTROL AREA RESPONSES Agree Disagree Undecided
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6 Chart7: Control area responses. Table 6: Control area responses. Reasons Respondents were offered to select from a series of statements that reflected common themes raised in the earlier consultation instead of or in addition to leaving open comments. The statement options offered to respondents who expressed support for the proposal were:- Support 1. There are too many STLs in the proposed Control Area and they’re impacting the availability of homes. It will give the Council the opportunity to have more control over the loss of homes to new STLs within the Control Area 2. The Council should use all the tools at its disposal to support the numbers of homes locally 3 It will slow the growth of new STLs 4 It will allow the Council the opportunity to have more control over any detrimental impact on amenity and character of a neighbourhood within the Control Area 5 It will make it clearer as to when planning permission is or isn’t required for a short-term let, in the Control Area 6 It is fairer that all new tourism accommodation (purpose-built / conversion / change of use) in the Control Area will be treated the same way in the requirement for planning permission It is fairer that all new tourism accommodation (purpose-built / conversion / change of use) in the Control Area will be treated the same way in the requirement for planning permission Nb. Respondents were able to select multiples Results Statements selected in support of the proposal 1 2 3 4 5 6 Not answered Total 144 116 94 119 85 98 49 705 20.4% 16.5% 13.3% 16.9% 12.1% 13.9% 7.0% 100.00%
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7 Table 7: Overall summary of statements selected in support of the proposal. The most common statement selected in support of the proposal was • There are too many STLs in the proposed Control Area and they’re impacting the availability of homes. It will give the Council the opportunity to have more control over the loss of homes to new STLs within the Control Area? The main reason for supporting the proposal from the additional open comments can be summarised as: • The need for affordable housing for single person households, young families, downsizers, housing for local workers in key services - STL accommodation puts further pressure on the system Not in support Statement options offered to respondents that expressed that they were not in support of the proposal and also still allowing for open comments were: 1 The numbers of short-term lets are not impacting the availability of homes in the proposed Control Area 2 Controlling which new short-term lets in the Control Area get planning permission will not significantly improve the affordability of homes in the area 3 There is not sufficient impact on amenity or character of neighbourhoods to necessitate the introduction of a Control Area 4 There should not be more costs and controls on tourism businesses 5 Controls on STLs could negatively impact tourism 6 The Council should use other tools at its disposal to support the numbers of homes locally 7 STL Control Area might discourage second-home owners from considering short-term letting Nb. Respondents were able to select multiples Results Statements selected not in support of the proposal 1 2 3 4 5 6 7 Not answered Total 26 30 20 28 33 30 19 171 357 7.3% 8.4% 5.6% 7.8% 9.2% 8.4% 5.3% 47.9% 100% Table 8: Overall summary of statements selected not in support of the proposal. The most common statement selected for not supporting the proposal was • Controls on STLs could negatively impact tourism
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8 The most common reasons given in the additional open comments that were not in support of the proposal were equally split between two comments summarised as: • The Council should fund the building of more affordable homes • That in very rural locations where there is a lack of amenities- it can be difficult to sell property and STLs enables more sales (The settlements of Ballintuim, and Glenlyon were specifically referred to) An open comment box only was offered to those who were undecided on the proposal. The reasons given were varied but could be summarised as: • It was unclear how the policy would work to affect the individuals’ situation. Results breakdown by respondent category Residents The responses from residents mirrored the main results with 81% of resident responses in support of the proposal, Chart 8 below). 17% not in support and 2% undecided (Chart 8 below) A slightly higher majority of residents 84% in the proposed control area supported the proposal, whilst 14% were not in support and 2% were undecided (Chart 9 below). Chart 8 - Overall residents Chart 9 – Control Area resident Chart 8: Overall resident responses Chart 9: Control Area resident responses. Agree 152 81% Disagree 31 17% Undecided 4 2% Total 187 100% Agree 107 84% Disagree 17 14% Undecided 3 2% Total 127 100% 84% 14% 2% RESIDENT (CA) agree disagree undecided 81% 17% 2% RESIDENTS agree disagree undecided
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9 Table 9: Overall resident responses. Table 10: Control Area resident responses Reasons As residents were the largest respondent group, the reasons given for supporting or not supporting the proposal are reflected in the overall reasons outlined above. There was a greater variety of reasons made in the open comments that were not in support of the proposal from those out with the proposed Control Area, so in addition to those above were • Better STLs than empty properties • Focus should be on addressing empty homes and second homes • The proposal is unlikely to have any real impact on housing shortages in Perth and Kinross • Concerns that restricting STLs raise prices, will harm tourism, and damage the local economy Business Of business/service responses overall, 28% were in support but the majority 55%, were not in support of the proposal. 17% were undecided (Chart 10 below)
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10 Chart 10-Business/service overall Chart 11- Business/service Control Area Chart 10: Business/service responses overall Chart 11: Control Area resident responses Table 11: Overall resident responses Table 12: Control Area resident responses More Business/service responses from within the proposed Control area, 34%, were in support of the proposal. The majority, 53%, did not support the proposal and 13% were undecided (Chart 11 below). Only 9% of respondents overall were from businesses/services (18), 10% from within the proposed control area (15). Reasons Statements selected that were not in support of the proposal were • There should not be more costs and controls on tourism businesses. With additional reasoning given:- • Negative impact on overall tourism industry Statements selected that were in support of the proposal were Agree 5 34% Disagree 8 53% Undecided 2 13% Total 15 100% Agree 5 28% Disagree 10 55% Undecided 3 17% Total 15 100% 28% 55% 17% OVERALL BUSINESS/SERVICES Agree Disagree Undecided 34% 53% 13% BUSINESS/SERVICE CONTROL AREA Agree Disagree Undecided
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11 • It will allow the Council the opportunity to have more control over any detrimental impact on amenity and character of a neighbourhood within the Control Area. Reasons for supporting the proposal were varied including • Quality of evidence, application of the policy, losses of the STL sector Comments made by those that were undecided about the proposal were around • Quality of evidence • Lack of affordable housing rather than STLs being the issue, unclear how the proposal will impact that • Licensing has brought better balance Business/Service Categories We asked about the nature of the business/service. The businesses that were not in support were STLs, other accommodation, food and drink, and service providers. All the businesses that were in support of the proposals were STL businesses. Those that were undecided were also all STLs. The most common statement selected that was not in support of the proposal did not differ from that selected by business both inside and outside the proposed control area Additional reasons were given in the open comments • Having issues with the evidence presented • The Council should build more homes, tackle second homes and empty homes Organisations 67% of organisations supported the proposal, 33% were not in support the proposal (Chart 12 below). 5 out of the 6 organisations that responded were representing interests within the control area. 60% supported the proposal and 40% were not in support (Chart 13 below). One of those responses was an industry representative and representing multiple views of self-catering accommodation providers.
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12 Chart 12- Overall organisation responses Chart 13 - Control Area organisation responses Table 13: Overall resident responses Table: 14 Control Area resident responses. Reasons All 6 supporting statements were selected by organisations representing interests within the proposed control area (Statements listed on p.6) The respondents from outwith the proposed control area selected only two of the supporting statements number • There are too many short-term lets in the proposed Control Area and they’re impacting the availability of homes. It will give the Council the opportunity to have more control over the loss of homes to new short-term lets within the Control Area. • It will make it clearer as to when planning permission is or isn’t required for a short-term let, in the Control Area. Additional supportive reasoning was given from representations within and outwith the control area, summarised by:- • the introduction of any mechanisms to enable Councils to manage the number of second houses/holiday lets, to protect the local housing supply for long- term residents. We understand the importance of providing accommodation Agree 3 60% Disagree 2 40% Undecided 0 0% Total 15 100% Agree 2 33% Disagree 4 67% Undecided 0 0% Total 6 100% 60% 40% ORGANISATION RESPONSES (CA) Agree Disagree 67% 33% ORGANISATIONS Agree Disagree
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13 for visitors, however, this should be balanced with the housing needs of local communities. The Organisations that were not in support of the proposal were both within the control area. The most common statements selected that were not in support of the proposal were • The Council should use other tools at its disposal to support the numbers of homes locally. With very varied additional comments that can be summarised • STLs are not the cause of housing scarcity but are being treated as such. This narrative ignores larger structural issues: a lack of new supply, demographic shifts, and poor delivery of affordable homes. Other interests There were 3 responses representing 2% of respondents with other interests, all expressed an interest in the Control Area. These were former residents and a visitor. 67% were in support of the proposal and 33% were not in support of the proposal (Chart 14 below). Chart 14 – responses of other interest Reasons Those in support of the proposal selected the statements • The Council should use all the tools at its disposal to support the numbers of homes locally. 67% 33% OTHER INTERESTS agree disagree
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14 • It will allow the Council the opportunity to have more control over any detrimental impact on amenity and character of a neighbourhood within the Control Area. • It will make it clearer as to when planning permission is or isn’t required for a short-term let, in the Control Area. • It is fairer that all new tourism accommodation (purpose- built/conversion/change of use) in the Control Area will be treated the same way in the requirement for planning permission. The additional reasons given were • prevent existing long term rental properties becoming STLs, encourage the local communities to be more vocal in use applications for STLs Those with other interest, not in support of the proposal selected the statements • Controlling which new short-term lets in the Control Area get planning permission will not significantly improve the affordability of homes in the area. • There should not be more costs and controls on tourism businesses. • Controls on short-term lets could negatively impact tourism • The Council should use other tools at its disposal to support the numbers of homes locally No additional reasons were given.
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15 4. Additional Responses 113 additional comments were received outside the offered statements. They have been summarised below with the officer response and arranged by type of respondents. Within that, they have been ordered by frequency. *number of responses making the same point Table 15: Extended responses: nb. Responses will not tally with number of respondents as multiple points were made Control Area / Residents /‘Agree’ (no.of similar comments) Officer Response • The need for affordable housing for local single folk, young families, young people, downsizers and key workers is well known and STL accommodation puts further pressure on the system (14)* The proposal intends to provide a mechanism to help balance competing needs for property use. • Having fewer full-time residents not only detrimentally impacts the viability of local service provision and affects community cohesion. Communities are becoming holiday resorts. Few shops and businesses are open in winter. • More full-time residents would mean be year-round businesses. Match numbers of STLs with local facilities and attractions so the whole of Perth and Kinross can benefit (7) • Aberfeldy and Dunkeld mentioned specifically • Priced out of our community outbid by second home and STL owners. Hard to find long term rental homes (Eastern HMA- PH10 & Highland HMA- PH8). This policy will help the supply of long-term housing. (5). • All businesses including tourism business find it hard to get staff due to lack of housing (2) • Increased pressure on sewerage system, roads and parking from increased tourism used (2). Pressure on Dunkeld sewage system mentioned specifically (1)
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16 • The local Community Action Plan just completed in 2024 in my area had ‘Control of Short Term Let’s’ as the second priority for our community only after the number one priority of ‘More Affordable Housing’. • Pressure on road network from additional tourism traffic from over provision of tourist accommodation • Better balance needed especially in rural communities where commuting from Perth with more options just isn't possible. • Real issues with managing existing short term let problems in our postcode area - owners live abroad and no one cares what happens to the properties week to week spoils living here The proposal will extend the instances where planning matters can be considered, including amenity. • Extend to other areas The evidence does not support the inclusion of these areas at this time, however monitoring will continue • Former council houses should not be made into STLs. Should be returned to Council ownership if used as STL but for the same discount they received when purchased (2) This is not workable as there may have been several owners since the initial purchase from the Council. However former council properties may be considered in planning decisions as likely to be a more affordable home therefore requiring greater justification to become an STL, depending on the circumstances • Better financial returns on STLs and tenancy conditions of private rental tenancies means STLs are more favourable use Local authorities cannot affect the conditions of private rental tenancies however the proposal may impact the balance locally towards more favourable conditions for private lets. • Jobs within the village are being taken by people living further away, having to drive in and increasing the parking problems The policy is supported by planning policy NPF4, to support sustainable communities and local living • Many affordable homes (previously owned by Council or etc) have been sold privately and never replaced The Council has a programme to support the building of affordable homes in the proposal area. There are many barriers to building new homes. The policy is intended to support the availability within existing stock and any future stock. The council is currently reviewing the Local Development Plan. • I wish the council would stop allowing the building of holiday lets and build affordable housing
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17 • Increase taxation to triple for Council Tax second homes PKC increased Council Tax for second homes to the maximum level at the time in 2024. • I understand that as small businesses, STLs are exempt from rates. There have been an increasing number of STLs being run by owners based outwith P&K, so they are using local services but not contributing to the costs of the services they are using. A small business bonus scheme exists giving tapered relief for very small businesses. Any relief or rate would depend on the rateable value of the business(s) (combined). Business rates are payable to Perth and Kinross Council and therefore contributing to local services. • Agree, but more targeted STL CA would be better to avoid towns dependant on tourism Each application is considered on its merits therefore will not specifically impact a town or village but instead recognise the impact which might be at a street level. • 5 year residency for any applications There is currently no mechanism that would allow for this to be introduced Control Area/ Resident/ ‘Disagree’ (no.of similar comments) Officer Comment • Property is difficult to sell here including more affordable properties. Demand is low due to lack of amenities. STL demand facilitates sales in these more difficult locations, (4) Ballintuim, Glenlyon mentioned. The individual circumstances of each planning application would be considered. • The Council should fund the building of more affordable homes (4) The Council as a programme to support the building of affordable homes in the proposal area. There are many barriers to building new homes. The proposal is intended to support the availability within existing stock and any future stock. • Don’t see the evidence that the policy will increase availability of homes to let (2) • Risks impacting tourism - a major source of income in the local / rural economy, with short-term lets a small but valuable component of that (2)
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18 • The relationships in the demands for both 'affordable' housing and well-paid local employment are complex matters and not within the capabilities of PKC to solve or this policy. The policy intends to provide a mechanism to help balance competing needs for use property. • Rural places (40mins from A9) need STLs for tourism and income- Response is not proportionate to the facts. • Towns like Aberfeldy are economically supported by tourism. 15 years shops were closing. Now new cafes, shops, etc are opening. • STLs provide more affordable tourism accommodation than hotels which are getting increasingly expensive. Impacting STLs, will impact economic benefits gained from lower cost, often locally owned STLs – Pitlochry mentioned. • Have little faith in the planning system. Approval given to purpose built holiday letting that can cause serious disturbance. • Would be reluctant to widen the remit of planning. • It will result in few additional rejection of licences resulting in more revenue for the council The fees charged cover only the application costs. They are not mechanisms of taxation. Small numbers of additional homes can be valuable to supporting rural services such as retained fire services • I don’t understand why more bureaucracy than the licence scheme is needed. Strange that some ex-council/social type housing used as holiday lets. That is inexplicable. The Licence scheme has no legal framework to consider which housing is used for STL letting. The proposed Control Area would enable this consideration along with other planning considerations. • The Council has over-estimated the number of STLs (Dunkeld and Birnam mentioned) See comment on p.38 below Within the proposed control area, the number of empty homes is less than the number of short-term lets, see response on p.31 below • I understand empty homes are double the number of holiday lets
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19 Control Area/ Resident/ Undecided (no.of similar comments) • Too many houses being used as STLs, whilst less desirable property, like flats, now sit empty/unsellable because of the current rules. • My family can’t move into a house as no buyers for my flat and houses are all bought and changed to STLs The proposal will require change of use for houses to be treated in the same way as flats currently are. This aims to reduce the number of houses being changed into STLs Permission can be granted on flats and is dependant on the individual circumstances of the application • The proposal doesn’t go far enough. STLs Licence granted to a dwelling house in an area of housing pressure. Where key workers for the local school struggle to find housing. Unless councillors get tough, the proposals are more rigorous and community pressures are taken into consideration, this IS a total waste of time! The proposal will provide the legal framework for dwelling houses to require planning permission (currently only flats require planning permission) where the number of STLs and housing availability can be considered in the application. • Comment around homelessness experience due insufficient housing and at an affordable price. The proposal is one tool to help manage the number of homes available where this is the best use Outside proposed Control area / Resident/ ‘agree’ (no.of similar comments) The proposal intends to provide a mechanism to help balance competing needs for use property. • More homes for local residents at affordable rents for younger families and downsizing. Housing being built is for 2 income families and smaller housing is now STL (3) • Need families and young people to work in our business. Long term rentals needed to encourage them (2) • Ratio of STLs to housing is unsustainable (2) • Combine proposal with using the planning process to favour building of new homes converting empty. It seem to be easier to get permission for holiday homes than permanent homes at the moment.
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20 • Too many STLs for the demand resulting too many empty properties most of the year, whilst having to build more permanent homes The evidence does not support the inclusion of these areas at this time however monitoring will continue • As an NHS worker I’m concerned that health and social work services will be unable to find staff as they are unable to afford to live in the proposed Control Area • Include P&K (2), Comrie, Caputh-Meiklour- Blairgowrie. Caputh-Murthly-Stanley- to manage sensitive future development • Support but Control Area should be more targeted settlements • Conditions of private rental tenancies mean STLs are more attractive • Whilst a housing emergency exists all new [STL] lets should be put on hold. Current let's, if possible, should be reduced by 50%. The legal framework of the proposal does not allow for the legislation to be applied retrospectively to existing lawful STLs. Due to the economic benefits of STLs, the individual circumstances of each application will be considered. This will help balance competing needs for use of each property. Outside proposed Control area / Resident/ ‘disagree’ (no.of similar comments) • Better STLs than empty properties (2) The non-statutory guidance that guides planning decisions on STLs supports the conversion of empty homes to STLs, where this is appropriate • Focus should be addressing empty homes and second homes (2) PKC does this through the Empty Homes Initiative and applying a 100% supplement on the Council Tax of second homes. • unlikely to have any real impact on housing shortages in Perth and Kinross (2) The proposal is not intended to address all causes of housing shortages but a tool that can be used to better
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21 • General comment about the lack of council property for single, elderly and people with disabilities; condition of old housing stock, design and quality of new build stock also listening to tenants’ needs from housing. Statement on the fairness of people owning 2 properties and using one for holiday letting balance the use of residential homes for tourism accommodation. • Concerns that restricting STLs will raise prices, harm tourism, and damage the local economy (2) The importance of tourism to the local economy in Perth and Kinross is recognised. The proposal is not a blanket ban on all STLs so will not ‘halt’ the growth of STLs. The proposal intends to provide a mechanism to help balance the competing needs of residential and tourism purposes to the benefit of sustainable local communities • STLs are small businesses. People working hard to make a living. People providing somewhere for tourists to stay. People employing local people. People making an honest living. Its time the Government and Local Councils stopped scape-goating STL owners and driving a culture of hate against them. • stimulate the economy to generate jobs and ultimately tax to pay for our priorities rather than ‘control’ (2) • Self-catering offers a different option to hotels often more suitable for people with disabilities and longer stays. • Reduction in availability of hotel accommodation due to migrant boats There are no hotels for asylum seekers in the proposed Control Area • Information provided is insufficient to make decisions. • Assessment of housing need is required You need to provide a view of.. 1. Total housing stock 2. % housing stock residential 3. % housing stock empty 4. % housing stock 2nd homes 5. % housing stock self catering/short term lets Background documents provided this detail. The evidence reports explain the rationale. Background documents to the consultation provided this detail specified in the response.
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22 • If the demand shows more affordable housing needed - stopping short term letting will make very little difference to housing stock availability. Result will be to damage the local economy. The Council completes a Housing Need and Demand Assessment every 5 years – and an abridged version (housing pressure study was updated which informed the proposal and attached to the Consultation) • plans have already been rejected, reintroducing for the “right” outcome undermines public trust. It was the decision of the full Council to proceed with the proposal. • Outside Control Area / Resident/ Undecided (1 comment made) • Additional benefit suggestion- STL Contribution - give permission to STLs on the condition that they make a contribution towards the HRA to help expand affordable housing Currently there is no legal mechanism to do this. Proposed Control Area / Business/ Disagree (no.of similar comments) STL business • Council should have a coherent policy for tourism and housing - which it currently does not, resulting in contradictory planning consents to the aim of providing more affordable homes. Planning decisions are based on a suite of policies outlined in NPP4, LDP 2 and non-statutory STL planning guidance. The proposal will provide more opportunities for development to be guided by these policies and aim for a balance between competing uses. • Obstructive, senseless initiatives. Creating chaos, extra red tape, unfair bias, de facto stealth taxes, micromanagement, and destruction to local, small tourism businesses. The proposal is not a ban on new STL lets, but individual impact on the availability of homes and short-term lets can
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23 SUPPORT your local residents who work hard to uphold and continue the fantastic and VITAL tourist trade by providing short term lets. both be considered for the economic and community benefits. The Council has a programme to support the building of affordable homes in the proposal area. There are many barriers to building new homes. The policy is intended to support the availability within existing stock and any future stock. PKC supports the conversion of empty homes back into use for residential use through the Empty Homes Initiative. Conversion of empty/derelict properties is supported by the non-statutory guidance that guides decisions on STLs. In this way STLs can play a part in the restoration of these properties back into use. • This consultation to address the lack of affordable homes is misguided. It’s lazy scapegoating to target short-term-lets. Holiday lets are not the issue • The lack of new affordable homes being built is the issue • no tangible action plans to reinstate the significantly high number of empty and derelict properties into homes these hugely imperative solutions must be brought into this consultation to ensure a comprehensive review is being undertaken to establish a credible strategy to create affordable homes. • It has become difficult over the last few years to operate a self-catering business and to do "our bit" to help the tourist industry within P&K. Pressures include:- • STL licencing requirements (cost and effort); rising energy costs; rising cost of living. The market won't bear these costs being fully passed-on to the customer. Noted. The proposal will not impact the costs of existing lawfully operating STLs as the proposal is not retrospective. It would only apply to new STLs. • The proposal is not well targeted, evidenced, and risks doing harm without solving the issues it is supposed to address. • Dunkeld & Birnam is not equivalent to remote Highland Perthshire. The data being used doesn’t reflect how our local housing market actually works. • D&B is 10-15 mins from Perth, on rail line, our local workforce and housing market are tied into a much bigger area. The evidence reports explain the rationale - Background documents to the consultation provide this detail. Analysis of house sales conducted to Scottish Government standard, indicates that Dunkeld and Birnam are part of the Highland Housing Market area.
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24 • No evidence PH8 is running out of housing land • Council’s Housing Land Audit state issue is delivery, not land supply. Pipeline of housing in the wider Perth and Highland areas that local people can and do access • Misleading to suggest that STLs are blocking new homes when the Council identifies economic conditions, construction costs and slow build-out rates as the primary constraints. • Reported planning stats suggests existing system is largely working, since 2021,153 STL planning applications relating to STLs in proposed Control Area — fewer than 38 per year. • This planning activity does not suggest widespread or rapid conversion of houses requiring intervention; indicates existing planning framework is generally effective • The reported growth in licence numbers appears to coincide with the bedding-in of the licensing scheme itself, not a sudden surge in new conversions of residential housing. • Licence numbers and growth figures are being presented without sufficient context i.e. a licence does not equate to the loss of a family home. • all kinds of tourist accommodation have been lumped together, (yurts etc, purpose-built lodges, timeshares, home- sharing in someone’s spare room, and very large houses that were never realistic family homes). Giving the impression that “lots of homes” have been converted to STLs that actually have, so headline exaggerates the scale of the problem. The current local development plan has almost no allocated housing land in PH8. The proposal would allow the best use of existing residential housing to be considered in STL applications, in an area of limited potential for new housing. There are many barriers to building new homes, particularly in the current economic climate. The policy is intended to support the future availability of residential homes. Planning permission is currently only required for a small number of the STL new licence applications granted. The proposed control area will extend this to all STLs so that the number of homes, economic benefits, amenity and other planning considerations can be assessed. The introduction of the Licensing scheme has been taken into account where possible Our reports are clear that the figures include the total number of secondary STLs. The way the data is collected makes it difficult to identify the number of homes changed to STLs historically. The figures therefore do reflect where tourism accommodation prevalence is relatively high and also an important contributor to the economy. The proposal is not a blanket ban on STLs but a requirement for more new STLs to require planning permission. Decisions on planning applications will be made on the individual context of the STLs. Current prevalence of STLs in D&B (PH8) is 10%.
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25 • No clear definition of a “tipping point”/proof we’re close to one • Without that clarity, the proposal feels more like a reaction to general concern than a targeted response to a demonstrated problem • No evidence restricting future STLs in PH8 would improve recruitment or produce housing in any measurable way. • STL use provides a market for flats that aren’t sold or make it into the rental market. • STLs lets play a key role in Tourism economy of D&B • STLs offer to a wider range of visitors than hotels can • STLs creates, local work, especially important for women, carers with flexible hours • Local staffing pressures are national issues, not STL-driven, even in places with almost no holiday accommodation. Causes:- ageing population, low pay in key sectors, shortages across health and social care, and changing working patterns. • more effective, less disruptive alternatives:- • stronger action on second homes, • bringing empty houses back into use, This will give the council the opportunity to consider all planning matters as well as the prevalence of all tourism accommodation in the area of the application where currently there is very little opportunity for the council to do this. The local community and development trust has been asking the Council to address housing pressure and the role of STLs in the PH8 and evidenced in the recent CAP. Engagement of this kind with several communities within the proposed Control Area led directly to the research and consideration of introducing a STL Control area. The proposal intends to support the number of options in the residential market where relevant. Small numbers can make a difference in rural communities enabling services to continue eg. Retained fire service. Where these issues are housing-related PKC can use the tools at its disposal to mitigate some of the contributing factors. This proposal is one of tool of several aimed at improving the availability of residential homes. The council is addressing second home ownership through the increased Council Tax Supplement for second homes.
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26 • helping developers deliver on existing allocated sites, community-led housing, • targeted rules for specific streets or areas where there is a genuine issue. These measures feel more focused and constructive than a blanket control zone. • A control area will push more decisions into political territory, so decisions will be inconsistent and driven by local pressure/politics more than by evidence. • What may be lost if legislation becomes too restrictive: the occupation of a large historic house, renovation of annexes, (some derelict), into long-term let and STLs • Short-term letting allowed our family, to return to the area, care for family members, make, a viable living and contribute to the local community. • Concerned that if the regulatory environment becomes overly restrictive, future owners may be discouraged from taking on derelict or challenging buildings, and the kinds of opportunities that allowed us to return home and invest locally may no longer be possible. • We strongly believe in finding a balance between housing and tourism, but we feel the current proposal does not get that balance right. • We ask the Council to withdraw or rethink the proposal, or to postpone it until proper, PH8-specific evidence is gathered and alternatives have been explored. • We all want a thriving, sustainable community; however, this proposal, feels more likely to undermine than protect it. PKC supports the conversion of empty homes back into use for residential use through the Empty Homes Initiative. PKC is supporting the Dunkeld and Birnam Development Trust to identify potential sites for Community Led Housing The proposal is not a blanket ban on STLs. It will require more STLs to obtain planning permission, whereby a decision will be guided by planning policies, and based on the individual circumstances of the application. Conversion of empty properties is considered by the non- statutory guidance that guides decisions on STLs. In this way STLs are recognised in playing a positive part in the restoration of these properties back into use. It may be the case planning permission is required for the type of project highlighted, in which case the proposal is unlikely to have additional impact The policy intends to provide a mechanism to help balance competing needs for use property for economic and community benefit.
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27 • many rural STLs are used as an income stream from tourism - so important for enabling people to continue to live in rural areas with limited job opportunities. The proposal is not a ban on new STL lets but individual impact on availability of homes and short-term lets can both be considered for the economic and community benefits. • Other business Our experience is • 40% downturn in tourism trade this summer • Lots of property for sale but market is dead. • Long term rental is not financially viable due to recent increase in regulation protecting tenants. There is no economic confidence in the property market or anything at the moment Noted The evidence shows that across the proposed STL Control Area, that there is increasing pressure on housing availability and affordability • The Cairngorms National Park attracts tourism to the region • Availability of short-term lets boosts the local economy by generating jobs in management of the lets and trade to pubs, restaurants and shops. • This boost is not achieved where STLs are not available or where visitors opt for the use of camper vans and wild camping. • Control area will reduce the availability STLs that support the local economy. The proposal is not a ban on new STL lets but individual impact on availability of homes and short-term lets can both be considered for the economic and community benefits.
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28 • STL's are not a driver of Scotland's housing crisis • P&K planning has led to Kenmore community to be destroyed by allowing 4 large Self-catering businesses without ensuring the owners built much needed accommodation for workers, and residents • It is now a designated holiday village with Taymouth Castle and Taymarina and has led to a lack of housing for residential use. • Cost of market housing (sale and rent) is prohibitive to local wage levels • STLs have a role in supporting rural incomes and retirement Plans after tied-accommodation and are a traditional solution. • STL's should be recognised as part of the solution to building resilient, balanced and sustainable communities. • Concentrations of holiday villages should be severely restricted as it has been shown the dispersal of STL's throughout a place gives better balance to the housing diversification and maintains the community Noted Recent affordability analysis indicates that house prices in the proposed Control Area have been continuing to grow significantly over the last 5 years. The proposal is not a ban on new STL lets but individual impact on availability of homes and short-term lets can both be considered for economic and community benefit Control area /Business / ‘Agree’ (no.of similar comments) STL business • Stop the proliferation of new lodges and purpose-built holiday lets • Must not be applied retrospectively. • Unnecessary paperwork and cost to an already too busy Planning Department. The proposed legislation cannot be applied retrospectively to lawfully operating STLs • There are very few homes to let or buy for residential purposes-If you buy somewhere with outbuildings to convert,
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29 or to have pods, proposing to live there yourself, I'd be in favour - brings increase in overall consuming population without losing a full-time resident/family and contributor to the community. These examples currently require planning permission and are considered on an individual basis in line with planning policy. The proposal would bring further types of STL into this individualised consideration. • Figures are mis-leading-STLs are a tiny minority of households • Competing demands are not straightforward: incoming retirees, remote working from home, second homes, other tourism accommodation they are all interdependent and contribute to Highland Ps economy. • Vocal lobby wanting affordable housing in an area they can afford to live in including those with no vested interest (eg. Taymouth Castle lobby) • Some STLs aren’t suitable for permanent housing and are premium priced as they represent an ideal. Same for newbuilds and period homes • Controlling STLs won’t improve affordability; issue is new social rent is not being built whilst sprawling purpose built holiday villages don’t provide permanent housing • The missed Tay Forest Park may have done this • Self-catering is where the most spending per capita occurs • The challenge is to encourage this type of tourism which protecting natural assets. • Managing numbers and standards is a part of this. STL Licences and Control Area are supported because of that • Providing affordable accommodation for local people is essentially a separate issue. Prevalence of STLs varies. As outlined in the evidence, the numbers are considered to be significant enough for a STL Control Area to be proposed to better balance the use of residential housing for the benefit of local communities. The competing demands on residential can be considered on an individual basis via a planning application. The proposal will bring more instances where this individualised decision can be made to assist a better balance in for sustainable communities.
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30 Not in Control Area/ Business/ ‘Disagree’ (no.of similar comments) • Pressures on us include, STL licencing requirements (cost and effort); rising energy costs; rising cost of living which means that the market won't bear these costs being fully passed-on. The proposal does not apply to existing lawfully operating STLs. The viability of new STLs may have to reach higher tests before being converted from residential use. The proposal aims to help balance competing demands for residential property. • Lack of Evidence and Transparency • Small fraction of the total housing stock used for STLs in Perth & Kinross - 1.7% • whilst double (3.5%) of homes sit empty The supporting papers detailed the evidence including the Housing Pressure study. Whilst the figures quoted by the respondent were correct at the time, they refer to the whole of PKC. As the supporting evidence report indicated, Empty homes in the proposed control area were fewer than the number of STLs. • Jan 2024-Empty properties in proposed control area = 6% • Jan 2024-Second homes in proposed control area = 9% • Jan 2024-STLs in proposed control area = 9% Council’s initiatives have led to reductions in both empty properties and second homes within the control area:- • Apr 2026-Empty Properties in proposed control area = 3% • Apr 2026-Second homes= in proposed control area = 8% • Apr 2026- STLs in proposed control area = 930 = 13% The evidence has been completed at the sub-PKC level, enabling the identification of geographic areas where the prevalence of short-term lets is having a more significant impact. As concluded in the supporting report, in these locations, STLs were significantly higher than the 1.7% quoted i.e Highland HMA (9%) and north-Eastern HMA (13%). These areas are included in the proposed control
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31 • In Dunkeld & Birnam, Council’s figures overstated STL prevalence — claiming 15% when actual figure is 5.7%. • These discrepancies raise serious questions about the accuracy and transparency of the data underpinning the proposal. Before any PCA is considered, the Council must explain: • Why it is pursuing a policy that has already been rejected twice. • What new evidence has emerged to justify this renewed attempt. • How a PCA would realistically deliver additional housing supply, given the minimal proportion of homes involved. • Self-catering tourism contributes £52 million annually to the local economy and supports hundreds of microbusinesses across Perth & Kinross. • STLs play a vital role in rural and seasonal tourism, offering flexible accommodation and supporting local jobs. • Disproportionate regulation risks harming small businesses and undermining the region’s visitor economy. • Constructive Alternatives • Rather than targeting responsible operators, the Council should focus on: • Bringing empty homes and underused second homes back into use. • Accelerating affordable housebuilding, especially in rural areas where housing pressures are most acute. • Fostering collaboration between the housing and tourism sectors to develop balanced, community-led solutions. area. Areas with less impact are not included in the proposal. The figure quoted for Dunkeld & Birnam is not correct. See response on p.38 for more detail. The Scottish Government introduced regulation to improve standards via the STL licensing scheme. Perth and Kinross Full Council wanted to regulate the expansion of STLs and therefore considered and approved the proposal for STL CA The role of STLs to the local economy is fully acknowledged and the proposal is not to ban new STLs but to consider competing use of residential property and amenity impacts. PKC supports the conversion of empty homes back into use for residential use through the Empty Homes Initiative. Empty homes are one consideration in the STL non- statutory planning guidance. As well as purchasing homes to secure some affordable supply in Dunkeld, the Council has a programme to support the building of affordable homes in the proposal area. There are many barriers to building new homes. The policy is intended to support the availability within existing stock and
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32 • This response is not a rejection of regulation — it is a call for proportionate, evidence-based policy. • Members of the community support fair oversight of short- term lets but oppose blanket controls that lack justification and risk unintended harm. • We urge the Council to work constructively with residents, businesses, and stakeholders to develop solutions that protect housing supply while sustaining the local economy. any future stock. PKC supports local development trusts to develop community led housing Regulation requires deeper justification for prospective STL business owners to provide a better balance of land use in communities. The Council believes the proposal is proportionate response to the circumstances. Control Area / Business / ‘undecided’ • Farmers need scale to achieve economic success so does holiday letting. Some operations need to scale up and this could be thwarted by excess letting by distant neighbours. Noted • Unsure of what the control zone will add. At present with the short term let licensing there is a much better balance than previously. • the problem in the area is not the concentration of STLs but the lack of affordable housing. The proposal will extend the requirement for planning permission to more properties allowing the balance to be considered more effectively In locations where housing supply is constrained due to a number of factors as evidenced, managing numbers of STL can be supportive of a better balance • The facts you have presented (number or short term lets and growth rate by area) are presented with NO context. You haven't included the number of available dwelling houses/flats etc, what % STLs represent of those, and what's the growth rate of those are (eg: new builds for dwelling). • How do the figures and % of STL figures compare with other regions, national averages etc. A more comprehensive The supporting documents in the consultation provided this context. At the time of the decision, Scottish Government figures indicated that Perth and Kinross has the 4th highest numbers of STLs in Scotland and the third highest concentration.
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33 review is required in order for me to understand the situation, and to give a view. Organisation / ‘Agree’ (no.of similar comments) The need for affordable housing well known and STL accommodation puts further pressure on the system (2) Lack of housing is the No.1 priority issue in Highland Perthshire, and especially in the area around Aberfeldy. It is a genuine issue, and the scale is much wider than many people appreciate. It denies opportunities to live here for young people, and local services and businesses shop workers. Unaddressed, this will threaten the very fabric of this community. Arguably, it has been doing this already for several years, and certainly since lock down in 2020. Control of short term lets is one part of the equation for dealing with this. Aberfeldy Community Council Noted Several community surveys to support the Community Action Plan between 2022 and 2025, representing 1200 households and 26 businesses. STL Control Area • was the number two priority of the community Housing Community Action Plan Noted
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34 • the biggest single issue (56%) was the lack of affordable homes to buy or let, for people who work or want to work here. • the lack of control on 2nd homes and STLs - 23% of respondents stating there were too many 2nd homes/holiday lets. Affordability Lower than average wages and higher than average house prices. • Ave house prices Aberfeldy: (2025/6) £334,775. • Higher than P&K average if £253,910 • 36% of the community are earning less than £25,000 a year • Survey based demand for social housing= 4 times the level of supply, never mind its availability. • 40% had one or more children • 45% would like to set up a business in the area if they were able to move into it. • Rannoch & Aberfeldy has one of the highest percentages of second houses/holiday lets to permanent homes, at 23% (11th) in Scotland. • highest concentration in the UK of Airbnb whole-property listings with 36 listed per 100 properties, so 36% (Guardian newspaper) “This choking of supply in the face of the demand that the Housing Needs Survey shows is undoubtedly one of the underlying causes of the unaffordability of local housing.” • Nearly 70 % of respondents have tried to find housing in the area already but failed • 203 households stated that they may need housing within Noted
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35 the next 5 years: • 87% support the need for more affordable housing Left unmitigated these risks exacerbating demographic changes. • Aberfeldy has a higher proportion of people over 60 (35.6%) than the Scottish average. • with working-age population priced out of the housing market, this issue is likely to intensify. Business – housing affecting business operation & growth • 68% of businesses that have had experienced problems recruiting / retaining staff due to a lack of suitable housing locally and is a frequent and re-occuring problem • Nearly 50% of businesses feel that their staff turnover is impacted by a lack of affordable housing; • A total of 25 employees were identified from the survey that require housing in the area; • With nearly 70% of businesses hoping to expand in the future, a lack of workers locally and lack of affordable housing were identified as the two most limiting factors to business growth. Accommodation for visitors is important, however, this should be balanced with the housing needs of local communities. Aberfeldy Development Trust strongly support the introduction of Perth and Kinross Council's proposed short term let planning control area. Noted
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36 Organisation control area ‘disagree’ On behalf of clients' who own and operate holiday lets in rural locations where issues around neighbour amenity and privacy are not triggered- the STL control area should not apply to outside settlements. Current planning regulations are adequate for these areas The proposal will allow all planning considerations to be made on an individual basis. The context of each application will be considered. The loss of residential dwellings can still be relevant in remote rural locations. No demonstrable link that restricting STLs will deliver the affordable housing that local communities need. Risks damaging vital part of local economy and businesses and jobs that depend on visitor spending STLs are not the cause of housing scarcity but are being treated as such. Narrative ignores larger structural issues: • a lack of new supply, • demographic shifts, • poor delivery of affordable homes. The proposed Control Area does not address, • empty • second homes. Policy likely to displace properties into • second home ownership See response on page 25. As some residential homes are being used for STLs they are by definition a part of the housing demand and supply. The intention of the proposal is to facilitate more options in the residential market, where needed. This is especially important for local purchasers whose buying capacity is up to £80k less than purchasers from outside the local housing market. Decisions on planning applications could increase the supply of homes. Even small numbers can make a large impact in rural communities. The challenges of increasing supply are acknowledged, and the proposal aims to support supply by considering the individual circumstances of each application in the context of competing demands. The proposed STL Control Area cannot not directly address second and empty homes. Other tools are used to do this. The non-statutory planning guidance highlights conversion of empty properties into STLs for consideration. The council is addressing second home ownership through the Council Tax Supplement for second homes. Since its
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37 • long-term vacancy. BiGGAR Economics demonstrated, • only 1.7% of properties are STLs, compared to • 3.5% empty across Perth and Kinross. In Dunkeld and Birnam, Council data wrongly claimed • 15% STL saturation, • when actual self-catering units account for just 5.7%, which was a fundamental misrepresentation. • It is critical to differentiate between self-catering units and second homes, with the latter generating no economic benefit. The Council must be cognisant of the legal risk re. Judicial Review of Edinburgh’s Planning Control Area, ruled • parts of the policy “unfair and illogical.” • Retrospective application of planning powers under Section 26B of the Act - unlawful. introduction in April 2024, there has been the move of some second homes into STLs. See response on p.31 The figure quoted by the respondent for Dunkeld & Birnam is not correct. The 2023 report published proxy data for STLs in the PH8 Dunkeld area as • Self-catering =5.7% • Second homes = 5.2% The true STLs figure would be sourced from both of these figures making a maximum of 10.9%. (15.6% was the proxy estimate of potential STLs for the proposed Control Area of which Dunkeld and Birnam included). The report included all of the figures above. The evidence has since been updated by data from the STL licence register which is more accurate than the proxy data and the figures quoted by the respondent are now out-of- date. The decision to establish a control area were made on the figures from the licence register. At the time of the decision to introduce a STL control area in May 2025 the prevalence of STLs in the PH8 postcode was 10% The Council is cognisant of the outcome of the Judicial Review referred to in the response and understands the powers cannot be applied retrospectively to existing lawfully operating STLs.
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38 Perth and Kinross Council risks the cost to the public purse if a challenge is similarly pursued. Finally, there is no evidence this approach actually works. • The Highland Council introduced a PCA in Badenoch and Strathspey March 2024, resulting in over 200 planning applications, confusion and huge expense to the sector. • There is zero evidence that it has delivered a single additional home. Had either City of Edinburgh Council or The Highland Council’s respective control areas met their policy intentions, we would have expected this to have informed the evidence base for this consultation. Association of Scottish Self-Caterers (ASSC) Highland Council have refused 43 STL planning applications change of use in Badenoch and Strathspey with 2 later granted on appeal. In the Perth and Kinross rural context, the retention of small numbers of residential homes can make a large impact on the maintenance of essential services such as retained fire services etc. The scale of this type of positive impact can be difficult to measure. The Council has deemed the response to be proportionate to the evidence to establish a STL Control Area to balance competing uses for residential property.