Democracy Spraffa

Item 3 Appendix 3 - Licensing of Short-term Lets - Review of Temporary Exemptions Policy

West Dunbartonshire Council · 24 September 2025
Back to Licensing Committee — 24 September 2025 and its agenda

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Appendix 3
Responses from licence holders
Response one 
Thanks for your email.
Here’s my perspective:
I believe it’s important to ensure there is sufficient short-term let (STL)
accommodation available for guests during peak periods. The temporary licensing
scheme is a positive step in this regard. However, it might be beneficial to require
that operators have some prior experience—ideally, at least one year of
managing short-term lets themselves. This doesn’t necessarily mean using a
management company but having direct operational experience.
Kind regards, 
Response two
Dear Michael,
With respect, I think that a consultation on further legislation is a bit farcical when the
current legislation for STL is not fit for purpose.  Furthermore, The DAB Valuation
Board computer (which implements a large part of this system, the Council Tax/NDR
values) system has been 'migrating' for the last 7 months - instead of thinking up
how more red tape can be weaponised to punish the people of this district who seem
to be trying their best, whilst being shut down at every opportunity, maybe it would be
best to turn your attentions to getting your 'house in order' so that the current system
the Scottish Government are trying to implement actually does what it is supposed
to. 
As for your original question, an exemption should be just that, if it comes with
conditions, then it isn't really an exemption. 
Yours Sincerely, 
Response from Building Standards
The Building Standards service advised that it “would have concerns particularly if
non-domestic properties that had not been assessed as suitable for sleeping
accommodation were to be used in this way. The main concern would be matters
relating to fire (escape, travel distances, early warning, lighting etc) and suitable
provision (showers or similar). Non-domestic applications are assessed depending
upon their final use, whilst domestic applications are assessed depending upon their

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final use, they are always assessed as though people are living and sleeping in
them.” 
Response from Fire and Rescue Scotland
The Scottish Fire and Rescue Service wrote that “[t]he decision to grant a licence
does of course lie entirely with the council. However whether a licence is granted or
exempted, [the Scottish Fire and Rescue Service’s] stance is that it is still a relevant
premises and would fall under all the appropriate benchmark standards. By not
having a licence, it would probably engage the need for a written FRA  unless the
undertaking hits any of the other triggers for written FRA requirement.”