 Good morning and welcome to the 14th meeting of the Local Government, Housing and Planning Committee in 2021. I would like to ask all members and witnesses to ensure their mobile phones are on silent and all other notifications are turned off during the meeting. Our first item this morning is consideration of whether to take item 4 in private. Item 4 will be an opportunity for members to reflect on the evidence that they have heard earlier in the meeting on short-term lets. Do members agree to take item 4 in private? That is all agreed. The second item on our agenda today is to take evidence as part of the committee's work on short-term lets. This will be the first of three evidence panels over the next three weeks. Today's meeting the committee will hear from organisations opposed to the approach taken by the Scottish Government to the regulation of short-term lets. I would like to welcome to the committee Fiona Campbell, who is the chief executive of the Association of Scotland's self-caterers, David Weston, the chair of the Scottish Bed and Breakfast Association, Amanda Couples, general manager for Northern Europe, Air B&B, and Sho McPanda, director general of the UK Short-Term Accommodation Association. Thank you for joining us today. We had also hoped to hear from Highland Council this morning too, but unfortunately they were unable to field anyone today. We'll move straight to questions. Witnesses, if you wish to respond or contribute to this discussion, please add an R to the chat box to indicate this. I would like to add that we will try to direct our questions to specific people. Just in the interest of time, if you can come in, if you feel like a perspective you want to get across has not been already raised, that would be very good. Thank you. I will take the first question. Many tourism and hospitality businesses, such as taxis, pubs, restaurants and coach operators, are subject to licensing regimes for the benefit of both users and communities. Can you explain why you think short-term lets should be exempt from licensing? I would love to hear from Amanda and then David. Thank you for the opportunity to be here today. I think we would start by saying not that we are opposed to regulation, it's that we are specifically opposed to licensing. The reason that we are opposed as Airbnb on behalf of our hosts is fundamentally that we believe the licensing system as tabled is disproportionate and an overly burdensome given the nature, the level of activity that hosts on Airbnb Scotland carry out. Just to give you a snapshot of the host community on Airbnb in Scotland, around 83 per cent of hosts in Scotland on Airbnb host one listing only and they on average host for less than four nights per calendar month. This is not a highly professionalised megacorp conglomerate of hosts. These are ordinary, everyday Scottish people who use the income from hosting on Airbnb as an economic lifeline. Many of those hosts rent a space in their own house. This is their primary residence. Licensing and forcing them to comply with licensing would effectively make their primary residence a licensed premise. We think that's inappropriate. We also believe that and we see this when we go around the country and talk to hosts. It's simply too burdensome, too expensive and many hosts will simply withdraw their properties both from the short-term letting market but also the long-term letting market. There are no winners in this. The tourism industry doesn't benefit, the housing industry doesn't benefit and most of all we have removed the ability of these hard-working everyday Scottish people, many of whom live in rural communities where tourism is an absolutely vital part of economic empowerment of the region. We have removed their ability to be able to support themselves. Almost 40 per cent of hosts on Airbnb do use the income from hosting to cover their monthly household expenses. As I said, we're not against regulation per se. We've been very proactive in calling for registration systems. We believe that they are a necessary part of short-term letting regulation. We believe that they're proportionate, they get the job done and they give regulators and local authorities the tools they need to make decisions on short-term regulation but this licensing system is not it from our perspective. Okay, thank you for that and can we hear from David and also just to say that we do have time but try to keep your answers to the point. Thank you. Yes, I'd echo a lot of what the previous speaker said and emphasize that B&Bs are very small businesses, micro businesses. 77 per cent of our members have between one and six letting bedrooms. They're very small businesses. Just to give you an example, a typical three-bedroom B&B at the average occupancy rate in 2019, which is 50 per cent, charging £65 a room. We'll have total gross turnover of 35,600 a year. That's not income, that's gross turnover. All the costs have got to come off that and that usually represents livelihood for two people. So we're talking about very small businesses. The question asked about shouldn't what's wrong with licensing if they're licensing in other areas. I think in some other areas licensing is there from historical reasons it might not necessarily always be the thought appropriate if it was starting now. I think the key thing in our sector is to look at the facts in our actual sector and to see if licensing is appropriate. As with the previous speaker, the Scottish Bend Breakfast Association and our colleagues at the UK Association have long said that we would be in favour of levelling the playing field, in other words, having more regulation on our sector to protect guests in the same way wherever they're staying in tourism accommodation. We think that that can be achieved as it is in many countries in the world by a registration scheme, a low-cost or no-cost light-touch registration scheme. There are many examples. Portugal has one, which is a simple online registration scheme. That is what we and other colleagues proposed at the working group to overlay on the licensing scheme or registration scheme, which would be a way that we think of making it less onerous on very tiny businesses and achieving what the Scottish Government wants to achieve, which is the minimum health and safety requirements that are complied with by all tourism accommodation, which we fully support as name. However, we think that the way that is being proposed at the moment with the licensing scheme is unduly onerous and costly. Thank you, David, and I believe Fiona would like to come in. Thanks very much and thank you very much indeed for giving us the opportunity to give evidence today. I absolutely concur with Amanda and David. What really needs to be remembered here is that professional operators are already regulated, so the mandatory conditions of the licensing scheme are essentially duplication and therefore we would suggest unnecessary. The Association for Scotland's Self-Catruses is not anti-regulation, but we are absolutely against disproportionate regulation that is going to risk jobs and damage Scottish tourism. We have constructively engaged with the Scottish Government for years and, in 2017, actively encouraged an Astra registration scheme in order to make sure that all accommodation providers do indeed meet the existing regulations to do with health and safety. We also have to remember that, since the rationale behind introducing licenses is apparently compliant with basic health and safety, why are hotels, service accommodations and so on and so forth exempt? Although they are licensed, they are licensed to serve alcohol, not on the basis of health and safety. We desperately want to get the regulatory framework in place right that works for everybody and gives a balance between tourism, business and local communities. Notification and registration are so much better and have proved to be so much better across the globe than licensing, which is an authorisation scheme. We had to look at the licensing scheme and ask whether it is really underpinned by necessity, justification, proportionality and non-discrimination. My answer to that would unfortunately be no, it is not. Thank you very much for the opportunity to speak to you today. I would like to concur also with what the previous speakers have said. We are absolutely pro-regulations, sensible and proportionate regulation for the sector. I think that this is about trying to make sure that we come up with something proportionate, justified and necessary. Just in addition to what the previous speakers have said about the proposed regulation being too onerous and too costly with the potential effect of freezing out a number of different hosts and small businesses from the sector, I would like to mention a couple of other issues with the licensing. First, it is too restrictive in the sense that the licensing scheme assumes that it would close the market and open up the opportunity to certain individuals or businesses that wish to do that afterwards. A much more proportionate way of doing it would be to keep the market open and to restrict it when necessary if there is evidence of a particular problem that we believe is a much more sensible and proportionate way of doing things. I would also like to raise the issue of regulatory fragmentation. The powers that are given to local authorities here to overlay the licensing conditions with its own rules and regulations means that essentially all local authorities could come up with a separate regime for regulating short lets, which makes it very difficult for professional operators to work at scale. It is also very difficult for newcomers to understand what the rules are and to comply with the standards from one authority to the next. There is a very basic question here. Why should safety standards be different in Edinburgh versus safety standards in the Highlands? Surely they should be the same and it would get rid of a whole load of complexity if we could have one regime here for the whole of the country. Lastly, I would like to add that it creates a lot of uncertainty for businesses in the sense that local authorities can determine a length of a licence after the initial three-year period and there is no automatic renewal process. That means that it is very hard to plan because you do not know how long you will get a licence for in the future and it will starve investment into the sector because it allows those who want to invest in keeping up good properties and making sure that the property stock is fit for tourists to come to Scotland will be disinvented and disincentivised from doing so. I think that there are a number of problems with the legislation. I agree that registration is a much more sensible way of doing that with some additional conditions around health and safety, perhaps through accreditation, which I am happy to talk to. The consequences of that is that how small businesses will drop out of the sector, the Scottish economy will suffer because jobs will go and tourism accommodation stock will also change in the sense that the variety will go. That is not good for the environment because you will have to build new hotel stock instead if you are going to freeze those types of properties from being able to let out. We think that there are distortions that will come from that which need to be considered. Thank you very much for sharing your perspective there. Concerns have been raised about uncertainty and the associated impact on future bookings caused by the need to obtain and renew a short-term license, which some of you have already expressed. What is the source of those concerns? Do you have any evidence of significant business disruptions caused by license renewal in other licensed industries? Perhaps we could hear from Fiona and then Shomak on that. I am so sorry, we lost sound at the beginning of that. Would you be able to repeat the first part of that question? We are used to the tech thing, don't worry. We need to never be sorry in the technical realm because there are always these tech glitches. Concerns have been raised about uncertainty and the associated impact on future bookings caused by the need to obtain and renew a short-term license, which some of you have already expressed. What is the source of those concerns? Do you have any evidence of significant business disruption caused by license renewal in other licensed industries? Unfortunately, having poured over the complexities and the detail of the proposed licensing legislation, I will happily follow that up with a slightly more detailed explanation in writing post-office event, if that is okay, because it is incredibly complex. The uncertainty is really impossible for small and micro businesses. I have been doing this as a business for 20 years, and I find it hard to understand how the civil servants of produced this licensing legislation feel that they know how we run our businesses better than we do. This comes down to everything from fees, how much is it going to cost, hopefully unnecessarily to take a box to say that we already comply with existing health and safety legislation. Will we get charged more because we accommodate more guests? How are local authorities indeed going to set the fees, given that they have no idea how many premises will need to be licensed? In terms of fees, it is really impossible that any fee that is going to be added to the existing cost of doing business is simply going to be untenable for small businesses, especially in light of the global pandemic, with huge increases in energy prices, services and consumables. We have been given an indicative fee of around £300, £400, but Sola and many local authorities have already contested that fee and are saying that it will be more like £1,500 to £2,000, which will be crippling for small businesses. Then you move on to the uncertainty about how we run the business. How can we accept future bookings when we might have our licence revoked or refused for some reason? Licensing may not even be on a 36-month basis in some local authorities for some reason, but a 36-month basic turnaround for licensing is impossible. Guests simply will not book into the future if there is a possibility that a licence may be revoked or refused. I have been talking to mortgage providers. What happens when our mortgage provider pulls our financial support because of that uncertainty or where a material change has been in circumstance? The breeder refused that that would occur, but they have not spoken to those financial institutions. I have, and they have said that they will actively start looking at whether it is viable to offer mortgages or financial support for our sector. That goes back to what Shomak said. We are going to start having to look at whether we are going to invest in our businesses, because we will not necessarily have that financial support behind us. Of course, you have neighbour objections. What happens if a vexatious neighbour complains about the activity? We have one. I have experienced that. He assaulted me in 2018 because we operate a self-catering property near his house, despite the fact that he has never had any problems associated with that activity. He has a criminal record and I have a PTSD, but I assume that when I apply for a licence for that property, he is going to complain. Will a licence be refused on those grounds? Are we going to lose our business because of Nimbism? We just do not know. There has been a brilliant narrative. Thank you, Fiona. I want to let time for other questions. We have quite a few questions to get through and I also want to hear other perspectives. Shomak, if you have anything new and different to add to what Fiona is saying specifically on what is the source of the concerns and do you have any evidence of significant business disruption caused by licence renewal in other licence industries or a licensing of short-term lets in other countries? Yes, I will try and keep it brief. The concerns are probably twofold. From the operator's perspective, we have said that the fees could well be disproportionately high versus the income received, which will be problematic. It will take a lot of stock out of the market. I would also like to talk about what the impact is on local authorities. If local authorities are having to administer the scheme, there will be large upfront costs around enforcement. It is not clear where the funding will come from and how they will manage to administer the scheme. That brings me to the question that you asked. What experiences have we seen elsewhere, which might be problematic when licensing schemes have been introduced? I can recall the scheme that was brought into Berlin and certain districts in Berlin a few years back. What happens is that local authorities do not bring forward the licence applications and they become de facto bans because it is quite costly to process and they would rather not deal with them. That is a key reason why we do not like licensing, because it gives an opportunity for de facto bans to emerge when most people's right to be able to and businesses' rights to let out their properties. Thank you very much for that. I believe that David would also like to come in on this, and then I will bring Megan Gallagher in with a supplementary question. Yes, thank you. I think that you will find that, if you speak to representatives of other industries, there are such problems in other areas. I cannot speak for that, because we are obviously in our sector. More importantly, other areas of licensing have had many years to bed in and for people to understand them, particularly alcohol licensing issues. Even then problems arise when anything has changed. In this instance, the Scottish Government is imposing all at once a complete industry-wide licensing scheme from scratch. That is a very, very risky thing to do. Those kinds of problems that we have been talking about do not have to be very large in percentage terms to cause a huge problem to the Scottish tourism economy. As the minister, Mr McKee, said the other day, 24 November, at the Scottish Tourism Conference, he said that tourism recovery is critical to the Scottish economy, and I totally agree with that. I will bring in Megan Gallagher in with a question. Thank you, convener, and good morning, panel. Before I ask my question this morning, I would like to refer members to my register of interests, as I am a serving councillor in North Lanarkshire. My question relates to the tourism question that the convener asked just moments ago. My question is that I have heard concerns that the proposed licensing scheme could have a damaging impact as businesses try to recover from the pandemic, with many relying on tourism at home and the tourism industry to give their businesses a boost. I would be interested to hear the panel's concerns regarding the timing of the legislation and any lasting impacts that it could have on businesses across the sector. If I could start with Fiona, please. Thanks very much. Our sector alone, the self-catering sector, represents £867 million to the Scottish economy with 24,000 jobs. We have all gone through a harrowing time, as we all know. It is absolutely essential that policy makers reflect on that and understand that we need to support small businesses and micro-businesses as we come out of the pandemic. We are not even out of survival mode realistically. We need to be able to recover. Unfortunately, the licensing legislation is going to be hugely damaging to the Scottish tourism economy. We really need to reflect on that. We need to support small businesses and micro-businesses. It is people's lives and livelihoods that I represent. It is not their hobby. They are not casual hosts who also rely on their assets to make them as much needed additional money. I represent those people. Thousands and thousands of businesses rely on their income and that is their livelihoods. We need to support those livelihoods as we prepare from the pandemic. And Amanda, I would like to come in on that as well. Thank you very much. I echo a lot of what Fiona said. Most of those messages are equally applicable to the everyday Scottish people who make up the bulk of the hosting community on Airbnb in Scotland. Just to give you a few data points, we have commissioned independent economic research. Hosting on Airbnb delivers around £677 million of gross value added and supports around 33,500 jobs. That same modelling estimates that if those proposals were to be implemented now, around half of those jobs would go away and they would cost the Scottish economy approximately £1 million a day. That is a big deal from an economic point of view. And again, I would emphasise what Fiona said about the impact on ordinary everyday people for whom tourism is not only an economic lifeline but really in some communities the only way they have to actually support themselves. Again, I would point to some of the more rural communities. I speak to a lot of hosts. Many of them tell me stories along the lines of hosting on Airbnb enables me to stay in the village or in the community that I grow up in. It provides employment for families. It supports the village pub staying open. These things will go. That is what our hosts are telling us consistently around Scotland. There is economic impact but there is also people's lives that will be damaged by this. As Fiona said, we are not out of this pandemic yet by any stretch of the imagination. I wish we were. Tourism remains in a very fragile place. From our perspective, we would emphasise the need to, at this particular time, be as supportive of Scottish tourism as ever before. It is our belief that those proposals are not that. Thank you, Amanda. I will now come to questions from Eleanor Wittam. Thank you very much, convener. Good morning to the panel. Before I ask my questions, I refer everyone to my register of interests. I am an existing councillor and an East Ayrshire council. The first question that I have is, what are your views on the changes made to the draft licensing order from the version that was presented to our predecessor committee in February? I would perhaps like to start with Shomak first. Hi there. Thank you very much for the question. Obviously, we are happy that some improvements have been made to the previous version, but I think that our concern is really over the licensing scheme as a whole. Those larger concerns have not been removed. We think that tweaking the scheme and the concessions that have been made are some positive tweaks, but they are just tweaks. We really need a fundamental overhaul of the thought of what is an appropriate system for Scotland at this point, taking into account not just the effects of the pandemic and the impact on businesses at this moment, when they are already beaten down quite significantly in the hospitality sector, but just in the long term, as we think about a regulatory regime that is fit for the 21st century, something that is simple, that is online, that is easy for people to understand, that keeps the market open and restricts it flexibly when necessary. We think that licensing is not the right way forward, and we have an opportunity to rethink that now. That is what we would like to push today. You give it a little bit of extra thought to see whether a more slimline registration scheme would be more appropriate for you to first get the data. That will allow you to get the data in terms of who is doing this, if there are any problems, you will be able to then enforce against them. Once you have the data, you will be able to analyse whether there are any specific problems where you need to legislate further. We think that is the appropriate step at this stage, rather than a licensing scheme that will shut the market off for no good reason. I absolutely concur with what showmates just said. We welcome some of the concessions that are made on 7 October, but when you look at the detail of them, they do not go far enough. Even the overprovision, which was the most welcome withdrawal as part of that statement, when you look into it, it is still in there. There are powers for licensing to allow overprovision, and that is incredibly worrying for operators of bona fide legitimate businesses, as well as casual hosts. We, as a sector, have provided alternative options that truly believe are proportionate, workable and targeted solutions. If they do not work, absolutely let us revisit it in a few years once we have that data. However, we need the data before we can make sensible policy decisions, rather than introducing an incredibly burdensome scheme, which, as people have said before, will have a huge impact on local authorities, who again have been massively hit by the pandemic and simply do not have the resource and have openly said that they do not have the resource to deliver the licensing scheme as proposed. Many thanks. I have another question that I would perhaps like to direct to David. It has been argued that traditional B&B should be exempt from any such licensing scheme. How would that be done in practice, considering that it could create a loophole where the provision of a breakfast might be what somebody could do to avoid the need to obtain a licence? We have always been surprised that traditional B&Bs were included in the scheme, and I think that our surprise was shared by many within Government circles as well, because as everybody seems to agree, traditional B&Bs are not the source of a lot of the problems that the legislation seeks to address. We are already compliant with health and safety legislation, and there are already mechanisms to enforce that on B&Bs. Our view was that the playing field can be levelled, in other words, that the existing legislation applied and enforced to all tourism accommodation by having a simple low-cost registration scheme. We are not specifically saying that B&Bs should simply be excluded from the legislation. What we are saying is that an accommodation registration scheme would be fairer, proportionate and cover everybody, and there would not be those loopholes that you suggest. I would just emphasise, and it has not been much mentioned so far, it has been mentioned by a couple of my fellow panellists, that the importance of having a digital scheme, a simple scheme that works in the digital sphere, because even with B&Bs, the reality of the tourism world is that many bookings are online, many through platforms, even for tiny B&Bs. To have a licensing scheme that works in the real world means that you are going to have something that must be digitally enabled, so that it works on a simple license number or registration number. That has been found to work in practice in many other countries, so I just want to emphasise that point about digital consistency and how the modern tourism economy works, even for B&Bs. I have a couple of questions for you. One is to continue the discussion on the impact on the rural communities and on costs that might come up. What do you think about the impact on the impact on a small rural business in South West Scotland or the Highlands compared to the City of Edinburgh? Do you think that the proposed licensing scheme should be the same? Is it applicable in both locations and circumstances? Maybe David and Amanda could start and offer an answer on that, please. Certainly B&Bs and guest houses are particularly important to the Scottish economy in rural and coastal areas such as Highlands and Islands, because we tend to be the only type of accommodation in some of those areas, and professional self-caterers as well. What I am saying is that there are not big hotels in a lot of those locations, so the tourism accommodation is a small-scale accommodation such as B&Bs, guest houses and professional self-caterers. That is particularly important when you think that the average spend at a B&B for international visitors is £498, for domestic visitors £294, then there is the additional spend as well. That all trickles into that local economy, to the local pub, the local shops, farmers and all the food suppliers, so that is very important for the fragile economies in rural and coastal areas of the country. We have already seen anecdotally comments from members saying that if those things come in, they will give up. There have been surveys that I am sure the committee has seen about numbers of small businesses that say that they may discontinue these things to be introduced. Even the threat of licensing scheme possibly happening over the next two, three or four years will have a depressing effect on the tourism economy, and people who would have started businesses or invested in them may decide not to do so. I guess there will be a disproportionate effect on the rural and coastal economy in Highlands and Islands. I echo a lot of what David has said in terms of what we are hearing from hosts on Airbnb. Our rural hosts tell us consistently that hosting on Airbnb is the way that they make ends meet. It is an economic lifeline for them, and in many of those rural communities, without tourism, the communities themselves simply do not exist. We also need to think about, and of course this is speculation, but it is our view that if we think about the costs of licensing for those hosts who have not given up and taken their properties off the market, it is quite likely that the cost of compliance with licensing will be passed on to the end consumer. Of course that will have the impact of driving up prices and potentially the impact of making Scotland less competitive as a destination versus many of the other options, particularly in those rural communities. This will have a negative effect on the tourism economy. I also just wanted to flag that while I agree with the statement that perhaps in some ways the impact on a licensing system on rural communities versus cities is different. I would not necessarily go so far as to say that one is more important than the other. I would in particular point to Edinburgh and Glasgow through major cities and the role of short-term accommodation in effectively providing a flexible, scalable solution in terms of when those cities host major events. This is not something that the hotel or traditional hospitality industry can easily flex and solve. I point as an example to the music festival called Transmit that happened in Glasgow for the first time this year. 150,000 people turned up, there were no camping facilities and the official accommodation partner was the Hilton Hotel. We know that Glasgow has a capacity of around 15,000 people. In those instances, small short-term letting operators are actually enabling those events to happen in those places and again delivering huge economic benefits to those cities. I would just remind the committee that short-term letting, particularly as we move to a world in which we are increasingly making sure that how we travel and how we invest in infrastructure is sustainable, short-term letting has an important role to play in delivering economic benefits to cities as well as rural areas. I want to ask the second question, convener, on the cost issue that has been raised several times by some of our panelists. The information that we have in front of us is an indicative suggested cost of between £200 and £400 for a three-year licence. Fiona, during your contribution, you indicated that it could, in fact, be much higher. If we start at the figures that we have in front of us, that would work out at roughly £1.30 to £2.60 per week, if we believe those figures. Could you share with us your thoughts on why you think those figures would be much, much higher than that and what discussions have you had, if any, with the local authorities who would have the discretion, as I understand it, to introduce the actual fee? Thanks so much. If you are looking at those indicative figures as the correct figures, then that is really not something to be particularly concerned with. The problem is that, from everybody that we have spoken to, from representatives from Solar to also the many local authorities that we have spoken to, they suggest that it is going to be much more akin to an HMO licence, which ranges from about £1,500 to £2,000. That is a huge amount for a small microbusiness. It is untenable to add that as an additional cost of doing business, but it is unnecessary for businesses that are already regulated and already covered by health and safety legislation. We already have huge costs associated with complying with that existing legislation, so the cost of licence seems to be an unnecessary expense. I think that what we are concerned about is the uncertainty. As we understand it, that indicative fee is based on the number of 32,000 Airbnb listings in 2019, and that is divided by the example that is made of a two-bedroom property, a two-bedroom tenement flat, for example in Edinburgh, as we understand it. If that is going to be scaled up, depending on the size of the activity and the type of short-term let, we have no idea what that will look like. How much is a five-bedroom house in Argyll and Bute going to be charged compared to that two-bedroom property in Edinburgh? We just do not know that that is the problem. The fact that Solar and local authorities are refuting that it is ever going to be possible to deliver the scheme on that lower fee, we have to be concerned that the breeder has simply not got it right. As I mentioned before, local authorities will find it incredibly difficult to know what fee to set if they have no idea how many numbers of premises are going to have to be licensed. They will also have no idea how many members of staff they are going to need to deliver that licensing scheme. It is really hard for them to front-load that expenditure and divide that by the number to get the appropriate fee. The uncertainty is more damaging and dangerous than perhaps anything else, but it is important that we get to the bottom of those fee levels before we start thinking that that is in any way a sensible option. You compare that to registration for private landlords, which is £82 for a register. Thank you for that, Fiona. Are there any other contributions from David, Amanda and Shomick on the licensing fee issue that Fiona has not already shared? Yes, thank you. I echo what Fiona just said and also say that you mentioned that local authorities would have discretion. As I understand it, they would have been mandated by law to have full cost recovery on their costs, so they would, quite understandably, in the financial situation, have to look at the cost of administering the scheme and make sure that that is fully charged across the tiny micro-businesses that are going to be licensed. Our fear is that that full cost recovery model would make the license fees very disproportionate to micro-businesses and more like the other fees in other areas, HMOs and things that have been mentioned. Also, the other issue is inconsistency and unfairness. Why would it be fair that a two-bedroom B&B in one local authority area may pay hundreds of pounds differently than a two-bedroom B&B in another local authority area? I understand how that would happen if those proposals were implemented, but it would give unfairness and inconsistency, which would not be a factor in a Scotland-wide registration scheme. I concur with both David and Fiona on everything that they have said. I have just had one more point. You mentioned that it is only £1.36 a week, and it sounds very reasonable when you put it that way, but it is the nature of the front loading here, the one-off cost at the beginning, which is quite a significant amount. If you consider those who are doing it just for three, four or five or six weeks in a year, maybe when they go away or if they have family in another place or they have a seasonal job and their home is lying empty for a little while, those folks will not make that money back through their profitability to make such a licence worthwhile, so they will simply drop out of the market. So I just wanted to make those use cases available to you so that you could consider those as well. Okay, thank you everybody for your comments. Thank you, Willie. I would just like to come in on a supplementary from Willie just picking up around the kind of rural issues. So the survey responses submitted to this committee raised concerns that the proposed legislation was designed to tackle issues experienced principally in central Edinburgh. Considering this, I'd like to hear your views on how short-term lets and housing demands interact in a rural and island context, and I'd love to hear from David and then Fiona. So specifically around the issue of short-term lets and housing in rural and island context. Do you mean that how it would, how it would disproportionately affect small businesses like B&Bs in those rural areas? What we're hearing is that there are housing challenges and I would just like to hear if you have a perspective on that in rural areas. Yes, well in general, a comment to make is that which nobody's made so far is that yes, there are housing issues in Scotland and in particular in Edinburgh that are very real issues and affordable housing availability and other issues like that. And nobody's denying that those are very real issues. I think some people imagine that the proposals before the committee today would help solve some of those housing issues, but they certainly would not and certainly the existence and business of small B&Bs and whether they should pay licensing fees and have a licensing scheme imposed on them will not in any way alleviate housing issues in any areas of Scotland. Thank you. And Fiona, what are your thoughts on, particularly the rural and the island's housing issue that I'm interested in hearing your thoughts on? Yeah, I think what we really need to be clear about here is this discussion is that licensing deals with health and safety, not housing, as A over provisioned powers have already been removed. Both of the short-term planning control area legislation was already passed in February 2021 as part of the planning act 2019 and that is solely related to the use of the property. The two completely different pieces of legislation dealing with completely different issues and actually neither of those pieces of legislation is in any way going to ameliorate the issue of second homes. A lot of professional self-caterers and indeed B&Bs have come in, people have come in and invested heavily in rural and island areas to properties that wouldn't necessarily be bought by local indigenous folk and made an amazing contribution to that local community. Nonetheless, there's absolutely no empirical data whatsoever, which demonstrates a link between short-term lets and the housing market. Moreover, we know that there are five times as many empty homes in Scotland than there are self-catering units. I think we need to remember that there's two different pieces of legislation here and this piece of licensing legislation we have been told by the Scottish Government numerous times now is about health and safety and not housing. Thank you for that. I'm going to move on with questions from Miles Briggs. Thank you. Good morning to the panel. Thank you for joining us today. A number of you have touched upon the impact that you believe this will have on the sector. I wondered if you could outline to us what sort of numbers you would expect to be leaving the sector if this gets brought forward and whether or not in other countries, for example, a few people have touched upon the scheme in Portugal, how that's impacted as well. I'll maybe start with Fiona and if anyone wants to put an R in the chat, we can bring you in. Thanks very much indeed. Well, it's interesting. We've run a few surveys and we've based it on the existing proposals of the licensing schemes. In 2020, 49 per cent of our professional sector said that they would remove themselves from the sector if this licensing scheme was introduced. That increased in September of 2021 to 55 per cent. That's 55 per cent of £867 million to the Scottish economy that may well withdraw from the sector. That's hugely concerning. If you look at how licensing has impacted on somewhere like Ireland, where they have indeed introduced a licensing and used it as a de facto ban in some city centre areas, that sector has been absolutely decimated because people do not get the licenses. Conversely, if you look at Portugal, which is a very proportionate sector that is best practised across the whole of the EU and possibly the world, that gives people, it gives local authorities the data to enable them to understand the scale of the activity, it ensures the health and safety of the activity and then what they've done is they've introduced licensing in areas of demonstrable link between short-term netting and housing stock. Basically, it enables the activity to continue in a sustainable fashion. I urge the committee to look at those best practised examples. Again, we've given examples of them over the years through our constructive collaboration with the working group and its predecessor, the delivery group. Look at those best practised examples and make Scotland better than those best practised examples. We have the opportunity to be world leading in line with the Scottish tourism outlook 2030 aspiration to be world class in the 21st century. We have evidence that strong licensing has a crippling impact on tourism economies in the world. We have examples of best practice where it enables the sustainable growth of the sector. Amanda, do you want to come in as well? Yes, just very briefly, just to give you the perspective from our patch, very consistent with what Fiona is saying. I gave the data point before that we did some independent economic modelling. At a macro level, the estimation was that putting in those proposals would cost around 17,000 jobs and take about £1 million out of the economy per day. At a host level, we also surveyed hosts on Airbnb and just over half of them, 51 per cent, said they would leave the sector and no longer participate in the short-term letting sector. I also want to just emphasise what Fiona said. At Airbnb, we have a lot of experience working with local authorities and regulators all around the world to implement registration systems. We are happy to share the detail of that in writing post this session. They work, they protect communities, they balance the need of communities to regulate short-term letting with the benefits of tourism. Licensing systems are experiences that they do exactly the opposite and they do critical tourism sectors. We are happy to share best practices and case studies from where we worked with regulations. That would be really helpful, thank you very much. Looking at the impact that the sector is currently facing with the pandemic, we have seen in terms of restrictions but also the number of international tourists for example who are coming to the country. Where do you think the sector currently is in recovering from the pandemic? With those changes, where do you think the sector will be able to potentially adapt to this? Given the timescale, I know a few people have mentioned the fact that the Government has moved and tweaked some things on that, but where do you think the sector would be able to meet the costs and complexity around the compliance that the sector would bring to them? I do not know if anyone specifically wants to come in on that point. Amanda, back to you. On compliance costs, I might defer perhaps to Fiona or I will show it because we obviously only see a slice of the sector, but just to take some thoughts on the tourism recovery and where it would leave Scotland as a whole, there are a couple of points. What I can see very clearly in my day job is that this is a competitive market and the tourism market is a global market. Effectively, by implementing those proposals now, what you are doing is putting a drag on Scotland's ability to win that business back and make no mistake about it. DMOs from countries all around the world are very aggressively going after that international tourist base. That by and large is not quite back to where it was pre-pandemic for lots of obvious reasons. You need only to look at a specific example of that if you look at Ireland, which is at the moment spending a lot of money and sending a lot of delegations to some of those core international markets like the US and really wooing those guests back. I think that taking large amounts of supply and consistently we are hearing around 50 per cent of hosts would no longer put their properties on the market. Taking that supply out at a time when the sector really needs to put its best foot forward, showcase Scotland, enable tourists to actually get to some of those places, particularly rural places, where perhaps hotels and traditional hospitality are not very well equipped either financially in terms of the actual feasibility of building hotels in those places. Removing positive sources of supply and tourism accommodation feels like a real misstep and one that Scotland can ill afford. What is a very delicate time in a recovery that has not happened yet? Thank you for that. I believe David would like to come in on this and then we will move to questions from Paul McClellan, David and then Fiona and then questions from Paul McClellan. Thank you. Yes, and the question is where is the sector at the moment in terms of the route to recovery and where a very, very long way away from full recovery and people talk about two, three, four, even four years for full recovery of our sector. Even in the B&B sector and guesthouse sector across Scotland, there was just under a million visits in 2019 domestic tourism and 0.3 million, 300,000 visits international, but the international has spend was 498 compared with 294 domestic. The percentage, especially in terms of spend of international tourism is very, very significant. Of course, that is almost completely absent at the moment and it is going to take a while to come back and nobody believes that it is going to fully come back next year, let alone in months. We are talking about years for recovery and as a previous speaker has said, a licensing scheme with its long lead time can have a depressive effect on a sector even before it comes in and before people have to be licensed. If they know it is coming, that can have that effect. Thank you and Fiona briefly. Thanks very much, just very briefly. I was interested to see that the brass says that the tourism sectors will have recovered adequately by March 2023, but the impact of the pandemic is ongoing, it says. I just feel like that is completely unrealistic and we heard at the Scottish Tourism Alliance last week that Euro monitor believes that we are going to be recovered by about 2026. Ultimately, small accommodation businesses are facing a perfect storm of Covid uncertainty plus a hugely onerous licensing regime, not to mention the prospect of short-term that controlled areas. I just feel like we need to support our small businesses through this and minimise the burden, not add to the burden of this completely treacherous torrid time. Thank you and I am going to come back to Miles for another question. Thank you convener. I just wanted to get some more information with regard to the benefits that the panel thought would be in place with regard to the registration scheme instead of a licensing scheme and specifically around areas that have highlighted concerns to the committee around high concentration of short-term lets. I know that some of the evidence that Airbnb gave us was around some of the blocking of reservation attempts for younger people under 25 years old making entire home bookings. I wondered a few of the panel members have touched upon the need to get data. Is that your key benefit that you think will provide or do you think some of the outcomes that the Government are trying to suggest can only be achieved within licensing, could actually be achieved through a registration scheme? I will maybe start with Fiona on that and go around. Yeah, absolutely. I mean I think the important thing is to try and work out what we are trying to achieve with this licensing scheme. Now if it is data about the scale of an activity that can absolutely be done by registration, if it is the concern about antisocial behaviour, we already have existing antisocial behaviour legislation, that just needs to be deployed and we did the FOI in July of this year to all of the local authorities. The instances of antisocial behaviour associated with our sector is absolutely minimal. Licensing is not going to help that, there is already existing legislation to deal with that. If we are looking at health and safety, we have already discussed existing health and safety legislation. We just need to ensure that everybody in whatever capacity needs to be adhering to that health and safety legislation. The big question is what are we trying to achieve? Data is always king, data gives us evidence of who is doing what in each property, but we get that through a registration. That registration is simpler, less onerous and less burdensome. I think that register underpins all of the information that we need in order to work out if there are any gaps in legislation and if there are, how do we achieve that? How do we fill the gaps? There is no point in putting a plaster cast across the whole body when you just cut your finger with a courgette. Thank you for that Fiona. I think that Schoenack would like to come in on that as well. Yeah, thank you. I think the benefits of registration, I just mentioned that compliance would be much higher, which means that you would have a much bigger market and people would not be going underground to do that because of the fear of not paying a licence. If compliance is larger and the market is bigger, you will have a much bigger tax intake from those who are doing it. You will be able to see which businesses are doing it, which individuals are doing it. They can be taxed appropriately. Essentially, with that data, you will be able to get the income that you can then be funneled back into tourism-related activities, much more income, I suspect, than through the licensing itself. These are other benefits that you could get versus the licensing scheme. Thank you for that, Schoenack, and I will move to questions from Paul McClellan. Thank you, convener. Welcome to the panel. Like Megan, I refer everyone to my register of interests. I am a seven councillor on Eastwood and Council. Just a couple of points I wanted to pick up. The first one was probably for yourself, Amanda. You mentioned a number of people who you recommended would leave the industry. I wanted to ask you a bit more about the methodology. You mentioned a number of people who would leave, but on what circumstance? Is that based on, for example, the extra regulation? Is it based on the estimated cost? What was the framing of the question on that, which I think is really important? That is probably specific to yourself. I will ask a bit more about the licensing and registration. The first one is probably for yourself. Sure. The question was posed simply as if the regulations were introduced, would you continue to let your property on the short-term market, put it on the long-term market or remove it? We got a 51 per cent answer stating that, if the regulations were introduced, they would neither let their property on the short-term nor the long-term rental market, which is where that statistic comes from. As I said, I am constantly in dialogue with our post community in Scotland to give some colour to that dry statistic. The overall mood is one of the wilderment. It is the cost that comes through as one of the primary concerns. To put that in context, the average host on Airbnb earns £3,000 a year. They are not earning tens and tens of thousands of pounds, so the cost has a meaningful impact on the viability of their ability to host. We have also heard concerns about compliance, uncertainty. The vast majority of our hosts, in fact all of our hosts, are very happy to comply with minimum standards and laws. As Fiona said, no-one believes that short-term letting providers should opt out from any of those minimum standards. The concern is really about cost. The concern is that their livelihoods could be taken away from them and that they could be stuck in a holding pattern because the council cannot process an application. In the meantime, they cannot work. It is a variety of concerns, but it would be disingenuous to suggest that cost is not one of the main ones. Amanda, thank you for that. It would be useful if that methodology could be shared for the committee to look at. The second point that I want to look around about comes back to the basic safety standards. The sport at the heart of the licensing scheme is talking about mandatory basic safety standards. We have heard the vast majority of self-catenable prayers already apply with these standards. I want to pick up on a point that Schomack picked up earlier on about the registration scheme, which is possibly needing some form of accreditation around safety concerns. Is that not what the licensing scheme would ensure? Schomack probably came back to himself, because he made that point and opened it up beyond that. The licensing scheme would require an inspection of every property. Each local authority would have to inspect each property that is short-letting, which we think is very burdensome for people who are obviously all complying with the regulations already. There is a better way of doing it, which is through a Government-sponsored or accredited provider that allows people to get accredited. Those who are accredited will be checked for health and safety, making sure that they are complying with the standards. Those who are not could be subject to checks from time to time, but they are not getting to the point of registering. They can declare that they are in compliance with certain different things, such as electrical safety standards and so on. If, at any point further down the line, councils believe that there may be an issue, they can go and inspect and enforce against them. That would be a much less burdensome and costly system than having to only give a licence once a property has been inspected, which is what is currently being put forward and essentially leads to a much more expensive system than otherwise, and a higher licensing fees than otherwise. I do not know if anybody else wants to come in on that one. Thank you. We feel that a registration scheme would do all that was needed to allow a proper enforcement of health and safety standards, because it would give all the regulators the ability to make risk-based decisions and enforcement action on all of the tourism accommodation that guests are using. At the moment, the problem still is that businesses such as traditional B&Bs comply with legislation and are visible and are able to be checked by local authorities, by the fire authority and other regulators. Other kinds of property on platforms effectively are not able to be checked, although the same rules may apply to them. There is not effective checking and inspection ability to happen. With a registration scheme, that would mean that there is a database there of the properties that are offering accommodation, and the fire authorities and others would be able to do their own risk-based enforcement. That does not mean, as I said earlier, that everybody must be inspected at the beginning. That is disproportionate, unrealistic and hugely expensive, but it means that the authorities can choose what types of property and what risk-based checks they want to do and apply those in a sensible way. That is how we think registration will be a much more effective and proportionate solution than licensing, and a particularly better solution for local authorities and their costs and the costs to the local communities. I want to point out that I agree with what David said in terms of a registration system being the right way to achieve health and safety measures at Airbnb as a platform. We are highly aligned with all of you in wanting the very highest standards of safety and security for our hosts, and we spend a lot of time educating our hosts and doing things like working with providers to, for example, provide free carbon monoxide and fire alarms to ensure that we do that. I want to point out the process that landlords in the private rented sector in Scotland use, which is self-attestation. As part of a registration host would attest to understanding existing health and safety standards. It works very well in the private sector, and we would suggest that it is also the most applicable and the most appropriate way of achieving health and safety compliance in the context of short-term letting. Thank you. Thank you, Amanda. We are going to move on to questions from Mark Griffin. Thank you. Good morning, everyone. A lot of the discussions that I have had over the course of the summer before consideration of the regulations were around what is a short-term let. How is a short-term let counted? I have concerns about where we are at a starting point for regulations, if we do not understand the volume of short-term let that we have in the country. The Government has used the figure of 32,000 properties from inside the Airbnb, but the non-domestic rate roll only shows 18,000 properties. To ask witnesses this morning what their view of how many short-term let's that there are actually are and how that compares to the Government's figure. If that figure of 32,000 is out of step with what is there, how could that affect the starting point for the regulations and the impact that they could potentially have? If I could come first to Amanda and then perhaps Shomick. It is always a very dangerous game to try and type data sources on the flag that I will give it a go. I think that, fundamentally, both of those numbers are probably right. I would suggest that there are two main reasons for the discrepancy. The first is that a lot of hosts on Airbnb in Scotland share a space in their own home, rather, which may not show up as a property available to rent. There are also lots of type of supply on Airbnb that is not suitable for long-term accommodations. I am sure that many of the committee will have seen that there are yurts, annexes, cabins and all sorts of what we call unique supply that just is not appropriate for long-term rental. A lot of that supply on Airbnb was very proud of that supply, because we think that it brings something unique and distinctive to Scotland's tourism sector. As I say, we can do the bridge between the two numbers properly after this, but I would suggest that there are the reasons for the discrepancy. Fiona, I would like to come in. Just to say that we have always had a major concern about that figure of 32,000 simply because it is, as you quite rightly say, drawn from a data scope from Airbnb. As Amanda has said, not only is a lot of the stock on Airbnb not suitable for long-term rent, etc. There are also multiple listings and replicated listings. A five-bedroom house could have seven different listings on Airbnb, for example. That 32,000 is not really reflective of the number of businesses or premises that are offering short-term rents. There are indeed 18,000 self-catering units on non-domestic rates. There are very few bed and breakfasts on non-domestic rates, but again, what we have said all along is that we need to understand what the scale of the activity is and you get that from the data provided by a register. We should not be using data scrapes to underpin and force through legislation. We need to understand what we are legislating before we introduce licensing. I had another question in a different area. We have touched on almost the different community responses to short-term rents. There are some communities in Edinburgh, parts of the Highlands and parts of Fife, who have expressed real concern about the number of short-term rents in their area. Similarly, in areas such as South of Scotland, where communities have expressed real support for economic benefits and would like to see the number of short-term rents grow. I know that witnesses have spoken about wanting to avoid varying regulations across the country, but I just wanted to ask witnesses again what their view was on potentially a pilot project, looking at an area where communities were looking to see those regulations introduced or just wholesale devolving those powers to local authorities, so that local authorities can choose how best to respond to the needs of their own communities, rather than a one-size-fits-all approach across the country. Fiona, I think you want to come in on this and then David. So, yes, just very briefly, A, again going back to the point that licensing is ostensibly about health and safety rather than the number of, so we need to be clear that we're not talking about over-provision because that's already been dealt with by the short-term net control zone legislation, and you're absolutely right. In many parts of the country people want more. In East Lothian, for example, they actually want more, and in the borders, they want more provision because it is the way of the future. It's the accommodation that people want now, especially after the pandemic. It's safe. It's welcoming. You're part of the community. You're helping the community. You're benefiting the local providers, the accommodation, the activity providers, et cetera, et cetera, and it's not a one-size-fits-all. So, yes, we would absolutely welcome a pilot scheme. We think it would be amazing to have a pilot scheme, but you couldn't just have a pilot scheme in Edinburgh, for example. You'd need to have a pilot scheme, and you couldn't necessarily have one in Highlands. We need to be aware that this is not the same situation across the whole of Scotland. So, yes, a pilot scheme would be incredibly welcome. Thank you. Then David and then Amanda. And then we're going to move on to questions from Fergus Ewing. Thank you. I just echo what Fiona just said. It shouldn't be, in terms of what we're discussing here, a licensing scheme. It's about the safety and protection of guests. It shouldn't be about controlling a number of short-term lets in this way. It should be controlling harms and nuisance if those arise. And there's existing legislation to control those harms and nuisance where and when they arise. And there are other areas, including the planning that is not being discussed this morning, where control can be exercised in that way in specific areas. But in terms of health and safety and what we're talking about here for a licensing scheme, that's not a route to control sort of numbers. It's a route to ensure that standards are there to protect people. Thank you. And Amanda. Thank you. Obviously, I echo what David and Fiona said. I also just wanted to pick up on this idea that there's the idea of community and the idea of tourism as somehow kind of irrevocably in conflict. I think one of the, I would disagree with that strongly, and I think one of the strengths of the short-term letting accommodation sector is that it does have such a role to play in dispersing tourism and actually supporting communities. In April this year, Airbnb, speaking of the South of Scotland, actually launched a campaign that was backed by Visit Scotland and the Scottish Tourism Alliance. The idea was to shine a spotlight on an area of the country that is often overlooked in terms of stays and experiences. Now, being able to spread the benefits of tourism to less of travel parts of the country, rather, ensures that both the economic benefits of tourism are felt by all communities and also that that kind of over sort of concentration is dealt with. So, I think it's fallacious to say that the idea of community and the idea of short-term rental or accommodation are always opposed to each other. That's a different part of the country. We'll have different issues. We are supportive of local authorities and councils having the power and the choice to tackle their particular issues in the way that they best fit. We do believe that the registration system is the right way to achieve that. Thank you very much. Now, I'd like to welcome Fergus Ewing to the committee. Fergus Ewing MSP is joining us. Fergus, if you have questions for the panel, please do that now. Thank you very much, convener, and thank you very much, indeed, especially to the four witnesses whose evidence has been comprehensive and, I believe, persuasive and compelling. I have some specific points that I wanted to pursue, convener, with your leave. First of all, I want to ask David Weston about the fire and safety provisions that apply to the operation of bed and breakfast premises. Is it the case that there already is a well-established and successful set of guidance that operates to protect customers of B&B, and that it has operated for some years now following introduction when I was the tourism minister without incident? Yes, thank you for your question, Mr Ewing. The answer is yes, there is a very well-established regime for fire safety, where responsible persons, as they are called, who are responsible for the safety of accommodation, are required to do a fire risk assessment. That is a proportionate piece of legislation, which is a sort of self-assessment, as it were, that they must look at the fire safety of their premises and put in place appropriate fire precautions. Those can be inspected and checked by the fire authorities. If the fire authorities do not think that they are sufficient, they can take action. The problem has arisen with the growth of platforms offering temporary accommodation, which are less visible to regulators. It has been, in effect, more difficult, if not impossible, to enforce that legislation in the same way. Hence, the requirement for a registration scheme, which would level that playing field and simply say that here is the list of all the tourism accommodation, and the regulators would be able to extend their risk-based enforcement action to all tourism accommodation in the same way. They would have a lot more inspection to do, but that would be only right that all the accommodation would be subject to inspection, and it would be risk-based and proportionate. As has been said before, it does not mean that every bit of tourism accommodation must be inspected every year. Of course not, but the fire authorities have very well-established ways of deciding how much inspection they think needs to be done. They can concentrate in certain high-risk areas, and they can do random inspections, but they must, at least as a starting point, as a minimum know which are the identities of the responsible people for each piece of accommodation that paying guests are going to stay in. I ask the question out of fairness to the other witnesses to say how they believe the guests of people in Airbnb and self-catering properties are, if you like, sufficiently well catered for in respect of fire safety. Fergus Amanda would like to comment on this. From our perspective, as I have said before, safety is absolutely one of the pillars of our host community. We spend a lot of time educating our hosts around what those standards are. Obviously, every Airbnb host in Scotland is already subject to, for example, fire safety regulations and those existing regulations. The risk-based approach is really important. Someone who is sharing a spare room in their home clearly has to take safety precautions and what those steps will look like might be different from someone who is operating in entire premises as a tourism accommodation business. I also want to point out that, as a platform, we are very proactive in ourselves removing hosts who do not comply with standards. We do do that all the time. We also have one of the best, I would say, inspection systems in the world, which is that we have our wonderful Airbnb guests who are also very vocal about reporting instances where they feel things are not up to scratch. As I said, the risk-based approach is important. We believe that the self-cater station contained in the registration system is the way to go in the first instance, but we are proactive and supportive partners in driving up safety standards. It is a core part of what we do as a business. I also wanted to ask how a registration scheme might operate in practice. We did hear at the outset that each of the four witnesses all supported a registration scheme, and indeed they referred to schemes operating in other countries in the world. I know Fiona Campbell mentioned that she first proposed that in 2017, and I believe that she has had engagement about how such a scheme might work. If it might be appropriate to ask Fiona Campbell to start off with, how such a scheme would work and in what way would it deliver benefits as opposed to the licensing scheme that the Scottish Government is proposing? As I said before, we have evidence of best practice from across the world that registration systems work. It is akin to the private land laws register, which is again a self-certification scheme that is largely complying with existing legislation. What we imagine is that it could be delivered by the development of tourism acts. We can give you much more detail on that afterwards. It is quite detailed. We are not proposing that our scheme is infallible. It obviously needs to be looked at by the Scottish Government and make sure that the Scottish Government lawyers are happy with it. However, it could be delivered right now. We believe that it will bring real benefits to tourism in Scotland, whereas licensing will be hugely detrimental to tourism. Those are two diametrically opposed positions, but we genuinely believe that registration is a targeted and proportionate solution to the policy objectives that the Scottish Government has. We think that they can be achieved really quite easily by looking at the private land laws register. Thank you. I have many other questions, but I would like to have one more if I may, convener, because I appreciate that time is short. I have been in lengthy correspondence with the minister about all those matters and others. I think that I am correct, and perhaps that is a question that Fiona Campbell might be best able to respond to, that at the outset, the purpose of the regulations appeared to be primarily or even solely to deal with antisocial behaviour that was perceived to arise from the use of tenemental flatted properties in the city of Edinburgh for party purposes. In my constituency, very large properties used for such as stag parties and so on are also occasionally concerned about antisocial behaviour. However, the question that I want to address is that, first of all, does Fiona Campbell believe that the Scottish Government no longer sees the regulations as playing a role here? Secondly, is it not the case that there already is existing powers and legislation under the antisocial behaviour notices that houses use for holiday purposes in Scotland order 2011, which provide local government with the powers to tackle precisely this antisocial behaviour? In other words, there already are regulations that enable local authorities to act where there are serious cases, convener, of antisocial behaviour. I wonder if Fiona Campbell might be first offered this question, and if other witnesses have for views, I would be very interested to hear their evidence. You are absolutely right that one of the issues identified in the 2017 and 2019 research done by Indigo House was antisocial behaviour, and I absolutely concur that there is existing legislation in place that covers that particular mischief. Now, the other problem is that, going back to the 2019 research, there were also issues to do with housing. Basically, the problem is that there have been many different issues conflated here. As a result, this piece of legislation has ended up with an element of mission creep. We are not sure what the purpose of the legislation has ended up being. Is it about health and safety? Is it about housing? Is it about antisocial behaviour? I suppose that is why it has become quite so complicated. There is existing legislation to cover health and safety. There is now existing legislation to cover the overprovision of short-term lets. There is existing legislation in existence to cover antisocial behaviour. Perhaps we should start looking at those and how those are working and whether those need to be tweaked rather than introducing legislation for the sake of legislation. Thank you for that, Fiona. I believe Amanda would like to come in on that as well. I think I just wanted to echo everything that Fiona said and add to that just to make the point around, by trying to tackle antisocial behaviour through this legislation, you effectively put a blanket of uniform imposition across Scotland. Our view is that any measures to handle that kind of behaviour should be at the discretion of councils, as it indeed is today. I also wanted to make the point on antisocial behaviour. From an airbnb perspective, we take it very seriously. We are very much aligned with local authorities in terms of wanting it all gone. We can and do remove bad actors all the time. We block reservation attempts all the time that prevent under-25-year-olds from making entire home bookings in their local neighbourhoods, trying to crack down on those party houses. We have new technology that identifies high-risk reservations. That technology is aimed at preventing people who are likely to want to let properties have parties to stop them from doing that. We suspend listings all the time. We suspended 1,000 listings across the UK in recent months following a crackdown on so-called party houses. We have a neighbour support line that means that anyone in the neighbourhood can contact airbnb directly with concerns about a suspected listing. We can again take actions against those suspicious listings. All of those things are things that we as a platform and as a participant in the community can and do do. We continue to make those technologies and those services better. We acknowledge that sometimes there is a need for councils themselves to take action. We work very closely with local authorities when we are notified about these bad actors. However, this legislation is not legislation that is going to tackle anti-social behaviour. It is not the right route. Thank you, Amanda. I believe that we have come to the end of our questions this morning. I want to thank the panel for joining us to give evidence on this issue. I am now going to suspend to allow the witnesses to leave. The third item on our agenda today is consideration of the Town and Country Planning General Permitted Development Coronavirus Scotland Amendment 2 Order 2021. This is a negative instrument and there is no requirement on the committee to make any recommendations on it. I would like to ask committee members if anyone has any comments. Does the committee agree that it does not wish to make any recommendations in relation to the instrument? I agree. We will move into private. As agreed earlier in the meeting, we will consider item 4 in private. I will close the public part of the meeting and move into private.