 I would like to let you know that we have received apologies from committee member Paul McClellan. I would like to ask all members and witnesses to ensure that their mobile phones are on silent and that all other notifications are turned off during the meeting. Our first item this morning is consideration of whether to take items 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. Item 5 will be a chance for the committee to agree its approach on the scrutiny of the budget for 2022-23. Do members agree to take items 4 and 5 in private? Members all agree. The second item on our agenda today is to take evidence as part of the committee's work on short-term lets. That is the second of three sessions on these regulations. The committee will hear from the cabinet secretary next week. I would like to welcome to the committee Tony Kane, who is the policy manager of Alachow, Andrew Mitchell from the regulatory services of the city of Edinburgh, and also Ray Byrn, who is the chair of Community Land Scotland, chief inspector Nicola Robson from Police Scotland, and Liam Thomson, who is the executive director of UK hospitality Scotland. Thanks for joining us today. We will move straight to questions and witnesses. If you wish to respond or contribute to the discussion, please add an R to the chat box to indicate that. I will start with the first question. I will direct this to Elsa Ray Byrn and Andrew Mitchell from Edinburgh Council. Do you think that the proposed short-term lets licensing system will effectively tackle negative impacts on some short-term lets on neighbours and communities? In addition, do you think that over-provision powers are required for local authorities? Maybe Elsa, if you start. Can you hear me okay? Yes. Great, excellent. I thank you very much for the opportunity to speak today. I do not want to say that I am nervous, but I am slightly overwhelmed about being the only community representative here. As you know, my colleague Kirsty Henderson from Place had to give her apologies. She is a key worker and could not get additional time of work to attend this. First of all, I would like to put on record that it is a shame that there are no more community voices being heard in these meetings, but I will do my best to represent those communities that I have spoken to about this. First of all, the first question was around whether the short-term lets licensing helped to deal with the negative effects. I think that the licensing scheme as a whole is to be hugely welcomed. It has taken such a long time to get to this point. I know that it has been under consideration for a number of years now, while short-term lets have continued to operate. There are lots of elements of the licensing scheme that will impact positively, not least the issues around health and safety of individual properties and ensuring that they meet at least the requirements of private-tented long-term lets. That is absolutely critical. Having a licence so that people can find out who owns a short-term lets, even though that is by the local authority, is really useful if complaints are to be made because the current system is not working. We know that the only potential routes if you have a complaint at the moment is either by the police, by some sort of antisocial behaviour, and of course by the time things are investigated, the people that have caused the nuisance are away. The owner of the short-term let can disclaim more knowledge of it or by the planning system, and we know that the planning system is hugely overburdened already. It is a really positive step to be welcomed, but there are elements of the replacement out in October by the Cabinet Secretary, which hugely watered down the potential effectiveness. One of those is around the need to have natural names of the owners available. We think that that is for a number of reasons. It has never been really clear as to why you would not have owners' names freely available when you have that for houses in multiple occupation and the landlord register. We are not quite sure what the difference is between short-term lets and those types of operations when they are both commercial operations. Given that the Scottish Government's particular move to water transparency around ownership through the registered controlled interest in land and the land register generally, it seems wrong that those provisions around making sure that natural names are included and publicly available have been taken out. That is a real concern of ours. Coming to the issue of overprovision, overprovision is absolutely essential, the overprovision element of it. The planning control area orders will not address the issues around overprovision, particularly in places like Edinburgh and in some of the rural communities such as Skye and Mull and Tyree and the east coast of Fife, etc. We believe that the place and community land Scotland believe that the removal of the overprovision powers shows a fundamental misunderstanding of the scope of the new short-term let control areas and planning legislation. We welcome those, but they only remove the materiality check on whether the change of use of the dwelling house is material and would require planning permission. For short-term let control areas to be used to tackle the overprovision of short-term lets by denying a property planning permission, there needs to be a supporting policy in a council's local development plan. An LDP, a local development plan, can only be changed every five years if the city of Edinburgh has put into motion the process to put this policy into their LDP. On that basis, the short-term let control areas that control overprovision in any sense, and we need to see the overprovision policy reintroduced into the legislation and the licensing scheme to give local communities and local authorities the ability to control the numbers of short-term lets in very specific areas where they are either causing a problem in cities like Edinburgh where you have huge numbers that have hollowed out the community or in places such as Mull, Sky and Tyree where huge numbers of short-term lets have impacted massively on the availability of affordable housing stock, particularly for young working families. Therefore, people are being made homeless and not able to return or move to those areas and address the issues of depopulation as a result of the huge numbers of houses being taken out of permanent residential use and put into short-term let. If you can get your property, you can rent it for £500 a month to a local family who is providing important services and sending their kids to the school, or you can let it for £1,000 a week for a short-term let. It is really a no-brainer. The market is completely uncontrolled and we need the overprovision policies back in the legislation to enable local communities and local authorities to be able to manage that. I have gone on a bit there, but I think that those are two really important points. Thank you, Elsa. Can we now hear from Andrew? That would be a great question. Good morning, committee. I think that the council strongly welcomes the introduction of the short-term let licensing scheme. As your previous speaker said, it seems to have a long time coming in terms of the concerns of local communities in Edinburgh. The sector currently is largely unregulated and the licensing scheme will give local authorities important powers, mostly discretionary powers, to tackle some of the issues that communities face. In terms of the overprovision, I think that the council hasn't, I suppose, formally reached a view of the overprovision elements being taken out of the legislation. It would be fair to say that I would imagine that quite a number of elected members on the council and the community at large would have preferred that those measures stayed in the legislation, but that being said, as your previous speaker highlighted, Edinburgh is quite far down the road in terms of looking at its LDP and consulting on the short-term let control order within planning context. In terms of the legislation running in parallel and providing that protection, we are already taking those steps to put that issue before the council so that it can make a decision on that early in the new year. Thank you very much for that response, Andrew. I have another question. I would like to direct that question to Tony Cain and Leon Thompson. Tony and Leon, I would be interested to hear what your views are on the changes made to the draft licensing order from the version presented to our predecessor committee in February. Forgive me, convener. Those are the changes that were set out in the cabinet secretary's letter a couple of months ago. On balance, one or two of them make sense and there are others that would be more concerned about. The changes around notification, for example, make sense. The changes that require the applicant to do a neighbour notification rather than the council also make sense. The question around the over-provision elements is really about what we think they are going to achieve and our concern—and it is part of the answer to the last question—is that there are some areas, not many but very definitely some areas in Scotland where there are far too many short-term lets and the number needs to be reduced. There is nothing in either the licensing regime or the planning provision that will allow for the active management down of the number of short-term lets in an area. We have heard from one member of the community, I have spoken to others. They all say the same thing in those most pressured areas, which is that this substantial over-provision is doing great damage to local communities, to individuals who are living next door to poorly regulated or poorly managed short-term lets but also to the local housing market and the way in which they constrain the availability of accommodation, particularly affordable accommodation. My concern about the changes is principally that it is not clear to me how any of those provisions will allow a reduction in the number of short-term lets in those most pressured areas. The indication of an intention to set out an average fee but also to provide stricter guidance around the use of inspections are, frankly, inappropriate. Local authorities know how to manage licensing schemes, they know what the sensitivities are in their communities, they know how much it costs to deliver licensing schemes and both the fee and the regulatory regime in terms of verification but also enforcement is a matter for local councils and should simply be left to them. The issues vary area by area, ward by ward, so dramatically, that I do not think it is possible for the Government to make properly flexible guidance at that level and it really is a matter for councils to manage those issues. Before I bring in Leon, I have a supplementary for you, Tony, on your comments about over-provision. What do you think we could do about what would we need to bring in to manage down in the areas of Scotland that— I think that you simply have to go through a process of removing licences and permissions to operate. One of the objectives of that is always going to be that you cannot do that, people are doing this, it is their business, you have got to stop them. I was thinking about this earlier. We regularly prohibit activities that were previously unregulated and this is one of those areas. Ten years ago, there was no such thing as a short-term let. It has taken ten years to get to a place where we understand how it needs to be managed and the risks of unmanaged short-term let, we simply now need to be fairly bold and say that there are too many in these areas and we are going to select—now that needs to be fair, it needs to be transparent, but you simply need to select those that can no longer operate. I would suggest that Edinburgh's approach around tenements, for example, is a good starting point. Short-term let in flats, particularly in very high-density areas, are extremely difficult to manage in a way that is properly sensitive to local community. I would also argue, by the way, for strict liability on the part of the operator and the owner. The idea that somebody can disappear out of the country and then nobody is liable for their bad behaviour is offensive. The owner has to carry strict liability for things that go on in the properties that they manage and that should be written into these regulations. Thank you very much for that. Leon, can I come back to you on the question about your views on the changes that were made to the draft lessons order from the version that was presented to the previous committee in February? Thank you, committee, and thank you, convener, for the question. I think that the changes that have been made in the order as it has come back show that the Government has listed to the concerns of my colleagues and who represent the short-term letting sector. Some of those changes are to be welcomed and reflect the fact that short-term let is an important part of the mix for tourism in Scotland. The changes certainly take away some of the more restrictive elements that were in place in the original order, which is helpful for tourism to continue to thrive. UK Hospitality Scotland supports the licensing order that has been brought forward. The priority for us is to arrive at a point where all accommodation businesses are operating in the same way, following the same rules and liable for tax. Those are the overriding concerns for UK Hospitality Scotland and for our members, but it is pleasing to see that things such as the overprovision powers have been removed, because you can see that that creates a lot of challenges for people who are running short-term let businesses, similarly focused use of inspections as well, and then working with local authorities on guidance to reduce the fees, which has been another major, and as you know from last week's evidence session is a major concern for businesses. For UK Hospitality Scotland, the changes that have come through are welcome. We are not anti-competition, we welcome the fact that we have a thriving short-term let market in Scotland, and competition is always good. We are not here to stifle that competition, but clearly we are in support of a strong system of regulation so that short-term let businesses fall into line with traditional accommodation providers. I see in the chat that someone else wants to come in and we think that it is Elsa. Elsa, do you want to come in briefly on this? Thank you convener, just very quickly in terms of how overprovision could work. Under the new planning act, there is of course the opportunity for communities to introduce local place plans together with local authorities, and that is where we see if there was a call and a need for an overprovision policy on a very local basis, then that would be a great route to do it through, a very effective route, because you could consult with everybody in the community and then come to a local decision as to what would be an appropriate number of short-term lets for that particular community. It will differ from community by community, and it is something that actually the Cairngalls National Park Authority is currently doing as part of that draft development plan, so there are processes in place for doing this in a democratic and open and fair and accountable way. That is the point that I wanted to make. Thank you very much for adding that very useful perspective and a great point and a tool for communities. I am now going to move on to questions from committee member Eleanor Wittam. Thank you very much convener and good morning to the panel. Before I ask my questions, I will refer members to my register of interests. I am still a serving councillor at East Ayrshire Council. I have got two questions this morning, and the first one I would like to direct to Chief Inspector Nicola Robison and perhaps Andrew from Edinburgh. The committee has heard that powers already exist to deal with illegal or antisocial behaviour associated with a small number of short-term lets. I am thinking particularly of the evidence that is contained in the letter from Police Scotland. I am concerned about the possibility of women being trafficked across the country and into prostitution. I am worried about county lines drug activities and the potential for puppy farming. Do you think that the powers that are already in existence have proven effective in practice? If we could start with Nicola, that would be fantastic. Good morning everybody. Thank you for the opportunity to allow Police Scotland to feed back in relation to that. In response to your question there, Eleanor, yes, absolutely, there are powers that exist at the moment in respect of legislation that we can use. However, what we do find is that that creates certain limitations and obviously presents us with further challenges in respect of how we can then support local communities when they are coming to us with potential issues. That is primarily caused by the quick turnover of obviously different persons from week on, week in, every weekend, which we find it very difficult then to really get that intervention and prevention opportunity that we would like. The proposed licensing system would obviously give us the opportunity to feed back into local authorities to give our point of view in respect of whether that person is a fit and proper person and it would just allow us then to be able to do our checks and ensure that we are safeguarding any persons who are going to be utilising those properties and also by doing that we then obviously can identify the owners of those knowing that they are fit and proper persons, which again helps us to support the local communities and obviously the local authorities if problems are identified to us. Thank you very much and Andrew from City of Edinburgh, can we hear from you as well please? Thank you. I suppose that the core benefit of our licensing system is that it brings transparency. We know who the operators are, they are subject to checks, that they are fit and proper. It allows local authorities and the police to tackle particular problems that arise in certainly Edinburgh's experience thus far as that the current powers are nowhere near effective in doing that. The antisocial behaviour legislation that currently exists is designed to deal with people in the community, people who are living in tenancies, who are creating problems over a longer term and I think that it would be naive to think that it would be easily used to deal with types of problems that communities in Edinburgh are facing. We had given evidence to the Government and I am happy to send it on to your clerks if it helps of how difficult it is to use the very limited powers under antisocial behaviour legislation to tackle problem short term less. I think that in one case we ended up spending £30,000 worth of court costs trying to get a management control order to deal with just one landlord, so the current antisocial behaviour powers do not assist in any meaningful way the current problems being faced by communities. Thank you very much for that, Andrew. I think that the committee would appreciate if you did send that evidence that you gave to the Government on to us. I have another and final question from myself. The committee has heard concerns that local authorities might not have the staffing or the resourcing to effectively administer a licence in the scheme or take prompt enforcement action. Do you share those concerns and, if so, how could they be best overcome? I would like to direct that to Tony from Alachow and then also to Andrew from Edinburgh. Tony, over to you first, please. Yes, resources are an issue across local authorities and have been for a number of years. This is an additional burden and it will be a challenge. However, it is also a Civic Government Act licencing scheme, which means that the fees can be set in a way that should cover, in fact, must cover, the whole of the cost of the activity. That being the licensing process itself and verification, that does not include enforcement action and that is where the difficulty arises. The first point is that the council will know what it is going to cost to set up an appropriate licensing and verification process, one that fits with the concerns and the pressures and the issues arising in local communities. I think that that is a matter for councils. The bigger issue arises in the enforcement activity, the day-to-day of responding to and addressing concerns and complaints when they arise, and that is where the principal difficulty will be with this scheme, as it is with HMO licencing, for example, and to an extent to land of registration too. I could make a special plea, if you like, for specific funding to assist councils in enforcement around those issues. I am not sure that that is the appropriate solution, or that one that colleagues in COSLA would be in favour of. However, there will be a challenge in finding the resources to carry out enforcement work outside the licensing process, because there always is. That is an issue for the Government in COSLA to talk about. Thanks very much, Tony. Andrew, do you have anything to contribute on that issue? I think that local government is well used to operating a licensing system under the 1982 act. Yes, it will be a challenge, particularly if you have the scale of Edinburgh, the number of properties that we are likely to have to deal with, but local authorities will put in place provisions to fund dealing with the applications as they come in. In Edinburgh's case, the current year budget has a funding allocation of £250,000 to start looking at the start-up costs of dealing with licence applications and the stuff that we talked about earlier. The fee structure within the act will allow local authorities to cost-recover the cost of operating a licensing system. Reflecting back on some of the evidence that you heard last week, I think that local authorities, particularly Edinburgh, are bearing the costs now. We are dealing with communities that are unhappy with the rapid and uncontrolled expansion of short-term lets, the problems that come with that. Colleagues in planning are highlighting the head over 400 inquiries in a three or four-year period. Local communities are paying for trying to manage some of those effects currently, and a licence system that allows local authorities to recover an appropriate fee from the businesses that they are regulating would be an appropriate way to address some of that spend that is currently going on. Thank you very much for that, Andrew. Your last comment is particularly helpful. I thank you, convener, back to yourself. Thank you, Ellen. I will now invite a question from Megan Gallagher. Good morning, panel, and, like Alina, I would like to draw a member to my register of interests, as I am a serving councillor in North Lanarkshire. I also have two questions this morning, and if I could start with the first question that we heard from witnesses last week and the raised concerns over the cost of the short-term licence, how much would the panel expect a three-year short-term let licence to cost? Do they believe that that could effectively harm small businesses and their ability to function? If I could start with Leon, please, and then Tony. Good morning, and thank you for the question. The cost of the licence has been an on-going issue for short-term let operators and the bodies that represent them. The Scottish Government has been pretty clear and consistent all the way through the process that it sees a licence costing between £200 and £350 for a three-year licence. It seems to be borne out in the conversations that it has had with several local authorities around this issue. The key in the conversation is making sure that guidance is in place to keep costs as low as possible. At the moment, what we have is a huge discrepancy between the figures that the Scottish Government has been very clear about and the figures that are being used by the AWSC and so on. The Government has been very clear on the figures that it has. We have talked about the options around potentially capping the fees, and I understand that, although that is not necessarily an option, I believe that having some guidance on setting fees will be helpful in terms of how the licensing process would work. There are clearly very cost-effective ways of managing that system, and some of that allows for self-certification up to a point, which is helpful and should allow local authorities to conserve resources and time and thereby not pass on additional costs to businesses. It is obviously still clearly an area of concern for some businesses, but if we are looking at between £200 and £300 for a three-year licence, that is a relatively small amount of money, I would suggest. I do not have a set of exact figures in my head, but I would expect the range of fees to be very similar to the range of fees that we see for HMO licensing. It is a similar activity with a similar range of concerns, and that range of fees reflects the local decisions that are made about how licensing schemes are managed. The primary constraint is that the fee will be set to cover the costs. I do not think that the operators can have any legitimate ground to claim that other people should pay for the regulation of their industry, but it is a common cost. Everybody pays the same fee within a particular area in terms of impact on business. Those are the terms of trade, and it is for local government to set the terms of trade. If there is a cost for licensing, then all the businesses in that area operating within that licensing regime will pay the same cost. I think that it is a red herring, frankly. The issue here is whether or not the regimes that are proposed will be effective in delivering the level of control and safety for communities that we are talking about. Local authorities, as has already been said, have a lot of experience in running licensing schemes. They are subject to best value regimes that control the way in which they go about their business. Nobody has presented any evidence from other licensing schemes to suggest that councils actively, willingly or deliberately set excessive fees for whatever reason. The fees will be set at the necessary rate to deliver the licensing regime that is considered appropriate for that area. Those are the terms of trade, and those people who want to enter that trade will need to accept those terms. I think that I just wanted to reiterate that local government has well experienced setting fees to recover, and there are transparent mechanisms for doing that. I think that Kerrumbach contributed fully to the Government's calculations. We would argue that the HMO fees for those who are operating in effect commercial operations 24-7s are as much likely to be the cost that local government will set the licence at. Within the act, there is no reason why, if somebody is only operating occasionally or perhaps renting out one bedroom whilst they are still living on the property, they might be subject to a less onerous licensing system beyond the management conditions, and the fee would no doubt reflect that. I strongly urge the committee to trust local government to represent the communities and reflect on the cost, because it is something that they do DND out. Thank you Andrew, and thank you for everyone's contributions there. I will move on to the next question quickly, convener, and then I will pass it to you. I was wondering if the panel had any concerns about the inclusion of traditional bed and breakfast accommodations within the definition of a short-term let, and if the panel can provide any reassurances to those who own a traditional B&B accommodation? If I could start with Andrew this time round, and then if anyone else would like to come in. So the inclusion of bread and breakfast in the traditional sense makes absolute sense. If you do not include that, all you will do is create a look poll that will allow every short-term let to offer a take-away breakfast and inclaim their accent from the licensing laws. We strongly support that poll being closed by including traditional bread and breakfast in that category. Again, as I have said previously, licensing systems that chiefs local authority will deploy will reflect where they see the risks are. For example, if somebody is living on the property, which is perhaps more of a case on a traditional B&B, they might be subject to a less onerous inspection regime, less requirements. If I take Edinburgh as an example, the number one category of short-term let if we get complaints about is those where there is no host or no landlord on the property. The tenants or the guests are just left to their own devices, nobody is managing the properties. You can see that you could distinguish between them and traditional bread and breakfast when you are designing what the local rules will look like and what the level of checks would be at a local level. Thank you, Andrew. I think that it is sorry that I cannot see the chat function there. That is great. I will jump in here really just a short couple of points. It is regrettable that B&Bs, which are traditional businesses, have been captured by this, but I completely understand why that is the case and the need to close the loophole. However, it is encouraging to hear what Andrew just said about working to make sure that B&Bs are not subject to less onerous requirements. I think that that will help those businesses quite a lot. Thanks be on end, Tony, please. I think that, from Andrew's evidence, you hear the voice of experience in managing licensing schemes and the types of responses that might be appropriate for lower-risk premises. I think that, on B&Bs themselves, the risk of avoidance is real and if the idea that somebody might offer a breakfast of the way getting around things seems a bit far-fetched, that is exactly what private landlords did during the 80s and early 90s in order to avoid or during the 80s rather in order to avoid the regulations in place at that time. It was very common, it was very damaging and it was very exploitative, so that is a real risk. That is not a made-up thought. The other issue is around the fit and proper person test. I agree that we had a traditional B&B operating three doors up for us for 10 years. The guy is long-term in business, never any issues apart from the occasional family on the doorstep with suitcases. I have no doubt that many of these operators see this as an imposition, but there is a risk in the relationship between residents and landlords that the landlord is resident. There is a vulnerability there. For me, it was a gap that there was no fit and proper person test for B&B operators and it is a good thing that we will now have that degree of protection for those that might be at risk. Thanks to you, I think that Ulster is looking to commend. Sorry, can be done. Thank you, Megan, just quickly. One of the concerns that communities have in particular is that the industry likes to present this particular industry as all individuals making a little bit of extra income on the side. They are all small businesses. Of course, we know both from the Scottish Government data and some Sunday times data that more than 55% of listings, just an Airbnb, and we assume that that is replicated across other booking agencies, are held by multi-listers. This is actually big business. It is not small business. I do not think that data and that evidence has come across in what you have heard so far. Almost 40% of owners across Scotland have more than three properties, and 8% have more than 100 properties that have run a short-term mess. In Edinburgh, over 10% of all the owners have 10 or more properties. I urge you to think about the nature of these businesses, and a lot of them are not small businesses. They are really big commercial operators. There is some concern that that is perhaps why this whole issue of transparency is very important to those types of operators, and that they do not want people to know how many of these types of properties they have. We need to be thinking again about what the nature of a lot of these businesses are. They are not small, local, independent, grantee letting a room in a house. That time has been and gone, and now it is substantial big business in a lot of places. We are going to move on to questions from Miles Briggs. Thank you, convener. Good morning to the panel. Thank you for joining us today. I wanted to ask a few questions and firstly to look towards some of the unintended consequences. I wanted to ask the panel specifically if you are aware of any evidence from other industries that are subject to local authority licensing at present. Whether or not licensing renewal produces significant disruption for their businesses, specifically what proportion of licensed renewals are regularly refused by local authorities for other industries. I wonder if the panel had any data on that. We start with Andrew and then comes to Tony. Again, that was one of the points that struck me from the evidence of last week. I think that there is a fear in the industry of what a licensing system will be. The legislation using the 1982 act is a good model, as well understood. The reality of licensing decisions on the ground is that the vast majority of licences are granted. The legislation is quite clear. A licensing authority shall grant a licence unless there is a good reason not to. One of the principal advantages of a licensing system is that it is in the businesses' interests to deal with any problems so that they do not come into problems when their licence comes up for renewal. Certainly, in the case of Edinburgh, refusals of licences are in the hundreds compared to being processed over 20,000 applications a year. It is not a large figure at all. If you are a business who is likely to have your licence refused, then the problem will be how that business is operated, not that the licensing system is not operating well. I am very happy to reiterate Andrew's evidence there, but councils are not looking unnecessarily for work and to start poking about in licences for businesses that have been operating perfectly effectively over the previous licence period. When I worked for Stirling Council, I signed all the licence approvals, hundreds of them in a week, and almost everyone was approved in a routine way. The issues arise when there are complaints. The operators will know when there are complaints and when there is a problem and will be well geared up in advance to address that in the renewal process if they are in a position to do that. I do not think that the renewal process needs to become a burden, but, again, to repeat what I said earlier on, those are the terms of trade, and all the operators in the area will need to go through exactly the same process, will face exactly the same challenges and will be under exactly the same requirements in terms of the way that they operate and the way that they engage with the council. I do not see anybody being disadvantaged here. I do see communities being protected. Thanks for the question and for bringing me in. Across hospitality, hospitality businesses are also subject to licensing at the moment, particularly alcohol licensing. Speaking from that side of things, businesses manage perfectly well with the licensing regime, with the applications that they manage, with the renewals, the system that is being proposed for short-term lets will obviously guarantee right of reply and to make appeal and so on, where there are potentially challenges coming. That is just the nature of regulating this market. I can understand why some businesses will be concerned about that. It is new territory for them. The key thing here is to make sure that businesses understand the process fully so that they are equipped with all the information that they need. That is helpful. Thank you. As the panel members will know, previous witnesses have told the committee that licensing of short-term lets could lead to a significant reduction in their availability and potentially cost the Scottish tourism industry tens of millions of pounds in loss to revenue annually, even given the disruption that we have seen during the pandemic. How would you respond to those claims and the impact that they will have on the industry? I will maybe bring Liam back in there if anyone else wants to put an R in the chat. I think that the claims are obviously borne out from surveys that the groups have run amongst their members. I think that sometimes that does not necessarily present the full picture. It obviously depends very much on how questions were asked at the moment. Businesses within tourism are in a difficult situation, so businesses are not feeling particularly upbeat at the moment. That may be a factor in why people are viewing that in a negative way. There are a lot of points of view floating about and being put forward, which is perhaps getting in the way of the facts. I think that businesses really need to understand fully what is being proposed here, and that that is not something that is unusual or outlandish. It is simply about bringing businesses that are currently unregulated into the regulated marketplace in which they will operate in a very similar way to their competitors, which is absolutely key and important. We are not looking at prohibitive costs as far as Scottish Government calculations go. I think that when hopefully we get past that point and things are perhaps a little clearer for businesses, they will be able to make sensible decisions about their future operating arrangement. That is helpful. Thank you, convener. A lot of the evidence that you have heard will obviously have been surveys undertaken by the industry. There has been an independent report by the Economic Policy Institute, which finds that claimed increases in economic activity by short-term letting platforms are often vastly overstated, because that spending would have occurred anyway by travellers staying in other types of accommodation. There is little evidence that cities with an increasing supply of short-term early and via rental accommodations are seeing a large increase in visitors. That is, of course, borne out by the Visit Scotland economic impact of tourism surveys, which showed no signal between 2011 and 2018, and yet short-term lets had increased by at least 10-fold during that period. We would query the link between increasing numbers of short-term lets and increased tourism economy. We think that it is substitutional and not incremental. Two further surveys have indicated that only 2 to 4 per cent of those using this type of accommodation would not have taken the trip anyway. That is a really clear statement that this is a substitute for other types of accommodation. I stay on the west coast, East Hotels and traditional B&Bs around here completely bemoan at the impact of this type of much cheaper, unregulated, untaxed accommodation and the impact that is having on the tourist industry. That is the first point. The second point that I would make is that, obviously, licensing has been introduced in a number of other cities and locations worldwide, where this type of activity has been shown to have a serious detrimental impact on local communities in places such as New York, Paris, Amsterdam, Vienna and other amroral locations. It is not significantly impacted on the numbers available, just as Tony and Andrew have already said. It is a cost of doing businesses. If £300 a year for a licence enables you to change your property from achieving £500 a month on a traditional short-term net to £1,000 a week, that is a pretty good return for money. I would query some of the economic assumptions and statements that are being made. Tony, do you want to come back in there? Very quickly, two points. One is simply to support everything that Alice has just said. She makes the point very strongly. There is absolutely no evidence to suggest that short-term lets having themselves boot into the tourism industry or that, if they reduce in number, they will reduce the tourism industry if they have substituted quite aggressively. The other point is that, can we get away from the idea that tourism is of itself some kind of sacred cow in the world of business? It is possible to have over tourism. It is absolutely the case that we have over tourism in some areas. Changing the terms of business around that and changing the way that you manage these things and reducing tourism and the way that it impacts on communities is probably going to be a good thing. What is absolutely clear, though, is that we have a number of very large and very powerful operators who have been existing in what has essentially been unregulated. I have attempted to call it a wild west context around these things for a long time. We have seen them being very aggressive in their opposition and undermining democratic attempts to regulate them. I am quite happy to engage in and encourage hosts to engage in unlawful activity and ignore court orders, as we have seen in a number of places. There is something important about these businesses that is to understand that their terms of engagement have to be exactly the same and their respect for the processes and the democratic air controls around them have to be the same as everybody else. Tourism is not a sacred cow. It is not the only industry in Edinburgh or the western Isles or islands that provide jobs. Actually, there is no evidence at short termlets, which did not exist 10 years ago and have changed the world of tourism. Given the way things are going at the moment, it is impossible to predict where tourism will be in five years' time, and that has nothing to do with licensing of short termlets. Thank you for that. My final question is about the data around the link between short termlets and the housing market. Has anyone on the panel had any evidence with regard to that? The potential outcome that the cabinet secretary said that the legislation would have to help to address the housing crisis? We know that there are five times as many empty homes, for example, in Scotland than self-catering units. If the outcomes of the legislation and if the panel had any evidence of where that will be achieved, I might bring Tony back in and, if anyone else wants to, please put an hour in the chat and then hand back to you, Camina. This is one of the questions where, in general terms, our data around the operation of the housing system and the housing market is not good across the piece, so that we are short of data in some areas is no great surprise. The other thing to bear in mind is that evidence provided in response more generally to these consultations has demonstrated that the short termlets are problematic in the housing market term in a very small number of locations, so it makes it extremely difficult to generalise, but I do not think that anybody and certainly none of the communities involved are going to look at Sky or Central Edinburgh or the East Nug and say that the massive growth in short term letting in these areas and the transfer of properties out of traditional residential uses into commercial tourism use has not had an impact on the availability accommodation, but the price of accommodation in these areas as well. You have only got to look at the map of—and it is principally Airbnbs that get mapped because of the way that they release the data—the map of Airbnbs through Edinburgh. You can see that the availability of accommodation and the price of that accommodation has been impacted by the growth of short term lets. We are short of data on how precise that is. We are talking about a relatively small number of communities, but those communities are facing some fierce problems as a consequence. When you listen to the industry to present an image of it, it is just the single people renting out a bedroom from their property. I think that Edinburgh, a few years ago, commissioned Rhettys to do some research, and I think that their research highlighted, back in 2018, something like 5,000 properties potentially lost to the housing market in Edinburgh. That was back then. The impact of that is that private rented sector rents go up because there is more competition for the properties that are remaining. Communities tell us that you do not need research communities to tell you that communities in some areas are being hollowed out because short term lets has become the most dominant and certainly part of central Edinburgh. Certainly, if it helps the committee, I can send you that research that we did, albeit a few years ago, that highlights the displacement of homes from the housing market into commercial short term lets operations. Thank you, Andrew. That would be very good to see that research. I am just ready to echo Andrew and Tony's points on the impact of local prices, both rental and capital values and availability in many rural communities, particularly tourism hotspots in the west coast and on the islands, where 30 per cent of properties have been put over to this type of use. That is hugely impacting on the ability of local working-age people and families to secure local housing, which then impacts on services. Andrew used the phrase, they are hollowing out of communities. That is absolutely the case in many places on mull and sky and Tyree and Apple Cross and Plopton. We can all name these places where that is happening. I think that the other point to make, as well as the impact on prices and availability, is that a lot of these operators do not pay either council tax or they claim small business rates relief. Even if they own 100 properties, they are able to claim small business rates relief on each of the properties. Therefore, they are not making any financial contribution to the local services. We are obviously seeing a loss in council tax and a loss in revenue for local communities and local authorities because these operations are not paying any of those taxes. It has a really broad impact well beyond just the loss of that particular house to that community. If you speak, that is why it is such a shame that more of my community colleagues were not here to tell you much more articularely and clearly what the impact is on those places. From a hotel and wider hospitality perspective, information that I get from members operating both in rural locations and urban locations is that they increasingly find it harder to secure their workers that they need, because there just are not the people there and people cannot afford the accommodation. The accommodation is not in place, so that does have a knock-on effect for other parts of tourism as well. On the point about taxation, it is very important that all tourism businesses and accommodation businesses are paying an appropriate level of tax into their communities. The licensing scheme will, hopefully, lead to that eventually, and that will be helpful for boosting support for tourism in areas where perhaps there is a lot of negativity right now. We are now going to move to questions from committee colleague Willie Coffey. I wonder if we could ask the panel just to give a brief response to this question. Last week, we heard that the panelist last week seemed to prefer a registration scheme rather than a licensing scheme. Could you offer us a view of which your organisation might prefer and tell us why, please? I wonder if I might start with Andrew. I would describe a registration scheme as licensing light. I think that it would be nowhere near as effective as a proper licensing system. There are two categories of registration systems, so ones that are in dispute. The old controls over estate agents back in the 70s and 80s. We are, again, to use a phrase that, to only use the wild west, where anybody could be a estate agent, no qualification and ripping off home buyers, no reference centre. There is the landlord registration scheme that currently exists and, although in the face of it, that might look attractive, but if you look behind that, the landlord registration is probably one of the most highly regulated industries in Scotland. The landlord registration can afford to be a light touch in that regard, because there are significant other legal protections and controls on how they operate their business out, not least the first-tier tribunal. If you had a landlord registration scheme for short-term lets, it would achieve no more than having a register of where the landlord short-term lets are but would not allow local authorities any meaningful powers to tackle some of the problems that we spoke about here today. Thanks, Andrew. I bring in Leon, Tony or Reilsor, please. Yes, happy to come in now on that, thank you. Yes, this is obviously part of the debate that is being had. Within tourism, we all agree that there needs to be regulation, but that is where we disagree. The challenges around the registration scheme is that they will largely be toothless, which might lead to more complexity and, ultimately, we believe that they will not deliver on the things that we are looking for, which are about ensuring that all short-term let businesses are visible, that they are complying with health and safety measures that are not particularly onerous and that they are applicable to even the smallest hotel operators in Scotland at the moment. Also that, ultimately, businesses are paying their share of tax as well, which is really important, particularly at the moment. We do not believe that a registration scheme would deliver that. We feel that a licensing scheme, which is thorough and thought through, will deliver what we are looking for. On the point of the conversation last week from the witnesses, there was a lot to talk about our registration scheme, but the plans are not going to appear to be fully fleshed out. Even the proposal from the ASC suggests having a twin approach, so some businesses could be registered with professional operators, and there would be licensing for those unprofessional operators. I am not entirely sure how that scheme would work, but the difficulty with any of that now is that, going back and looking at those proposals again, we would just cause delays in a system that we need to have in place as quickly as possible. I can bring in Ailsa, Tony and Chief Inspector Nicola Robison, if you want to come in on that, too. That would be great to hear from you as well. Thank you, convener. I think that echoing on Leon's points, the registration system that is proposed does not address any of the issues around transparency, around health and safety, around taxation or provision. The proposals that have been put forward by the ASC are not developed in any sense. If there is some thought about investing in those further, obviously that would lead to further delays in the implementation of any system. There is no clarity, and they have not been clear about who would manage that scheme. Initially, they were thinking about Visit Scotland, but as far as I am aware and others on the call may know more, Visit Scotland has not expressed any interest in managing that scheme. Of course, it would be self-regulatory if it is done by the organisations themselves and therefore no element of independence or transparency. As Leon has said, they are still proposing that you need a licensing scheme to sweep up the bad operators. The licensing scheme that is being proposed by the Scottish Government is still an integral part of what it is proposing, but there is no opportunity for local authorities to recover any costs around that. It is proposing a hybrid model that will not work in any sense and will not provide transparency or independence. There are lessons that Scotland should be learning from other places that have issues with short-term nets that have all rejected registration schemes and have not gone for licensing schemes. I do not think that there is probably any need to reinvent the wheel that we should be looking at what other places are doing that have been through this process. They have decided that an independent, transparent licensing scheme is the way forward. That is fairer for everybody, both the operators of short-term nets and, as Leon has already mentioned, the rest of the tourism industry as well as local communities. I apologise. I think that there are two observations on the issue of registration against licensing. We licence taxi drivers, we licence window cleaners and we licence those activities because they present a potential risk in the relationship between the operator and the client and the customer, and managing that risk is important. The other thing that occurs is that there is a reason why the chief inspector is in this room. That is because there is a very clear connection between serious and organised crime and short-term nets, as well as private netting and private renting more generally. Serious and organised criminals are both serious and organised, and we need to have a system that is capable of addressing the risk that they present. That is not an exaggeration. I am absolutely confident that Police Scotland would not have committed to chief inspector to this conversation if it did not think that there was a serious issue. There is a serious issue, and it is interesting that the industry has largely denied that and is seeking to avoid transparency in regulation. We need to listen to what the police are saying. Hear the warning bells that come from a sector that has those connections that do not want to be regulated and not be fooled by them. That is important in safety and in tackling organised crime in Scotland as well. The idea that a registration scheme is a suitable alternative is nonsense. Thank you. Just echoing Tony's concerns in respect of a Police Scotland point of view, we would absolutely be supportive of the proposed licensing system in respect of those concerns that surround criminality in the sector, which we have based on intelligence that we have received. In addition to that, we would give us further tools in respect of the anti-social behaviour elements that are reported to ourselves. Obviously, at the moment, we do not have a system that recognises short-term lets because they are not licensed, so any anti-social behaviour that is reported as a result of short-term lets, we obviously cannot quantify that actual issue at the moment, so it would allow us to do that. Obviously, the most important part is that, with a licensing system, we then have that opportunity to identify whether those persons are fit and proper to be holding that licence. Again, that is for the safeguarding element of the persons utilising that. That would also allow us the opportunity to check our intelligence system and make an assessment of ourselves as to whether that person is fit and proper, so we are fully supportive of the proposed licensing system for those reasons. I thank you for that. I am sorry, Willie. Do you have more questions? Yes, thank you. I just wanted to clarify on a point of law. Should an unscrupulous operator be using a short-term lets and have a licence withdrawn, does that make it an offence, a criminal offence, continue to operate? Similarly, if it was a registration scheme, and an unscrupulous operator continued to operate, is that an offence to do so under a registration scheme? Chief Inspector, or even Andrew, might be able to help to clarify that? We would obviously be treating that the same as we would in respect of taxi drivers, et cetera, so we would look into the full circumstances and, with the proposed licensing system, that would allow us the tool to do that. Andrew, any view on that? Is it an offence to continue to operate without a licence, or is it an offence to continue to operate if it is removed from a register? I think that, in practice, the answer is usually yes to both questions, certainly in terms of licensing, because it is a very definite yes. I think that the disadvantage of most registration schemes is that there is a presumption that you can continue to operate until such times as there is a problem, whereas in a licensing system, as the chief inspector said, there are proactive checks before you are allowed into the system, and that would be one of the key differences between licensing and registration normally. I see that Elsa would like to come in on that as well. Just very quickly, as I understand it, the proposals that have been put for by the industries for a self-regulating registration scheme would not have any powers attaching to it. If you failed to meet the initial registration requirements, there is no penalty whatsoever. You can continue to operate. For me, as I understand it, the real difference is that licensing will stop bad actors but will enable the vast majority of good actors to proceed, but a self-regulatory registration scheme will not have any powers at all. I will hand back to you, convener. Thanks very much, Willie. I am going to ask a quick supplementary to Elsa and also to Andrew. The survey response is submitted to the committee raised concerns that the proposed legislation was designed to tackle issues experienced principally in central Edinburgh, but considering that, I would like to hear your views on how short-term lets and housing demands interact in the rural. How do you think that short-term lets and housing demands would interact in the rural and island context? Elsa, if you wanted to come back on that, that would be great. Thank you, convener. I am aware that the industry has been focusing particularly on central Edinburgh, where I think that the evidence is almost overwhelming of the impact, particularly around antisocial behaviour. In rural communities, it tends to be much less around antisocial behaviour and much more around the impact that we have already discussed on the local values, both rental values and capital values, pricing local people out of the market, pricing young people out of the market, pricing working-age people out of the market. In places, as I have already stated, you are removing 30 per cent plus of traditional long-term residential housing stock from its availability, and that is moving over into short-term lets. That reduces the number of houses available and, of course, you can never rebuild. I know that that has been something that has been suggested that we should be building more houses. Yes, we should be building more houses, but we are never going to build 30 per cent more houses in Skye in the next five years to replace the amount of stock that is being lost. When you speak to local young people, particularly in places like Skye and Mull, their stories are really depressing and really sad because they have got good jobs, family connections, they either want to stay or they want to return to their home. Of course, the Scottish Government is really promoting repopulation, and yet the critical factor of available affordable housing is hugely impacted by the loss of so much stock to this type of activity, which, as we have already said, of course, is commercially providing a much, much better return than either living in it yourself or renting it out of the local plumber and his family. I think that the answer is there to see. I would urge all the committee members to, if they have not already read the recent report that Place and Community Landscotland put together, which gives some really compelling evidence on the impacts of this type of activity in the north, in the west and in the islands, on the Ayrshire coast, in places like the Cairngorms and the East Newark. As we have said, it is not across all of Scotland, but it is across enough areas of Scotland to require a nationwide scheme. I called on you, Andrew, but maybe you do not have so much of a rural perspective. If you want to come in on that and then, Tony, I see that you want to come in too. I think briefly, convener. Edinburgh had always argued for a discretionary scheme, albeit that there are mandatory elements. I would make the point that you have to take the licensing scheme plus the planning controls and its totality, and that maybe for more rural communities it is the planning controls that might be the more effective way of looking at this, and local government up and down the country will balance between those two schemes to try and find a solution that meets their local needs. I think that that is what Edinburgh advocated, given local authorities that discretion and freedom to tackle local problems. Thank you very much for that. Tony? Just partly to echo that, licensing schemes under the Civic Government Act operate across all 32 local authorities that are all very different. Those authorities understand that areas and they operate those schemes in a way that is right for those communities, and they are accountable to their communities where we have an election coming up in May, in which they will be held accountable. As Andrew said earlier, there is an issue here about the Scottish Government trusting local government, but acknowledging local government swaying it within its own sphere of government, within its own range of democratic accountability, those schemes can operate flexibly. That is not a one-size-fits-all, because the Civic Government Act does not operate as a one-size-fits-all, and councils in Moray Council or Angus Council or Dumfriesen, Galloway or Argyllum but will not be saying, while Edinburgh is doing it this way, so we would better be saying how do we make this work in our communities for our industry and for our economy. One of the critical issues here is, can we just trust local government, we know what we are doing, and they know what they are doing to get on and manage those schemes effectively? I would like to bring in Mark Griffin, who has some questions. My question is following the discussions that we have just had. The first question was about data, and the second question was about how we do that to any system locally. Perhaps I can come first to Andrew, since he talked about study work that took place in Edinburgh in 2018. My question will be around do we know how many short-term leps there are in the country? Do we know the scale of the issue that we are regulating for? If we are doing this in the absence of any data, can we be sure that we are going to get it right? I will put that first to Andrew and ask it if there has been any refresh of that 2018 study, so that we perhaps know the scale of what we are trying to accomplish. I do not agree with the industry that we do not have any idea of the scale. One of the problems that we face is the lack of transparency in the industry. Local authorities such as Edinburgh have made some attempts to quantify the market. I know that the Scottish Government has commissioned consultants at various points to quantify the market, and the industry at various points has given statistics to both Edinburgh and the Scottish Government, which quantifies the market in terms of thousands. The Conservative estimate going into the pandemic was that there were about 12,000 short-term leps operating in Edinburgh. I suspect that that number may have dropped somewhat just because of travel restrictions. However, I see no reason why the market would not return to that level once the travel tourism returns to pre-pandemic levels. One of the core benefits of the licensing system is that it will allow us to know accurately who is operating, where they are operating, and design a system to deal with that. In Edinburgh's case, our working assumption is that north of 10,000 will be applying for a licence, and we will put in place processes to manage that. I think that the idea that thousands of properties will just voluntarily leave the market, I am not sure that there is much evidence from other licensing schemes being introduced, which would bear out the idea that existing industry or existing businesses would just retreat from what is a market that is operating. There is some data, of course. The Scottish Government referred to just those listings on Airbnb in the whole of Scotland, which was 31,884 in 2019, and they were active in those listings. That is just one. We know that there are booking.com and Scottishers. The issue, of course, is that there is no transparency because there is no licensing system. So, nobody actually knows the exact number because we do not have any way of collecting that data. The other way of checking is for those properties that have applied for small business rates relief, as letters of holiday business and councils do, of course, have that data. That is coming back to Andrew McLean and Tony's point about local authorities probably being much more clearer on the ground as to the numbers, particularly in hotspot areas where they are causing a problem. You have an issue with transparency and numbers because we do not have a licensing system and it enables lots of people to operate under the radar. Locally, there is probably quite a lot of information that local authorities can use to help to design the licensing system at a local scale. That brings me on to my second point. Just to ask the panel whether we feel that a national system is something that needs to be introduced or whether there are particular local authority areas that would rather not expend the resources to do that for what they would perhaps locally see as not a pressing issue. I will kick off with Nicola to ask whether Police Scotland has any data on issues around anti-social behaviour in the first instance, whether that is common across the country or is much more localized than if anyone else wanted to come in on issues of a national versus devolving powers to local government, to run local areas and welcome any indication? Thanks, Mark. Obviously, in respect of anti-social behaviour and what is attributable to short-term lets, as alluded in the written submission, unfortunately, we do not have a way of recording that at the moment. Obviously, we can of course record anti-social behaviour as a whole but we cannot attribute what proportion of that is attributable to short-term lets specifically due to it being unlicensed at the moment. That is obviously one of the challenges that we have got and a benefit of a licensing system. In addition to the obvious fit and proper person perspective, it would allow us to be able to check in our national licensing system and see how many short-term lets we have got registered and then take it from there as to any problems that were identified in local policing divisions but, at the moment, we do not have those figures, unfortunately. Thank you for that, Nicola. It looks like Andrew, Tony and then Leon would like to come in. Thank you. I suppose that I would struggle to identify the benefit of a national system. The consequence of that would be to remove flexibility to deal with local circumstances and you would, in effect, be imposing a one-size-fits-all on the whole of Scotland. I suspect that nobody would end up particularly happy. I think that Edinburgh would be unhappy that the scheme was not strong enough for its local needs, whereas Highland or Moray would be unhappy that the scheme was too onerous given the circumstances that they find themselves in. I would struggle to identify any real benefit from a national system, other than command and control, in terms of centrally dictating what the system does. Licensing schemes operate in many categories of businesses that we have discussed this morning, and I would say no reason why local government should not be trusted to get on with implementing a local scheme that meets the local needs. Thank you, Andrew, and can we bring in Tony? I confess that I slightly misinterpreted the question when I first heard it, so I will answer it in two ways. First, if the suggestion is that a national scheme would be run from Edinburgh, I think that the principles of specificity would suggest that that is absolutely not the way to do this, that local authorities ought to be and locally controlled organisations ought to be the ones that are delivering this scheme. I cannot understand why you would make a suggestion like that when we already have 32 organisations that are well experienced and perfectly capable of operating a civic government that act licencing scheme within their local area in an appropriate way. However, if the alternative is—my initial interpretation is why don't we just have a scheme that covers the hotspots or covers the areas where there are problems? The safeguarding issues are national, so we need a scheme that is capable of being in place across Scotland so that the safeguarding issues in particular are there for every community where short-term nets are operating. Thank you, Tony. I have interpreted the question as referring to having licencing schemes in places where there are hotspots. We need to have that operating at a national level. That is actually more helpful for businesses as well, because then they know exactly what they need to do if their short-term net owners are working across a number of different local authority areas, then the legislation is the same and they are not having to mix and match depending on where they are operating. That needs to be implemented across the board. Ultimately, that is more helpful for businesses and for communities. We have a little bit of time left. You have been all very good and succinctly answering the questions. I just wanted to open it up and see if there is anything else that any of you feels really important that we need to hear or that you want to underscore. If you want to put an R in the chat, that would be great. I am particularly keen, Nicola, because you have not really had a lot of opportunities here. If you have anything else to add that you feel like it has not been aired, that would be great. I am just looking for Rs in the chat if anyone wants to come in on anything that may not have been covered. I will let that be for a moment. I will start with Andrew and then Elsa. If others want to come in with anything else that you think of, please put an R in the chat. I was just one of the point raised by the panel last week that the operation of the licensing scheme could, in effect, allow a de facto ban. It would be just to give the committee reassurance that the protections in the 1982 act, which is fairly comprehensive in how applications will be dealt with in licences, is granted. Simply would not allow that to happen. If an operator is seeking to renew a licence provided that they apply before the licence expires, the licence would continue in effect until a decision is made. In terms of that aspect of potential disruption to businesses, which they were foreseeing, simply would not happen. The vast majority of operators, we are sure, are good actors. We want sustainable tourism. All of our members in community land Scotland want sustainable tourism, but coming back to Tony's point earlier, there can be such a thing as over-tourism, where the benefits of tourism are hugely outweighed by the disbenefits of tourism. That is felt by local people, so they must have more of a say in how that is managed. That is the first point. The second point is that we know that some of the big global corporations will take every opportunity to challenge licensing, to challenge new schemes, to challenge new systems. There are lots of court cases, including where they have been fined. We need to be cognisant of that and recognise that a self-administered registration scheme, given that context and the background of how some of those intermediary agencies operate, would be completely pointless. We need the backing of the local authority and Scottish Government to better manage that for all the good actors out there and the good operators, as well as to manage the bad operators. Tony Leone I will go back to the suggestion from the cabinet secretary that natural names would be taken off the licensing scheme. I have no idea why that suggestion has emerged. I am not aware of any other schemes in which the named operators are not identified in the scheme. I have a small concern. I was a member of the working group on this that was met throughout 2021. The issue was never raised in that working group. It was never discussed that the operators didn't raise it and it emerges in the cabinet secretary's letter after the operators walked out of those conversations. There is just a little bit of a concern in there about transparency in the process but also the effectiveness of extremely well-resourced and very well-targeted lobbying, which I suspect is what has brought that about. However, I do not understand why natural names would not appear on the register. It seems to me to be a layer of removing transparency, but it is a dangerous precedent, because it is not something that we see in other schemes. Tony Leone Thank you, convener. I follow on from the point that Ailsa was making. It is absolutely true that the vast majority of operators in the stock-term-led rental market are professional in what they do, and many are complying with everything that they need to at the moment. The licensing scheme will not put undue burdens and new pressures on to them, but what it will do is make sure that everybody understands that the Sdl dector is professional, that it is licensed, and that people are paying the taxes that they are due to pay. That is so important as we look to have tourism recovery. We want to have communities behind tourism and welcoming visitors back. I think that the licensing scheme can be an important part of that. Thank you very much. I just want to check, Nicola Dey. Would you like to come in with some final words? It would be most welcome. Yes, absolutely, I could. Thank you, convener. As I mentioned before, there is existing legislation that is open to ourselves to use at the moment in respect of antisocial behaviour. However, it has limitations, and that presents us challenges. Of course, we want to support the local communities and local authorities as much as we can to prevent antisocial behaviour issues and the potential for criminality in the sector of short-term lets, and ultimately to ensure the safeguarding of the people who are using those properties. By the licensing system, that would allow us to check whether those people are fit and proper persons, to be the owner of such premises, and to achieve consistency and bring it more in line with other areas that are licensed, and the details of which are kept in our national licensing system. It is acknowledged that there will be a resourcing impact on local authorities and ourselves on the introduction of the system, but I think that the benefits outweigh the disadvantages of that. Thank you very much. That has been a very informative session, so thank you very much for joining us on the panel. I take your point about needing to get more community voices in the space, but I trust that we have managed to air out all the views here. With that, I want to say thank you very much for joining us, and you can now leave, and we are going to continue on to our next agenda item. Thank you for the opportunity to contribute.