13/05/2026
Why the proposed STL control area proposed by Highland Council will not achieve its objectives.
The evidence conflates two separate problems. The Statement of Reasons presents high external buyer rates, elevated house prices and housing unaffordability as evidence that STL restriction is justified. However these are symptoms of a structural mismatch between rural wages and property values that predates and exists independently of the short-term let sector. The document does not establish a causal chain between STL activity and housing unaffordability — it establishes correlation between external purchasing, high prices and STL concentration, which is not the same thing.
The external buyer premium is misinterpreted. The Statement cites the fact that external buyers pay 24-27% more than local buyers as evidence of market distortion caused by STL investment. However this premium partly reflects selection bias — external buyers purchasing higher specification, better located or more scenic properties — rather than demonstrating that their presence inflates prices across the market as a whole. The document does not disaggregate these effects.
The school closure evidence is presented misleadingly. Mothballed and closed schools are cited as evidence of STL-driven depopulation. However the council itself acknowledges that STLs are not the sole contributor to these closures, and that second homes — a separate and larger category — have consistently been more prevalent in these areas. Many of these school closures predate the significant growth of the licensed STL sector entirely. Using them as justification for an STLCA overstates the connection.
The Badenoch and Strathspey precedent is not addressed honestly. The Statement references the existing STLCA in Ward 20 as a model and notes that STL growth slowed following designation. It does not acknowledge that the two-year review of that area found zero additional affordable homes created, increases in both empty homes and second homes, and house price growth above the Highland average. If the Statement of Reasons is to rely on this precedent it should address these outcomes directly rather than citing only the reduction in STL applications.
The statement contains no economic impact assessment. A Statement of Reasons for a designation of this geographic scale — covering eight wards, multiple island communities and some of Scotland's most tourism-dependent economies — should address the economic consequences of the proposed action. It does not. There is no assessment of visitor displacement, job losses, business closures or the impact on communities where self-catering accommodation is the primary or only overnight provision for tourists. This is a significant omission that undermines the document's credibility as a balanced evidential basis for designation.
The proportionality of the response is not justified. The STLCA applies uniformly across a vast and diverse area. Communities with very high STL concentrations such as parts of Portree and Skye are treated identically to remote rural areas where a handful of properties are involved. A blanket control area is a blunt instrument where a more targeted, evidence-based approach to specific high-pressure communities would be more proportionate and less economically damaging.
The statement does not consider alternative interventions. A robust Statement of Reasons should demonstrate that less restrictive alternatives have been considered and found insufficient. The document does not engage with alternatives such as targeted action on empty homes, additional affordable housing delivery, enhanced licensing enforcement, or community land initiatives — all of which address the underlying housing supply problem more directly than planning controls on secondary letting.
