Response 234187652

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Questions

1. For Paper 2: Draft Licensing order - please state your issues and how to resolve them:

Please provide any comments and any suggestions you have to resolve this
As a Chamber of Commerce representing over 400 members from all sectors of the economy we outline below the most significant concerns we have with this legislation. Organisationally we are not opposed to measures that ensure we continue to offer a safe and internationally competitive visitor product that puts our remote rural communities at its heart. We believe that the vast majority of businesses in the Cairngorms already achieve this.

Premises captured by this proposed legislation underpin the economy of the Cairngorms National Park. There is little evidence of the ‘controversy’ within the National Park as stated as fact in 1.1 of paper 1.

Non-serviced accommodation accounts for 2m visitor days per year and £100m of our £257m visitor economy (STEAM 2019). Of course a very significant (majority) portion of serviced accommodation will be captured by this legislation and this accounts for £152m and 1m visitor days. We have seen non serviced demand grow in proportion to serviced pre pandemic and this has accelerated post pandemic.

We believe the the legislation needs be amended to account for the following concerns:-

1. Investment

It is imperative that Scotland maintains and grows its international competitive position as a destination. Private sector investment in quality at all levels will be critical in achieving this and to keep pace with increasing international and domestic visitor expectations.

We believe that, as drafted, the legislation will provide a disincentive for long term investment in quality and a decline in the ability of businesses to borrow to support such investment. This will have a knock on effect to the supply chain (local builders, joiners, electricians etc) and therefore have a negative economic impact on the communities the legislation is setting out to protect.

Legislation must give businesses long term security of tenure to enable long term investment for the benefit of our economy and communities who rely on it.

Scotland Outlook 2030 has an ambitious vision of being a 'world leader in 21st century tourism' and a mission of growing 'value and positively enhance the benefits of tourism across Scotland by delivering the very best for our visitors, our businesses, our people, our communities and our environment.' We will not achieve that if we choke private sector investment and we believe this needs to be addressed in the final legislation.


2. Short Term Economic Impact

The cost and bureaucratic burden of this legislation will result in reduced capacity for visitor accommodation in the period leading up to 1/4/21.

Given that during the summer season we are often at 100% capacity in the National Park this can only result in a shrinking of our tourism dominated economy as we look to recover from the pandemic, grow our economy and ensure the sustainability of our communities.

Many operators within the Cairngorms (B&B and Self Catering) are very small businesses. Many have been operating professionally and successfully for many many years, they are part of the community they support. The bureaucratic burden and cost of evidencing there proven track record will be disproportionately borne by these smaller professional operators and will result in many withdrawing from the market causing economic contraction and damaging our communities.

GENERAL COMMENT

Housing For People Who Want To Live in, Work in and Care for our National Park

Nowhere in Scotland is the economic disparity between wages and house prices more pronounced than in the Cairngorms National Park. Nowhere is the economy more restricted by a lack of housing for local people than the National Park.

Shrinking our economy cannot be the answer to resolving this challenge and we believe that this legislation and thoughts of reallocating existing housing stock should be decoupled from this conversation.

We believe that there are solutions to the housing challenges we face and those solutions are aligned to the 2040 strategy and existing mechanisms such as the rural burden. We are working with Government, Local Authorities and other partners to find innovative models to unlock those solutions.

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Cairngorms Business Partnership