Executive Summary
This submission constitutes a formal objection to the designation of a Short-Term Let Control Area (STLCA) for Mull and Iona. As the representative body for the islands’ hospitality sector and in particular, accommodation, VMI stress that this sweeping policy will inflict severe, irreversible damage on our island communities.
The council’s “Statement of Reasons” relies on flawed assumptions regarding housing markets and overlooks the structural realities of an island economy. Rather than resolving the housing emergency, this policy will choke the primary economic engine of Mull and Iona, reduce visitor capacity, and devastate the supply chain that sustains local livelihoods.
Severe Economic Harm & Interdependence
The Statement of Reasons treats the short-term let sector as an isolated housing variable, completely ignoring its role as the foundation of the islands’ broader economies. Accommodation providers do not operate in a vacuum. Every tourist bed-night lost directly reduces the viability of our local restaurants, pubs, boat tours, wildlife guides, and retailers. The sector directly employs and sustains local tradespeople, property managers, laundry services, and cleaners. Capping or reducing short-term accommodation will trigger immediate job losses and income reductions for year-round island residents.
Lack of Economic Impact Assessment
It is unacceptable that Argyll and Bute Council has failed to produce an independent, comprehensive Economic Impact Assessment or an Island Communities Impact Assessment prior to this consultation. Proceeding without this data risks sleepwalking into an island recession.
Flawed Logic and Lack of Housing Delivery
The council’s central thesis—that restricting short-term lets will automatically yield affordable homes for permanent occupation—is fundamentally inaccurate on a remote island setting. Forcing a self-catering business out of operation does not translate into an affordable long-term rental. Due to exceptionally high island renovation costs, logistics, and property values, these homes are far more likely to be sold as empty second homes, inherited family retreats, or left entirely vacant. Short-term lets frequently provide crucial financial buffers that allow islanders to remain in their homes, or they provide temporary, flexible accommodation for essential seasonal workers (including NHS staff, agricultural workers, and hospitality staff). Removing this flexibility will worsen recruitment crises for other island employers.
Punitive Regulatory Burden
The timing of this proposal places an unsustainable regulatory burden on small, independent businesses already reeling from successive policy shocks. The accommodation sector has already absorbed massive administrative and financial costs to comply with the Scottish Government’s Short-Term Let Licensing scheme. Layering a mandatory planning permission requirement on top of licensing introduces severe market friction, cost, and bureaucratic gridlock. Requiring a “Change of Use” application with no guarantee of approval removes all asset security for business owners. It suppresses property values, blocks business financing or bank lending, and prevents operators from passing viable livelihoods on to the next generation. In addition, accommodation businesses are faced with the pressure of the introduction of an inappropriate visitor levy at a time when years of severe ferry disruption is showing no sign of recovery.
Retrospective Risks and Retraction of Rights
While the council notes that an STLCA formally targets “new” change of use applications, VMI membership remains deeply concerned regarding retrospective policy. Operators who have run lawful self-catering businesses for years without formal planning consent face major legal vulnerability. If established, licensed operators are required to obtain retrospective Certificates of Lawfulness, they could face closure during routine reviews or licence renewals. This risk arises if the planning department does not clearly protect their right to continue operating under the rules that previously applied.
The Action required for the Housing Emergency on Mull and Iona
VMI is very aware of the housing pressures on Mull and Iona, but we reject the strategy of destroying one vital sector to salvage another.
The housing crisis is a failure of supply, not a symptom of tourism. The council must prioritise building dedicated social housing and key-worker accommodation and target long-term empty properties rather than penalising active, tax-paying, job-creating commercial businesses.
Conclusion
An STLCA on Mull and Iona will not build a single affordable home. It will, however, systematically dismantle the tourism infrastructure that keeps our island economically viable. On behalf of our membership, VMI strongly objects to this proposal and urge Argyll and Bute Council to withdraw it immediately in favour of an independent, island-specific economic assessment.
How to respond to the STLCA Consultation
If you havent already done so, you can submit your response on the Council website portal which takes around 20 minutes. You can upload a complete response document at the end of the questionnaire. If the Control Area proposals affect you, please do respond, the Council has to acknowledge views of the general public. If you have time, please also contact your local councillors and MSP/MP
Amanda Hampsey (Reform UK) Email: amanda.hampsey@argyll-bute.gov.uk
Willie Hume (Scottish National Party) Email: willie.hume@argyll-bute.gov.uk
Andrew Kain (Independent) Email: andrew.kain@argyll-bute.gov.uk
Jim Lynch (Scottish National Party) Email: jim.lynch@argyll-bute.gov.uk
Jenni Minto – MSP for Argyll & Bute – jenni.minto.msp@parliament.scot
Brendan O’Hara – MP for the Argyll, Bute and South Lochaber – brendan.ohara.mp@parliament.uk