Amid growing calls for controls on Airbnb style short-lets sucking housing out of residential use, the Government is conducting a 'Call for Evidence' consultation on a registration scheme. We suggest you respond by email (suggested template below).


You need to respond by September 21st for your response to count.


The email address for responses to the Government Consultation is [email protected] - please copy us in at [email protected] so we can keep you up to date on our campaign.


Here is our suggested template, which you should feel free to embellish with examples or experiences from your area:


Dear Sir/Madam,


I am writing to submit a response to the government’s call for responses over a proposed tourist accommodation registration scheme.


I am pleased that the government is considering taking action with respect to short-term and holiday accommodation platforms, which currently operate almost without regulation in England. But I am concerned that the proposed measures would not allow councils to address the central problem of short-term lettings, housing. Namely the rapidly increasing numbers of commercial short-term lettings, which affect the availability and quality of housing for long-term residents, whether renters or owner-occupiers. While continuing to allow the proportion of short-term letting hosts who are genuinely ‘home sharing’ to continue benefiting from the platforms, there must be a greater balance between their needs and those of the local residents.

Your call for responses asks for responses to a number of issues, but I want to respond specifically to 1, 2, 6, 7, 8, 9, 10, 11 and 12.


Question 1 asks for evidence illustrating the size and nature of the short-term and holiday letting market in England. I am concerned that this question risks soliciting non-independent research commissioned or produced directly by short-term lettings platforms who have refused repeatedly to provide their raw data, and whose baseline assumptions cannot be verified. I therefore want to ask that the consultation bases its report on independent research, and data, such as those provided by InsideAirbnb and AirDNA. For example, research from London Councils (2020) suggests that one in 50 homes in the capital is let on a short-term basis.


Question 2 asks about the benefits of short-term and holiday lettings. There are some important benefits of using platforms such as Airbnb in cases where listings are not offered by commercial landlords. Unfortunately, research such as Adamiak (2019) and data from InsideAirbnb and AirDNA show that the majority of listings and Airbnb revenue are made up of commercial lettings which are not the primary residence of the landlord. Here, the costs outweigh the benefits, as I explain below. Furthermore, the use of statistics generated about the economic benefits of Airbnb listings for communities are problematic in several ways. They assume that long-term residents who might otherwise occupy a property do not consume goods and services. It ignores that long-term residents tend to work, pay taxes and contribute to these communities in a range of diverse ways that they cannot if properties are instead used for short- term visitors. Any credible analysis of the economic benefits would need to compare how much tourists using entire house short-term lets spend on the days they stay there with residents who live there all year round. Claims that Airbnb support new jobs and consumption are based on the assumption that the money spent by those staying in Airbnbs is money that would not have been spent if they were staying in other accommodation. Yet research such as Guttentag (2016) and Morgan Stanley Research (2017) shows that most visitors - between 96 and 98% - would still have undertaken their trips had Airbnb not existed. That means that claimed benefits of Airbnb are likely to be redistributions of consumption from traditional accommodation providers, which pay business rates and relevant taxes. The cost to the economy of Airbnbs also includes the cost of replacing houses, which research shows far exceeds the value of visitor spending.


Question 6 asks whether the increase in short-term and holiday letting in England has had adverse consequences on the housing market. I consider it to have had a major impact - and independent and peer-reviewed research demonstrably shows this. Increases in commercial listings have led to increased rent and gentrification. This has been shown to be true for all cities where independent research has been conducted, including (for example) New York (Wachsmuth and Weisler, 2018), Boston (Horn and Merante, 2017), Barcelona (Cocola-Gant 2018, Garcia-Lopez et al, 2019) and Lisbon (Cocola-Gant 2019). Many authors have also documented a relationship between growth in Airbnb listings and increases in private rental costs (Sheppard and Udell 2016, Zervas et al 2017, Barron et al 2017). In London, rises in Airbnb have also been shown to produce moderate and statistically significant rises in house prices (Todd et al 2022).


These adverse impacts are associated with the widely documented trend towards using property as an investment in the short-term rental market worldwide and in England. This highlights that terms like ‘home sharing’ and the ‘sharing economy’ could only be reasonably applied to a minority of cases. Adamiak (2019), for example, highlights that globally, 59% of listings are ‘professional accommodation offers’, a figure which rises to 92% if entire home rentals and multiple room listings are included, with only 8% being single rooms. Recent estimates suggest, for example, that entire-home listings account for 58% of London’s Airbnb listings, 60% of those in Greater Manchester, and 62% of those in Bristol (InsideAirbnb 2022). An industry of property management companies now allows landlords to play little role in ‘hosting’, with more than ten firms operating even in the medium-sized market of Manchester (Berry et al 2021).


Question 7 asks about whether noise, ‘anti-social’ or nuisance behaviour in short-term and holiday lets in England is a problem. I consider this to be a major problem. Councils appear not to be systematically gathering evidence on the issue because it is rare to have particular named leads on the issue, and research also suggests most people are unaware of how to make a complaint against a short-term or holiday let (Berry et al 2021). Part of the problem is that short- term lets are commonly used as party houses, yet are located in residential neighbourhoods or blocks of flats, which cause great discomfort to local residents. Short-term, large-group lets also attract events and occasions such as stag weekends. The house goes from being a home in a residential street to a leisure destination location, making the interests of neighbours and guests often sharply divergent (e.g. Berry et al 2021, Richards et al 2020).


Question 8 asks whether there are other adverse impacts on local communities and residents. The answer to this is yes. There are many issues, which include parking problems, fragmentation of communities;lack of use of local facilities such as libraries, schools, playgroups or of civic activity such as residents associations; anxiety and mental health of neighbours; loneliness for permanent residents and lack of support for elderly; shift from stable jobs and poor employment conditions for locals in hotels to insecure work in Airbnbs; vacant properties presenting security risks to neighbours, and loss of income for local businesses.


Question 9 asks about the most appropriate form of government intervention in the short-term letting market. Here, I think we need changes that allow councils the power to refuse further increases in commercial entire-home short-term lettings. It is planning regulations in England that deal with how land is used. Therefore in order to protect housing, short-term lets should be given their own planning use class so that owners are required to seek planning permission before turning a home into a short-term let so that local authorities are empowered to say no depending on local housing pressures and other concerns. This is the only way to stop the loss of housing for locals to tourism. Currently in England, most short-term lets fall within Class C3, the same as a home, or are undefined. We note that Wales is bringing in a new planning use class that distinguishes between primary homes, second homes and properties for short-term lets so that local authorities will have the powers to require that planning permission is sought to change from one to the other. Scotland has given councils the ability to apply for “Short Term Let Control Zones” where they can refuse permission. Registration and licensing on their own can at best serve to improve the conditions and management of short-term lets. They will do nothing to stem the loss of housing and the devastating impact on communities. The powers for councils to limit or ban numbers of short-term lets should be at the heart of this consultation. Without such powers, communities will continue to lose houses to short-term letting with the only difference that they will be registered or licensed as they go.


Question 10 asks about the costs and associated burdens of these options. I disagree with the implication of this question, which is to suggest that the current lack of regulation has no costs. The costs and burdens of doing nothing will become increasingly costly and burdensome to the government and to local authorities. Currently, lack of control on numbers of short-term rentals increases noise, rubbish and nuisance complaints to local councils, and increases housing pressures by removing homes from residential use year-round in the case of ‘whole home’ short-lets. The costs for implementing regulation that allows further housing losses to be controlled should not be borne by councils, but be recoverable from hosts through a scheme of licensing charges.


Question 11 asks about insight or evidence on the impact of schemes that are already running, or approaches taken elsewhere in the world. It is widely recognised that without legally mandated supply of data from the platforms, and some form of mandatory licensing or permit scheme, it is almost impossible to gain reliable estimates of the scale of the sector and its problems, let alone being able to control numbers in high-use areas or in housing associations / social housing / affordable housing. Dozens of cities have adopted schemes with some success on these counts, as documented by Colomb and De Souza (2021).


Finally, question 12 asks about the impact of the Deregulation Act 2015, specifically changes made by section 44 to the Greater London Council (General Powers) Act 1973. The data since deregulation has shown day caps to be a very poor solution to Airbnb’s impact on housing. We reject the London model where planning permission is only required for houses letting for more than 90 nights per year, and we reject proposals regularly put forward by Airbnb for a cap of 120 or 140 days for the same reason. Many family houses letting to large groups will bring in within 20 weekends the same income as if let to locals all year round. Furthermore, a house that is short-term let for 90 days has little use as a permanent home for long-term renters for the remainder of the year. The Greater London Authority analysed data on short-term rentals (STRs) from 2015, the year of deregulation, to 2019. It showed that the total number of STRs increased four-fold across London, from 18,440 to 80,770; that entire-home STRs (commercial short-term lettings, not home-sharing) made up 1.2% of the city’s dwelling stock. This is highly concentrated in some areas: entire-home STRs accounted for more than 1 in 20 houses/apartments in Westminster. There is also extensive evidence that the 90-day rule is proving difficult to enforce (e.g. Ferreri and Sanyal 2018, London Councils 2020, GLA Housing and Land 2020, Lynn and Allen 2017).


Yours sincerely,

 [suggested draft ends]

The Government Consultation page is here: