From: Redacted
To: Legal Postbox (shared mailbox)
Subject: For the attention of Redacted - ICIA consultation response from Redacted
Date: 22 June 2025 16:52:12
Attachments: image001.png
Dear Redacted
ICIA consultation response from Redacted
I am writing on behalf of Redacted to respond to the representations made to North Ayrshire Council (NAC) regarding the Island Communities Impact Assessment for Cumbrae in relation to the second homes council tax premium. I will not restate the clear case that Redacted presented in challenging the ICIA. The comments below are restricted to an assessment of the representations made.
The fact that 129 representations were made highlights the significance of this matter to the island. 126 of those representations were critical of the second homes council tax premium, sending a clear message about our community's opinion.
We trust you will properly consider these representations when making a determination on this review. Concern has been expressed by several of those making representations that the views of the community were ignored following the initial consultation on the introduction of the second homes council tax premium, and the expectation is that the views of the community will be ignored again now.
It was clear from the committee debate on this matter that even though 59% of the initial consultation responses were against the policy (compared to just 38% in favour), the local authority was determined to push it through. In this latest consultation, focussing specifically on Cumbrae 97% are opposed to the policy. The widely expressed view is that while the policy might be appropriate on the mainland or on Arran, on Cumbrae, the effects are already devastating.
The representations tell a consistent story that is unique to Cumbrae:
- Many of the second homeowners on Cumbrae have owned their properties for generations. They have been handed down from one family member to another, and some were purpose-built as second homes more than 100 years ago.
- Others have bought properties that have been on the market, unsold for considerable time - sometimes for years.
- These properties are occupied for a significant proportion of the year, often by extended family members and friends, as well as by the owners.
- Second homeowners are not just visitors, they are embedded in the community. They have friendship and support networks on the island, they are active members of community groups and many intend to retire to the island.
- They spend money on the island, supporting local businesses, shops, bars and restaurants, and it is these people that prop up the island's fragile economy in the off season, when day-trippers are not here and holiday lets are empty.
- The properties they occupy are typically small flats in old properties. Some are unheated, and most have little or no insulation. They are entirely unsuitable for permanent occupation by working families.
- Many second homeowners do not have the money to absorb the additional cost of the council tax premium. When they purchased their property, many benefited from a 50% discount recognising that they were not using island services all the time, and they were paying full council tax elsewhere. They are now paying a 100% premium. This is an increase of 300%, in addition to the normal increases in council tax. Despite this, they are ineligible to vote in local elections.
- Many face a stark choice. They can either sell their property and leave the island, or they can reduce their spending on the island and the maintenance of their property so they can pay the extra council tax. Either option is bad for our small community, taking money from our fragile economy to bolster NAC's finances. The island has a total economic output of just £12.9 million, and the council tax premium places a total charge of more than £500k a year on Cumbrae. This is totally disproportionate.
- Business owners have also made representations, expressing their concern at the impact this will have, and we are already hearing reports of a surge in second homes being put on the market, but without any demand to buy them.
What is clear is that nobody seriously believes this policy will have the outcome NAC intends. It is not good enough to wait for this to be confirmed by future monitoring, that will be too late. Urgent action is needed now to prevent Cumbrae from entering into a spiral of decline at the hands of NAC, and to ensure that its special circumstances are recognised, as required by the Islands Act.
To deliver the intended outcome of the policy, first, a detailed study of the second homes on the island should be undertaken to assess their condition and to consider the viability of possible alternative solutions for retrofitting and altering them to make them suitable for permanent occupation by working families. A programme of works will then be required to upgrade those properties that need it. If this is not possible, a reduction in, or exemption from, the council tax premium should be considered for Cumbrae, in particular for smaller properties.
Finally, I would be grateful if you could explain to me the process that you will now undertake in order to make a determination on this matter. In particular, please can you clarify how you will ensure that the determination is impartial. We are concerned that the legislation allows NAC to review its own ICIA, and we are seeking reassurance from you that the review will be carried out entirely independently from the process that created and accepted the ICIA.
I look forward to hearing from you.
Kind regards
Redacted