Democracy Spraffa

Appendix 2 - Objections and Support

Perth and Kinross Council · 8 June 2026
Back to Licensing Committee — 8 June 2026 and its agenda

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Mr. David Jegier,
Parkview, Ferry Road, Pitlochry, PH16 5DD
30/01/26 
To the Head of Legal Governance Services 
I revoked my original objection previously submitted on 16/01/26. I would like this revised objection
document, in its entirety, to be accepted in its place due to additional information.
Precis 
The Heartland Festival does not comply with and contravenes multiple processes, guidelines and legislations
applicable to its licensing and operation and to the site itself; these are fully argued, documented and
referenced in the accompanying document but are summarised here:
1. Non-compliance with the licensing application process. The Site Notice shows the date of application
as 07/01/26 but itself was not publicly displayed until eight days afterwards on 15/01/26 
2. Failure to as yet submit a separate licensing and hire application for an additional third evening event
“An Evening With…” advertised, promoted and ticketed as a “separate event” to Heartland itself. 
3. The event does not meet nor comply with Para. 15.5 of PKC Community Greenspace CONDITIONS OF
HIRE/USE in regard to not exceeding the required Music Noise Levels (MNL)
4. Non application of the Noise Council Code of Practice on Environmental Noise from Concerts 1995, or
any equivalent replacement guidelines to limit disturbance to the surrounding community. 
5. Disregard of and Non-Compliance with PKC 'Safe and Legal Events' guidance on ‘Venue Suitability” 
6. Blocking of access to a core footpath without obtaining or displaying a Section 11 exemption or
modification order – and originally intending that to be for longer than 5 days which would itself have
required public consultation and possible consideration by Scottish Ministers
7. Blocking of access to children’s playground/car-park/pavilion despite being outwith the approved site
boundary
8. Failure to mitigate detrimental impact of noise on neighbours, in opposition to the Agent of Change
Principle
9. Non-compliance with para. 13.9 of PKC’s ‘Community Greenspace CONDITIONS OF HIRE/USE’ due to
contraventions of environmental legislations, further resulting in potential offences under applicable
wildlife legislations.
10. Failure to require or undertake a Habitat Regulations Assessment or any other form of ecological or
environmental assessment of the site despite it adjoining the Tay Special Area of Conservation, with
the SAC and surrounding habitat hosting legally protected species
11. Licensing of the event on this site could also be considered a breach of PKC’s statutory duty to protect
and conserve biodiversity under the Nature Conservation (Scotland) Act 2004 and licensing of the
event would further be in opposition to Objective 6 of the government’s ‘Scottish Biodiversity Strategy
and delivery plan 2024 - 2030’
12. Licensing approval can also be viewed to be in further contradiction to the Scottish government
National Events Strategy, “Developing the Industry”, Part 3: "Supporting the protection and considerate
enjoyment of Scotland’s natural and cultural heritage". 
13. Operation of this event on this site is also further contrary to all of PKC's and Scottish government
climate action/net zero/ green economy/transport plans and aspirations national events strategy, event
guidance, and Pitlochry Community Action Trust (PCAT) statements about environment & sustainability
14. Contravention of PKC 'Safe and Legal Events' Guidance. Step1. Section 28. Parking Arrangements - On
and Off-Street. The 2026 event proposes to take place without supplying any dedicated parking
whatsoever for previously advertised 2,500 vehicles.

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Please find herewith our objections to the 2026 Public Entertainment License application for the Heartland
Festival Pitlochry and a now additional event on the preceding Friday evening. My submission is made in
reference to grounds for objection under the Civic Government (Scotland) Act 1982 and with direct referral to
existing governing legislation, policy, and guidances.  
For the referenced reasons here submitted, it has not been shown from the outset that this event has met or
can ever meet the conditions of hire and licensing applicable to the Pitlochry Recreation Ground site; PKC was
therefore wrong to previously approve both. The length of this submission is unfortunate, but that is entirely
due to the multiple transgressions identified in the licensing and operation of this event.
❖ “A Site Notice must be displayed at the premises or site for a continuous period of 21 days, in a
position where it can be easily read, from the date of submission of your application. This allows
members of the public to object to the application should they wish.  Once the 21-day period has
lapsed, you must remove the Site Notice and complete and return the Compliance Notice to the
Licensing Department.”1
In immediate disregard of process and compliance, the Site Notice went on display on the recreation
ground notice board on 15/01/2026 but it is showing the date of application submission as 07/01/2026
eight days prior; nor was it removed after 21 days of the submission date as also required. I pass this
notice board outside my home twice a day and have taken a photograph of it every Monday since
11/08/25 for precisely this reason.
❖ An additional third event day is being billed as ‘An Evening With…’ on 26/06/26. It is advertised on
the Heartland website2 as being “separate from the Heartland Festival 2026” and ticketed for
separately, yet no separate Site Notice has been displayed nor therefore any separate licence
application yet submitted for that event (if so required).             
12/01/2026                                                  15/01/2026                                                      30/01/2026   
1 https://www.pkc.gov.uk/media/54077/Guidance-for-Public-Entertainment-
Licence/pdf/Public_Entertainment_Licence.pdf?m=1748610973970 
2 https://heartlandfestival.co.uk/friday-night-an-evening-with/

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1. Objection: Unsuitable Location/Inability to meet Conditions/Nature & Extent/Impact/Undue
Nuisance - Noise & Residents:
In previous comments made to the media3 and I believe to the Licensing Committee, it has been stated that
the Organiser’s ‘dream' is for Heartland to “become a mini-Glastonbury” and the belief that “If you were going
to design a park area to put a festival on, the Recreation Ground is the perfect location.”
Furthermore, the Organiser claims to "...have done everything I possibly can to minimise disturbance to the
local community because I am part of that local community" while conflictingly also stating to the media
recently that the event is now “the third biggest music festival in Scotland” and furthermore, being “eager to
build on that top three slot.”4. For your information, No.1 is Trnsmt on Glasgow Green (136 acres) and No.2 is
Belladrum Tartan Heart Festival held on Belladrum country estate (1,150 acres). 
Meanwhile, the referenced Glastonbury festival is held on and surrounded by 1,500 acres of privately owned
agricultural land. The nearest habitation is a village which is 1/3rd of the population size of Pitlochry and
approximately 1Km distant from the main stage. The town of Glastonbury itself is approximately 10Km distant
to the festival site.
1.1  The Pitlochry recreation ground is a community greenspace. The event boundary, which encapsulates the
entirety of the site other than the playground, measures only some 200m x 140m (6.9 acres).
• The site is 5x smaller than the next smallest regional festival site - Bonfest, Kirriemuir, with an outdoor
stage operating on 34 agricultural acres. The nearest dwelling there is also more than 5x further away
from the front of stage than in Pitlochry.
• The site is 11x smaller than South Inch, Perth, also a PKC community greenspace on which Heartland
intends to hold a new festival in 2026.  The nearest dwellings will be more than 3x further away from
the front of stage (if in same position as previously held festival) as Heartland in Pitlochry yet the same
Music Noise Limit level as in Pitlochry will apply.
• The Pitlochry site is in the centre of a residential area surrounded by family homes. A protected Special
Area of Conservation directly adjoins it and immediately surrounding habitat and gardens host legally
protected species.  
A 2026 event in Pitlochry would take place on a site entirely encircled: the recreation ground is
immediately bordered on three sides by our closely adjoining dwellings and now a new supermarket on
the 4th side. No other regional event site comparison, or indeed ANY I can find in Scotland of this type,
size and duration takes part on or is currently licensed for a site remotely like Pitlochry5. 
3 https://news.stv.tv/east-central/heartland-festival-organiser-hopes-to-become-mini-glastonbury-for-scotland 
4 https://www.thecourier.co.uk/fp/news/5361088/pitlochry-heartland-music-festival-success/ 
5 See Attachment 1

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1.2 Approximately 96 dwellings and a hotel surround the recreation ground inside only a 300m radius of the
event sound deck from which the sound level is set. The event is therefore without question closely
adjoined by - and it impacts upon – noise-sensitive dwellings & premises. 
• The closest dwelling to the front of the sound deck (on Dundarach Gardens) is only some 118m6 and
our home is approximately 175m in unobstructed direct line - and directly overlooking the park as
multiple homes do. In comparison, the closest dwelling to the front of stage of any other current
regional event of this type is approximately 420m, or more than 3.5x as distant. 
Residents are therefore subjected to a weekend of amplified pop/rock music7 (wholly unlike other events
historically held on the site) at a sound level so clearly above the licensed limit and resonating throughout the
property it is impossible to normally use our home or any of our garden. Added to by a wholly inappropriate
site plan we were compelled to leave our home during both days of the ‘25 event having already been
subjected to the 2024 event. As such, the event unreasonably, substantially and quite definitely interferes with
the enjoyment of our property - “plus quam tolerabile” in Scottish law - and thereby creates any or all of a
public/private/statutory nuisance in contravention of PKC licensing objectives of the Licensing (Scotland) Act
20058. Multiple neighbours have also expressed to me that they also leave their homes for noise reason.
1.3 Failure to Meet or Comply with the MNL in Conditions of Hire/Use and the Licensing Conditions
Para. 15.5 of PKC Community Greenspace CONDITIONS OF HIRE/USE9 requires: “In terms of noise the Hirer
shall ensure that the music noise level shall not exceed 65dBLAeq over any 15-minute period during any
performance, rehearsal or sound check when measured outside the window of any dwelling house or other
noise sensitive premises…” and that is again a stipulation within the event license conditions (draft) at para
610. Levels not exceeding 70-75dB at 63Hz and 125Hz (i.e. Bass) are also required.  
i) I had a telephone conversation with Ms. Dawn Stewart, PKC Environmental Health Officer (EHO), on
14/10/25, at 13:30, where she kindly sought to answer my previously emailed questions to the
Environmental Health (EH) team11. From that call, Ms. Stewart’s answers confirmed to me that: 
a) Despite a reasonable public assumption that the event, first and foremost, would have provided PKC
with supporting evidence - and/or PKC would have required - that an intended event of this type on 
6 See Attachment 2.  
7 https://www.youtube.com/watch?v=Vow4Y2uIDco 
8 Microsoft Word - Licensing Policy Statement 2023 2028 Approved 2.docx  
9 https://www.pkc.gov.uk/media/43655/Greenspace-conditions-of-
hire/pdf/GREENSPACE_CONDITIONS_OF_HIRE_JAN_20191.pdf?m=636860918906070000 
10 https://perth-and-kinross.cmis.uk.com/Perth-and-
kinross/Document.ashx?czJKcaeAi5tUFL1DTL2UE4zNRBcoShgo=A7H%2b0ItrbFWRJmDe6Nlx3QJYcwgkMH%2bFhSmg1P6aX7c0DPU%
2bey%2bFrw%3d%3d&rUzwRPf%2bZ3zd4E7Ikn8Lyw%3d%3d=pwRE6AGJFLDNlh225F5QMaQWCtPHwdhUfCZ%2fLUQzgA2uL5jNRG4j
dQ%3d%3d&mCTIbCubSFfXsDGW9IXnlg%3d%3d=hFflUdN3100%3d&kCx1AnS9%2fpWZQ40DXFvdEw%3d%3d=hFflUdN3100%25%20
3d&uJovDxwdjMPoYv%2bAJvYtyA%3d%3d=ctNJFf55vVA%3d&FgPlIEJYlotS%2bYGoBi5olA%3d%3d=NHdURQburHA%3d&d9Qjj0ag1P
d993jsyOJqFvmyB7X0CSQK=ctNJFf55vVA%3d&WGewmoAfeNR9xqBux0r1Q8Za60lavYmz=ctNJFf55vVA%3d&WGewmoAfeNQ16B2M
HuCpMRKZMwaG1PaO=ctNJFf55vVA%3d 
11 See Attachment 3

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this site could meet and comply with the sound levels required by the license and Conditions of
Hire/Use, that is not the case at all and has in fact not happened.
b) The Organiser has not at any prior point involved a qualified independent Noise Consultant to
undertake pre-event noise modelling, noise mapping or noise impact assessment which would have
identified if the event was initially viable on this site from a sound limit perspective. Nor has PKC
required that information when assessing and approving the hire/use and license. From inception, the
Organiser and PKC thereby wholly failed to identify, consider, or assess noise impact on all or indeed
ANY noise sensitive dwellings or premises, despite that being a key component in meeting the license’s
Music Noise Levels (MNL) to begin with and a qualifying requirement of PKC’s Conditions of Hire/Use. 
c) Previous email correspondence I received from Mr D Stubbs12 (PKC Greenspace Coordinator -
Communities) provided information of the event timings from the event’s Noise Management Plan.
None of the pre-event audio system and stage sound tests themselves were to exceed 65dB(A).
However, Ms. Stewart stated that PKC EH somehow agreed a sound deck limit of 90dB(A) for 2025 via
“recorded sound tracks before the event started”. 
In conjunction with the absence of any prior noise modelling etc, the question has to be asked how a
sound limit of 90dB(A) or otherwise could therefore have been established? This should have required
at least one period of 15 min continuous sound (but above 65dB as the event timings officially limited it
to) being measured specifically at the windows of (multiple) noise sensitive dwellings surrounding the
site to ensure ANY sound level set at the sound deck was compliant – and with the most obvious
starting point being the closest dwellings; that testing admittedly again did not take place, neither by
the Organiser or PKC EH prior to the 2024 and 2025 events commencing. 
d) It has also been previously stated to me (in email communication with Mr. Rankine (PKC LSO) that it
was again Environment Health, not the Organiser, who had reportedly conducted sound monitoring
during the ‘24/’25 events “at various locations including the ‘site boundary”. EH were also quoted in
the media claiming “There were no breaches (of the MNL)”. In my case, the site boundary (i.e. the
recreation ground) adjoins my front garden hedge and is only 14 meters from my windows. No MNL
compliance testing whatsoever was conducted at my windows nor on my property in general.
Moreover, as stated to me by Ms. Stewart, neither the Organiser nor PKC EH undertook any sound
propagation tests whatsoever during both events at the windows of any dwellings, particularly those
closest to the noise source, despite compliance with that measure being integral to meeting licensing
and hire conditions. 
12 See Attachment 4

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Factually therefore, Heartland did not at event conception nor during planning, set-up, or in
operation, show or prove it can meet or has met the MNL required. The specific test to measure
compliance was not at any time undertaken by the Organiser or PKC EH. 
ii.) Notably, a 65dB(A) sound level is exampled in Appendix 2 of PKC’s ‘Licensing Board Policy With Regards to
Noise - Environmental Health Review’ as comparable to being only 5dB louder than that of a typical office or
restaurant environment (i.e. 60 dB(A)13. The Scottish government example of 60 db(A) is that of a normal
conversation heard at 1m. 
a) The sound deck for Heartland was approximately 25 meters in front of the main stage14. With a
claimed event sound level of 90dB(A), the use of a sound distance attenuation calculator15 indicates the
resulting sound level at the nearest dwelling (118m) would therefore be 76.52dB(A) and at my own
property (175m) 73.1 dB(A). On this basis, and in total absence of any documented counter evidence,
there is every reason to believe my own and multiple dwellings within the 300m radius of the sound
deck were exposed to MNL’s above the maximum licensed limit and terms of the conditions of
hire/use.16 Furthermore: -
• “Industry research shows that the music noise level in the audience by the mixer position at
concerts is typically 100dB(A) and that levels below 95dB(A) will be unlikely to provide
satisfactory entertainment for the audience “(see footnote 16, The Noise Council Code of
Practise on Environmental Noise from Concerts). 
• Notably, HSE event noise guidance states “Where the Event LAeq is likely to exceed 96 dB,
advise the audience of the risk to their hearing in advance...”17 
Heartland Terms & Conditions (T&Cs)18 correspondingly contains the following risk advice
for attendees: “Prolonged exposure to loud music may cause damage to your hearing.” 
If the level at the sound deck was above 95dB(A) as research indicates is an event norm and which
Heartland T&Cs appear to warn of, the above referred to limits (described at (a) above) at the nearest
and all noise sensitive dwellings would of course be higher than the limits described at (a) above. That
scenario is far more representative of the sound level we were subjected to in our home.
b) In further example, I attach my own sound reading comparisons of other uses of the Pitlochry recreation
ground. I used the US National Institution of Occupational Safety and Health (the US equivalent of the UK 
13 See Attachment 5
14 See Attachment 6
15 See Attachment 7 https://www.omnicalculator.com/physics/distance-attenuation?c=GBP&v=SPL1:98,r1:25!m,r2:175!m 
16 See Attachment 8
17 https://www.hse.gov.uk/event-
safety/noise.htm#:~:text=Where%20the%20Event%20LAeq%20is,or%20notices%20at%20entry%20points. 
18 https://heartlandfestival.co.uk/terms-and-conditions/

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Institution of Occupational Safety and Health (IOSH)) iPhone app with applicable settings, (accurate to +/-
2dBA with a calibrated external microphone)19. 
• 01/11/2025, 18:58, Fireworks night (pre-fireworks). A local pair of musicians on non-electric guitar and
with no drums/bass, singing country/folk songs through a microphone. Several hundred people were in
attendance at the time of the reading. The LAeq15mins from this small event was 68.8dB(A)20 outside
the windows of my home. An earlier DJ playing pop tracks was considerably louder. 
• 09/11/2025, Children’s football matches. Two pitches in use with 44 players and a total of only 43
spectators. The LAeq15mins from this activity was 58.6dB(A) outside the windows of my home.
It cannot at all be claimed (and is not in any way factually supported) that a significantly larger Heartland
event with 8000 daily attendees; concert size speakers; two performance stages; continuous multi-piece bands
across 11 hours per day, results in sound levels LOWER than a pair of local musicians and a crowd of a few
hundred - or a level only slightly higher than a children’s football match! I trust you can see how evidentially
unbelievable and unsubstantiated that claim about Heartland therefore is.
By definition, a site where any dwelling is not subjected to a maximum MNL exceeding 65dBLAeq15mins, is
the licensed criteria for this event and a condition of hire/use. Heartland does not meet, cannot meet and
has not been shown to meet that MNL. The extremely small site size and immediate proximity of noise
sensitive dwellings mean - and should have always indicated - this site is inherently unsuitable for this type
of event, not the opposite.
1.3 Non application of the Noise Council Code of Practice on Environmental Noise from Concerts 1995 21 or
any equivalent replacement guidelines in order to limit disturbance to the surrounding community. 
It was confirmed to me by Ms. Stewart that this is one of the Codes of Practise applicable to this event and
from which the Music Noise Limit (MNL) originates. I am of the belief and it appears self-evident that if this
Code of Practice – or its subject guidance - had been applied then this event would have been identified from
the outset as being unviable on this site.  
“The Code is designed to assist those planning a music event, those responsible for licensing such events and
those responsible for enforcing nuisance provisions”. Though ‘long in the tooth’, it still remains the only guiding
standard to best manage noise from outdoor music events and its impact on communities close to the event. It
is referenced in the Scottish Government “Assessment of noise: technical advice note”22and PKC’s “Licensing
Board’s Policy With Regards to Noise - Environmental Health Review”.23   
19
https://www.cdc.gov/niosh/noise/about/app.html#:~:text=The%20app's%20features%20include:%20*%20Noise%20Dose,the%20ap
p%20from%20the%20Apple%20App%20Store.
20 See Attachment 9
21 Code of practice on environmental noise control at concerts
22 https://www.gov.scot/publications/technical-advice-note-assessment-noise/pages/6/ 
23 https://www.pkc.gov.uk/media/42221/Environmental-Health-Noise-
Review/pdf/Environmental_Health_Noise_Review#:~:text=4.2%20The%20Agent%20for%20Change,is%20with%20the%20venue%20
operator.

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This Code was also referred to in the HSE ‘The event safety guide (Second Edition)’ at para 56424. It advised
“Refer to this source of guidance for the control of environmental music noise and its impact on communities
neighbouring outdoor music events.” 
However, the current HSE version (also known as The Purple Guide, which PKC requires adherence with)
shifted focus entirely from environmental noise control to occupational noise management instead, with the
position that event organisers would rely on local authority policies, acoustic consultants, or industry good
practice (still the Noise Council Code) to manage residential noise impacts.
i) Despite still using the MNL from the ‘Pop’ Code, PKC licensing/hire process does not in any way further
require the event organiser to follow any of that Code’s guidance or undertake the best practise pre-
event and in-event procedures. Instead, your process is entirely centred and focused on meeting HSE
legislation and guidance which itself, in regard to noise, is now concerned only with those holding the
event, those working at the event and those attending it. PKC has not substituted or replaced the ‘Pop’
Code of Practise with any other specific policies or guidance in regards to mitigating noise impacts on
the surrounding community; you have voided the topic altogether (for no applicable reasons I can find)
other than advising contact with EH and generic language of being mindful about disturbance. 
ii) As none of the recognised best practise guidance is therefore being followed, no pre-event modelling
(etc.) took place; no affected residents were identified or contacted nor PKC supplied with a list of those;
no fixed noise monitoring positions were implemented at identified noise sensitive locations; no notice
was given to residents or the general public of any monitored complaint ‘hotline’. Moreover, the
community received no information whatsoever that an EHO would be in attendance as they
reportedly were (at least in 2024). In conjunction with the absence of any sound monitoring
undertaken at the windows of the closest dwellings, Ms. Stewart acknowledged that no direct contact
was specifically made with any neighbouring residents at our homes (particularly the closest residents),
before, during, or after the events – and this is despite having made a related complaint myself to PKC
and the Organiser two days before the 2025 event started (1.4 below). PKC were on site the day before
the event started and on the day of the event itself for site checks. 
iii) Tickets are on sale for a separate additional event (through a new subsidiary company of Heartland)25
“An Evening With …” from 3:00pm to 10:00pm on the preceding Friday and extending the event to
three consecutive days and 29 hours of performance. This began being advertised (and separately
ticketed for) on social media from JULY 26th 2025 and clearly once again long before any other and
differing licensing application was submitted (at the time of this objection none has been made). Zero
contact or consultation whatsoever (from the Organiser, P&MCC, PCAT or PKC) has again been made
with neighbouring/affected residents on this further disruption and event enlargement. A 2025 post 
24 https://www.huntingdonshire.gov.uk/media/2746/hse-event-safety-guide.pdf 
25 https://heartlandfestival.co.uk/friday-night-tickets-2026/

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event survey was released on Heartland social media but that only asked questions of attendees of
their experience.
1.4 Disregard of and Non-Compliance with PKC 'Safe and Legal Events' guidance26: "As an organiser of an
event, you must at all times have regard to environmental noise concerns by taking into account whether
the venue is suited to the type of event being proposed by being aware that noise from many different
sources can occur during an event and may cause undue disturbance to local residents and neighbouring
properties. The size of the event and the nature of the entertainment will dictate the type of disturbance
that will arise and by contacting Environmental & Consumer Services in advance of the event, officers will
be able to provide advice/information specific to your event on the control of noise nuisance". 
Given the sensitivity and intimacy of the location and the non-application of the industry best practise
guidelines or any alternative for mitigating community disturbance, it is unarguable that the organiser nor
PKC fully considered, assessed or proved the suitability of the site for this amplified mass attendance
event. PKC EH has also failed to correctly monitor initial and ongoing MNL compliance (and absolved the
Organiser of any requirement to do the same) while making wholly unsubstantiated but supportive public
statements in the media that “there were no breaches” (of the MNL). 
I made a formal complaint (to the Organiser and PKC) two days prior to the 2025 event regarding:
• The siting of a Ferris Wheel less than 25m from my windows27 (where it remained anyway despite my
objection and a PKC pre-event site visit) 
• Blocking of access to the children’s playground despite it being outwith the event site boundary. 
• Blocking of a core footpath28 from Wednesday 25/06/25, 3 days before the event commenced
(PLRY/55: Riverside Path, Tummel Cresent to Bridge Road) contrary to the Land Reform (Scotland) Act
2003 - for which, as far as I am aware, no S.11 Modification Order/Exemption was obtained nor
displayed by the Organiser or PKC29. The blocking was blatantly in operation during the PKC pre-event
site visit. The Organiser had intended the access restriction to be in place for 7 days, despite exemption
from access rights longer than 5 days requiring advance approval from Scottish Ministers and a formal
public consultation process. This again highlights a blatant disregard by the Organiser and PKC toward
community disturbance, let alone toward the governing legislative requirements.
It should be further considered that for members of the Public a Site Notice provides no substantive event
information whatsoever and thereby we have no access to any of the event plans (I have twice asked PKC
for copies of the event NMP’s but they haven’t been forthcoming). It should not be left to members of the
public to ensure (or challenge) that an event has met or is adhering to the terms of a PKC license and
conditions of hire/use, or PKC site plan approvals are actually fit for purpose – and we can only do so during 
26 https://www.pkc.gov.uk/media/41357/Event-safety-guidance-full-
version/pdf/Safe_and_legal_event_guidance.pdf?m=1516881250340 
27 See Attachment 10
28 See Attachment 6
29 https://www.gov.scot/publications/land-reform-scotland-act-2003-modification-order-2013-guidance-local/pages/3/

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or after the event. The reality then becomes “we messed up, sorry, but you have to put up with it anyway”.
Allowing the event to be held again under the same circumstances simply won’t be acceptable nor
compliant with conditions of hire/use and licensing.
1.5 “Perth and Kinross Licensing Board’s Policy With Regards to Noise - Environmental Health Review”30: “The
Agent for Change Principle places the responsibility for mitigating any detrimental impact of noise on
neighbours to a music venue with those carrying out the new development or operations.” 
I believe this Principle is a wholly applicable consideration for the Licensing Committee and was from the
outset when assessing the impact on neighbouring residences of the new use of this site. It is very much a
change of use from existing events and due to the biodiversity sensitivity of the site, this use should be
considered by PKC to be a ‘plan or project’ if necessary (see 2.3 below). Heartland is unlike any other
long-standing events such as the Highland Games, Highland Nights, Etape or the occasional Circus in terms
of length, sound levels, disturbance, size and impact. Affected residents living around the site pre-date the
event being given 2024 approval yet have had ZERO consultation on its suitability nor consideration of its
impact upon us. 
• I do not believe there are any mitigation measures which can lessen the sound impact. The event
needs to be at a sound level which is viable for audience enjoyment (of 8-9000 per day); However,
that clearly results in and requires sound levels exceeding the maximum licensed MNL experienced
at site adjoining dwellings due to the confines of the site and the proximity of those dwellings.   
2. Objection: Unsuitable Location/ Nature & Extent/ Other Good Reason – Contravention of Wildlife/Species
Protections and Habitat Disturbance
Licensing of this event on Pitlochry recreation ground further contravenes government directives and multiple
wildlife legislations and I believe wrongly makes a legal activity out of what would otherwise be offences under
those. Gardens of neighbouring residences and the immediately surrounding habitat of the site - and
watercourse being a Special Area of Conservation (SAC) - are home to and/or provide shelter and access
networks to UK and European protected species and native birdlife. These nature networks “ensure that
wildlife can move from place to place and enable the natural world to adapt to change, providing plants and
animals with places to live, feed and breed wherever they are”. PKC in assessing the suitability of the site
should once again already be fully aware of that as the information comes from you31. 
• Licensing approval therefore further contravenes and is not consistent with para. 13.9 of PKC’s
‘Community Greenspace CONDITIONS OF HIRE/USE’32.  “The Hirer must ensure the
Event/Promotion must be fully compliant with all applicable environmental legislation…” 
30 https://www.pkc.gov.uk/media/42221/Environmental-Health-Noise-Review/pdf/Environmental_Health_Noise_Review
31 https://www.pkc.gov.uk/article/24381/Perth-and-Kinross-Nature-Networks 
32 https://www.pkc.gov.uk/media/43655/Greenspace-conditions-of-
hire/pdf/GREENSPACE_CONDITIONS_OF_HIRE_JAN_20191.pdf?m=636860918906070000

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• Licensing of the event on this site could also be considered a breach of PKC’s statutory duty to
protect and conserve biodiversity under the Nature Conservation (Scotland) Act 200433 
• Licensing of the event would further be in opposition to Objective 6 of the government’s ‘Scottish
Biodiversity Strategy and delivery plan 2024 - 2030’34
2.1 In the immediately adjoining wooded areas and residential gardens surrounding the recreation ground,
(most notably on the Bruach Lane, Ferry Road & Tummel Crescent side) Red Squirrell, Bats and transient
Pine Marten are resident/present. These are all legally protected species. Holding the event on this site
contravenes the Wildlife and Countryside Act, 1981.  
2.2  Schedule 5, Section 9(4)(a) of the 1981 Act prohibits the damage, destruction, or obstruction of access to
any structure or place which any wild mammal listed on Schedule 5 uses for shelter or protection; Section
9(4)(b) prohibits the disturbance of any such mammal while it is occupying a structure or place which it
uses for that purpose and it is an offence to do so unless in pursuit of a legal activity. 
I submit that it is entirely unfeasible that this event does not obstruct nor disturb these protected species
from their normal places of occupation/use which immediately surround the site and the River Tummel
which runs alongside.35 As opined earlier, as the event does not actually meet PKC’s licensable
requirements or Conditions for Hire/Use, I submit that the wildlife disturbances it creates cannot therefore
be considered to be made legal. 
2.3 Otters and Beaver - also European protected species – have twice (Nov 2022 & Mar 2025) been formerly
identified and recorded as using the River Tummel and its north bank as a habitat in immediate proximity
to the recreation ground and the event car parking area36. The event site directly adjoins37 the Tay Special
Area of Conservation (a protected ‘European site’ of international importance). PKC clearly identifies and
recognises at Section.5 in your own SAC document, that Otters “… need quiet conditions and can be prone
to disturbance (i.e. a possible offence) resulting in them deserting an area.”.38  The event therefore further
contravenes The Conservation (Natural Habitats) Regulations 1994 (S.39 (b) (iv)) which implements the EU
Habitats Directive.
2.4 It is my understanding that because the event site adjoins and thereby impacts upon a SAC, that a Habitats
Regulations Appraisal (HRA) should be required39. At least one other local authority (The Highland Council)
40 interprets the Habitats Directive in this manner and requires consultation with Planning when applying
for a Public Entertainment License. I therefore highlight: - 
33 https://www.nature.scot/doc/guidance-note-biodiversity-duty-
explained#:~:text=Under%20the%20Nature%20Conservation%20(Scotland,compliance%20with%20the%20Biodiversity%20Duty. 
34 https://www.gov.scot/publications/scottish-biodiversity-delivery-plan-20242030/pages/7/ 
35 https://www.britishecologicalsociety.org/loud-music-festivals-could-reduce-bat-activity-in-some-species-by-nearly-50/ 
36 https://planningapps.pkc.gov.uk/online-applications/files/B2744D67BB45A23C3AB7F43ACE9C2592/pdf/10_00666_FLM-
CONDITION_14_ECOLOGY_REPORT-2332853.pdf 
37 See Attachment 12 https://sitelink.nature.scot/site/8366 
38 https://www.pkc.gov.uk/media/37577/River-Tay-SPG-Final-2016/pdf/River_Tay_SPG_Final_2016.pdf?m=636108416088970000
39 For the Birds? The Habitats Regulations and the Licensing of Outdoor Festivals | Cornerstone Barristers 
40 Public_Entertainment_Guidance_Notes___Sep_2025.pdf

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• Under Regulation 48 of the Conservation (Natural Habitats, &c.) Regulations 1994 (as they apply in
Scotland), a licensing authority must treat an application for a public entertainment licence as a
“plan or project”41 where:
— the activity could potentially have an impact on a European site (SAC)
— the licence is a “consent, permission or other authorisation” issued by a competent authority;
(Licensing authorities are competent authorities under Reg 3.)
— the activity authorised by the licence is not directly connected with or necessary to the
management of any European site; and
— the activity is likely to have a significant effect on a European site, either alone or in
combination with other plans or projects (notably the Tesco development).
— If these conditions are met, the licensing authority:
— must carry out a Habitats Regulations Assessment (HRA) screening, and
— if a likely significant effect cannot be excluded, an Appropriate Assessment is legally
required.
By PKC’s own criteria, 29 hours of amplified music and crowds of thousands per day, across 3 days and until
10pm is self-evidently a guarantee of disturbance to said species. It is nonsensical that PKC on one hand
warns of disturbance (which is ordinarily an illegal activity and could thereby be an offence under law)
and then nonetheless licenses a weekend long music event which directly and negatively impacts upon
both the resident species and habitat which PKC has a statutory duty to protect. 
2.5 The prior ecological/Otter42 surveys conducted for the Tesco supermarket planning application43 state at
4.2.5: “Avoid working in the vicinity of otter habitat during the hours of darkness and within two hours after
sunrise and two hours before sunset”. Sunset on the weekend of Heartland 2025 was at 22:10 and the
event was nonetheless licensed to end at 22:00 (having been 23:00 in 2024). Despite warning about the
perils of disturbance, it is once again entirely illogical that PKC in licensing this event would not then at
the very least apply the same guidance and extend the same time restriction to a weekend-long music
festival in order to ensure the same recommended species and habitat safeguards; If you did so, this
event, if allowed to operate, would have to end by 8pm. 
2.6 Licensing approval can also be viewed to be in further contradiction to the Scottish government National
Events Strategy, “Developing the Industry”, Part 3: "Supporting the protection and considerate enjoyment
of Scotland’s natural and cultural heritage"44. 
41 “Applying The Guidance” https://www.nature.scot/doc/european-site-casework-guidance-how-consider-plans-and-projects-
affecting-special-areas-conservation 
42 https://planningapps.pkc.gov.uk/online-applications/files/1234157478F6CF94D12FA24E9BBD1CCE/pdf/10_00666_FLM-
CONDITION_14_-_OTTER_SURVEY-1979110.pdf 
43 https://planningapps.pkc.gov.uk/online-applications/files/B2744D67BB45A23C3AB7F43ACE9C2592/pdf/10_00666_FLM-
CONDITION_14_ECOLOGY_REPORT-2332853.pdf 
44 https://www.visitscotland.org/tourism-events-industry/strategies/national-events

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Pitlochry's attraction to residents and visitors alike remains overwhelmingly due to its environmental heritage
and biodiversity, as identified by Pitlochry Community Action Trust (PCAT)45 and PKC46. PKC also recognises our
biodiversity as remaining under risk47 and as already referenced, you have a statutory duty to protect and
conserve it. 
3.   Objection: Location/Nature & Extent/Possibility of Public Nuisance, Public Order and or Public Safety/
Other Good Reason: - Environment & Transport:
The entire approach to transport for this festival is also further contrary to all of PKC's and Scottish
government climate action/net zero/ green economy/transport plans and aspirations48 , national events
strategy, event guidance, and even the PCAT49 statements about environment & sustainability: 
3.1 This festival relies exclusively on fossil fuel power. Festival HGV’s, event suppliers, bands and their
equipment, up to 2500 private vehicles (as per previously advertised parking capacity) and additional laid-
on buses are travelling into the heart of rural residential Pitlochry transporting attendees to an event
wholly powered by a myriad of fuel powered generators.
For the 2025 festival, shuttle buses additional to public transport had to be laid-on to and from caravan
parks as far away as Aberfeldy. This was entirely as a result of insufficient public transport to facilitate
movement to and from the event50 or around the area in general and, presumably, in response to the
event making a significant financial loss in 2024 due to insufficient numbers attending. 
3.2 From the volume of private vehicles attending the 2025 festival, it is apparent that will be and continue to
be by necessity the main mode of transport to and from this event. All of the public transport buses
(Citylink, Megabus, Flix) available after event close in 2025 provided a combined total seating capacity of
only some 307 passengers on all services North and South. Obviously, not all of those passengers would
have been event attendees. Clearly the contribution of public bus transport is therefore inconsequential to
the visitor numbers the event attracted. As far as I am aware only one southbound train left after the event
close and that was only on the Saturday – there were none in either direction on the Sunday.
• PKC only provides and administers some 227 public parking spaces in Pitlochry51. On-street parking is
limited to 30mins. Clearly the town has no capacity whatsoever to provide any appropriate level of
parking purely for this event which takes place on a weekend during peak tourist season when the
town is already known to at least double in occupancy and before event parking restrictions are
further applied. 
45 https://pitlochryaction.org.uk/theme-groups/environment-and-sustainability/2/ 
46 https://www.pkc.gov.uk/media/27297/Householders-Guide-to-
Biodiversity/pdf/Householders_Guide_To_Biodiversity.pdf?m=1410534692097 
47 https://www.pkclimateaction.co.uk/biodiversity-act-now 
48 https://www.pkclimateaction.co.uk/transport 
https://www.transport.gov.scot/our-approach/environment/ 
49 https://pitlochryaction.org.uk/theme-groups/environment-and-sustainability/2/ 
50 https://heartlandfestival.co.uk/shuttle-buses-update-03-09-2024/ 
51 https://www.pkc.gov.uk/article/20720/Map-of-car-parking

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3.3 The adjoining parking field previously used by the event is now being built upon for the Tesco supermarket
development52. Despite knowing this: -
• The Organisers claimed on 17/08/25 that a park-and- ride’ facility ‘2-miles outside of town’ would be
available. They are also still claiming that the parking sold up to that time, including Blue Badge
holders, will still be available on the original site.  
• On 05/11/25 (still almost 8 months before a 2026 event), the Heartland website provided an update
that there would likely be no such facility after all “…as it is proving problematic to get the logistics in
place and to make a Park ‘n’ Ride commercially viable for 2026”53. 
3.4 Contravention of PKC 'Safe and Legal Events' Guidance. Step1. Section 28. Parking Arrangements - On and
Off-Street54. 
“You must take into consideration that the existing public/private parking arrangements may be affected by
the event. This, along with the required parking needs for the event, must be catered for.”
If this event will not and cannot ‘cater for’ the required parking for the attendees it sells tickets to – now by
choice simply due to commercial viability / profitability considerations - then it again highlights this site is
not at all in the ‘perfect location’ and will be once again in breach of specific PKC event terms (PKC
language that “parking needs (…) must be catered for” is clearly an instruction). The expanding event
cannot be allowed to simply divest itself again of another problem it creates (and has known of long in
advance) without any recourse and at the further expense of residents, community and environment. 
• This event takes place on a mid-summer weekend in peak tourist season. It is wholly unlike other
events such as The Enchanted Forest which takes place in mid-Autumn across an entire month. The
Enchanted Forest event only has a maximum of 1/3rd of the total daily attendees of Heartland; the
majority arrive late afternoon and leave on a staggered timed ticket basis across the evening.
However, even this results in resident and organiser complaints about visitor parking in
inappropriate and potentially life-threatening places55 as those organisers warned of on their
website and social media. 
•  I note that the Highland Games (one-day event ending at 6:00pm) in September attracts a similar
one-day number of attendees as Heartland and yet they considerately - and were commercially
able - to put on a park-and-ride in 2025 due to the same parking field issue56 despite what appears
to be extremely short notice (Tesco development commenced in the month preceding the Games).
When considering ‘commercial viability’, it is notable their adult ticketing cost considerably less
than Heartland (1/6th of a full price Saturday ticket) and parking charges being 50% less. 
52 See Attachment 11. 
53 https://heartlandfestival.co.uk/our-november-2025-update/ 
54 https://www.pkc.gov.uk/media/41357/Event-safety-guidance-full-
version/pdf/Safe_and_legal_event_guidance.pdf?m=1516881250340 
55 See Attachment 13
56 https://www.facebook.com/pitlochrylife/posts/-pitlochry-highland-games-2025-recreation-ground-ferry-road-ph16-
5dz%EF%B8%8F-online-tic/1337822628128180/

Page 15

• As for the Organisers newly announced desire to challenge the top 2 festivals, Trnsmt in Glasgow
city centre in addition to being served by excellent local regional and inter-city public transport
links, also provides 2,354 parking spaces across 7 designated public car parks within 15 mins walk
to the festival site. However, dozens of streets still face disruption due to full road closures, parking
bans, and suspensions of taxi and bus lanes. 
The Belladrum Tartan Heart festival, held on a country estate, provides three car parking fields and
a caravan/campervan site. In addition, a shuttle bus service runs between Inverness and local
towns. Despite that, the event brings well-documented traffic chaos to the area every year.57
• Due to carparking mismanagement in 2025, mid-afternoon on the Sunday saw the Heartland
carpark area ‘full’ (despite the 2,500 advertised spaces) and vehicles being turned away. This
caused additional traffic disruption into and out of town and on the High street especially as
arriving vehicles then tried to park anywhere they could.  This was clearly a warning of what lies
ahead when there is no carparking facility whatsoever, or reduced and insufficient capacity in the
future.
As it now stands, at event end at 10:00pm and for 3 consecutive nights, a crowd 3x larger than Pitlochry’s
entire population would be on our streets. Due to the main acts being at the end of each evening, the
crowd majority is therefore incentivised to stay until that time. The majority of those would now be
awaiting a campsite shuttle (on the High Street) or heading back to cars parked all over our town anywhere
a space can be found. 
• In the very unlikely off-chance that a park-and-ride facility ‘2-miles outside of town’ materialises,
that would not alleviate matters of disturbance. If it is conservatively estimated only 50% of event
attendees arrive by private vehicle, then that would still mean some 4000 people (+ those using
campsite shuttles) per night would be left at the event site, high street, or other congregation point
awaiting transport. It would literally take well into the early hours of the next day to move a crowd
still 1/3rd larger than Pitlochry’s population.  
The potential for public nuisance, safety and community disturbance is glaringly obvious, especially as
many will also have been making use of the event bars all day58. Moreover, even if a park and ride did
materialise, the health and safety risk arising from attendees choosing to walk back in the dark (many with
children) to some unfamiliar rural parking field instead of waiting hours for a shuttle sounds as inevitable
and dangerous as it does absurd.
It is locally presumed that in the future some remaining Tesco land will again be available for parking.
However, that will be <50% capacity (and a shared entry/exit onto Bridge Road with the supermarket
access) which means this parking issue will not be remedied nor will it go away in future. It can only get 
57 https://www.strathspey-herald.co.uk/news/belladrum-to-introduce-12-charge-per-vehicle-in-2024-to-tac-323261/ 
58 See Attachment 13

Page 16

worse especially as this event now has admitted aspirations to keep growing in spite of all the existing
transgressions identified here. 
• This issue is compounded further by the fact that due to the Tesco development it is most likely
that access to a 2026 event will only be via Ferry Road. Up to 8000 daily attendees using a single
route and access point (it also being a National cycle route and the main pedestrian walkway
from town to and from the Pitlochry Festival Theatre) throughout the day and at event close
guarantees public nuisance to residents and throws up obvious public safety concerns for event
emergency access/egress for attendees and services.
• Moreover, as of 23/01/26 a PKC warning has now been posted on your social media about
structural defects being found on the Aldour Bridge on Bridge Road. Traffic control measures
including lane reduction have been implemented and if they continue, or a possible bridge
closure for (lengthy) repairs, access to and from the town during this event (combined with Tesco
development at the same location) and for an additional 2,500 vehicles, is going to result in
chaos with access into and out of town then solely via the high street. 
Conclusion
This event should first and foremost be held on a site where it meets and fully complies with the PKC
conditions of hire/use, license terms and all associated legislation and event guidance. The many fully qualified
and referenced points outlined here are entirely sufficient in identifying and confirming that the Pitlochry
recreation ground was and is now more than ever an entirely unsuitable site to hold this type of event on, not
the opposite as claimed. 
Moreover, licensing approval would in fact be (again) contrary to and in direct contravention of a multitude of
PKC, EU, UK/Scottish government legislation, policies, and guidance (and even the PCAT Action Plan) relating to
noise, transport/parking, climate, environment, biodiversity, sustainability, access, and, specifically events of
this type. 
All laws, guidelines or requirements to ensure residents, environment and local biodiversity are not subject to
disturbance or nuisance are being overlooked, over-ridden and/or disregarded in order to operate and
facilitate this commercial for-profit event – one which it should be noted is only viable at all due to volunteer
participation and will not even provide parking for its own event due entirely to further profitability
considerations. 
There is in fact no evidence that any mitigation measures have been undertaken to minimise community
disturbance. The absence of, or inadequacy of, any parking facility compounded by an additional day of
operation ensures disturbances keep being added to rather than diminished.

Page 17

• PCAT Action Plan59 at Theme 4 states “Ensure large events providers work with the community to
manage visitor impact “. We residents (particularly site adjoining ones) are the community and it is
us this event most negatively and directly impacts upon and creates a nuisance to and yet we have
had no consultation or consideration whatsoever. The lack of any event parking or greatly reduced
future parking and the impact from visitor numbers stemming from that has not in any way been
broached with Pitlochry’s wider community. 
We wholly respect the Organiser’s “dream” to hold a festival. However, Pitlochry is home to some 2,700
residents, most like us whose dream was and is to enjoy our environment and biodiversity. 
• PCAT Community Action Plan acknowledges at Theme 5 - “The natural environment and
surrounding beauty of the area is what people value most about Pitlochry with nearly 75% of
responses in the survey. So, it makes sense that protecting and enhancing the environmental
assets and sustainability of the area were prioritised as actions.”. 
• This is in comparison to Theme 6 where it is stated only “a quarter of respondents in the survey
said they valued and appreciated the local events, arts and cultural offerings in the town.”
An expanding, polluting, ‘mini-Glastonbury’ outside of our windows and booming through our homes, gardens
and wildlife habitats for three days was never part of our dream, nor, as the survey suggests, the wider
community’s. Neither was the prospect of an additional 2,500 vehicles and their occupants trying to park in
our town; rather, it allows the further monetisation of Pitlochry’s environment for the benefit of profit makers
and other vested interests once again. However, to adjoining residents particularly, this event creates a
statutory nuisance and more widely negatively impacts upon biodiversity; it can disturb and drive species away
as warned by PKC itself in your Tay SAC document. 
Both dreams can be fulfilled and maintained if the event is held in a more suitable, accessible, sustainable, less
invasive and less disruptive location – as the former longstanding Blair Horse Trials (as previously referenced
by the Organiser in the media) more than adequately proved. Likewise, any and all alleged local economic
benefit claimed in support of the event would of course equally apply should it take place on a more
appropriate site - once again as the Blair Horse Trials historically proved. 
Should the Organiser state that it is too late to move this event if this or any other objection is upheld, then I
again bring to your attention your own Safe and Legal Events Guidance, notably venue suitability. Someone
else brought this topic up on Heartland social media back in August ’25 resulting from news of Tesco and the
loss of carparking. The organiser was already claiming back then that relocating was “not a viable option at
this stage”. That was in fact at an unlicensed stage and only some 6 weeks after the 2025 event ended. 
59 https://pitlochryaction.org.uk/wp-content/uploads/2024/04/PitlochryCAP-fin_al-document-with-printer-1.pdf

Page 18

I have no idea what, if any, other local sites the Organiser originally considered for this event (or was ever
questioned about that) but evidently Pitlochry recreation ground is not only far from the ‘ideal’ location it is
claimed to be, it is wholly unsuitable to the residential community which surrounds it. 
Sincerely, 
D Jegier

Page 19

Attachment 1. Locations/sites of comparable outdoor music events within approx. 1 hour of Pitlochry: 
Pitlochry Recreation Ground event site is only some 6.9 acres in size and the nearest dwelling to the front of
the sound deck is only 118m.
• “Doof in the Park” Camperdown Country Park, Dundee, >400 acres, attendance 10,000, closest
dwelling to front of stage 510m,  Google map   
• “Bonfest” (agricultural land – outdoor stage only in operation 17:00 – 23:00) Kirriemuir, Angus, 34
acres, attendance 7,000, closest dwelling to front of stage 620m,  Google map
• “Solas Festival” Erroll Park, Perthshire, 3,000 acres, attendance 1,000, closest dwelling front of stage
not applicable (too distant),  Google map 
• “[Back] Doune The Rabbit Hole” Cardross Estate, Stirling, 4,500 acres, attendance 15,000 closest
dwelling to front of stage not applicable (too distant), Google map 
• “Rockore” Lochore Meadows Country Park, Lochgelly, Fife, 1,200 acres, attendance 4000, closest
dwelling to front of stage 717m,  Google map
• “Outwith” Pittencrief Park, Dunfermline, Fife, 76 acres, attendance 9,000 (spread across town venues)
closest dwelling to front of outdoor stage 420m, Google map
Further Afield:
• Belladrum Tartan Heart, Belladrum Estate nr Inverness, 1,150 acres, attendance 20,000, closest
dwelling to front of stage not applicable (too distant), Google map
Former Festivals:
• Rewind, Scone Palace, Perth, 18,000 acres, attendance 20,000, closest dwelling to front of stage 820m, 
Google map
• Fake Festival, South Inch, Perth, 77 acres, 2000 capacity (held inside a Marquee), closest dwelling to
front of stage 420m,  Google map
• T in the Park, Strathallan, 1,000 acres, 70 -80,000 daily capacity, closest dwelling to front of stage not
applicable (too distant),  Google map

Page 20

Attachment 2: Approximate 300m Radius of Heartland Sound Deck. 
Some 98 dwellings immediately surround the site, commencing at only 118m from the sound deck. A slight
increase in radius would incorporate the entire Tummel Crescent estate and extend well beyond the lower
High Street

Page 21

Attachment 3: Email Questions to PKC EH Team – answers subsequently discussed with Ms. Stewart, EHO,
via Telephone at her request.
Sent: 25 September 2025 11:57 
Subject: Information request, Heartland Festival, Pitlochry 
Apologies, you may receive this twice as I might have sent it to the wrong email address the first time. Good morning EH team,
I have made prior enquiries to PKC in relation to the Heartland Festival which were kindly answered by Mr Rankine (Licensing Standards Officer)
with, I believe, the relevant input coming from yourselves. 
I would kindly appreciate further clarifications (in red below) on those answers please as clearly your team is the one who is responsible for these
specific matters: -
Mr. R: "Noise Management Plan was submitted detailing controls in place that are required to ensure MNL’s meet the Code of Practice limits.
Propagation tests carried out prior to opening of event with EH in attendance." 
What Code of Practise is specifically being referred to? 
What 'Propagation tests' were carried out? When and where, specifically, were they conducted and what did they consist of?
To your knowledge, was any form of noise modelling or noise impact assessment conducted (or required) on the site before the event – as part
of NMP or otherwise?
Mr. R: “Whilst not set as limits, NMP stipulates maximum Front of House at mixing desk level, along with Event Safety Management Plan (ESMP)
stipulating HSE Noise at Work regulations. Guidance is also taken from The Purple Guide” 
In the NMP, what was the referred to maximum stipulated FOH/mixing desk level? 
During the set-up propagation tests what, if any, FOH/mixing deck maximum level was established in order to achieve the event limit of 65dB? 
At which specific location/s was the limit of 65dB (and referred to low frequency levels) tested at during that process? 
Mr. R: "PKC stipulate The Code of Practice levels as being the limit at any event within P&K area. In addition to the MNL not exceeding 65dB,
guidance levels of 70-75dB at 63Hz and 125Hz are followed."
Again, what specific Code of Practise is being referred to here and where are these guidance limits contained?
Mr. R: “In addition to the event organiser carrying out noise monitoring. EH officers were in attendance throughout event in 2024 and 2025 and
carried out monitoring. This was done with a Type 1 noise meter at various locations. Majority of monitoring was undertaken at the boundaries
of the site, outside properties at Ferry Crescent and Ferry Road.”
Did the Organiser, prior to the event, identify all noise-sensitive premises liable to be affected?
Did the Organiser or yourselves conduct noise monitoring at any noise-sensitive premises?
If so, specifically which noise-sensitive premises did monitoring take place at, by whom and how frequently?
Thank you in advance for your assistance.
Kind regards, 
Sent: 14 October 2025 14:18
To: Dawn Stewart 
Subject: Re: Information request, Heartland Festival, Pitlochry 
Hi Dawn,
Just a quick follow-up to thank you for the call today and for discussing/answering the points I raised in my original email.
Regards,

Page 22

Attachment 4.
Email content from Mr. Dave Stubbs, PKC Greenspace Coordinator (Communities) 26/06/25, 15:56. All tests
themselves required not to exceed 65dB.
Dear Mr Jegier,  
Your recent enquiry has been passed on Community Greenspace. We manage park event bookings
including for the Heartland Festival. Can you please confirm the funfair rides are being set up in the
location shown on the attached plan which is what has been agreed.  
It is not going to be possible to move it in relation to this year’s event but if you feel that it is too intrusive
we can certainly look to make changes in relation to future events. 
For your information these are the event timings from their Noise Management Plan.  
3. Event Timings in Relation to Noise
3.1 The following days and times detail risk of potential noise
• Wednesday 25th June:
o Stage construction commences (low-level metallic sounds)
o Plant movement (low-level car noise from a single engine)
• Thursday 26th June:
o Stage construction continues (low-level metallic sounds)
o Plant movement (low-level car noise from a single engine)
o Site deliveries (low-level car noise from multiple vehicles)
• Friday 27th June:
o Production load in (low-level noise from vehicles)
o PM – Audio system testing (not exceeding 65db)
• Saturday 28th June:
o AM – Production load in (low-level noise from vehicles)
o AM – Sound check (not before 9am and not exceeding 65db)
o 11:00 – 22:00 – Concert
o 22:00 – 23:30 – Production load out (low-level car noise)
• Sunday 29th June:
o AM – Production load in (low-level noise from vehicles)
o AM – Sound check (not before 9am and not exceeding 65db)
o 11:00 – 22:00 – Concert
o 22:00 – 23:30 – Production load out (low-level car noise)

Page 23

Attachment 4. Typical sound levels as per A) PKC ‘Licensing Board Policy With Regards to Noise -
Environmental Health Review” & B) Scottish Government Antisocial Behaviour etc (Scotland) Act 2004: 
A) 
B)

Page 24

Attachment 6. Heartland Site Boundary, Site Plan, Sound Deck Position 
Blocking of Core Footpath & Access to Playground as of 25/06/25
Fenced Off Pavillion, Car Park and Playground also Outwith the Site Boundary

Page 25

Attachment 7. Sound Distance Attenuator Calculator. 
If 90dB(A) at sound deck 25m from main stage as PKC EHO claimed: -            
Closest Dwelling                                My Home                                         300m Radius Limit 
If at least 96db(A) at sound deck (as per Code of Practise event research): -

Page 26

Attachment 8. Basic Desktop Visualisation of Sound Attenuator Calculator, 90dB(A) at sound deck, 300m
radius 
96dB(A) at sound deck (as per event industry researched norms) 300m radius

Page 27

Attachment 9. 
01/11/2025. Pre-Fireworks, Pitlochry Recreation Ground. Several Hundred People Attended (Photo Taken
Before Crowd Arrived as it Was Getting Dark) A Local Guitarist and a Singer Were Playing / Singing Country &
Folk Songs. An earlier DJ was significantly louder. 
11/09/25. Children’s Football. Two Pitches in Use. 44 players and 43 Spectators

Page 28

Attachment 10. 
In addition to excessive event sound, this attraction was in use throughout the whole of the 2-day event. It was also illuminated by
neon strip lighting during the evenings and a generator was situated on the other side of my garden hedge. PKC responded that this
could be reconsidered in future “…if you find it too intrusive”! (Attachment 4). “Plus Quam Tolerabile”, Objective Test: Whether a
reasonable person, in the same circumstances, would find the interference with their use and enjoyment of property to be "more
than can reasonably be tolerated" 
21.95m From My Windows and 10m From My Front Garden : Core Path/Park Closure From 25/6/25 Organiser intended for 7 Days.                                                                                                                         
Fenced Off Areas are also Outwith the approved Site Plan

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Attachment 11. Pitlochry, Tesco Supermarket & Car Park:
Site workers now advise the timeline for completion as being December 2026.  Construction work is
undertaken Mon-Fri inclusive so it will be underway during the proposed additional Friday event. 
28/01/2026

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Attachment 12. TAY Special Area of Conservation adjoining Pitlochry Recreation Ground 
Tesco Planning, Eco Reports (2022/2025) Otter & Beaver Field Signs

Page 31

Attachment 13. Heartland Facebook Page From 25/08/2025, + Enchanted Forest & Theatre Posts

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Civic Licensing
From: Donald Mullen
Sent: 24 January 2026 19:11
To: Civic Licensing
Subject: Heartland Festival objection
Follow Up Flag: Follow up
Flag Status: Completed
DearSir/Madam 
I wish to object strongly to the above festival on grounds of woefully inadequate provision of parking
spaces since the organisers are providing no additional spaces.  In the past, even when the festival
provided additional parking spaces, we experienced people parking on our premises when we were
out. The situation will now be much worse. Pitlochry is a small town unsuitable for the staging of
large events. This problem is exacerbated by the fact that it takes place during the peak tourist
season in Pitlochry.
Dr Donald Mullen
The Querns
Bruach Lane
Pitlochry PH16 5DG

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Civic Licensing
From:
Sent: 02 February 2026 12:23
To: Civic Licensing
Subject: Heartland Festival 2026
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe.
Sir / Madam
I write to make my views known regarding the Heartland Festival 2026 https://heartlandfestival.co.uk
to be held on the 27th & 28th June 2026.
I am aware that an individual has been orchestrating a pernicious campaign objecting to the festival
on grounds that I am not aware of.
As a local resident living close to the centre of the town (PH16 5FB) I wish to register my support for
the festival and the economic and cultural benefit the festival will once again bring to the town.
I am a trustee of two Pitlochry based OSCR registered charities and of an associate of an
international charity all of which devout a lot of time and energy raising funds to enhance the
Pitlochry Community.  In the current economic climate raising funds can be a challenging
undertaking.
As treasurer of Pitlochry Community Action Trust (PCAT), I confirm the Trust were delighted to have
been awarded a grant from the Heartland Festival 2025 team, this award allowed the Trust to
leverage matched funding from other funders (including Perth and Kinross Council & the Gannochy
Trust) which has in turn contributed to Pitlochry Town Centre Enhancement and a soon to be
announced music project in conjunction with Pitlochry High School.   
The Heartland Festival 2025 delivered significant economic impact for Perth & Kinross, with over £2.1
million in direct spend, a highly engaged audience travelling from across Scotland and beyond, and
an exceptionally strong satisfaction and loyalty rate and we are looking forward to an even bigger and
better festival in 2026. Hopefully the 2025 Festival's nomination for Scotland's Festival of the Year will
help raise the town's profile and I am aware that a number of the accommodation providers both in
Pitlochry and the surrounding area are already fully booked for the week-end indicating the economic
benefit is spread well beyond the immediate PH16 area.
The focus of the organisers in providing a family friendly event (free for children) has had the desired
outcome of a multi-generational cultural event and I and the organisations I volunteer with fully
support the Heartland Festival 2026 and will again offer our support as community volunteers to
promote and deliver the event for the Pitlochry Community.
Kind Regards
Leslie Gill
1 St Colm Place
Pitlochry
PH16 5FB
President of the Rotary Club of Pitlochry (2025/26)
Treasurer and Trustee of Pitlochry Community Action Trust
Treasurer and Trustee of Pitlochry Community First Responders
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Civic Licensing
From: laura lewis
Sent: 05 February 2026 12:21
To: Civic Licensing
Subject: Heartland Festival- support!
[You don't oen get email from . Learn why this is important at
hps://aka.ms/LearnAboutSenderIdenficaon ]
CAUTION: This email originated from an external organisaon. Do not follow guidance, click links, or open
aachments unless you have verified the sender and know the content is safe.
Dear Sir/ Madam,
I felt it necessary to write having seen your email address being shared on a local Facebook page.
Ironically it was posted by someone wanng to cause trouble for the Heartland Fesval which I found somewhat
galling.
They appeared to be aempng to gather support for prevenng this event to go ahead/ be deliberate menacing to
hinder the organisers?
Luckily, they have lile if any social media support.
Having aended the event both 2024 and 2025, with ckets purchased for 2026, I wanted to get in touch to show
huge support for the event.
Knowing the area well, we were delighted to come to Pitlochry for the weekend the last two years.
Working in hospitality for many years, I wanted to support the fesval with my then 11yr old son, some friends with
younger children also came along.
We travelled from Edinburgh both years and were totally excited to parcipate in a very organised, personal and
family friendly weekend.
While 2025 was busier than the first year- the hotels well and truly took advantage of this by hiking up their prices-
the atmosphere and feeling of ‘safety’ were just as present the second year as they were the first.
My friends brought ear defenders for her younger children since was worried about the noise- these were
unnecessary however due to the clever stage posioning and being an outdoor event, can’t imagine noise being any
problem at all for neighbouring homes.
The music also ended around 10pm both evenings each year and everyone exited smoothly and quickly.
The buses being available from the Main Street were also orderly, swi and I didn’t hear any negaves whatsoever.
Being on Heartland’s social media page, I connue to be impressed with their organisaon, addressing any issues- (I
know parking is an issue this year due to building works) and am extremely confident this 2026 weekend will be
another huge success.
It’s saddening that a very few people choose to aempt to conjure up bad feeling and negavity.
Thankfully these folk appear to be a very small minority.
Heartland fesval 2026, here we come!
Sincerely,

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Laura C. Lewis

Page 36

Judith Dingwall, Chair
Pitlochry Community Action Trust   
February, 2026 
Dear Members of the Council, 
RE: Letter of Support for Heartland Festival 
I am writing on behalf of Pitlochry Community Action Trust to express our strong support for the Heartland
Festival in June at the Recreation Ground in Pitlochry. 
As a community action trust dedicated to working with local people, community groups, businesses, Perth and
Kinross Council and other stakeholders to help support a thriving and aPracQve town that is resilient and enjoys
sustainable growth, we believe this event is a valuable asset to our community. 
The Heartland Festival provides considerable benefits to the area in a number of ways. 
It supports the local economy by attracting visitors to the area, boosting local businesses including hotels, cafes,
and shops. Last year’s event generated an estimated economic boost of more than £2 million which is hugely
significant. 
The festival promotes community cohesion by providing a family-friendly, inclusive event that fosters a sense of
pride in our local area and has put Pitlochry on the map to a whole new generation of visitors and music lovers. 
Heartland also creates a number of volunteering opportunities for people to get involved with, providing
experience, training and an unmatched camaraderie for those who help out. Several local community groups
and organisations have also volunteered at the event, and were delighted to receive generous donations for
their efforts. 
Through the Discovery Stage, the Heartland Festival provides a platform to showcase home-grown local talent,
and the event also welcomes a number of local vendors and suppliers, including Pitlochry’s very own Wasted
Degrees brewery and many others. 
We believe the organisers have a solid plan and the necessary experience to once again deliver a safe,
successful, and high-quality event in Pitlochry that will provide joy and entertainment to thousands of people.
Having worked closely with the team at Heartland over the past two events, we know that they go above and
beyond the legal requirements of holding such an event to ensure that it is the best possible experience for
everyone, and we are delighted to support it once again. 
We would therefore encourage the council to support the Heartland Festival to ensure its ongoing success in
what is currently a difficult operating environment for many in the events industry. 
Yours sincerely,
Judith Dingwall

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Civic Licensing
From: Stew Hall
Sent: 15 February 2026 12:19
To: Civic Licensing
Subject: Heartland Festival Pitlochry
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe.
Hi there, 
I am a Trustee with the Pitlochry Community Action Trust, a local resident of Pitlochry, an ex soldier &
Police Officer.
When the initial idea of a music Festival was voiced in our Community, I observed a strong &
overwhelming Community support,
I grew up in & around Pitlochry in the 1960's & 70's, activities for young people were sparse to say the
least, apart from after school classes such as learning the Chanter & Bagpipes.
Since year 1, I have heard nothing negative about the Festival, but so much strong positive support
from all ages here & in the locality.
We are now very lucky to benefit from the amazing Theatre, Etape cycle Event & the Enchanted
Forest, and will soon have more private & affordable housing and a new stronger School Campus with
Leisure facilities for all.
Along with the popular & respectful Music Festival, Pitlochry must be the envy of many a Community,
within Scotland & overseas.
The added bonuses are that the Event contributes to the financial wellbeing of Pitlochry, Perth &
Kinross & Scotland thanks to visitors & tourists utilising the shops, cafe's, Pub's, Hotels &
Restaurants. Locals also benefit from a feeling of worth & pride; by helping as stewards, litter pickers
& customers.
Thanks to PKC & the Festival organisers, we should all be very proud of a very well organised &
respectful of others 2 day music festival.
Stewart Hall

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Civic Licensing
From:
Sent: 27 January 2026 17:12
To: Civic Licensing
Subject: Heartland Festival
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe.
Hello there. 
I'm not sure if I'm addressing this comment to the correct department. If it isn't relevant to
yourselves, I would appreciate if you could let me know who would be the relevant people to contact,
as I feel really strongly about this matter.
I am 62 years old. I live in Muir of Ord, North of Inverness. I love music and have attended music
festivals most of my adult life. I had kind of given up on them latterly, thinking it was mostly for
younger people. In 2024 a friend suggested going to Heartland Festival in Pitlochry. I love the area but
was sceptical. After purchasing tickets, I started following the Heartland Festival on social media. I
was immediately impressed with the communication from the festivals organisers. They encouraged
questions and answered them all honestly, with a level of patience I have never experienced before.
They said that they wanted it to be a family friendly festival. I thought to myself, "You'll be lucky to
achieve that." After attending, I stood corrected. 
Attending in 2024 was fantastic. It was a very friendly family atmosphere. Kids and dogs! Not my first
choice but it was a joy to see. I didn't see any antisocial behaviour, which, being honest, with a large
crowd, would be expected. 
I attended the Human League at Slessor Gardens in Dundee this year in July. Whilst it was quite
enjoyable organisationally, it's professionalism and set up and service was honestly not in the same
league as the Heartland Festival. Food and drink and toilets didn't compare favourably in comparison
to Heartland. ( Visit the Heartland Festival's Facebook group page and you will see 100's of people
saying that the toilets are the cleanest and best looked after that they've ever experienced.)
Also at Dundee I witnessed older drunk? males getting escorted from the crowd. This was what
potentially would put me off attending such an event. 
Anyway Heartland Festival 2024 was wonderful and quite frankly I thought that Pitlochry would have
been more than appreciative of what the organisers had done for their town. 
I decided that I was definitely going to go to Heartland Festival 2025. I thought it would struggle to live
up to 2024 as the online comments after 2025 had been so complimentary, meaning that it was likely
to be much busier.
I went. It was fantastic. Much busier, just as well organised! The online advice and customer
questions and feedback prior to the event were again first class, unparalleled in my personal
experience. 
The family friendly feel was there again, no trouble, fantastic toilets. No evidence of drunk idiots. No
signs of drug use. I spoke to a few police constables, who were beyond pleasant and helpful. I can't
overstate the feelgood factor, but don't take my word, just check out the, beyond  positive, feedback
on the Heartland Festival Facebook page. 
So the motivation for contacting you, is I heard  on the Heartland Festival Facebook page, of someone
making a complaint about it. I don't know exactly what the complaint was, but I wanted to feedback
what it was that made me ignore a local (to me) Festival at Belladrum in favour of attending the
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Heartland Festival in Pitlochry. I might add that Pitlochry gets it's pound of flesh by increasing hotel
prices and the festival obviously takes a lot of money into the area. Personally, in an ideal world,I
would like to  see the Heartland Festival take place further North, but will continue to attend as long
as I am fit to.
What a gem the organisers are and I think Pitlochry should move mountains to safeguard this event.
Sorry for writing 'War &Peace' but I think you'll be able to gauge how strongly I feel on the matter.
Perth and Kinross should be very grateful in my opinion. Maybe a bit more attention to Slessor
Gardens in the future. Maybe get the organisers of that event to attend Heartland Festival to get a few
pointers on what I perceived as service and customer satisfaction before profit.
Regards Archie Forbes

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Civic Licensing
From: Stefanie MacLeod
Sent: 27 January 2026 21:41
To: Civic Licensing
Subject: Heartland festival Pitlochry
[You don't often get email from . Learn why this is important at
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CAUTION: This email originated from an external organisafion. Do not follow guidance, click links, or open
aftachments unless you have verified the sender and know the content is safe.
Hi,
As someone who grew up in Crieff, Perthshire and loves the country, I thoroughly enjoyed aftending the Heartland
fesfival last year with my husband and 3 children . It was our first year aftending but we enjoyed it so much we
purchased our fickets for this year as soon as they became available.  One of the reasons why I found it so enjoyable
was the idillic sefting and the family friendly atmosphere. We stayed the full weekend, enjoying not only the fesfival
but Pitlochry itself. The town was bustling and buzzing with excitement, things the tourism industry in these small
towns haven’t seen for a long fime. Local businesses including hotels, restaurants, bars, shops etc all hugely
financially benefifted from such an event. Although I grew up in Crieff, Pitlochry wasn’t somewhere I was familiar
with but as a result of visifing for the fesfival, we have since been back a couple of fimes for visits. I think any
objecfions to the fesfival are unfounded and completely irrafional and are the unsupported views of very single
minded people who only care about themselves.  I was saddened to hear these and felt I had a duty to get in touch
myself.
Kind regards
Stefanie MacLeod
Sent from my iPhone

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Civic Licensing
From: Bruce Patterson
Sent: 28 January 2026 16:34
To: Civic Licensing
Subject: Heartland Music Festival
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe.
Pavilion User Groups
(Working to make Pitlochry and even better place to be)
Dear Sirs,
We note the license application for the Heartland Festival has been posted at the Recreation Ground,
Pitlochry.
Pavilion User Groups (PUGs) would like to add their support to the application and the ongoing
success of the Festival. This event brings a great deal of attention to the Recreation Ground and has
increased the number of daily visitors to the play park area and the sports facilities. This is a direct
result of returning visitors who had attended the Festival.
In 2026, we will be taking on the lease for the Pavilion, bringing it under community management. Our
fundraising efforts have been enhanced through a community payback from the Heartland Festival in
the form of a financial donation. We have used this money to match and leverage funding from other
sources, meaning we can now upgrade the building into an important community asset to benefit the
town in a variety of ways. 
As a future community payback resource, the Festival will allow us to continue to improve facilities at
the Recreation Ground for residents and visitors on a year-round basis.
Regards,
Bruce Patterson
(Chair PUGs)

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Civic Licensing
From: Alan Crombie
Sent: 30 January 2026 16:02
To: Civic Licensing
Cc: Judith Dingwall
Subject: Heartland Festival 2026
CAUTION: This email originated from an external organisation. Do not follow guidance, click links, or
open attachments unless you have verified the sender and know the content is safe.
Sir, Madam,
I understand that an individual, who does not make their name public, has been
campaigning against and objecting to this year’s Heartland Festival.
I am writing as someone who has lived and worked in the Pitlochry area for many years
to give my wholehearted support to Heartland Festival’s application. I have no objection
to you making my name and this email public.
My, now adult children, complain that there was “nothing but School, Scouts, salmon
and serving in cafes” in Pitlochry.  Now, Heartland brings them back here! The eclectic
range of performers attracts a range of ages and interests locally and nation-wide.
Heartland Festival has put Pitlochry on the map and in the news without resorting to
“tweed and tartan” nostalgia and brought in a much younger set of visitors than
Pitlochry Festival Theatre, the scenery and the off-A9 eateries. The main stage brought
leading performers into the hills away from the big city venues while the Discovery
Stage has supported new and upcoming talent across a range of musical genres from
traditional to trendy. This will encourage a younger generation to see Perthshire and
the entertainment industry as attractive places to work, build a career and bring up a
family.
There is a significant direct positive impact on the local Pitlochry and Highland
Perthshire, economy with many thousands of visitors at the event itself staying, dining
and spending locally. Heartland Festival distributed its surpluses to many local
charities, organisations and events enhancing Highland Perthshire’s local
culture.  More widely, there are many indirect benefits as the younger generations
mature and make return visits bringing their children on longer visits camping,
caravanning, B-n-B-ing. The economy of Perth and Kinross, and Tayside
generally  also benefit as festivalgoers pass through.
I am well aware that there are some negative impacts, but they are minor and can
mediated. The ten o’clock curfew and sensitive placing of stages has mitigated the
perceived noise problem and further tweaks based on last year’s experiences will do
more. Parking and Travel problems occur throughout the season but Heartland
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weekend is no worse than the Highland Games and a lot better than the Etape. Litter
on the Recreation Gound is hardly  significant as attendees are generally well behaved
and local volunteers scour the field the day after the event. This along with other
volunteer positions such as box office, scanning entry tickets, the administration of wrist
bands, queue management and general stewarding, provides some real-world
experience for local teenagers and reinforces their work ethic as
they see the reward flowing back as donations to their local
organisations as well as their own freebie tickets.
I should also like to draw your attention to the recent announcement (see The Courier
29/12025) that Heartland Festival has been nominated for Festival of the Year. This
clearly shows that it has done much to raise the profile of Pitlochry and Highland
Perthshire.
In summary, Heartland Festival is a multi-generational cultural event worth supporting
as it generates economic, cultural, educational and social benefits to the organisations
and people of Pitlochry, Perth and Kinross and Scotland. I, along with many local
organisations, strongly support it.
Alan Crombie
18 Duff Avenue,
Moulin, Pitlochry 
PH16 5EN