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Appendix 3 - Objection (Horsfall)

Perth and Kinross Council · 11 August 2025
Back to Licensing Committee — 11 August 2025 and its agenda

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SPR STL
From:
Sent: 13 June 2025 08:43
To: SPR STL
Subject: Objection to Short-Term Let Licence Application at Aldcharmaig PKC Short-Term
Let Licence Application ID: 2271 UPRN: 124112461
Categories: OBJECTIONS/COMPLAINTS
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Mr. Nicholas H. and  Mrs Diana Coldwell-Horsfall
New Flax Mill, Foss Pitlochry Perthshire
PH16 5NH
Dear Sir, I am writing to object to the above application for a short-term let licence at Aldcharmaig,
midway along the north shore of Loch Tummel.
PKC Short-Term Let Licence Application ID: 2271 UPRN: 124112461 Application submitted: 20
May 2025
Planning and Policy Context
You will be aware that under Planning Reference 18/01875/FLL, consent was granted on 6
February 2019 for the erection of a dwelling house. The current application seeks
to significantly intensify the use of the property by converting it to a commercial short-term let
business that would be catering to up to 10 guests.
As the property has never been occupied, it seems therefore that the initial application was
submitted under a false premise, clearly with the intent to convert to a 'commercial' premises,
circumventing in spirit, if not in practice, the intention of planning applications.
The proposal represents a major material change of use and raises serious concerns regarding
the impact on local amenity and the character of the surrounding area which to date has remained
free from commercial overdevelopment.  A stunning quiet rural piece of Scottish countryside for
humans and wildlife to enjoy.
Note that the property lies within the Loch Tummel National Scenic Area, the River Tay Special
Area of Conservation (SAC) catchment, and countryside as defined in the Local Development
Plan. It is also located within a region currently under consultation for designation as a Short-Term
Let Control Area. Under NPF4 Policy 30(e), proposals for short-term lets should not be supported
where they:
(i) Result in an unacceptable impact on local amenity or the character of the area;
(ii) (ii) Lead to the loss of residential accommodation, unless this is clearly
outweighed by demonstrable local economic benefits.

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This change of use will impact the character of the area with noise carrying across the water from
parties, motorised speed boats, jet skiing, with the risk of pollution from both noise and possible
fuel spillages on the loch.
Disturbing nesting birds and visiting rare birds such as Kites, Harriers, whooper swans, golden
eye, osprey, barn owl and little owls that enjoy the area now only because this is a undeveloped
corner of Scotland, a quiet, clean, bit of country that is dark at night,
I believe that we need to protect our countryside from inappropriate developments that will
change the character of the area.
to grant the change of use of the property by converting it to a commercial short-term let business
would materially damage what we have here.
The proposal flies in the face of this Policy, as it would obviously result in an unacceptable impact
on the amenity and character of the area and lead to a loss of residential accommodation (the
original planning application) with no demonstrable economic benefits.
I provide more detail on each of these below.
Local Amenity
The proposed change of use materially differs from that of a private residence in terms of;
frequency and turnover of occupants; expectation of holiday behaviour (often louder and more
inclined towards the consumption of alcohol); the intensification of activity, particularly during
evenings and weekend mini breaks and the winter holiday period.
The site sits directly across the water from the rural settlement of Foss. The distance across Loch
Tummel is around ½ mile with clear line-of-sight across open water, which amplifies sound. You
should be aware that even low-level noise and low-volume music travel audibly across the water,
particularly during calm weathe.  Even the voice of farmers and dogs gathering sheep can be
clearly heard from across the loch, so a group of holiday guests partying on the large south facing
balcony could potential significantly increases the likelihood for noise disturbance, especially in
the context of short-term lets, where the occupants are transient, uninvested in need to maintain
the neighbourliness in local area and less likely to observe noise discipline than permanent
residents. The impact is likely to be persistent, repetitive, and unpredictable, which can be deeply
unsettling for year-round residents and wildlife.
You will be aware that the Loch Tummel surroundings are already subject to significant intrusions
by transient visitors ostensibly 'wild camping', though typically this is 'car camping' with the
associated noise, litter, fire lighting and anti-social behaviour. Residents are frequently subjected
to abuse by these visitors and you may be aware of a recent serious assault on a resident by such
visitors. The proposal would increase the potential for and intensity of such issues.
Light Pollution and Visual Intrusion. The building already makes a pronounced visual impact due
to its size and positioning across three levels facing the Loch. At night, lighting from the property
reflects strongly off the water, further intensifying its presence. The change of use to a holiday let
– with increased evening activity, more intensive lighting, and outdoor use – is likely to
significantly increase light pollution and erode the tranquillity of this scenic rural environment for
humans and wildlife.
This is visibly and environmentally harmful, especially given the protected landscape and
designation as a National Scenic Area.
Concerns About Motorised Activity and Loch Usage.  The property has direct waterfront access,
including a private jetty or pier and a boathouse yet to be built. This raises specific concerns about
the potential for intensified use of the Loch by short-term holiday guests, including motorised

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watercraft activity. Loch Tummel is currently characterised by peaceful, low-impact
usage. Motorised activity is very much not the norm. Any increase in powered boat use, jet
skis, or other motorised watercraft from this property would not only undermine the tranquillity of
the Loch but could introduce safety risks, noise, and ecological disturbance.
For example, the local sailing club undertakes peaceful and unobtrusive sailing activity, often with
local children learning to sail and swim and the potential for additional risk to these activities from
motorised watercraft should be noted. This risk is heightened by the fact that transient guests may
be unfamiliar with local codes of conduct, leading to greater disruption than from permanent
residents.
The combination of easy water access and holiday usage patterns creates an unacceptable
potential for nuisance and environmental degradation.
Housing and Character of the Area
The original planning permission in 2019 was for a dwellinghouse – contributing to the local
housing supply. It’s proposed conversion to a commercial enterprise removes it from residential
use, which is inconsistent with NPF4’s emphasis on sustainable, balanced communities.
Furthermore, the scale and commercial intent of the short-term let are incompatible with the
residential character of the surrounding area, where existing properties are primarily long-term
family homes or used as occasional second homes without commercial turnover.
Again, I would reiterate my view that, as the property has never been occupied, it seems that the
initial application was submitted under a false premise, clearly with the intent to convert to a
'commercial' premises, circumventing in spirit, if not in practice, the intention of planning
applications.
Economic Impact
There is minimal evidence to suggest the proposed change of use would deliver any significant
local economic benefit. Short-term let guests typically arrive by car, bring supplies with them, and
make limited use of local businesses. Any economic benefit is likely to be marginal and does not
outweigh the substantial negative impacts on neighbours and the surrounding wildlife and
environment.
In conclusion, this application is incompatible with NPF4, the Perth & Kinross Local Development
Plan 2 (2019), and the PKC Short-Term Let Licensing Policy, particularly in relation to
residential amenity, overdevelopment, and environmental impact. It introduces persistent
nuisance risks, including anti-social behaviour, noise and light disturbance, and results in the loss
of a residential property to a large-scale commercial use.
Loch Tummel remains largely unspoiled by human activity and is one of the few refuges for
wildlife having large areas of roadless land to the north and south of the loch as wildlife
corridors.  At present the area is free from the damaging light pollution that affects wildlife in less
managed areas.
I would urge the Licensing Authority to refuse this application.
Yours sincerely
Mr. Nicholas H. and  Mrs Diana Coldwell-Horsfall
New Flax Mill, Foss Pitlochry Perthshire

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PH16 5NH