Appendix 9 - Objection (Stanfield)
Perth and Kinross Council · 11 August 2025
Back to Licensing Committee — 11 August 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Archived: 29 May 2025 16:24:32 From: Sent: Wed, 28 May 2025 08:57:00 To: SPR STL Subject: Objection to Short-Term Let Licence Application at Aldcharmaig PKC Short-Term Let Licence Application ID: 2271 UPRN: 124112461 Importance: Normal Sensitivity: None 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. Dear Sir, I am writing to formally object to the above application for a short-term let licence at Aldcharmaig, located on 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 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. 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; or (ii) Lead to the loss of residential accommodation, unless this is clearly outweighed by demonstrable local economic benefits. 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 weekends.
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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 weather. This potential significantly increases the likelihood for noise disturbance, especially in the context of short-term lets, where the occupants are transient, uninvested in local harmony, 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. 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. 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. This raises specific concerns about the potential for intensified use of the Loch by short- term holiday guests, including motorised 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 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
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There is minimal evidence to suggest the proposed change of use would deliver 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 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. I would urge the Licensing Authority to refuse this application. Yours faithfully, Colin Stanfield Dallros Foss Pitlochry PH155NQ