Agenda Document Pack - Licensing Committee - 11/08/2025
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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Ambition | Compassion | Integrity Our vision is for a Perth and Kinross where everyone can live life well, free from poverty and inequality Council Building 2 High Street Perth PH1 5PH 05/08/2025 A hybrid meeting of the Licensing Committee will be held in the Council Chamber on Monday, 11 August 2025 at 13:00. If you have any queries please contact Committee Services on (01738) 475000 or email Committee@pkc.gov.uk. THOMAS GLEN Chief Executive Those attending the meeting are requested to ensure that all notifications are silent on their device and other devices are in silent mode. Please note that the meeting will be broadcast online and recorded. Members: Bailie Mike Williamson (Convener) Councillor Iain MacPherson (Vice-Convener) Councillor Keith Allan Councillor Hugh Anderson Councillor Bob Brawn Bailie Rhona Brock Councillor Steven Carr Councillor Andy Chan Councillor Michelle Frampton Councillor Ken Harvey Councillor Carol Mair Councillor Willie Robertson Councillor Alan Watt Page 1 of 64
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Licensing Committee Monday, 11 August 2025 AGENDA MEMBERS ARE REMINDED OF THEIR OBLIGATION TO DECLARE ANY FINANCIAL OR NON-FINANCIAL INTEREST WHICH THEY MAY HAVE IN ANY ITEM ON THIS AGENDA IN ACCORDANCE WITH THE COUNCILLORS’ CODE OF CONDUCT. 1 WELCOME AND APOLOGIES/SUBSTITUTES 2 DECLARATIONS OF INTEREST 3 MINUTE OF MEETING OF LICENSING COMMITTEE OF 30 JUNE 2025 FOR APPROVAL (copy herewith) 5 - 8 4 GRANT OF SHORT TERM LETS LICENCE - GREYSTONES, LOGIEALMOND, PERTH, PH1 3TD Report by Strategic Lead - Legal and Governance (copy herewith 25/189) 9 - 20 5 GRANT OF SHORT TERM LET LICENCE - SCHIEHALLION HOUSE, STRATHTUMMEL, ABERFELDY, PH16 5NT Report by Strategic Lead - Legal and Governance (copy herewith 25/190) 21 - 64 IT IS RECOMMENDED THAT THE PUBLIC AND PRESS SHOULD BE EXCLUDED DURING CONSIDERATION OF THE FOLLOWING ITEM(S) IN ORDER TO AVOID THE DISCLOSURE OF INFORMATION WHICH IS EXEMPT IN TERMS OF SCHEDULE 7A TO THE LOCAL GOVERNMENT (SCOTLAND) ACT 1973 P1 IMMEDIATE SUSPENSION OF TAXI/PRIVATE HIRE CAR DRIVER LICENCE - TD2398 • Exempt Reason 14 - Any action taken or to be taken in connection with the prevention, investigation or prosecution of crime. Page 3 of 64
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Licensing Committee Minute of hybrid meeting of the Licensing Committee held in the Council Chambers, 2 High Street, Perth on Monday 30 June 2025 at 1.00pm. Present: Bailie M Williamson, Councillors K Allan, B Brawn, M Frampton, K Harvey, I MacPherson, G Stewart (substituting for Councillor S Carr), and W Robertson. In Attendance: M McLaren, K Engelberts, S Michie, D Rankine, M Pasternak and S Dockerill and R Ramsay (all Legal & Governance). Apologies for Absence: Bailie R Brock, Councillors H Anderson, S Carr, A Chan and A Watt. Bailie M Williamson, Convener, Presiding. 1. Welcome And Apologies The Vice-Convener welcomed all those present to the meeting. Apologies for absence were noted as above. 2. Declarations Of Interest There were no Declaration of Interests in terms of Councillors Code of Conduct. 3. Minutes (i) Minute of Meeting of Licensing Committee of 12 May 2025 for Approval The minute of meeting of Licensing Committee of 12 May 2025 was approved as correct record. (ii) Minute of Special Meeting of Licensing Committee of 2 June 2025 The minute of special meeting of Licensing Committee of 2 June 2025 was approved as correct record. 4. Amendments to Taxi Fare and Scale Review after Consultation There was submitted a report by Strategic Lead – Legal and Governance (25/176) outlining the findings of the most recent review and proposes that the Committee consider whether there be an increase in the fares, and alterations made to the current Scale of Taxi Fares card. Resolved: (i) A 5% increase across all tariffs as set out in Option 3 (para 5.1.3), and inclusion of a new Tariff 3 to apply from 10pm – 6am and Easter holidays and 3 Page 5 of 64
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hirings begun on a Sunday for larger vehicles carrying 5 or more passengers as set out in Option 1 (para 5.2.1), be agreed. (ii) It be agreed that the change to the current Scale of Taxi Fares be updated as set out in section 4.1 of this report. (iii) It be agreed that the Scale of Taxi Fares be advertised in the local press and interested parties are invited to respond within one (1) month of the advertisement. (iv) It be agreed that if no adverse comments or representations are received after advertising, the new scale of fees and changes to the taxi tariff card commence from a date specified by the Strategic Lead - Legal and Governance in the advertisement, that date to be approximately six weeks after the date of the advertisement. (It was agreed that the public and press should be excluded during consideration of the following item in order to avoid the disclosure of information which is exempt in terms of Schedule 7A to the Local Government (Scotland) Act 1973.) P1. Grant of Taxi/Private Hire Car Driver Licence – TD2423 There was submitted a report by Strategic Lead – Legal and Governance (25/177) along with a letter of representation from Police Scotland dated 10 April 2025 in relation to Grant of Taxi/Private Hire Car Driver Licence – TD2423. Police Scotland attended the meeting, addressed the Committee and answered Members’ questions. Mr Chamil Gamagedara attended the meeting, addressed the Committee and answered Members’ questions. (Following a short adjournment the Committee re-convened) Resolved: Grant of Taxi/Private Hire Car Driver Licence – TD2423, be deferred until the next Licensing Committee meeting on 11 August 2025 to allow for a Certificate of Good Conduct or Criminal Record Certificate checks to be carried out. (Due to following two items relating to the same applicant, the Committee agreed to consider them concurrently) P2. Renewal of Taxi/Private Hire Car Driver Licence – TD1744 There was submitted a report by Strategic Lead – Legal and Governance (25/178) along with an objection letter from Police Scotland dated 18 February 2025 in relation to Renewal of Taxi/Private Hire Car Driver Licence – TD1744. Police Scotland attended the meeting, addressed the Committee and answered members’ questions. Mr Sebastian Banat, applicant and his legal representative L Barber attended the meeting, addressed the Committee and answered Members’ questions. Page 6 of 64
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(Following a short adjournment the Committee re-convened) Motion by Bailie M Williamson and Councillor M Frampton To grant the application for a period of 1 year. Amendment by Councillors I MacPherson and K Harvey To grant the application for a period of 3 years. In terms of Standing order 21 a roll call vote was taken 4 Members voted for the Motion as follows: Bailie M Williamson, Councillors K Allan, B Brawn and M Frampton 5 Members voted for the Amendment as follows: Councillors K Harvey, I Macpherson, C Mair, G Stewart and W Robertson. Resolved: Renewal of Taxi/Private Hire Car Driver Licence TD1744, be granted for a period of 3 years. P3. Suspension of Taxi/Private Hire Car Driver Licence – TD1744 There was submitted a report by Strategic Lead – Legal and Governance (25/179) along with an objection letter from Police Scotland dated 21 January 2025 in relation to Suspension of Taxi/Private Hire Car Driver Licence – TD1744. Resolved: As per above – the suspension of the licence was considered to no longer be relevant as it expired on 4 April 2025. Page 7 of 64
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PERTH AND KINROSS COUNCIL – LICENSING COMMITTEE 11 August 2025 REPORT BY HEAD OF LEGAL AND GOVERNANCE SERVICES TYPE OF APPLICATION Grant of a Short-Term Let Licence APPLICANT Mrs Sheila Flavell PREMISES (if applicable) Greystones, Logiealmond, Perth, Perth and Kinross, PH1 3TD THE APPLICATION Mrs Sheila Flavell, the sole Applicant, has applied for a three-year short-term let licence as a new host. The Application has been validated by Licensing Officers and was sent out for consultation. Police Scotland, Scottish Fire and Rescue Services, and PKC Planning Department have stated they have no objections to this application. The short-term let property is a detached house. The Application is for that of a ‘Secondary Letting’ short-term let licence. The property has four bedrooms and one additional room used for sleeping, the Applicant has applied for a maximum capacity of ten guests. The Day-to-Day Managers are Mr Philip Blount Kindrum Park Farm, Logiealmond, Perth and Kinross, PH1 3TD & Ms Victoria Susanne Banks 11 Stormont Road, Scone, Perth, Perth and Kinross, PH2 6RH. One letter of objection has been received with regards to this Application (see attached letter of objection). RELEVANT LICENSING POLICIES The Council’s Short Term Let Policy was approved by the Licensing Committee on 22 September 2022. The Council’s Short-Term Lets Policy focuses on ensuring that an efficient, effective and proportionate licensing scheme is in place, which is customised to the needs and circumstances of the Council’s local area and supports applicants who wish to obtain a short-term let licence. The aims of the licensing scheme are: • to ensure all short-term lets are safe; • to facilitate licensing authorities in knowing and understanding what is happening in their area; and • to assist with handling complaints and address issues faced by neighbours effectively. In assessing an application for a short-term lets licence, the Council will consider: • the suitability of the person applying and that of the other people named on the application form (whether they are “fit and proper”); 4 Page 9 of 64
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• compliance/ability to comply with mandatory conditions (applicable to all short-term lets across Scotland) (copy attached); • compliance/ability to comply with any additional conditions that the Council might attach to the licence (either specific to the accommodation, or specific to short-term lets in Perth and Kinross); and • the suitability of the premises in the context of Perth and Kinross Council’s policies. The Council may vary the terms of a licence on any grounds they think fit and can do this at any time. This can be done following an application made to the Council by the licence holder on their own initiative. This could include adding further conditions to the licence. The Council will consult with the statutory consultees and any other parties it considers appropriate. Conditions attached to a Short-term Let Licence Mandatory Conditions Any Licence will be subject to Conditions. Under the 2022 Order, there are certain conditions which the Council must attach to a short-term let licence, irrespective of the type of short-term let granted, whether it is Secondary Letting, Home Letting, Home Sharing or Home Letting and Home Sharing. These are known as “mandatory conditions” and are detailed at Annex A. Please note that the Council has no power to amend these mandatory conditions. All applicants should ensure, prior to applying for a short-term let licence of any type that they are able to comply with the mandatory conditions attached to a licence. Applicants should also note that in term of listing their premises as a licensed short-term let, as required under mandatory condition 14, the listing must include the licence number provided by the Council and the valid energy performance certificate rating) if an Energy Performance Certificate is required for the premises, in accordance with the Energy Performance of Buildings (Scotland) Regulations 2008. LEGAL POSITION The Civic Government (Scotland) Act 1982 provides grounds for refusal of a short-term let licence. Any decision to refuse a short- term let licence must be relevant to one or more the following grounds of refusal as detailed in the Civic Government (Scotland) Act 1982:- A licensing authority must grant the application unless one of the grounds of refusal exists. If, in the opinion of the Committee, a ground of refusal exists then the application must be refused. The grounds of refusal are:- Page 10 of 64
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(a) the applicant or, where the applicant is not a natural person, any director of it or partner in it or any other person responsible for its management, is either – (i) for the time being disqualified under section 7(6) of this Act, or (ii) not a fit and proper person to be the holder of the licence; (b) the activity to which it relates would be managed by or carried on for the benefit of a person, other than the applicant, who would be refused the grant or renewal of such a licence if he made the application him/herself; (c) where the licence applied for relates to an activity consisting of or including the use of premises, those premises are not suitable or convenient for the conduct of the activity having regard to – (i) the location, character or condition of the premises; (ii) the nature and extent of the proposed activity; (iii) the kind of persons likely to be in the premises; (iv) the possibility of undue public nuisance; or (v) public order or public safety; or (ca) the applicant would not be able to secure compliance with: (i) the mandatory licence conditions, and (ii) the standard conditions and any further conditions to which the licence is to be subject; (cb) the application does not contain the consent of the owners of the premises; or ( (d) there is other good reason for refusing the application; and otherwise shall grant the application. In deciding whether or not to grant or renew a Licence, the Council will consider each Application on its own merits and will take into account the following: • any Objections or Representations • this Licensing Policy Statement • any other relevant considerations OPTIONS The Committee need to consider whether the objections received relate to the activity of a short term let licence. The options open to the Committee are therefore to: • grant the application; • grant the application for a shorter period of time; • grant the application with additional conditions; or Page 11 of 64
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Annex A – Mandatory Conditions Mandatory conditions will be applied to all types of short-term let licences (as specified in schedule 3 of the Order) and Temporary Exemptions. The following are mandatory conditions and will apply to all licences issued:- Agents 1. Only those named as a holder of the licence can carry out the day to day management of the short- term let of the premises. Type of licence 2. The holder of the licence may only offer the type of short-term let for which the licence has been granted. Fire safety 3. The holder of the licence must ensure the premises has satisfactory equipment installed for detecting, and for giving warning of - (a) fire or suspected fire, and (b) the presence of carbon monoxide in a concentration that is hazardous to health. 4. The holder of the licence must keep records showing that all upholstered furnishings and mattresses within the parts of the premises which are for guest use, or to which • refuse the application if one of the grounds for refusal exist. PROCEDURE • Identify parties • Consider any preliminary issues • Members of the public speak to their representation(s)/objection(s) • Committee asks any questions to the objectors • Applicant makes submission • Committee asks any questions of the applicant • Objector/s sum up • Applicant sum up • Committee makes decision Page 12 of 64
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the guests are otherwise permitted to have access, comply with the Furniture and Furnishings (Fire Safety) Regulations 1988(1). Gas safety 5. Where the premises has a gas supply - (a) the holder of the licence must arrange for an annual gas safety inspection of all gas pipes, flues and appliances in the premises, (b) if, after an annual inspection, any appliance does not meet the required safety standard, the holder of the licence must not allow a short-term let of the premises until the works necessary to bring the appliance to the required safety standard have been carried out. Electrical safety 6. Where there are electrical fittings or items within the parts of the premises which are for guest use, or to which the guests are permitted to have access, the holder of the licence must - (a) ensure that any electrical fittings and items are in - (i) a reasonable state of repair, and (ii) proper and safe working order, (b) arrange for an electrical safety inspection to be carried out by a competent person at least every five years or more frequently if directed by the competent person, (c) ensure that, following an electrical safety inspection, the competent person produces an Electrical Installation Condition Report on any fixed installations, (d) arrange for a competent person to— (i) produce a Portable Appliance Testing Report on moveable appliances to which a guest has access, and (ii) date label and sign all moveable appliances which have been inspected. 7. In determining who is competent, the holder of the licence must have regard to guidance issued by the Scottish Ministers under section 19B(4) of the Housing (Scotland) Act 2006. Page 13 of 64
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Water safety: private water supplies 8. Where the premises are served by a private water supply, the licence holder must comply with the requirements on the owners of private dwellings set out in the Water Intended for Human Consumption (Private Supplies) (Scotland) Regulations 2017. Water safety: legionella 9. The holder of the licence must assess the risk from exposure to legionella within the premises, whether or not the premises are served by a private water supply. Safety & repair standards 10. — (1) The holder of the licence must take all reasonable steps to ensure the premises are safe for residential use. (2) Where the premises are subject to the requirements of Chapter 4 of Part 1 of the Housing (Scotland) Act 2006, the holder of the licence must ensure that the premises meet the repairing standard. Maximum Occupancy 11. The licence holder must ensure that the number of guests residing on the premises does not exceed the number specified in the licence. Information to be displayed 12. The holder of the licence must make the following information available within the premises in a place where it is accessible to all guests - (a) a certified copy of the licence and the licence conditions, (b) fire, gas and electrical safety information, (c) details of how to summon the assistance of emergency services, (d) a copy of the gas safety report, (e) a copy of the Electrical Installation Condition Report, and (f) a copy of the Portable Appliance Testing Report. Planning Permission 13. Where the premises is in a short-term let control area for the purposes of section 26B of the Town and Country Planning (Scotland) Act 1997(4) (“the 1997 Act”), the holder of the licence must, where the use of the premises for a short-term let requires planning permission under the 1997 Act, ensure that either— (a) an application has been made for planning permission under the 1997 Act and has not yet been determined, or Page 14 of 64
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(b) planning permission under the 1997 Act is in force. Listings 14. - (1) The holder of the licence must ensure that any listing or advert (whether electronic or otherwise) for the short-term let of the premises includes - (a) the licence number, and (b) a valid Energy Performance Certificate rating if an Energy Performance Certificate is required for the premises, in accordance with the Energy Performance of Buildings (Scotland) Regulations 2008(5). (2) The holder of the licence must ensure that any listing or advert (whether electronic or otherwise) for the short-term let of the premises is consistent with the terms of the short-term let licence. Insurance 15. The holder of the licence must ensure that there is in place for the premises - (a) valid buildings insurance for the duration of the licence, and (b) valid public liability insurance for the duration of each short-term let agreement. Payment of fees 16. The holder of the licence must pay any fees due to the licensing authority in respect of the licence on demand. False or misleading information 17. The holder of the licence must not provide any false or misleading information to the licensing authority. Interpretation 18. In this schedule - “Electrical Installation Condition Report” means a report containing the following information – (a) the date on which the inspection was carried out, (b) the address of the premises inspected, (c) the name, address and relevant qualifications of the person who carried out the inspection, (d) a description, and the location, of each installation, fixture, fitting Page 15 of 64
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and appliance inspected, (e) any defect identified, (f) any action taken to remedy a defect, “Energy Performance Certificate” means a certificate which complies with regulation 6 of the Energy Performance of Buildings (Scotland) Regulations 2008), “gas safety report” means a report containing the following information - (a) the date on which the appliance or flue was checked, (b) the address of the premises at which the appliance or flue is installed, (c) a description of and the location of each appliance or flue checked, (d) any safety defect identified, (e) any remedial action taken, (f) confirmation that the check undertaken complies with the requirements of an examination of - (i) the effectiveness of any flue, (ii) the supply of combustion air, (iii) subject to head (iv), its operating pressure or heat input or, where necessary, (iv) if it is not reasonably practicable to examine its combustion performance, (v) its operation so as to ensure its safe functioning, (g) the name and signature of the individual carrying out the check, and (h) the registration number with which that individual, or that individual’s employer, is registered with a body approved by the Health and Safety Executive for the purposes of regulation 3(3) of the Gas Safety (Installation and Use) Regulations 1998(7), “holder of the licence” means any person to whom a short-term let licence has been granted or jointly granted, “home letting” means a short-term let consisting of the entering into of an agreement for the use, while the host is absent, of accommodation which is, or is part of, the host’s only or principal home, Page 16 of 64
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“home sharing” means a short-term let consisting of the entering into of an agreement for the use, while the host is present, of accommodation which is, or is part of, the host’s only or principal home, “premises” means the accommodation which is the subject of an application for a short-term licence or the subject of a short-term licence, “repairing standard” means the steps which the holder of the licence is required to take to comply with the obligations placed on the holder by Chapter 4 of Part 1 of the Housing (Scotland) Act 2006(8), “secondary letting” means a short-term let consisting of the entering into of an agreement for the use of accommodation which is not, or is not part of, the licence holder’s only or principal home, “short-term let” has the same meaning as in article 3 of the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022, “short-term let licence” means a licence for a short-term let, and “type of short-term let” means one of the following purposes - (a) secondary letting, (b) home letting, (c) home sharing, or (d) home letting and home sharing. Page 17 of 64
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From: Mail received time: Tue, 27 May 2025 12:02:21 Sent: Tue, 27 May 2025 13:02:01 To: SPR STL Subject: Application for short term let at Greystones, Harrietfield PH13TD ID 2256 Importance: Normal Sensitivity: None Archived: 02 June 2025 09:44:22 ___________________________________ 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. I am writing to object to the above application on the grounds of impact on surrounding property due to location, character and condition ; lack of clarity on nature and extent of activity ; and lack of evidence to satisfy mandatory and additional conditions. I own the adjacent property the Old Village Hall which has a short narrow shared access to the property; private water supply running through the property and rights of access to maintain a septic tank within the property boundary. I have resided in Perth for 8 years for family reasons and have let out the property for residential use and am currently considering disposal, re occupancy by my family or alternative use of the property. Location, Character and Condition Greystones is part of a historic building group including former church and ancillary outbuildings, with a shared access and 3 immediately adjacent properties with common boundaries. The Old Village Hall has a short narrow shared access to the boundary and common boundary on area of garden grounds and undefined are of former woodland comprising part of the boundary. The applicant manages other short term lets on the Estate but this will be the only one with a shared access and immediately adjacent private residential property. Previous short term let granted within the village are apparently currently being used for occupancy by workers rather than holiday use. Greystones has been altered by the applicant including new exterior access and structural alteration, revised water and drainage infrastructure and felling of mature woodland. There is no public evidence of approval for alterations and works in respect of building warrant; listed building consent in respect of alteration to access at church; SEPA licences for discharge and alteration of water course, or Forestry felling licence which questions the ability to satisfy mandatory conditions on condition and safety if no overarching required regulatory consents have been secured. Nature and extent of proposed activity The proposed occupancy of 10 is double the number of people who have occupied Greystones in the previous 30 years. No indication has been given in respect of use of the church or outbuildings which are currently used for storage for servicing other short term lets and generate additional traffic on the shared access. There is potential for further expansion of the proposed use on the basis of precedent should the short term let be granted, resulting in greater potential impacts on adjacent properties. The area of cleared woodland is accessed by the property and adjacent to area of garden ground of the Old Village Hall. No indication has been given as to the use of this ground. Possibility of undue public nuisance The proposed use has potential to cause undue public nuisance to adjacent private property as a consequence of shared access and common boundaries. There is and will be greater vehicles accessing the property impacting on access from public road, shared access and adjacent parking areas resulting in nuisance to occupiers though delayed access and use of private space and potential damage to entrance walls. The privacy of the Old Village Hall cannot be guaranteed until the use of adjacent ground is determined and 4 Page 19 of 64
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boundaries agreed and installed. Other - Communication of proposed short term let use and future management. The notice of application is shown as 29/4/25 yet public notice was erected on 7/5/25. There has been no communication on the proposed use despite attempts to discuss the future of both properties with the applicant given common infrastructure, access and good practice in terms of communicating intent and future management arrangements to highlight and address concerns and foster a positive working relationship should the use be permitted. On the basis of the above I object to the proposed use and ask the licensing authority to give these consideration. The decision will have an impact on my property and determine future consideration of its use. Yours Sincerely John McCrone MRTPI FRSGS Page 20 of 64
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PERTH AND KINROSS COUNCIL – LICENSING COMMITTEE 11 August 2025 REPORT BY HEAD OF LEGAL AND GOVERNANCE SERVICES TYPE OF APPLICATION Grant of a Short-Term Let Licence APPLICANT Mr Peter Bremner MacDonald PREMISES (if applicable) Schiehallion House, Strathtummel, Aberfeldy, Perth and Kinross, PH16 5NT THE APPLICATION Mr MacDonald, the sole Applicant, has applied for a three-year short-term let licence as a new host. The Application has been validated by Licensing Officers and was sent out for consultation. Police Scotland, Scottish Fire and Rescue Services, and PKC Planning Department have stated they have no objections to this application. The short-term let property is a detached house. The Application is for that of a ‘Secondary Letting’ short-term let licence. The property has five bedrooms the Applicant has applied for a maximum capacity of ten guests. The Day-to-Day Manager is Catriona Watson-Brown Aldcharmaig, Strathtummel, Pitlochry, Perth and Kinross, PH16 5NT. Ten letters of objection have been received alongside one letter of representation with regards to this Application (see attached letters of objection and representation). RELEVANT LICENSING POLICIES The Council’s Short Term Let Policy was approved by the Licensing Committee on 22 September 2022. The Council’s Short-Term Lets Policy focuses on ensuring that an efficient, effective and proportionate licensing scheme is in place, which is customised to the needs and circumstances of the Council’s local area and supports applicants who wish to obtain a short-term let licence. The aims of the licensing scheme are: • to ensure all short-term lets are safe; • to facilitate licensing authorities in knowing and understanding what is happening in their area; and • to assist with handling complaints and address issues faced by neighbours effectively. In assessing an application for a short-term lets licence, the Council will consider: • the suitability of the person applying and that of the other people named on the application form (whether they are “fit and proper”); • compliance/ability to comply with mandatory conditions (applicable to all short-term lets across Scotland) (copy 5 Page 21 of 64
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attached); • compliance/ability to comply with any additional conditions that the Council might attach to the licence (either specific to the accommodation, or specific to short-term lets in Perth and Kinross); and • the suitability of the premises in the context of Perth and Kinross Council’s policies. The Council may vary the terms of a licence on any grounds they think fit and can do this at any time. This can be done following an application made to the Council by the licence holder on their own initiative. This could include adding further conditions to the licence. The Council will consult with the statutory consultees and any other parties it considers appropriate. Conditions attached to a Short-term Let Licence Mandatory Conditions Any Licence will be subject to Conditions. Under the 2022 Order, there are certain conditions which the Council must attach to a short-term let licence, irrespective of the type of short-term let granted, whether it is Secondary Letting, Home Letting, Home Sharing or Home Letting and Home Sharing. These are known as “mandatory conditions” and are detailed at Annex A. Please note that the Council has no power to amend these mandatory conditions. All applicants should ensure, prior to applying for a short-term let licence of any type that they are able to comply with the mandatory conditions attached to a licence. Applicants should also note that in term of listing their premises as a licensed short-term let, as required under mandatory condition 14, the listing must include the licence number provided by the Council and the valid energy performance certificate rating) if an Energy Performance Certificate is required for the premises, in accordance with the Energy Performance of Buildings (Scotland) Regulations 2008. LEGAL POSITION The Civic Government (Scotland) Act 1982 provides grounds for refusal of a short-term let licence. Any decision to refuse a short- term let licence must be relevant to one or more the following grounds of refusal as detailed in the Civic Government (Scotland) Act 1982:- A licensing authority must grant the application unless one of the grounds of refusal exists. If, in the opinion of the Committee, a ground of refusal exists then the application must be refused. The grounds of refusal are:- (a) the applicant or, where the applicant is not a natural person, Page 22 of 64
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any director of it or partner in it or any other person responsible for its management, is either – (i) for the time being disqualified under section 7(6) of this Act, or (ii) not a fit and proper person to be the holder of the licence; (b) the activity to which it relates would be managed by or carried on for the benefit of a person, other than the applicant, who would be refused the grant or renewal of such a licence if he made the application him/herself; (c) where the licence applied for relates to an activity consisting of or including the use of premises, those premises are not suitable or convenient for the conduct of the activity having regard to – (i) the location, character or condition of the premises; (ii) the nature and extent of the proposed activity; (iii) the kind of persons likely to be in the premises; (iv) the possibility of undue public nuisance; or (v) public order or public safety; or (ca) the applicant would not be able to secure compliance with: (i) the mandatory licence conditions, and (ii) the standard conditions and any further conditions to which the licence is to be subject; (cb) the application does not contain the consent of the owners of the premises; or ( (d) there is other good reason for refusing the application; and otherwise shall grant the application. In deciding whether or not to grant or renew a Licence, the Council will consider each Application on its own merits and will take into account the following: • any Objections or Representations • this Licensing Policy Statement • any other relevant considerations OPTIONS The Committee need to consider whether the objections received relate to the activity of a short term let licence. The options open to the Committee are therefore to: • grant the application; • grant the application for a shorter period of time; • grant the application with additional conditions; or • refuse the application if one of the grounds for refusal exist. Page 23 of 64
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Annex A – Mandatory Conditions Mandatory conditions will be applied to all types of short-term let licences (as specified in schedule 3 of the Order) and Temporary Exemptions. The following are mandatory conditions and will apply to all licences issued:- Agents 1. Only those named as a holder of the licence can carry out the day to day management of the short- term let of the premises. Type of licence 2. The holder of the licence may only offer the type of short-term let for which the licence has been granted. Fire safety 3. The holder of the licence must ensure the premises has satisfactory equipment installed for detecting, and for giving warning of - (a) fire or suspected fire, and (b) the presence of carbon monoxide in a concentration that is hazardous to health. 4. The holder of the licence must keep records showing that all upholstered furnishings and mattresses within the parts of the premises which are for guest use, or to which the guests are otherwise permitted to have access, comply with the Furniture and Furnishings (Fire Safety) Regulations 1988(1). PROCEDURE • Identify parties • Consider any preliminary issues • Members of the public speak to their representation(s)/objection(s) • Committee asks any questions to the objectors • Applicant makes submission • Committee asks any questions of the applicant • Objector/s sum up • Applicant sum up • Committee makes decision Page 24 of 64
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Gas safety 5. Where the premises has a gas supply - (a) the holder of the licence must arrange for an annual gas safety inspection of all gas pipes, flues and appliances in the premises, (b) if, after an annual inspection, any appliance does not meet the required safety standard, the holder of the licence must not allow a short-term let of the premises until the works necessary to bring the appliance to the required safety standard have been carried out. Electrical safety 6. Where there are electrical fittings or items within the parts of the premises which are for guest use, or to which the guests are permitted to have access, the holder of the licence must - (a) ensure that any electrical fittings and items are in - (i) a reasonable state of repair, and (ii) proper and safe working order, (b) arrange for an electrical safety inspection to be carried out by a competent person at least every five years or more frequently if directed by the competent person, (c) ensure that, following an electrical safety inspection, the competent person produces an Electrical Installation Condition Report on any fixed installations, (d) arrange for a competent person to— (i) produce a Portable Appliance Testing Report on moveable appliances to which a guest has access, and (ii) date label and sign all moveable appliances which have been inspected. 7. In determining who is competent, the holder of the licence must have regard to guidance issued by the Scottish Ministers under section 19B(4) of the Housing (Scotland) Act 2006. Page 25 of 64
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Water safety: private water supplies 8. Where the premises are served by a private water supply, the licence holder must comply with the requirements on the owners of private dwellings set out in the Water Intended for Human Consumption (Private Supplies) (Scotland) Regulations 2017. Water safety: legionella 9. The holder of the licence must assess the risk from exposure to legionella within the premises, whether or not the premises are served by a private water supply. Safety & repair standards 10. — (1) The holder of the licence must take all reasonable steps to ensure the premises are safe for residential use. (2) Where the premises are subject to the requirements of Chapter 4 of Part 1 of the Housing (Scotland) Act 2006, the holder of the licence must ensure that the premises meet the repairing standard. Maximum Occupancy 11. The licence holder must ensure that the number of guests residing on the premises does not exceed the number specified in the licence. Information to be displayed 12. The holder of the licence must make the following information available within the premises in a place where it is accessible to all guests - (a) a certified copy of the licence and the licence conditions, (b) fire, gas and electrical safety information, (c) details of how to summon the assistance of emergency services, (d) a copy of the gas safety report, (e) a copy of the Electrical Installation Condition Report, and (f) a copy of the Portable Appliance Testing Report. Planning Permission 13. Where the premises is in a short-term let control area for the purposes of section 26B of the Town and Country Planning (Scotland) Act 1997(4) (“the 1997 Act”), the holder of the licence must, where the use of the premises for a short-term let requires planning permission under the 1997 Act, ensure that either— (a) an application has been made for planning permission under the 1997 Act and has not yet been determined, or Page 26 of 64
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(b) planning permission under the 1997 Act is in force. Listings 14. - (1) The holder of the licence must ensure that any listing or advert (whether electronic or otherwise) for the short-term let of the premises includes - (a) the licence number, and (b) a valid Energy Performance Certificate rating if an Energy Performance Certificate is required for the premises, in accordance with the Energy Performance of Buildings (Scotland) Regulations 2008(5). (2) The holder of the licence must ensure that any listing or advert (whether electronic or otherwise) for the short-term let of the premises is consistent with the terms of the short-term let licence. Insurance 15. The holder of the licence must ensure that there is in place for the premises - (a) valid buildings insurance for the duration of the licence, and (b) valid public liability insurance for the duration of each short-term let agreement. Payment of fees 16. The holder of the licence must pay any fees due to the licensing authority in respect of the licence on demand. False or misleading information 17. The holder of the licence must not provide any false or misleading information to the licensing authority. Interpretation 18. In this schedule - “Electrical Installation Condition Report” means a report containing the following information – (a) the date on which the inspection was carried out, (b) the address of the premises inspected, (c) the name, address and relevant qualifications of the person who carried out the inspection, (d) a description, and the location, of each installation, fixture, fitting and appliance inspected, Page 27 of 64
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(e) any defect identified, (f) any action taken to remedy a defect, “Energy Performance Certificate” means a certificate which complies with regulation 6 of the Energy Performance of Buildings (Scotland) Regulations 2008), “gas safety report” means a report containing the following information - (a) the date on which the appliance or flue was checked, (b) the address of the premises at which the appliance or flue is installed, (c) a description of and the location of each appliance or flue checked, (d) any safety defect identified, (e) any remedial action taken, (f) confirmation that the check undertaken complies with the requirements of an examination of - (i) the effectiveness of any flue, (ii) the supply of combustion air, (iii) subject to head (iv), its operating pressure or heat input or, where necessary, (iv) if it is not reasonably practicable to examine its combustion performance, (v) its operation so as to ensure its safe functioning, (g) the name and signature of the individual carrying out the check, and (h) the registration number with which that individual, or that individual’s employer, is registered with a body approved by the Health and Safety Executive for the purposes of regulation 3(3) of the Gas Safety (Installation and Use) Regulations 1998(7), “holder of the licence” means any person to whom a short-term let licence has been granted or jointly granted, “home letting” means a short-term let consisting of the entering into of an agreement for the use, while the host is absent, of accommodation which is, or is part of, the host’s only or principal home, Page 28 of 64
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“home sharing” means a short-term let consisting of the entering into of an agreement for the use, while the host is present, of accommodation which is, or is part of, the host’s only or principal home, “premises” means the accommodation which is the subject of an application for a short-term licence or the subject of a short-term licence, “repairing standard” means the steps which the holder of the licence is required to take to comply with the obligations placed on the holder by Chapter 4 of Part 1 of the Housing (Scotland) Act 2006(8), “secondary letting” means a short-term let consisting of the entering into of an agreement for the use of accommodation which is not, or is not part of, the licence holder’s only or principal home, “short-term let” has the same meaning as in article 3 of the Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022, “short-term let licence” means a licence for a short-term let, and “type of short-term let” means one of the following purposes - (a) secondary letting, (b) home letting, (c) home sharing, or (d) home letting and home sharing. Page 29 of 64
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1 SPR STL From: Sent: 03 June 2025 17:06 To: Subject: Objection to Application for secondary letting at Schiehallion House, PH16 5NT Follow Up Flag: Follow up Flag Status: Completed Categories: OBJECTIONS/COMPLAINTS 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. I, Peter Pejacsevich of Domnaheiche, Foss, Pitlochry Perthshire PH16 5NQ wish to object to the Application for Secondary Letting at Schiehallion House, Strath Tummel, Perthshire PH16 5NT . I list my reasons below . 1/ Schiehallion House faces directly onto Loch Tummel and thus the sound of large groups using it and its lawn, which runs down to the water’s edge, will carry far to the disturbance of neighbours, particularly those on the opposite bank . 2/ Loch Tummel is a tranquil loch used by fisherman and sailors. Indeed the Riparian Association has a voluntary agreement to exclude motorised craft whose bows rise out of the water at speed, the exception being the safety boat of the sailing club. The proposed future Boat House at Schiehallion House would go against this intention, if it housed jet skis and other fast moving motorised water craft. Their location and use so close to the Loch Tummel Sailing Club on the southern shore would also endanger sailors. 3/ The premises was recently given permission to be built as a home. For the owner to now apply for Secondary Letting permission represents a significant change in the building’s use which might have resulted in the original application being rejected if it had been previously known about particularly when one notes the close proximity of the Strath Tummel Inn available to visitors. I believe that the above demonstrate that Schiehallion House is not suitable to be granted Secondary Letting permission because of : Its location and character ; the nature and extent of its proposed new activity ; and the possibility of undue public nuisance. I thank you for your consideration of these observations and opinions, Best regards 5 Page 31 of 64
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1 SPR STL From: Sent: 10 June 2025 19:00 To: SPR STL Subject: Objection to short term letting at Shehallion House - UPRN - 124112461 Attachments: A boat on the water at night Description automatically generated.jpeg Categories: OBJECTIONS/COMPLAINTS Licensing Legal and Governance Perth and Kinross Council Pullar House 35 Kinnoull Street Perth PH1 5GD 27/05/2025 PKC Short-Term Let Licence Application ID: 2271 UPRN: 124112461 To Whom It May Concern, I write to formally object to the above application for a Short-Term Let (STL) licence at: Schiehallion House, Aldcharmaig, PH16 5NT, located on the north shore of Loch Tummel. This objection is submitted on the basis of: • NPF4 Policy 30(e) of the National Planning Framework 4, • The relevant provisions of the Perth & Kinross Local Development Plan (2019) • The STL licensing criteria under the Civic Government (Scotland) Act 1982. 1. Planning History and Policy 30(e)(ii) – Loss of Residential Accommodation This property was granted consent in 2019 under planning reference 18/01875/FLL for the erection of a dwellinghouse, not for a commercial STL business. To immediately seek change of use upon completion to a commercial letting business is contrary to the letter and spirit of the original consent. As the property has never been occupied, it seems the initial application was submitted under a false premise, with intent to build commercial premises, disregarding the essential purpose of planning applications. The owner had assured local residents that he was building a personal home, but now has openly stated he always intended to use the property as a short-term let business. Under NPF4 Policy 30(e)(ii), short-term letting of existing buildings should not result in the loss of residential accommodation unless justified by demonstrable local economic benefit. In this case, the economic impact for the community is likely to be minimal and will not outweigh the permanent loss of a newly completed, family-size residential home. This proposal therefore fails to satisfy this limb of the policy.2. NPF4 Policy 30(e)(i) – Unacceptable Impact on Amenity and Character A 10-person short-term rental property introduces high occupancy turnover and anti-social ‘party’ activity that is intensive and unpredictable compared to a permanent home. The intended use of speedboats and outdoor party areas for large groups may attract stag- and hen-dos, and adult birthday parties with increased alcohol consumption, rather than family holiday rentals. 5 Page 33 of 64
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2 The scale and commercial intent of the building is incompatible with the quiet, rural, residential character of the surrounding area. The major majority of the houses at this place on the loch are homes for families who live here full- time. 3. Waterfront Access, Lochside Use and Intensification The property has direct loch access via a private pier, creating scope for motorised leisure activity on a loch where such use is currently rare and low-impact. Loch Tummel is known for its peaceful environment, used primarily for passive recreation such as fishing. Short-term letting groups, with no long-term stake in the community, bring a high risk of anti-social behaviour, on land and water. Noise from jet skis, motor-boats, or shoreline activity would undermine the natural character of the loch and increase disruption to nearby residents and fishermen. We experienced the first example of this on Saturday 7th June. To loud music, and cheers, a large party of guests were given a display of the owner’s speedboat racing past the house several times with a huge Union Jack flag trailing behind. For many years there has been an understanding that motorized boats stick to a 5mph speed limit on the loch. This protects the sailing club’s small dinghies on which young children learn to sail. This agreement is being ignored by the owner. Loch Tummel’s surroundings already have significant problems from transient visitors 'wild camping', though typically this is 'car and campervan camping' with much noise, litter, fire-lighting and anti-social behaviour. Residents are frequently verbally abused by these visitors and you may be aware of a recent serious physical assault on a resident by a tourist. The ‘party’ premises Shehallion House will provide may encourage and exacerbate noisy behaviour by campers seeing this as acceptable noise and lighting levels. 4. Sound and Light Amplification Across Water Research confirms sound travels more efficiently over water than over land, especially in calm conditions. Local experience supports this. At Foss the loch just 0.58 miles (0.93 km) wide across open water. Everyday noise such as music, motors, and conversation is audible at Foss from the north shore. The building noise from Shehallion house proves how far sound from the property travels. Noise from parties at night will be horrendous. This is not a modest residence, but a multi-level, mansion-scale structure with an expansive loch frontage. Existing mature trees have been removed contrary to planning stipulations. The house is brightly illuminated at night. Its three- tiered elevation means artificial lighting is reflected on to the loch, creating the appearance of a six-tiered building. This is particularly harmful given the setting within a National Scenic Area, where natural darkness is part of the protected character. These effects are not hypothetical - they are already being experienced. On Saturday 7th June, the house remained fully illuminated until after 3 am. The party lit a huge bonfire, which they did not extinguish before retiring to bed. At 3 am it was still blazing without supervision. It is clear this is how the owner will allow guests to behave, ruining the life-quality, and fire safety, for local residents on potentially any and every day of the year. Photos below show the impact of lighting from the building, even at 3am. The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location. The house lit up all night and the size of the fire in the garden (taken from my house across the loch). Page 34 of 64
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3 Photograph proving the time (2.52am) that the unsupervised fire was still burning. 5. Licensing Grounds – Nuisance The Civic Government (Scotland) Act 1982 allows licensing authorities to refuse an STL application where the use is likely to cause nuisance to neighbours or the public. The evidence of amplified sound across water, persistent light intrusion/reflection, social/holiday use, bonfires, and loch-side activity by transient visitors pose an unacceptable risk of nuisance. Conclusion This application: Fails NPF4 Policy 30(e)(ii): unjustified loss of a newly built residential home; and the PKC Short-Term Let Licensing Policy, particularly in relation to residential amenity, overdevelopment, and environmental impact. The property threatens nuisance under STL licensing legislation, introducing persistent risks including anti-social behaviour, alcohol fuelled parties, unsupervised fires, noise from party music and motorised speedboats, and light pollution. It will result in the loss of a family-sized, residential property to solely commercial use without financial benefit to the area other than to the owner. The potential to bring a family, living full-time to the area is so important. I hope the planners will see that such a prominent, disrespectful, loch-side holiday rental, offering speedboats with Union Jack flags, cannot be reconciled with either planning or licensing objectives for sustainable, respectful development in scenic, rural Scotland. I respectfully plead with the licensing authority to consider refusal of this application. Yours faithfully, Alison MacLeod The Granary Foss Home Farm Pitlochry Perth & Kinross PH16 5NQ Page 35 of 64
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1 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 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. 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. 5 Page 37 of 64
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2 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 Page 38 of 64
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3 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 Page 39 of 64
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Comments on Short -Term Let Licence Application ID: 2271 UPRN: 124112461 Application Submitted: 20 May 2025 To Whom it May Concern, I am writing in my capacity as Commodore for Loch Tummel Sailing Club to formally object to above application for a short-term let licence at Aldcharmaig on the North shore of Loch Tummel. Loch Tummel Sailing Club is located on the South shore of the Loch directly opposite Aldcharmaig. Our sailing area is immediately in front of the club and we run a regular calendar of sailing for dinghies and small keelboats from April through to October. The loch benefits from limited use by motorised watercraft, with longstanding code of conduct agreements from surrounding residents restricting powerboat use. This makes it a safe, tranquil environment for those using the loch to sail or for paddle sports and making it relatively unique in Scotland. At the sailing club our lease of the foreshore explicitly prevents launch of motorised craft other than rescue boats necessary for safety purposes. The club has always been recognised as a great environment for families to learn to sail. We regularly have children out sailing on the loch, hold camps for children learning to sail and host community days or local charities allowing those from the local area to come along and try sailing and make use of the loch. Aldcharmaig benefits from direct access to the Loch including a private jetty, with this access being in the middle of the sailing area used by the club. Whilst we have no general objection to the property being granted a short-term let licence, we do have significant concerns about the safety risks presented by any unregulated powerboat or jet ski use, particularly from guests who will not be familiar with the existing code of conduct on the loch. 5 Page 47 of 64
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Should the Licencing Authority include an explicit restriction on motorised access to the loch as part of the terms of the licence then we would have no other objection. This would be consistent with the terms of our own foreshore lease, ensure that the existing agreements which serve to limit motorised access to the loch are respected and prevent risks to club members including young children. Yours faithfully Iain Macintyre Commodore, Loch Tummel Sailing Club Loch Tummel Sailing Club Foss Pitlochry PH16 5NQ Page 48 of 64
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Objection to Short-Term Let Licence Application at Aldcharmaig/ Schiehallion House PKC Short-Term Let Licence Application ID: 2271 UPRN: 124112461 Application submitted: 20 May 2025 We write to tender our formal objections to the above application for a short-term let licence at Aldcharmaig, Loch Tummel. Under Reference 18/01875/FLL, planning consent was granted, on 6 February 2019, for the erection of a private dwellinghouse. This current application now seeks to change, fundamentally and materially, the use of the property by converting it to a commercial short- term let to accommodate up to 10 guests. This raises serious concerns regarding the impact on the local area. Unfortunately, none of the proprietors across the loch from Aldcharmaig was consulted on the application for the construction of the original dwelling and the position and size of the house, and its outbuildings, already have an obvious visual impact. Light from the property reflects strongly off the water, particularly at night. This is likely to be intensified if the property is being used as, in effect, a hospitality venue. There was considerable noise disturbance when the building of the house was taking place and if the property is now to be used as a holiday let then this is going to continue and intensify. It is well known that sound travels audibly across water, particularly during calm weather, and even low-level conversations and low-volume music will be clearly heard by the proprietors on the south side. Usage of the loch is also going to be an issue. To date, this has been a tranquil loch used by sailors and anglers and where there has been general consensus about the watercrafts which were suitable. There is a long-established sailing club on the south side of the loch and outboard motors for other boats are generally restricted to a maximum of 5 horsepower. All this would be threatened if, for example, power boats, water or jet skis were to be offered for use by guests. There would undoubtedly be noise disruption as well as serious safety concerns for other loch users. We feel that were this property to be granted a licence for short-term letting the impact on the local environment and on resident loch dwellers would be immense and we, therefore, submit that the application should be refused. Dr Namdar Mossaheb Sronan Foss PH16 5NQ Ishbel Jane Dow McLaren (Mrs N Mossaheb) Sronan Foss PH16 5NQ 5 Page 49 of 64
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1 SPR STL From: Sent: 05 June 2025 17:54 To: SPR STL Subject: Objection to STL licence application Categories: OBJECTIONS/COMPLAINTS 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. To whom it may concern I am writing to register my objection to the application for a short-term letting licence details of which are given below; Ref no: 124112461 ID: 2271 Schiehallion House Strathtummel Aberfeldy PH16 5NT At the time of application the property in question is only at or nearing completion of construction. The original application for planning permission (granted in 2019) to construct the house in question was for a " dwelling house". The house therefore to all intents and purposes has not been used as a private dwelling which is perhaps a separate issue as it contradicts the purpose for which planning was granted in the first place. This is pertinent as the area is currently under consultation for designation as a STL Control Area Putting the above point to one side my immediate concerns are: The property, which is large, built over 4 floors and sits on the north shore of loch Tummel, already imposes a significant visual impact when viewed from the water and the south shore. The impact and potential for sound and light pollution as guests, of whom there may be up to 10 at any one time, use the facilities should not be underestimated. Living opposite the site on the south shore of the loch, I can testify to the levels of noise we have had to put up with during 5 years of construction! The peace and tranquility of what is both a designated scenic area and a special area of conservation is at risk. Noise transmits freely over water and is often magnified by the hillside and woods behind. Light is reflected on the waters surface multiple times and the effect to residents having to endure this will be deleterious. All of which negatively impacts on residents and visitors enjoyment of the surrounding environment and their own property. The house has provision for launching and berthing watercraft. This poses the potential for the use of motorised watercraft . Currently, and for many years now, use of motorised watercraft has been restricted by a "locals agreement" to day cruisers operated at slow speed so causing a minimum of disturbance to people and wildlife. Also the local sailing club operates rescue boats observing safe 5 Page 51 of 64
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2 and considerate speeds. IF a STL licence were granted and should the need arise, would there be a willingness to comply with this? It would be difficult and it would need to be voluntary. Difficult when guests want to have a good time, are ephemeral and only there for a short stay. The proposed change of use from a dwelling to commercial short term let holiday business will increase significantly the level of footprint and activity from the site in all aspects. To date no attempt has been made to reduce the visual impact of the property. A considerable number of trees were felled to clear the site for construction which has also opened the properties views to the loch. Unfortunately, without any mitigating landscaping and planting to buffer this it is reciprocal and now other house owners and members of the public have no other option but to look back. Lastly, I also would like to point out that when the original planning application was submitted and approved for Schiehallion House (then referred to as Aldcharmaig) being the name for the original cottage on the site, permission was sought and granted for another large building, a boathouse at the western end of the property. As construction on this has not yet begun I can only anticipate that there is more noise and disturbance to come. I strongly recommend that the application for a STL is rejected David Gifford North Cottage Foss Nr Pitlochry PH 16 5NQ Page 52 of 64
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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. 5 Page 53 of 64
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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 Page 54 of 64
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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 Page 55 of 64
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Licensing Legal and Governance Perth and Kinross Council Pullar House 35 Kinnoull Street Perth PH1 5GD 27/05/2025 PKC Short-Term Let Licence Application ID: 2271 UPRN: 124112461 To Whom It May Concern, I am writing to formally object to the above application for a Short-Term Let (STL) licence at: Schiehallion House, Aldcharmaig, PH16 5NT, located on the north shore of Loch Tummel. This objection is submitted on the basis of: • NPF4 Policy 30(e) of the National Planning Framework 4, • The relevant provisions of the Perth & Kinross Local Development Plan (2019), and • The STL licensing criteria under the Civic Government (Scotland) Act 1982. 1. Planning History and Policy 30(e)(ii) – Loss of Residential Accommodation This property was only recently completed, having been granted consent in 2019 under planning reference 18/01875/FLL for the erection of a dwellinghouse, not for a commercial STL business. To immediately seek change of use upon completion to a commercial short-term let is contrary to both the letter and spirit of the original consent. Under NPF4 Policy 30(e)(ii), short-term letting of existing buildings should not result in the loss of residential accommodation unless justified by demonstrable local economic benefit. In this case, the economic impact is likely to be minimal and certainly does not outweigh the permanent loss of a newly completed residential home. This proposal therefore clearly fails to satisfy this limb of the policy. 5 Page 57 of 64
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2. NPF4 Policy 30(e)(i) – Unacceptable Impact on Amenity and Character The proposed use is materially different from a private dwelling in terms of: • Frequency and turnover of occupants, • Expectation of “holiday behaviour” (often louder and more sociable), and • The intensification of activity, particularly during evenings and weekends. A 10-person short-term rental property introduces high turnover, high occupancy social activity, and more intensive, unpredictable use than a permanent home. This is incompatible with the quiet, rural, residential character of the surrounding area. 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. The scale and visual dominance of the property are already highly prominent from across the loch. This is not a modest residence - it is a multi-level, mansion- scale structure with an expansive loch frontage. The building is already a stark and visually jarring imposition on the landscape - even before any consideration of intensified commercial usage adding further to nuisance from noise, light, and potential for water-based activity. 3. Waterfront Access, Lochside Use and Intensification The property includes direct loch access via a private pier or jetty, which creates scope for motorised leisure activity on a body of water where such use is currently rare and low-impact. Loch Tummel is known for its peaceful environment, used primarily for passive recreation with longstanding riparion owner agreement on restriction of motorised activity. The introduction of short-term guests - particularly large, transient groups with no long-term stake in the community and who may not be aware of local norms - brings a risk of amplified disturbance, both on land and on the water. Potential noise from jet skis, motor-boats, or shoreline activity would further undermine the natural character of the loch and increase disruption to nearby residents. Page 58 of 64
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4. Sound and Light Amplification Across Water Scientific research confirms that sound travels much more efficiently over water than over land, especially in calm conditions. Local experience supports this - at a distance of just 0.58 miles (0.93 km) across open water to the residential settlement at Foss, everyday noise - such as music or conversation - is already clearly audible on the opposing shore on a calm day. Residents on the south shore routinely hear activity the north shoreline with unexpected clarity, even under normal use. The house is also highly illuminated at night, and its three-tiered elevation means artificial lighting is reflected off the loch, increasing it’s visual impact after dark, effectively creating the appearance of a six-tiered building. This is particularly harmful given the setting within a National Scenic Area, where natural darkness is part of the protected character. These effects are not hypothetical - they are already being experienced. A change of use to commercial activity risks intensifying these disturbances, with greater frequency and less predictability. 5. Licensing Grounds – Nuisance The Civic Government (Scotland) Act 1982 allows licensing authorities to refuse an STL application where the use is likely to cause nuisance to neighbours or the public. The evidence of amplified sound across water, persistent light intrusion / refelction, social holiday use, and lochside activity intensification by transient visitors pose an unacceptable risk of nuisance and all support refusal of the license on these grounds. Conclusion This application: 1. Fails NPF4 Policy 30(e)(ii): unjustified loss of a newly built residential home; 2. Fails NPF Policy 30(e)(i): introduces an unacceptable impact on amenity, tranquillity, and landscape character; 3. Meets the definition of potential nuisance under STL licensing legislation. Page 59 of 64
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In summary, it is difficult to see how such a prominent, large-scale, lochside holiday rental can be reconciled with either planning or licensing objectives for sustainable, respectful development in scenic, rural Scotland. I therefore respectfully ask the licensing authority to consider the strong case for refusal of this application. Yours faithfully, Andrew Macintyre Foss Home Farm Pitlochry Perth & Kinross PH16 5NQ Page 60 of 64
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1 To The Licensing Committee, Perth and Kinross Council Date : 30th June 2025 The following representation has been agreed with the residents of Loch Tummel who have lodged objections to the following proposal. The text of this document has been approved by the objectors, has been copied to them and reflects their concerns. Representation regarding the Application for a licence for the use of the Residential Property at Aldcharmaig, Loch Tummel, as a short term let, without the benefit of a Change of Use Approval from the Perth and Kinross Planning Authority. Application Ref 124112461 Application Address PH16 5NT Yesterday, I attended a meeting of the Foss objectors to obtain a sense of their concerns regarding the above application. As recommended by the Licensing Authority, it has been agreed that an approach will be made to the owner of the property to see whether he is willing to take action that would reduce the potential effect of nuisance to the Foss inhabitants. It was noted by one of the objectors that she had already had a meeting with the owner, Mr MacDonald, and had found his attitude to her concerns dismissive; with no commitment being given that ameliorating actions would be taken. Another resident mentioned a recent party at the property during which a launch passed at high speed along the loch trailing a large Union Jack. Apparently, the party was in honour of an ex-marine, an army colleague of the owner. Such reports do not suggest any great willingness to be neighbourly, although a meeting will certainly be sought. The concerns expressed at the meeting were many and varied and since these have largely been expressed in individual objection letters, they are not repeated in this representation. Hardly surprisingly, most concerns are centred around how the property will be managed if a licence is granted. This is of course unknowable in advance, but since the owner categorically refused to state that stag and hen parties would not be held at the property, there is understandable worry. An important matter that has been commented on by one objector, , is the fact that Loch Tummel lies within a National Scenic Area. National Planning Framework 4 c) states that development that affects an NSA will only be permitted where; “Any significant adverse effects on its special qualities are outweighed by social, environmental or economic benefits of national importance. Planning Authorities should ensure that: - New development in.. an NSA doesn’t detract from the quality or character of the landscape - The scale, siting and design of such are appropriate - The design and landscaping are of a high standard” The wanton destruction of the tree landscape in front of the new house and along the loch frontage suggests that none of the above requirements have been met. Any aggressive use of the waterside facilities at Aldcharmaig will undoubtedly contravene the above requirements. 5 Page 61 of 64
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2 Advisory Guidance The following documentation from the Scottish Government and the Perth and Kinross Council identifies the fact that a Short-term Letting Application such as is proposed for the above property should have the benefit of an approval from the Planning Committee of the Perth and Kinross Council. There is no record of such an Application being made. Short Term Lets; Planning Guidance Published by The Scottish Government – 25 June 2021 2.1 Planning permission is required for ‘development’. The definition of development includes a material change of use of land or buildings, even if there are no physical alterations to the land or buildings. 2.6 Changing the use of a dwellinghouse to provide short term lets may constitute a material change of use requiring planning permission. Whether or not this is the case will depend upon the circumstances and factors which apply to the particular change of use. 2.7 There are a number of factors which may affect a planning authority’s consideration of whether a change of use is a material change of use. Factors include the change on local amenity and the character of a neighbourhood or area, safety and impact on immediate neighbours. 2.10 This means that planning permission for change of use from any other use as a short term let may be required in most cases. 2.18 Examples of material planning considerations are; 2.19 Guest arrival and departure times and whether these are at unsociable hours. 2.22 The high turnover of guests in short-term lets………increases the chance of some people wilfully or negligently failing to behave appropriately. 2.24 Likelihood of increased noise and general disturbance compared to the occupancy of a property on a permanent or long-term basis. 2.27 Guests may have different food shopping habits than permanent residents, possibly bringing provisions with them rather than using local food retailers. 2.28 More people ………are likely to have more impact on neighbours. Greater numbers of people staying are likely to be an amplifying factor on …..considerations. (by the Planning Department) Page 62 of 64
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3 Perth and Kinross Council Advice: “Short term lets - Development Management” “Checklist - Do I need Planning permission to use my property as a short term let? If the answer to any of the following is ‘YES’ then you need Planning Permission Question 4. Will any guests be regularly checking in or out at unsociable hours? Question 6. Will parties be held in the property by guests? (including accepting stag and hen bookings etc) Question 9. Do you consider that the use of the property might detract from the character or amenity of the area in any way? From the above, it is suggested that a Planning Application for Change of Use to a short term letting operation should have been lodged. It is hardly contentious to state that the use of Aldcharmaig House as a short-term let will inevitably affect the ‘character or amenity’ of the Loch Tummel neighbourhood. The loch is a unique microcosm, completely different from an urban or even a village environment. A short term let of the scale and facilities; eg huge games room, sauna, hot tub, speedboats etc cannot help but attract a particular clientele affecting the tranquility of the area. Statement from the Licensing Authority In connection with the above application, the Licensing Authority has stated that since “there is no Control Area within Perth and Kinross , there is no requirement for planning permission to be secured before a short-term licence may be granted”. However, “the granting of a short-term licence does not supersede the requirement for planning permission if the Planning Authority determines that it is required.” Statement from The Planning Department The Planning Department of PKC has responded to questions regarding the above Application with the following statement. “Based on the information within the submission (the short-term letting application), the planning department consider that planning permission is required for change of use and licencing have been advised of this. The Planning Support Officer will write to the applicant to advise the planning departments position.” As at 23/06/25, “no change of use (application) has taken place to date.” Page 63 of 64
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4 Submission The Licensing Authority may grant a licence for a short-term let and if an application for Planning Consent has not been determined by that time, the owners of the property may start their commercial operations. A refusal of Consent or operational restrictions being placed on the operation of the let, means that two separate departments of the Council will have arrived at contradictory positions regarding the use of the above property. It is easy to imagine circumstance under which the property owner could launch legal action regarding this contradiction, particularly if the owner is forced to suspend or alter his commercial activities. There is no need for this anomalous situation to arise, because if the Planning Department requires an Application for a Change of Use and pursues it with energy, then the issue of consent, conditional consent or refusal will be clearly defined, allowing the Licensing Authority to take its own decisions regarding the license. It is therefore suggested that the Licensing Authority pauses the application for a short-term letting license until such time as the Planning Department has concluded whether a Change of Use Application is appropriate. A Planning Application is the appropriate forum in which the competing claims of environmental effects and commercial advantage can be assessed. If the Licensing Authority feels compelled to grant a licence then it is suggested that stringent operational conditions be applied to the licence. Signed, David K Taylor. Barch Drumnakyle, By Foss, Tummel Bridge, Perthshire PH16 5NJ Statement: The Committee is respectfully requested to consider this representation despite the fact that the deadline for this submission was missed by a day. I had been working in the Middle East until three days before the due date and had not been aware of the application to the Committee until my return to the UK. Page 64 of 64