(b) Planning Decision Notice, Report of Handling and Reference Documents (Pages 165-184)
Perth and Kinross Council · 27 January 2025
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4(ii)(b) LRB-2024-50 LRB-2024-50 24/01079/FLL - Change of use of flat to short-term let accommodation unit, 4A Breadalbane Terrace, Aberfeldy, PH15 2AG PLANNING DECISION NOTICE REPORT OF HANDLING REFERENCE DOCUMENTS (part included in applicant’s submission, pages 153-154)
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REPORT OF HANDLING DELEGATED REPORT Ref No 24/01079/FLL Ward No P4- Highland Due Determination Date 13th September 2024 Draft Report Date 22nd August 2024 Report Issued by John Williamson Date 22 August 2024 PROPOSAL: Change of use of flat to short-term let accommodation unit LOCATION: 4A Breadalbane Terrace Aberfeldy PH15 2AG SUMMARY: This report recommends refusal of the application as the development is considered to be contrary to the relevant provisions of the Development Plan and there are no material considerations apparent which justify setting aside the Development Plan. BACKGROUND AND DESCRIPTION OF PROPOSAL Full planning permission is sought for the change of use of a first floor, three bedroom flat to a short term let accommodation unit on Breadalbane Terrace in Aberfeldy. The flat is located within an attractive stone built, slate roofed, listed three storey block dating back to 1880. The site is located within the settlement boundary of Aberfeldy within an area allocated for residential and compatible uses in the Perth and Kinross Local Development Plan 2019. The Town and Neighbourhood Centre of Aberfeldy as allocated in the LDP2 is 63 metres to the south west. There are residential properties within the remainder of the flat block and the on the opposite side of Breadalbane Terrace. The neighbouring building to the south west is occupied by the Townhouse Hotel. Whilst there is a nearby hotel the area is considered to be predominantly residential in character. The building is category C listed and is located within the Aberfeldy Conservation Area. SITE HISTORY 12/01260/LBC Alterations to flats 15 November 2012 Application Approved 12/01265/FLL Alterations to flats 2 October 2012 Application Approved 24/01018/FLL Change of use from flat to short-term let accommodation unit 22 July 2024
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PRE-APPLICATION CONSULTATION Pre application Reference: n/a DEVELOPMENT PLAN The Development Plan for the area comprises National Planning Framework 4 (NPF4) and the Perth and Kinross Local Development Plan 2 (2019) (LDP2). National Planning Framework 4 The National Planning Framework 4 (NPF4) is the Scottish Government’s long-term spatial strategy with a comprehensive set of national planning policies. This strategy sets out how to improve people’s lives by making sustainable, liveable and productive spaces. NPF4 was adopted on 13 February 2023. NPF4 has an increased status over previous NPFs and comprises part of the statutory development plan. The Council’s assessment of this application has considered the following policies of NPF4: Policy 7: Historic Assets and Places Policy 13: Sustainable Transport Policy 14: Design, Quality and Place Policy 30: Tourism Perth and Kinross Local Development Plan 2 – Adopted November 2019 The Local Development Plan 2 (LDP2) is the most recent statement of Council policy and is augmented by Supplementary Guidance. The principal policies are: Policy 1A: Placemaking Policy 1B: Placemaking Policy 17: Residential Areas Policy 27A: Listed Buildings Policy 28A: Conservation Areas: New Development Policy 56: Noise Pollution Policy 60B: Transport Standards and Accessibility Requirements: New Development Proposals
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Statutory Supplementary Guidance Supplementary Guidance - Placemaking (adopted in 2020) OTHER POLICIES Non Statutory Guidance Conservation areas Finalised Short-Term Let Non-Statutory Planning Guidance (Consultation ended 18th August 2023) NATIONAL GUIDANCE The Scottish Government expresses its planning policies through The National Planning Framework, Planning Advice Notes, Creating Places, Designing Streets, National Roads Development Guide and a series of Circulars. Planning Advice Notes The following Scottish Government Planning Advice Notes (PANs) and Guidance Documents are of relevance to the proposal: PAN 40 Development Management PAN 51 Planning, Environmental Protection and Regulation PAN 61 Planning and Sustainable Urban Drainage Systems PAN 68 Design Statements PAN 69 Planning and Building standards Advice on Flooding PAN 75 Planning for Transport PAN 77 Designing Safer Places Creating Places 2013 Creating Places is the Scottish Government’s policy statement on architecture and place. It sets out the comprehensive value good design can deliver. It notes that successful places can unlock opportunities, build vibrant communities and contribute to a flourishing economy and set out actions that can achieve positive changes in our places. Designing Streets 2010 Designing Streets is the policy statement in Scotland for street design and changes the emphasis of guidance on street design towards place-making and away from a system focused upon the dominance of motor vehicles. It was created to support the Scottish Government’s place-making agenda, alongside Creating Places. National Roads Development Guide 2014 This document supports Designing Streets and expands on its principles and is considered to be the technical advice that should be followed in designing and approving of all streets including parking provision.
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CONSULTATION RESPONSES Internal Conservation Team – no objection Environmental Health (Noise Odour) - No objections subject to short term let licensing informative, and noise conditions would form part of any licence that was granted. External None REPRESENTATIONS 1 letter of representation has been received which raises concern regarding the impact which the change of use would have on residential amenity and also that the loss of this flat to an STL would put pressure on the balance of supply and demand of properties in Highland Perthshire. These issues are addressed within the appraisal section below. Additional Statements Received: Screening Opinion Not Required Environmental Impact Assessment (EIA): Environmental Report Not applicable Appropriate Assessment under Habitats Regulations Habitats Regulations AA Not Required Design Statement or Design and Access Statement Not Required Report on Impact or Potential Impact eg Flood Risk Assessment Not Required APPRAISAL Sections 25 and 37 (2) of the Town and Country Planning (Scotland) Act 1997 require that planning decisions be made in accordance with the development plan unless material considerations indicate otherwise. The Development Plan comprises NPF4 and the Perth and Kinross Local Development Plan 2019. The relevant policy considerations are outlined in the policy section above and are considered in more detail below. In terms of other material considerations, involving considerations of the Council’s other approved policies and supplementary guidance, these are discussed below only where relevant. In this instance, section 14(2) of the Planning (Listed Buildings and Conservation Areas) (Scotland) Act 1997 places a duty on planning authorities in determining such an application as this to have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which
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it possesses. Section 64(1) of the Planning (Listed Buildings and Conservation Areas) (Scotland) Act 1997 is relevant and requires planning authorities to pay special attention to the desirability of preserving or enhancing the character or appearance of the designated conservation area. The determining issues in this case are whether; the proposal complies with development plan policy; or if there are any other material considerations which justify a departure from policy. Policy Appraisal The proposal seeks to change the use of an existing first floor flat in Aberfeldy settlement to a short term let. The primary policy in this instance is NPF4 Policy 30(e): Tourism, as there is no specific LDP2 policies relating to Short-Term Let accommodation, particularly where changes of use of existing properties are concerned. As such, LDP2 Placemaking Policies 1A and 1B, and 17: Residential Areas have relevance for a proposal of this nature, and seek to protect or improve residential amenity, and create safe, accessible, inclusive places for people. Specifically, NPF4 Policy 30(e): Tourism states that Development proposals for the reuse of existing buildings for short term holiday letting will not be supported where the proposal will result in: i. An unacceptable impact on local amenity or the character of a neighbourhood or area; or ii. The loss of residential accommodation where such loss is not outweighed by demonstrable local economic benefits. In respect of criterion (i) of NPF4 Policy 30(e), the proposed use of the property as a short term let is not significantly different from a flat in terms of its physical appearance, the extent of guest footfall or noise emanating from the property, so long as good management practices are in place. However, the high turnover of guests is likely to be higher than typical private rented or owner-occupied accommodation, and this could have an impact on noise and disturbance to neighbours. Whereas such impacts may be offset in town centre or mixed-use areas, the same cannot be said for this building which comprises a number of residential flats within a residential block. Whilst there is a hotel located to the west and an allocated employment area to the north east, the building which the flat is located within is entirely residential in character and includes a shared stairwell which would be utilised by users of the STL and owner/occupiers of the neighbouring residential flats. The flat is also three bedrooms which potentially gives rise to larger parties utilising the STL which could have more scope for impact on the amenity of existing residential properties. In respect of criterion (ii) of NPF4 Policy 30(e), the proposal would result in the loss of a flat to short term let accommodation in an urban location. It is also acknowledged that the Council's Housing Strategy have undertaken consultation in respect of the introduction of a Short Term Let Control Area, however no such Control Area has yet been formally designated. It is also acknowledged that economic benefits can derive from small-scale short-term let accommodation which provides access to a range of attractions and activities for business and leisure
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guests alike. As such, the loss of this three-bedroom flat in Aberfeldy to short term let accommodation would not have a significant impact on the availability of residential accommodation in the local area. Notwithstanding this, the proposal, by virtue of its location in a residential building within an area which is predominantly residential in character, conflicts with NPF4 Policy 30(e)(i) Tourism, and the intent of LDP2 Policies 1A: Placemaking and 17: Residential Areas. The principle in this instance is therefore unacceptable. Residential Amenity NPF4 Policy 14: Design, Quality and Place and LDP2 Policies 1A: Placemaking, and 17: Residential Areas supports proposals, including business and tourism, which are compatible with the amenity and character of the surrounding area, and consistent with the six qualities of successful places. It is acknowledged that short term lets can result in additional levels of disturbance and noise concerns, and that the primary avenue to regulate such matters is via the separate licensing regime. In this instance, there is the potential for noise from the users of the property to affect neighbouring residential properties. The introduction of Civic Government (Scotland) Act 1982 (Licensing of Short-term Lets) Order 2022 requires these to licensed and noise conditions will form part of the licence. Notwithstanding this, a recent appeal decision from the DPEA elsewhere in Perth and Kinross at Birnam (ref: PPA-340-2155), indicated that management guidelines cannot be relied upon to restrict or control the adverse impacts on neighbouring properties and harm to amenity. Furthermore, harm to amenity could arise even if there is effective control, due to the frequent turnover of guests. The proposed intensification of use and movements would adversely impact the amenity of neighbouring residents within the host building and would alter the existing residential character of this part of Breadalbane Terrace and the surrounding predominantly residential area. As such, the proposal fails to accord with the intent of NPF4 Policy 14(c) and LDP2 Policies 1A and 17 in respect of residential amenity, by virtue of its location in a predominantly residential area. Conservation Considerations and Visual Amenity No external works are proposed as part of this proposed change of use of a listed flat within Aberfeldy Conservation Area . However, it could be argued that the introduction of a short-term let accommodation in predominantly residential areas which are in or adjacent to conservation areas may adversely affect the character of such places. Roads and Access The proposals raise no access or parking concerns due to it being a upper floor flat with parking available in the local area. There are bus stops nearby on Perth Street. In these respects the proposal accords with NPF4 Policy 13 and LDP2 Policy 60B.
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Drainage and Flooding There are no drainage or flooding concerns associated with this proposal. Waste Collection The waste collection arrangements are likely to be similar to the existing use as a flat and as such no concern is raised. Other Material Considerations STL Guidance adopted in November 2023 Non-statutory Planning Guidance for the Change of Use of Residential Property to Short-Term Let (STL Guidance) has recently been produced due to concerns expressed over the impact of STLs on services, local business staffing and expansion, as well as housing affordability. The STL Guidance was formally adopted by the Council on 1 November 2023 following consultation during Summer 2023. The STL Guidance acknowledges that while short-term lets can bring economic benefits to the host and local areas, this must be balanced against the impact the loss of that residential property has on the availability of housing for local people, affordable housing in particular, and the potential for adverse impacts on residential amenity where an increased proportion of the housing stock becomes short-term lets. Six considerations have been outlined within the STL Guidance to assist in the application of the policy framework set out in NPF4. The considerations include location, larger residential properties, refurbishment of long-term empty properties, local amenity and character, business diversification, and the relationship between loss of residential accommodation and local economic benefits. The location consideration contains reference to three area types: city and town centres; mixed- use areas within settlements; and predominantly residential areas. The adopted STL Guidance forms the most up-to-date indication of Council policy intent on the matter, and as such is a material consideration in addition to other policy factors and supplementary guidance in the assessment of the proposals. In this instance, the property is located within an entirely residential flatted block and whilst there are some mixed uses in the surrounding area, the overall character of this part of Breadalbane Terrace and this flatted block is residential. The properties on the opposite side of the road are all, also residential. Furthermore, the scale of the property, being three bedrooms also gives potential for a larger number of guests to utilise the STL which would increase the coming and going associated with the STL and therefore increase the potential disturbance to residential neighbours. The effect of the proposal on local amenity and character of this area should therefore be considered, in addition to the loss of residential accommodation and local economic benefits which may accrue from the proposal.
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In the absence of the formal designation of a Short Term Let Control Area, the proposed loss of this particular residence is not considered detrimental to housing availability in the wider area, and may have a modest economic benefit. However, as set out elsewhere in this report, the proposal raises concern in terms of residential amenity and its effect on the character of this residential building and area. Whilst it is preferable for a property to be occupied than not, the nature of the proposed short-term let use is finely balanced against the impact such uses can have in predominantly residential areas. It is considered that in this instance, the concern regarding residential amenity and the effect on the surrounding area attracts greater weight within the planning balance. As such, the proposal fails to accord with the policy intent of the adopted STL Guidance due to its location within a shared residential block in a predominantly residential area. This aligns with the officer assessment of the proposal against adopted Development Plan policies. Developer Contributions The Developer Contributions Guidance is not applicable to this application and therefore no contributions are required in this instance. Economic Impact The economic impact of the proposal is likely to be limited to guest and operator expenditure in the local economy. PLANNING OBLIGATIONS AND LEGAL AGREEMENTS None required. DIRECTION BY SCOTTISH MINISTERS None applicable to this proposal. CONCLUSION AND REASONS FOR DECISION To conclude, the application must be determined in accordance with the Development Plan unless material considerations indicate otherwise. In this respect, the proposal is considered to be contrary to the Development Plan. Account has been taken of the relevant material considerations and none has been found that would justify overriding the Development Plan. Accordingly the proposal is refused on the grounds identified below.
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Reasons for Refusal 1. The proposed change of use is contrary to Policy 30(e): Tourism of National Planning Framework 4 (2023) as the proposal results in: i) An unacceptable impact on local amenity and character of the area, and ii) The loss of residential accommodation where such loss is not outweighed by demonstrable local economic benefits. 2. The proposal is contrary to National Planning Framework 4 (2023) Policy 14(c): Design, Quality and Place and Perth and Kinross Local Development Plan 2 (2019), Policies 1A: Placemaking and Policy 17: (d) Residential Areas as the short-term let accommodation adversely impacts on the amenity of neighbouring residents and the short-term let use is not compatible with the amenity and character of the residential flatted block and surrounding predominantly residential area. Justification The proposal is not in accordance with the Development Plan and there are no material reasons which justify departing from the Development Plan. Informatives None Procedural Notes Not Applicable. PLANS AND DOCUMENTS RELATING TO THIS DECISION 01 02
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Page 1 of 7 Pullar House 35 Kinnoull Street Perth PH1 5GD Tel: 01738 475300 Fax: 01738 475310 Email: onlineapps@pkc.gov.uk Applications cannot be validated until all the necessary documentation has been submitted and the required fee has been paid. Thank you for completing this application form: ONLINE REFERENCE 100649483-003 The online reference is the unique reference for your online form only. The Planning Authority will allocate an Application Number when your form is validated. Please quote this reference if you need to contact the planning Authority about this application. Type of Application What is this application for? Please select one of the following: * Application for planning permission (including changes of use and surface mineral working). Application for planning permission in principle. Further application, (including renewal of planning permission, modification, variation or removal of a planning condition etc) Application for Approval of Matters specified in conditions. Description of Proposal Please describe the proposal including any change of use: * (Max 500 characters) Is this a temporary permission? * Yes No If a change of use is to be included in the proposal has it already taken place? Yes No (Answer ‘No’ if there is no change of use.) * Has the work already been started and/or completed? * No Yes – Started Yes - Completed Please state date of completion, or if not completed, the start date (dd/mm/yyyy): * Please explain why work has taken place in advance of making this application: * (Max 500 characters) Applicant or Agent Details Are you an applicant or an agent? * (An agent is an architect, consultant or someone else acting on behalf of the applicant in connection with this application) Applicant Agent My proposal is to apply for planning permission for a change of use of an existing 3 bedroomed residential property to a short term accomodation unit . There are no changes to be made to the property structurally either internally or externally which is a 3 bedroomed flat The property has only been re-painted and freshened up internally along with electrical and gas compliance checks , no works have been conducted on the property , as the owner of the property this is re-decorating work that would have been carried out as a matter of course whether this change of use had been proposed or not as the property was in a tired condition . There are no works/ changes planned for the property other than mentioned above 06/09/2023
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Page 2 of 7 Applicant Details Please enter Applicant details Title: You must enter a Building Name or Number, or both: * Other Title: Building Name: First Name: * Building Number: Address 1 Last Name: * (Street): * Company/Organisation Address 2: Telephone Number: * Town/City: * Extension Number: Country: * Mobile Number: Postcode: * Fax Number: Email Address: * Site Address Details Planning Authority: Full postal address of the site (including postcode where available): Address 1: Address 2: Address 3: Address 4: Address 5: Town/City/Settlement: Post Code: Please identify/describe the location of the site or sites Northing Easting Mr 4A BREADALBANE TERRACE Michael Perth and Kinross Council Pickersgill N/a ABERFELDY PH15 2AG 749233 285865
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Page 3 of 7 Pre-Application Discussion Have you discussed your proposal with the planning authority? * Yes No Site Area Please state the site area: Please state the measurement type used: Hectares (ha) Square Metres (sq.m) Existing Use Please describe the current or most recent use: * (Max 500 characters) Access and Parking Are you proposing a new altered vehicle access to or from a public road? * Yes No If Yes please describe and show on your drawings the position of any existing. Altered or new access points, highlighting the changes you propose to make. You should also show existing footpaths and note if there will be any impact on these. Are you proposing any change to public paths, public rights of way or affecting any public right of access? * Yes No If Yes please show on your drawings the position of any affected areas highlighting the changes you propose to make, including arrangements for continuing or alternative public access. How many vehicle parking spaces (garaging and open parking) currently exist on the application Site? How many vehicle parking spaces (garaging and open parking) do you propose on the site (i.e. the Total of existing and any new spaces or a reduced number of spaces)? * Please show on your drawings the position of existing and proposed parking spaces and identify if these are for the use of particular types of vehicles (e.g. parking for disabled people, coaches, HGV vehicles, cycles spaces). Water Supply and Drainage Arrangements Will your proposal require new or altered water supply or drainage arrangements? * Yes No Do your proposals make provision for sustainable drainage of surface water?? * Yes No (e.g. SUDS arrangements) * Note:- Please include details of SUDS arrangements on your plans Selecting ‘No’ to the above question means that you could be in breach of Environmental legislation. Are you proposing to connect to the public water supply network? * Yes No, using a private water supply No connection required If No, using a private water supply, please show on plans the supply and all works needed to provide it (on or off site). 86.00 This property’s most recent use was as a first floor residential 3 bedroomed flat situated within a mid terrace 0 0
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Page 4 of 7 Assessment of Flood Risk Is the site within an area of known risk of flooding? * Yes No Don’t Know If the site is within an area of known risk of flooding you may need to submit a Flood Risk Assessment before your application can be determined. You may wish to contact your Planning Authority or SEPA for advice on what information may be required. Do you think your proposal may increase the flood risk elsewhere? * Yes No Don’t Know Trees Are there any trees on or adjacent to the application site? * Yes No If Yes, please mark on your drawings any trees, known protected trees and their canopy spread close to the proposal site and indicate if any are to be cut back or felled. Waste Storage and Collection Do the plans incorporate areas to store and aid the collection of waste (including recycling)? * Yes No If Yes or No, please provide further details: * (Max 500 characters) Residential Units Including Conversion Does your proposal include new or additional houses and/or flats? * Yes No All Types of Non Housing Development – Proposed New Floorspace Does your proposal alter or create non-residential floorspace? * Yes No Schedule 3 Development Does the proposal involve a form of development listed in Schedule 3 of the Town and Country Yes No Don’t Know Planning (Development Management Procedure (Scotland) Regulations 2013 * If yes, your proposal will additionally have to be advertised in a newspaper circulating in the area of the development. Your planning authority will do this on your behalf but will charge you a fee. Please check the planning authority’s website for advice on the additional fee and add this to your planning fee. If you are unsure whether your proposal involves a form of development listed in Schedule 3, please check the Help Text and Guidance notes before contacting your planning authority. Planning Service Employee/Elected Member Interest Is the applicant, or the applicant’s spouse/partner, either a member of staff within the planning service or an Yes No elected member of the planning authority? * It’s my intention to have the relevant recycling bins in place as per the local councils recommendations and to match those of neighbouring premises respectively , if I can produce or utilise a bin store of some description to assist this application I will do so
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Page 5 of 7 Certificates and Notices CERTIFICATE AND NOTICE UNDER REGULATION 15 – TOWN AND COUNTRY PLANNING (DEVELOPMENT MANAGEMENT PROCEDURE) (SCOTLAND) REGULATION 2013 One Certificate must be completed and submitted along with the application form. This is most usually Certificate A, Form 1, Certificate B, Certificate C or Certificate E. Are you/the applicant the sole owner of ALL the land? * Yes No Is any of the land part of an agricultural holding? * Yes No Certificate Required The following Land Ownership Certificate is required to complete this section of the proposal: Certificate A Land Ownership Certificate Certificate and Notice under Regulation 15 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 Certificate A I hereby certify that – (1) - No person other than myself/the applicant was an owner (Any person who, in respect of any part of the land, is the owner or is the lessee under a lease thereof of which not less than 7 years remain unexpired.) of any part of the land to which the application relates at the beginning of the period of 21 days ending with the date of the accompanying application. (2) - None of the land to which the application relates constitutes or forms part of an agricultural holding Signed: Mr Michael Pickersgill On behalf of: Date: 29/10/2023 Please tick here to certify this Certificate. * Checklist – Application for Planning Permission Town and Country Planning (Scotland) Act 1997 The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 Please take a few moments to complete the following checklist in order to ensure that you have provided all the necessary information in support of your application. Failure to submit sufficient information with your application may result in your application being deemed invalid. The planning authority will not start processing your application until it is valid. a) If this is a further application where there is a variation of conditions attached to a previous consent, have you provided a statement to that effect? * Yes No Not applicable to this application b) If this is an application for planning permission or planning permission in principal where there is a crown interest in the land, have you provided a statement to that effect? * Yes No Not applicable to this application c) If this is an application for planning permission, planning permission in principle or a further application and the application is for development belonging to the categories of national or major development (other than one under Section 42 of the planning Act), have you provided a Pre-Application Consultation Report? * Yes No Not applicable to this application
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Page 6 of 7 Town and Country Planning (Scotland) Act 1997 The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 d) If this is an application for planning permission and the application relates to development belonging to the categories of national or major developments and you do not benefit from exemption under Regulation 13 of The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013, have you provided a Design and Access Statement? * Yes No Not applicable to this application e) If this is an application for planning permission and relates to development belonging to the category of local developments (subject to regulation 13. (2) and (3) of the Development Management Procedure (Scotland) Regulations 2013) have you provided a Design Statement? * Yes No Not applicable to this application f) If your application relates to installation of an antenna to be employed in an electronic communication network, have you provided an ICNIRP Declaration? * Yes No Not applicable to this application g) If this is an application for planning permission, planning permission in principle, an application for approval of matters specified in conditions or an application for mineral development, have you provided any other plans or drawings as necessary: Site Layout Plan or Block plan. Elevations. Floor plans. Cross sections. Roof plan. Master Plan/Framework Plan. Landscape plan. Photographs and/or photomontages. Other. If Other, please specify: * (Max 500 characters) Provide copies of the following documents if applicable: A copy of an Environmental Statement. * Yes N/A A Design Statement or Design and Access Statement. * Yes N/A A Flood Risk Assessment. * Yes N/A A Drainage Impact Assessment (including proposals for Sustainable Drainage Systems). * Yes N/A Drainage/SUDS layout. * Yes N/A A Transport Assessment or Travel Plan Yes N/A Contaminated Land Assessment. * Yes N/A Habitat Survey. * Yes N/A A Processing Agreement. * Yes N/A Other Statements (please specify). (Max 500 characters)
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Page 7 of 7 Declare – For Application to Planning Authority I, the applicant/agent certify that this is an application to the planning authority as described in this form. The accompanying Plans/drawings and additional information are provided as a part of this application. Declaration Name: Mr Michael Pickersgill Declaration Date: 29/10/2023 Payment Details Created: 14/07/2024 12:36