Agenda Document Pack - Pre-Determination Committee - 10/09/2025
Perth and Kinross Council · 10 September 2025
Back to Pre-Determination Committee — 10 September 2025 and its agenda
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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 03/09/2025 A hybrid meeting of Pre-Determination Committee will be held in the Council Chamber on Wednesday, 10 September 2025 at 09:30. 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. The recording will be publicly available on the Council’s website following the meeting. Members: Provost X McDade Depute Provost A Parrott All Bailies All Councillors Page 1 of 26
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Pre-Determination Committee Wednesday, 10 September 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 2 DECLARATIONS OF INTEREST 3 RECONFIGURATION OF EXISTING GOLF COURSE AND CLUB HOUSE FROM 18 HOLES TO 9 HOLES, AND A COMMUNITY HUB BUILDING AND ASSOCIATED SPORTS COURTS AND BIKE TRAILS, WALKING AND CYCLING PATHS AND CAR PARKING AREA, ERECTION OF UP TO 175 RESIDENTIAL DWELLINGS, OPEN/AMENITY SPACE, LANDSCAPING, DRAINAGE, UPGRADED SITE ACCESS AND ASSOCIATED WORKS AT CRAIGIE HILL GOLF CLUB, PICKEMBERE, PERTH Report by Strategic Lead - Economy, Development and Planning (copy herewith 25/221) 5 - 26 Page 3 of 26
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PERTH AND KINROSS COUNCIL Our vision is a Perth and Kinross where everyone can live life well, free from poverty and inequality ___________________________________________________________________ Committee or Board: Perth and Kinross Council Date of Meeting: 10 September 2025 Report Title: Reconfiguration of existing golf course and club house from 18 holes to 9 holes, and a community hub building and associated sports courts and bike trails, walking and cycling paths and car parking area, erection of up to 175 residential dwellings, open/amenity space, landscaping, drainage, upgraded site access and associated works at Craigie Hill Golf Club, Pickembere, Perth Report Number: 25/221 Report Author: Alex Gudgeon, Planning Officer Organisational Lead: Serge Merone, Strategic Lead - Economy, Development and Planning ___________________________________________________________________ 1. Purpose 1.1 This Report relates to an application for Planning Permission in Principle (24/01421/IPM) for the development of part (primarily 9 existing holes) of the current Craigie Hill Golf Club, Perth. This would see up to 175 residential properties developed, as well as a community building, sport and outdoor recreation facilities and associated works. The site is designated as green belt within the adopted Local Development Plan 2 (LDP2). The proposed development is within the identified green belt and is therefore significantly contrary to the policies/provisions of both National Planning Framework 4 (NPF4) and LDP2. 1.2 The Council’s Planning Applications Decisions – Scheme of Delegation requires that proposals for major developments that are significantly contrary to the development plan must be determined by the Full Council. 3 Page 5 of 26
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1.3 Sections 1. Purpose 2. Recommendation 3. Background and Description of Proposal 4. Site History 5. Environmental Impact Assessment 6. Pre-Application Consultation 7. Development Plan and Non-Statutory Guidance 8. Consultations 9. Representations 10. Additional Statements 11. Appraisal 12. Conclusion and Reasons for Recommendation 13. Impact Value Assessment 2. Recommendation It is recommended that the Council: 2.1 refuse to grant planning permission for the proposed development. 3. Background and Description of Proposal 3.1 The site extends to 35.25ha and is located to the south-west of Perth and is bounded by existing woodland, with residential properties to the north and east, there are fields to the south, with the M90 beyond and woodland and the ‘Aviva’ campus and building to the west. The recently completed wind turbine is close to the south-west corner. 3.2 The site is currently in use as an 18-hole golf course, with a club house located in the north-west part. Access is from the north, along Low Road and this will continue, although the existing priority junction off Low Road is to be upgraded to an adoptable standard. 3.3 The landform rises from north to south towards ‘Craigie Hill’, the Craigie Burn runs eastwards just to the north. The hill comes to a summit around the tee of the hole 6, near the south-eastern corner of the site. This 112m (AOD) at a raised knoll in the undulating topography. Otherwise, it then falls away towards the southern boundary, 107m (AOD) at the south-east part and 101m (AOD) to the south-west. The land more significantly falls to the north, across the golf course, with a central ridgeline whereafter the topography falls more rapidly to a height of 45m (AOD) in the north-west and 49m (AOD) towards the north-eastern corner. The housing area comprises around a third of the site area 12.08ha and is proposed on that steeper northern slope beyond the ridge, the higher undulating land remaining in use as a reduced golf course. Page 6 of 26
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3.4 The site is characterised by the structure of the golf course, with open avenues containing the holes, these generally enclosed and separated by bands of trees. The majority of holes running back and forth east to west, with some linking north/south. To the east and west, the site is flanked by woodland corridors. This includes ‘Buckie Braes’ and a small burn along the western boundary, which offers an attractive amenity route and connections to the core path network. 3.5 The site boundaries are largely defined by groups of trees and areas of woodland, to the north, east and west. Beyond these boundaries are existing residential neighbourhoods, with the Aviva building and grounds to the west and the Aviva turbine then M90 to the south-west. 3.6 The western boundary is defined by the burn that runs through the Buckie Braes. To the west of the burn is the Buckie Burn footpath, running north to south. 3.7 To the south, the site is bounded by a track that runs east to west and under the M90. This southern boundary is largely defined by the M90 corridor. 3.8 The proposal comprises a reconfiguration of the golf course, reducing it from 18 to 9 holes, although with 18 tee boxes. Upgraded and additional facilities include a remodelled clubhouse/community facility, bike trails, a pocket park, a greenkeeping shed, padel/pétanque courts and golf practice areas. 3.9 The overall concept splits the site north and south, with up to 175 residential units proposed to the north with the reconfigured golf course to the south. The new club house, community hub and car parking are proposed on the area of the existing club house and car park. Footpaths will provide access to the golf course with bike trails also proposed between the community hub and golf course. SuDS areas are indicated in the north-eastern area in the form of connected basins following the topography as it slopes down to the Craigie Burn. There are two areas of identified ancient woodland near and within the eastern site boundary, this issue is discussed below under ‘Biodiversity’. 3.10 It is understood that the development of part of the existing golf course is proposed for the club to raise funds to secure its long-term future. These funds generated through income generated from the development of a large part of the site for residential purposes. To accommodate this, the existing 18 holes would be reduced to 9 holes. A new clubhouse, which could also provide a community hub, is also proposed. 4. Site History 4.1 98/01105/FUL Full Planning Permission was approved on 15 September 1998 for extensions to the clubhouse. 4.2 04/01470/FUL Planning Permission was refused on 21 September 2004 for the installation of a 12m monopole, 6 antenna, 2 transmission dishes, radio equipment housing and ancillary development. Page 7 of 26
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4.3 05/00273/FUL Full Planning Permission was approved on 15 April 2005 for the installation of a 12m monopole, 6 antenna, 2 transmission dishes, radio equipment housing and associated ancillary development. 4.4 17/00852/FLL Full Planning Permission was approved on 20 June 2017 for the reinstatement of a track and alterations to ground levels. 4.5 22/02017/SCRN An EIA Screening was submitted on 15 November 2022 relating to the: Proposed reconfiguration of existing golf course from 18 holes to 9 holes, re-development of existing clubhouse into new community hub building for golf, other sports and community uses and car parking area, erection of circa 200 residential dwellings, open/amenity space, landscaping, woodland planting, site access, new and upgraded footpath provision and associated works. It was determined that the proposal was unlikely to have a significant effect on the environment and a detailed study through an EIA was not required. 4.6 23/00002/PAN A Proposal of Application Notice (PAN) was submitted on 15 March 2023 related to the: Re-development of 18-hole golf course to 9 holes, alterations and extension to clubhouse to form sports community hub building, erection of 200 dwellinghouses, formation of open/amenity space, landscaping, parking, footpaths and associated works. PKC confirmed that the content of the PAN and the extent of public engagement proposed as part of that process was in compliance with the relevant Regulations and was accepted. 5. Environmental Impact Assessment 5.1 The impact of the proposed development was screened for EIA (22/02017/SCRN) and it was determined that the proposal did not constitute an EIA development. 6. Pre-Application Consultation 6.1 Pre application Reference: 23/00002/PAN 6.2 The proposed development is classed as a ‘Major’ development, in terms of the Town and Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009. Therefore, the applicant was required to undertake formal pre-application consultation with the local community. The submitted Pre- application Consultation (PAC) Report outlined that two rounds of public consultation events were held in the golf clubhouse. The first round of events was held on: • Wednesday 19 April 2023 for Golf Club members only –7.30pm – 9pm • Thursday 20 April 2023 – 2pm – 8pm • Sunday 23 April 2023 – 1pm – 4pm Page 8 of 26
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6.3 These were followed by a second round of events held on: • Wednesday 14 August 2024 for Golf Club members only – 7.30pm – 9pm • Thursday 15 August 2024 – 2pm – 8pm • Sunday 18 August 2024 – 1pm – 4pm 7. Development Plan and Non-Statutory Guidance 7.1 The Development Plan for the area comprises National Planning Framework 4 and the Perth and Kinross Local Development Plan 2 (2019) along with its associated statutory supplementary guidance. 7.2 National Planning Framework 4 7.2.1 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 has an increased status over previous NPFs and comprises part of the statutory development plan. 7.2.2 The Report’s assessment of this application has considered the following policies of NPF4: • Policy 1: Tackling the Climate and Nature Crises • Policy 2: Climate Mitigation and Adaptation • Policy 3: Biodiversity • Policy 6: Forestry, Woodland and Trees • Policy 7: Historic Assets and Places • Policy 8: Green Belts • Policy 9: Brownfield, Vacant and Derelict Land and Empty Buildings • Policy 13: Sustainable Transport • Policy 14: Design, Quality and Place • Policy 15: Local Living and 20 Minute Neighbourhoods • Policy 16: Quality Homes • Policy 18: Infrastructure First • Policy 20: Blue and Green Infrastructure • Policy 21: Play, Recreation and Sport • Policy 22: Flood Risk and Water Management • Policy 25: Community Wealth Building 7.3 Perth and Kinross Local Development Plan 2019 7.3.1 The Local Development Plan 2 (2019) (LDP2) sets out a vision statement for the area and states that, “Our vision is of a Perth and Kinross which is dynamic, attractive and effective which protects its assets whilst welcoming population and economic growth.” It is the most recent statement of Council policy and is augmented by Supplementary Guidance. Page 9 of 26
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7.3.2 The principal relevant policies are, in summary; • Policy 1A: Placemaking • Policy 1B: Placemaking • Policy 2: Design Statements • Policy 5: Infrastructure Contributions • Policy 6: Settlement Boundaries • Policy 14A: Open Space Retention and Provision: Existing Areas • Policy 14B: Open Space Retention and Provision: Open Space within New Developments • Policy 15: Public Access • Policy 20: Affordable Housing • Policy 25: Housing Mix • Policy 26B: Scheduled Monuments and Archaeology: Archaeology • Policy 27A: Listed Buildings • Policy 32: Embedding Low & Zero Carbon Generating Technologies in New Development • Policy 40A: Forestry, Woodland and Trees: Forest and Woodland Strategy • Policy 40B: Forestry, Woodland and Trees: Trees, Woodland and Development • Policy 41: Biodiversity • Policy 42: Green Infrastructure acceptable • Policy 43: Green Belt • Policy 47: River Tay Catchment Area • Policy 52: New Development and Flooding • Policy 53A: Water Environment and Drainage: Water Environment • Policy 53B: Water Environment and Drainage: Foul Drainage • Policy 53C: Water Environment and Drainage: Surface Water Drainage • Policy 53E: Water Environment and Drainage: Water Supply • Policy 57: Air Quality • Policy 58A: Contaminated and Unstable Land: Contaminated Land • Policy 60B: Transport Standards and Accessibility Requirements: New Development Proposals 7.4 Statutory Supplementary Guidance • Supplementary Guidance - Air Quality (adopted in 2020) • Supplementary Guidance - Developer Contributions & Affordable Housing (adopted in 2023) • Supplementary Guidance - Flood Risk and Flood Risk Assessments (adopted in 2021) • Supplementary Guidance - Forest & Woodland Strategy (adopted in 2020) • Supplementary Guidance - Green & Blue Infrastructure (adopted in 2020) • Supplementary Guidance - Landscape (adopted in 2020) Page 10 of 26
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• Supplementary Guidance - Open Space Provision for New Developments (adopted in 2021) • Supplementary Guidance - Placemaking (adopted in 2020) 7.5 PKC Non-Statutory Guidance • Planning Guidance - Loch Leven SPA, the Dunkeld-Blairgowrie Lochs SAC and the River Tay SAC • Planning Guidance - Planning & Biodiversity 7.6 National Guidance 7.6.1 The Scottish Government expresses its planning policies through Planning Advice Notes, Creating Places, Designing Streets, National Roads Development Guide and a series of Circulars in addition to NPF4. 7.7 Planning Advice Notes 7.7.1 The following Scottish Government Planning Advice Notes (PANs) and Guidance Documents are of relevance to the proposal: • PAN 40 Development Management • 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 7.8 Creating Places 2013 7.8.1 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. 7.9 Designing Streets 2010 7.9.1 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. 7.10 National Roads Development Guide 2014 7.10.1 This document supports Designing Streets and expands on its principles and is the technical advice that should be followed in designing and approving of all streets including parking provision. Page 11 of 26
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8. Consultations 8.1 External Consultations 8.1.1 Historic Environment Scotland: No objection. 8.1.2 Scottish Water: No objection. Advise that there is currently sufficient capacity at Perth Water Treatment Works and for a foul only connection at the Perth Waste Water Treatment Works. 8.1.3 Transport Scotland: No objection, subject to the Council seeking appropriate contributions towards the upgrade of Broxden Roundabout. 8.1.4 Dundee Airport: No objection. 8.1.5 Sportscotland: No objection. Advise the reconfiguration of a 9-hole course would retain playing capacity of the sport at the site and is intended to provide a better user experience than currently available. 8.1.6 SEPA: No objection, subject to a condition requiring an updated Flood Risk Assessment. However, note that during flood events Low Road becomes inundated, cutting off vehicular access to the site. This sees the application propose a secondary emergency access/egress route linking to Woodside Crescent. However, SEPA advise that the two roads leading to Woodside Crescent (Queens Avenue and Murray Crescent) also become inundated and impassable during flood events. How flooding acts as an impediment to vehicular movement is for the local authority to take a decision on, but SEPA has sought to highlight that the alternative route proposed can also become impassable. 8.2 Internal Consultations 8.2.1 Community Waste: No objection. Provide general advice on waste collection. 8.2.2 Development Plan Team: Object. Advise the application is significantly contrary to the Development Plan and premature to the LDP3 review. Only through detailed review will it be confirmed if there is any requirement for additional housing land within this Housing Market Area. Concerns are raised, even if there was an identified need within the HMA, whether the application site would be considered an appropriate location. Importantly it is advised that ad hoc and unplanned approval of such development in the green belt could set a significant precedent and place pressure for development on other parts of Perth’s Green Belt. 8.2.3 Housing Strategy: No objection. Advise that the LDP2 Affordable Housing Policy requires that 25% of the total number of houses, above a threshold of 5 units, is to be in the form of affordable housing. The indicative 175 dwellings would equate to an Affordable Housing requirement of 43.75 units. Page 12 of 26
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8.2.4 Transport Planning: Object. Despite being requested, the submitted Transport Assessment (TA) does not consider the potential impacts of the proposed supermarket on Necessity Brae. The TA has noted that a decision was taken not to include the proposed supermarket on the assumption that it was quashed following judicial review. Following the decision on 16 July 2025 consent for the supermarket still stands and should be considered as a committed development (21/00248/FLL). The TA is therefore not robust and Transport Planning are unable to determine the extent of mitigation measures required to address potential queuing and delays. 8.2.5 Environmental Health – Contaminated Land: No objections, subject to a condition requiring further site investigation works. 8.2.6 Environmental Health – Noise and Odour: No objection, subject to conditions to control noise from the commercial and community elements, lighting and the submission of a further Air Quality Assessment. An initial request saw a detailed Air Quality Assessment submitted, this found that no significant air quality impact is predicted on existing or future residents. 8.2.7 Conservation Team: No objection in principle. Advise that the proposal has potential to impact on the setting of the Category A listed Aviva UK Insurance Building. If the application is granted, consideration at the detailed stage will have to be given to the proposed scale and layout of development, to minimise impact on the listed building. 8.2.8 Structures and Flooding: No objection, subject to conditions on flood resilience, the preparation of a Flood Action Plan, implementation of the measures identified in the Flood Risk Assessment and SuDS details. 8.2.9 Development Contributions: No objection, subject to conditions to secure the delivery of affordable housing and contributions for primary education and transport infrastructure (likely via a legal agreement), if the application is granted. 8.2.10 Biodiversity: Object. This following a request for and the submission of an Ecological Impact Assessment and Bat Survey Report. However, it is considered that the information provided is not in accordance with relevant legislation, policy and guidance. Particularly there is insufficient information to assess the proposed application against NPF4 Policy 6, as no details of appropriate mitigation measures have been identified in line with the mitigation hierarchy. It is noted that the proposals will result in a loss of 0.35ha of native upland mixed ashwood and habitat loss of a strip of connected woodland, thus resulting in habitat fragmentation. No information has been provided on why the loss and fragmentation of native upland mixed ashwood could not be avoided, reduced, or compensated for. 9. Representations 9.1 There have been 212 representations submitted in support of the application and 107 objections. Page 13 of 26
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9.2 Support comments • Will secure the future of the golf club • Helps with housing shortage and will provide affordable homes • Employment provision and economic development • Environmental Improvements • Enhances character of the area • Support for creation of a community hub • Will help to reduce flood risk • Improvements to Buckie Brae • Accessible location and accords with 20-minute neighbourhood principles 9.3 Objection comments • Development will exacerbate existing flooding issues in the area • Adverse effect on visual amenity • Contrary to development plan policy • Inappropriate land use • Light pollution • Loss of open space and biodiversity impacts • Loss of trees • Noise pollution • Out of character • Impacts on traffic and parking • Houses will be located too close to the Aviva wind turbine • Detrimental impacts on existing services and infrastructure 10. Additional Statements Screening Opinion EIA not required Environmental Impact Assessment (EIA): Environmental Report Not required Appropriate Assessment under Habitats Regulations AA not required Design Statement or Design and Access Statement Submitted Other supporting Reports on Impact or Potential Impact • Design and Access Statement • Air Quality Assessment • Drainage Strategy Report • Ecological Appraisal • Biodiversity Enhancement Statement • Low Carbon Statement • Economic Impact Assessment • Tree Survey • Landscape and Visual Impact Page 14 of 26
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Assessment • Transport Assessment • Flood Risk Assessment • Ground Investigation Report • Statement of Community Benefit • Archaeological Assessment • Outline Construction Management Statement • Golf Club Business Plan • Ecological Impact Assessment • Bat Survey Report 11. Appraisal 11.1 Principle 11.1.1 The proposed development includes for up to 175 residential dwellings. The applicant has suggested this ‘enabling’ development will release a site for housing whilst protecting an existing land use (albeit in a reduced and consolidated format). 11.1.2 The site is located within the green belt, as designated in LDP2. NPF4 Policy 8: Green Belts advises that LDPs should use green belts to support their spatial strategy as a settlement management tool to restrict development around towns and cities. The policy goes on to provide specific criteria in which development proposals in the green belt can be supported. 11.1.3 These include: • Development associated with agriculture, woodland creation, forestry and existing woodland (including community woodlands); • Residential accommodation required and designed for a key worker in a primary industry within the immediate vicinity of their place of employment; • Horticulture, including market gardening and directly connected retailing, as well as community growing; • Outdoor recreation, play and sport or leisure and tourism uses; and • Developments that provide opportunities for access to the open countryside (including routes for active travel and core paths); • Flood risk management (such as development of blue and green infrastructure within a “drainage catchment” to manage/mitigate flood risk and/or drainage issues); • Essential infrastructure or new cemetery provision; • Minerals operations and renewable energy developments; • Intensification of established uses, including extensions to an existing building where that is ancillary to the main use; • The reuse, rehabilitation and conversion of historic environment assets. Page 15 of 26
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11.1.4 In addition, LDP2 Policy 43: Green Belt sets out the following specific criteria for development to be supported in the green belt: a) the development supports an established use, or develops a new business within the green belt which has a direct relationship to the land; or b) (the development is essential for agriculture, horticulture (including allotments) or forestry operations; or c) it constitutes woodlands or forestry, including community woodlands; or d) it constitutes uses which advance the Council’s aims of improving public access to the countryside around Perth, including recreational, educational and outdoor sports; or e) it complies with criteria (4) or (5) of the Policy 19: Housing in the Countryside and associated Supplementary Guidance, and a positive benefit to the green belt can be demonstrated; or f) it constitutes essential infrastructure. 11.1.5 The total site area extends to 35.25 hectares, of which 12.08 hectares is proposed for residential development. The development of the site for residential use does not meet any of the limited exceptions set out in the above green belt policies. The application arguing that the residential element is ‘enabling development’. However, it is considered that due to the scale and extent of the housing component, this is assertion is not accepted. However, any significantly reduced housing element would also require to be considered on its merits and any particular circumstances. 11.1.6 The Scottish Ministers have made a requirement for planning authorities to produce delivery programmes to include the sequencing of, and timescale for, the delivery of housing sites allocated in local development plans. The LDP2 Delivery Programme – Housing Land Pipeline Addendum (March 2025) shows significant housing land allocations in the Greater Perth Housing Market Area (GPHMA), where the site is located. This includes Perth West (2,210-3,453 homes), Almond Valley (704-1,100 homes) and Bertha Park (3000+ homes). 11.1.7 Housing sites in the GPHMA are not being delivered more rapidly than envisaged, creating a shortage of sites. Moreover, the phasing programme contained within the Housing Land Pipeline demonstrates that, were housing sites being delivered more quickly than anticipated, then there is adequate land already allocated in LDP2 to address this issue. In summary there is a significant amount of LDP2 allocated housing land available and being delivered to meet the identified needs within the GPHMA, thus there is no significant need for additional housing to be delivered or to justify development of additional sites significantly departing from the development plan and particularly in the Green Belt. Page 16 of 26
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11.1.8 The Council has shown a commitment to providing much needed housing land in a plan-led manner, with the development of some of these sites now underway. Allocated sites have also been considered in terms of their impact on local services and infrastructure with new schools, roads infrastructure upgrades and opportunities for the provision of additional services for their communities. Significant residential development should be carefully planned and focused toward allocated sites, which have been identified and considered through the Local Plan process. This is the strategy of the LDP2. It is important to appreciate that proposals for speculative development can adversely impact the ability to deliver these areas identified as most appropriate and suitable within LDP2, thereby undermining the aspirations of the Plan and its spatial strategy. In short, the development could see the ability to deliver these planned areas compromised. 11.1.9 While the Development Plan provides support for aspects of the proposal, including the reconfiguration of the golf course, upgrading of the club house, pétanque/padel courts and other associated development, the relevant policies (principally NPF4 Policy 8 and LDP2 Policy 43) do not support the residential element of the proposal, which is of significant scale. 11.1.10 Craigie Hill is a prominent landscape feature in this part of the city. The overall objective of the Green Belt in this location is to protect and enhance the character, landscape setting and identity of this locality. Policy 43 states that ‘proposals for new buildings must be of a suitable scale and form, located and designed in such a way so as not to detract from the character and landscape setting of the green belt’. However, this on the presumption that the principle of the buildings is acceptable. Notwithstanding the principle not aligning with the aforementioned policies, at the scale proposed, the residential element would represent a significant incursion in the green belt. The scale and quantum of which is considered would damage the integrity of the green belt and adversely affect the setting of the city. Overall, the proposed residential development on a substantial area of the Green Belt does not comply with green belt policies or objectives and is considered significantly contrary to both local and national planning policy. 11.1.11 The applicant refers to a letter from the Chief Planner dated 26th June 2024 which states that: ‘The Scottish Ministers have continued to reinforce that policies in NPF4 should be read and applied as a whole and that conflicts between policies are normal and to be expected. The planning system requires decision makers to weigh up all relevant policies, for example, quality homes, brownfield development and town centre living, as well as relevant material considerations in applying balanced planning judgement (section 25 of the Town and Country Planning (Scotland) Act, 1997, as amended). The introduction of NPF4 has not changed this.’ However, other policies that are potentially of relevance to an assessment of the proposal, do not contain any provisions which, if satisfied, are capable of justifying a development which is directly contrary to the most salient development plan policy relating to the principle of development. Even if the proposal was capable of according with all of these more detailed policy considerations, this would not overcome the fundamental conflict with NPF4 Policy 8 and LDP2 Policy 43. Page 17 of 26
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11.1.12 While there will be some loss in sport provision with the golf course being reduced from 18 to 9 holes, the proposal seeks to diversify play, recreation and sport opportunities at this location. The inclusion of new play provision, as well as formal biking trails and facilities, complies with NPF4 Policy 21d and is supported. Furthermore, this diversification provides opportunities that are more accessible and inclusive for a range of demographics, particularly children and young people. Sportscotland is a statutory consultee where there is to be a loss of outdoor sports facilities. They have commented advising that they have no objection to the proposals, in terms of the new level of sports facilities to be provided. 11.1.13Overall, the application fails to justify the requirement for the development of green belt land for a substantial residential development. The proposal for 175 houses on the green belt is excessive and will impact on the landscape setting of this part of the city. It is not considered that the indicated financial predicament of the Golf Club has any significant weight to outweigh the principles of the relevant planning considerations. Particularly it is not considered or demonstrated that there is a significant, if any, shortfall of golf facilities available elsewhere to satisfy any diverted demand. In addition, if the scale of the existing course is problematic, support for a reduced playing area is available. Any surplus areas could then naturalise, and this would reflect the Green Belt policy objectives. On this basis the proposal is considered to represent a significant departure from NPF4 and LDP2 and cannot be supported. 11.2 Amenity 11.2.1 An Air Quality Assessment (AQA) has been submitted in support of the application. The AQA considered the potential impact from associated traffic emissions on the air quality of the existing and future population. 11.2.2 Air dispersion modelling was undertaken which predicted that there would be no predicted significant change in pollutant concentrations. 11.2.3 In terms of noise, there is the potential impact from the daily operations of the club house and community hub, especially from any new plant, a function room, nursery, and outdoor bike trails, to affect the residential amenity. Consideration is also to be given to operational noise from within the buildings, to ensure that activities such as patron noise, music, etc. be controlled and not affect neighbouring properties. Although it is considered that the principle of the development is not acceptable, should permission be granted suitable conditions will be required to protect residential amenity from potential noise. 11.2.4 The closest indicative location of proposed dwellinghouses is approximately 300 metres away from the existing Aviva wind turbine and there is the potential for noise and shadow flicker to affect residential amenity. Therefore, should permission be granted the detailed layout and design should ensure that future residents are not affected by shadow flicker and noise from the existing turbine. Page 18 of 26
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11.2.5 Overall, it is considered that, through careful siting and design, the proposal could be compliant with NPF4 Policy 14: Design, Quality and Place and LDP2 Policies 56: Noise Pollution and 57: Air Quality. 11.3 Flooding and Drainage 11.3.1 A large number of the objectors are concerned with flood risk, due to recent flood events in the area. A Flood Risk Assessment (FRA) and a Drainage Strategy (DS) support of the application and propose flood mitigation measures to manage the risks. These include: • Sustainable drainage systems (SuDS) to manage surface water and reduce runoff; • Raising floor levels to protect against potential flooding impacts, especially during extreme rainfall events; • Measures to reinforce embankments; and • Improvements to local drainage infrastructure to ensure effective water flow and prevent accumulation around the development site. 11.3.2 The FRA acknowledges that the level of Low Road, which provides the main vehicular access, cannot be raised and will become inundated and prevent access and egress during flood events. Therefore, the application proposes a secondary access from Woodside Crescent that could be used during flood events. However, both SEPA and the PKC’s Transport Planning team advise that this alternative route is also inundated and becomes impassable by vehicles during flood events. There is a flood scheme for the Craigie Burn culvert at Queen’s Avenue that will likely provide safe access to the site. However, at present the scheme is currently at the design stage and its delivery timeline is uncertain. 11.3.3 The hydraulic modelling undertaken notes that the area proposed for residential development is not at risk of fluvial (watercourse related) flooding during a 1 in 200-year (plus climate change) event, due to the vertical separation between the known extent of the flooding and the indicated development area. Neither Flooding and Structures colleagues nor SEPA has objected to principle of dwellings in the indicated locations on grounds of flood risk in and around them, although advising that access would be cut off. However, SEPA has requested that, should planning permission be granted, a condition should be imposed requiring an updated FRA to be submitted, including detailed modelling of the proposed golf course burn and details of the new pond in the south-west of the site demonstrating that it will not adversely affect the functioning of the existing pond and dam on the Buckie Burn. Page 19 of 26
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11.3.4 NPF4 Policy 22 a): Flood Risk and Water Management advises that ‘Development proposals at risk of flooding or in a flood risk area will only be supported if they are for: i. essential infrastructure where the location is required for operational reasons; ii. water compatible uses; iii. redevelopment of an existing building or site for an equal or less vulnerable use; or. iv. redevelopment of previously used sites in built up areas where the LDP has identified a need to bring these into positive use and where proposals demonstrate that long- term safety and resilience can be secured in accordance with relevant SEPA advice.’ 11.3.5 It is only the access routes into the site that are at flood risk. However, the proposed development is not one of essential infrastructure, and is therefore contrary to Policy 22(a). 11.3.6 The mitigation measures proposed within the Flood Risk Assessment broadly comply with the requirements of LDP2 Policy 52: New Developments and Flooding. It is also accepted that the mitigation measures may provide a betterment to the existing situation in terms of flood risk. 11.3.7 Overall, while the site itself is not considered to be at flood risk with the mitigation measures proposed, access and egress from the site may be compromised during flood events. The proposed Craigie Burn Flood Scheme may resolve this issue in future, but until it is fully implemented, the principle of housing using an access subject to known flooding is not accepted. 11.4 Transport and Access 11.4.1 NPF4 Policy 13: Sustainable Transport and LDP2 Policy 60: Transport Standards and Accessibility Requirements are both relevant to the consideration of roads and access to the development. 11.4.2 A Transport Assessment (TA) has been prepared to accompany the application. Increased traffic levels expected as a result of the development have been modelled for the 175 dwellinghouses and do not exceed key queueing thresholds. 11.4.3 The submitted TA does not consider the potential impacts of the proposed supermarket on Necessity Brae. The TA has noted that a decision was taken not to include the proposed supermarket on the assumption that it was quashed following judicial review. Following the decision on 16 July 2025 consent for the supermarket still stands and should be considered as a committed development (21/00248/FLL). The TA is therefore not robust and Transport Planning are unable to determine the extent of mitigation measures required to address potential queuing and delays. Page 20 of 26
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11.4.4 The application advises that the proposals associated with the golf club clubhouse (golfing and community hub activities), are relatively small scale and unlikely to generate any notable traffic during the weekday AM or PM peak hours. Further detail was subsequently provided to clarify expected trip numbers using TRICS. The current estimation, based on the indicative use, is that up to 8 two-way trips during the AM peak hour and up to 17 two-way trips during the PM peak hour can be expected. This is not deemed significant, but these have not been accounted for in the junction assessments in the TA. 11.4.5 It is proposed that Low Road is narrowed to both accommodate two-way traffic and to allow the formation of a two-metre-wide footway on the southern edge and connecting the existing footways at Necessity Brae and Low Road to the development site. The adequacy of footways in the area and development would require to be considered at detailed application stage. The existing public parking on Low Road already narrows the road space. To accommodate additional vehicular traffic from the development a traffic solution would be required to ensure that two-way traffic flows can be maintained. Parking may also need to be restricted on sections of Low Road/Craigie Hill Access Drive to improve junction visibility. The proposal may include the provision of appropriate passing facilities and may require a traffic regulation order (TRO). 11.4.6 Transport Planning has also raised concerns relating to site access during flood events. If permission is to be granted it is requested that a Flood Action plan is required by condition detailing access and egress arrangements and measures to be implemented to secure safe access and egress during flood events. If the emergency access is to be formed onto Woodside Crescent, the private section of Woodside Crescent must be formed to an adoptable standard. 11.5 Biodiversity 11.5.1 NPF4 policies 3: Biodiversity and 6: Forestry, Woodland and Trees are relevant considerations as are LDP2 policies 40: Forestry, Woodland and Trees and 41: Biodiversity. 11.5.2 An Ecological Appraisal and a Biodiversity Enhancement Statement (BES) were submitted in support of the application. Following a request from the Biodiversity Officer, an Ecological Impact Assessment (EcIA) and a Bat Survey Report were also submitted. 11.5.3 The submitted bat survey information is sufficient to inform a major application for Planning Permission in Principle. 11.5.4 The submitted BES is a high-level statement of intent, the success of which will be dependent on the final site design. Biodiversity enhancement should be provided over and above compensation for lost habitats. Woodland planted to compensate for destroyed habitat should not be included in enhancement calculations. Page 21 of 26
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11.5.5 NPF4 does not support any development that will lead to the loss of ancient woodland or impact on their ecological conditions. An area of ancient woodland (Site ID: 45) is present on the east side of the site. 11.5.6 The submitted EcIA states the area of ancient woodland is an irreplaceable habitat and will be protected and there will be no habitat loss from this woodland within the Ancient Woodland area. However, all other documents submitted for this planning application indicate this as the location for a SuDS pond and pocket park. Thus, the indicative layout contradicts the EcIA and the information which seeks to address ecology and flooding concerns. 11.5.7 Much of the area around the site is listed on the Native Woodland Survey of Scotland as upland mixed ashwood, which is a UK Biodiversity Action Plan priority habitat and should be protected. NPF4 does not support development that will impact native woodlands or fragment woodland habitats. 11.5.8 The EcIA states the proposed development will result in a loss of 0.35ha of native upland mixed ashwood and habitat loss of a strip of connected woodland, thus resulting in habitat fragmentation. 11.5.9 This is contrary to NPF4 Policy 6 ii and iii and no details of appropriate mitigation measures have been identified in line with the mitigation hierarchy. No information has been provided on why this loss could not be avoided, reduced, or compensated for. 11.5.10 Compensatory tree planting is required on a ratio of 1:3 for every tree loss as outlined in the PKC Planning for Nature Supplementary Guidance. Details such as the area of compensatory planting has not been provided and so it cannot be confirmed that woodland loss will be adequately compensated. 11.5.11 Overall, the submitted information is not in accordance with relevant legislation, policy and guidance. There is insufficient information to assess the proposed application against NPF4 Policy 6: Forestry, Woodland and Trees and LDP2 Policy 40: Forestry, Woodland and Trees as no details of appropriate mitigation measures have been identified in line with the mitigation hierarchy. Neither has information been provided on why loss and fragmentation of native upland mixed ashwood could not be avoided, reduced, or compensated for. As such, the proposals are considered contrary to NPF4 Policy 6 and LDP2 Policy 40: Forestry, Woodland and Trees. In principle Policy 3 of NPF4 and Policy 41 of LDP2 are addressed. 11.6 Cultural Heritage 11.6.1 In terms of any impacts on archaeology and cultural heritage NPF4 Policy 7: Historic Assets and Places and LDP2 Policy 26: Scheduled Monuments and Archaeology are relevant. Page 22 of 26
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11.6.2 An Archaeological Assessment has been submitted which highlights that there are nine cultural heritage sites within the proposed development area. These comprise the location of a burial cist, three nineteenth century quarries, a curling pond, a cottage, a club house, a shelter and the golf course itself. Of these, the quarries and curling pond may be directly affected by the proposal. An archaeological condition requiring a scheme of investigation will be required should the application be granted. 11.6.3 The site is within close proximity to the Category A listed Aviva Building (listed building ref: LB52450, listed on 28 August 2017). PKC’s conservation officer initially had some concerns as to the impact the residential development aspect may have on the setting of the listed building. However, following discussion it was agreed that, as the current application is in principle only, the relationship and impact of any future development on the listed building and its setting can be carefully considered and addressed through any subsequent detailed applications. 11.6.4 Overall, the proposal is considered compliant with NPF4 Policy 7: Historic Assets and Places and LDP2 Policies 26: Scheduled Monuments and Archaeology and 27: Listed Buildings, subject to conditions to protect known and potential heritage assets. 11.7 Development Contributions and Affordable Housing 11.7.1 The application proposes up to 175 dwellings. For residential developments of this scale, NPF4 Policy 16: Quality Homes and LDP2 Policy 20: Affordable Housing require that 25% of the total number of houses for which planning permission is being sought is to be in the form of affordable housing. The applicant has acknowledged this requirement in their supporting information. 11.7.2 The Council’s Developer Contributions Supplementary Guidance also requires a financial contribution towards any requirement to increase primary school capacity in areas where a primary school capacity constraint has been identified. A capacity constraint is defined as where a primary school is operating at over 80% and is likely to be operating following completion of the proposed development, extant planning permissions and Local Development Plan allocations, at or above 100% of total capacity. The proposal is within the catchment of Craigie Primary School. Further detail can be provided if the application is supported. 11.7.3 The Council’s Transport Infrastructure Developer Contributions Supplementary Guidance requires a financial contribution towards the cost of delivering the transport infrastructure improvements which are required for the release of all development sites in and around Perth. The application falls within the identified Transport Infrastructure Supplementary Guidance boundary and a condition to reflect this should be attached to any permission if granted. Page 23 of 26
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11.8 Economic Impact 11.8.1The submission has been reviewed by the Council's Business, Place and Investment Team (BPIT) who have indicated that the application aligns with the Council's corporate priorities of developing a resilient economy, promoting physical and mental wellbeing and tackling poverty. Employment and business opportunities will be generated across key economic sectors, particularly in tourism and leisure, through the operation of the reconfigured golf club, community hub, café/restaurant, and recreational facilities. 11.8.2 The BPIT also considers that the proposal is expected to create up to 60 one- off construction jobs, with the on-going net direct impact generated through the operations at the revamped Craigie Hill Golf Club are estimated at 8 full time equivalent jobs. The addition of 175 homes will bring long-term economic benefits, increasing footfall for local businesses, supporting public services, and enhancing demand for local amenities. 11.8.3 However, they also accept that unplanned residential developments could put unplanned strain on existing local services such as healthcare, education, and public transport, compromising other planned developments and also that the loss of designated green belt land carries economic and environmental risks. 11.8.4 Overall, whilst there are considered to be some economic benefits associated with the proposal, these may not be positive in a wider sense and are not considered to outweigh the fundamental planning policy conflicts which are outlined above. 12. Conclusion And Reasons for Recommendation 12.1 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, whether individually or cumulatively, have been found that would justify overriding the Development Plan. Accordingly, the proposal is recommended for refusal on the grounds identified below. 12.2 Reasons for Refusal 12.2.1 The residential aspect of the proposal is contrary to National Planning Framework 4 (2023) Policy 8: Green belts and the adopted Perth & Kinross Local Development Plan 2 (2019) Policy 43: Green Belt. The extent of the proposal would undermine the purpose of the green belt in this location, and no reasoned justification has been provided as to why a green belt location is essential for a residential development of this scale. The proposal also fails to demonstrate that it complies with any of the specified criteria within those policies that would allow development within the designated green belt. Page 24 of 26
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12.2.2 There is insufficient information to assess the proposed application against NPF4 Policy 6: Forestry, Woodland and Trees and LDP2 Policy 40: Forestry, Woodland and Trees as no details of appropriate mitigation measures have been identified in line with the mitigation hierarchy. Neither has information been provided on why loss and fragmentation of native upland mixed ashwood could not be avoided, reduced, or compensated for. As such, the proposals are considered contrary to NPF4 Policy 6 and LDP2 Policy 40: Forestry, Woodland and Trees. 12.2.3 The existing access and proposed emergency access to the site are both located on or near to areas at risk of flooding. NPF4 Policy 22: Flood Risk and Water Management sets out specific criteria for development proposals in a flood risk area. The residential aspect of the proposal does not meet any of the specified criteria and is therefore contrary to Policy 22. 13. Impact Value Assessment 13.1 Due to the nature of the report, an impact value assessment is not required. Page 25 of 26
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