Democracy Spraffa

Mr Billy Mcphee: Repositioning of 3 Chalets (Static Caravans) (Retrospective): Auchengower Caravan Park, Auchengower Park, Cove (Ref: 25/00516/Pp)

Argyll and Bute Council · 18 February 2026
Back to Planning, Protective Services and Licensing Committee — 18 February 2026 and its agenda

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Argyll and Bute Council
Development & Economic Growth   
Planning Application Report and Report of Handling as required by Schedule 2 of the
Town and Country Planning (Development Management Procedure) (Scotland)
Regulations 2013 relative to applications for Planning Permission or Planning
Permission in Principle 
Reference No:  25/00516/PP
Planning Hierarchy: Local
Applicant:  Mr Billy McPhee
Proposal:  Repositioning of 3 chalets (static caravans) (retrospective)
Site Address:  Auchengower Caravan Park, Auchengower Park, Cove, Argyll
And Bute    
DECISION ROUTE 
☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 
☒Committee - Local Government Scotland Act 1973 
(A)  THE APPLICATION 
(i) Development Requiring Express Planning Permission
• Repositioning of 3 caravans (chalet style) within the site boundary
(Retrospective)
• Formation of parking/turning areas for each plot (Retrospective)
• Associated land engineering/reprofiling ground levels work
(Retrospective)
• Erection of associated timber decking (Retrospective) 
(ii) Other specified operations
• N/A 
(B) RECOMMENDATION: 
Having due regard to the Development Plan and all other material considerations, it
is recommended that Planning Permission be granted as a minor departure to
Development Plan Policy and subject to the conditions, reasons and advisory notes
appended to this report. 
(C) CONSULTATIONS:   
Argyll and Bute Council – Roads Authority 01.05.2025
On review, it is considered that the proposed does not represent an intensification of
an existing site facility. 
Additionally, the proposed does not feature any alterations to the existing parking
provision or any parking provision requirements.

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Furthermore, as the application does not propose or suggest any alterations to, or
intensifications of, any point of access/ egress. I therefore confirm Roads have no
objection to the proposed. 
Core Paths – No response at time of writing the report 
Biodiversity Officer – 26.08.2025
European Protected Species and Protected Species
Desk studies show that bats, red squirrel and breeding birds are present within the
area, with other species likely present due to the habitat present. As no surveys
were submitted prior to works being carried out I cannot comment on whether
licences would have been required from NatureScot for works to proceed, but it is
likely that protected species were present. It is therefore important that measures
are taken to mitigate against the loss and provide biodiversity enhancement. 
Trees
Ancient Woodland is present on site and was impacted upon by the development.
This is an irreplaceable habitat and in accordance with NPF4 Policy 6: 
b) Development proposals will not be supported where they will result in: i. Any loss
of ancient woodlands, ancient and veteran trees, or adverse impact on their
ecological condition; ii. Adverse impacts on native woodlands, hedgerows and
individual trees of high biodiversity value, or identified for protection in the Forestry
and Woodland Strategy; iii. Fragmenting or severing woodland habitats, unless
appropriate mitigation measures are identified and implemented in line with the
mitigation hierarchy; 
A tree survey indicating the biodiversity value of each individual tree should have
been submitted along with the condition of the woodland, species present, age and
location.
A programme of tree planting should be submitted to include species which must be
native and appropriate to the locality of the area and sourced locally, location, age,
timing of planting and a schedule of monitoring and maintenance until such a time
as the trees become established. 
Biodiversity Enhancement Measures
As no further works are proposed and due to the loss of habitat and biodiversity on
the site, I ask the applicant to provide a plan of biodiversity enhancement measures. 
A programme of tree planting should be submitted to include species which must be
native and appropriate to the locality of the area and sourced locally, location, age,
timing of planting and a schedule of monitoring and maintenance until such a time
as the trees become established. 
If there is any Invasive Non-Native Species (INNS) on site, then I recommend these
are removed and managed accordingly to ensure they do not grow back. 
Other measures could include installation of bird and bat boxes including swift boxes
if appropriate, insect bricks, red squirrel feeding boxes, retention of dead wood and
log piles, planting of native wildflowers appropriate to the locality of the area. The
applicant should refer to the ‘Developing with Nature’ guidance on the NatureScot
website https://www.nature.scot/doc/developing-nature-guidance#planting-for-nature
for further guidance. 
Further comments on 20/01/2026

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The site sits wholly within ancient woodland of semi-natural origin. Ancient
woodland is an irreplaceable habitat and sensitive to impact and change. Any
proposed planting must be carried out in a sensitive matter, using species that are
appropriate to the habitat, locality of the area and locally sourced. I am satisfied
with the proposed tree, shrub and hedge species to be used (This is referring to
the proposal planting plan submitted 20/01/26). 
Any potential soils that need to be added to the site must be carefully managed
and if possible, sourced from a nearby site with compatible soil type to reduce
impact. The use of chemicals should be avoided, especially within this habitat due
to the sensitivities present.  I note Rhododendron ponticum is in the process of
being removed. This guidance from FLS may be of use Stem Guide (low res web
copy) single pages. Any proposed debris clearance must also be sensitively
managed. 
I recommend a survey is carried out by a suitably qualified ecologist to determine
species already present. This survey will feed into the Landscape Design and help
formulate appropriate mitigation and management measures necessary as well
as enhancement opportunities on site and ensure further impact to this habitat is
avoided. I am satisfied for the above to be Conditioned. 
Environmental Health – 20.08.2025
No objections subject to a condition relating to the control of external lighting. 
Cove and Kilcreggan Community Council – 11.06.2025  
The Community Council (majority decision) object in the strongest possible terms
to this large retrospective planning application regarding the ‘sighting’ of what are
new caravans outside the area designated in initial planning permission
11/00984/PP.  The granting of this large retrospective planning application would
appear to people in the community that non-compliance with statutory
requirements is ‘rewarded’ with ex-post planning permission.  The CC and
members of the community feel this is unfair and has a potential ‘knock-on’ effect
for other sites where developers and can evade normal systems and processes
and still achieve their individual aims.   The use of the discretionary powers that
rests with A&B Council are, in this instance, possibly inappropriately applied given
the level of complaints at ‘delivery’ of the new units to the site when enforcement
action (to a site with a history of planning issues) could have been easily taken.    
We are also mindful that we understand that 2 of these units are residential and
the third is more holiday accommodation.  Therefore, the CC requests that should
the decision regarding the 25/00516/PP be to remove the 3 units from their current
location that the relocation, to other sites within Auchengower, is undertaken at
the expense of the site owner and not those who appear to have purchased their
unit in good faith.    
In the event that A&B Council grants this planning application the Community
Council wishes to see significant amelioration of the current site to reduce the
visual impact of this development.  This would include issues of vegetation
management, resolving the drainage issues which cause significant flooding on
the B833 and more appropriate colour schemes for fencing etc.

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(D) HISTORY:   
24/00057/ENOTH2
Unauthorised siting of three caravans without planning permission; siting and use of
caravans not in accordance with approved planning permission (C.3122). 
13 separate live enforcement cases 
Relating to each individual caravan that is alleged to be in breach of condition as not
in accordance with approved planning permission. 
20/00053/ENFLB 
Unauthorised demolition of a Listed Building (Auchengower House) 
11/00202/ENFOC2
Layout differs from original consent. 
C.3122
Use of land as part residential caravan site for 30 caravans and part non-residential
caravan site for 30 caravans and erection of 6 toilet units.  Approved 1969 subject
to the condition “that all caravans located in the non-residential area are vacated
and removed from their summer positions during the period 1st November to 31st
March of each calendar year.” 
C3122/1 
Amendment to layout of caravan park.  Approved 1977 subject to the conditions:
• that all caravans located in the non-residential area are vacated and
removed from their summer positions during the period 1st November to
31st March of each calendar year.
• No trees shall be removed without the prior consent of the District
Council. 
C.3122/2 (also known as 94/00218/VARCON)
Winter storage (removal of condition).  Approved 1996 
97/00312/DET
Erection of porch- Caravan 8 Holly Twirl Shore Road Cove 
11/00984/PP
Variation of Condition 1 (occupancy restriction) in relation to planning permission
(C.3122)
Holiday caravans to be vacated 1st Feb- 7th March.
Approved August 2011. 
(E) PUBLICITY:   
Advert Type: Regulation 20 Advert Local Application             Expiry Date: 05.06.2025 
(F) REPRESENTATIONS:

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There has been a total of 14 representations made in respect to the application, of
which 12 are in objection and 2 are in support. 
(i) Representations received from: 
Objection
Mrs J Barr, South Park East, Shore Road, Cove 05.05.2025
Mr Lionel Wilson, Auchengower Mansion House, Shore Road, Cove 05.06.2025
Mr Ken Owen, Hartfield Court, South Ailey Road, Cove 22.06.2025
Ms Anne Strachan, Edendene, Shore Road, Cove 15.06.2025
Mr Alastair McLean, Ellerslie, Shore Road, Cove 12.06.2025
Mr Richard Reeve, Aidenwood, Barbour Road, Kilcreggan 14.06.2025
Mr James Greg, Upper Flat, Craigowlet House, West Shore Road, Cove 13.06.2025
Mr Euan Wright, Waveney, Argyll Road, Kilcreggan 12.06.2025
Mr James McLean, Seymour Lodge, Shore Road, Cove 29.05.2025
Ms Charlotte McLean, Seymour Lodge, Shore Road, Cove 29.05.2025
Dr Lucy Steeds, Ailey Cottage, North Ailey Road, Cove 14.06.2025
Mrs Penny Elles, West Ailey, Shore Road, Cove 04.06.2025 
Support
Mr Andy Evans, 3 Bluebell Dell, Auchengower Park, Cove 09.06.2025
Mr Roy Pearce, 12 Mansion View, Auchengower Park, Cove 15.05.2025 
Representations are published in full on the planning application file and are available
to view via the Public Access section of the Council’s website. 
(ii) Summary of issues raised:
Objections
Amenity
• The siting of the caravans has a negative impact on visual amenity, as
they are positioned at the roadside/shore with no supplementary
landscaping.
Officer Comment: Please see the assessment below. 
Character/Landscape Impact
• The character of the area is affected, as the other caravans are out of
view up the hill. An objector argues that this development does not fall
within the original applications scope, where caravans were permitted out
of sight from the road and shore side.
Officer Comment: Please see the assessment below. 
• It is mentioned that the character of built heritage and natural landscapes
is broken by the development. It is a sensitive site as it forms a first
impression when entering the village. 
Officer Comment: The Site is on the boundary to the village, although not
within it. Please see the assessment below. 
• The objector requests the site be returned to woodland as per the
conservation area.
Officer Comment: the site is outwith the Cove and Kilcreggan
Conservation Area.

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Woodland
• There has been a loss of trees in order to make room for the site, and to
provide views of the loch for the caravans. The objector mentions the loss
of trees should be viewed in the context of the climate crisis and the
relevant development plan policies which seek to protect, conserve,
restore and enhance biodiversity.
Officer Comment: The development is sited in an area of ancient
woodland but is not in a conservation area, and the trees were not
protected by a tree protection order (TPO). Please see the assessment
below. 
• Trees were cut down without first informing the council, and there are no
trees on the existing site plan provided by the applicant. These include
native trees of significant value.
Officer Comment: The tree removal did not require permission and
therefore there is no requirement to include the trees on the existing site
plan. As above, see the assessment below. 
• It is alleged that the applicant felled trees in the Open Space Protected
Area (OSPA) adjacent to the site.
Officer Comment: This would be treated as a separate issue to this
application as it is outside the red line site boundary but it should be noted
that the trees within the adjacent OSPA are not protected by conservation
area or TPO and would not have required consent for felling. 
Site Designation
• The site is not designated for residential homes in the local development
plan 2 (LDP2), and does not comply with criteria for developments
outside of designated areas, sustainable development, placemaking and
conservation of the built environment required by the LDP2. 
Officer Comment: While it is not an allocated site within the Local
Development Plan, the residential caravans are repositioned within the
original boundary of the caravan park rather than an addition/extension
of the caravan park boundary. The overall site area therefore has an
established use as a caravan park. Please see the assessment below as
it pertains to compliance with the relevant development plan. 
Climate Impact
• The development is contrary to the National Planning Framework 4
(NPF4) in its provisions to address the nature crisis.
Officer Comment: Please see the assessment below. 
Miscellaneous 
• There is objection to the nature of retrospective planning applications and
how this damages the civic environment of the area, including local faith
in the planning system.
Officer Comment: This pertains to the Scottish planning system in
general rather than this specific application. 
• The objector states that the caravans are not repositioned from
elsewhere in the site, but new caravans. The site is already at the
permitted quota for caravan provision.
Officer Comment: The caravans have been accounted for against the
submitted plans and there are the correct number of caravans on site.

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• The foundations and hardstanding laid on the site is alleged to be
insufficient in terms of safety. Objections to the dumping of materials to
form hardstanding are made, and the objector requests the area is
replanted to return it to woodland. 
Officer Comment: The engineering works to create the platform are not
part of this application as the works were undertaken more than 4 years
and are exempt from planning enforcement. 
• It is mentioned that the needs of the current residents are addressed by
the landowner before the removal of the caravans.
Officer Comment: Please see the assessment below. 
• Reference is made to previous planning enforcement issues with the site.
Officer Comment: Each application is weighted on its own merits. Please
see the assessment below. 
• The site does not comply with the views set out in the Cove and
Kilcreggan Local Place Plan – which has care for the natural environment
and encouraging working age people to move to the area as key aims. 
Officer Comment: Please see the assessment below. 
• The objector states that the site is outwith the boundary of the original
planning application.
Officer Comment: the new development is within the red line boundary
on 11/00984/PP, although it is not designated as pitches for caravans. 
Support 
Economic Impact
• The economic benefit of development is mentioned, with the contributor
stating that more people will be attracted and contribute financially to the
local area. 
Officer Comment: While it can be argued that if the park is enhanced
there may be economic benefit, the caravans are repositioned from
elsewhere in the site – there is no overall increase in plots meaning that
there will not be significantly more residents or holiday makers than
previous to the development. 
Road Safety
• It is mentioned that the development will not increase risks to motorists
or pedestrians on Shore Road.
Officer Comment: Please see the assessment below. 
Character/Landscape
• The development is small, and therefore will have a low impact on the
character of the area.
Officer Comment: Please see the assessment below. 
Amenity
• The siting of the caravans enhances the view of the park from the road,
and will only improve as the landscaping becomes settled and managed.
Officer Comment: Please see the assessment below.

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Environmental Impact
• The attached septic tanks will prevent pollution in the loch.
Officer Comment: the caravans are shown as within Scottish Water
Mains Supply. 
• There will be minimal impact on light or noise pollution.
Officer Comment: Please see the assessment below. 
Miscellaneous 
• The development is supplying residential homes in the context of a
housing crisis.
Officer Comment: The new caravans replace old caravans that have
been removed from the site, and as they are repositioned they are not
providing any additional residential homes. 
• Should the caravans be required to be removed, that part of the site could
damage visual amenity being an area of hardstanding only, potentially
becoming a site for antisocial behaviour.
Officer Comment: The potential for antisocial behaviour in the future is
not a material planning consideration. 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact Assessment Report: ☐Yes ☒No 
(ii) An Appropriate Assessment under the
Conservation (Natural Habitats) Regulations
1994:   
☐Yes ☒No 
(iii) A Design or Design/Access statement:    ☐Yes ☒No 
(iv) Sustainability Checklists (with reference to the requirements of LDP2
Policy 04) 
TN06 Sustainability Checklist
TN07 Sustainable Buildings Checklist 
The Checklist was submitted 08/09/2025 and then a
revised Sustainability Checklist was submitted
20/01/2026. 
Contribution to community – The parks supports both
permanent residents and holidaymakers. The three new
chalets have greater accessibility and inclusivity and
provide shorter walking distances. 
Support for home working – The chalets is supported by
good broadband access.
Minimise need for travel – The site is located near shops,
schools, healthcare and recreation. There is no increase
in units on the site, so no increase in travel movements.
☒Yes ☐No
☐Yes ☒No

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Existing public transport and active travel – Local bus
services connect the site to nearby towns. There is
walking and cycling routes locally.
Appropriate location for regeneration/growth -  The site
has been successfully operated for decades, making it a
sustainable location. There is no growth proposals and
relocations would satisfy a demand for more accessible
units near the entrance.
Impact on existing org – Local businesses benefit from
sustained tourist trade and resident expenditure. There
is no food store or restaurant on site so residents require
to purchase food locally.
Infrastructure – the development uses existing utilities,
road and drainage.
Brownfield – The works are entirely within an area of
Brownfield land previously used for storage and does not
involve naturalised or greenfield land.(note: the planning
authority do not consider the full site to have been used
for storage and there has been loss of Ancient
Woodland).
Measures to improve/retore the natural env –
Landscaping will be maintained and natural vegetation is
preserved to support biodiversity.
Loss of trees/woodland – There were 4 silver Birch trees
removed from the area as part of woodland maintenance.
The trees were in poor condition. As well as the trees
some invasive Rhododendron were removed. (Note: this
is not been evidenced and the planning authority have
concluded more trees were removed)
Loss of Open space – The development is entirely within
an area previously used for storage in an established
site.
Construction phase – no applicable, retrospective.
Landscape – the site is in a countryside location but not
in a NSA or LLA. The chalets are located on the lower
levels of the park and wont be prominently located or
highly visible to the public. It respects the established
landscape character. (Note: planning authority
assessment on landscape impacts is below, this is the
applicant’s perspective).
Building details – The chalets are single storey, low ridge
with neutral colour and sited to maximise natural light
while benefiting from woodland shelter. No cut and fill
was required. 
Conclusion – The proposals strengthens the long-term
viability of an established mixed use site. It reinforces
local economic resilience by supporting both permanent
housing and tourism sectors.    
(v) A report on the impact of the proposed
development eg. Retail impact, transport
impact, noise impact, flood risk, drainage
impact etc.
Planning Statement / Economic
☒Yes ☐No

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A short statement was initially submitted explaining the
site context and nature of the retrospective application
and then it was subsequently revised and further
information on the Housing Emergency and Economic
factors was submitted. Initially all that was said was “The
purpose of this application is to seek retrospective
approval for the re-siting of 3 existing chalets within the
park, with no increase in the currently approved number
of chalets”  They state the reason for the application is:
“As accommodation and safety standards have
increased over the years, minor changes have been
made to chalet plots to best accommodate vehicles, fire
safety distances between chalets, and to the chalet units
themselves to deliver the most up to date modern living
accommodation standards. This has resulted in the site
owner relocating the 3 chalets to an alternative location
where accessibility is improved on a lower ground level
near the entrance of the site.”
“The retrospective 3 chalets are in use as 2 residential
chalets, and 1 holiday chalet. The applicant is simply
reorganising 3 existing chalets to an alternative location
within their established site boundary. The proposal
does not constitute an intensification of use, and
complies with the limitations set out in Policy 69 of the
LDP2, and the intended aims of NPF4 Policy 30.”
The additional / revised statement also includes the
following key points:
- “The two residential chalets included in this
application provide permanent homes, directly
contributing to housing availability. While
sustainability objectives are important, the housing
emergency requires planning decisions to prioritise
the preservation of existing housing stock.”
- Granting permission would be “ensuring that the
Auchengower Caravan Park can continue to play its
part in supporting local tourism, sustainable rural
living, and addressing Scotland’s pressing housing
challenges.”
- Park investment “the applicant has invested
£570,000 in maintaining, improving and
safeguarding the site over the last 10 years. This
investment has been funded entirely from private
means and reflects a sustained commitment to the
site.” Also in summary they state that prior to
investment, internal roads were badly maintained
and footpaths unsafe, woodland/tree management
was non existent, and rhododendron was overgrown
throughout the site. The removal of the Listed
Auchengower House was for genuine safety
reasons as the building was derelict, unsafe and
beyond repair. The applicant accepts that formal
consent was not secured but the works were carried
out in good faith.
- The retrospective units are necessary to the site
financial structure and the income will help meet the

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ongoing essential costs – tree inspections, woodland
management, compliance upgrades, insurance and
general maintenance. Without this investment, the
site will inevitably deteriorate and there will be
increased safety risks. Refusal would remove a key
income stream. 
- 
Supporting Information is published in full on the planning
application file and is available to view via the Public Access
section of the Council’s website.   
(H) PLANNING OBLIGATIONS 
Is a Section 75 agreement required:   ☐Yes ☒No 
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  ☐Yes ☒No 
(J) Section 25 of the Act; Development Plan and any other material considerations
over and above those listed above which have been taken into account in the
assessment of the application 
(i)  List of all Development Plan Policy considerations taken into account
in assessment of the application. 
National Planning Framework 4 (Adopted 13th February 2023)
Part 2 – National Planning Policy 
Sustainable Places
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 2 – Climate Mitigation and Adaption
NPF4 Policy 3 – Biodiversity
NPF4 Policy 6 – Forestry, Woodland and Trees
NPF4 Policy 7 – Historic Assets
NPF4 Policy 9 – Brownfield, Vacant and Derelict Land and Empty Buildings 
Liveable Places
NPF4 Policy 14 – Design, Quality and Place
NPF4 Policy 16 – Quality Homes
NPF4 Policy 17 – Rural Homes
NPF4 Policy 20 – Blue and Green Infrastructure
NPF4 Policy 22 – Flooding and Water Management 
Productive Places
NPF4 Policy 29 – Rural Development
NPF4 Policy 30 – Tourism 
Argyll and Bute Local Development Plan 2 (Adopted 2024) 
Spatial and Settlement Strategy

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Policy 02 – Outwith Settlement Areas
Policy 04 – Sustainable Development 
High Quality Places 
Policy 05 – Design and Placemaking
Policy 06 – Green Infrastructure
Policy 08 – Sustainable Siting
Policy 10 – Design – All Development
Policy 16 – Listed Buildings 
Diverse and Sustainable Economy 
Policy 23 – Tourism Development, Accommodation, Infrastructure and Facilities
Policy 26 – Informal Public Outdoor Recreation and Leisure Related Development 
Connected Places 
Policy 33 – Public Transport Infrastructure
Policy 35 – Design of New and Existing, Public Roads and Private Access Regimes
Policy 37 – Development Utilising an Existing Private Access or Existing Private
Road
Policy 39 – Construction Standards for Private Access
Policy 40 – Vehicle Parking Provision 
Sustainable Communities 
Policy 52 – Community Plans, Local Place Plans and Locality Plans
Policy 60 - Private Sewage Treatment Plans and Wastewater Drainage Systems
Policy 61 – Sustainable Drainage Systems 
Homes for People 
Policy 66 – New Residential Development on Non-Allocated Housing Sites within
Settlement Areas
Policy 69 – Residential Caravans and Sites (for Permanent Homes) 
High Quality Environment 
Policy 73 – Development Impact on Habitats, Species and Biodiversity
Policy 77 – Forestry, Woodland and Trees 
(ii)  List of all other material planning considerations taken into account in
the assessment of the application, having due regard to Annex A of
Circular 3/2013. 
• Third Party Representations
• Consultation Reponses
• Planning History
• Caravan Sites and Control of Development Act 1960 (“The 1960 Act”) 
• Cove and Kilcreggan Local Place Plan
• Landscape Character Assessment (Nature Scot 2019)

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• Rosneath Peninsula Environmental Baseline Report (LUC 2023)
• Argyll and Bute Local Housing Strategy 2022-2027 (“LHS”)
• Housing (Scotland) Act 2014 (“The 2014 Act”)
• TN06 Sustainability Technical Note and Checklist (Oct. 2023)
• ABC Economic Development Action Plan
• SEPA Standing Guidance for Development Management (Dec. 2022)
• Historic Environment Scotland - HEPS
• Historic Environment Scotland – Managing Change in The Historic Environment
- various 
(K) Is the proposal a Schedule 2 Development not requiring an Environmental
Impact Assessment:  ☐Yes ☒No 
(L) Has the application been the subject of statutory pre-application consultation
(PAC):  ☐Yes ☒No 
(M) Does the Council have an interest in the site:  ☐Yes ☒No 
(N) Requirement for a pre-determination hearing: ☐Yes ☒No 
A total of 15 public representations have been received in response to this planning
application, of which 12 are in objection and 2 are in support. There is also a
representation from the Community Council in objection. Although the application
has raised many concerns locally given it is retrospective and required enforcement
case being opened, it is the opinion of the Planning Authority that the representations
received do not raise any complex issues. We consider that the Officer assessment
of the relevant planning issues contained within this report and the presentation at
PPSL which will present the finished retrospective development, provides all the
information required to enable Members to make an informed decision based on all
the material planning considerations in this case. It is therefore not considered that
a discretionary local hearing would add value to the planning process. 
(O)(i) Key Constraints/Designations Affected by the Development:
• Ancient woodland inventory
• Semi ancient woodland
• Setting of Listed Building 
(O)(ii) Soils
Agricultural Land Classification:  Class 4.1 -  Land capable of producing a
narrow range of crops, primarily
grassland with short arable breaks of
forage crops and cereal.
Peatland/Carbon Rich Soils Classification: ☐Class 1
☐Class 2
☐Class 3
☒N/A
Peat Depth Classification: N/A

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Does the development relate to croft land? ☐Yes ☒No
Would the development restrict access to
croft or better quality agricultural land?
☐Yes ☐No ☒N/A
Would the development result in
fragmentation of croft / better quality
agricultural land?
☐Yes ☐No ☒N/A 
(O)(iii) Woodland  
Will the proposal result in loss of
trees/woodland? 
Note: This is a retrospective application and
tree loss has already taken place. No further
tree loss is proposed. 
☒Yes
☐No 
Does the proposal include any replacement
or compensatory planting?
☐Yes
☒No details to be secured by condition if to
be approved
☐N/A  
(O)(iv) Land Status / LDP Settlement Strategy
Status of Land within the Application  ☒Brownfield
☐Brownfield Reclaimed by Nature
☒Greenfield 
Site is part brownfield and part greenfield. 
ABC LDP2 Settlement Strategy
☐Settlement Area
☒Countryside Area
☐Remote Countryside Area
☐Helensburgh & Lomond Greenbelt
ABC LDP2 Allocations/PDAs/AFAs etc:
N/A 
(P) Summary assessment and summary of determining issues and material
considerations 
This application is made following planning enforcement case 24/00057/ENOTH2. 
Retrospective planning permission is sought for the following; a repositioning of
three caravans (one holiday and two residential use), along with associated works
being the erection of associated decking for each caravan and formation of
parking/turning areas for the caravans within an established caravan park. The
application site is at the south-west of the Auchengower Park, on the first bend of
the access that leads up to the rest of the park. Auchengower Park has been a
registered caravan site from 07/04/2017 for both residential and holiday caravans. 
At the time of writing, public representations had been received by the Planning
Authority from 15 respondents in relation to this planning application with 13
objecting (including the Community Council) and the remaining 2 supporting. Loss of
woodland and landscape/visual impacts are the key concern of the public
representatives.

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In summary the key conclusions of the officer’s assessment are: 
• There are significant benefits of the proposal in terms of providing affordable,
accessible permanent homes within an established residential park to meet
current expected standards. 
• There are benefits in creating an income stream for an existing established
tourism / residential caravan site that requires the income to ensure the long
term maintenance and sustainability of the site as a whole. 
• The layout and landscape effect of the development has altered the woodland
and coastal character of the area, affected the setting of a listed building,
namely Auchengower Lodge and the important gap between the settlements
has adversely affecting the sense of place, and resulting in a proposal that is
therefore not consistent with the development plan but subject to conditions
these impacts can be reduced significantly. 
• There were adverse impacts on trees and Ancient Woodland through the
creation of the original hardstanding area but this area was created more than
4 years ago and is now lawful. There was also further removal of trees to
create views from the caravans within the Ancient Woodland. There is
however no objection from the biodiversity officer as there is now an
opportunity to mitigate the loss of woodland and protected species, via
conditions, by requiring a wildlife survey, bringing in soils from a local source
and securing compensatory native planting to enhance the woodland in the
long term. This long-term enhancement also includes continued management
of the non-native rhododendron on site which is a significant benefit to the
area. 
• On balance, the provision of caravans on this area of hardstanding that has
become lawful, will be an improvement to the area being used for
storage/materials which would be more unsightly than this tidy and quality
caravan development. The landscaping will reduce any impacts to negligible
in the long term. 
In conclusion, there is support within the policy provision of the adopted National
Planning Framework 4 (NPF4) and Local Development Plan 2 (LDP2) in terms of
providing permanent affordable homes, supporting the tourism sector and sustaining
an established long business but it is acknowledged the local landscape and ancient
woodland has been affected by the development works. In approving the proposal,
there can be significant gains to local biodiversity in terms of long-term woodland
management and the landscape harm can be somewhat mitigated. 
It is therefore recommended that planning permission be approved as a minor
departure from the development. The full report is provided in Appendix A. 
This application would be determined as a local application under the Council’s
delegation scheme; however, several public representations has been received. To
meet the requirement of the scheme of delegation, the planning application for the
proposed development is therefore put to Members for determination. 
(Q) Is the proposal consistent with the Development Plan: ☐Yes ☒No

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(R) Reasons why Planning Permission or Planning Permission in Principle Should
be Granted: 
See Section (S) below. 
(S) Reasoned justification for a departure to the provisions of the Development
Plan 
NPF4 policies 9, 14, 30 and LDP2 policies 05, 08, 09, 10 and 23 seek to ensure that
development is of appropriate design and siting and does not adversely affect on
landscape character or valued landscape qualities. The proposal has had an adverse
impact on the sensitive undeveloped woodland and coastal landscape character and
valued landscape qualities of this countryside area between Ardpeaton and Cove. 
NPF4 Policies 4 and 6 and LDP2 Policies 02, 73, 77 and 78 seek to enhance
biodiversity, protect woodlands including Ancient Woodland. The proposal has
involved the loss of some woodland which has not been able to be quantified. The
loss of Ancient Woodland is contrary to the aforementioned policies. 
NPF4 Policy 7, LDP2 Policy 16 and relevant HES guidance seek to protect historic
assets. The setting of the nearby Listed Building - Auchengower Lodge – has been
affected by the introduction of the three new chalets. The lodge house would have
previously been the only building at the road level to the main house. 
In the particular circumstance of this case, it is considered that this shortfall can be
accepted as a minor departure to policy given the following wider considerations: 
• There are significant benefits of the proposal in terms of providing
affordable, accessible permanent homes and also creating an income
stream for an existing established tourism / residential caravan site that
requires the income to ensure the long term maintenance and
sustainability of the site. 
• The site is within an established site with necessary infrastructure provision
and does not result in an overall net increase in the number of caravans in
terms of impact on travel. There is good connections by bus from the site
to nearby facilities such as medical centre, shops, onward travel, schools
and the residents and holiday makers of the site will support the local
businesses – shops and facilities etc. 
• There will be suitable tree re-planting to reduce the visual impact and the
previous unsightly storage area has been removed. 
• There will be biodiversity gains from long-term woodland management and
removal of invasive Rhododendron ponticum. 
• The application site was the previously a storage area at the entrance to
the caravan site with a bin area and so had already had its setting affected.
The impact therefore considered minor.

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• There are no objections from Roads, Environmental Health or the Council’s
biodiversity officer. It is noted that the Community Council object but this
is on the issue that it was retrospective rather than the impacts the
proposal has on the environment. 
Whilst it is recognised that the proposal does not fully meet the provisions of a number
of policies in terms of landscape, woodland and historic assets, the mitigating factors
detailed above are of sufficient materiality for the application to be approved as a
minor departure to the Development Plan. 
(T) Need for notification to Scottish Ministers or Historic Environment Scotland:
☐Yes ☒No 
Author of Report:  Kirsty Sweeney Date: 30.01.2026 
Reviewing Officer: Sandra Davies Date: 05.02.2026 
Fergus Murray
Head of Development & Economic Growth

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CONDITIONS AND REASONS RELATIVE TO APPLICATION REF. NO. 25/00516/PP 
1. Approved Details 
Unless otherwise directed by any of the conditions below, the development shall be
implemented in accordance with the details specified in the application form dated 1
May 2025; the supporting information; and the approved drawings listed in the table
below unless the prior written approval of the planning authority is obtained for an
amendment to the approved details under Section 64 of the Town and Country
Planning (Scotland) Act 1997. 
Plan Title. Plan Ref. No. Version Date Received
Location Plan 1 of 4  28.04.2025
Existing Site Plan 2 of 4  31.03.2025
Proposed Site
Plan 
3 of 4  28.05.2025
Chalet Floor Plan 4 of 4  10.04.2025
Landscape Plan 10B  20.01.2026 
Reason: For the purpose of clarity, to ensure that the development is implemented in
accordance with the approved details.
2. Defining Use of Caravans: 
The occupation of caravans 1 and 3 hereby approved shall be permanent residences
and the occupation of caravan 2 hereby approved shall be solely for holiday purposes
and may not function as a permanent residence. 
Reason: In order to define the permitted occupancy having regard to the lawful use of
the site. 
3. External Lighting 
Unless otherwise agreed in writing with the Planning Authority, all external lighting on
the application site shall be operated, positioned and angled in compliance with the
Scottish Government Guidance Note “Controlling Light Pollution and Reducing
Lighting Energy Consumption” (March 2007). 
Reason: In order to protect the amenity of the immediate area from the creation of
nuisance due to light pollution and to support the reduction of energy consumption 
4. Wildlife Surveys 
Notwithstanding the provisions of Condition 1, within 1 month from the date of this
decision, a detailed habitat and species survey shall be undertaken and the results,
together with a scheme of enhancement measures, shall be submitted to and
approved in writing by the Planning Authority.  The survey methodology shall be
submitted to and approved in writing by the Planning Authority before the survey
commences.  The scheme of measures shall be implemented in full accordance with
a time-scale to be agreed in writing with the Planning Authority or no later than 12
months from the date of this decision.

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Reason: To safeguard protected species and nature conservation interests and
ensure the proposed biodiversity enhancement and landscape proposals are suitable. 
5. Biodiversity Enhancement 
Notwithstanding the provisions of Condition 1, within 3 months from the date of this
decision, a final biodiversity statement, based on the findings of the species survey as
per Condition 4, shall be submitted to and approved in writing by the Planning
Authority. The statement shall demonstrate how the proposal will contribute to
conservation/restoration/enhancement of biodiversity, and how these benefits will be
implemented and maintained for the lifetime of the development. 
All physical biodiversity enhancement measures (e.g. bird nesting boxes, ‘swift bricks’,
wildlife ponds, bat and insect boxes, hedgehog homes, etc) shall be implemented in
full no later than 12 months from the date of this decision. 
All biodiversity enhancement measures consisting of new or enhanced planting shall
be undertaken either in accordance with the approved scheme of implementation or
within the next available planting season or no later than 12 months from the date of
this decision. 
The biodiversity statement should refer to Developing with Nature guidance |
NatureScot and Scottish Government Planning Guidance: Biodiversity as appropriate. 
Reason: In order to comply with the requirements of NPF4 Policy 3. 
6. Non-Native Species Removal Plan 
Within 3 months of the date of this permission, a long-term Invasive Non-Native
Species (INNS) Flora Management and Removal Plan, including a timetable for the
maintenance works, shall be submitted to, and approved in writing by, the Local
Planning Authority in consultation with the Council’s Biodiversity Officer. The approved
plan shall have been prepared by a suitably-qualified person. Thereafter, the plan shall
be fully adhered to, and any removal shall be implemented in accordance with the plan
and the timetable. 
Reason: In the interests of biodiversity 
Note: This guidance from FLS may be of use Stem Guide (low res web copy) single
pages 
7. Landscaping scheme 
Notwithstanding the provisions of Condition 1, within 3 months from the date of this
decision, a final scheme of landscape plan (based on the draft plan, received
20.01.2026) shall be submitted to and approved in writing by the Planning Authority.
The scheme shall comprise a final planting plan and schedule which shall include
details of: 
i. Proposed soft landscaping including the final location, species and size of
every tree/shrub to be planted alongside the road edge with no gaps (based
on any recommendations from the protected species survey); 
ii. Final paint colours for the decking;

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iii. Details of any soils to be brought on to site, including the source. Note: it
should be sourced from a nearby site with compatible soil type to reduce
impact.
iv. A programme for ongoing maintenance. 
All of the hard and soft landscaping works shall be carried out in accordance with the
approved scheme unless otherwise approved in writing by the Planning Authority
within 6 months of the decision hereby issued. 
Any trees/shrubs which within a period of five years from the completion of the
approved landscaping scheme fail to become established, die, become seriously
diseased, or are removed or damaged shall be replaced in the following planting
season with equivalent numbers, sizes and species as those originally required to be
planted unless otherwise approved in writing by the Planning Authority. 
Reason: To assist with the integration of the proposal with its surroundings in the
interest of amenity. 
8. Changes to caravans 
The permission hereby granted relates to the retention of the caravans existing on the
site at the date of the application only and no replacement caravans shall be sited on
the land unless, and until, details of the size, design and colour of such replacement
caravans have first been approved in writing of the Planning Authority. 
REASON:     For the avoidance of doubt and to safeguard the visual amenities of the
area. 
9. Numbers of Caravans:  Not more than 3 caravans shall be sited on the land the
subject of this permission at any one time and shall not be laid out other than in
accordance with the approved Proposed Site Plan received by the Planning Authority
on 28.05.2025. 
REASON:     For the avoidance of doubt and to safeguard the visual amenities of the
area. 
10. Surface Water Drainage 
Notwithstanding the provisions of Condition 1, within 3 months from the date of this
decision, details of a sustainable urban drainage system compliant with the guidance
set out in CIRIA’s SuDS Manual C753 shall be submitted to and approved in writing
by the Planning Authority, in consultation with the Council’s Flood Advisors. The
approved surface water drainage system shall be operational within a further 3 months
of the scheme being approved and shall be maintained as such thereafter. 
Reason: In order to ensure that adequate surface water drainage is implemented to
prevent flooding elsewhere. 
11. Parking 
The parking area for a minimum of 1 vehicle per unit shall be retained for such a
dedicated purpose, unless the prior consent for variation is obtained in writing from the
planning authority.

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Reason: To comply with car parking standards contained in Policy 40 of the Argyll and
Bute Local Development Plan.

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COMMITTEE REPORT
APPENDIX A – RELATIVE TO APPLICATION NUMBER:  25/00516/PP 
PLANNING LAND USE AND POLICY ASSESSMENT 
1. Background and Settlement Strategy 
.
1.1. The Caravan Park is located between the settlements of Cove and Ardpeaton in an area
of countryside and has been in operation since the 1970s and is a long-established local
business. The caravan site has permission for 30 residential caravans and 30 non-
residential caravans – a total of 60 caravans with a specific layout, required by Condition
5 of C3122: “That the caravans are sited in accordance with the layout pan approved by
the county council”. The site was originally built around a Victorian Villa, known as
Auchengower Mansion House (Category B Listed Building), which has been subject to
unauthorised demolition in circa 2020. The House sat up on the cliffside and its
landscaped gardens surrounding was developed into the caravan park. There are
numerous enforcement cases live at the caravan park, mostly relating to the repositioning
of caravans without permission, some which followed the demolition of the listed building.
Members should be aware that it is the planning authority’s opinion that the building was
likely to have been beyond economic repair and was subject to a Demolition Notice issued
by the Council’s building standards team. The applicant states in their supporting
statement that “The removal of the Listed Auchengower House was for genuine safety
reasons as the building was derelict, unsafe and beyond repair. The applicant accepts
that formal consent was not secured but the works were carried out in good faith.” So it is
agreed that even though formal consent was not sought that the works to demolish the
house are likely to have been consented as the Policy on Listed Buildings allows
demolition where there a property is beyond economic repair. It has therefore not been
considered expedient to enforce against this matter. 
1.2. The historic planning permissions provide clear detail on the layout of the caravan park
as it relates to the pitches and access to caravans in the upper part of the site, in contrast
to this, the application site is listed as a ‘refuse/bin store and collection point’ and
‘woodland area’. In the historic planning reports it was states that: “We would also like to
set a limitation on the siting of caravans in that they must not be visible from the main
road”. The previous planning history of the park clearly and precisely sets out the
permitted number of caravans and their layout, which this application contradicts hence
the reason for enforcement. Further, both C3122 (condition 6) and C3122/1 (condition 2)
require that: “no trees or bushes be removed from the site without the consent of the
county council” and “No trees shall be removed without the prior consent of the district
council. Reason: In accordance with previous consent and in the interests of amenity”
respectively which is a breach of condition. 
1.3. The legislation from the Scottish Government on fire safety was updated guidance in
2022, requiring spacing between caravans to generally be no less than 6 metres and the
site license has conditions dictating this minimum distance between caravans. The
applicant argues that increased demands on space for parking/turning, larger units as
well as legislation requiring set distances between caravans to increase, the site has
become crowded in its previously permitted layout. It is therefore not offering the best
environment for permanent residents in accordance with current standards and is bringing
the viability of the caravan park into question. They argue that this is why the repositioning
has been carried out, to improve access and privacy for residents across the whole site.

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1.4. In terms of the LDP2, the site is defined as ‘Outwith Settlement Areas’ within an area
identified as ‘Countryside Area’ (CA) where Policy 02 of LDP2 gives a presumption in
favour of sustainable development where it is of an appropriate scale, design, siting and
use for its countryside location, as set out in the relevant sustainable siting and design
policies of LDP2. In CAs, where there are nature conservation or landscape designations
in place, Policy 02 requires that development proposals will demonstrate that they are
compatible with the designation interests. The woodland interests and landscape
character have been impacted by the development. The clearing of trees on the boundary
of the site has made it especially prominent, especially compared to the previously
woodland appearance along the roadside.  The landscape character of the area has been
altered. There has been no submission of a landscape and visual impact assessment to
support the application. Further detailed assessment of this impact is below. 
1.5. The site is partially brownfield site, as prior to siting the caravans part of the site was a
level area of hardstanding. The area of hardstanding was unauthorised works undertaken
in 2020 that is now time barred from enforcement. The rest of the site was greenfield and
included woodland. The proposed development must be considered against NPF4 Policy
9 – Brownfield, Vacant and Derelict Land and Empty Buildings. Policy 9 b) requires that:
proposals on greenfield sites will not be supported unless the site has been allocated for
development or the proposal is explicitly supported by policies in the LDP.  The proposal
is a minor departure from this policy given a very small part of the application site was
greenfield. 
1.6. LDP2 Policy 23 – Tourist Development, Accommodation, Infrastructure and Facilities
dictates a presumption in favour of new or improved tourist facilities and accommodation,
provided it meets certain criteria. NPF4 Policy 30 Tourism states that a) development
proposals for new or extended tourist facilities or accommodation, including caravan and
camping sites, in locations identified within the LDP, will be supported if they meet a
number of criteria. The proposal is effectively re-positioning of caravans for tourist and
residential use and therefore the principle of the development is supported by this policy.
However, the policy has other criteria including compatibility with the surrounding area
which is relevant when considering the re-positioning and this is assessed below. 
1.7. NPF4 Policy 17 rural homes does not apply to this proposal, as the caravans are not new
homes. Similarly, Policy 69 – residential caravans and sites (for permanent homes) states
that no new residential caravans will be permitted for permanent homes; however, there
is no policy conflict between this requirement and the proposal. Several objectors
mentioned that the caravans are new, and that this development therefore must be
contrary to policy, however the caravans on site have been counted and accord to the
site plans that have been provided. There is no increase in residential caravans. This
aspect of the application is therefore consistent with policy 17 and 69, despite it being a
development that involves residential caravans. They are caravans that previously have
had permission and are solely being re-positioned. Despite the lack of support from Policy
69 for new residential caravans, it should be recognised that the residential caravan
sector in Scotland plays a significant role in delivering housing, particularly affordable
housing. 
2. Local Living and sustainable transport 
2.1. NPF4 Policy 13 – Sustainable Transport seeks to encourage, promote and facilitate
developments that prioritise walking, wheeling, cycling and public transport for everyday
travel and reduce the need to travel unsustainably. 
2.2. As the development is a repositioning of 3 caravans within the existing Auchengower
Park, this development creates no additional travel generation. Furthermore, the site is

Page 24

already served by nearby public transport routes, although it has been identified in the
LPP that active travel routes in the area need improvement. The 3 units are also not up
the steep road so provide 3 more accessible units wherein those that are disabled can
easily access the bus stop at the entrance of the site. Overall, the application is consistent
with the requirements of NPF4 – Policy 13 and LDP2 Policy 33 – Public Transport
Infrastructure and Local Living Policy 15 of NPF4. 
3. Location, Nature and Design of Retrospective Development 
3.1. The application site is within the existing boundary of Auchengower Caravan Park,
approximately 30 metres up the access from the B833 (Shore Road). It is rectangular in
shape, 1500 square metres in size, and approximately 6 metres east of the B833. As the
application is retrospective, the site has already been cleared of vegetation, the ground
has already been profiled, and the caravans have been erected on site with associated
decking, new internal road and parking areas. 
3.2. In terms of the engineering works to create the previous storage area, this was created
approximately 9-10 years ago shortly after the new owner bought the site. The area was
used to store rubble at the time of the demolition of the Auchengower Mansion site in
circa March 2020 and the council have photographic evidence of this and the expansion
of this area (now 6 years ago). The engineering works to create this platform / storage
area and the loss of woodland as the result of this storage area are not subject to
consideration as they have become time barred from any enforcement action. 
3.3. Peaton Glen, Ardpeaton Woods is designated as a Local Nature Conservation Site
(LNCS) and it bounds Auchengower Caravan Park to the north, approximately 100 metres
from the application site. Open Space Protected Area (OSPA) OS2036 is immediately to
the west of the B833; it runs parallel to the site and separates the land between the shore
of Loch Long and the B883. There is no overlap between the application site and the
LNCS or the OSPA, they are merely in close proximity. While the site is not within the
settlement boundary of Cove, it is immediately adjacent to the village boundary making it
approximately half a kilometre from the Cove and Kilcreggan Conservation Area.  It is
concluded that the LNCS, OSPA and the Conservation Area are not affected by the
development. 
3.4. The site is within an area of Ancient Woodland and this is assessed in more detail below
as there has been some impacts in this regard. 
3.5. The landscape and seascape character of the wider Rosneath Peninsula is described as
noticeably less developed, giving a greater sense of rurality. The smaller-scale wooded
nature of the coastal fringes create a more intimate landscape with a higher perceived
sense of wildness, whilst the open moorland hills offer panoramic views across the sea
lochs to the mountains beyond by the Rosneath Peninsula Environmental Baseline
Report (2023). The site of this development is visible primarily in close view from the road,
and the area is accessed by a diverse array of receptors, from commuters and locals to
recreational walkers, cyclists and those on ferries, sailing or fishing but the wider views
are from a distance and are filtered and framed by trees along the shore (which remain
and are in the OSPA on the opposite side of the road).   
3.6. The proposal consists of the repositioning of three Boston model caravans, measuring 12
metres x 6 metres (12.68 metres x 6.644 metres size from roof and including barge
boards) and single storey in height with a sloped roof. They have been erected with the
decking facing towards the B833 and Loch Long, with the side elevation visible on
approach from the access. They provide an open plan lounge, dining area and kitchen at
the rear, with bedrooms, shower room, and en-suite at the front. The caravans are of

Page 25

contemporary design, finished with wood grained aluminium cladding. The attached
decking extends a further 2.5 metres from the rear elevation, 7.2 metres across from the
elevation, 9 metres parallel down the side elevation, before meeting the side elevation
again 1.2 metres in. The siting of the caravans positions panoramic windows and decking
towards Loch Long and positioning near to the entrance of the site is intended to enhance
the accessibility. The layout can therefore be said to improve views of the landscape from
the caravans. 
3.7. The Landscape Character Assessment (Nature Scot 2019) states that the area is ‘Open
Ridges’ Landscape Character Type and it is described as “Settlement is largely confined
to the loch edges. The houses are typically at an acute angle to the road and are stepped
up the slope on terraces. Beech hedges contrast with local stone walls, natural rock
outcrops and mixed woodlands to create a richly varied local landscape. The strip of land
by the loch side is particularly prominent in views from the opposite side of the loch.
Reflection increases the visual effect of built development on this shoreline landscape.” It
also states “Despite the wooded character, there are many long, framed views and the
landscape has an open, well-structured character” and “On the loch edges, there is a
gradual change to a smaller scale landscape, with wooded gills and a narrow, intermittent
band of built development”. 
3.8. The topography of Auchengower Caravan Park contributes to the assessment of this site
as it relates to landscape character and amenity. The park sits on a steep slope and
before this development the caravans were all sited in the upper portion, therefore
screened from view by the slope and surrounding woodland. This also meant the
landscape character between the settlements of Cove and Ardpeaton was predominately
the original woodland character. This is only a small section between the two settlements
but it is important green area between the build up areas and interrupts the ribbon
development that makes up the settlement areas. 
3.9. The caravans sit on a small and gentle slope down to the B833, with the rear raised to
maintain level, which provides the caravans a better view out onto Loch Long; and their
height above the road mean they are not immediately on the roadside and there is space
for landscaping to the front. Part of the application site was the ‘refuse/bin store and
collection point’ as shown on the original application C.3122 and 11/00984/PP which
benefited from a woodland screen. This woodland screen could be replaced. 
3.10. It is accepted that the previously approved layout (in the 1970s) was carefully
considered to avoid the area on the lower side of the cliff next to the road where there is
a strip of Ancient Woodland. However, via suitable mitigation a new woodland screen can
protect and enhance this important roadside strip on the lower slope. 
3.11. The applicant claims it was only 4 birch trees that were removed but there was
evidence of more than 4 trees and a mix of species. On the officer’s site visit it was noted
that there were a number of stumps of Sycamore trees left along the edge of the site
beside the road, and one stump from a birch.  The trees are already growing back and
the original stone boundary wall remains. Even though there has currently been no
replanting to form screening via new shrubbery/trees, the applicant confirms that he was
told to stop works before he had finished the landscape works. The applicant has
submitted a detailed replanting plan including the replacement of a mixed native
hedgerow along the side of the wall, 15 larger Oak and Birch trees and a mix of smaller
native bushes around the edge of the decking. This is welcomed and will significantly
mitigate the landscape and visual impacts of this development.

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3.12. NPF4 Policy 14 – Design, Quality and Place seeks to encourage, promote and facilitate
well designed development that makes successful places by taking a design-led approach
and applying the ‘Place Principle’. LDP2 Policies 05, 08, 09 and 10 serve to ensure that
development, by reason of density and layout, effectively integrate with their setting and
they resist developments with poor quality or inappropriate layouts or densities including
over-development. NPF4 Policy 29 – Rural Development b) requires that development
proposals in rural areas should be suitably scaled, sited and designed to be in keeping
with the character of the area. 
3.13. The design of the development does not in itself present a contradiction to NPF4 policy
14 or LDP2 Policies 05, 08, 09 and 10 as the caravan’s colour and style is in keeping with
the caravans across the existing caravan park. The LDP2 states that: “Argyll and Bute’s
wet and damp climate and often exposed locations mean that such homes [Caravans]
can be difficult to heat and are prone to deteriorating faster than their designed life and
so they are not considered suitable for long term retention” (8.7). However, the caravans
are new, likely making them more sustainable than older models. 
3.14. LDP2 Policy 23 – Tourist Development, Accommodation, Infrastructure and Facilities
dictates a presumption in favour of new or improved tourist facilities and accommodation,
provided that: i. the development is in a form scale and location which is consistent with
its surroundings; ii. The proposals respect and integrate well with the
landscape/townscape character and the amenity of the surrounding area; iii. They are
located in accessible locations, taking into account the scale and nature of the proposed
development, and include proposals to widen the options for sustainable travel to access
them (including public transport, cycling or on foot); and iv. They are well related to the
existing built form of settlement areas or the existing development pattern outwith the
settlement areas and avoid dispersed pattern of development unless the developer has
demonstrated a locational requirement based upon the need to be near to the specific
tourist interest being exploited and that the proposed development will not undermine
these interests. It is considered that this development is acceptable in terms of its location
with access to sustainable travel, and subject to the landscaping as mentioned above, it
will be framed and sit comfortably in the landscape in the longer term. Even though it is
creating further ribbon development, this development pattern is existing and therefore
the development has not created a dispersed pattern of development. 
3.15. NPF4 Policy 30 has similar criteria and requires proposals to be compatible with the
surrounding area in terms of nature and scale of the activity and impacts of increased
visitors. There is no increase in the number of visitors as the caravans are not ‘new’ but
re-positioned. 
3.16. The Rosneath Peninsula Environmental Baseline Report (2023) states that new
development and changes in land use along the coastal fringes of the peninsula may
result in the degradation of the landscape and visual resource, including loss of important
landscape features such as trees and woodland. The proposal is considered to be a minor
departure from both LDP2 Policy 23 and NPF4 Policy 30 given that there has been loss
of important landscape features i.e. trees, but subject to extensive new landscaping the
coastal fringe is considered to be protected in the long term. 
3.17. The significant level of replanting will bring back the woodland character and reverse
the adverse effect on the previously woodland character of the site. Subject to the
compliance with the condition, the development will become sympathetic to the woodland
landscape that it is positioned in, and the concern over the current lack of boundary
treatment on the landscape will be removed.

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4. Visual Amenity 
4.1. As stated above, the site of this development is visible to the locality, with the visual
amenity of this site characterised by a rural, woodland and coastal appearance between
the settlements of Cove and Ardpeaton. The contemporary design of the caravans,
coupled with the raw material finish and loss of woodland has had an impact on the visual
amenity of the area, particularly from fleeting glimpses as you travel along the road. 
4.2. LDP2 Policy 02 and 23 requires that there will be no unacceptable adverse effects on
visual amenity. NPF4 Policy 14 – Liveable Places c) states that proposals that are poorly
designed, detrimental to the amenity of the surrounding area or inconsistent with the six
qualities of successful places, will not be supported.  
4.3. The LDP2 states that: “static caravans because of their shape, size and materials of
construction can often be difficult to integrate visually with their landscape or townscape
settings and can therefore have a detrimental impact on the amenity of a local area” (8.8).
There are concerns from several contributors with regard to the amenity of the local area,
and how the development has negatively impacted it. Even though the impact on amenity
of the development is currently deemed unacceptable, there is significant mitigation
proposed. As previously mentioned, the site is sensitive due to its location on the B833
and proximity to the OSPA and shorefront where there are a large and diverse array of
receptors. However, the views from the loch are framed by existing woodland and are
fleeting. The muted brown colours of the caravans means that from a distance they will
be difficult to distinguish in the wider landscape. 
4.4. The decking and fencing surrounding the caravans is of timber construction, it significantly
extends the footprint and visibility of the caravans. The raw material finish of the timber
fencing makes the caravans stand out strongly against the surrounding trees which
previously characterised the site. The contemporary finish and design of the caravans is
acceptable in the context of a long-established caravan park. Currently, there has been
no replanting to screen or soften the visual impact of the caravans, however the owner
proposing new landscaping to help integrate the caravans with their site. 
4.5. Conditions requiring extensive boundary treatments and landscaping to integrate the site
with its surroundings and provide screening would be required to reduce the harm to
amenity. It is therefore considered that subject to the screening the proposal would be a
minor departure from policy in this regard.  
5. Natural Environment 
5.1. The site is within an area of ancient woodland, where there has been a loss of woodland
resource which may have been home to red squirrels, bats and many other important
birds and plants. The woodland has already been removed and the information provided
by the owner has not been verified by any supporting information and there is no
information on the condition or the biodiversity value of the current site. Aerial
photography and street view imagery illustrates there was continuous woodland on the
site (prior to the unauthorised engineering works and the caravans being sited) and a
number of mature trees.  It should be noted that there is a small part of the site (next to
the access road) has been clear of woodland for many years, so the full site is not ancient
woodland. This part of the site has been listed as a bin store or vacant space in different
approved plans and constitutes under a third of the total site. 
5.2. The Rosneath Peninsula Environmental Baseline Report (2023) states that increasing
demand for new development along the narrow coastal fringes of the Rosneath Peninsula

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could result in increased fragmentation of habitats (e.g., woodland). Not only does this
vegetation provide habitats for biodiversity, but it is also integral to defining the smaller
scale landscape character of the coastal fringes. 
5.3. Even though part of the application site has been previously a bin storage area of
potentially low biodiversity value given the rhododendron which is invasive, there has
been part of the site that would have been mature woodland (as can been seen from
google imagery), where there could have been important wildlife. The clearing of
vegetation and ground engineering works will have had some impact on biodiversity.
NPF4 Policy 3 – Biodiversity requires that d) any potential adverse impacts, including
cumulative impacts, of development proposals on biodiversity, nature networks and the
natural environment will be minimised through careful planning and design. A draft
landscaping plan has been submitted to show proposed landscaping works with some
biodiversity enhancement measures including the continued control of the non-native
invasive rhododendron and retention of felled trees/logs on the woodland floor. The draft
landscape plan will help reduce the fragmentation of the woodland and enhance
biodiversity. The biodiversity officer is content with the draft landscape plan, although
there was some concern about bringing soil into the site and the need for a species survey
to gauge what species are using the site currently to inform the final landscaping and
biodiversity enhancement measures. 
5.4. It is recommended that conditions would secure the implementation of the landscaping
plan and the final details of the size of species and any other biodiversity enhancement
measures inc. long-term control of the invasives and features that help the wildlife on site.
Therefore, nature based solutions would contribute significantly to enhance the site, and
potentially could make the proposed development consistent with the requirements of
NPF4 Policy 4 or LDP2 policy 73 (development impact on habitats, species and
biodiversity). 
5.5. Conditions are considered to make the development compliant and enhance the
biodiversity to reverse the loss. This would include biodiversity enhancement measures:
a programme of tree planting and monitoring; bird and bat boxes; red squirrel feeding
boxes; native wildflower planting; among other possible measures. 
6. Trees and Woodland 
6.1. As indicated above, the site is identified as Ancient Woodland where there has been
removal of woodland resource to accommodate the hardstanding/engineered platform
(which is exempt from enforcement) where the caravans are sited but also areas of
woodland around this platform were cleared to create views. This means that developing
part of the site would not have resulted in loss of woodland and the area removed has
mainly been along the roadside. 
6.2.  The applicant has said 4 silver birch were removed and were in poor condition but they
have not backed this up with any evidence of the size or condition of the trees that have
been cleared. A tree survey was not carried out on site before works began, meaning that
it cannot be said what trees were on site; however, during a site inspection there was
evidence of several tree stumps from mainly Sycamore and Birch and that the site is fairly
wet with a ditch running behind the wall. There was evidence of rhododendron having
been removed and is now returning in small shoots. There is woodland removed outwith
the red line boundary, but the works to remove it were carried out in conjunction with this
development. In addition, historic images and mapping show a mixture of trees and
shrubbery contained along this stretch.

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6.3. NPF4 – Policy 6 b) states that development proposals will not be supported where they
(i.) result in any loss of ancient woodlands, ancient and veteran trees, or adverse impact
on their ecological condition; (iii) fragmenting or severing woodland habitats, unless
appropriate mitigation measures are identified and implemented in line with the mitigation
hierarchy. The loss of ancient woodland in this instance is contrary to the development
plan. 
6.4. NPF4 - policy 6 c) requires: “Development proposals involving woodland removal will only
be supported where they will achieve significant and clearly defined additional public
benefits in accordance with relevant Scottish Government policy on woodland removal.
Where woodland is removed, compensatory planting will most likely be expected to be
delivered.” This, at a minimum, requires compensatory planting to be carried out by the
applicant to become compliant with this aspect of the policy. 
6.5. LDP2 Policy 77 states there is “a strong presumption in favour of protecting woodland
resources” with particular care to be taken to ensure that ancient semi-natural woodland
of high nature conservation value is safeguarded, conserved and, where possible,
enhanced. While a loss of irreplaceable woodland has already resulted from this
development, further works must be undertaken to compensate for the impact. 
6.6. The proposal is clearly contrary to the development plan as it relates to trees and
woodland where Ancient Woodland has been removed to accommodate this development
site. If the development is approved, a programme of tree planting should be submitted
to include species which must be native and appropriate to the locality of the area and
sourced locally, location, age, timing of planting and a schedule of monitoring and
maintenance until such a time as the trees become established. 
6.7. Both previous permissions contain conditions restricting the removal of trees from the site
in order to preserve the amenity that they provide in screening the site. No trees or bushes
are to be removed without the prior consent of the planning authority, which means that
these works constitute a breach of conditions as well as being contrary to the development
plan. This is however it a minor breach given the owner is willing to provide replacement
tree planting, in native species which will mitigate the loss and indeed further enhance the
woodland, that was previous choked with invasive rhododendron, via long-term
management of the invasives. 
7. Historic Environment 
7.1 The caravans are positioned at the entrance of what was the Auchengower Lodge
House which is a Category B Listed Building. The Listing states “Later 19th century.
Single storey, L-plan, gabled Gothic lodge with Jacobean Baronial details en suite with
villa of Auchengower. Whinstone and sandstone rubble, polished sandstone dressings
and margins; chamfered reveals, lintel band with chip-carved floral details. Base course;
quoins; eaves band. Projecting eaves supported on paired timber consoles at corners.” 
7.2 The caravans are approximately 70m to the north of the Lodge and therefore the setting
of the Lodge House needs to be considered. 
7.3 NPF4 Policy 7 (Historic assets and places) generally seeks to protect and enhance the
historic environment, assets and places, and to enable positive change as a catalyst for
the regeneration of places. NPF4 Policy 7(c) requires that development proposals affecting
the setting of a listed building preserve its character, and its special architectural or historic
interest. LDP2 Policy 16 (Listed Buildings) add to this that that development must be of
the highest quality, and respect the original structure in terms of setting, scale, design,
materials and proposed use.

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7.4 Historic Environment Scotland do not advise on matters relating to category B or C listed
properties. 
7.5 It is considered that the proposed development, by reason of siting, scale, form and style
will have an adverse impact on character of the listed lodge house in accordance with NPF
4 Policy 7, LDP2 Policy 16 and relevant HES guidance on development impact on historic
assets, but it must be noted that the site was previously a storage area (albeit constructed
without planning permission) and was unsightly. Therefore this is considered to be a minor
departure from the development plan. 
8. Road Network, Parking and Associated Transport Matters. 
8.1. The proposal does not provide an intensification of use, and so access does not materially
differ from previous to the development. As mentioned previously, there are existing
public transport networks that serve the park; and while the LPP states active travel links
need improvement, they are in place. The parking provision is sufficient for the caravans,
and there has been enough space provided for one car between each caravan as per the
fire safety guidance (2022). 
8.2. As the roads authority has no objections to the proposal, access and parking is consistent
with requirements. 
9. Infrastructure, flood and water management 
9.1. NPF4 Policy 22 – Flood Risk and Water Management seeks to strengthen resilience to
flood risk and to ensure that water resources are used efficiently and sustainably. While
some contributors mention concern about the potential for flooding on the B833, the site
is not within a future flood likelihood area, or a drainage consultation area. This site is
within Scottish Water Mains Supply. 
9.2. The proposal therefore aligns with NPF4 Policy 22 and LDP2 Policy 55 – Flooding. 
10. Contaminated Land 
10.1 The source of the material to construct the storage area where the caravans are now
sited, is unknown.  There may have been risk of contaminants but the engineering works
to create the platform is not part of this planning application. 
11. Other Material considerations 
11.1. The Local Place Plan (LPP) produced by Cove and Kilcreggan Community Council,
accords with NPF4 and LDP2 requirements by: showing how the community has been
engaged and involved in the plan; it has been informed by place based assessments;
spatial maps clearly show development and improvement proposals; and, an outline
delivery strategy is included, meaning that it can be considered in this application as a
material consideration. 
11.2. The Local Place Plan (LPP) requires that all new developments show a commitment
to sustainability while preserving the area’s unique heritage. Protecting and building on
the Victorian heritage of the village, any new development should fit in and reflect this. It
is accepted that the site is on a prominent approach to the village, but once the new
landscaping is established this will preserve the character and heritage of the village.

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11.3. Environmental protection is identified as a core tenant of the LPP, it is the second
theme addressed by the plan. The repositioning of three caravans and their associated
decking is not considered to be a significant detriment to the nature or climate crisis in
itself. Depleted biodiversity in the area is a key challenge addressed under this theme
however, and as mentioned above, the full extent of biodiversity impact of the
development is difficult to assess when the development is retrospective. The biodiversity
requirements set out in the LPP include: the planting of native species and wildflowers,
as well as providing wildlife habitat. A community initiative detailed in the plan identifies
the coastal foreshore (including this site in the caravan park) as key for providing better
access, whilst maintaining and managing habitats for wildlife. The applicant has submitted
a draft landscape scheme which includes details of the new native planting and also
rhododendron clearance in line with this aspiration. 
11.4. The Cove and Kilcreggan Community Council whilst they offer objection, it relates to
the owner undertaking the works retrospectively, rather than in principle or in relation to
the harm caused. Indeed the Community Council have suggested suitable mitigation.
They request that in the event of the application being given permission that “significant
amelioration of the current site to reduce the visual impact of this development”, including
vegetation management, appropriate colour schemes for the fencing and resolving any
potential drainage issues which could cause flooding on the B833. They also state that in
the event enforcement action requires the removal and replacement of the caravans to
elsewhere in the park, that this is done at the expense of the owner and not the residents.