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Planning Appeal Statement of Case

‘Bankhead’, Balerno, Edinburgh

(Land 30m west of 60 Glenbrook Road, Balerno, Edinburgh)

Change of use from derelict farm steading to erection of 6 no. glamping pods and associated works

including concrete bases, footpaths, refurbished barn and landscaping (as amended)

Planning Application Ref. 19/01963/FUL

On behalf of

Mr Simon Thomson

December 2019

Clarendon Planning and Development Ltd

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1 INTRODUCTION 3

2 REASONS FOR REFUSAL 4 3 GROUNDS OF APPEAL – SUMMARY OF THE APPELLANT'S CASE 5

4 BACKGROUND TO THE APPLICATION 6

4.1 Location and Site Description 6

4.2 The Development Proposal 6

4.3 Planning History 6

4.4 Consultation Responses and Representations 6

5 DEVELOPMENT PLAN COMPLIANCE 8

5.1 Development Plan 8

5.2 Development Plan Assessment – SESplan 8

5.3 Development Plan Assessment – Edinburgh Local Development Plan 8

6 MATERIAL CONSIDERATIONS 18

6.1 Scottish Planning Policy 18

6.2 National Planning Framework 3 18

6.3 Tourism Development Framework for Scotland 18

6.4 VisitScotland & Edinburgh Tourism Action Group Support 18

6 CONCLUSION 19

7 APPROPRIATE PROCEDURE 20

List of Documents submitted on behalf of the Appellants 21

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1. INTRODUCTION

1.1 This Statement supports an appeal by Mr Simon Thomson (“the Appellant”), in terms of section 47 of the Town and Country Planning (Scotland) Act 1997. The appeal is against the refusal by City of Edinburgh Council (the “Council”) of the application for Detailed Planning Permission, ref.19/01963/FUL (the “Application”) relating to a change of use from derelict farm steading to erection of 6 No. glamping pods and associated works.

1.2 The Application was registered by the Council on 17th May 2019 with the statutory determination period ending on 16th July 2019, which was subsequently extended to 2nd August 2019 for additional information to be provided in response to case officer comments received on the final day of statutory determination. The Application was refused by the Council at Development Management Sub-Committee on 20th November 2019 (without debate) with a decision notice issued on 22nd November 2019.

1.3 This Statement contains details of the Appellant’s grounds of appeal and the matters which they consider require to be taken into account in determining this Appeal.

1.4 The Statement should be read in conjunction with the documents detailed in the Document List on Pages 21-22 which form part of the Appellant’s case and supporting evidence, addressing or expanding upon matters in this Statement.

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2. REASONS FOR REFUSAL

2.1 The Council’s reasons for refusal are set out in its Decision Notice (DOC24), issued on 22nd November 2019. They can be summarised as follows:-

a) Perceived impact on the rural character and appearance of the surrounding area and the special character of the Pentland Hills Special Landscape Area (Refusal Reasons No.1 & 2).

b) Perceived impact upon the living conditions of neighbouring residents (Refusal Reason No.3).

2.2 We address these and the Appellant’s justification for stating there are no good reasons to refuse planning permission in this Statement.

2.3 The Council’s Decision Notice also sets out that the Application is an acceptable green belt use in principle and it complies with the Planning (Listed Building and Conservation Areas) Scotland Act 1997 as it preserves the setting of the adjacent listed building. The Case Officer’s Report to Committee (DOC23) expands further upon the Application and this is addressed further below.

2.4 The Appellant does not consider the reasons for refusal to be supported by an accurate application of the policy framework and considers that planning permission should be granted.

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3. GROUNDS OF APPEAL – SUMMARY OF THE APPELLANT'S CASE

3.1 It is considered that planning permission should be granted and the Appellant appeals on the following grounds:-

3.2 Having regard to the Development Plan and to material considerations as specified in this Appeal, planning permission should be granted in accordance with section 25 of the 1997 Act.

3.3 The application is Development Plan compliant when assessed against policy and supplementary guidance for development in the Green Belt. The Countryside Recreation principle of development is agreed as acceptable by the Council and the Application proposal provides appropriate structures and site features for this type of use as tourist accommodation, including the re-utilisation of key site features including a rural building.

3.4 The impact on both the rural qualities of the surrounding area and the wider Special Landscape Area designation is insignificant and is further minimised by proposed mitigation measures.

3.5 The proposed management plan is a suitable mechanism by which to control the use of the site by occupiers of the tourist accommodation and the local nature of the proposed employees ensures monitoring will be constant and action immediate as required.

3.6 The proposal is supported by key material considerations in terms of its provision of tourist accommodation as a contribution to Edinburgh’s strong and growing demand. The net economic benefits of the proposal are supported by national planning policy as is the re-use of a derelict site for tourism/employment generating use. Tourism strategies and agency advice for Edinburgh all support the type and form of accommodation being proposed.

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4. BACKGROUND TO THE APPLICATION

4.1 Location and Site Description

4.1.1 The Application subjects comprise of an area of hardstanding, a derelict barn building, sheep pen and scrub land extending to 0.26 hectare on the western edge of the suburb of Balerno, approximately 7 miles south-west of Edinburgh City Centre.

4.1.2 The Application boundaries are formed by Glenbrook Road to the south (from where access is taken), fencing to north/west (with agricultural land beyond), mature trees to the north-east and a residential steading conversion previously completed by the Appellant to the south-east.

4.1.3 The site location and description are more fully described (including site photographs) within Pages 3-5 of the Application Planning Supporting Statement (DOC4).

4.2 The Development Proposal

4.2.1 The application is for Detailed Planning Permission for tourist accommodation, comprising 6 No. glamping pods with associated works including concrete bases, footpaths, a refurbished barn and landscaping.

4.2.2 The proposal is to upgrade a currently derelict site through minimal physical changes, which would provide for retention of all site boundary trees, use of the existing vehicular access and refurbishment of the existing barn for parking purposes. A new landscaped bund would be created between the six proposed timber pod buildings (accessed by a single new footpath) and the existing residential conversion to the south-east. The proposals are more fully described on Page 6 of DOC4 but essentially seek to retain the semi-rural character of the location through suitable design and landscaping whilst improving visual amenity. The proposals are illustrated within the amended site layout (DOC13), materials examples (DOC8), pod manufacturers drawings (DOC9) and proposed drainage layout (DOC10). The amended layout addressed concerns raised by the Case Officer to the original site layout (DOC7) by repositioning the pods further away from the existing residential conversion and introducing the stronger landscape bund proposal as opposed to simple planting measures. Additionally, a statement outlining how the site is to be managed was submitted (DOC14) to further support the proposal.

4.3 Planning History

4.3.1 The Application site was the subject of a previous planning application for five residential units in 2017 which was refused by City of Edinburgh Council in 2018. This is more fully detailed within Sections 1.6 to 1.8 of DOC4.

4.4 Consultation Responses and Representations

4.4.1 In terms of statutory consultees, the Appellant notes and accepts responses (and associated proposed conditions) from the Council in relation to Archaeology and Roads. Similarly, the Appellant notes and accepts responses and associated conditions from external consultees, namely SEPA and Scottish Water and notes there is no objection or condition requirement from Edinburgh Airport.

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4.4.2 The response received from Balerno Community Council is addressed more fully below in terms of points (ii) Special Landscape Area and (iii - part) neighbouring amenity. However, it is noted that the Council disagrees with the Community Council’s interpretation of Green Belt policy in terms of their point (i), impact on setting of Listed buildings in point (iii-part) and traffic impact in point (v). Further, the application is not for housing as outlined in point (iv) as the pods would not be occupied on a permanent basis.

4.4.3 The response received from the Council’s Environmental Protection Officer is addressed further below in terms of impact on neighbouring amenity.

4.4.4 The consultation responses are contained within DOC15-22.

4.4.5 In terms of third-party representation, there were 75 material comments of support and 84 objection comments. These have been summarised within the Case Officer’s report (DOC23) and, where relevant to the refusal reasons, are addressed further below. It should be noted that supporting comments from the local community included employment creation and visual improvement of the site.

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5. DEVELOPMENT PLAN ASSESSMENT

5.1.1 Section 25 of the Town and Country Planning (Scotland) Act 1997 requires that, in making any determination under the Planning Acts, regard is to be had to the development plan and determination shall be made in accordance with the plan unless material considerations indicate otherwise.

5.1.2 The existing Development Plan relevant to this Appeal Site comprises the South East Scotland Strategic Development Plan (‘SESplan’) (approved 2013) (DOC27) along with the Edinburgh Local Development Plan (“LDP”) (DOC28) (adopted 2016).

5.1.3 A Proposed SESplan ‘2’ was rejected by Scottish Ministers in May 2019 and therefore the whilst the 2013-approved plan is out of date with respect to housing targets it remains relevant in terms of general strategic policy at the current time. Edinburgh are set to review their Local Development Plan with publication of a Main Issues Report in early 2020.

5.2 SESplan

5.2.1 SESplan has relevance to the Application only with regard to the purpose of Green Belts and, in particular, maintaining landscape setting.

5.2.2 Approved SESplan Policy 12 defines the objective of the Green Belt, which is to:

a) Maintain the identity and character of Edinburgh and Dunfermline and their neighbouring towns, and prevent coalescence, unless otherwise justified by the Local Development Plan settlement strategy;

b) Direct planned growth to the most appropriate locations and support regeneration;

c) Maintain the landscape setting of these settlements; and

d) Provide opportunities for access to open space and the countryside.

5.2.3 The Council have assessed the proposal as an “acceptable green belt use in principle” (DOC24) but have deemed that the proposal would have an adverse impact on the rural character of the surrounding area and the special character of the Pentlands Special Landscape Area. The impact of the proposal on the landscape is more fully considered below but when assessing the proposal against SESplan Green Belt policy the proposal does not impact on stated objectives. In particular, a) there would be no loss of identity or character of Edinburgh’s setting, b) the proposal would regenerate a brownfield site in the Green Belt, c) the landscape setting of Edinburgh would not be affected, and, d) the proposal would provide open space within a managed environment.

5.3 Edinburgh Local Development Plan

5.3.1 As noted above, the principle of development has been accepted by the Council under Policy Env 10 – Development in the Green Belt and Countryside (part a), being for the purposes of countryside recreation. Therefore, assessment must address detailed local planning policy with respect to the two broad reasons for refusal.

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Perceived impact on rural character and appearance of the surrounding area and the special character of the Pentland Hills Special Landscape Area (Refusal Reasons No. 1 & 2)

5.3.2 LDP Policy Env 10 states that development in the Green Belt will only be permitted where it meets one of the specified criteria (including countryside recreation which the proposal comprises and is deemed acceptable in principle as noted above) and “would not detract from the landscape quality and/or rural character of the area” and “provided any buildings, structures or hard standing areas are of a scale and quality of design appropriate to the use”.

5.3.3 Addressing the last point first, the proposal re-utilises an existing building (barn refurbished as covered parking) and existing hardstanding (for vehicular access). The new elements comprise a footpath (granite sett material) and six concrete bases with timber pod units (hexagonal shape of 5m diameter, overall length of 7.1m and ridge height of 3.9m) each of just 23m2 with tongue and groove spruce timber wall and roof construction. The re-used and new structures and hard standing areas are wholly appropriate for the proposed countryside recreation use (deemed acceptable in principle) in terms of scale and design quality.

5.3.4 With regard to the proposal impact on rural character and appearance of the surrounding area, attention is drawn to the Council’s ‘Guidance for Development in the Countryside and Green Belt’ (“Guidance”, updated February 2019 – DOC29). As stated on Page 2 of the Guidance, “new development can bring a number of benefits – assisting farm diversification, supporting the local economy and making beneficial use of an existing resource” with the key test for proposals being to ensure that the development does not detract from landscape quality or rural character. As an accepted Countryside Recreation use (defined as “uses where the proposal requires the land resource and is compatible with an agricultural or natural setting such as horse riding facilities, golf courses and golf driving ranges, touring caravan and campsites”) it must also be accepted that structures of some nature would be required to accommodate that use. The proposed timber units would have no greater presence than timber stable blocks, riding arenas, driving range structures, static caravans or campsite communal facility blocks. Indeed, it is argued that the structures would have significantly less of an impact given their limited footprint and integration within existing site features (barn, hardstanding, boundary trees).

5.3.5 On the basis that a Countryside Recreation use must accommodate certain structures and that this type of use is by nature, within a rural or semi-rural area, the impact of the proposal on the rural character of the location cannot be deemed to be significant.

5.3.6 Page 10 of the Guidance states that, “existing landscape features should be protected and the impact of obtrusive suburban clutter associated with the development such as roads, lamp posts, pavements, car parks and boundary features should be minimised”. The proposal retains all boundary tree and landscape cover with physical change limited to the bases/pods and footpath. The amenity open space to the west of the pods will form maintained grassland and the specification of the landscaped bund can be determined/controlled via planning condition to provide appropriate planting species for the location. Vehicular access will utilise existing hardstanding and cars will be discretely located within the refurbished rural barn. Boundary treatments will remain as post and wire or timber fence along with existing landscaping. In this respect, the proposal wholly accords with the Guidance for proposals within the Countryside or Green Belt with specific materials/planting requirements capable of being controlled by planning condition.

5.3.7 In terms of impact on the surrounding area, the proposed pods would be partially obscured from the western approach along Glenbrook Road by existing tree

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cover. However, the remaining partial view of the proposed pods from this direction would not detract from the rural setting given the points noted above and the acceptance that rural structures are appropriate for rural locations.

5.3.8 Figures 1-4 below provided a sequential view along Glenbrook Road from the west towards the Application site (expanding upon images provided in Pages 4-5 of Application DOC4).

Figure 1 – site not visible from road c.300m to west (manager’s house has views)

Figure 2 – barn partially visible but site mainly obscured by trees

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Figure 3 – site remains partially obscured by trees, new pods sit below barn height

Figure 4 – close up view, pods backdrop would be barn and trees to rear

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5.3.9 The road user views from the south/south-east would be obscured by both existing tree cover and the proposed landscape bund. The positioning of the bund allows for green ‘breathing space’ between the residential steading conversion and the pods. Indeed, planting along the landscape bund could ensure that the majority of the pods are screened from view.

5.3.10 Figures 5-8 below provided a sequential view north up Glenbrook Road from the south-east towards the Application site (expanding upon images provided in Pages 4-5 of Application DOC4).

Figure 5 – part of existing barn visible with pods site screened by existing trees

Figure 6 – from Coach House entrance, part of barn visible, pods site screened by existing trees

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Figure 7 – from Bankhead Steading entrance, barn visible, pods site partially obscured by mature tree

Figure 8 – from corner of site, site partially obscured by mature trees, steading conversion to east will be screened from pods site by proposed landscape bund

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5.3.11 The Case Officer considers in his report (DOC23) that the proposal would impact on the rural character of the area but it is this very reason the proposed Countryside Recreation use is considered a suitable use of this site. The current derelict nature of the site does not contribute to the character of the locality and is indeed a potential threat to the rural character in terms of fly-tipping and illegal occupation. The proposed use would bring the site back into use with a safe and managed environment while still retaining the existing site features that act as a transition between countryside and the built development around Bankhead.

5.3.12 Overall, in terms of impact on appearance of the surrounding area, it is considered there would be, contrary to the Case Officer’s opinion, an insignificant impact on local views (the only direct neighbouring views being from 58&60 Bankhead Steading to the east of the site which are to be screened by the proposed landscape bund). The overall impact would be a positive net impact given the derelict nature of the site as it stands and the rural character of the location would be maintained. Policy Env 10 and associated Guidance for Development in the Countryside and Green Belt could be positively addressed.

5.3.13 LDP Policy Env 11 states that development will not be granted which would have a significant adverse impact on the special character or qualities of the Special Landscape Areas shown on the Proposals Map, which includes the Pentlands Special Landscape Area (“SLA”), which covers an extensive area between the Edinburgh City Bypass and Pentland Hills and includes all land bounding the A70 (Juniper Green/Currie/Balerno) corridor as illustrated on Figure 9 below (site marked in red).

Figure 9 – Pentland Hills Special Landscape Area – site marked in red

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5.3.14 A Statement of Importance for this Special Landscape Area is included within the ‘Review of Local Landscape Designations’, prepared by Land Use Consultants for City of Edinburgh Council in January 2010 (DOC30). The report is almost ten years old now but provides an overview of the importance of each SLA and can be assessed in relation to the Application site.

5.3.15 The statement notes the main characteristics of the Pentland Hills SLA as being the role it plays as a backdrop to Edinburgh, providing an identifiable setting to the city and settlement corridor of Juniper Green, Currie and Balerno. The landscape in the western part of the SLA is stated as being characterised by 18th and 19th century fields enclosed by drystone dykes, hedgerows, tree lines and shelterbelt planting. The Application site itself does not contribute to the backdrop setting of Edinburgh given its natural containment and the proposal does not impact upon the defined landscape pattern.

5.3.16 The SLA includes a number of defined Landscape Character Areas (“LCA”) as defined and categorised by the Edinburgh Landscape Character Assessment (2010) as outlined in DOC30. The site is located within the Cockburn Geometric Wooded Farmland LCA (No.36) which is characterised by regular field layout demarcated by shelterbelt planting. The woodland belts are stated as providing an inward-looking landscape with views into and outside of the character area restricted by mature trees. The scenic quality is of gently sloping arable land and pasture farmland with strong shelterbelt patterns overlaying landform which creates enclosure and restricts views. The fundamental characteristics of this LCA would not be compromised by the proposal.

5.3.17 The development proposal makes minimal physical changes to the Application site, which would retain its existing boundaries (trees, agricultural style fencing) and main feature (barn).

5.3.18 Based on the SLA Statement of Importance and associated LCA qualities, contrary to the Case Officer opinion, the proposal would have an insignificant impact on the Pentlands Hills SLA. None of the stated qualities of the SLA or LCA would be compromised with limited inter-visibility between the site and surrounding area.

5.3.19 Balerno Community Council consider that the proposal would “introduce a different style of building and a different style and volume of activity”. The proposal would indeed bring a different style of building but a rural style to suit its location. The perceived impact is considered further below but it is not the purpose of a Special Landscape Area to restrict types of users of that space.

5.3.20 Overall, in terms of impact on the SLA, the Application site does not contribute to the wider qualities of the designation in terms of a landscape backdrop to Edinburgh and the proposal does not compromise the clear shelterbelt landscape pattern qualities. Indeed, these qualities assist with integrating the proposed pods as visibility for road uses from west and south is limited as illustrated above. The scale, nature and location of the proposal would have an insignificant impact on the SLA designation. Policy Env 11 states that development must have a ‘significant’ impact on the special character or qualities of the SLA to not be supported. This is clearly not the case with the Application.

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Perceived impact upon the living conditions of neighbouring residents (Refusal Reason No. 3)

5.3.21 LDP Policy Hou 7 states that development, including changes of use, which have a materially detrimental effect on the living conditions of nearby residents will not be permitted. LDP Paragraph 234 which underpins this policy states:

“the intention of the policy is firstly, to preclude the introduction or intensification of non-residential uses incompatible with predominantly residential areas and secondly, to prevent any further deterioration in living conditions in more mixed use areas which nevertheless have important residential functions. This policy will be used to assess proposals for the conversion of a house or flat to a House in Multiple Occupation (i.e. for five or more people). Further advice is set out in Council guidance”.

5.3.22 The purpose of this policy is therefore clearly aimed at addressing two specific issues; intensification of non-residential uses in residential areas and houses of multiple occupation (HMO’s) in more mixed-use areas. The application of this policy to the proposal at Bankhead is considered inappropriate in this respect.

5.3.23 Notwithstanding this mis-applied policy protection, amenity concerns in relation to the proposed tourist use have been raised by both the Council and Balerno Community Council. The Council’s Environmental Protection officer stated in his consultation response (DOC18) that the principal concern is in relation to noise from users of the pods in evening/night periods. The officer considers that this type of use “encourages users to sit outside and will invariably mean noise from talking, laughing etc”. It is suggested that, weather-permitting, there is a high potential for this type of activity also in the adjoining steading conversion gardens and, indeed, most mainstream residential properties. Whilst a noise assessment has not been provided with the Application, advice from a specialist consultant was undertaken during the application process which confirmed that determining a worst-case scenario for noise impact of users of tourist accommodation is very difficult to define. The uncertainties over what methodology should apply whether it be peak noise levels compared to background or WHO sleep disturbance criteria at nearest receptors are deemed too high to provide an accurate assessment. As such, the specialist advice (whilst not submitted as so) was that a suitable management plan is the most practical approach to managing this issue.

5.3.24 As noted by the Environmental Protection Officer, the amended site layout (DOC13) provides for the pods being located further west within the site away from existing properties whilst also being separated by a landscaped bund. The purpose of this bund is more visual screening for the benefit of the steading conversion properties albeit it would likely have some level of noise mitigation.

5.3.25 The management statement provided with the Application (DOC14) outlines that the proposed manager of the pods resides less than 300m from the site and is therefore in close contact to deal with any perceived nuisance. This is further backed-up by the proposed part-time employees (housekeeping, maintenance) living in close proximity and the Appellant himself resides at nearby Cockburnhill Road.

5.3.26 The Environmental Protection Officer does not consider this sufficient, but it is a process that is in place for the majority of tourist accommodation across Edinburgh, the high proportion of which are located in close proximity to permanent homes. The risk of nuisance is directly related to the capable management of accommodation and in this case, the Appellant has put in place a practical and proportionate management plan with local employees to monitor the use of the site.

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5.3.27 As noted in the Case Officer’s report (DOC23), the proposed pods are all located over 18m from existing residential properties and there will be no amenity impacts in terms of daylight, overshadowing or privacy in terms of window to window views.

5.3.1 Overall, it is considered that any amenity concerns in terms of noise and nuisance can be addressed by the proposed management plan as with any other tourist/visitor accommodation within Edinburgh. As such, it is considered that there is no contravention of Policy Hou 7 on amenity grounds.

Supporting LDP Policies

5.3.2 In terms of supporting LDP policies, the proposal can also be assessed positively as per the following:

Design (Policies Des 1, Des 3, Des 4, Des 5, Des 7)

5.3.3 The Application Planning Statement (DOC4) and supporting plans fully detail the proposal and how the design addresses design quality, incorporating existing features, site setting and site layout design. It is noted that design policy is not put forward as a reason for refusal.

Environment (Policies Env 3, Env 10, Env 11, Env 12)

5.3.4 Policies Env 10 and 11 are addressed above in relation to Green Belt and Special Landscape Area. Additionally:

• The Council do not consider there to be impact upon B-listed Bankhead House given distance to the site and lack of inter-visibility and the proposal complies with Policy Env 3.

• No existing trees are to be removed to enable the proposal, which complies with Policy Env 12.

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6. MATERIAL CONSIDERATIONS

6.1 Scottish Planning Policy (“SPP”)

6.1.1 SPP (DOC26) states a “presumption in favour of development that contributes to sustainable development” (SPP p.9). In particular, Paragraph 29 states that decision should be guided by a number of key principles. The proposal should be supported as sustainable development in terms of creating employment (net economic benefit), responding to economic issues (providing additional tourism accommodation for Edinburgh), supporting good design (limited physical change of site to enable development) and making efficient use of resources (bringing a derelict site back to life). There is no adverse impact on any wider SPP policies.

6.2 National Planning Framework 3 (“NPF3”)

6.2.1 NPF3 (DOC25) sets out the priorities for Scotland’s planning system and its delivery and highlights key issues for regions including Edinburgh and South East Scotland. As stated on Page 12 of NPF3, “Edinburgh is one of Europe’s most important centres for financial services and tourism, and the world’s foremost festival city”. The provision of sufficient range and type of tourist accommodation is therefore of prime importance to Edinburgh’s economy.

6.3 Tourist Development Framework for Scotland 2016

6.3.1 The Tourism Development Framework for Scotland (DOC31) was prepared to assist and promote growth of Scotland’s visitor economy to 2020. Paragraph 2.4.3 notes that an analysis of the VisitScotland 2015 Visitor Survey highlighted that there was a need to invest in new accommodation provision across the whole range of accommodation types including in Edinburgh and rural areas. In particular, Paragraph 2.53 states, with respect to self-catering tourist accommodation in the countryside, that gaps were identified at the higher quality end of the market and planning authorities actions included encouragement of investment in new self-catering accommodation in rural areas including holiday home parks and more novel low carbon development. The proposal at Bankhead accords with this latter aim.

6.4 VisitScotland & Edinburgh Tourism Action Group Support

6.4.1 As outlined in DOC11 which supported the Application, VisitScotland and Edinburgh Tourism Action Group provided support for the type of accommodation proposed by the Application.

6.4.2 VisitScotland confirmed that there is a “very healthy market for the style of accommodation” being provided by the proposal.

6.4.3 Edinburgh Tourism Action Group noted that, “key to future success and maximising economic value of the tourism sector (in Edinburgh) is having a wide range/variety of accommodation types to service growing demand”.

6.4.4 The proposal provides for a type of accommodation that is lacking in Edinburgh, with the exception of Mortonhall camp site on the southern edge of the city which provides an element of ‘wigwam’ and ‘shepherd hut’ style accommodation. Whilst small in scale, the proposal at Bankhead will cater for Edinburgh’s continued tourism growth by providing a high quality, self-catering experience on the edge of the city, close to public transport but within a rural setting.

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7. CONCLUSION

7.1 The preceding Statement, in conjunction with the appended supporting documentation, sets out the case for planning permission to be granted at Bankhead.

7.2 The proposal will provide new tourist accommodation in the form of 6 glamping pods, making a contribution to Edinburgh’s tourist accommodation offering and providing a low-impact alternative to more mainstream options within the city. The proposal will provide local employment with three part-time positions to manage the pods, contributing to wider economic development aims. The development will re-use existing site features including a refurbished barn for parking, existing hardstanding area for access and retention of all boundary trees/landscaping. The development’s only new elements will comprise six concrete bases with timber pod buildings and a new granite sett footpath providing access.

7.3 In assessing the proposal against the Development Plan, it is considered that the application is compliant with the approved SESplan and the adopted Local Development Plan. The principle of the proposal is considered an acceptable Countryside Recreation use in the Edinburgh Green Belt by the Council. The proposal meets detailed policy provisions related to development within the Green Belt (SESplan Policy 12 and LDP Policy Env 10) and the Council’s Guidance for Development in the Countryside and Green Belt. The proposal will regenerate a brownfield site and not have an impact on Edinburgh’s landscape setting or identity. The proposal would re-use an existing rural structure whilst new timber pods are an appropriate building type for the proposed use, similar in impact to other countryside recreation uses. The proposal provides a low-impact, non-suburban development in accordance with guidance.

7.4 In terms of impact on the surrounding area, views into and outwith the Application site are restricted by its self-containment and existing tree cover along Glenbrook Road to both the west and south. The timber pods would only be clearly visible by road-users in close proximity and would be set against the backdrop of the existing barn and site boundary trees.

7.5 The proposal’s impact on the adjoining steading conversion is restricted to the immediate views of 58 & 60 Bankhead Steading. The proposal provides for a landscape bund to screen the majority of the pod buildings from this localised view whilst improving existing visual amenity overall through the re-use of a derelict, brownfield site.

7.6 The proposal would not have a significant adverse impact on the Pentland Hills Special Landscape Area in terms of LDP Policy Env 11. When assessing the proposal against detailed landscape qualities outlined in the SLA Statement of Importance and associated Landscape Character Area definition, there would be no loss or detriment to this designation, given the scale and nature of the proposal.

7.7 With regard to amenity impact on neighbouring residents, the proposed site layout was amended during the Application process to provide a greater distance between the proposed pods and the existing steading conversion, whilst a landscape bund was introduced to act as a partial screen and can assist with noise mitigation. The Council noted that the proposal caused no daylight, overshadowing or privacy concerns. A management plan has been proposed to ensure any perceived threat of noise or nuisance can be addressed directly and locally. A managed approach to protecting existing residential amenity is common throughout tourist accommodation in Edinburgh.

7.8 The proposal accords with wider LDP policy on design and environment protection and material considerations include Scottish Planning Policy’s presumption in favour of development that contributes to sustainable development with particular regard to net economic benefit (local employment creation) and support for increased range and type of tourist accommodation by the National Planning Framework 3, Tourist Development Framework for Scotland, Visit Scotland and Edinburgh Tourism Action Group.

7.9 It is thereby respectfully requested that having regard to the Development Plan and all material considerations this appeal be upheld and Detailed Planning Permission be granted for the Application with requisite conditions as may be deemed appropriate.

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8. APPROPRIATE PROCEDURE

8.1 The Appellant considers that a site visit would assist the Reporter in determining the site’s suitability for the proposal.

8.2 However, given the final decision on procedure is with the appointed Reporter, the chosen method will of course be respectfully accepted.

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List of Documents submitted on behalf of the Appellant

Reference Title Format

Planning Appeal

Planning Appeal Form Uploaded

DOC1 Appeal Cover Letter Uploaded

DOC2 Planning Appeal Statement of Case Uploaded

Planning Application Ref.19/01963/FUL

DOC3 Application Form

DOC4 Planning Statement

DOC5 Location Plan

DOC6 Existing Site Layout

DOC7 Proposed Site Layout & Contextual Elevation

DOC8 Materials Examples

DOC9 Manufacturers Drawings & Specifications

DOC10 Drainage Plan

DOC11 Support for Tourism Proposal

Post-submission Documents to Application Ref. 17/04001/PPP

DOC12 Application Form – Post-submission Additional Documents

DOC13 Amended Site Layout

DOC14 Management Statement

Consultation Responses

DOC15 Balerno Community Council

DOC16 CEC Archaeology

DOC17 CEC Flood Prevention

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DOC18 CEC Environmental Protection

DOC19 CEC Roads

DOC20 Scottish Water

DOC21 SEPA

DOC22 Edinburgh Airport

Application Determination

DOC23 CEC Case Officer Report to Committee

DOC24 CEC Decision Notice

Policy Documents & Guidance

DOC25 National Planning Framework 3 (2014)

DOC26 Scottish Planning Policy (2014)

DOC27 SESplan (2013)

DOC28 Edinburgh Local Development Plan (2016)

DOC29 Edinburgh Guidance for Development in Countryside and Green

Belt

DOC30 Review of Local Landscape Designations 2010

Other Material Considerations

DOC31 Tourism Development Framework for Scotland 2016