To:
Jane Brooks-Burnett
Senior Planning Officer
Claire Milne
Principal Planning Officer
From:
cc:
Jay Dawson, Principal Planning Officer
Tel:
01786 233685
Your Ref: 14/00455/PPP
Date:
6 July 2015
Planning & Policy
Consultation
14/00455/PPP - Land at Park Of Keir, Dunblane [Amended]
Proposed development of new tennis and golf centre, including museum and visitor centre,
indoor and outdoor tennis courts, golf course with clubhouse and practice areas, hotel with
leisure and conference facilities, multi-user sports pitch and outdoor play area, cycle trails and
footpaths, new access roads and junction, new tree planting and landscaping, SUDS pond and
associated drainage works, car parking and servicing, and enabling housing development.
1.0
Introduction
1.1
This application for planning permission in principle was submitted in July 2014 and was
previously responded to in August 2014. A further consultation has been issued because
amended plans have been submitted.
1.2
The amended plans are supported by the following documentation: 
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

Design and Access Statement, June 2015
Outline Drainage Strategy, June 2015
Environmental Statement Addendum, May 2015
Outline Business Case (confidential), May 2015
2.0
Latest Proposals
2.1
The previous submission put forward a total 100 new residential units across 19
hectares (ha). The latest submission amends this to 19 residential units across
approximately 11 ha, with the proposed location for housing now taking place in the
southern residential area and not to the north and south as previously proposed. The
Design and Access Statement confirms the following revisions to the housing proposals:

An 80% reduction in the overall number following feedback from the initial
consultation to address concerns over the extent and location.

Housing land area reduced by 84% & substituted with additional community
parkland.

70% more new woodland planting.

41% more country parkland.
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2.2

Very low density rural housing proposed.

Debenture membership funding to create permanent direct link between housing
and the sports facilities.
The applicant is keen to highlight the relative proportions of the overall site now
proposed for built development (housing, sports facilities, hotel), the golf course and
outdoor courts (recreational space combined), and other accessible open space. These
are broken down as follows:



Built development – 15 ha
Recreational space combined - 26.23 ha
Accessible open space – 55.8 ha
2.3
The remaining 8.52 ha of the overall site area of 105.69 ha is for the planting of new
woodland. A new Country Park is proposed at 53.3 ha. The latest proposals however still
result in a substantial area (10% of the whole site area compared with the previous 18%)
taken out of the countryside for housing development purposes.
3.0
Stirling Development Plan (LDP)
3.1
The current development plan comprises of the Stirling Local Development Plan 2014.
As previously highlighted the following main policies are relevant to the assessment of
this proposal: 

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Policy 2.9- Economic Development in the Countryside
Policy 2.10 - Housing Development in the Countryside
Policy 1.5 - Green Belts
Primary Policy 15 - Tourism and Recreational Development
Policy 9.1 – Protecting Special Landscapes
Primary Policy 8 – Conservation and Enhancement of Biodiversity.
3.2
It is not proposed to repeat the previous policy assessment. In summary, the
proposed main land uses comprising of housing, hotel, tennis and golf centre, museum
and visitor centre, would continue to be contrary to local and national policy on
development in the Countryside and Green Belts, and should not be supported unless
there is considered to be an overriding national requirement or established need for the
development that could not be satisfied elsewhere.
4.0
Housing Proposals
4.1
It is clear from the revised Design and Access Statement that the housing development
has been introduced to help cross-subsidise the investment in the tennis and golf
facilities. It is argued that if these facilities are built “debt free”, this will ensure the
affordability and access charges for use of the sports facilities are as low as possible.
4.2
Although an updated Planning Statement has not been submitted, in terms of the above
context it is assumed that the applicant is no longer continuing to promote the site as
meeting any shortfall in the 5-year effective housing land supply. In any case, I maintain
the view as previously expressed, that the type of housing proposed is unlikely to be
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affordable in the local context and provides no scope for those on lower and middle
incomes to access new housing. The development would make no contribution to the
area’s housing need and demand as evidenced in the Housing Need and Demand
Assessment 2011. Given that the latest proposals for housing are below the 20 unit
threshold for seeking on-site affordable housing, an appropriate financial contribution
would be expected consistent with Policy 2.2.
4.3
In relation to SPP’s presumption in favour of development that contributes to sustainable
development. When assessed against the guiding principles for sustainable
development in paragraph 29, the proposed development is rural in nature and will
require residents to travel for all their basic amenities and services, contrary to local and
national policy and sustainable development principles. The proposal will continue to
place significant demands on existing infrastructure, local services and amenities and
require the provision of new infrastructure. The proposal will also have a detrimental
impact on a sensitive landscape and cultural heritage features, although this might be
managed through appropriate mitigation.
4.4
The Design and Access Statement no longer includes a ‘sketch layout’ of the proposed
housing but presents a ‘sketch plot layout’ instead, covering two separate housing areas
previously described as the ‘southern area’. The housing is described as “low density”
with the design of the residential units indicated as “of very high quality, comprising
individually bespoke house designs”. The previous Design Statement referred to
“buildings located in a way which reflects the pattern of settlement nearby Dunblane and
Bridge of Allan”. The current proposals make no such claim and the houses are put
forward with the intention of promoting them as suitable for a countryside location.
4.5
Various references are made to the Council’s housing in the countryside Design Guide
(which supports Policy 2.10 Housing in the Countryside), and although I do not intend to
comment on any specific design matters at this point, they will be relevant for any
detailed application. However, the development of 19 detached houses in the
countryside, unrelated to the beneficial re-use of a brownfield site, an established
building group or cluster, or any infill situation, would not meet the criteria within Policy
2.10. Only exceptional reasons would justify any deviation from this policy.
4.6
The Statement further indicates that a “full Landscape and Visual Impact Assessment
has been carried to identify where these homes can be sympathetically located”. In the
previous submission a total of 40 housing units were proposed for the ‘southern area’
now being put forward for a total 19 units. A revised LVIA has not been submitted to
demonstrate the appropriate siting of housing in this latest scheme. Without this, the
landscape issues relating to the development site cannot be fully appreciated.
5.0
Outline Business Case
5.1
A revised outline business case has been submitted in confidence to the planning
authority. Both the LDP and SPP highlight the importance of giving due weight to net
economic benefit to justify development within rural locations. However a careful balance
must be made between the costs and benefits of development over the longer term to
ensure that the right development takes place in the right place, and not development at
any cost.
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5.2
As previously intimate, the approval of the whole development would need to be an
‘exceptional case’ under current planning policy, the circumstances of which require to
be properly understood and balanced accordingly. The wider economic benefits of the
proposal have been previously cited and remain worthy of further scrutiny. Whether the
housing is critical to the overall delivery of the capital components of the scheme
remains to be tested. Whether the development has to be delivered debt free is also to
be appraised, and there continues to be little information on how other income sources
such as museum, café, retail, gym etc, will contribute to the financial running of the
project.
6.0
Conclusions
6.1
As previously indicated, the planning authority is being asked to set aside its planning
policies on Countryside and Green Belt to approve a significant development that is
argued to be in both the local and national interest. The only physical parts of the
development that have changed are the overall number of houses proposed which are
now at a lower density. However, around 11 ha of the original 19 ha is still proposed to
be built upon for housing purposes, with its rural character permanently altered, and a
further 4 ha is to be taken up by the built sport and hotel facilities.
6.2
There remains considerable policy concerns over the level of proposed housing
development associated with the application, which it is stated is only included to assist
the financial viability of the development. My previous comments indicating that all
financial recipients of the proposed development should carry the burden of risk still
stands, and this should be taken into account in any fair assessment of the
environmental, economic and social benefits of the development.
6.3
As submitted, this latest proposal does not provide any additional justification or
convincing case that there is an overriding national need, established need or sitespecific need for the development that could not be satisfied elsewhere, and therefore
does not currently justify an exception to policies on development in the Countryside and
the Green Belt.
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