Donald Campbell
Development Control Manager
Falkirk Council
Abbotsford House
David’s Loan
FALKIRK
FK2 7YZ
Direct line: 0131-243 9522
Email: jmayhew@nts.org.uk
6 June 2006
DUNMORE PARK, FALKIRK
PROPOSED BUILDING PROJECT INCLUDING THE ERECTION OF 54 HOUSES
OBJECTION
I write in response to the planning application recently submitted for this site. The National Trust
for Scotland objects to this application, for the four principal reasons that:
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It is contrary to the Adopted Structure Plan
It is contrary to the Adopted Local Plan
It is contrary to policies in the Finalised Local Plan
It would seriously damage the Historic Garden and Designed Landscapes of Dunmore Park
and The Pineapple
This letter gives full details of our objections and sets out our interests in relation to this application.
Falkirk Structure Plan 2002
This development contradicts four policies in the Structure Plan:
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Policy ENV 1 – Countryside and Protected Areas
Policy ENV 5 – Built Environment and Heritage
Policy COM 4 – Rural Communities
Policy ECON 7 –Tourism
Policy ENV 1 states that there is a presumption against development in the countryside, particularly
in those protected areas named in Schedule ENV.1. Both Dunmore Park and The Pineapple are
named in this schedule, therefore the application should be refused.
Policy ENV 5 states that protected sites including Gardens and Designed Landscapes will be
protected and enhanced. This development has a clear adverse impact on both the Dunmore Park
and The Pineapple Gardens and Designed Landscapes and should therefore be refused.
Policy COM 4: within section 4.16 it is stated that open countryside outside of settlements will be
protected from inappropriate development. This site is outside a settlement and is inappropriate in
its damage to the historic environment so should therefore be refused.
Policy ECON 7 aims to promote new sustainable tourism, yet this development would have an
adverse impact on The Pineapple, one of the key iconic images and tourist attractions within the
Falkirk Council area.
Falkirk Rural Local Plan 1994
The development of this site would be contrary to the Adopted Falkirk Rural Local Plan 1994 in
three ways:
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It would contravene Policy Rural 1 on new development in the countryside
It would contravene Policy Rural 21 on historic gardens and designed landscapes
It is not allocated for housing
Policy Rural 1 creates a general presumption against new development in the countryside and
(Section 2) specifically states that although some small-scale housing development in former
country estates may be allowed this does not apply where the site is included in the Inventory of
Gardens and Designed Landscapes in Scotland. Dunmore Park is listed in the Inventory, therefore
this application should be refused.
Policy Rural 21 states that there is a general presumption against development that would adversely
affect gardens and designed landscapes listed in the Inventory. Both Dunmore Park and The
Pineapple are included in the Inventory and would be adversely affected; therefore the application
should be refused.
The site is not allocated for housing. Planning authorities are obliged to determine applications for
planning permission with regard to the provisions of the development plan unless any other material
considerations indicate otherwise, so this application should be refused.
Finalised Falkirk Local Plan 2006
Although this site is allocated for housing and tourism development within the Finalised Local Plan,
the scale and nature of the proposed development bears no relation to that suggested in the plan. In
addition the development contradicts the Local plan in four other areas.
Policy EQ18 – Historic Gardens and Designed Landscapes
Policy EQ 19 – Countryside
Policy SC 3 – Housing Development in the Countryside
Dunmore Village Statement
Policy EQ 18 contains a presumption against development which would adversely impact the
character and setting of sites listed in the Inventory of Gardens and Designed Landscapes. This
proposal would have an adverse impact on both of the only Inventory sites within Falkirk Council
area and should therefore be refused.
Policy EQ 19 restricts development outwith urban and village limits except for specific
circumstances. The proposed development does not match these circumstances and should
therefore be refused.
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Policy SC13 sets out the criteria that need to be matched to allow housing development in the
countryside. This proposal does not match these criteria so should therefore be refused.
Dunmore Park and The Pineapple Gardens and Designed Landscapes
The site proposed for development lies within the Dunmore Park Garden and Designed Landscape
(GDL) and forms the principal views from the Pineapple GDL. The Inventory entry for the GDLs
makes the following assessment of their significance:
Category
Work of Art
Historical
Architectural
Scenic
Nature Conservation
Horticultural
Dunmore Park
The Pineapple
Value
High
Some
Outstanding
Some
Nature Conservation
None
Value
Outstanding
Some
Outstanding
Little
Little
None
Although it is laudable that the protection of Dunmore Park House and the associated stables is
pursued, it is our strongly held view that the proposal for 54 houses in the open park at the heart of
the designed landscape is wrong. It would appear from the documentation that not enough weight
has been given to the importance of this open space and the critical views that flow in many
directions across it. The location and scale of the houses and the positioning of many of them on
Dunmore Hill suggests that there has not been enough understanding of the designed landscape as a
whole, with all the emphasis being placed on the immediate surrounds of Dunmore Park House and
the woodland.
The majority of the principal views to and from the House plus from The Pineapple and other
viewpoints within the landscape would be severely damaged. This is highlighted by the Historical
Landscape Appraisal which states that “The Pineapple is part of a walled garden and is very much
inward looking, with little in the way of planned views outward into the surrounding landscape”.
This is completely inaccurate, and the fact that this document contains such an error has to bring its
value into question. The views from The Pineapple are absolutely critical, as one of its critical
functions was as a gazebo or viewing platform with far-reaching views over the surrounding
countryside. The evidence for this lies not only in the design of the building itself but in the
construction of a ha-ha between The Pineapple and the field proposed for development, which
would only have been done if the view was regarded as being of importance. It is also evidenced in
historical documentation that a thorough landscape appraisal would have examined. The landscape
consultants did not approach the National Trust for Scotland, which is surprising given our
ownership of the Pineapple and our knowledge of the landscape in question.
The Trust’s Role
The protection of Scotland’s finest landscapes from inappropriate development is one of our
principal objectives. However, we have a particularly strong interest in this site, as we own The
Pineapple and value it highly as one of the most important garden buildings in the UK. It is a
unique structure of which we all should be very proud and protective. However, its importance is
not restricted to it being a superlative building, but rests also in its integral role as part of the much
wider and very important Dunmore Park Historic Landscape and they must be protected together.
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NPPG 18 Planning and The Historic Environment
As has been previously stated it is laudable that we should seek to protect Dunmore Park House and
the associated stable block, and we recognise that as part of this some enabling development may be
necessary. However, this proposal does not meet the standards required of such development.
NPPG 18 gives very clear guidance on this:
“Where a building is seriously at risk from neglect as a result of the inability of all concerned to stabilise
its decay or to find an appropriate new use then the planning authority should consider the merits of some
new development. The principal purpose of enabling development should be to rescue historic buildings
from imminent collapse or further decay. High quality, innovative new architecture and design may, in
certain locations, serve to enhance the character of the historic environment. The settings and interiors of
some buildings, however, have been designed and laid out to complement their form or function. These
locations are extremely sensitive to any amount of new development and will need to be safeguarded.
Enabling development should, in all cases, be regulated so that the funds raised from the sale of the
enabling development are successfully channelled into the conservation of the building or buildings to
which the enabling development relates. This is normally possible by means of a planning agreement.”
“Enabling development: This should be the minimum necessary to unlock the development potential of
buildings or sites and enable their restoration. It should be located and designed to have minimum impact
upon the architectural and historic interest, character and setting of the historic environment.”
There must be a solution that allows both the buildings and the landscape to have a sustainable
future, but to have such a housing estate in such a location would be completely inappropriate and
contrary to the above guidance.
In terms of the management of the wider landscape the plans are not complete, in that there is no
mention of works to some of the other significant built features within the landscape, such as the
Tower. A full and holistic management plan would be essential, as would a legally binding
agreement between Falkirk Council and the developers to ensure that all works are carried out
(preferably to the historic buildings first) and that the future maintenance of the whole designed
landscape is secured.
Please contact me if I can provide any further information or clarification, and please keep me
informed as to the progress of this application.
John Mayhew
Head of Policy and Planning
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