The draft NPF4 aims 'to inspire people to visit Scotland, and to support sustainable tourism which benefits local people and is consistent with our environmental commitments'. That is laudable, but how does the draft NPF achieve that aim?
Policy 17 starts with two key provisions:
- Local authorities are to use sector driven tourism strategies (presumably related to attractions) to identify proposals for tourism development to 'support the resilience of the tourism sector'. These proposals will be contained in the local development plan.
- Development proposals for new or extended tourist facilities or accommodation are to be supported where they can contribute to viability, sustainability and diversity of the local economy.
So the farmer who diversifies with a camping field / washing / café facilities / converted farm cottages or 'pods' for holiday let to make attractions in an area of Scotland accessible would seem to be supported, if there is a business case using local employment, maybe even providing accommodation on site for employees etc.
What about contributing to our national rather than just local economy? More substantial tourism projects could have an influence beyond the LDP area. Perhaps this will be addressed in the tourism strategies.
(Smaller scale projects proposed by farmers might benefit from the expanded permitted development rights)
Where existing tourism is having adverse environmental or quality of life / health /wellbeing impacts on local communities, policy 17 states that development proposals should only be supported 'If satisfactory measures are proposed to alleviate existing pressures and prevent further adverse impacts'.
There is a planning difference about cause and effect here that seems to be being challenged by this proposed policy. Developers should rightly be responsible for mitigating the effects of their development but fixing pre-existing problems in order to get permission is a double if not triple taxation ie – paid and continue to pay tax to date to have a working system; pay to fix existing deficit; and pay to improve to accommodate development which in turn will bring benefit to the area.
Short term holiday lets
Given the numerous types of holiday accommodation Scotland proudly offers, strangely the policy specifically addresses only 2 types – 'huts' (which it generally supports) and 'short term holiday letting' (which is newly the subject of legislation and controversial regulation – we will soon be publishing a flyer on short term letting and if you would like to receive a copy please contact us here).
Policy 17 (e) discourages proposals for reuse of existing buildings for short term holiday letting if this would result in unacceptable impact on amenity or character, or the loss of residences is not outweighed by local economic benefit (so the farmer may not be able to reuse existing cottages or convert his stable block for short term letting, and the family who inherit a relative's home may not be able to use it for commercial short term letting).
Whist the corollary is also apparently true: 17 (f) Change of use from tourism related facilities is not supported unless non- viability is demonstrated 'and that there is no requirement for alternative tourist facilities in the area'.
That could make it difficult for a family who have permitted use of their holiday home for short term lets or who run a BnB/guest house, to change to use the property as their main residence with no letting, unless they can show there is no need for their tourist facility. Is this a double need requirement in practice? Showing need for the development proposed to obtain permission as well as showing no need for the former use.
Proposals for tourist facilities in terms of Policy 17 should take account of their contribution to economic prosperity, local employment, and community wealth building (not defined); their compatibility with the surrounding area in terms of nature and scale and increased visitor impacts; " and their impacts on communities (eg hindering provision of homes and services for locals)"; as well as access, parking and traffic.
Surely the impacts on communities should also take account of local and broader opportunities, different to economic prosperity, eg enabling access to areas, providing education about the area, etc – maybe that is community wealth building? And how broad is 'local' and 'community '? Is there a danger of not seeing the wood for the trees here? For example is the contemporary idol equivalent of say the Robert Burns museum in Ayrshire not also to be assessed on it's national significance?
If the stated aims of policy 17 are to be met, this analysis shows that the draft policy raises more questions than it answers. Less is definitely more in this case. Policy 17 tries to cover too many issues and fails to do so adequately, thereby undermining its laudable intentions.