Stirling LDP Topic Paper 27: Tourism Developments and Accommodation

Stirling LDP Topic Paper 27: Tourism Developments and Accommodation 1.0 Introduction 1.1 The purpose of this topic paper is to review current Development Plan policies, national planning policies and relevant research to guide the development of future LDP policies on tourism developments and tourism accommodation. Based on this assessment, it makes recommendations as to the direction future policies should take. 2.0 Background and Context 2.1 The landscapes and historic environments of the LDP area provide the resource upon which one of its most important industries, tourism, depends. Tourism is a significant contributor to the economy of the LDP area, and a provider of local employment. The hotel and restaurant sector alone employs 4,000 people - this includes the Loch Lomond and Trossachs National Park (LLTNP) - and plays a key role in supporting businesses in both urban and rural areas (Stirling Council, Economic Positioning Strategy, 2008). It is estimated that in 2008, the total revenue generated by the tourism sector in the Stirling Council area (also including the LLTNP) was around 380 million (Stirling Council STEAM report 2008). 2.2 Tourists are drawn to a variety of attractions, and the LDP area has clear linkages to the LLTNP, a highly popular destination for both domestic and international tourists throughout the year. The LDP should be supportive of the tourism industry, and this can be achieved by identifying the most significant development opportunities and requirements, and developing a revised planning policy framework that facilitates sustainable tourism developments. 2.3 In the LDP area, the tourism product is varied. Stirling City centre is the focus for the historical and cultural tourist offering, along with other smaller centres scattered throughout the LDP area, each with their own strong identity. The highly accessible and expansive rural environment surrounding the city is also a major draw for tourists, offering a range of recreation opportunities including country parks, and acting as a gateway to the LLTNP. Business tourism is identified as being an area with opportunity for growth in Stirling Council s Single Outcome Agreement (2009). 2.4 The visioning workshops held by Architecture and Design Scotland in 2009 on behalf of the Council did however identify that within the city centre and its immediate environs, the linkages between many of the major components of the tourism product are poor, for example between the castle and the main streets of the city centre, and the surrounding countryside and the city centre area in general. This was identified in the report summarising the workshops as an issue that the LDP should aim to tackle. 2.5 The incorporation into the LDP of the Central Scotland Green Network as set out in National Planning Framework 2 may go some way to improving recreational opportunities and access to open space, and providing linkages between the urban and rural parts of the LDP area. 2.6 In land-use planning terms, tourism development ranges from hotels and other forms of accommodation to major tourist resorts and attractions. There is also a role for the LDP to play in helping to deliver the infrastructure required to support the tourism industry, and in protecting and enhancing the natural and historic assets upon which the tourism offer is based. There is a particular need for more sustainable public transport services to enable visitors to access the rural tourism product more easily. 3.0 National Planning Policy and Guidance 3.1 National Planning Framework 2 (2008) 1

3.1.1 The Scottish Government has identified tourism as being one of six national priority industries in its Economic Strategy (2007), and the importance placed on tourism is reflected in the National Planning Framework 2. This document is the most strategic statement of national Planning policy and it states the following in relation to tourism: Tourism and leisure activities have an important contribution to make to the development of the economy. (The Scottish Government) is also continuing to support the conservation and promotion of the historic environment as an irreplaceable resource, a reflection of Scotland s cultural identity and a key feature of its appeal as a tourist destination. 3.1.2 There is no specific guidance as to how individual Planning Authorities should support the tourism sector through Development Plans or planning applications. 3.4. Scottish Planning Policy (2010) 3.4.1 Scottish Planning Policy (SPP) is the current statement of national planning policy, and supersedes all previous planning policy documents. Statements specifically related to tourism developments are spread across several distinct policy areas and are as follows: Economic Development Para.47 The tourism industry is one of Scotland s largest business sectors and planning authorities should support high quality tourism related development, including the provision of appropriate facilities in key locations across urban and rural Scotland Rural Development Para.93 Development plans should promote economic activity and diversification in all small towns and rural areas, including development linked to tourism and farm diversification, whilst ensuring that the distinctiveness of rural areas, the service function of small towns and the natural and cultural heritage are protected and enhanced. 3.4.2 SPP also highlights the importance of protecting the built and natural heritage of Scotland in order to safeguard the tourism industry. With reference to local natural heritage and landscape designations, SPP states that one of their purposes is to, safeguard and promote important settings for outdoor recreation and tourism locally Para.140. Tourism is also referred to in relation to Green Belts, where it states that if effectively managed, they can provide a range of opportunities for outdoor recreation, education and tourism Para. 110. SPP also states that the impact of wind farm developments on local and national tourism and recreation interests should also be taken into account in the consideration of such developments. 3.4.3 This demonstrates that the tourism sector is affected by and has indirect links to a range of planning policy areas, but in national terms, there is no specific framework for dealing with tourism developments, or guidance as to how they should be supported and planned for in the LDP. Therefore, it is considered that policies devised for the LDP should help support locally defined tourism objectives. 4.0 Current Development Plan Position 4.1 All current Development Plan policies on tourism and tourism-related development are set out below along with a description of the objective of each policy, and an assessment of how the policy compares with the broad themes set out in SPP. 4.2 Structure Plan (2002) Policy T1: Tourism The Councils will support quality tourism development where: 1. It has satisfied a sequential approach favouring town centres, local centres and local plan sites before sites out with settlement boundaries. Developments out with existing settlements must demonstrate that there is an essential requirement for a countryside location or be justified in terms of rural development Policy ED4; and 2. It aims to increase the length of peoples stay, increase visitor spending or promote a wider spread of visitors; and 3. It will promote access to, interpretation, effective management or enhancement of the natural and built heritage. 2

Policy objective: To ensure that tourism development takes place in the most sustainable locations and that it provides appropriate support for existing tourism infrastructure and facilities. Does it meet with national policies and guidance? : As there is no national Planning policy framework dealing specifically with tourism developments, there is no requirement to subject such developments to a sequential approach. However, the policy supports other nationally defined objectives with regard to promoting the tourism industry. Recommendation: The policy is a mixture of strategic policy objectives and Development Management criteria. Criterion 2 and 3 supporting tourism development where it increases the duration of visitor s stay, spending and access to built and natural environment could form the basis for a strategic tourism policy. Reference could be added to the various types of tourism that the LDP will aim to support. The spirit of criterion 1 could be used to form the basis for a new Development Management policy, without the reference to the sequential approach, and incorporating wording similar to the following: Tourism-related development will be supported within and adjacent to settlement boundaries in locations which satisfy other development management policies. Rural locations will only be allowed where a reasoned justification exists. Other issues: The policy does not define what is meant by quality tourism development. 4.2 Local Plan Alteration 1A (2007) Policy ED9 General Policy on all Tourism Developments, Visitor Attractions, Accommodation and Interpretation Facilities Tourism related development will generally be supported: - 1.Within settlement boundaries, in locations where the Council is satisfied that the activity associated with a successful tourist business can be accommodated without adverse impacts upon neighbouring uses or the built heritage; 2. In countryside, only where consistent with Plan policies on development in rural areas; 3. In locations where it will complement existing provision, be consistent with other Plan policies, and assist in delivering the tourism objectives of the Council and the Area Tourist Board; 4. In situations where development will facilitate the sustainable management of visitors (within and between the major tourist destinations of the Castle/Stirling Old Town, Stirling Town Centre, Forthside and key areas of visitor pressure within and on the fringes of the National Park). 5. All tourism related developments will require to be designed with suitable provision of facilities to be accessible to people of all abilities. Planning Conditions or a Section 75 agreement may be attached to a permission for any tourist related development in order to control occupancy and/or use, restrict sale/disposal, to ensure landscape maintenance/environmental management, and to ensure appropriate infrastructure in accordance with Policy ED11. Policy objective: To ensure that tourism-related development takes place in appropriate and sustainable locations with the appropriate level of infrastructure in place to support it. The policy applies to all tourism developments including accommodation and is broadly similar in its objectives to policy T1. Does it meet with national policies and guidance? : See above comments for policy T1. Other issues: The policy does not define where the key areas of visitor pressure are within criterion 3. Recommendation: Aspects of the policy could be used in a Development Management policy on tourism developments as outlined in the recommendations for Policy T1 above. Other aspects could be used in a Development Management policy on the requirements from developers from specific types of developments for infrastructure with regard to planning conditions/s.75 agreements. 3

Policy ED10 Holiday accommodation and other related developments Proposals for holiday letting accommodation, hotels, associated retailing and staff accommodation will be assessed against the general tourist development Policy ED9, Policy ED7 on economic development in the countryside, and the Council s Supplementary Planning Guidance on Chalet Development. The following specific criteria will also apply: - a) Timber chalets will only be acceptable in a managed woodland setting. All chalets will require to be in locations where an established landscape setting can accommodate such development without it being visually prominent within the built or natural environment. b) Hotels, B&Bs and guesthouses will be encouraged within or adjacent to town centres or ancillary to strategic employment sites. Where such sites are not available, they may be supported in other accessible locations within settlements and in rural areas where consistent with rural development policies. c) Sensitive expansion of existing caravan and camping sites will be supported in preference to the establishment of new sites, where these sites are well sited and designed. New capacity for transit tourist caravan and camping, either expansion or new sites, will only be considered where the site is accessible (consistent with ED7 (5)) and can be accommodated within an existing landscape setting without detriment to the landscape character of the area. A presumption against development will apply to new sites for static caravans. d) Retailing and other commercial uses will only be supported where ancillary to the principal tourist use. (See Policy ED23) e) Staff accommodation of appropriate scale, siting and design, integrated with the development and its surrounding environment, will be supported where it is demonstrated that it is required in association with existing or new facilities to meet an essential need for on-site management. Policy objective: To ensure that tourism accommodation development takes place in the right locations and that associated developments are ancillary to tourism development. Does it meet with national policies and guidance? : See above comments for policy T1. Recommendation: The content of this policy could be modified to create a new Development Management policy on tourism accommodation only with a link to Supplementary Planning Guidance on Chalet Developments. It is suggested that ancillary retail and commercial developments are dealt with under the policy area Retail and commercial developments, and a proposed policy to deal with such developments is set out in the topic paper for this policy area. There is also a linkage between developments such as Bed and Breakfasts and staff accommodation, and the recently adopted Housing in the Countryside policy H10A. Policy ED11 Tourism Infrastructure The Council will seek contributions from the developers of major new tourist facilities towards providing supporting infrastructure, which would help to enhance the general tourism product. Examples would include off site car parks, lay-bys, viewpoints and signage/interpretative facilities. The Council will, in consultation with other services, relevant agencies and the Tourist Board, identify suitable infrastructure and locations where there is considered to be a deficiency or need. Policy objective: To ensure that tourism-related developments are supported by an appropriate level of infrastructure. Does it meet with national policies and guidance? : It aims to make expectations of developers clear. It is broadly similar to the section in Policy ED9 on infrastructure and planning agreements. Recommendation: A policy similar to this could be taken forward in the LDP as a general Development Management policy on infrastructure provision for tourism-related developments in accordance with the advice in Circular 12/1996. 4.3 Development Advice Note: Supplementary Guidance for Chalet Developments (2001) 4

4.3.1 The Guidance could be updated with regard to the references to other Councils and the interim committee, which are no longer relevant. The majority of the guidance is still valid and new pictures, diagrams etc. could be used to bring it up to date. It could hook to a policy on tourism accommodation in the LDP, similar to existing policy ED10. This Development Advice Note sets out sets out good practice in the siting and design of new chalet developments and serves to complement Policy ED10. It provides detailed guidance on issues such as siting, design and suitable materials. 5.0 Other relevant Strategies/Studies and Engagement 5.1 Single Outcome Agreement, Stirling Council, (2009) 5.1.1 The agreement highlights the importance of tourism to the economy of Stirling (including the LLTNP) and identifies a specific target of increasing the growth rate in the value of tourism activity by 2% beyond the national rate, and increasing from 4.4 to 5 million the number of annual visitors. This is in order to meet the strategic objective for a Stirling with, a vibrant economy that is open for business. The document also states that tourism is reliant on a high quality natural environment, which is identified as one of the strategic topics in the agreement as it is an important contributor to the overall success of Stirling. 5.2 Tourism Framework for Change, Scottish Executive, (2006), and Destination Stirling: Tourism Action Plan, Stirling Council, (2008 2012) 5.2.1 The Framework for Change sets out the Scottish Executive s (now Government s) ambition to achieve 50% revenue growth (in real terms) in the tourism industry by 2015. This is the framework that Scottish Local Authorities must work to in order to help deliver this revenue growth. The Council s Action Plan identifies some key objectives to help improve the City of Stirling specifically as a tourist destination. Those where the LDP could have an input are as follows: To promote Stirling s unique mix of compact historic city and accessible countryside To improve the visitor experience To increase visitor footfall between the Castle, Top of the Town and the retail core To create a more vibrant Old Town To improve the food and beverage offer To strengthen the evening economy To improve and promote the identities of the towns and villages around the city 5.3 Stirling Visitor Survey, Stirling Council and Lynn Jones Research, 2009 (and 2008) 5.3.1 This survey, commissioned by the Council s Economic Development, sought to discover the perceptions of visitors to the City of Stirling specifically, and to determine to what extent Stirling acts as a gateway to the LLTNP. The study will be repeated in 2010.The findings related specifically to areas of planning policy are as follows: The historical aspect of the city is the biggest draw for visitors to Stirling, with Stirling Castle and the National Wallace Monument being the most visited attractions. This highlights the importance of conservation and archaeology planning policies in the LDP. Current Development Plan policies seek to preserve and enhance the historic element of Stirling City, as well as other historical centres and environments. The 2008 survey found that views and setting were seen to be the most impressive aspects of Stirling. This highlights the tourism importance of landscape and nature conservation policies, for example those on the Green Belt, development in the countryside, Areas of Great Landscape Value etc. It is important that these views and the setting of the City are protected through the policies of the LDP. This should include views within, of and to the city. Most visitors who are staying away from home during their visit choose to stay in locations other than Stirling, such as Glasgow or Edinburgh (58%). The study does not identify reasons for this, but it may be attributable in part to a lack of suitable holiday 5

Shopping is an important activity for visitors to Stirling, and was the third most popular activity (49%) after visiting attractions (80%) and walking around (70%). This highlights the importance Stirling s retail offering as part of the tourism package, particularly for domestic tourists. However there are questions as to how much importance should be placed on the retail offer in relation to tourism given that there are other rival shopping centres nearby with better retail offers. Forty-two percent of all visitors choose to eat and drink within the city centre at some point during their visit or stay. The survey identified that the food and drink offer available to tourists could be improved, particularly in comparison with perceptions of accommodation, attractions etc. This indicates that there is a need to create a high quality pub/restaurant quarter within the city that meets the needs of tourists as well as local people, and there is a role for planning policy to play in delivering this. Twenty-eight percent of all visitors to Stirling (both day and overnight) visit the city on the way to or from the LLTNP. This indicates the importance of the relationship between Stirling and the LLTNP and it also demonstrates that the policies of the LDP have a part to play in managing visitors to the LLTNP. 5.3.2 Additional facts and information related to tourism in the LDP area can be found in Appendix 1. 5.4 Economic Positioning Study, Stirling Council, (2008) This study was carried out in order to identify the industrial/business sectors that are critical to providing a sustainable economy for Stirling and to develop an informed positioning of Stirling within Scotland and its linkages to other economies. It identifies the tourism sector as being a potential industrial specialism, and states that in 2006, tourism revenue in the city centre equalled that of the whole LLTNP area, at approximately 250 million. The study states that the development of retail and other tourism related services such as restaurants should be prioritised and developed to enhance Stirling as a key tourist destination. 6.0 Local Considerations/Policy Usage 6.1 Applications and appeals 2.2 Tourist numbers in Stirling in the coming years (both domestic and international) may be adversely affected by the economic downturn. However, it is hoped that the offering is strong enough to withstand the recession. In the long term, tourism is unlikely to lose its place as a major contributor to the economy of Stirling. The Council s Single Outcome Agreement 2009-2011 (covering the whole Council area) states that the total employment supported by tourism consists of industries that are also part of the services industry such as hotels. Approximately 20% of jobs in the Stirling area were estimated as being directly related to or supported by tourism in 2006 compared with a national figure of around 8% demonstrating the importance of tourism for the local economy. 6.1.1 A recent trend has been for larger Outline applications in the urban area of Stirling to include hotels as part of the range of proposed uses, although it may be the case that they do not feature in the Full applications submitted subsequently. The extent to which there is a surplus or deficit of hotel provision in the LDP area is unknown (i.e. size, quality, type and specific location of need). However, the recent growing market interest has highlighted the lack of a clear policy framework within the existing Development Plan for new hotel development. With regard to tourism-related applications, hotels account for the majority of those that we receive. All recent/current applications (Detailed and Outline, approved and under consideration) are listed below. It should be noted that a number of these applications are for sites outwith the city centre as defined in the current Development Plan. 6

08/00314/OUT: Mixed use outline application including a hotel, Crookbridge, Stirling, Pending consideration 08/00726/OUT: Golf course with hotel, Park of Keir, Dunblane, Outline application pending consideration 08/00313/OUT: Mixed use outline application including a hotel, Burghmuir, Stirling, Pending subject to S75 07/00680/OUT: Mixed use outline application including a hotel, Kildean Loop, Stirling, Pending subject to S75 07/00673/OUT: Mixed use outline application including two hotels, Craigforth, Stirling, Approved 08/00412/DET: Conference hotel, Forthside, Stirling, Approved 08/00732/DET: Six storey hotel development, Dumbarton Road, Stirling, Detailed application pending consideration 06/00798/DET: Change of use to hotel, King Street, Stirling, Detailed application, Approved 08/00603/DET: Change of use to hotel, Spittal Street, Stirling, Detailed application, Approved 6.1.2 Two of the current Development Plan policies on tourism have been tested at appeal since 2001. Policy ED9 has been used three times at appeal, all of which were refused. On two occasions the reporter agreed with the Council s use of the policy and from their comment s, it is apparent that they found the policy to be useful. On one occasion the reporter did not use the policy when refusing permission for a chalet development, stating that it is a catchall policy. Policy ED10 has also been used three times at appeal (in two of the above appeals), all of which were dismissed. The appeals were for holiday cottages and chalets. 6.1.3 Although the instances where these policies have been used at appeal are few, this information does indicate that policy ED10 is effective in decision-making, while ED9 is perhaps too general and should be reviewed. 7.0 Recommended Future Policy Direction 7.1 Points for consideration The content of current Development Plan policies overlaps, and there is a lack of distinction between strategic aims to support the tourism industry, and criteria for assessing a planning application. It is considered that there should be three levels of policies used consistently throughout the LDP: strategic policies, Development Management policies and area-based policies. For example, policies stating that the LDP is supportive of the tourism sector, and encourages tourism-related development would be strategic-level policies, while those detailing how to assess an application would be Development Management policies. If sites for tourism development are identified, these could be incorporated as area-based policies with a hook to Supplementary Planning Guidance if required. For Development Management purposes, it is important for future policies to set out what is meant by tourism developments, for example, hotels, large leisure developments, etc. etc. This will enable the policy to be used to determine planning applications. It is important that any policy on tourism developments acknowledges that they should be in locations easily accessible by and connected to the public transport network. 7.2 Preferred policy option Table 7.2 below sets out specific recommendations for policy changes. The main policy issue is that there is a need for two distinct levels of policy related to tourism and tourism developments, and that in general, any future LDP policies should aim to be more explicit in their support of tourism developments. 7

Key to table: : Preferred option?: Suggested alternative Table 7.1 Policy recommendations summary table Existing policies T1 - Tourism Criterion 2 and 3. T1 - Tourism Criterion 1. ED9 - General policy on tourism developments (aspects of this policy-see ED9 below) ED10 Holiday accommodation and other related developments ED11 Tourism infrastructure ED9 - General policy on tourism developments (aspects of this policy-see ED9 above) Policy options with alternatives where appropriate 1. Tourism 1 Policy supporting the tourism sector and tourism developments in general. Use criterion 2 and 3 from existing policy T1. 1. Tourism 2 - Policy indicating preferred location for tourism-related developments incorporating aspects of T1 and ED9 but removing the references to the sequential approach. Suggested wording as follows: Tourism-related development will be supported within and adjacent to settlement boundaries in appropriate locations. Rural locations will only be allowed where appropriate justification exists. 1. Tourism 3 Policy related to tourism accommodation only, with a hook to Supplementary Planning Guidance on Chalet Developments. 1. Tourism 4 A general policy on infrastructure requirements from tourism-related developments incorporating aspects of ED11 and ED9. Suggested policy status Strategic policy Development Management policy Development Management policy with hook to Supplementary Planning Guidance Development Management policy 8.0 Link to other Topics/Policy Areas 8.1 There is a clear link between this policy area and economic development, rural development, the historic environment, retailing, countryside access and recreation, managing landscape change and natural heritage/biodiversity. There is also a link with the recently approved Housing in the Countryside Policy H10A in relation to houses for specific purposes to manage a rural business. 9.0 References Destination Stirling: Tourism Action Plan, Stirling Council, 2008 2012, 2008 Economic Positioning Strategy, Stirling Council, 2009 National Planning Framework 2, Scottish Government, 2008 Scottish Planning Policy, Scottish Government, 2010 Stirling Council Single Outcome Agreement, Stirling Council, 2009 Stirling Council STEAM Report, 2008 Stirling Visitor Survey, Stirling Council and Lynn Jones Research, 2009 and 2008 The Government Economic Strategy, Scottish Government, 2007 Tourism Framework for Change, Scottish Executive, 2006 8

Appendix 1 Length of stay (overnight visitors): Stirling (% of visitors) Average 2.52 nights 1 night 34% 2 nights 36% 3 nights 4+ nights 12% 18% Source: Liz Jones Research, Stirling Visitor Survey 2009 Hotel bed space occupancy: Accommodation Occupancy 2007 % Room Occupancy 100 80 60 40 20 0 January March May July September November Hotel Guest House/B&B Month Source: Visit Scotland, Tourism in Argyll, The Isles, Loch Lomond and Forth Valley 2007 statistics Tourist attraction visitor numbers 2007-2008 Attraction 2008 2007 % change 08/07 Mugdock Country Park 622,375 No figures av. - Blairdrummond Safari Park 388,112 433,070-10 Stirling Castle, Stirling 375,344 389,011-3.5 National Wallace Monument, Stirling 117,466 118,957-1.3 Stirling Smith Art Gallery and Museum, Stirling 51,438 40,859 +25.9 Glenoyne Distillery, Nr Killearn 42,356 38,995 +8.6 Bannockburn Heritage Centre, Stirling 40,925 61,410-33.4 Doune Castle, Doune 31,879 34,257-6.9 Argyll's Lodging, Stirling 28,470 50,573-43.7 Old Town Jail, Stirling 27,045 29,047-6.9 Church of the Holy Rude, Stirling 26,000 25,000 +4.0 Briarlands Farm, Stirling 25,162 18,565 +35.5 Inchmahome Priory, Stirling 16,441 16,790-2.1 Dunblane Cathedral, Dunblane 11,552 14,894-22.4 Buchlyvie Pottery, Buchlyvie 3,600 3,600 0.0 Leighton Library, Dunblane 926 876 +5.7 Bridge of Allan Parish Chuch, Bridge of Allan 229 275-16.7 Source: Visit Scotland, Scottish Visitor Attraction Survey 2008 9