July 2024 – a new proposal for change of use of the old cinema has been submitted. Public comments may be made until 18 July https://planning.fife.gov.uk/online/applicationDetails.do?keyVal=SC777LHFKMA00&activeTab=summary
Proposed Crail Airfield Development – Observations and Objections by Crail Community Council
- Overview:
Crail Community Council wishes to raise a number of observations and resultant objections to the Application for Planning Permission in Principle for the proposed development at Crail Airfield, Reference 23/02309/PPP by Ground Developments Ltd (“the Developer”).
There is considerable non-compliance with the FIFEplan (also known as the Local Development Plan), contained within the submitted Planning Statement – Appendix 5 and other supporting documents. The most important here is the question of access to the development.
In terms of Section 25 of The Town and Country Planning (Scotland) Act 1997, it is provided that where “… in making any determination under the Planning Acts, regard is to be had to the development plan, the determination is, unless material considerations indicate otherwise, to be made in accordance with that plan”.
The development plan includes the existing FIFEplan of 2017 and National Planning Framework 4 (NPF4) of 2023. In terms of Section 24 (3) of The Town and Country Planning (Scotland) Act 1997, if there is an incompatibility in the development plan, the latter in date is to prevail. The Developer in their Planning Statement refers to various general policies contained in NPF4. These are all general and strategic objectives of the National Planning Framework but none of these are incompatible with the specific requirement in relation to access in the existing local development plan (“FIFEplan”).
The FIFEplan refers specifically to Crail Airfield under reference LWD022. In addition to requiring developers to prepare a development brief and carry out community consultation, it provides specifically that “Development…. should resolve site access issues from Crail to the airfield and Crail golf courses – an alternative route will be required“. This is a specific requirement in the FIFEplan. The Developer will have been aware of this existing planning requirement when purchasing the site in 2021.
Other considerations and objections are as follows:
- Misrepresentation of community consultation
- Misrepresentation of the Crail Local Place Plan
- Stipulation of new access in FIFEplan
- Increased traffic generation
- Denburn Narrows considerations
- Protection of listed buildings and site
- Implication of the Wide Extent of Use Classes and Description of Development
- Lack of Planning Gain
- Limited information on events and event spaces
- Comments on the National Planning Framework 4 (NPF4)
As a result of the non-compliance with regard to an alternative main access, expressly required by the FIFEplan, as well as the other material considerations referred to above, the Fife Council Planning Authority must refuse consent to the Application.
- Detailed Observations and Objections:
- Misrepresentation of community consultation
The Pre-Application Consultation Report – Appendix 4 refers to two public consultation events on Saturday 25 March and Saturday 29th April 2023, which are statutory requirements.
In paragraph 4.0, reference is made to electronic feedback forms and there appear to be 6 items mentioned.
The Report indicates that there were 152 attendees at the first event and many of the attendees made comments about the issues around access and transport to and from the airfield site during the discussions with the representatives of the developers as well as amongst each other. There was an opportunity for feedback to be provided in written form on the day.
In the Report it is suggested that there was little reference to the access issue and this was allegedly borne out by the feedback from 6 online forms that the developers received after the event.
However, the offline feedback collated on the day of the first event was shared by the Developer with the Crail Community Partnership shortly afterwards. There were 30+ comments slips and a great majority referenced issues and concerns around access and transportation. The lack of an alternative access to the current link via Marketgate/Denburn Narrows/Balcomie Road was frequently cited as an objection to the development, reflecting very much the discussion in the room during both consultation events.
Furthermore, the Developer met with Crail Community Partnership on a number of occasions and concerns about access to the site were raised at each meeting.
The Pre-Application Consultation Report indicates at paragraph 1.5 that the proposal “addresses the issues raised during the consultation process”, but there have been no changes to the proposal which address the concerns raised around traffic in the village. In fact, it is disappointing that the Planning Application by the Developer misrepresents the discussions and omits the wider feedback.
- Misleading Representation of the Crail Local Place Plan
Reference is made to the Crail Local Place Plan in paragraph 2.30 of the Transport Assessment (and in other parts of the Application). The Developer acknowledges that Crail Airfield is not referred to in the document, but Crail North is referred to instead (along with the discussion of a possible second access to Crail North).
On page 25 of the Transport Assessment – Appendix 18 the Developer states that “residents have identified the Denburn route via the local place plan as the preferred alternative secondary route to Crail North” and the Developer has therefore concluded that there is no concern about increased traffic through Marketgate, Denburn Narrows and Balcomie Road. This is a misrepresentation of the conclusions contained in the Crail Local Place Plan.
The Crail Local Place Plan focuses on Crail North as a possible residential development with a new primary access from the A917 St Andrews Road, diverting the bulk of traffic through that route. A secondary access is needed and this remains problematic. Residents and Fife Council are aware of the issues with Denburn Narrows, but the conclusion in the Crail Local Place Plan was that a secondary access through Denburn Narrows would be the least worst option as a new primary access would take away the majority of the traffic heading to Crail North, the Airfield and the golf courses.
- Stipulation of new access in FIFEplan
Furthermore, the FIFEplan makes specifically clear that a new access is required for Crail Airfield under Reference LWD022. This stipulation has been completely omitted by the Developer from their Planning application.
- Increased traffic generation
The Developer commissioned consultants Transport Planning Limited to provide a traffic assessment. Paragraph 2.3 of the Transport Assessment states that the Site is 1600m from the junction of A917 and Marketgate North. A walk (one way) from the junction of the A917 and Marketgate North (ie the Town Hall in the centre of Crail where most of the existing services are located) to the heart of the application site will take at least 25 minutes ie 50 minutes return trip (according to Google Maps). Therefore, the reality is that increased car traffic will be an inevitable consequence of the holiday accommodation, hotel, community buildings, retail, museum archive, craft workshops, light industrial workshops, events and seasonal accommodation aspects of the proposed development.
The Transport consultants undertook a week-long measurement of existing traffic flows in May 2023. However, this short period does not take into consideration any increase in traffic during holiday months such as July and August. Even based on these limited measurements, Transport Planning Ltd admits that the trip numbers are likely to almost double from what was measured, if the Airfield development were to open.
As indicated below, the Application includes other uses, which have not been calculated ( e.g. events in addition to Crail raceway – and who knows what the numbers would be at the weekend with a Crail Raceway event, along with any event at the proposed Crail airfield event site itself).
Looking specifically at Table 3.1, the Table lists seven uses. However, as indicated below, the Application relating to 10 Use Classes appears to be missing data for the following use classes:
- community buildings
- retail (related to the proposed Market Hall, which is proposed to be similar to the Bowhouse operation near St Monans, which can produce a great deal of traffic)
- affordable seasonal accommodation
- public events
- existing uses at the site – including general industrial and events.
There are serious questions concerning the analysis above and the conclusions reached in the Transport Assessment and these assumptions will require rigorous analysis by Fife Council Transportation/Roads departments.
- Denburn Narrows considerations
In the Transport Assessment – Appendix 18, Paragraph 3.42 refers to the “give and go” at Denburn Narrows.
The Transport Assessment suggests that the Crail Local Place Plan identifies the community preference for a second access point to Crail North being through the Denburn Narrows route and implies that this route can cope with increased traffic and serve as the main access to the Airfield development.
However, the community already has serious concerns about the existing use of Denburn Narrows. The historic and ongoing concern has been that the Denburn Narrows route to Crail Airfield and the golf courses is hazardous, causing health and safety concerns particularly to pedestrians and cyclists and is therefore unsuitable for increased traffic.
The photo provided in paragraph 3.42 of the Transport Assessment – Appendix 18 is of assistance here, showing the narrowing of the road is at the junction with Kirk Wynd. The carriageway at that point from the edge of the pavement to the building on the other side at the top of Kirk Wynd is 4.8 metres, but at that point the pavement beside the wall is only 0.9 metres wide.
There was consideration given to widening the pavement but that was not possible due to the requirement for bin lorries to turn right down Kirk Wynd and that would make the roadway too narrow. The result is that pedestrians (including, but not limited to parents with children/prams, pedestrians dependent on mobility devices and dog walkers) are squeezed through a very narrow, one-sided pavement on the North side of Denburn Narrows with traffic coming through. In addition, pedestrians walking up Kirk Wynd and turning into Marketgate have no pavement and are faced with passing cars and no visibility splay to the West.
The Developer asserts that the capacity of the Denburn Narrows arrangement is 4800 vehicles per day, which is higher than the peak projected usage. However, the suggestion that Denburn Narrows is simply to be considered a single track road is misleading. The route is used not only by cars, buses, lorries and tractors, but also by cyclists and pedestrians, despite there being very limited pavement provision and severely restricted visibility of traffic and road users. Near misses are an almost daily occurrence at the site and the current “give and go” is not addressing the issue.
Furthermore, the figures for additional traffic provided are estimates and omit a number of use classes, most notably those for hosting extra events at the Markethall and on the technical site.
The particular issues around Marketgate, Denburn Narrows and Balcomie Road are part of the reason why the FIFEplan contains a requirement for a new access to Crail Airfield and the golf courses and ideally that access should be from the A917, St Andrews Road, potentially through Crail North and to Crail Airfield. This requirement was raised with the Developer at the pre-application consultation events and in feedback provided online and offline, as well as in the dialogue with Crail Community Partnership but has been ignored both by the Developer and Transport Planning Limited.
- Protection of listed buildings and site
In paragraph 8.0 of the Heritage Statement, it is identified that there are four listed buildings in the accommodation area and 30 in the technical area of which four listed buildings in the technical area are category A and the others are either in category B or C.
It is also noted that there are Scheduled Monuments, Gardens and Designed Landscapes, Conservations Areas, SSSIs and a Special Landscape Area within close proximity to the Site. Therefore, very careful consideration should be given to this.
The Application in question is an “outline” type of planning application. The Application therefore does not provide detail in relation to the actual alterations to the listed buildings themselves or details of the alterations to the curtilage of the listed buildings (which could include the whole Site). The Heritage Statement indicates that individual impact assessments will be submitted with later detailed applications for planning and listed building consent approvals.
Dealing with a site containing numerous listed buildings requires in-depth consideration of not only the individual building, but the entire site.
The Planning Statement – Appendix 5 suggests in conclusion under Point 7.2 that “the application site is an opportunity to preserve part of the UK’s wartime history…”, but there is clear indication that some of the listed buildings will be removed or altered beyond recognition or appropriated for non-appropriate uses such as playgrounds and art installations: in the Planning Statement (Appendix 5) provided, the Developer is already suggesting that the Junior Officers’ Quarters and the Junior Rates Block will be replaced rather than restored and renovated – see point 4.9.
If Planning Permission in Principle is granted, the implication will be that future planning permissions and listed building consents must also be granted, notwithstanding any impacts on each of the listed buildings and/or their curtilages.
- Implication of the Wide Extent of Use Classes and Description of Development
The agreed description is defined in paragraph 1.7 of the Planning Statement as “the regeneration and conversion of Crail airfield to form a mixed used development, including self – serviced holiday accommodation, hotel, community buildings, museum archive, craft workshops/ light industrial, retail, business incubators, affordable seasonal accommodation, public events space and ancillary infrastructure. Proposed master plan zoning incorporates planning use classes, 1,2,3,4,6,7,8,9,10 and 11“.
This description and in particular the Use Classes are very wide with only Use Class 5 (heavy industrial) being omitted. There is a zoning plan contained in the Application and it is noted that potentially very large areas are zoned as holiday accommodation, while the Use Classes shown (1,3 and 9) allow for other forms of development. Similarly business and light industrial (Use classes 4 and 6 ) are not well defined.
There are a number of concerns arising from this:
- Enforcement of holiday accommodation use: The Use Class is stated as
9 – residential, but the Application otherwise makes reference to holiday accommodation. This was also a question raised at the Pre-application Consultation about how the limited use associated with holiday accommodation will be policed and enforced. Furthermore, what is to stop plot owners applying to change the use in the future to full residential use? We would therefore ask that the Application is either (a) refused on these grounds or (b) there will be a Title Restriction, ie Section 75 Agreement or a Holiday Accommodation Conditioning such as 11 months occupation only.
(b) The business and storage and distribution uses (Classes 4 and 6 ) could be intensified. Currently this does not appear to be the intention of the Application but how would that be policed and enforced in future?
- Lack of Planning Gain:
This is a major Application and you would normally expect to see some element of planning gain out with the red line boundary of the site apart from the new access already required by the FIFEplan. Further items of planning gain should include improvements to Balcomie Road, along with a new separate shared footway/cycle path along the length of Balcomie Road to help integrate the Site to Crail, which is some 1600m away, which was also suggested by Fife Council Transportation Department (page 25 of the Transport Assessment ). Public transport by bus would be sensible to serve the site, however the existing road is unsuitable for a bus.
The Planning Application for the Airfield site shows no residential accommodation (which might yet be achieved by individual owners at a later stage). However, it is disappointing that there is no obligation and hence no plans for the building of much-needed affordable housing either onsite or offsite.
The proposal for the former gym and cinema to serve as a Market Hall showcasing local food and drink stalls, while offering event space as well as internal and external seating duplicates a similar offering at Bowhouse. Bowhouse has become established as an events and food/drink venue, with units dedicated to food production and hospitality. These events are well delivered but nevertheless generate large amount of extra traffic as well as demand for parking spaces, which Balcaskie Estate (Owners of Bowhouse) are able to provide.
It is unlikely that the East Neuk requires a second venue of this nature.
It should also be pointed out that Crail itself offers a number of event spaces, including the Crail Community Hall.
Furthermore, the suggestion of an additional events area on the technical side of the Airfield site gives no further information on nature, scope nor frequency. Planning Permission in Principle should not be granted for this development when key parts are ill-defined.
- Comments on National Planning Framework 4 (NPF4)
The Planning Statement – Appendix 5 also references NPF 4 policies. Their statement ignores Policy 7 (Historic Assets and Places). The Planning Permission in Principle, if granted, will not be able to reflect the need for assessment that “should identify the likely visual or physical impact of any proposals for change, including cumulative effects and provide a sound basis for managing the impacts of change”.
While the Planning Statement refers to Policy 13 (Sustainable Transport), the statement does not reference the need/desire for private car journeys to reach the site, both for visitors to holiday accommodation and work purposes in regard to other parts of the site. According to point 6.37 in the Planning Statement – Appendix 5, the site “will be accessible by public transport, ideally supporting the use of existing services” While the development in itself might provide a walkable and cycle-friendly environment on the site itself, there is already a lack of defined plans to link up these paths to the existing town. The distance from the site and the frequently inclement weather are likely to lessen the demand for active travel. Furthermore, Crail is poorly connected by public transport to the rest of Fife, the Central Belt and beyond, which means that major journeys in and out of the development and for further exploration of the surrounding area will be made by private car.
Policy 15 (Local Living and 20 Minute Neighbourhoods) of NPF4 has been omitted though in earlier meetings with the Crail Community Partnership and the public consultations, 20-minute neighbourhood principles were cited as proof that the development will generate low additional car travel. As we can see from the Transport Assessment commissioned by the Developer, the distances involved are indeed beyond the 20-minute neighbourhood boundaries and imply additional car travel. Contrary to earlier plans discussed, the submitted Application no longer requires holiday homes owners and visitors to park their cars in communal areas but provide up to two parking places per plot at each individual holiday home. This shows clearly that there will be strong reliance on private car journeys for future owners at the Airfield development.
Balcomie Road is not wide enough for the bus service that currently provides public transport to Crail and the lack of a segregated Cycle and Walking path along Balcomie Road support this assumption.
The Developer also cites Policy 16 (Quality Housing), designed to improve housing provision across Scotland. Rather surprising, as the Planning Permission in Principle in this case refers to holiday accommodation which will be holiday homes (ie second homes) and short term let units. Currently the application submitted does not show any permanent residential housing. Citing this policy in support of the Planning Application is misleading.
In Policy 29 ( Rural Development) it is stated very clearly that developments should “take into account the transport needs of the development as appropriate for the rural location”. It is not appropriate to interpret this only in light of the development itself, as the Airfield is a considerable distance from Crail town centre and consideration has to be given how visitors will access the site – see comments above to Policy 13.
Policy 30 (Tourism) requires that Local Development Plans should “also identify areas of pressure”, rendering further developments not appropriate. Crail already is home to a significant number of short term lets ( on AirBnB alone there were 78 short term lets listed on 23 Sep 2023) plus a number of serviced accommodation at the Balcomie Links Hotel, The Honeypot B&B, the Golf Hotel and the Shoregate as well as considerable numbers of day trippers. All of these can lead to traffic issues, not just at Denburn Narrows, but throughout the High Street.
Suggestions for economic benefits arising for Crail and Fife from a hotel, café, events space and museum are just that – they are not costed, neither for CapEx nor for Revenue expenditure.
This application does not give any impact/figures on the economic benefit that could potentially accrue to Crail, Fife and wider Scotland.
- Conclusion: Refusal of Application
As has been demonstrated above, there are numerous considerations and objections that compromise the development. As the Developer was undoubtedly aware of the access issue when buying the site and since had considerable feedback from community groups and residents of Crail, they should have considered provision of a new access route. Bearing in mind that Crail North is a potential development site for significant residential housing, an opportunity to find a comprehensive solution in conjunction with other interested parties has been missed.
In the FIFEplan, the decision-making process for the planning application is shown as a flow chart, which states clearly that if the Proposal has not met its requirements, in this case the provision of an alternative access to the site in question as well as considerations shown above, “Planning Permission will not be supported”.
We therefore ask Fife Council to refuse this application outright.
As plans emerge, we will place them on this page.
An Outline Planning Pemission Application has been submitted. Details can be found at the Fife council Planning Portal at https://planning.fife.gov.uk/online/applicationDetails. do?activeTab=documents&keyVal=RZQS5THFIH700. The deadline for receipt of comments from the community is 13 October; the response time for the observations from Crail Community Council, a statutory consultee, has now been extended to 27th October 2023.
There will be a meeting of the Community Council on 2 October at 7.15pm in the Town Hall. The proposed Planning submission will be the major agenda item, and the response to the proposal will be formulated.
Crail Matters understands the principle areas of concern raised at the the meeting held 29 April relate to access along Balcomie Road. To see if the developers have anything to add we suggest you go to https://crailairfield.co.uk/.
The second public meeting about the regeneration of the airfield will be held in The Community Hall from 9am to 1pm on Saturday 29 April.
Ground Development Ltd. have prepared a website that includes the most relevant information presented at the meeting of 25 March. https://crailairfield.co.uk/
A meeting to inform the Crail Community about the plans will be held on March 25th in the Community Hall at 0900-1200
Ground Development Ltd have submitted to Fife Council a Proposal of Application Notice for the proposed development of the former airfield. This is the plan submitted ref. No 23/00558/PAN
Crail Matters 