Planning matters blog | Lichfields

Planning matters

Our award winning blog gives a fresh perspective on the latest trends in planning and development.

I’m often asked what my most interesting, or favourite project during my 7 years at Lichfields has been. It’s a difficult question to answer. Due to the very nature of our business and indeed the make-up of our Edinburgh office, I’ve worked on a wide variety of projects – from signage applications for Hampden Stadium that needed to be in place by the Cup Final, all the way up to large mixed-use developments like Elements Edinburgh at Edinburgh Airport. My mind does however more often than not revert back to my time working on a number of projects at Cameron House Hotel. Lichfields' involvement in the Cameron House estate extends long prior to my joining the company, and a review of our work to date serves as a good indication of the varying needs, in planning terms, of the evolution of a 5 start hotel throughout changing markets. As construction on one of our most recent planning permissions nears completion, this blog is an opportunity to reflect on those projects and the lessons learned. For those who may not be as familiar, Cameron House is a 5-star luxury resort comprising hotel, marina, golf course and lodge park. The resort is located on the banks of Loch Lomond, to the north of the town of Balloch, within the Loch Lomond and the Trossachs National Park. Cameron House itself is a Category ‘B’ listed building and is comprised of a mansion house mostly dating from two phases of development: 1812-4 and 1866-7, though excavation work in 2017 revealed surviving fabric of an earlier building (which likely dates back to the 1600s). For three centuries Cameron House belonged to Smollett family who over that time are said to have hosted a number of dignitaries - James Boswell and Samuel Johnson, Winston Churchill, Sir Anthony Eden as well as Princess Margaret and Empress Eugenie of France. The family sold the house in 1985 and it was converted into a hotel in 1986. It has been subject to a great deal of investment since then to make it the 5 star resort it was to become - a number of extensions, including a modern leisure wing in 1989, an eastern accommodation wing in 2006 and a gin terrace in 2016 prior to the most recent extension, just complete, to provide a new ballroom and additional bedrooms. Like its time as a private house the property has continued to host and be popular with dignitaries, politicians and celebrities looking for a luxury place to stay not too far from Glasgow. Lichfields involvement in Cameron House commenced not long after the construction of the accommodation wing, initially in the form of supporting evidence to accompany architect led development proposals within the estate in 2008. Shortly thereafter we, carried out due diligence work in advance of a prospective sale, reviewing development that had taken place on the estate and comparing it against planning permissions and Listed Building Consents relating to the site. Exercises such as these are essential in establishing the degree of risk associated with the purchase of an established and going concern such as a hotel resort. Lichfields carries out tasks such as this on behalf of many clients, and although more often than not it is behind-the-scenes and low-profile work, it can form a key component to any transfer of asset between parties. My own role commenced in 2015, in relation to minor works to relocate LPG tanks within the historic walled garden at the rear of the hotel. Not all that glamourous I grant you, but plant associated with hotels of this scale more often than not have planning implications. This saw me move on to assisting in securing permissions (both planning and Listed Building Consent) for works to extend the late 1980’s leisure wing to incorporate an elevated gin terrace for guests and diners of the Great Scots Bar. I am happy to report the terrace supported its first marriage proposal shortly after it opened. Early feasibility work into the potential to develop a bedroom and ballroom extension to the hotel followed but was put on hold when extensive damage was caused to the historic core of Cameron House in December 2017. Lichfields had an instrumental role in securing the relevant planning permissions and listed building consents to reinstate the building and get the hotel back up and running. The degree of interaction with the salvage and reclamation, redesign and rebuild of the hotel was complex and extensive. Key to the enabling of these works was a constructive and pragmatic relationship with the Local Planning Authority (LPA), in this case the Loch Lomond and the Trossachs National Park Authority. Officers of the National Park Authority have provided an exemplar planning service in reacting swiftly and with flexibility in response to fast moving circumstances arising from a damaged Listed building which required intervention. Consents required to facilitate this process have included implementation of a salvage and reclamation strategy through Listed building consent to enable emergency demolitions to take place, with regularisation applications post-event. Temporary access proposals saw the upgrade of a historic access to the south of the estate to allow guests to visit those facilities that remained open while construction had exclusive use of the principal access onto the trunk road network. This temporary solution has resulted in legacy benefit through the retention of a newly resurfaced route from Balloch to Cameron House. Interestingly for a planning consultant we were on site working hand in hand with the architects and contractors as the project evolved. While reinstatement work progressed, bedroom and banqueting extension works resumed. Planning permission and Listed Building Consent were sought and approved, in close collaborative work with the LPA. The principal applications were supplemented by an array of other associated applications including:   Amendment of a historic legal agreement to update a Land Management Plan which will see the appropriate management of the historic estate into the future;  Permission to establish and implement a lighting management plan;  Advertisement consents in and around the estate;  Installation of extensive plant within the estate;  Refinishing existing and retained hotel components; and  Multiple variations requiring NMVs and discrete stand-alone Listed Building Consents. Our work on this estate over some 14 years demonstrates the planning needs of a 5-star luxury hotel in a historic setting that needs to invest and change to remain at the top of the game. It is a testament to the work of the owners that the hotel has evolved to meet the changing aspirations of its customer base and the diligent work of the National Park Authority to effectively regulate this evolution. The Cameron House of today is a luxury five-star resort. It boasts a magnificent new grand foyer, library, and a brand-new Lobby Bar serving the finest champagnes, cocktails and afternoon teas. Today the Cameron House Hotel offers 140 guest bedrooms, including 24 luxury suites, a completely remodelled Cameron Leisure Club and The Tavern Bar. The wider Cameron House Resort is also home to an award-winning spa complete with a rooftop infinity pool, an 18-hole championship golf course, and a 234-berth marina. Guests can enjoy an array of water activities along the banks of Loch Lomond, including adrenaline-fueled speed boat and jet-skiing trips, kayaking and katakanu excursions, as well as peaceful paddle boarding, fresh-water fishing, or opulent champagne cruises onboard the impressive Celtic Warrior. Visitors can enjoy unparalleled views through scenic bike hire trails, falconry experiences, pony treks, clay pigeon shooting, 4x4 off-road driving adventures, Segway safaris, as well as a list of picturesque walks and hikes curated by the hotel’s leisure and events team. It has been a pleasure to have played a small part in the history of Cameron House, ensuring this beautiful hotel resort remains one of Scotland’s premier tourism destinations.  


Tourist Accommodation in Edinburgh: more not less is needed…
Edinburgh’s comeback festival season 2022 has injected some much-missed hustle and bustle back into the Scottish capital’s streets, no doubt welcome relief to the local hospitality and retail sectors across the city that have endured a turbulent few years. Drawing eye watering numbers of visitors to the city each year, the cultural bonanza has become an essential component of many businesses in the area whose fortunes hang on the success of this part of the calendar. Those in the know are predicting that the staycation market will remain strong beyond 2023. This is not surprising given many are still reluctant to travel overseas and that many have had positive experiences of holidaying in the UK over the past couple of years visiting places they had never been before or returning to old haunts.  Overseas travellers are also expected to return but perhaps more slowly and business travel is anticipated to reach pre pandemic levels again by 2024. Hotel occupancy is strong in the city throughout the year, with peaks in the summer, room occupancy rates[1] were over 80% in May – September 2019. With the exception of January and February other months are also relatively strong (room occupancy over 69% in 2019) with the winter festivals, marathons, rugby and concerts, not to mention all the rest the city has to offer, making Edinburgh a year-round tourist draw. The pandemic had a considerable impact on these numbers but figures for April 2022 suggest that room occupancy levels are returning to 2019 levels (74.22%).  Figure 1 compares hotel occupancy data from Visit Scotland for Edinburgh and the Lothians in 2019 and 2021. The most up to date and comprehensive published information on tourist accommodation on Edinburgh is 2019 based. This is a report prepared for the City Council by Ryden and GVA.   It sets out that in 2019 there were 167 hotels in Edinburgh providing 13,180 bedrooms, there were 40 serviced apartment buildings providing 1488 apartments. 38% of the hotel rooms were in the 2 star / budget sector, 54% were 3 / 4 star and 8% were 5 star.  There are no budget serviced apartments, 28% are upper midscale, 50% are upscale / upper upscale and 22% are luxury class.  In 2019 there were 15 hostels with 457 bedrooms, 200 guesthouses / B&Bs with around 1300 bedrooms and there are 35 student halls with rooms available to rent during the summer. In addition to this there are great number of bed spaces available in Edinburgh that are short term lets, sometimes referred to as Airbnbs. In the quarter to September 2021 there were 4,168 whole properties listed on Airbnb and 1894 single rooms within the Edinburgh City boundary.  Airbnb list shared rooms but these are mostly in hostels and some hotel rooms but these are not reported here as they form part of the formal tourist accommodation stock. Given these findings it is reasonable to assume that in the key summer period the following accommodation is available in Edinburgh:  13,180 Hotel bedrooms 1,488 Serviced Apartments 457 hostel bedrooms 1,300 B&B/Guesthouse bedrooms 4,168 Airbnb whole properties 1,738 Airbnb private bedrooms Contrary to reports in the press pre pandemic that there were too many hotel bedroom in Edinburgh recent reports in the press suggest that there wasn’t enough reasonably priced accommodation available for festival goers and artists this year and some have said this threatens the future of the Fringe. Hotel rates benchmark against each other but private short term lets can go for huge sums if there is huge demand and this can price many out of the market.  Similar, issues arose in Glasgow last year with accommodation for COP26.  Added to this, there were also reports of the soaring homelessness problem in the city and the lack of both temporary accommodation, now that hotels couldn’t be used as they were during the pandemic, and shortages of permanent accommodation given the number of properties used for short term lets. So, there are 2 wants here (1) more accommodation in August for visitors and (2) more accommodation all year round for residents.   Expected changes to the make up of tourist accommodation in Edinburgh Hotels, Service Apartments and hostels There are a number of new hotels in the pipeline. Given current consents and construction activity since 2019 we can be reasonably sure that there will soon be over 16,000 hotel bedrooms in the city.  In terms of serviced apartments there are 506 additional bedrooms with planning approval or under construction bring in this to total to nearly 2000 additional bedrooms.  There are 2 hostel schemes with a total of 30 bedrooms also approved.   Short term lets As measures introduced by the Scottish Government to address the short-term let (STL) phenomenon begin to bite and the numbers of STLs in the city can be expected to begin to drop. The number of Short Term Lets in Edinburgh is well publicised and various data sources are available. The most popular booking platform, Airbnb is the most interrogated but others such as do play a role. Inside Airbnb is a website that seeks to “add data to the debate”.  The data collected by Inside Airbnb indicates that for the quarter ending September 2021 47% of whole properties listed were listed by a host with more than 1 property. Some of these hosts are agents for individuals but it is fair to assume that these properties are all being let commercially and that these are not family homes being let while people are on holiday.  There will be hosts that have only listed 1 property who are also letting commercially.  It is difficult to calculate with any great accuracy from the data how many that might be so we have assumed that if you have more than 4 reviews in a quarter you are probably letting that property commercially.  There are 1,165 listed whole properties that have had 4 reviews or more suggesting multiple lettings.  It is impossible to verify this data and Lichfields do not take any responsibility for its accuracy.  It is used here simply to paint a picture of what might be assumed to be going on in the city. As Lichfields has previously blogged, the requirement for licensing and the STL control area could significantly reduce the number of properties that are available to rent via Airbnb and other platforms. Edinburgh’s Short Term Let Control Area is now in force. Implemented from 5 September 2022, this control area covers the entirety of the City of Edinburgh Council area. This means that the use of a dwelling as an STL, in certain circumstances, will constitute a material change of use and planning permission will be required. In addition, from September this year, the Scottish Government’s licencing regime will commence, with a requirement for all STL properties to be licensed by July 2024.This will include evidence of planning permission or evidence that it is not required. Licence requirements will apply to all STLs, including homeowners renting out a single room or their whole home for short periods while on holiday. It is difficult to accurately predict the likely impact of these measures. The Council of course are hoping it is significant and a great number of short term let properties become available for long term residents instead.   Conclusions In conclusion more accommodation is needed in the city for residents and tourists alike. The hotels are pretty much at capacity during the summer period and there will be less short-term lets in the future.  New purpose-built affordable tourist accommodation is needed to replace the short term let stock that will be lost.  Hotel developers, operators and investors should start sharpening their pencils.    [1] Hotels - Occupancy Statistics & Surveys |