HOW TO OBJECT

Balmullo Quarry Extension - How to Object to the Planning Application

The planning application to extend the quarry at Lucklawhill is available for objection on the Fife Council Planning portal. The closing date has been set as Saturday 28th March 2026.

Balmullo Quarry has been in operation for about 100 years but its next phase, if the quarrying company Breedon gets its way, could be the most significant yet. The proposal is to take away an area of over 3 hectares (7.4 acres) from the top of Lucklawhill which will increase the size of the quarry significantly. The shape and character of Lucklawhill will be irrevocably changed.

If this application is approved, further applications on Lucklawhill can’t be ruled out because Breedon has control of most of the hill top including the mast area.

Click here to view the 3D video

We would lose access to paths that have been used possibly for centuries to approach the hilltop and a vast area of extremely rare heathland habitat (Annex 1 heathland is globally rare). Wildlife that depends on this habitat will be lost with it because they cannot move to other similar habitat (they are ecologically isolated). Over 750 species have been formally recorded on Lucklawhill including rare butterflies and moths, highly protected birds (red listed) and highly protected mammals such as red squirrels and pine marten.

We will gain at least another twenty years of exposure to silica dust from blasting, exposed stockpiles of processed rock and from the lorries transporting it. This dust is a health risk and small particulates (PM2.5), which travel further, can get into our bloodstream. They are linked to many serious diseases including lung cancer, cardio-vascular disease and autoimmune disease. Balmullo village and the primary school are within a kilometre of the Quarry and all of it is within the area that these small particulates can reach.

Why Should I Object?

Fife Council will need to take this planning application very seriously because of its major impact on the local area. The Save Lucklawhill Community Action Group (SLCAG) will be objecting to the application but the more objections the Council receives from individuals the better. Everyone in a household can object, including under 18s who can write a meaningful objection.

Won’t the Quarry Extension Go Ahead Anyway?

No, it can be stopped. Councillors on NE Fife Planning Committee have the power to refuse the application. SLCAG considers that there are so many planning problems with the extension that Council officers should recommend refusal. Breedon can appeal a refusal but appeals are not always successful. In April 2023, Aberdeenshire Council’s decision to refuse an application for a quarry was upheld by the Reporter appointed by the Scottish Government even though the Council went against their officers’ recommendation to approve. Examples such as this show that if the local opposition is strong enough and well-argued, planning proposals can be fought off.

Where Do I Send My Objection?

Use the Fife Planning Portal (just type that in Google) and click on the link. On the front page click on the Fife Council On Line Planning System button and search “Balmullo Quarry” to find the application for the extension

Or try these links:
https://www.fife.gov.uk/kb/docs/articles/planning-and-building2/planning/planning-applications/view,-track-and-comment-online

https://planning.fife.gov.uk/online/applicationDetails.do?keyVal=SRKK5EHFMSU00 &activeTab=summary

Easy to do – first register (contact information) then tick “Object” and type your reasons – see below. It is best to type your comments in Word first and then cut and paste them into the portal so that you are not timed out. You cannot add attachments.

Email development.central@fife.gov.uk with the Application Reference Number: 25/00418/EIA in the subject and in the text
You can add attachments (which must not be secure). There is no word limit but try to keep it concise. Write “I object” or it is just a comment.

Post (we advise using this method ONLY if you have no internet access).
Write your address, the Planning Application Reference Number 25/00418/EIA and the address of the Quarry:

Breedon Balmullo Quarry,

Quarry Road,

Lucklawhill,

Balmullo,

St Andrews

KY16 0BH.

Make sure you write “I object” otherwise it is just a comment.

How to Object Effectively

Objections hold most weight if they are well argued. This is not difficult - the key is to use planning material considerations to argue your case. For the most part these are the obvious negative effects from a quarry extension and are listed below. (Please note that a negative impact on house prices or the ability to sell your house are not legitimate arguments against a planning application and will be ignored.)

Residential amenity - for example noise and dust generated by the quarry
Visual amenity and landscape - what the quarry extension will look like
Recreational use of the hill - restrictions and loss of access for walkers, footpaths and rights of way as a result of the quarry extension
Ecology - flora (for example the globally rare heathland and ancient woodland) and fauna (for example, red listed birds, red squirrels, pine marten, rare butterflies and moths) that will be affected by the quarry. Click to see “Biodiversity” page.
Road access and road safety Hydrology and drainage - the effect a quarry extension could have on flooding locally
Archaeology and local history Supply of minerals - is there a demand for the mineral being quarried?

On the supply of minerals – Breedon’s own figures show that it has at least 10 years supply of rock in the existing quarry. There are also existing planning permissions for minerals to meet demand well into the foreseeable future for both Fife and East Central Scotland.

Please note that the Petition on our website will count as ONE objection. If we had supplied a template letter, all of those submitted would count as one objection and so we have not provided one or anything that might lead to that assumption. It is important to write your objection in your own words but we have provided the information below and throughout the website to help you.

The role of planning conditions

It is usual if there are local concerns which can be ameliorated by a developer (in this case the quarrying company) for the Council to deal with this through planning conditions, for example the quarry’s working hours can be restricted and noise
levels limited. Local experience has shown that planning conditions have not been effectively followed or monitored at Balmullo, but this will not stop the quarrying company suggesting them as ways around negative impacts. The most effective objections are those which cannot be mitigated through planning conditions. The most obvious example is the removal of part of the top of Lucklawhill which once removed can never be replaced. Also, wildlife such as butterflies and moths, once lost from the site will not return because their habitat has been destroyed.

How To Use Planning Policy

It also helps to strengthen your objection if you can refer to a planning policy which supports it. There are two levels of planning policy:

National: the National Planning Framework (known as NPF4) which is Scotland-wide
Local: the FIFEplan which contains the local policies.

Planning policies change over time and the more recent policies, such as NPF4 from 2023 put more emphasis on environmental protection and the climate emergency than the FIFEPlan from 2017 which is now somewhat out of date. Here are the links to the complete documents:

www.gov.scot/publications/national-planning-framework-4/

www.fife.gov.uk/kb/docs/articles/planning-and-building2/planning/development-plan-and-planning-guidance/local-development-plan-fifeplan

The most relevant sections of the documents are reproduced below. Quoting the relevant policy number which supports your specific objection will help. You could also quote the text from either of the documents - all the text in italics below is taken straight from the documents. We have put the policy titles and most significant wording as it relates to Lucklawhill in bold.

NPF 4 - National spatial strategy

The following extracts have been directly quoted from Part 1 - A National Spatial Strategy for Scotland 2024
“Scotland’s future places will be net zero, nature-positive places that are designed to reduce emissions and adapt to the impacts of climate change, whilst protecting, recovering and restoring our environment.

Policy 1 gives significant weight to the nature crisis to ensure that it is recognised as a priority in all plans and decisions. Policy 4 protects and enhances natural heritage, and this is further supported by Policy 5 on soils and Policy 6 on forests, woodland and trees.

Most significantly, Policy 3 plays a critical role in ensuring that development will secure positive effects for biodiversity. It rebalances the planning system in favour of conserving, restoring and enhancing biodiversity and promotes investment in nature- based solutions, benefiting people and nature…Development proposals for national, major or Environmental Impact Assessment (EIA) development will only be supported where it can be demonstrated that the proposal will conserve, restore and enhance biodiversity, including nature networks, so they are in a demonstrably better state than without intervention. Proposals for local development will include appropriate measures to conserve, restore and enhance
biodiversity.”

(The planning application for the extension to Balmullo Quarry falls within Policy 3
because it requires an Environmental Impact Assessment (EIA))

Policy 33 Minerals (extract below)

“d) Development proposals for the sustainable extraction of minerals will only be supported where they:

i. will not result in significant adverse impacts on biodiversity, geodiversity and the natural environment, sensitive habitats and the historic environment, as well as landscape and visual impacts;

ii. provide an adequate buffer zone between sites and settlements taking account of the specific circumstances of individual proposals, including size, duration, location, method of working, topography, and the characteristics of the various environmental effects likely to arise;

iii. can demonstrate that there are no significant adverse impacts (including cumulative impact) on any nearby homes, local communities and known sensitive receptors and designations;

iv. demonstrate acceptable levels (including cumulative impact) of noise, dust, vibration and potential pollution of land, air and water;

v. minimise transport impacts through the number and length of lorry trips and by using rail or water transport wherever practical;

vi. have appropriate mitigation plans in place for any adverse impacts;

vii. include schemes for a high standard of restoration and aftercare and commitment that such work is undertaken at the earliest opportunity. As a further safeguard a range of financial guarantee options are available, and the most effective solution should be considered and agreed on a site-by-site basis. Solutions should provide assurance and clarity over the amount and period of the guarantee and in particular, where it is a bond, the risks covered (including operator failure) and the triggers for calling in a bond, including payment terms.”

FIFEplan (2017)

“5. In the case of proposals in the countryside or green belt, be a use appropriate for these locations (see Policy 2 Homes, Policy 7 Development in the Countryside, Policy 8 Houses in the Countryside, Policy 9 Green Belt and Policy 11: Low Carbon Fife);

6. Protect sport and recreation facilities and the amenity of the local community and businesses (See Policy 3 Infrastructure and Services and Policy 10 Amenity);

7. Safeguard the character and qualities of the landscape (see Policy 13 Natural Environment and Access, and Policy 15 Minerals);

8. Avoid flooding and impacts on the water environment (see Policy 12 Flooding and the Water Environment);

9. Safeguard or avoid the loss of natural resources, including effects on internationally designated nature conservation sites (see Policy 13 Natural Environment and Access and Policy 15 Minerals);

10. Safeguard the characteristics of the historic environment, including archaeology (see Policy 14 Built and Historic Environment);

11. Not compromise the performance or safety of strategic infrastructure or, alternatively, assist in the delivery of necessary improvements to mitigate impact arising from development (see Spatial Strategy diagram).”

FIFEPlan Minerals Policy (2017)

Policy 15: Minerals
Development proposals for the extraction of minerals, coal bed methane, shale gas, or coal bed gasification, including associated infrastructure, will only be supported where they:

1. do not result in an unacceptable impact on communities, the environment, or the economy;
2. provide for restoration and aftercare to a high standard, including the provision of an appropriate guarantee, such as bonds or other financial guarantees; and
3. in the case of aggregates, facilitate a minimum 10 year landbank of permitted reserves for construction aggregates at all times in all market areas.
Consideration will also be given to the benefits the development may bring to the local or national economy. More detailed advice is contained in the Minerals Supplementary Guidance and attention is drawn to the restrictions on peat extraction which reflect Scottish Planning Policy (see also Policy 13 Natural Environment and Access).
Minerals sterilisation
Minerals that are, or may be, of economic or conservation value will be protected from development which could prevent or jeopardise their extraction. Prior extraction of minerals should be facilitated and encouraged for any substantial new development sites, in line with national policy, with the aim of preventing sterilisation of minerals.

Extension and restoration of mineral workings
Proposals for mineral working will be supported if they will result in the restoration of previously worked areas where the earlier restoration has not been completed to a high standard, or which have left a legacy of ground instability. Extensions to existing quarries will be preferred to establishing new quarries.
An appropriate buffer zone between site boundaries and settlements must be provided to safeguard the amenity of houses and occupied properties.
Areas of search
All minerals applications will be considered within the context of the areas of search for surface coal, and sand and gravel as highlighted in the accompanying mapping.