Do City officials really back plans which have “no regard to the need for flexibility and realism”?

Behind the headlines last week that Aberdeen City planners were backing the Kingsford stadium proposal, which city councillors will determine tomorrow; if you have had time to read the plus-100 pages of the planners’ reports, you will find many contradictions and repeats of the word “nevertheless” and you may be left wondering why such a “willingness to approve subject to conditions” has been put down in black and white when planners state that “the applicant has not demonstrated the necessity of a single 25ha site”, “the location is not readily accessible by sustainable modes of transport”, and “the applicants have not demonstrated that proper consideration was given to accommodating the development in a different form, and having regard to the need for flexibility and realism”.

The report starts off with summaries of the representations; using the planners’ words. Where I have added my own words, these are in italics. I have highlighted some words in bold for easier reading. These issues, to my mind, have not been adequately addressed in their evaluation.

Roads Management Team, ACC
• Provision for travel to non-football events has not been made clear.
• Correspondence from the bus station’s commercial manager indicates that there is capacity to accommodate 10 additional X17 services per hour, but there is no mention of capacity to accommodate shuttle buses at the bus station
• The use of additional parking provision at Arnhall Business Park is an arrangement that would not normally be permitted. There is uncertainty over long term retention of any such spaces to be secured at Arnhall through similar arrangements, undermining aims to promote sustainable travel.
• There are concerns over the main access, principally in terms of road safety. Access arrangements of any description will likely place a burden on Police Scotland. Since Aberdeenshire Council just last week agreed not to decriminalise parking, a CPZ is unlikely to be top priority with Police Scotland in light of the extra burden on site at the stadium.
• The proposed signalisation of the AWPR/A944 roundabout could remove any potential queue back onto the AWPR mainline, but to the detriment of the local road network.

SDPA
• Restated earlier position that the development in its current form and location does not accord with the SDP, would result in the loss of 25ha of Green Belt land and the coalescence of urban areas. The development is inappropriately sited, giving rise to unsustainable travel patterns in a manner contrary to the modal shift sought by the SDP. Further, there would be a negative impact on the city centre.
No indication is given on the potential visual impact of the footbridge on this important entrance to Westhill.

Aberdeenshire Council
Restates position that the economic impact on Aberdeenshire is likely to be fairly modest. Notes that there is no specific consideration of the impact on Westhill town centre, and highlights the negative impact due to loss of trade from customers avoiding or being unable to enjoy the existing level of convenience is an area of concern.

WECC
AWPR is not designed to facilitate development, but to alleviate congestion around Aberdeen. There would be a huge disruption to the local community on matchdays.

The report then goes on to discuss the Development Plan

DEVELOPMENT PLAN
D3 Big Buildings –
The most appropriate location for big buildings is within the city centre and its immediate periphery. Big buildings must be of a high quality design which complements or improves the existing site context.

SDP
The SDP sets out a series of key objectives for the growth of the City and Aberdeenshire. It is framed around a vision, spatial strategy and a series of aims and objectives; with those relating to economic growth, sustainable mixed communities, quality of environment and accessibility being the most relevant to this application. The SDP sets a strong framework for investment decisions, and its purpose is to focus the right development in the right places and to prevent inappropriate and poorly located development.

In terms of the plan’s spatial strategy, the proposed stadium falls within the outer edge of the Aberdeen City “Strategic Growth Area”. The plan explicitly supports the principle of the development of a “new community stadium, a regionally important facility which will bring economic, social and cultural benefits”. Two possible locations are identified – on and around the current stadium site at Pittodrie/Kings Links and to the south of the city as part of the Loirston development.

MATERIAL CONSIDERATIONS
National Planning Policy and Guidance
In terms of promoting sustainable transport and active travel, paragraph 287 of SPP states in relation to Development Management functions that “Planning permission should not be granted for significant travel-generating uses at locations which would increase reliance on the car and where:
• Direct links to local facilities via walking and cycling networks are not available or cannot be made available;
• Access to local facilities via public transport networks would involve walking more than 400m; or
• The transport assessment does not identify satisfactory ways of meeting sustainable transport requirements.

EVALUATION
I have left the reference numbers on if you want to refer to them in the report.

9.2 The proposed development relates to a site allocated in the Green Belt….. other elements (most notably the stadium itself) would cause a degree of harm in terms of the main aims of the Green Belt Policy. This is because of the dominant size of the stadium would intrude into, and erode, a green buffer which visually separates existing settlements of Kingswells and Westhill and contributes to maintaining their separate identities. Nevertheless, sufficient information has been submitted by the applicant to enable the officers to conclude that there are no other sites within Aberdeen and the area covered by the ALDP that would be suitable….

9.4 The applicant has not definitively demonstrated the necessity of a single 25ha site, but the planners go on to say…. Nevertheless…

9.5 …. The location, within the green belt, is not readily accessible by sustainable modes of transport…. This would be mitigated to some extent by shuttle buses (where there is no guarantee they could be facilitated at Aberdeen Bus station) … together with the provision of off-site parking (again the Arnhall parking has not been guaranteed, and cannot be).

9.38 Co-location of Stadium and Training Facilities
The question of ‘need’ is central to consideration of this application. ‘Need’ is relevant to the overall assessment of the application and its Kingsford location against the LDP. The personal circumstances of the applicants are of limited relevance. The planners go on to say that “the extent to which they are reliant on a co-located development is considered to remain unsubstantiated. Put another way, there is no compelling evidence provided to demonstrate that these same benefits could not be reasonably achieved with a new stadium and training facilities in separate locations”.

The Aberdeen City Council LOIP as mentioned under 9.56 in that it supports the work of AFCCT would stand wherever the trust is based. Both Aberdeen City and Aberdeenshire Council provide financial support to AFCCT and the trust would continue to operate successfully from their various outreach centres within city and shire, regardless of where they are based.

9.59 It is considered that the potential benefits of the proposed development have been demonstrated. However, there is no evidence to suggest that the benefits identified are unique to the Kingsford location.

9.63 The applicants’ requirements for (i) a single, co-located development comprising stadium and training facility; and (ii) a site of at least 25ha – are not decisive. The Council requires to be persuaded that they are justified in the planning context.

9.64 On that basis, it is therefore considered that in developing their proposals in accordance with the relevant policies, the applicants have not demonstrated that proper consideration was given to accommodating the development in a different form, and having regard to the need for flexibility and realism.

9.65 There appears to have been little consideration given to sites other than those which could accommodate the applicants’ stated requirements for co-located facilities. However, even if there is a need for co-location, the Council still requires on that basis to be satisfied that the sequential approach has been properly addressed. The expectation remains that the applicants will assess alternative sites having adopted a flexible and realistic approach. It appears that the proposal has evolved without proper consideration being given to whether development in an alternative form would, or could, be more appropriate. It is considered that the applicants have not adopted the flexible approach required.

9.66 It is noted also that the alternative sites considered by the applicants in the Environmental Statement and in the later statement on ‘Co-Location, Site Selection and Sequential Test’ refers to ‘advantages and disadvantages’ throughout, with the ES concluding that the alternative sites present no ‘significant advantages’ to the Kingsford site. This is a further indication that the applicants have approached the consideration of alternative sites and application of the sequential approach from a perspective of advantage to the applicants’ interests, rather than an objective assessment. This approach is reinforced by the November 2017 Supporting Statement, which refers (at 2.15-2.18) to capital costs and operational expenditure as guiding AFC’s consideration of sites.

9.68 The preceding text explains why it is considered that the applicant has not carried out the sequential approach with flexibility and realism in accordance with SPP, ALDP policy and case law.

Some further paragraphs contradict some of the previous statements by saying such as (re Loirston) “sale of land within Loirston site is not ruled out, however Hermiston’s letter confirms that full residential value would be sought”.

9.102 It should be noted that the lack of suitable, deliverable and available sites in sequentially preferable locations does not in itself justify the application site at Kingsford.

Transport and Accessibility
The initial TAA incorporated a further supporter survey, carried out by Aberdeen and Grampian Chamber of Commerce (AGCC). Whilst the sample size and return rate are considered sufficient to provide a representative sample, the Council’s RDM Team has expressed concern regarding the methodology used in conducting this survey. The AGCC survey, in addressing chosen mode of travel, relates entirely to travel to the current Pittodrie site. The survey results seem to back up a view that people will walk further to football matches than might otherwise be assumed, and therefore demonstrate that the city centre and its public transport connections across the region are relatively accessable from Pittodrie. By contrast, the Kingsford site is in a peripheral location on the edge of the city, where it would be heavily reliant on a combination of car borne travel and dedicated match day shuttle services from the city centre.

The requirement of a CPZ will need to be addressed through a “Grampian condition”. This type of condition is used to grant permission which is conditional upon something else happening first (in this case the requirement for implementation of a CPZ) but without specifying who is responsible for its implementation. A further Grampian condition would be required for the footbridge across the A944. A third Grampian condition would be required to upgrade the core paths.

City Councillors have a task ahead of them tomorrow. I would hope that the following statement within the report is foremost in their minds:

THE GREENBELT AT KINGSFORD SEPARATES EXISTING SETTLEMENTS OF KINGSWELLS AND WESTHILL, AND THEREFORE HAS VALUE IN DEFINING THE OUTER BOUNDARY TO ABERDEEN, PREVENTING COALESCENCE BETWEEN KINGSWELLS AND WESTHILL, AND MAINTAINING THE IDENTIDY OF THESE RESPECTIVE SETTLEMENTS. THE PROTECTION OF GREENBELT LAND FROM DEVELOPMENT IS CONSISTENT WITH SPP’S STATED EXPECTATIONS OF A ‘PLAN-LED’ SYSTEM, WHERE THE LOCATION OF NEW DEVELOPMENT IS DIRECTED BY DEVELOPMENT PLANS, AND PLANS ARE BOTH UP-TO-DATE AND RELEVANT. AT TIME OF WRITING, THE ALDP HAS BEEN ADOPTED FOR A LITTLE OVER 12 MONTHS OF ITS INTENDED 5 YEAR PERIOD, AND THEREFORE REPRESENTS AN UP-TO-DATE FRAMEWORK WITHIN WHICH PLANNING APPLICATIONS MAY BE DETERMINED WITH A HIGH DEGREE OF CERTAINTY.

To be clear, I acknowledge the body of support for a new stadium at Kingsford. I support the club in its aspirations for a new stadium. When determining planning applications, councillors are acting in a quasi-judicial basis. This means they are more tightly governed by legislation than most of the other decisions they make and should take heed of their own Local Development Plans (LDPs) and planning policies. The LDP allows democratic discussions about land use and all applicants are afforded equal opportunity to make bids for sites at the appropriate time. Equally, residents are afforded the same chance to have their say on any bids. Developers are well aware of the time scales for bids. Both developers and the public must have confidence in the local planning process. Approving this development would undermine this trust.

Full report can be accessed here.

 

 

3 thoughts on “Do City officials really back plans which have “no regard to the need for flexibility and realism”?

  1. William Skidmore says:

    An excellent piece of work that raises serious questions and many doubts about the competence of the ACC report and recommendation. ACC officers acknowledge that the application contravenes all of the relevamt development plans and Local and Scottish Planning policies. Nevertheless, it is their view that the economic case outweighs all other matetial considerations and on that basis alone, they recommend approval.

    ACC officers might argue that the authors said they appllied the guidance contained in the HM Treasury Green Book to the development of the economic case. But that does not absolve ACC officers of the responsibility to apply the HM Treasury Green Book to a critical assessment of the evonomic case put before them. Others have done that and found that it does not stand up to scrutiny.

    Therefore, there are no material considerations that would justify the the release of 25 hectares of Green Belt 7 miles from the city centre for a football stadium.

  2. Norman Smith says:

    I don’t think the Shire have left any green belt land on their side of the boundary with the city so why should the city pay heed to their complaints about the city approving this development on their side of the boundary. Who approved the development at Arnhall which has ruined the southern entrance to Westhill, the Shire of course. The Shire council should put its efforts into improving sports facilities in Westhill instead of objecting to a privately funded development that will improve immensely sports facilities for Westhill youth. I hope the City do the right thing and approve AFCs plans.

  3. Simon says:

    Fully support your article, thanks for being so tenacious Iris. The Planner’s report shows their level of discomfort.

Leave a Reply

Your email address will not be published. Required fields are marked *