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.

• 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.

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

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.

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.

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.

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:


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.



National Planning Review unlikely to improve local situation, councillors tell Government

Scottish Government proposals to overhaul the planning system in Scotland are unlikely to have any positive effect in meeting the demands and aspirations of communities and the development industry, say councillors.

Aberdeenshire Council’s Infrastructure Services Committee (ISC) has written to the country’s Chief Planner in response to a range of changes being proposed at a national level.

Councillors and planning officials believe the current approach to strategic and local planning in the area works well and the proposed changes take decision making further from local communities.

There is particular concern over a lack of detail around proposals to replace the role of the Strategic Development Plan (SDP), which currently provides a long term strategy for future growth.

It also guides the production of Aberdeenshire’s Local Development Plan, which provides a blueprint for the development of the area, ensuring a consistent approach to planning applications.

The Government’s current intention is to replace Strategic Development Plans with Regional Partnerships and officers and councillors are concerned about the lack of detail so far.

Its Places, People and Planning consultation asked Scottish councils for their opinions on plans to bring forward a Planning Bill in the near future, which is part of a wider programme of work aimed at strengthening “planning’s contribution to inclusive growth and empowering our communities”.

Now ISC chairman, Peter Argyle, has written to the Scottish Government on behalf of the committee to set out the council’s thoughts on a Position Statement which outlines the changes the Government is considering.

The Position Statement was published following an independent review of the planning system, published in May 2016, and a subsequent consultation on 20 proposals for improvement.

Aberdeenshire Council has already responded to the initial consultation, and has now given its opinion on proposals for changes which have emerged as a result.

There is particular concern around timing as the north-east needs, at the very least, a transitional arrangement to ensure up-to-date development plans are in place throughout any period of change.

Cllr Argyle said: “This council’s most immediate concern is the lack of detail around measures to replace the role of the Strategic Development Plan and the means of engaging over regional spatial strategy and, in particular, housing requirement.

“The Council welcomes change where benefits can be evidenced but, in the context of the north-east of Scotland the current arrangements have worked very well and there is not as yet sufficient evidence or detail around a replacement system to demonstrate that it will improve on the current system.

“One size does not fit all and there is a lack of evidence that the proposals will improve the process or performance of the system in delivering infrastructure and further housing.”

ISC vice chair, John Cox, added: “The current barriers to development, particularly housing, are the physical cost of development and the demand within the local markets, not the planning system or its processes.

“The changes being proposed would also remove political control from the local area, taking it to the centre, and would also potentially give developers the opportunity to renege on agreements made for contributions to improve infrastructure impacted upon by their developments, known as Developer Obligations.

“The committee wanted to reinforce the resource implications of the proposals for all councils and the need to improve trust in planning processes, which the current proposals do not assist.

“There is nothing that gives me confidence the process will be easier, quicker or more efficient, basically failing most of the objectives. Plain and simple, this would be a further erosion of the local democratic process and accountability, driven by lack of funding.”

Councillors have also expressed their concern about the fast pace of the consultation and the emerging legislation, fearing it may lead to errors.

The Government’s Position Statement states no final decisions have been made on the content of any future legislation at this stage.

Pre-Determination Hearing date for Kingsford Stadium set

CORRECTION: Please note individual letters to those who submitted a representation will NOT be sent out due to the huge volume. Letters have only been sent to consultees. Look out for public notices in the press over the next few days (I will copy here also) giving full details of who to contact if you wish to speak at this meeting. Those wishing to speak will be encouraged to group together with other like-minded supporters/objectors so that points are not repeated and that the time allocated to each speaker can be used effectively.

Aberdeen City Council last week issued a letter to all who submitted a representation notifying them of the Pre-Determination Hearing to be held on Wednesday 13th September 2017 at 9.30am in the City Council Chamber. Before this hearing, city councillors will undertake a site visit to Kingsford on Monday 11th September, leaving the Town House at 2pm. Members of the public can attend the site visit but are not permitted to lobby members or to participate.

The Hearing on 13th September will follow this procedure:

Convenor: Opening remarks, purpose and procedures set out;

Case Officer: summarises the planning application and material considerations;

Other services/external consultees (as relevant): detail aspects of the application/impact/issues;

Applicant: presents proposal;

Community Council for the area: present their observations;

Objectors/supporters: state their case;

Elected members: can ask questions of officers, consultees, applicant, Community Council, objectors and supporters after each presentation. Also opportunity to ask for additional advice and information from officers;

Convenor: Concludes session, following which the Head of Planning and Sustainable Development will prepare a report for submission to Full Council for subsequent consideration.

I have asked for information about who will represent Aberdeenshire Council at this Hearing and await a response.


Places, people and planning

The Scottish Government have now issued a Position Statement following the last round of consultations on review of the Scottish Planning system which closed in April 2017. This statement describes the key changes that Scottish Ministers are now considering taking forward through the forthcoming Planning Bill. Further responses on this Position Statement can be lodged up until 11th August 2017.

Some of the key proposals for the Planning Bill include:

  • The ability for communities to product Local Place Plans for incorporation in to the Local Development Plan
  • Introduction of a statutory link between development planning and community planning
  • Overhaul of the Local Development Plan process – the Main Issues Report stage will be replaced by early engagement and a ‘gate check’ followed by formal consultation on the draft Plan. LDPs will have a 10 year timescale with the opportunity for updates between full review cycles
  • Requirement for enhanced public engagement on planning applications for sites that are not allocated in the Local Development Plan and more proportionate pre-application consultation for allocated sites
  • Measures to strenghten enforcement against breaches of planning control
  • Mandatory training for Councillors serving on Planning Committes or Local Review Bodies
  • Proposals for nationally set housing land supply targets appear to have been rejected
  • Developers to include information on viability of sites and development delivery as part of the development plan process

Local authority planners, councillors as well as community councils and residents input greatly to the various consultation processes previously and it is good to see some of the issues raised being included in this Position Statement. The Statement can be accessed here along with the link for further comment on any of the proposals.

What’s behind the headlines as AFC ramps up stadium plans?

Love them or hate them, the No to Kingsford Group (NKS) continue to be painted the villains against the beloved Dandies as determination of AFC’s planning application for a new stadium looms nearer. The story paints a picture of the heroic Reds, struggling to score all things good against one dastardly group who don’t know what’s good for them. For those who don’t read beyond the headlines, any stadium built of course will be first-class if it is in the right location, but the story is a little more complicated than one lone group’s objection against “very localised issues”.

Back in May, the club submitted additional information to Aberdeen City Council to try to address some of the outstanding issues from their original submission some months earlier. Statutory consultees were invited to comment as well as representations being open for the public to comment on the new information. You can read all the new documents online at the AFC link on the right hand side of my page.

Aberdeen City Council’s Roads Development Management team have highlighted a host of outstanding issues not addressed in this second round of documents from the club. New information on trip generation, modal split and trip profiles of the proposed development has emerged with no new scoping details, nor has “the altered methodology been scoped with the Council and agreement has not been sought as would normally be expected.” Police Scotland has not confirmed in writing that they are willing to control the movement of vehicles, pedestrians and cyclists as required as part of the Traffic Management Plan nor to provide police officers in both east and westbound carriageways on the A944 to stop vehicles from entering the pedestrian crossing space.

Confirmation previously sought on the 600 spaces at the Arnhall Business Park being available during matches with an evening kick-off has not been forthcoming in the additional information either. Aberdeen City notes that these aspects have not been identified in the Transport Assessment Addendum and are requesting clarity in this regard. They also re-iterate that an off-site parking arrangement with a third party and out with the redline boundary of the site is not enforceable within the planning system. You will see many other issues on their response online; too many to document again.

Aberdeenshire Council’s Infrastructure Services response is not available online at this minute, so I will not make comment on that here. Westhill & Elrick Community Council’s response is awaited too.

On reading the many documents submitted from the club this time around, not only have they thrown in some new quanderies over the Fanzone with no backing information on noise assessments, economic implications, but also a new supporters survey compiled by Aberdeen & Grampian Chamber of Commerce.

After ploughing through these additional late papers, for me, and I know for many others, the fundamental planning issues remain. The greenbelt issue has not gone away. The site remains outwith the Local Development Plan. The stated preferred method of transport is by car, going against both councils’ sustainable travel policies. There is no direct route from the AWPR to the stadium; therefore the AWPR is not the magic bullet for this development. There remains no genuine community use available.

The “Dons executive” has a lot more talking up to do to satisfy not just the baddies of NKS, but the raft of statutory consultees including both councils, local community councils and members of the wider public who have read between the lines and have delved in to the reams of information to come forward with real, not perceived concerns. The plot will no doubt thicken as we turn the pages towards the pre-determination hearing and ultimate determination in October. And of course, what will the decision-makers make of it all?





City and Shire SDPA response to stadium proposal

The “Strategic Development Planning Authority” (SDPA) was designated by Scottish Ministers on 25 June 2008 under the Planning etc. (Scotland) Act 2006. The Aberdeen City and Shire SDPA have 12 members with six being appointed by both Aberdeen City and Aberdeenshire Councils.

Their observations and policy conclusions on the AFC stadium proposal are documented below. Although the response has been online for some weeks, it was before SDPA members yesterday for noting. With so many documents online, it can be time-consuming to find the statutory consultee responses.



Local planning authority: Aberdeen City Council

Proposal: Proposed Community and Sports Facilities, Football Academy, (comprising outdoor pitches, pavilion, ancillary buildings), Stadium (20,000 capacity), ancillary uses, formation of access roads, parking and associated landscaping and engineering works | Land At West Kingsford (North Of The A944 Road) Skene Road Aberdeen AB15 8QR

Reference No: 170021/DPP Date received: 16 January 2017

Case Officer: Garfield Prentice Target date: 27 February 2017



An application for detailed planning permission has been submitted on behalf of Aberdeen Football Club. The application seeks approval for a football stadium and campus development on an unallocated site forming part of the Aberdeen City Greenbelt to the west of the AWPR junction between Kingswells and Westhill. The proposed development would comprise:

20,000 seater football stadium

  • A football academy
  • Training pitches
  • Car parking for 1,600 cars
  • Ancillary retail (merchandising and match day concessions)

The stadium capacity is similar in scale to the current stadium (Pittodrie) and that for a community stadium allocated at OP59 in Loirston in the Aberdeen Local Development Plan 2012 (and 2017) on which Aberdeen City Council were minded to grant consent until the application was withdrawn.

Strategic Development Plan

The Aberdeen City and Shire Strategic Development Plan (SDP) was approved by Scottish Ministers on 28 March 2014, replacing the Aberdeen City and Shire Structure Plan (2009). The Aberdeen Local Development Plan (2017) was adopted on 20 January 2017. The development plan for Aberdeen City is therefore fully up-to-date. The plan 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. The purpose of the SDP is to focus the right development in the right places and to prevent inappropriate and poorly located development. The SDP is ambitious in its strategy for change, facilitating growth in focused places in order to deliver the significant and properly planned infrastructure required for this growth (SDP paras 3.5 and 3.9), while enhancing quality of life. In terms of the plan’s spatial strategy (p8- 23), the proposed stadium falls within the outer edge of the Aberdeen City “Strategic Growth

Area” (p12-14). 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” (para 3.24, Diagram – p13 and Schedule 2). 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.

It is recognised that the development proposal is attractive to and tries to meet the needs of the football community of the region. However, it is the principle of a new, single-purpose stadium (for football use and surrounded by ancillary football facilities), on an unallocated site, in the greenbelt which on the edge of the city that is the primary focus of this response.

Spatial Strategy

The SDP acknowledges the importance of Aberdeen City Centre as being vital to the economic future of the area (SDP para 3.21). The regeneration of the City Centre and a number of city communities is vital to reduce inequality (paras 3.47 and 3.48). A key facet of this is acknowledging that a varied mix of uses must be maintained and expanded in order to have a successful city which is attractive to business, residents and tourists. The importance of reducing travel distances and making walking, cycling and public transport more attractive is also highlighted as vital for the future (para 3.16). This again focuses attention on the City Centre or sites that are well connected to existing or planned communities.

Para 3.24 of the SDP details two possible locations for a Community Stadiums to support the growing sporting infrastructure of the city. This is further illustrated in the indicative diagram 5, p13. The careful consideration of the location of a community stadium was part of not only the SDP development process but the Aberdeen LDP. The SDP aims for the development of a Community Stadium which would facilitate more than one use on site and as such co-locate multiple uses at one facility that would be better connected to existing or proposed infrastructure than the single use and isolated proposed development. Specific sites have been allocated for this use within the spatial framework and to locate a stadium of this size and singular use on an unallocated site in the greenbelt, on the outer fringes of planned development corridors would be contrary to both the SDP and Aberdeen LDP. It is noted in the supporting Environmental Statement (ES) that the previously considered

Loirston and Bellfield Farm sites were located in areas designated as Greenbelt at the time of determination. However, this is misleading as the Loirston site was part of a new community coming through the Aberdeen Local Development Plan (2012) and Bellfield farm was considered under a specific policy in the 2001 Structure Plan relating to the SFA’s bid for Euro 2008. The policy context for the current application is therefore very different. It is also claimed that the AWPR would facilitate development at this location. The purpose of the AWPR is not to facilitate development rather alleviate traffic congestion in the greater Aberdeen area. A 20,000 plus capacity stadium on the periphery of Aberdeen City’s road network and public transportation routes is unlikely to make the best use of existing and planned transportation infrastructure. In a similar vein the ES states the stadium would be designed to the highest sustainability standards yet fails to mention given its location how heavily car dependent it would be, thus neutralising any gains made through greener technologies on site. The ES asserts the stadium would improve quality of life. Again this is debatable given the level of traffic that would be generated on match days and at peak commuting times placing increased pressure on the immediate area’s infrastructure. In addition to that it would only be accessible for pedestrians from Westhill given the AWPR forming a barrier to pedestrian and cyclist movement from Kingswells which is the only other adjacent neighbouring community.

Economic Growth

With regard to economic growth the SDP seeks to grow and diversify the economy. However, the applicant’s claim that the development of a football stadium at this location would help to provide a new range of employment that would also help to diversify the regional economy, moving it away from the oil and gas sector, is unfounded. The vast majority of job creation would be in construction, and therefore temporary. While additional employment is welcome, 30 jobs is difficult to class as a shift in employment base. It is also unclear from the supporting Economic Statement as to whether these jobs would be a net gain or a shift from the existing stadium at Pittodrie to the new stadium at Kingsford. However, no account appears to have been taken of either the fact that jobs will be transferring from one of the most economically disadvantaged parts of the City to a significantly more affluent one, or of pre and post-match revenue spent in the vicinity of Pittodrie or the wider city centre – with very limited opportunities for such expenditure in the vicinity of the application site. The issue of ‘Net Economic Benefit’ is covered in more detail below.

Sustainable Mixed Communities

It would appear that the proposal is for a football stadium rather than a community stadium as envisaged at the time of the preparation of the SDP (and previous structure plan) which identified potential stadium locations (SDP para 3.24) as a component of a broader mixed community. While it is recognised that there will be community access to some of the football facilities, the uses proposed are not integrated in a sustainable fashion into the community given the scale of the development and its proximity to established or planned developments.

Quality of the Environment

The Greenbelt around Aberdeen plays a vital role in protecting the character and landscape setting of the city and adjoining communities (para 4.31). Development of this site would remove the protection afforded by the designation and lead to coalescence between Westhill and Kingswells.


While the application sits on the edge of one of the plan’s ‘Strategic Growth Areas’, it is not within or adjacent to either the City Centre or other defined town or neighbourhood centres and has the potential to impact on the City Centre which is afforded significant protection within the plan. This issue will be considered in more detail below in terms of sequential site selection.

The objective of the SDP is to ensure all new development contributes towards reducing the need to travel by car and encourage walking, cycling and public transport – a target of the plan being that walking, cycling and public transport should be attractive options. This location will be a significant traffic generating use in a location only served by public transport between the City Centre and Westhill. It will have a limited residential walk-in catchment and would create further danger on the Aberdeen-west cycle route (with three entry points to the site), which needs to be further upgraded (although it is recognised that there are proposals to upgrade this).

The accompanying Transport Assessment (TA) proposes a number of measures to manage the potential traffic congestion such as overflow parking being accommodated within the Arnhall Business Park. However, it is difficult to see how the development could mitigate its impact in this location when (according to the TA) over 20% of supporters currently travel to the stadium on foot and this is likely to fall dramatically at the Kingsford site. If thousands of cars were to be parked at the nearby employment areas this would give rise to thousands of pedestrians trying to cross the A944 dual carriageway immediately before and after matches. The proposal would create a car dependant development in an area served by limited public transport and an almost non-existent walking catchment. As such it would not be in keeping with the objectives and targets of the SDP.

Scottish Planning Policy (SPP)

Uses that attract a significant number of visitors should generally be located in town and city centres and paragraphs 58 and 59 of SPP place a strong emphasis on the health and vibrancy of town centres, placing the right development in the right places. As such a town centre first approach is taken by the SDP and the Aberdeen LDP. A mix of uses is important in order to attract visitors and should be encouraged in order to have a variety of uses resulting in a more resilient centre. Furthermore the sequential town centre first approach of SPP para 68 would place developments which generate significant footfall firstly in established areas and require justification as to the lack of suitable locations for a similar development in these locations.

The supporting ES chapter 4 (as required in para 73 of SPP), discusses why the out-of-centreproposed location is considered acceptable. Analysis has been undertaken of alternative sites but restricted to those within the Aberdeen City Council boundary, despite the SDP explicitly seeing the ‘Community Stadium’ as a regional facility (SDP Schedule 2). Such an artificial restriction on potential sites in the sequential assessment is inappropriate. All allocated sites, those with previous permissions and possible alternatives have been discounted in the assessment. Multiple reasons have been given with a reoccurring issue being site size, due to the area required for the ancillary components of the proposal the applicant believes it is difficult to find a non-greenfield site within Aberdeen City with sufficient space. In the analysis of the Loirston site (15ha) it is claimed that there is insufficient space on site for training facilities when in fact the site (before the application was withdrawn) was minded to be granted consent by Aberdeen City Council for a stadium and training facilities. It has not been articulated sufficiently as to why such a scale of facilities is required and also the need for it to be co-located with a stadium. Redeveloping Pittodrie is viewed as in conflict with the existing residential use of the area even though the stadium has been in existence for over 100 years. Reasons against developing Kings Links are the loss of the golf course and land being Common Good. All development will encounter issues that required solutions and negotiation, many more complex than the above.

The analysis does not sufficiently justify why the co-location of the stadium and training facilities is necessary and that a standalone stadium could not be accommodate on a sequentially preferable site. Training facilities could be located on an alternative site within the City or Shire. This would negate the need for such a large site and the need to develop within the greenbelt detached from the built-up area of the city. Indeed, the strategy of developing separate sites was being pursued by Aberdeen Football Club until very recently.

In summary, the justification for the current proposal is particularly weak. The Scottish Government has issued draft guidance in order to assess a potential development’s net economic benefit. Para 29 of SPP requires due consideration be given to net economic benefit of a proposed development. The Scottish planning system supports economically, environmentally and socially sustainable places and achieving the right development in the right place. The applicant’s supporting Socio-Economic Impact Statement focuses on the proposal’s employment creation, gross and net, in the Kingsford area. It concludes that there would be a net generation of 30 jobs post construction and over a 25 year period that the net additional GVA generated could equate to £14m at the Kingsford level and £108m at the Aberdeen City level (including construction costs). While the document discusses the net gain to the Kingsford area it doesn’t address displacement of jobs from the Seaton area which is in the 20% most deprived areas in Scotland (Scottish Index of Multiple Deprivation). In addition, Seaton is subject to a Community Locality Plan (a component of the Community Planning system) in order to promote regeneration in the area. The impact of the relocation on the area around the current stadium is not addressed. Added to this, there is also likely to be a loss of match day revenue from this area and the wider City Centre which is not directly considered in the economic assessment. As a consequence, the economic assessment does not present a realistic picture of the impact of stadium relocation to this site.


Improving and modernising the facilities of Aberdeen Football Club are supported by the SDP, as is the provision of community facilities. However, this application is contrary to the Aberdeen City and Shire Strategic Development Plan (2014), which is up-to-date and relevant to this application. The proposal will result in the loss of greenbelt land, the coalescence of urban areas, inappropriately located development giving rise to unsustainable travel patterns and have a negative impact on the City Centre in terms of its mix of uses and lost revenue. The applicant has not adequately justified why the stadium and training pitches etc need to be co-located or why sequentially preferable sites have been dismissed as unsuitable. The applicant claims that the net economic benefit of the proposal is a material consideration.

However, the attempt to demonstrate what the net economic benefit would be seem to neglect the loss of jobs in a deprived area. Various gross and net figures are quoted in the economic assessment but without stating the loss to the existing community of Seaton or of match-day expenditure in the city. Draft guidance on assessing net economic benefit in the planning system was issued in early 2016 by the Scottish Government, but no account appears to have been taken of this. Without a proper assessment, it is not clear what the net economic impact of the proposal might be. The strong framework for investment decisions set by the SDP (SDP Aims, p6) requires strong decision-making on applications which clearly contradict the strategy of the plan. The application is in an unsustainable location in that it will have a very small catchment in terms of access by walking, cycling and public transport compared to other sequentially preferable sites. It does not follow the sequential town centre first approach of SPP or accord with the aims and objectives of the SDP.

“Stadium so far out of town, it’s in another town!”

Infrastructure Services Committee met today, as planned, to discuss (amongst other things) their response as consultees to Aberdeen City Council regarding the AFC stadium proposals for Kingsford. I sat in as an observer at the public meeting and share notes of my observations here. Please note that this is my take on the meeting and I’m happy to be corrected on any glaring mistakes by those who were there.

If you don’t want to know the score without reading the summary, look away now. 7 councillors voted to agree with the views of the Garioch Area Committee in February, i.e. to lodge an objection and 7 councillors voted to place a holding objection on the consultation on the grounds that further technical information be sought. The Chair had the casting vote and agreed that the views of ISC were aligned to those of the Garioch Area Committee. The formal view of Aberdeenshire Council is now to oppose this application.

The planners firstly outlined the application for members as well as summarising the consultation process so far. Councillors asked an array of questions about parking, pedestrians, traffic flow and economic impact. No-one at the meeting including the applicant could offer any definitive information about a proposed Controlled Parking Zone. This is a very integral part of the traffic assessment and surely both councils should be aware of what is planned. As parking has yet to be decriminalised in Aberdeenshire, who would foot the bill for policing of it and who would administer the permit system? It is likely that with the CPZ now being extended to a 30 minute walking radius, a large part of Westhill and Elrick could be included.

George Yule, AFC and Ally Prockter from the Community Trust addressed the committee and gave a brief timeline on why the application was lodged and made reference to having worked with Aberdeen City Council previously to find a site for the club with Loirston being acceptable and within the Local Development Plan (LDP) but now Kingsford was their plan C. When asked about the arrangements with Arnhall Park businesses for extra parking, George explained that the club now have 3 companies agreeing in principle. There will be a cost for parking at Arnhall and it has been said before by AFC that this would be reflected in the match ticket price. Today we were told that any funds raised from parking would go to the Community Trust.

Mike Forbes spoke next to the committee. Mike is a Westhill resident supporting the stadium. From speaking to his friends he feels there is a groundswell of support although he said this was difficult to quantify. He has spoken to people who are not football supporters but who welcomed the stadium. He spoke about the economic impact on local shops and restaurants. This conflicted with other views of local businesses who feared that rogue parking would keep their customer base away on match days. He mentioned that the stadium would be an inspiration for children. I cannot disagree with his point per say but children would be inspired wherever the stadium was built.

The No for Kingsford group were up next to refute some of these claims. John Simpson and John Thornton spoke about their independently-commissioned Transport Assessment from Waterman’s which concluded that this application does not comply with policy and is unsustainable. The TA from the applicant underestimates car travel. They said there will be little economic benefit to the local area and certainly would not mitigate the downtown in oil and gas as suggested. Concerns were raised about the impact on the Seaton area by removing the stadium from Pittodrie. Scottish Planning Policy states that a major development such as this should be close to the city centre and this application ignores the Strategic Development Plan. The applicant was accused of riding roughshod over planning policy.

Last but not least, Audrey Findlay, Acting Chair of Westhill & Elrick Community Council addressed committee saying that her group took time to form their opinion, poring over the some 160 pages which accompanied the application, basing their representation on planning policy and practical issues. Greenbelt is one of the main concerns with a huge building planted on the Kingsford site changing the landscape forever. The community does not want coalescence with Kingswells. She said planning policy is there for a reason and this breaks too many policies. She also highlighted recent articles in the press about congestion hot spots being likely after the AWPR is complete – without any new development and the A944/Kingswells junction being one such hot spot.

The planning policy concerns are well documented in reports from both councils so I won’t reiterate them – all are available on Aberdeen City planning website.

The recurring theme today at ISC was “great idea, wrong site” with AFC being applauded for their vision of the stadium (not the location). David Aitchison, the Chair, who is also a Westhill councillor summed up by saying that no-one can deny AFC need a new stadium but it will affect Westhill forever and ultimately people live here. He was not impressed by the transportation assessment  and said the proposal was so far out of town it’s in another town!

Now it’s over to Aberdeen City councillors in the summer to consider whatever report comes in front of them from their planners, based on planning policy and taking consideration of the many consultees’ responses, including Aberdeenshire Council. It won’t be a numbers game or a popularity contest which brings me to Mark McDonald, MSP’s very recent statement in the press where he urges the council to provide planning training to newly elected councillors and cited the AFC stadium application. The vote is expected to take place in June – a few short weeks after the local government elections. Although Mark has openly supported the proposals he says “It is absolutely vital that our city council’s planning processes are respected and newly elected councillors make that vote, adhering to the regulations and rules which govern the planning system.” He added that new members must be “absolutely clear on declaring any interest in the project”. As an ex-councillor himself, Mark will be very much aware that councillors must stick to planning policy when determining an application. I’ve had calls from residents to break planning policy for this one application. I am sure we would see a deluge of legal claims if we did! I am disappointed to see some online comments from supporters who have no regard or insight of the planning system dismiss those who have taken the time and made the effort to study the proposals so that they can at least make an informed representation based on planning considerations. “Get it built” and “COYR” are not material considerations and online letters of support left blank giving no material reasons for that support count for very little. I’ve spoken many times about the need for residents to get involved in the planning system earlier and this is a perfect example of why. We all have work to do to make this happen. Councillors have work to do to explain to their constituents what our roles are in the planning process if only to counteract the reactive “nugget”, “dinosaur”, “NIMBY” etc labels when we vote the “wrong” way!



Aberdeenshire to form final view on Kingsford stadium plans

On Thursday 16th March, Infrastructure Services Committee is recommended to note and consider the view provided by Garioch Area Committee last month that the application be refused for the reasons as detailed and to note and consider the responses already provided by consultees including the holding objections from Environmental Health & Transportation. The Committee is further recommended to agree a formal consultation response for submission to Aberdeen City Council on the stadium proposal at Kingsford. I hope that ISC will reiterate our comments made at Garioch Area to request that Aberdeenshire Council continue to be involved in the process as the plans progress. We fully respect the right of Aberdeen City councillors to make the final decision but as this plan is a significant departure from both the Local Development Plan and the Strategic Development Plan and affects Aberdeenshire residents, both authorities should be working in partnership to work through the issues raised. The report before ISC members can be seen here (item 8).



Places, people and planning – consultation events

As the period for responding to “Places, people and planning” draws to a close (4th April) there will be an opportunity to speak to the Scottish Government team over the next couple of weeks.

They are in Trinity Shopping Centre, Aberdeen on Wednesday 15th March from 9am-4pm.

The consultation can be found here and there is still time to send in your comments. If you have views about any of the main themes: making plans for the future, getting more people involved in local plans, building more high quality homes and associated infrastructure, stronger leadership and smarter resourcing, please respond to the consultation.