Proposed Community And Sports Facilities, Football Academy, Stadium, Ancillary Uses, Formation Of Access Roads, Parking And Associated Landscaping And Engineering Works At West Kingsford, . Reference 170021/DPP

OBJECTIONS FROM KINGSWELLS COMMUNITY COUNCIL (KCC)

The Overview lays out KCC’s principal concerns about the plans. The main body of our response details these concerns, with the ‘green boxes’ summarising each section. Appendices 1 and 2 cover some more detailed points about the Traffic Assessment (TA) submitted by AFC, including the use of park-and-ride facilities.

1.0 OVERVIEW

The development plans for Kingsford are a serious breach of planning policy and create a legal precedent for other future departures from the agreed SDP and ALDP. The Green Belt land involved is particularly important to the communities of Kingswells and Westhill because it is the last piece of Green Belt that can prevent the coalescence of the two communities and the creation of a development corridor along the A944. The gaudy external appearance of the stadium is completely unsuited to a semi-rural area. The site selection process is flawed and does not adopt an acceptable sequential approach to the evaluation of other sites. The need to have all facilities on one site is not an essential requirement – it has been used to minimize costs and manipulate the selection process. Other sites identified in the SDP and ALDP have been downplayed. The perceived economic and community benefits are not unique to the Kingsford site. They would be the same, or even greater, if the development was located on a more central site nearer to the communities and businesses that would benefit most. Moving the facilities to an out-of-town location goes against the principles of the City Centre Masterplan. The Traffic Assessment provided by AFC makes quite sweeping assumptions intended to favour the development. It describes modes of travel identified by a survey in which the validity and independence of the source are in question. Even then, it can only show that traffic flows will be no worse than at peak times. The success of the traffic plan depends on commandeering most of the park-and-ride facilities in the City and Shire, and a supply of buses that exceeds the capacity that is locally available. The vast majority of fans can only get to Kingsford by car or bus. Transport options are less sustainable than for Pittodrie and the carbon footprint will be higher. The TA underestimates the number of cars and buses involved and their impact on other road users. We would request that City Council roads specialists look in detail at the issues we have raised. KCC accepts that the majority of fans will be well behaved. However, due to the lack of CCTV, it will be much more difficult to monitor crowd behaviour in the Westhill/Kingswells area than it is in the city centre. The safety of fans on the busy A944 is a real issue. The main beneficiary of this development is Aberdeen Football Club, and there is no justification for the detrimental impact it will have on a semi-rural area and the local communities involved. Kingsford is the wrong location for this development, and a suitable alternative should be found using a more rigorous and approved site selection process. For the above reasons, this planning application should be refused. KCC reserve the right to comment on any modifications to this planning application.

Kingswells Community Council 1 2.0 RELATIONSHIP TO THE STRATEGIC DEVELOPMENT PLAN AND LOCAL DEVELOPMENT PLAN

The Aberdeen City and Shire Strategic Development Plan (2014) includes provision for a potential new community stadium at Loirston or Kings Links. The Aberdeen Local Development Plan (2017) states that “Loirston is considered suitable for a new football stadium and a site has been identified to accommodate this as part of a mixed use area.” Neither the SDP nor the ALDP mentions other alternative sites. Therefore, Kingsford would be a departure from both development plans which were put together after widespread public consultation. It is not entirely clear why Loirston is no longer considered suitable for AFC’s new stadium. The new Cove Rangers stadium at Calder Park and the new secondary school are both in a different development area from AFC’s original stadium site (OP61 and OP59 respectively). AFC’s plans for Kingsford are for a football stadium with some community facilities. This falls short of the requirement in the SDP to provide a “new community stadium”.

AFC’s plans for Kingsford are out-of-line with the SDP and the ALDP.

3.0 GREEN BELT AND COALESCENCE OF COMMUNITIES

NE2 Policy on Green Belt is unequivocal and is clearly set out in the Aberdeen Local Development Plan (ALDP). “The aim of the Green Belt is to maintain the distinct identity of Aberdeen and the communities within and around the city, by defining their physical boundaries clearly. Safeguarding the Green Belt helps to avoid the coalescence of settlements and sprawling development on the edge of the city, maintaining Aberdeen’s landscape setting and providing access to open space. The Green Belt directs planned growth to the most appropriate locations and supports regeneration.” The area in question at Kingsford is clearly shown in the ALDP as Green Belt and it fulfills the aim stated above. It is highly functional in preventing the coalescence of Kingswells with Westhill, and ribbon development along the A944. It enables Kingswells and Westhill to maintain their individual identities. This area of Green Belt protects the open and attractive landscape setting looking north from the A944 towards Brimmond Hill and Clog Hill. KCC is aware that a previous application in 2005 to build a floodlit golf driving range on the site was rejected by the Scottish Government Reporter because of its adverse impact on the landscape. Clearly the developments now proposed by AFC would have a much greater impact than a golf driving range. Artificial floodlit pitches alongside the A944 cannot be accepted as an appropriate “green” use of Green Belt. Nor can AFC’s future plans for an additional large building on the site (a covered pitch or stand). Police Scotland’s request for security fencing around the site would also have an adverse impact KCC finds it highly objectionable that AFC continually refers to the area as “Green Belt” (in inverted commas) as if the designation is false. The fact is that the area in question will be the last remaining piece of Green Belt between Kingswells and Westhill after Prime Four completes its permitted expansion on to OP29 (retail park or offices). This makes it even more vital that the site at Kingsford is kept as Green Belt.

Kingswells Community Council 2 The preservation of the Kingsford site as Green Belt is absolutely vital to protect the distinct identities of Kingswells and Westhill and prevent their coalescence. Removing this piece of Green Belt will also open the door to ribbon development along the A944 corridor. Approving this development will have fundamental consequences for the integrity of ’s planning policy. It will set an unwanted planning precedent for other communities around Aberdeen. Creating a new stadium for Aberdeen Football Club does not justify these risks. AFC have not provided sufficient reason, including perceived economic benefit, to justify breaching this policy. Any new stadium and facilities should be located on sites already approved for development in the SDP and ALDP, not on designated Green Belt.

4.0 CHOICE OF SITE AND CO-LOCATION OF FACILITIES

AFC have chosen Kingsford from a range of other options due to its proximity to the AWPR and the opportunity to co-locate a stadium and training facilities on a single site. AFC claims that co-located facilities are essential to secure the future of the club. The AWPR was designed to keep traffic moving and minimize delays. The junction of the AWPR with the A944 was planned in 2008 and was never intended to accommodate the additional traffic from a football stadium. The proximity to the AWPR does not solve all traffic issues and this is discussed in Section 7.0 Traffic Assessment. Other more suitable site options would be possible were it not for AFC’s insistence on the co-location of its training facilities. Whilst co-location, given a choice, might be desirable, it is certainly not essential. There is no evidence that locating everything on one site is required to ensure the sporting success of a team. Of the 10 top teams in the Scottish Premiership, the majority (7/10) have stadiums in urban areas and geographically separate training facilities. Of the top 10 teams in the English premiership, all have stadiums in urban areas and almost all (9/10) have geographically separate training areas. There is no link between co-location of facilities or the newness of the stadium and team performance. The current top 3 teams in the Scottish Premiership (Celtic, Aberdeen and Rangers) illustrate these points. The quality of the players and team management are the key drivers of success. AFC point out that the Pittodrie site has planning permission in principle for 350 new homes and that the financial gain from this development would help to fund Kingsford. This financial benefit should not be a planning consideration. Of the 7 site options considered by AFC, the former AECC site at and the new AECC site at were both rejected partially on the grounds that local roads lacked capacity due to nearby commercial developments. Although there are very significant commercial developments at Westhill and Prime Four, this fact has been ignored to help justify Kingsford. AFC rejected most of the alternative sites because the stadium and training facilities could not be co-located on the same site. However, they have made a weak case as to why this is necessary.

The site selection process is flawed and designed make Kingsford the only feasible outcome. A proper and robust sequential assessment should be made without the unreasonable restriction of finding one site for all components of the development.

Kingswells Community Council 3 5.0 VISUAL IMPACT

The stadium at Kingsford would not be seen from Kingswells village but KCC still objects strongly to the visual impact it will have on the landscape between Westhill and Kingswells (see Section 3 Green Belt). AFC assured KCC at an early stage in the planning process that they would make every effort to help the stadium “blend in”. Clearly this has not happened and the result is unacceptable. The gaudy red façade on three sides of the building (to be illuminated during matches) and huge displays of football action are totally out of keeping with the semi-rural surroundings. The photomontages provided by AFC do not show how the development will look from the elevated sections of the AWPR, only that it will be invisible from inside the cuttings! The stadium will be highly visible on the landscape when viewed from the A944 overbridge on the AWPR and its approaches. We support the screening of the development with a 12-metre-deep tree belt. However, this will take 15+ years to achieve an effective height and would require sufficient conifers in the mix to screen off the development during winter months. The hedges between car-parks would need to be protected by fencing to prevent them being thinned out by fans taking short-cuts. Police Scotland’s requirements for perimeter security fencing and the need to see through the tree belt is at odds with mitigating visual impact.

The external appearance of the stadium is completely inappropriate for a semi-rural situation.

6.0 SUSTAINABLE TRANSPORT

Fans who live near the city centre, and those who arrive by train, will no longer be able to walk through the city to matches. They will either have to drive or take a bus to out of town. Any businesses based in the city centre which currently service Pittodrie will also have further to travel. These factors will just increase traffic on the roads and result in a higher carbon footprint.

Kingsford will provide fewer sustainable transport options and a higher carbon footprint than Pittodrie.

7.0 TRAFFIC ASSESSMENT

7.1 General comments The TA provided by AFC has identified that the AWPR junction with the A944 will be significantly over- utilised (3 x capacity) at peak times in the base case without any additional traffic from development. This level of congestion is used as the measuring stick against which the traffic from the stadium is assessed. KCC have made enquiries through Councillors to get details of planned mitigation and, to date it appears, there is no planned mitigation of the forecasted congestion. AFC see this as a problem for others to solve. After the completion of the AWPR, the A944 is the only road that was predicted to have increased traffic flows. A leg of a junction is considered to work well at 85% capacity. This would have been the maximum design case for the junction. In the base case, the maximum utilisation of a leg on the junction was 318% with expected delays of 40 minutes (see Appendix 1). The slip roads are carrying 318 / 85 = 3.7 times the original expected traffic. Although the traffic flow on the junction will be mitigated, the A944 junction must deal with up to 3.7 times the additional traffic originally predicted. When AFC say the traffic will be no worse than peak time traffic, they are referring to the peak after the completion of the AWPR, not the existing peak. Of all the junctions on the AWPR, the A944 junction is probably the least able to cope, and AFC’s site selection should be questioned.

Kingswells Community Council 4 The TA concentrates on getting people in and out of the stadium and neglects to quantify the impact that additional traffic will have on other road users. To keep west-bound traffic on the A944 moving before a game, it is proposed to reserve the outside lane and long stretches of the re-claimed central reservation of the A944 as lanes for queuing right turning vehicles, allowing only the nearside lane for moving local traffic. There is no assessment of the impact this would have on local A944 road users. This situation will be compounded if cyclists are forced back on to the roads due to overcrowded cycle / footpath along the A944. All the traffic generated by the proposed stadium will be new to the area, and will be at times that will adversely impact the ‘work/life balance’ of people using the A944. The TA presumes to impose peak time congestion on other road users when they will be trying to enjoy non-work activities, including leisure, and generally go about their normal lives. The level of congestion on match days is not acceptable, as claimed by the TA. By the time the stadium is built, the A944 will be the main road for the three communities of Kingswells (2000 homes), Westhill (5000 homes) and Countesswells (eventually 3000 homes) to access Aberdeen and the surrounding countryside. The A944 is also the main arterial route for communities in more distant areas in Aberdeenshire. Unlike other more central areas of Aberdeen there are no easy alternative routes and the impact will be more significant. The road system will be over capacity and there are no contingency plans for accidents or breakdowns. The TA places emphasis on the police controlling traffic, and infers that this will ensure there are no problems. This puts an unfair onus on the police service to make a success of the traffic management, and identifies a scapegoat for any issues. The police service will have to take on additional duties of monitoring parking in the Shire (a task normally undertaken by city wardens), as well as their normal match day duties of monitoring traffic, crowd safety etc. It is questionable if Police Scotland has sufficient spare resource to achieve all this effectively. The TA does not deal with the possibility of other major events, like rock concerts, being held in the stadium. In this case, the vast majority of people are likely to want to travel by car and the TA would not be applicable.

AFC’s Traffic Assessment concentrates on getting football traffic in and out of the stadium. It does not assess the impact on other users of the A944 who may be trying to go about their everyday lives at the same time as a match is on. Police Scotland will be assigned to control the traffic but cannot magically achieve this if the TA is fundamentally flawed. The impact will be greatest on communities who rely on the A944 for access and have no easy alternative routes. The TA does not deal with other large-audience events which could be held in the stadium and for which the modes of travel will be significantly different. Of all the junctions on the AWPR, the A944 junction is probably the least able to cope, and AFC’s site selection should be questioned.

7.2 Validity of the TA The TA is based on the modes of transport determined from a survey of fans, and the number of car journeys is based on 3 fans travelling together in each car. These assumptions and the validity of the TA must be questioned for the following reasons. There must be concern over the validity and independence of the survey of fans conducted to determine key figures in the TA. There has been no contingency factor to account for errors in the survey, and there is no sensitivity analysis on the effects of using different figures. The predicted reduction in the use of the car for an out-of-town stadium is counter-intuitive.

Kingswells Community Council 5 The survey was undertaken by fans who, at the time, would have had little real insight into how they will travel to a new stadium. This can only be determined after people have tried various methods of travel and can make an informed decision. For example, when a fan who originally identified that they would travel by bus finds that this is more difficult, or takes longer than originally anticipated, they will reconsider their travel options. The use of a car is the obvious alternative to travel by bus. Although the area is served well by public bus services, and the frequency of buses will be increased on match days, there is no plan to locate bus stops on the A944 adjacent to the proposed stadium. The TA assumes that a bus drop-off point will be provided in the adjacent Arnhall Industrial Park, and that fans will then walk 800 metres to the stadium on a route that crosses the busy A944. The lack of bus stops at the closest points to the stadium will make travel by public transport less desirable. The diversion into the industrial park on a weekend will cause unnecessary delays to normal users of the bus service. AFC assumes that cars used by fans will have 3 occupants. This is only feasible when the car is parked in an area controlled by AFC officials. The occupancy rate of cars parked elsewhere cannot be controlled. It is understood that a more realistic norm is much lower. Consequently, the number of car journeys and the impact on nearby parking spaces in the local communities have been significantly underestimated. The TA is heavily dependent on buses, and the current TA identifies that there is not sufficient capacity within local bus companies to meet the demand for buses at certain times. Any underestimation of car use, or overestimation of car occupancy rates will result in demand for even more buses to transfer from Park and Ride sites. Appendix 1 considers some of the assumptions made in the TA in more detail, and concludes that little confidence can be placed on the TA. The method of mitigating the 3 x capacity flows at the AWPR junction are not certain and the validity of the TA is questionable. Appendix 2 looks at the use of park-and-ride facilities using more realistic car occupancy rates than those used by AFC. The conclusion is that the success of the TA requires AFC to commandeer most of the park-and-ride facilities in Aberdeen and the Shire. More shuttle buses will be required to travel further and will not be able to perform double journeys. This puts further pressure on the supply of buses, and brings the validity of the TA into question.

The TA is flawed. It is based on a questionable survey to identify the likely modes of travel. The TA underestimates the number of cars, as it assumes an unrealistically high occupancy rate that is out with the control of AFC. Even if the optimistic assumptions are accepted, the best that A944 road users can expect is peak time traffic flows and the AWPR junction operating at 3 x capacity. The TA depends on mitigation measures by others, and extensive use of Park and Ride facilities all the buses available locally. Appendices 1 and 2 question the validity of these assumptions. The TA concludes that peak time flow is an acceptable limit for traffic flows for other users of the A944. KCC strongly disagrees with this conclusion

7.3 Stadium Exit Strategy The TA concentrates on clearing the stadium as quickly as possible, but does not assess the impact on local traffic. At the end of a match, shuttle buses going to various places will ensure that the first wave of fans is cleared relatively quickly. However, the need for some buses to return to the stadium for a second trip will result in delays of 40 to 50 minutes before some fans can exit the stadium. Some will be tempted to walk alongside the A944 to the Kingswells park-and-ride, with the inherent dangers of walking beside a busy dual carriageway. They will also have to cross two busy slip roads at the AWPR

Kingswells Community Council 6 junction. Additional buses would be required to remove the need for second journeys, and to ensure the safety of fans. As stated above, the supply of buses is already at capacity. St Johnstone Football Club experienced problems with their park-and-ride shuttle system when fans stopped using the service when the waiting time to clear them from the stadium was 40 minutes. AFC plan for the last shuttle buses to clear the stadium 40 to 50 minutes after the end of a game. This is hardly a good objective for a “centre of sporting excellence”! More shuttle buses are required to prevent fans walking from the stadium to the park-and-ride and exposing themselves to danger.

The TA is heavily reliant on travel by bus and has identified that there is not an adequate local supply of buses. Unless the bus shuttle service is more speedy and effective than planned, fans will stop using it and resort to cars or walking alongside the busy A944.

7.4 Provision Of Car Parking

The provision of car parking for the development includes:  1,600 on-site spaces  600 off-site parking spaces at Arnhall Business Park with access to the stadium by foot.  Additional off-site provision utilising the various park-and-ride facilities around the City and Shire with transfer to the stadium by shuttle buses. The use of the 600 spaces at Arnhall is not under the control of AFC, and the long-term sustainability of this must be questioned. Consequently, the implications for rogue parking in Kingswells and Westhill will be worse than predicted. If we include Arnhall along with the stadium parking the development includes 867 parking spaces more than allowed by Aberdeen City Council’s parking standards (i.e. a 65% over provision). Any reduction of on-site or off-site parking assumed in the TA will place additional burdens on other local resources and ultimately on Kingswells and Westhill residents. The TA should accurately account for how car parking will be accommodated and ensure that there are sufficient shuttle buses to allow fans to safely access the stadium. The TA must incorporate some contingency to account for inaccuracies in the assumptions made; but this is not done. Taking account of this would increase number of cars and the need for shuttle buses. This would bring the feasibility of the TA into question. Parking restrictions will be imposed on an area within reasonable walking distance of the stadium. This will include 12 car parks for local shopping and other community uses. These car parks are already extremely busy, and it will be impossible to exclude fans from using them. The cost of enforcing restrictions on these resources should fall on AFC. Extensive car parking is planned for a retail park at Prime Four (still awaiting approval). Unlike office car parking, it is not feasible to prevent rogue parking in such an area and any fan using the facility would have to walk alongside the busy A944 and cross two slip roads at the AWPR junction, with associated safety implications. There is no provision in the application to make walking alongside the A944 safe. KCC would object to any improvement to the walkway/cycleway that involved further loss of trees. Residents within the parking restriction area will have a permit system imposed, which would be highly inconvenient. Residents on the boundary of the parking restriction area will be greatly inconvenienced by any fans parking on their streets. The streets adjacent to any of the park-and-ride facilities earmarked for use may provide an attractive alternative to the car-parks if they offer a quicker exit. Fans parking in these streets will have easy

Kingswells Community Council 7 access to the proposed shuttle buses. This use is not accounted for in the TA, and the number of shuttle buses required will be underestimated. The parking restriction area also includes various car parks based in the Arnhall Industrial Site. The cost of policing and securing these sites will be the responsibility of local businesses.

There will be a need for additional shuttle buses to serve rogue parking not identified in the TA. There is no provision by AFC to make walking alongside the A944 safe. Clearly, AFC expect local people to put up with any inconvenience resulting from having the stadium, and for businesses and councils to bear the cost of providing adequate mitigation.

7.5 Crossing the A944 and AWPR Slip-Roads. Anyone using the car parking facilities at Arnhall must cross the busy A944 then walk along the roadside footpath to reach the stadium. It is not clear from the TA if the phasing of the traffic signals includes time for 3 x 600 = 1,800 people to cross the A944 in a safe manner. To assess the capacity of the crossing consider the following:  The fans will arrive one hour prior to the start of the match.  For an equal distribution of vehicles over the hour, and a lights cycle time of 2 minutes, the crossing must allow 1800 / 60 x 2 = 60 people to cross at each cycle of the lights in, say, 30 seconds.  That leaves 90 seconds for 2 phases of vehicular access to the junction. The split would be decided on need. In reality the distribution will not be equal, and more people will arrive nearer kick off. This raises the following concerns:  More time will be required to allow pedestrians to cross  Less time will be available for vehicles, so the capacity of the junction must be questioned.  The ability of the crossing to cope with the number of people trying to cross must be questioned, and so to must the safety of the pedestrians.  The ability of the footpath to merge the people crossing with the people already on the footpath in a safe manner must be questioned. After the game the process is reversed, but all the people will want to cross the A944 over a shorter period of time, and the capacity of all the components will be stretched even more. The crossing will also have to accommodate the passengers who use public buses which will use Arnhall as a drop-off point. This will exacerbate the issues identified above. There is the additional problem of fans who choose to walk along the footpath/cycleway from the Kingswells park-and-ride. At the A944 junction with the AWPR, fans will need to cross two busy slip roads of the AWPR. There will be pedestrian crossings controlled by lights at these points. This will have implications for traffic flows and fan safety but is not mentioned in the TA.

At Westhill, the capacity of the Six Mile Junction to accommodate traffic and pedestrians crossing to/from the Arnhall car parks is questioned. There are road safety issues concerning fans queuing to cross the A944, walking on the roadside footpath, and negotiating the AWPR junction. These issues are not covered adequately in the TA. KCC requests that Aberdeen City Council roads specialists look in detail at the traffic-related issues we have covered, including the points made in Appendices 1 and 2.

Kingswells Community Council 8 8.0 DOUBTFUL BENEFITS TO THE LOCAL ECONOMY

To quote from AFC’s website: “The proposed training, community and stadium facilities at Kingsford, represent a c. £50m private sector investment in the region at a time when our economy is struggling. It will bring confidence and economic benefit to the region including the creation of new jobs. Combined with the existing indoor sports and aquatics facilities e.g. at Aberdeen Sports Village, this development will greatly enhance the North-east's position as a Scottish sporting powerhouse.” This is a private enterprise to improve the fortunes of Aberdeen Football Club. There is no convincing argument why re-locating AFC’s stadium from Pittodrie to Kingsford will help the regional economy. Overall, it will be a zero-sum game. There are already numerous developments going on within the city area which show that Aberdeen is “open for business”. We agree that any development that improves AFC’s facilities could contribute to this message. However, AFC could provide the same, or greater, benefit from any site selected. AFC’s sequential assessment of alternative sites needs to be more robust and not constrained by the demand to locate everything on the one site. Aberdeen and the surrounding area already has enviable business parks and commercial developments at Prime Four and Westhill, and major new developments ongoing or planned at Aberdeen Airport, AECC, Blackdog, Marischal Square and elsewhere in and around the city. The construction of the AWPR will also generate economic confidence. Each of these enterprises has real potential to generate significant new employment opportunities and therefore raise confidence in the region. The new stadium and training facilities planned for Kingsford, by comparison, will generate relatively few additional jobs in the long term in relation to the number of staff that AFC already employs. Any additional jobs are likely to be part-time or seasonal. Staff will be re-located to an out- of-town site which could involve them in additional travel costs. At present, city-centre businesses benefit significantly from the trade generated by fans going to Pittodrie. Re-locating from Pittodrie will move trade to AFC’s own commercial facilities at Kingsford and to the relatively small numbers of bars and shops in Westhill/Kingswells. Trade in Aberdeen city centre will suffer. This conflicts with the City Centre Masterplan. Businesses in the Westhill shopping area will suffer on match days as people will simply stay away due to the threat of disruption and traffic congestion. This would also apply to the new retail park proposed at Prime Four (if it goes ahead).

Re-locating from Pittodrie to Kingsford will bring little (if any) benefit to the regional economy. It will take considerable trade and revenue away from Aberdeen city centre and conflict with the City Centre Masterplan. Kingsford has no economic advantage over other possible sites and is highly contentious as a location. The main beneficiary of the move will be AFC and this is not sufficient justification.

9.0 LIMITED BENEFITS TO THE LOCAL COMMUNITY

We cannot see how re-locating from Pittodrie to Kingsford will “greatly enhance the North-east’s position as a sporting powerhouse”. Whilst the Aberdeen Sports Village provides a wide variety of sport and leisure activities, the new facilities promised at Kingsford are nearly all football-orientated. Sports provision on offer for those who are not interested in football is very limited. People in Kingswells could benefit by having some new facilities on their doorstep, thus reducing the need to travel. However, there would be competition from groups and organisations in Westhill and elsewhere in the wider area, so opportunities would be restricted. It is very unlikely that local people

Kingswells Community Council 9 would benefit from any preferential rates for using community facilities. On balance, the perceived benefits do not outweigh the detrimental impact the proposed development would have on the area. KCC fully appreciates the wide range of community work provided by the Aberdeen FC Community Trust, including its efforts on health promotion, inclusion and support for those who are most needy. However, we wonder what the net benefits will be of a move to Kingsford. Much of the support on offer (eg. for primary school football) is done by outreach, so what is the advantage to the Trust of moving their base? Kingsford is more distant than Pittodrie from the most deprived areas of Aberdeen, so people in these areas who already benefit from the work of the Trust would be disadvantaged.

We see very limited benefits to our local community in Kingswells in terms of promoting wider participation in sport. AFC has failed to spell out how the claimed advantages would be achieved in practice. We appreciate the work done by Aberdeen FC Community Trust but a move from Pittodrie to Kingsford would disadvantage many of its existing users.

10.0 NON-FOOTBALL EVENTS IN THE STADIUM

As a business enterprise, AFC may on occasion decide to hire out the stadium for large non-football events (eg. rock concerts). These events could potentially breach the light and noise mitigation measures proposed for the stadium. This would be of particular concern to residents of Westhill. AFC’s Traffic Assessment does not deal with events like these. AFC argues that such events are unlikely to happen due to the uncertainty in guaranteeing dates. However, it would be possible to arrange dates out with the main football season. The club is a business and balance sheets will dictate what non-football activities are promoted. This can be evidenced by considering the activities held at other ‘community’ stadiums.

Large, non-football events held in the stadium would present real concerns about additional light and noise, and the management of traffic.

11.0 CONTROLLING ANTI-SOCIAL BEHAVIOUR

KCC accepts that most football fans are well behaved and are only out to socialize and enjoy the game. However, there will always be a minority who are not, and certain match fixtures may result in higher levels of crowd aggravation and disruption. KCC has particular concerns about the potential for antisocial behaviour in and around the Kingswells park-and-ride (where large numbers of fans will park cars and wait for buses), at Westhill shops, and the proposed Prime Four shopping area on the A944 (if it goes ahead). The possibility of fans using the narrow walkway/cycleway along the busy A944 to access the stadium from the park-and-ride is particularly worrying; not least for the fans’ own safety. We have no information about how Police Scotland will monitor these areas and whether there will be sufficient manpower to do it effectively. The city centre has CCTV which can help to monitor fans’ behaviour on the way to Pittodrie. In our area we have no effective CCTV coverage in potential trouble-spots. AFC would need to take a responsible approach to dealing with any littering or vandalism by fans in and around the Kingswells park-and-ride. It is not unreasonable that people in Kingswells have concerns about these matters. They will require firm reassurances from AFC, Aberdeen City Council and Police Scotland about how any problems will be dealt with.

Kingswells Community Council 10 Procedures for monitoring and controlling fan behaviour in public areas in Westhill and Kingswells lack clarity. This does not inspire confidence in the plans.

Appendix 1

Assumptions made in the Traffic Assessment.

The TA includes the predicted traffic flows from Prime Four Phase 5 retail. This application is only for the principle of a change of use from office development to retail. Approval for this has not yet been given. The traffic flows for a retail development included in the TA are very different to an office development that would result if the retail is refused planning permission. For an office development, the peak time traffic flows will be significantly greater than for a retail development. The peak time flows for the base case without the stadium are shown in Table 7-7 extracted from the TA. Section 7.6.3 of the TA identifies that “Some priority controlled junctions can begin to experience operational difficulties when an arm reaches an RFC value of 85%” The mitigation to the AWPR roundabout proposed in the retail application includes increasing the number of lanes from 2 to 3 for the following locations:  approaching the roundabout in both directions  on the roundabout  exiting the roundabout in both directions This would appear to be a significant amount of mitigation, and potentially the maximum amount possible for this junction. If the office development were to go ahead then the traffic flows would be much greater, and it would not be possible to mitigate the resulting traffic using the same mitigation measures proposed for a retail development. Consequently, a different arrangement would be required for the access into the Prime Four site, and the TA for the AWPR junction would be invalidated. Tables 7.8 and 7.9 show the anticipated traffic flows including the stadium. They are justified on the basis that the 212% figure for the stadium traffic is less then the 318% for the peak time traffic for the base case. The assumptions used for the stadium traffic underestimate traffic flows and the 212% figure could be significantly higher than predicted. In this case, the validity of the ‘least bad’ approach to justify traffic levels from the stadium must be questioned. It is also noted that the mitigation measures are not in place, and if they were to be provided as a result of Prime Four offices, the mitigation is likely to be different and the validity of the 318% figure would come into question. The phasing of the Prime Four developments and the stadium is important as the latter is dependent on the mitigation measures provided by the former.

The assumptions made in producing the TA are too optimistic, and will underestimate the traffic flows. There has been no sensitivity analysis prerformed to quantify the implications of a different set of assumptions. Consequently, little confidence can be taken from the figures provided in the TA

Kingswells Community Council 11

Kingswells Community Council 12 Appendix 2.

Use of the Park & Ride Car Parks

Table 6-4 of the TA (see below), shows the intended use of the various park and ride systems in and around Aberdeen by the supporters. The table is based on the following assumptions.  That the development has 1,600 on-site and 600 off-site parking spaces. This would be 867 more than the parking allowance permitted by ACC parking standards.  That the number of cars is the figure predicted by a survey of fans. The validity of the results is questionable.  The survey predicts a reduction in the use of the car when the stadium is moved from a city centre location to an out-of-centre location. This result is counter intuitive, and must be questioned.  That 3 supporters will share a car. This figure is unrealistic and can only be controlled by AFC officials, and will not apply to the P&R car parks.  That use of the P&R facilities by normal users will be less than 10% for most sites and 7% for Kingswells P&R.  There will be no other demand outside normal use, which was determined by two surveys.  Prime Four, one of the main users of Kingswells P&R will not require an increase in its requirements. The survey was taken during a downturn in the oil industry, so this is not likely to be a valid assumption. The Prime Four development has not started construction of Phase 4 or 5, which have been allocated for development in the ALDP.  Despite the apparent increase in demand for new P & R sites, and the need to expand existing sites, AFC assume that existing demand will be less than 10% of capacity. This does not allow for any future increases in the use of the P&R facilities by normal users. KCC concludes that the number of cars used by fans on match days will be underestimated, and that the amount of spare capacity of the P&R network is overestimated. Irrespective of this, KCC has conducted a sensitivity analysis of the data contained in Table 6-4 of the TA using more realistic occupancy rates for the cars used by fans when using the P&R. The results are shown in the following tables. Even when using the figures in the TA, the capacity of all the available P&R sites is only just sufficient for a European match for a car occupancy rate of 1.4. Using the number of cars from a valid survey, the spare capacity of the P&R network from annual forecasts and more realistic car occupancy rates would provide a better assessment of the utilization of the Park and Ride network. This is a fundamental component, and without this the TA is invalid.

The current TA gives very little confidence that traffic issues have been assessed properly. ACC Roads Department should conduct an independent assessment of the TA and the issues identified by KCC.

Kingswells Community Council 13 Number of Cars Accessing the City Centre and each P&R Site Based on 3 supporters per car Cety Kingswells Bridge of B of D A90 South Match Type Dyce P&R Ellon P&R Total Centre P&R Don P&R Extension P&R Average Game 167 555 190 912 Old-Firm 286 898 300 1,484 European 400 891 397 300 1,988 Capacity 950 1,000 650 350 1,000 250

Utilisation of P&R Facilities for 3 Supporters per Car Cety Kingswells Bridge of B of D A90 South Match Type Dyce P&R Ellon P&R Centre P&R Don P&R Extension P&R Average Game 58% 19% Old-Firm 95% 30% European 94% 40% 46% Capacity 950 1,000 650 350 1,000 250

Based on 2 supporters per car Cety Kingswells Bridge of B of D A90 South Match Type Dyce P&R Ellon P&R Total Centre P&R Don P&R Extension P&R Average Game 251 833 285 1,368 Old-Firm 429 897 900 2,226 European 600 897 900 585 2,982 Capacity 950 1,000 650 350 1,000 250 Utilisation of P&R Facilities for 2 Supporters per Car Cety Kingswells Bridge of B of D A90 South Match Type Dyce P&R Ellon P&R Centre P&R Don P&R Extension P&R Average Game 88% 29% Old-Firm 94% 90% European 94% 90% 90% Capacity 950 1,000 650 350 1,000 250

Based on 1.4 supporters per car Cety Kingswells Bridge of B of D A90 South Match Type Dyce P&R Ellon P&R Total Centre P&R Don P&R Extension P&R Average Game 358 833 764 1,955 Old-Firm 613 897 900 585 185 3,180 European 857 897 900 585 315 706 4,260 Capacity 950 1,000 650 350 1,000 250 Utilisation of P&R Facilities for 1.4 Supporters per Car Cety Kingswells Bridge of B of D A90 South Match Type Dyce P&R Ellon P&R Centre P&R Don P&R Extension P&R Average Game 88% 76% Old-Firm 94% 90% 90% 53% European 94% 90% 90% 90% 71% Capacity 950 1,000 650 650 1,000 250

Kingswells Community Council 14