Proposed Aberdeen City & Shire Strategic Development Plan Representation Form

Please use this form to make comments on the Proposed Aberdeen City & Shire Strategic Development Plan, ensuring that your comments relate to a specific issue in either the Proposed Plan, Proposed Action Programme or Strategic Environmental Assessment Environmental Report. Please include the relevant paragraph(s) and use a separate form for each issue you wish to raise.

The period for representations will run between Monday 8 October - Monday 17 December 2018

Name

Organisation (optional) On behalf of (if relevant) Address

Postcode

Telephone (optional) E-mail (optional)

What is your preferred method of communication:

What document are you Proposed Strategic Development Plan commenting on? Proposed Action Programme

Strategic Environmental Assessment Environmental Report

Issue Paragraph(s)

What would you like to say about the issue? (if you would like to write more than the box allows then please attach this form to any additional papers)

What change would you like to see made? (if you would like to write more than the box allows then please attach this form to any additional papers)

Please return the completed form and any additional papers:

• By Post : Aberdeen City and Shire Strategic Development Planning Authority, Woodhill House, Westburn Road, Aberdeen, AB16 5GB

• By Email : [email protected]

If you wish to fill out a Word form, please be aware that you must email the above address for a copy of the form. Please save any changes before submission.

Please ensure all representations are with us by midnight Monday 17 December 2018.

Thank you. For more information, please visit www.aberdeencityandshire-sdpa.gov.uk or contact the Strategic Development Planning Authority on 01467 539734.

Privacy Notice

Why does the SDPA need your information?

As part of the review of the Strategic Development Plan, the Strategic Development Planning Authority (SDPA) is obliged by the Town and Country Planning (Scotland) Act 1997 and Town and Country Planning (Development Planning) (Scotland) Regulations 2008 to consult on a Proposed Strategic Development Plan and Proposed Action Programme. The Environmental Assessment (Scotland) Act also requires us to consult on a Strategic Environmental Assessment Environmental Report.

If you choose to respond to the consultation on any of the above documents, or the associated documents which support them, then you must submit your name and address in order to ensure that your representation can be considered valid. This is because we are required by the legislation noted above to contact you in relation to your response.

By submitting a response to the consultation you understand that the SDPA will use the information contained in your response, including your personal data, as part of the review of the Aberdeen City and Shire Strategic Development Plan. This will include consultation on the Proposed Plan (including any subsequent Proposed Plan as Modified), but also the Examination of the Proposed Plan and its eventual approval.

Any personal information that you provide in response to this consultation will be jointly held by both Aberdeen City Council and Aberdeenshire Council on behalf of the SDPA. Aberdeen City Council and Aberdeenshire Council will therefore be the Joint Data Controllers for your information. This is because the SDPA is a partnership organisation made up of both Councils.

Following the end of the consultation, i.e. after 17 December 2018, your name and respondent identification number (provided to you by the SDPA on receipt of your submission) will be published alongside a copy of your completed response on the SDPA website.

Your name, respondent identification number and a copy of your response will be retained on the SDPA website until a decision on the approval of the Proposed Strategic Development Plan has been made by Scottish Ministers. This decision is currently expected sometime in 2019. Once a decision on the Proposed Plan is made by Scottish Ministers, your name, respondent identification number and response will be removed from the SDPA website.

Other personal contact details associated with your response; such as postal address, telephone number and / or e-mail address will not be made public, although we will share this information with Scottish Ministers and the Scottish Government’s Planning and Environmental Appeals Division (DPEA). We are obliged under the Town and Country Planning (Development Planning) (Scotland) Regulations 2008 to issue a copy of all unresolved issues to Scottish Ministers / the DPEA when submitting the Proposed Plan for Examination in Public. Scottish Ministers / the DPEA then have a statutory requirement to contact respondents via The Town and Country Planning (Scotland) Act 1997, which again makes it necessary for us to provide your response and preferred method of contact to them. Should the DPEA request further information from you then they may subsequently publish that information on the DPEA website.

The SDPA will only keep your personal data for as long as is needed. The SDPA will retain your response and personal data for a retention period of 5 years from the date upon which it was collected. After 5 years the SDPA will review whether it is necessary to continue to retain your information for a longer period.

Your Data, Your Rights

You’ve got legal rights about the way the SDPA handles and uses your data, which include the right to ask for a copy of it, and to ask us to stop doing something with your data.

If you are unhappy with the way that the SDPA or the Joint Data Controllers have processed your personal data then you do have the right to complain to the Information Commissioner’s Officer, but you should raise the issue with the Data Protection Officers first. The Data Protection Officers can be contacted by writing to:

▪ Mr Fraser Bell, Data Protection Officer, Aberdeen City Council, Legal and Democratic Services, Level 1 South, Marischal College, Aberdeen, AB10 1AU.

▪ Mr Andrew Lawson, Data Protection Officer, Aberdeenshire Council, Business Services, Town House, 34 Low Street, Banff, AB45 1AY

Response to Aberdeen City and Shire Proposed Strategic Development Plan

1. Our Plan

I would like to restrict my comments on the Plan to issues concerning the environment and particularly the Green Belt, defined in your glossary as: An area of countryside where strict planning controls are in place to protect landscape setting, maintain the identity of a place and provide land for recreation.

My comments are also coloured by the recent call for ‘bids for land use’ - particularly within the area of Banchory Devenick. As this area is mostly designated as Green Belt, those bids for new housing developments probably will infringe the ‘strict planning controls’ of that designation.

In general I am in favour of the Strategy’s proposals and objectives re environment, and am not calling for any particular changes, rather a commitment from the City and Shire that implementation of the strategy is faithful to and consistent with it.

2. Our Vision

I am pleased to see that one of the main aspirations of the plan focuses on: the City Region’s unique built, historic and natural environment, which will be protected and, where appropriate, enhanced as a key asset in underpinning a high quality of life and place. and that in order to achieve this the plan will need to protect and, where appropriate, enhance our valued assets and resources, including biodiversity, the historic and natural environment and our cultural heritage (2.3)

The protection of the natural environment, its biodiversity and quality and identity of specific place should be something that the City and Shire does not compromise at any cost.

3. Our Spatial Strategy

New settlement developments need to be very carefully considered, as was the case with Chapelton (ref 3.38), and must not violate the ‘strict planning controls’ of the green belt, in order to maintain high environmental quality.

Across these Areas there will continue to be pressure for housing in the countryside that is not connected to existing settlements. This pressure will be dealt with through the Rural Policies of the Aberdeenshire Local Development Plan, which should approach this by focusing new housing in, or as an extension to, existing settlements, particularly those which are well served by public transport. This will help to create and maintain successful and sustainable places and protect agricultural land for food production. (3.46)

Locating new developments in relation to existing ones, especially with access to good public transport, is sensible. Agricultural land needs to be protected, as this enhances the feeling of ‘countryside’, especially on the fringes of the City.

The objective of increasing tree cover is very welcome, and existing and new landowners / developers need to pay attention to this. Increasing tree cover (both community and commercial) can bring significant environmental, economic, social and community benefits, particularly if new planting respects the different functions of the land concerned and its role in a wider green network. There is clear potential to increase tree cover across Aberdeenshire while respecting the competing interests for land. This will contribute to a wider Scottish Government target of increasing tree cover and timber production, and recognising the role of woodland in mitigating climate change. (3.48)

4. Our Communities

The recognition of the importance of ‘placemaking’ is welcomed, and especially the objective to protect existing habitats. (4.1) in the role of this:

… Quality of environment and place provides a cornerstone for quality of life and can promote a sense of identity. (4.2)

The contribution of the historic and natural environment must be properly recognised. (4.3)

A companion concept to ‘placemaking’ might be ‘placesaving’ - ensuring that established areas of high environmental quality are protected and preserved. Existing assets of the historic and natural environment must be recognised and promoted. A sense of identity relates to ‘belonging’ to a place and enjoying the assets that contribute to quality of life.

With this in mind the statements about the ‘delivery of new homes’ must not compromise the ‘protection of existing habitats’:

Land brought forward for housing must be used efficiently, and brownfield sites and regeneration areas should be given priority. … Opportunities for redeveloping brownfield sites will vary from place to place and over time but need to be a clear priority. (4.8)

Housing Land Audit data indicates that there is sufficient housing land already available to meet this Housing Land Requirement for both the Aberdeen and Rural Housing Market Areas for the period 2020 to 2032 at current rates of completion. This is a result of the considerable allocations made under the Housing Land Requirements of the Aberdeen City and Shire Structure Plan 2009 and the Strategic Development Plan 2014. (4.14)

As such, it is possible that no further housing land allocations could be made for the next Local Development Plans. However; a considerable proportion of current allocations are strategic allocations, and if any of these sites failed to come forward, there is a risk that the housing land supply may not be maintained. (4.15)

These statements on prioritising brownfield sites and regeneration areas for new housing developments are welcomed. Decisions on new land allocations need to take into consideration those developments currently underway e.g. Riverside of Blairs, Chapelton, that have to date been slow to complete and/or have had disappointing house purchase rates. Developments in progress must be completed before new settlements are approved. It is interesting to note that in the Housing Methodology document a statement is made about “a declining need for new homes over the life of the Plan” (3.11).

However; it is likely that some new development will need to take place on greenfield sites in order to help deliver our Vision and future strategy for growth. Reducing travel distances and making walking, cycling and public transport more attractive to people will be important considerations, particularly for any new greenfield development sites that are proposed. (4.18) Allocations should be small scale in nature (4.19)

Your definition of ‘greenfield sites’ is “land which has not been developed, in either urban or rural areas”. Would this land in rural areas have a similar status as ‘green belt’? If not this needs to be clarified. If so, then ‘strict planning controls’ need to be adhered to. Also it would be good to clarify the term ‘small scale’.

5. Our Economy

The following statements on tourism and recreation are welcomed:

Specific support is given by this Plan to protecting and enhancing existing nationally and regionally important locations for tourism and recreational development. (5.3) The importance that the historic and natural environment makes to sustainable tourism must also, however, be properly recognised. (5.5)

Tourism is a very important consideration. For example the River Dee corridor is the main access to/from Royal Deeside and into the Highlands and as such needs to maintain is existing natural beauty. A key factor in achieving this is the rejection of new housing developments that lie close to or on the B9077.

Recreation - especially in terms of public access to green spaces - is a crucial feature of any civilised city/region, enhancing health and well-being (ref. 6.10). In particular the area of Banchory Devenick provides superb ancient woodlands e.g. Tollohill, Cranhill, Brodie, and surrounding green spaces, that are enjoyed consistently by walkers (including seniors’ walking groups), dog walkers, cyclists, schoolchildren, wild life enthusiasts, etc from across the City, as well as local residents and - importantly - visitors to the region.

6. Our Resources

The objectives / statements on the quality of the environment, importance of historic and cultural assets, protecting biodiversity, increasing tree cover, the special status of the River Dee are welcomed:

Ensuring only appropriate sites are promoted and supported for development, and that only high- quality design is accepted, will make sure that development safeguards and, where appropriate, enhances the historic, natural and cultural assets that the City Region has to offer. (6.1.)

I can only reiterate my previous comments about the value of trees, and hope that Councils respond to any violation of forest / woodland by landowners / developers.

The important contribution that trees make, whether as natural landscape features, designed landscapes or recreational facilities, cannot be underestimated. Trees provide a valuable ecological resource, as well as a significant contribution to the City Region economy. Trees, forest and woodland cover should be protected and increased where possible. It is particularly important to protect native and semi-natural woodlands and support their restoration. (6.2)

As a resident who lives on the doorstep of the River Dee, I particularly welcome the statements concerning this distinct natural asset. The River Dee is an important environmental as well as economic asset, as well as being the region’s main source of drinking water. It is designated a Special Area of Conservation reflecting its environmental importance. This resource is under pressure and, as a result, managing the use of water and increasing water efficiency is vital. During and beyond the period of this Plan, the effects of climate change and increasing water demand from development may affect the river. Both Councils will need to work together to reduce impacts on the River Dee. (6.6)

Any proposed development in the area of the river - designated a SAC - needs very careful thought as to its potential impact on the scenic quality of the valley, the water quality of the river, the health of its fish and the other wildlife that depend on it.

Returning to the concepts of ‘green belt’ and ‘green networks’, I am pleased to see the following statements on the protection and enhancement of biodiversity, wildlife habitats and landscape:

Biodiversity, wildlife habitats and landscape can be vulnerable to the effects of new development. When considering the location and design of new development, we need to focus on protecting and enhancing key features as well as ensuring habitat connectivity. Most importantly, we need to make sure there are no possible effects from proposed development on internationally, nationally or locally designated areas. (6.8)

The green belt around Aberdeen will continue to protect the character and landscape setting of the City and make sure that development is directed to appropriate locations. It will do so whilst protecting the most important undeveloped areas that contribute to the environment and provide the City with its setting. The green belt is an area that should be positively planned for, and involve integration of approach across Council boundaries. Local Development Plans should promote recreational access, landscape improvement and habitat enhancement within green belt areas and beyond. (6.9)

Local Development Plans will play a key role in identifying existing and proposing new green networks and, where appropriate, considering enhancement and implementation opportunities, including through new development. (6.11)

The area of Banchory Devenick has an impressive array of wildlife, including foxes, badgers, red squirrels, pine martens, roe deer, otters, kingfishers, buzzards, red kite, herons, pheasant, woodcock, snipe, barn owls, little owls, tawny owls, various species of bat and numerous uncommon moths and butterflies.

The historic environment is equally as important as the natural, and its protection is also paramount.

Structures, sites and areas valued for their contribution to the historic environment also contribute positively to a sense of place, the economy and the natural environment and should be protected from any negative effects of development. (6.12)

With specific reference to the area of Banchory Devenick, there a a number of historic structures and sites. The Causey Mounth is a 12th Century drovers road and is a designated Heritage Path (http://www.heritagepaths.co.uk/pathdetails.php?path=24). The northern slopes below Tollohill Wood were the resting and camping place of the Covenanter army coming up Causey Mounth from the south before the Battle of Aberdeen in 1646. In excavating the site of the current car park to the Wood, musket balls were found, and there are numerous other sites of archaeological significance e.g. prehistoric burial and ritual sites, cairnfields. One of the targets the Plan sets in relation to Resources is admirable:

To make sure that development safeguards and, where appropriate, enhances, the City Region’s historic environment, and that development will not lead to its loss or damage.

The Plan identifies how to meet this target:

Both Councils will protect and enhance biodiversity, wildlife habitats, landscape, green and water networks and other sensitive areas, and prevent habitat fragmentation, in identifying land for development, preparing masterplans and assessing development proposals.

This is a bold statement that necessitates a strong commitment from Councils in ordeer not to lose, damage or fragment key environmental resources.

8. Our Future - How this plan can make a difference

This Plan provides a Vision to develop the economy, maintain and improve the quality of our environment, and provide better places and a high quality of life. (8.1)

Aberdeen City / Shire is a wonderful place to live, with a distinct environment - from mountain to sea. The plan makes some excellent proposals through clear and achievable objectives. I can only reiterate my opening comments that all decisions and implementations are consistent with the Strategy.

17 December 2018