Appendix 2: Summary of responses resulting in no changes

Rep. Number

135 4 Subject General Summary An extensive document was produced in 1996 that was largely ignored and this is why a poor response will be received from local residents, they do not see the point in responding.

Draft Response: Acceptance: Do not accept Changes to be made

Structure plans must be regularly updated to ensure they are relavant and meet the needs of the structure plan area. Extensive consultation has been carried out with the public and other stakeholders and a good response was received to the draft plan consultation.

Rep. Number

182 1 Subject General Summary Around 315 acres of land is under the control of the client and they are in a position to deliver the development proposal. The land is located between Calder Park and Balmoral Group to the north, Kincorth to the west, Wellington Road to the east and Cairnrobin and Mains of Charleston to the south. They present an argument that this area of land would be appropriate for development in line with the Draft Structure Plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 182 2 Subject General Summary Note and welcome the forecast requirements for 12,000 additional houses on greenfield sites from 2007-2016, this is necessary to meet the demand in the city.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

182 3 Subject General Summary Note and welcome the 105 ha of employment land in from 2007-2023, and a strategic reserve beyond that.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

182 4 Subject General Summary Welcome the need for a Green Belt review and would observe that when last publicly examined, the Loirston/Charleston area was found to have capacity whilst retaining the most important characteristics of the Green Belt.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

182 7 Subject General Summary Welcome preparation of Masterplans.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 1 of 244 183 1 Subject General Summary Though prepared under the Town and Country Planning () Act 1997 and the T&CP (Structure and Local Plans) (Scotland) Regulations 1983, it seems to lean heavily on the Planning etc (Scotland) Act 2006, the plan must be careful not to fall between two stools.

Draft Response: Acceptance: Noted Changes to be made

The plan is intended to reflect the moderning planning agenda, but meet the existing requirements for a structure plan. The danger highlighted is recognised. 183 6 Subject General Summary The issue of a housing need assessment has still not been addressed in terms of PAN74.

Draft Response: Acceptance: Noted Changes to be made

The Housing Need and Demand Assessement as required by SPP3 is highlighted in the draft plan on p.17 and work on this has commenced. The level of detail that the structure plan needs will emerge at an early stage in the production of this document, thus allowing it to feed into the plan in due course.

Rep. Number

184 1 Subject General Summary Own land at and put forward what they feel is a justification for its inclusion in the plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

185 1 Subject General Summary Own 1000 acres of land at Kirkton of Rayne and put forward a justification for its inclusion in the plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

186 1 Subject General Summary Put forward proposals to allow Old Leslie/Leslie to expand.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

14 January 2009 Page 2 of 244 194 8 Subject General Summary 2008 Employment Land Audit emphasizes that 20.6 hectares of employment land is currently under construction in Westhill, outlying the significant demand in the settlement. The employment land audit recognizes that the uptake of employment land in Westhill is due to the shortfall of land in the city.

An application to address the shortfall for the provision of a further 11.25 hectares is currently pending, therefore there is a proven need for release of more employment land in Westhill.

Draft Response: Acceptance: Do not accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment.

The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated infrastructure measures needing to be in place before transport issues can start to be resolved. Until resolution further relase of land on the scale indicated would not be appropriate. However, it is appropriate to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. The draft plan identifies considerable employment land in Aberdeen.

Rep. Number

195 1 Subject General Summary Own substantial land adjoining and are keen to demonstrate a willingness to release land for development.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

196 1 Subject General Summary Own substantial land adjoining and are keen to demonstrate a willingness to release land for development.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

197 1 Subject General Summary Support is given to the target on p.10 to work with the University to help make a positive contribution to the area. Also support the recognition of initiatives to strengthen the knowledge economy on p.20. However, it is requested that specific recognition is given to the economic and cultural contribution the University makes.

Draft Response: Acceptance: Noted Changes to be made

This expression of support is welcome. The recognitiion requested would not add value to the plan.

Rep. Number

198 8 Subject General Summary is particularly well placed to absord additional housing allocations. It is a popular location and benefits from a range of services, facilities and employment land to provide a sustainable mixed community.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

14 January 2009 Page 3 of 244 200 7 Subject General Summary If is not accepted within the Aberdeen to Peterhead SGA the housing allocations in the LG&DA should be concentrated on the main settlements within the RHMA. They are already well served by community facilities and relatively well established road and public transport links to the City. These will require improvement, but this can only be done by encouraging further development.

Draft Response: Acceptance: Noted Changes to be made

The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

201 5 Subject General Summary The increase in housing should be concentrated on settlements that are well served by existing road networks and is well placed to absorb allocations due to its wide range of existing services. Its proximity to the A90 ensures it is accessible to the wider area and public transport. The re-opening of Station will benefit the wider area, including Fordoun, improving the popularity of the area for residential development.

A pending employment application NW of Fordoun will help balance new residential allocation in the settlement, giving people the chance to work and live there.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not promote development at Fordoun, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A90 corridor in which Fordoun lies (from S of to Laurencekirk) is allocated 1,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

202 2 Subject General Summary The current population of is at a level which is unsustainable in terms of securing the long-term operation of the primary school and additional facilities within the settlement. Therefore critical that the levels of growth are permitted that sustain the primary school, operation and enhancement of the current physical and community infrastructure and procure additional facilities to support the future population.

The re-opening of Laurencekirk Station will benefit the wider area by improving accessibility and the popularity of the area for residential development.

Draft Response: Acceptance: Noted Changes to be made

St Cyrus lies in the LG&DA (RHMA) and an identified RPA. This area is therefore not designated for strategic growth, but may still experience growth in line with the spatial strategy. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

203 4 Subject General Summary Completion rates for do not reflect local demand, which is consistently high. However, Aboyne Academy is currently over capacity and the primary is predicted to reach capacity in 2012. It is recognised that settlements such as Aboyne will continue to grow and given the educational constraint, a large allocation should be made, enabling developer contributions to facilitate provision of this infrastructure. This is the local need in Aboyne.

Draft Response: Acceptance: Noted Changes to be made

Aboyne lies in the LG&DA (RHMA). This area is not designated for strategic growth, but may still experience growth in line with the spatial strategy. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

14 January 2009 Page 4 of 244 204 5 Subject General Summary Through 'Firm Foundations' the Scottish Government forecasts a need for 35,000 new homes per year by the end of the next decade, instead of the 25,000 provided over the past ten years. Local authorities are required to set realistic housing targets to meet this vision and there is an argument for a 40% increase in the current rate of development.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan recognises the aspirations for house building in Scotland as set out in Firm Foundations and believes it has set a framework which can contribute to the levels of development sought. However, there is no target set nationally for the amount of housing that Aberdeen City and Shire should deliver and it is therefore appropriate to be moving in the right direction. To this end, the plan proposes a rise in annual house building from the current 2,200 to 2,500 by 2014 and 3,000 by 2020. This represents a rise of over 13% initially and over 36% latterly on current figures. Monitoring will be required to determine actual completions in current years as the effects of the current economic unstability become resolved and the capacity of developers builds again.

Rep. Number

205 3 Subject General Summary Overall, the plan appears to be a position statement rather than a strategy with stated aims and deliverability programme. Concerned about the lack of substance to support strategic statements and little direction for the project management and ownership of delivering the strategic vision. The plan should include reference to partners accountable for meeting specific targets, e.g. Health Plan, LTS and North East Waste Strategy. These plans and others will require to work together as LDP's alone will be unable to meet all the stated aims of the structure plan.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan is a statutory land use planning document and aims to reflect the modernising planning agenda by removal of superfluous information and duplication of other plans and strategies. This is not to say these are not important elements in the growth and protection of the north-east and it is likely that the "action programme" referred to throughout the plan (but particularly on p.19) will include projects as well as who will lead them, when they should happen and how they will be funded.

Rep. Number

231 3 Subject General Summary Is not clear how SSCI fits with allocations in the present local plan. Once these projects move forward it is important that a non-restrictive and flexible approach is carried forward into the local plans. Clients site connects to "Whitestripes" and "Perwinnes" and offers an opportunity to build a sustainable community connected to Goval AWPR junction and the Third Don Crossing that could accommodate 10,000 new homes, plus facilities and the town centre that Bridge of Don has always sought.

Draft Response: Acceptance: Noted Changes to be made

Application under the Scottish Sustainable Communities Initiative had to be made to the Scottish Government by September 2008 and the results of the assessment process will not be known until later in 2009. The draft plan recognises the need to engage with the initiative. There is no relationship with the present local plans.

Rep. Number

237 14 Subject General Summary is a small settlement SE of the SGA and within the RPA and believe this settlement offers a good opportunity to contribute to proposed growth in a location with easy access to the main transport corridor and SGA.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

238 12 Subject General Summary Land at Fordoun is capable of accommodating future development consistent with the SGA identified in the plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

14 January 2009 Page 5 of 244 239 14 Subject General Summary Land at is capable of accommodating future development of an appropriate scale within the SGA and RPA identified in the plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

240 12 Subject General Summary Believe land at can accommodate future development and contribute to the plan's housing allocations for the Stonehaven area whilst overcoming constraints such as pipelines and landscape impact and due to its proximity to the existing transport corridor.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

241 12 Subject General Summary Land at Blackburn is capable of accommodating future development, both residential, community and commercial consistent with the plan's SGA identified for the area.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

243 14 Subject General Summary Future profiling of AWPR junctions is essential as built capacities only take account of what is in approved plans. This lack of foresight is easily rectified on South Deeside with construction of a sufficiently large diameter surface roundabout to allow a fourth 'leg' to connect to the Netherley road.

Draft Response: Acceptance: Noted Changes to be made

The provision of infrastructure will play a key role in assisting to deliver the plans vision and spatial strategy. The principle of the road has been agreed and the Public Inquiry has now completed, however we await the recommendation on the finalised route. Additionally the AWPR is a Scottish Government supported project and as such the structure plan does not have influence over the specifics of the planned route. 243 15 Subject General Summary In terms of transport infrastructure and landscape impact, the proposal at Park Quarry, meets the objectives of the structure plan. It should be noted that it is intended to submit this proposal as part of the SSCI process by the 19 September deadline.

Draft Response: Acceptance: Noted Changes to be made

Noted.

Site specific issues will be addressed through the Local Development Plan process.

Rep. Number

253 8 Subject General Summary Overall the proposed development would be wholly consistent with the aims of the emerging Structure Plan in that it would help to grow and diversify the regional economy; provide additional jobs and facilities helping to improve quality of life; promote the highest standards of design; and address challenges of sustainable development through making the most efficient use off transport network, reducing the need for people to travel and making sure that public transport is an attractive choice.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process.

A copy of your representation will be forwarded to the relevant Team.

14 January 2009 Page 6 of 244 Rep. Number

255 3 Subject General Summary In Bancon’s view, it is essential that the finalised Plan more fully recognises and embraces the Scottish Government’s current stance in the delivery of housing land as set out in Firm Foundations and SPP3.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan already recognises the aspirations for house building in Scotland as set out in 'Firm Foundations' and SPP3 and believes it has set a framework which can contribute to the levels of development sought. Targets for new housing reflect both the Councils forecasts and the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland.

Rep. Number

259 1 Subject General Summary Generally the Draft Structure Plan appears to be at last looking positively on the potential of the area.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcome.

Rep. Number

261 1 Subject General Summary We welcome production of the draft plan as a proposed replacement for the current NEST document.

Draft Response: Acceptance: Noted Changes to be made

Noted.

261 20 Subject General Summary It is our opinion that the style and writing of the plan is easy to follow but bold statements must be followed by bold actions otherwise they are just words and lack no clear accountability nor mechanisms for delivery.

Draft Response: Acceptance: Noted Changes to be made

This expression of support is welcome.

The new format of structure plan does not provide detail of how targets will be met. However, an Action Programme will be prepared which will provide more detail in relation to what the two councils and partners need to do to implement the plan.

Rep. Number

262 9 Subject General Summary The clear emphasis of the Draft Plan on stimulating and supporting sustainable development is welcomed, as is the intended action programme.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

263 9 Subject General Summary The clear emphasis of the Draft Plan on stimulating and supporting sustainable development is welcomed, as is the intended action programme.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

14 January 2009 Page 7 of 244 Rep. Number

264 11 Subject General Summary The reference to the plan reflecting the hopes and ambitions of local communities and ACSEF is offensively inaccurate.

Draft Response: Acceptance: Do not accept Changes to be made

The plan has been prepared after extensive consultation with the public and other stakeholders. Specifically the plan has beeen influenced by regional strategies such as the Aberdeen City and Shire Economic Forum’s (ACSEF) Economic Manifesto.

The reference in the representation refers to the Energetica initiative which is an ACSEF promoted initiative. 264 26 Subject General Summary The hybrid nature of the structure plan pretending as it does to be a strategic development plan suggests that it will not survive an EIP. Rather than waste time on the document it should be abandoned and work should commence on a competent strategic development plan early in 2009.

Draft Response: Acceptance: Do not accept Changes to be made

The draft structure plan contains clear policy materials and a spatial strategy, which will allow subsequent local development plans to respond with allocations and policies. It sets a clear direction for both local development plans and development proposals. The text of the plan will be amended to avoid the impression that it might not comply with the secondary legislation. However the way the plan can be used will be different from previous structure plans.

The Town and Country Planning (Development Planning) (Scotland) Regulations 2008 set out the detailed requirements for Strategic Development Plans. The emerging structure plan, whilst conforming to current legislation has been prepared in the context of the Scottish Government’s modernising agenda and The Planning etc (Scotland) Act 2006.

The Planning etc. (Scotland) Act 2006 (Development Planning) (Savings, Transitional and Consequential Provisions) Order 2008 sets out the detail for the transitionary arrangements applicable to structure plans currently in preparation. The order provides that the plan will be processed in the ‘normal’ way as if the new legislation had not come into force when the plan is submitted on 27 February 2009. If the emerging structure plan was, for whatever reason, to be submitted to the Scottish Ministers on or after 28 February 2009, the order provides that the finalised structure plan would go through a process more akin to the approval of a strategic development plan.

Rep. Number

265 1 Subject General Summary The current DSP does not meet the objectives in three important ways, In providing more opportunities for Live/Work in rural areas, Regenerating derelict rural brownfield land and Identifying potential new clusters or building groups that have the potential to be well connected to existing service centers by provision of cycle routes and footpaths.

Draft Response: Acceptance: Do not accept Changes to be made

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another.

The glossary defines brownfield sites as "land, normally in towns and villages" thus very few opportunities for redevelopment of brownfield sites in the countryside would occur. It would be for the Local Development Plans to determine the appropriateness of sites outhwith urban areas, whether brownfield or greenfield and set policies for housing in the countryside.

The structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

Rep. Number

266 1 Subject General Summary In principle I agree with most of the aspirations set out in the document.

Draft Response: Acceptance: Noted Changes to be made

Support for the plan is welcomed.

14 January 2009 Page 8 of 244 266 3 Subject General Summary There is no mention in the plan of the council's strategy to deal with the anticipated changes in the oil industry within the North East as production is reduced and the industry relies more on exporting its knowledge and skill base. An encouragement to keep the oil companies in the North East or to replace the oil industry with new industries such as renewables.

Draft Response: Acceptance: Do not accept Changes to be made

The Plan acknowledges that for the economy a to grow the region must overcome factors such as changes in the Oil and Gas sectors. These could have a major impact, so the plan has a strong emphasis on diversifying the regional economy, as does the Aberdeen City and Shire Economic Forums "Economic Manifesto.

The plan makes reference to a number of sectors that have the ability to maintain and enhance the economy, including oil & gas, knowledge, R&D, tourism etc.

Rep. Number

268 5 Subject General Summary The proposal has been promoted through the Scottish Sustainable Communities Initiative, the factors for this have been taken into consideration and will continue to be.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

269 1 Subject General Summary Own a 300 hectare site at that is allocated in the Aberdeenshire Local Plan as a development opportunity.

A 200 hectare outline application has been lodged with planning.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

271 12 Subject General Summary Support the vision and the fact that much of the infrastructure would have to be provided by land owners from the increase in land values however still much detail to be decided on ie how key utilities providers will work so as to support the development

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

An Action Programme will be prepared to outline how the plan will be implemented. Local Development Plan Process will also have a key role in implementation.

Rep. Number

272 4 Subject General Summary Note the objective and support the plan in respect of quick preperation of LDPs, as consider this is the key to meeting the aims and spatial strategy of the plan.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

14 January 2009 Page 9 of 244 272 6 Subject General Summary The capacity study recently carried out shows land at Mains of Ury would be appropriate and permission has been granted for development at Ury estate, establishing the principle of development to the north and west of the A90.

Furthermore the AWPR fast link junction would be located near the Mains of Ury and because of this development woud be appropriate in this location.

The emerging structure plan should make reference to work already underway by the structure plan authorities to identify where future growth should take place.

Draft Response: Acceptance: Do not accept Changes to be made

The plan operates at the strategic level, where the role of individual settlements is not explored and level of growth is not imposed. This leaves the relevant Local Authority the flexibility to determine allocations on a case-by-case basis through the local development plan process. A copy of your representation will be sent to the relevant team.

In the interests of brevity and not to misunderstand their status, it would not be appropriate for the structure plan to make reference to this work being taken forward by the two Councils.

Rep. Number

273 1 Subject General Summary Control land to the west of and development here could be of a scale that could constitute a new settlement.

The area of land is located between the AWPR and A90 and would help meet the targets of the draft structure plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 273 4 Subject General Summary Submit justification for the inclusion of their 580ha of land at Newtonhill to be promoted for development because of its location on the rail network, it is well serviced by public transport, AWPR fastlink route closeby.

This site could create a development would also facilitate a balanced new community with integrated housing, employment, , schools etc.

It could accommodate 6000 houses.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

276 1 Subject General Summary Client owns substantial areas of land to the North of Aberdeen at Grandhome.

It is contigious with the development area in the north of the city, and close to various employment locations in the Don valley corridor.

The area would contribute to meeting all the objectives of the plan.

Depending on densities and other uses Grandhome has the potential to absord between 5000 and 10,000 houses. With 6-7000 being more realistic with other community, economic and open space uses.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

14 January 2009 Page 10 of 244 277 3 Subject General Summary Structure Plan should recognise the potential of the Counteswells area for a new future settlement/community.

Past assessments have demonstrated that this area has few landscape constraints and that development woud have a low landscape and visual impact.

If it is not felt that the plan should be specific about the location at this stage, it is recommended alternatively that the plan should identify the potential for a new settlement that its need, location and scale will be further informed through assessment.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

279 1 Subject General Summary Whilst we appreciate that it is not for the Structure Plan to allocate sites, we do consider that the Structure Plan is well placed to consider the opportunities available within strategic locations around the city, and to this end Craibstone is presented as offering strategic benefits.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 279 9 Subject General Summary The Aberdeen City & Shire Structure Plan Draft June 2008 sets an ambitious target for new housing provision in the north east. CALA welcomes this forward thinking plan and encourages the council to consider the options available around the city for meeting the ambitious growth target. In this regard CALA would like to recommend Craibstone to help in meeting those targets as a sustainable new community

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

281 4 Subject General Summary Recognise that the structure plan is not designed to focus on individual sites, but our site at Portlethen is capable of contributing to any strategic allocation and is consistent with the objectives in the draft structure plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

282 2 Subject General Summary There is no provision in the 2006 Act for a local development plan to be consistent with a structure plan. Recognise that secondary, transitional legislation is awaited, but no assurance that this fatal anomaly will be resolved, so the future of this plan is uncertain.

Draft Response: Acceptance: Do not accept Changes to be made

The secondary legislation published in December 2008 allows for local development plans to be prepared in strategic development plan areas in advance of the strategic development plan. In such cases the local development plan must be consistent with the structure plan. 282 3 Subject General Summary Sincerely hope that the Scottish Government has no intention of somehow allowing a local development plan to be ‘teamed’ with this draft structure plan, as this is in serious conflict with the primary legislation. Has the potential to condemn the north-east to many more years without a competent development plan.

Draft Response: Acceptance: Do not accept Changes to be made

No "serious conflict with primary legislation" arises. This is what is provided for in the secondary legislation. It would have been a failure to make this allowance which would have caused development plan delay.

14 January 2009 Page 11 of 244 282 5 Subject General Summary The plan has not been prepared in an inclusive manner, the early stages were anything but. Several vital stages were missed altogether, notably a greenbelt review and the Housing Needs Assessment (HNA).

Draft Response: Acceptance: Do not accept Changes to be made

The plan has been produced in a very open and inclusive manner, as evidenced by the Publicity and Consultation Statement. The housing need and demand assessment is currently being produced. The level of detail needed to continue with the structure plan will be available on time and the plan will be amended accordingly as stated on p.17. There is an agreement between the two councils to carry out a review of the greenbelt. It will be carried out early on in the process as part of the implementation of the structure plan.

Rep. Number

284 1 Subject General Summary The early consultation undertaken seemed to be more of a box-ticking exercise than a serious attempt at engagement. Got the impression that there was a preferred outcome and this has fed through into the draft plan.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan has been subject to a high level of consultation over a period of two years. The options for the spatial strategy were considered at considerable length following extensive consultation with both Councils’, communities and with stakeholders. The plan presents a clear and rounded view of future development and represents a vision of the future shared across the whole of the city and shire area.

Far from being a tick box exercise it informed the development of the draft issues report and structure plan.

It should be noted that the structure plan will be subject to regular reviews to ensure it is consistent with economic and social changes that may affect the strategy.

Rep. Number

285 4 Subject General Summary Recent planning applications for commercial development have been refused in . The requirement for development on brownfield sites is a further obstacle to development along with the sequential test. Furthermore, the need for developers to contribute more towards infrastructure will mean schemes become increasingly unviable.

Draft Response: Acceptance: Do not accept Changes to be made

The emphasis on brownfield redevelopment is consistent with national policy and a valuable regeneration mechanism, but this does not preclude greenfield development where appropriate. However, this balance will be for the local development plan to determine. The principle of developer contributions is well established in the north east and planning gain is recognised as a means of addressing infrastructure deficiences that result from development. The failure to provide necessary infrastructure would make some of the developments unacceptable given the impact. Developer contributions are one way of addressing this.

Rep. Number

286 1 Subject General Summary Supportive of the aspirations in the draft plan to allow the north-east to prosper. However, believe that the supply of housing and employment land, particularly in Aberdeen, has been constrained over a sustained period and welcome plans for front-loading land releases as it is essential to allow catch up and the necessary growth to occur. The ‘credit crunch’ should not lead to any reductions on the allocations shown.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcome. The draft structure plan is a long term strategic land use planning document and current economic conditions have not resulted in reductions on the allocations shown.

14 January 2009 Page 12 of 244 286 2 Subject General Summary Concerned that the structure plan does not meet legislative requirements of the 1997 or the 2006 Act and could be subject to a legal challenge. It does not meet the provisions of PAN37 due to the lack of policies and reference to other policy documents. A structure plan should be clear, concise and robust to inform future local plans and to take planning decisions generally.

Draft Response: Acceptance: Do not accept Changes to be made

The draft structure plan contains clear policy materials and a spatial strategy, which will allow subsequent local development plans to respond with allocations and policies. It sets a clear direction for both local development plans and development proposals. The text of the plan will be amended to avoid the impression that it might not comply with the secondary legislation. However the way the plan can be used will be different from previous structure plans.

The Town and Country Planning (Development Planning) (Scotland) Regulations 2008 set out the detailed requirements for Strategic Development Plans. The emerging structure plan, whilst conforming to current legislation has been prepared in the context of the Scottish Government’s modernising agenda and The Planning etc (Scotland) Act 2006.

The Planning etc. (Scotland) Act 2006 (Development Planning) (Savings, Transitional and Consequential Provisions) Order 2008 sets out the detail for the transitionary arrangements applicable to structure plans currently in preparation. The order provides that the plan will be processed in the ‘normal’ way as if the new legislation had not come into force when the plan is submitted on 27 February 2009. If the emerging structure plan was, for whatever reason, to be submitted to the Scottish Ministers on or after 28 February 2009, the order provides that the finalised structure plan would go through a process more akin to the approval of a strategic development plan.

The secondary legislation published in December 2008 allows for local development plans to be prepared in strategic development plan areas in advance of the strategic development plan. In such cases the local development plan must be consistent with the structure plan. 286 3 Subject General Summary It appears that it is not an option for a local development plan to conform with a structure plan under the terms of the legislation. Hope that a legal issue such as this does not delay the preparation of the local plan and ultimate delivery of the strategy.

Draft Response: Acceptance: Do not accept Changes to be made

The secondary legislation published in December 2008 allows for local development plans to be prepared in strategic development plan areas in advance of the strategic development plan. In such cases the local development plan must be consistent with the structure plan. 286 12 Subject General Summary With regard to the provision of infrastructure (in the City), it is essential that current infrastructure, especially schools are being fully utilised before there is a need for new ones to be provided.

Draft Response: Acceptance: Noted Changes to be made

Phasing of development is outlined within the plan to ensure that development makes full use of existing infrastructure before building afresh. In this way infrastructure constraints that will need to be resolved prior to significant levels of development taking place.

An example of this is the limited numbers in the A90 (north) corridor until the AWPR, to Tipperty dualling and Third Don Crossing are in place. It is also necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period.

Rep. Number

287 1 Subject General Summary Believe that land for housing and employment has been constrained for a significant period of time (particularly in the City) and it is therefore essential that land be released quickly to allow the necessary catch up, as well as the necessary growth to occur. Support the front-loading of land releases and the need for sustainable mixed communities.

Draft Response: Acceptance: Noted Changes to be made

The support is welcomed.

Front-loading of City development is deemed necessary to 'catch-up' with recent lack of completions and resulting problems this creates.

14 January 2009 Page 13 of 244 287 2 Subject General Summary The plan should refer to Government policy announcements such as Firm Foundations (FF) and associated statements making it clear that increased housing construction is needed to meet demand, deal with affordability and support economic growth. FF seeks a rise in housebuilding to at least 35,000 units per annum by 2015, a target the industry believe achievable.

Development plans will have to therefore allocate more land for housing and development management will have to promote development more quickly.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan recognises the aspirations for house building in Scotland as set out in Firm Foundations and believes it has set a framework which can contribute to the levels of development sought. However, there is no target set nationally for the amount of housing that Aberdeen City and Shire should deliver and it is therefore appropriate to be moving in the right direction. To this end, the plan proposes a rise in annual house building from the current 2,200 to 2,500 by 2014 and 3,000 by 2020. This represents a rise of over 13% initially and over 36% latterly on current figures. Monitoring will be required to determine actual completions in current years as the effects of the current economic unstability become resolved and the capacity of developers builds again.

The structure plan proposes an early, front-loaded release of land to facilitate growth and meet the expectations of all stakeholders, both in communities as well as in the public and private sector. The identification of land for development will be done through the local development plan process in both Aberdeen City and Aberdeenshire. 287 3 Subject General Summary Do not believe that the current 'credit crunch' should persuade any reduction in the numbers proposed. Firmly of the view that this is a short term issue.

Draft Response: Acceptance: Accepted Changes to be made

Agree with the sentiment expressed. The plan considers development up till 2030 and so the current economic situation will have little impact on long term growth. 287 6 Subject General Summary The plan must set out a framework of policies that ensure the delivery of effective land, particularly in Aberdeen City. This must be coupled with a realistic, phased delivery programme. To ensure the growth of the economy the plan must also makes steps to attract further skilled employment to the region.

Draft Response: Acceptance: Noted Changes to be made

The draft structure plan contains clear policy materials and a spatial strategy, which will allow subsequent local development plans to respond with allocations and policies.

Phasing developments will be necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period.

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Rep. Number

288 2 Subject General Summary Plan fails to take account of the fundamental transformation of employment by the development of IT.

People can now work from home, or from facilities close to home.

The development corridors appears to be based on out-of-date models of a working society transported by road.

Draft Response: Acceptance: Do not accept Changes to be made

The plan seeks to provide integrated development of residential and comercial land uses, and as such states that "all new developments contribute towards reducing the need to travel and encourage people to walk, cycle or use public transport." (Pg18 Accessibility).

However, it is recognised that travel to work is likely to continue to be important during the plan period and the spatial strategy offers the opportunity to use the most frequent and accessible public transport modes (bus and rail) and concentrate development instead of widespread dispersal, which would encourage greater car useage and travel.

Rep. Number

14 January 2009 Page 14 of 244 289 2 Subject General Summary The identified sites ignore rising fuel costs and potential damage to the environment.

Draft Response: Acceptance: Do not accept Changes to be made

The plan seeks to provide integrated development of residential and comercial land uses, and as such states that "all new developments contribute towards reducing the need to travel and encourage people to walk, cycle or use public transport." (Pg18 Accessibility).

However, it is recognised that travel to work is likely to continue to be important during the plan period and the spatial strategy offers the opportunity to use the most frequent and accessible public transport modes (bus and rail) and concentrate development instead of widespread dispersal, which would encourage greater car useage and travel. 289 4 Subject General Summary A new town would be preferred if it meant that development in Fintray and Blackburn would be minimised.

Suggest Stonehaven - or Westhill to Alford Areas, these have links with AWPR.

Draft Response: Acceptance: Noted Changes to be made

A number of new settlement proposals were submitted in response to the draft plan. Some of these were in line with the plan’s strategy and some were not. However, none are at a stage where they could be given support through the structure plan. This issue will need to be addressed in the Action Programme so that decisions can be made in the strategic development plan. 289 5 Subject General Summary Where new development is planned it is essential that the necessary infrastructure is planned and work starts on it at the same time as everything else.

Draft Response: Acceptance: Noted Changes to be made

Infrastructure provision is an essential part of planning new developments and it is important to have measures in place to ensure that needs are met.

The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. The plan strongly emphasises the need to ensure required infrastructure improvements are in place prior to development.

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

290 4 Subject General Summary The plan is flawed in its transfer of housing to the city. People will prefer to live in the shire for the reasons they do now.

The urbanisation of Aberdeen's green belt on the scale envisaged will reduce the quality of life in the outer areas of the City and simply increase outward migration to the shire.

Draft Response: Acceptance: Do not accept Changes to be made

In 2007 the split of households between Aberdeen City and Aberdeenshire was 50.5% and 49.5%, while in terms of dwellings the figures were 50.9% and 49.1%. The background research for the plan clearly established that development in or close to Aberdeen had significant benefits. In light of these factors, a split of new developments around the 50/50 level was deemed appropriate as a basis for the structure plan.

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

The allocation of specific sites will be determined through the Local Development Plan process.

14 January 2009 Page 15 of 244 290 6 Subject General Summary It is evident from rising food prices that farmland will be needed to be conserved to ensure our future sustainaiblity and self sufficiency.

The zoning of excessive amounts of farmland for housing developments is very unwise.

Draft Response: Acceptance: Noted Changes to be made

The structure plan has not zoned land for housing developments.

It is likely that the majority of development in SGAs will be as extensions to existing settlements as this allows for the use of established services and facilities and maintains the sense of community. All areas outwith Strategic Growth Areas are classified as Local Growth and Diversification Areas however "Local Development Plans, in line with Scottish Planning Policy, should approach this by focusing new housing in, or as an extension to, existing settlements". The Structure plan allows for growth within small villages at an appropriate scale for that settlement.

The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

Rep. Number

292 2 Subject General Summary Key to "sustaining a high quality of life" is the creation and adoption of a fully integrated city and shire transport scheme, with a radical approach to getting people out of cars.

The draft structure plan does not address this.

Draft Response: Acceptance: Do not accept Changes to be made

The Structure Plan spatial strategy focuses development in places where there are clear opportunities to encourage people to use public transport and enables efficient provision of services whilst aiming to reduce the percentage of car. Furthermore, objectives such as Accessibility plan 'To make sure that all new developments contribute towards reducing the need to travel and encourage people to walk, cycle or use public transport by making these attractive choices.'

However, the structure plan is not the place to develop long term transport strategies; this would be duplication of the work of NESTRANS and the Regional Transport Strategy, or the Aberdeenshire Local Transport Strategy.

Rep. Number

297 1 Subject General Summary Use of forecasts for population growth and housing demand which are not supported by the council's own Strategic Forecasts.

The High Scenario case of population growth to 2031 completely distorts the basis for the draft Structure plan.

Draft Response: Acceptance: Do not accept Changes to be made

The population target of 480,000 by 2030 set out in the draft structure plan is higher than both the ‘Principal Projection’ of the GROS and the Probable-case forecast prepared by the two councils. However, the target is within the range established by both publications, and is lower than the GROS high projection (2006 based) of over 500,000. More detail is set out in the 'Background Paper' published with the draft plan.

Rep. Number

298 7 Subject General Summary Housing market area should be extended.

Draft Response: Acceptance: Partially accept Changes to be made

In 2006, Aberdeen City and Aberdeenshire Councils jointly commissioned DTZ Consulting and Research to undertake a review of housing market areas. The review found some evidence to support the extension of the existing Aberdeen Housing Market Area (HMA) boundary however it was felt that the scale of change proposed did not warrant a change of Housing Market boundary for this Structure Plan. The first Strategic Development Plan will provide an opportunity to revaluate this position.

Rep. Number

14 January 2009 Page 16 of 244 300 1 Subject General Summary In general support the proposals of the draft plan.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

301 4 Subject General Summary Promote inclusion not exclusion.

Draft Response: Acceptance: Noted Changes to be made

Agree. Part of the Plan's vision is to make "our society being more inclusive".

Rep. Number

302 20 Subject General Summary Question using the high migration population projections. It would be more prudent to use the 'principle projections' and the 'probable case' projections to arrive at an anticipated population for the city region of 458,000 - 468,000 in 2030.

Draft Response: Acceptance: Do not accept Changes to be made

Population growth is a challenge that must be met to ensure prosperity of the city region over plan period.

The draft plan aspires to growth rates in excess of the "probable" scenario. It is recognised that this will represent a considerable challenge. It is worth noting that the GRO(s) projections include a "high" scenario which sees the populaiton rise to 500,000. More detail is set out in the "Background Paper" published with the draft plan. 302 21 Subject General Summary The structure plan needs to be more explicit about the type of housing to be built and its implications for the allocation of land in diffierent locations.

Changes in household sizes are extremely important and must be considered.

Draft Response: Acceptance: Partially accept Changes to be made

The plan aims to deliver a range of different sized housing to meet the needs of all members of the community, including the elderly, people on lower incomes etc. The plan promotes a greater mix of housing and this will be investigated through the housing need and demand assessment referred to on p.17. These aspirations will be determined through the local development plan process, masterplanning and supplementary planning guidance.

Rep. Number

14 January 2009 Page 17 of 244 303 3 Subject General Summary It is unlikely that residents of Kintore will stand idly by and allow repetition of previous issues.

No public consultation ever took place regarding the disposal of developer contributions, the community has seen no benefits.

Developer contributions should be bricks and mortar ie building community centres and expanding medical centres, and not just handed over in cash.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed. In addition capacity studies may be used and masterplans produced for use at the settlement and large site level to ensure that the situation outlined by the respondant is not repeated.

With regards to developer contributions Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

304 14 Subject General Summary Should be minimum intrusion into the green belt.

Draft Response: Acceptance: Noted Changes to be made

There will be a greenbelt review will examine the boundaries to accommodate the levels of growth anticipated, whilst retaining the most important areas. Despite the high numbers, only a small percentage of land will be developed.

Rep. Number

306 2 Subject General Summary Agree with the objectives and proposals of the Structure Plan, and that a combined City and Shire approach is the way forward.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

307 20 Subject General Summary The plan contains many elements that are attractive to the community council and the team should be congratulated in formulating a Policy which endeavours to place a more proactive and holistic approach to future planning needs for the greater North East area.

Draft Response: Acceptance: Noted Changes to be made

This expression of support is welcome.

Rep. Number

308 1 Subject General Summary We are also concerned that local people are unable to source affordable or social housing.

Draft Response: Acceptance: Noted Changes to be made

The provision of affordable housing is of great importance. The Objective on Sustainable Mixed Communities has a target to ensure that;

"new housing meets the needs of the whole community by providing at least 25% of affordable housing"

The mix of housing will be determined through the local development plan process, masterplanning and supplementary planning guidance.

14 January 2009 Page 18 of 244 308 1 Subject General Summary Concern that houses built recently in Gourdon are making the town a dormitory settlement.

There are also concerns that the housing that has been built is not affordable for local people.

Concerns that the new housing in the past has not integrated well into the community

Draft Response: Acceptance: Noted Changes to be made

Future communities will be mixed in terms of the type and size of homes, as well as their tenure and cost. The Plan also aims to make sure that new homes are designed to a high standard, respecting the existing qualities of the area.

The provision of affordable housing is of great importance. The Objective on Sustainable Mixed Communities has a target to ensure that; "new housing meets the needs of the whole community by providing at least 25% of affordable housing" The mix of housing will be determined through the local development plan process, masterplanning and supplementary planning guidance. 308 2 Subject General Summary The current housing that is being built is not in keeping with the traditional vernacular.

Draft Response: Acceptance: Noted Changes to be made

The plan aims to facilitate mixed communities in terms of the type and size of homes, as well as their tenure and cost. All new homes will designed to a high standard, respecting and improve the existing qualities of the area. 308 4 Subject General Summary Concerns with the condition of roads, road condition, road safety, lack of public transport, planning gain money being spent elsewhere, vandalism, anti-social behaviour etc.

Draft Response: Acceptance: Do not accept Changes to be made

Concerns raise are noted however the structure plan is a high level strategic document and is not the appropriate medium to give detailed information with regards to how public transport and public safety will be improved. Improvements to the public transport systems and road are largely a matter for the regional and local transport strategies, while issues relating to vandalism are best tackled in other strategies.

The plan acknowledges the need to invest in the infrastructure of the structure plan area, especially given the predicted growth over the plan period. Provision of infrastruture must be considered very early in the development process, and contributions towards costs, within their own site, and where the development has wider effects extra contributions may need to be raised, additionally the public sector will also need to make an important contribution.

Rep. Number

311 1 Subject General Summary No problems with the Strategic Plan and are wholeheartedly welcome the SGA from Aberdeen to Peterhead.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

312 1 Subject General Summary Agree with the draft structure plan but have concerns with its financial viability (and as such the representation is more of a priorities wish list).

Draft Response: Acceptance: Noted Changes to be made

Noted.

Rep. Number

14 January 2009 Page 19 of 244 313 2 Subject General Summary No reference in the plan on protection of high quality agricultural land.

Draft Response: Acceptance: Noted Changes to be made

The requirement to protect high quality agricultrual land no longer applies. Notwithstanding this fact, the plan does not concern itself with issues that are not strategic or cross-boundary. However, the quality of agricultural land is likely to be one factor considered in the site selection process for new development. 313 4 Subject General Summary Concerns with further traffic using the A92, there are several junctions that will require upgrading if the plan is to be adopted.

Draft Response: Acceptance: Noted Changes to be made

The Regional Transport Strategy is the main document covering transport issues in Aberdeen City and Shire. However, the plan does identify the critical importance of infrastructure and this will be highlighted even more in the finalised plan.

Rep. Number

319 1 Subject General Summary It appears that even if every community in Aberdeenshire is experiencing the same problem (e.g. growth in elderly populations and lack of suitable residential care, rise in youth vandalism and lack of sports facilities, lack of public transport etc. ) these are not to be considered ‘strategic issues’ but over and over again we are told these are Local Plan issues.

The Structure Plan proposals fail to consider whether these widespread local problems will be improved or made worse by the proposals.

Draft Response: Acceptance: Noted Changes to be made

Provision of services listed are not covered by the structure plan which focuses on landuse planning, but are covered by other strategies and policies, for example the Regional Transport Strategy. 319 2 Subject General Summary Concern with the consultation events and process.

Draft Response: Acceptance: Noted Changes to be made

The structure plan has been subject to a high level of consultation over a period of two years. The options for the spatial strategy were considered at considerable length following extensive consultation with both Councils’, communities and with stakeholders. The plan presents a clear and rounded view of future development and represents a vision of the future shared across the whole of the city and shire area.

The consultation events informed the development of the draft issues report and structure plan. 319 3 Subject General Summary Further growth in Aberdeenshire that is unrelated to jobs growth has not been justified.

Draft Response: Acceptance: Do not accept Changes to be made

The draft structure plan does not seek to justify "growth in Aberdeenshire that is unrelated to jobs growth".

The draft structure plan seeks to provide opportunities for business, industry and housebuilding. The relationship between population and employment growth is more complex than one leading and the other following.

14 January 2009 Page 20 of 244 319 10 Subject General Summary Despite, I would suggest, the on-going demonstration of the failure of past policies we are promised more of the same - i.e. massive growth in Aberdeenshire divorced from the main centre of employment.

It would have been helpful to have been able to judge the statistical trends for each community on rural crime, road accidents, drugs use alongside the statistics on overcrowded schools, lack of job opportunities and lack of sports and other recreational provision.

With the above statistics available we might have encouraged community participation in this important planning exercise.

Draft Response: Acceptance: Do not accept Changes to be made

The Structure Plan is very different from past policies, with emphasis on social and economic development and sustainability. The issues raised are not planning issues, and are not strategic in nature, as a result the provision of statistics would not add anything meaningful. 319 11 Subject General Summary Planning gain does not create good, balanced sustainable communities and will do nothing to improve the existing problems in rural communities.

Draft Response: Acceptance: Noted Changes to be made

Planning gain in itself will not create good balanced communities, and is part of the system of dealing with the issues resulting from development rather than the existing problems in an area.

Rep. Number

324 1 Subject General Summary No mention of the Draft Structure plan is made in the representation but they have raised concerns with the Princes Foundation proposals.

Draft Response: Acceptance: Noted Changes to be made

Rep. Number

330 1 Subject General Summary The strategic, clear, accessible and action-orientated layout of the Draft Structure Plan is refreshing

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

330 2 Subject General Summary While final NPF2 has not yet been put into legislation, it is a positive sign of progress on planning reform that the Aberdeen City and Shire Draft Structure Plan has been written with it in mind.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

330 29 Subject General Summary The Cairngorms National Park is outwith the area of the Structure Plan and has a separate plan, but it may be worth the final Structure Plan commenting on the relationship between it and the Park’s plan and how those parts of Aberdeenshire immediately outside it can act as a gateway to the Park itself.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan is required to be a short and concise document which focuses on the key issues. The suggested additions would not add value to the plan but would add to its length, diverting the reader from its central purpose.

Rep. Number

14 January 2009 Page 21 of 244 331 7 Subject General Summary We appreciate the simplification of the structure plan.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

331 8 Subject General Summary Development of infrastructure and services requires planning and investment. The structure plan will extend well beyond the short tem business and political life cycles. For this reason we are seeking structure plan which is visionary, challenging and provides a ambitious solutions commensurate with a European city of standing.

Draft Response: Acceptance: Noted Changes to be made

The structure plan is to set a clear direction for the future development of the North East till 2030.

Infrastructure provision is an essential part of planning new developments and it is important to have measures in place to ensure that needs are met.

Rep. Number

334 16 Subject General Summary Generally the draft is clear and easy to read. However, clarity of the actual content is lacking throughout the plan.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Local development plans and an Action Programme will be prepared which will provide more detail on in relation to issues in the plan.

Rep. Number

338 1 Subject General Summary The John Lewis Partnership in Aberdeen welcomes and supports the City and Shire’s joint vision for the North East city region.

Draft Response: Acceptance: Noted Changes to be made

Support for the plan is welcomed.

Rep. Number

343 1 Subject General Summary Much of this new plan is to be welcomed if the north east is to remain a place to do business and provide employment.

Draft Response: Acceptance: Noted Changes to be made

Support for the plan is welcomed.

Rep. Number

344 1 Subject General Summary I am in favour of the general aims of the plan and see no reason to criticise the overall strategy.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

14 January 2009 Page 22 of 244 347 3 Subject General Summary Development should be led by business and industry rather than housebuilding.

Draft Response: Acceptance: Do not accept Changes to be made

The draft structure plan seeks to provide opportunities for business, industry and housebuilding. The relationship is more complex than one leading and the other following.

Rep. Number

349 1 Subject General Summary The Group welcomes the commitment that we will be ‘confident, courageous and robust’ in setting forth the aims and objectives of the Plan. It very much supports the demand that it be ‘front loaded’.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

350 2 Subject General Summary I find this plan to be vague and unhelpful

Draft Response: Acceptance: Do not accept Changes to be made

Extensive work has gone into creating a coherent vision and aims for the city region which is consistent with the regional economic strategy.

An Action Programme will be prepared which will provide more detail in relation to what the two councils and partners need to do to implement the plan. In addition monitoring has been embedded in the content of the plan.

Rep. Number

353 2 Subject General Summary Strongly object to housing developments in Blairs for environmental and social reasons.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The determination of specific planning applications is the role of the Development Management section of each Council. Each proposal must be judged on its merits.

Rep. Number

355 1 Subject General Summary Draft plan is pure speculation and fantasy.

Propose that the draft plan be revisited and start from scratch with realistic figures, more transparency, more professionalism and no interference from developers.

Draft Response: Acceptance: Do not accept Changes to be made

The draft plan is based on relevant background information to collected and analysed to help with the strategic planning process. This is contained in both the Report of Survey and the Background Paper. Additionally there will be regular monitoring throughout the plan period. 355 3 Subject General Summary Reference to proposal at Braehead and stated that the choice of site is contrary to the vision of the draft plan in terms of environmental concerns, local identity, quality of life, tourism etc.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The structure plan is a high level strategic document and is not the appropriate medium to give detailed information with regards to individual developments. Specific sites will be allocated through the local development plan process.

Rep. Number

14 January 2009 Page 23 of 244 363 1 Subject General Summary Object to local plan on grounds of:

- Having a disastrous effect on the greenbelt. - Inadequate infrastructure exists to support new households. - Aberdeen's projected demographic development indicates that there will be no need for the scale of development proposed.

Draft Response: Acceptance: Do not accept Changes to be made

-The retention of a green belt around Aberdeen is of fundamental importance, although the plan recognises that it will need to be reviewed to accommodate the levels of growth proposed. It is important to review the green belt to identify areas to continue to be protected as well as the areas that may be suitable for development. Although a substantial amount of development may be proposed on City greenfield sites, this continues to represent a very small percentage of the actual land available.

-The support, and provision, of infrastructure play a key role in assisting to deliver the plans vision and spatial strategy. Contributions towards necessary infrastructure, services and facilities within developments will be undertaken by developers, however, in cases where development has wider effects, we will have to secure extra contributions to provide a large percentage of the new infrastructure needed, and in addition the public sector will also need to make an important contribution.

-The population target of 480,000 by 2030 set out in the draft structure plan is higher than both the ‘Principal Projection’ of the GROS and the Probable-case forecast prepared by the two councils. However, the target is within the range established by both publications, and is lower than the GROS high projection (2006 based) of over 500,000. More detail is set out in the 'Background Paper' published with the draft plan.

Rep. Number

368 1 Subject General Summary Against the Aberdeen City and Shire concept. Two separate authorities should conjoin reducing the cost to the taxpayer of duplicating costs.

Draft Response: Acceptance: Do not accept Changes to be made

The Scottish Ministers have published Circular 3/2008, accepting the submission made by the Aberdeen City and Shire Strategic Development Planning Authority and setting the plan area following consultation earlier in the year. 368 3 Subject General Summary Concern was raised as to numerous aspects of the town of Stonehaven:

- Primary schools are beyond capacity - Secondary school accommodates pupils in portabins - Medical centre cannot be extended any further - Parking in the town centre is problematic - Town centre roads are controlled by traffic lights and are congested with queuing traffic - Stonehavens infrastructure has reached saturation point

Development at Braehead/Newtonleys would have a negative effect on the town. Concern was raised that sewerage facilties have already been put in place for thousands of houses.

Any future building should be inland.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure play a key role in assisting to deliver the plans vision and spatial strategy. Contributions towards necessary infrastructure, services and facilities within developments will be undertaken by developers, however, in cases where development has wider effects, we will have to secure extra contributions to provide a large percentage of the new infrastructure needed, and in addition the public sector will also need to make an important contribution.

Phasing of development within particular areas is based on ensuring sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure (such as schools), which means that development tends to be focused on a particular area during a particular period.

It is also necessary to ensure that where there is infrastructure constraints these will need to be resolved prior to development taking place. Development allocations on a case-by-case basis through the local development plan process

14 January 2009 Page 24 of 244 368 5 Subject General Summary Tourism is one of the remaining industries in the Stonehaven area and should be encouraged to grow and not strangled by developments in inappropriate places. Hotels should be retained and not sold on for housing developments.

Draft Response: Acceptance: Do not accept Changes to be made

Tourism will play an important part of the economy during the plan period, however specific sites will be determined through the Local Development Plan process.

It should be noted that the structure plan is a strategic document and local strategies for tourism promotion will fall to other documents and strategies. 368 6 Subject General Summary The plan makes no provision for an ageing population

Draft Response: Acceptance: Do not accept Changes to be made

Provision is made within the plan for the whole community. The Objective of the Sustainable mixed community section aims; ‘to make sure that new development meets the needs of the whole community…..’ including the elderly. Providing homes to meet the meet of the community is key and ensuring that it meets the needs will be vital to providing housing for the elderly.

Additionally the plan states that with an ‘ageing population and smaller households, new development will need to meet the changing needs of society over its whole life and provide homes suitable for all.' 368 8 Subject General Summary The plan is too vague for any sensible conclusion to be drawn.

You cannot lump together the towns of and Stonehaven just because there is a rail or road corridor. Each town along the route deserves to be considered on an individual basis as each demands differing considerations.

Start again and work together with all the agencies including the Economic Forum and produce something which will meet the needs of the population of Aberdeenshire.

Draft Response: Acceptance: Do not accept Changes to be made

The draft plan does not "lump together the towns of Huntly and Stonehaven as suggested. The challenges and opportunities of individual towns are very important and these will be considered in more detail in the local development plan. A wide range of organisations (including the Economic Forum) have been involved in the preparation of the plan from the onset.

Rep. Number

14 January 2009 Page 25 of 244 370 1 Subject General Summary Reasonably happy with the plan but only if the whole plan is implemented barring one item.

The AWPR will not make much difference. Not convinced by the need for the route itself.

Train service from to Stonehaven/Laurencekirk all day long is vital to the plans success. To get traffic off the road trains and buses are needed not a new route costing millions and destroying the countryside.

It is time to stop buildng new roads. Keep the current ones in good condition and spend on trains and buses.

Draft Response: Acceptance: Do not accept Changes to be made

The support for this aspect of the plan is welcome.

Transport infrastructure and transport issues are not the responsibility of the Structure Plan and any transport changes and proposals will be part of the Regional Transport Strategy.

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Additionally other transport infrastructure measures such as Crossrail is now to be delivered in a number of smaller projects over a period of time instead of together, this will increase the number and frequency of trains between the south and Inverurie and reopen Laurencekirk Station. A longer term aim is to open a station at Kintore

The plan acknowledges the need for infrastructure improvements. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements).

Rep. Number

373 4 Subject General Summary Objection to the contents of the Structure Plan and the impositions inherent within it.

Draft Response: Acceptance: Noted Changes to be made

Noted.

373 5 Subject General Summary Ignorance in relation to the unique historical value of many coastal communities and to these communities within the structure plan.

Draft Response: Acceptance: Do not accept Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. This will involve extensive community consultation and site selection will be based on a significant number of criteria.

Rep. Number

14 January 2009 Page 26 of 244 376 1 Subject General Summary Expressed concern with regards to services and facilities in Stonehaven: - Few infrastructure improvements for over 30 years - Schools are over capacity and in poor condition - Roads are in poor condition - Frequency of trains - Poor Police presence - Waste collection poor

Stonehaven's population has doubled but the infrastructure has remained stationary.

Stonehaven cannot expand anymore until the above issues are managed more effectively therefore no support is given to the proposal at Braehead.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure play a key role in assisting to deliver the plans vision and spatial strategy. Contributions towards necessary infrastructure, services and facilities within developments will be undertaken by developers, however, in cases where development has wider effects, we will have to secure extra contributions to provide a large percentage of the new infrastructure needed, and in addition the public sector will also need to make an important contribution.

Phasing of development within particular areas is based on ensuring sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure (such as schools), which means that development tends to be focused on a particular area during a particular period.

It is also necessary to ensure that where there is infrastructure constraints these will need to be resolved prior to development taking place. Development allocations on a case-by-case basis through the local development plan process

Rep. Number

379 2 Subject General Summary Bigger roads for more cars is NOT "sustainable".

Paving over one acre of land in a world where so many people are starving is irresponsible.

Affordable housing means that someone working full time at minimum wage can afford to own a home.

Genuinely sustainable housing is off the grid.

Draft Response: Acceptance: Do not accept Changes to be made

Do not accept

Rep. Number

382 1 Subject General Summary If you leave away all irrelevant phrasing which inflates the current draft version the 18 pages of the document can be condensed to the following statements:

-There will be a decline in the regional key industries. -There may be a decline in population. -There will be economic pressure together with environmental demands. -Therefore more people need to move here. -This justifies housing allowances, retail and employment sites. -On this premise transport infrastructure can be improved. -Some consideration will be given to environment and heritage.

Draft Response: Acceptance: Do not accept Changes to be made

Do not accept.

14 January 2009 Page 27 of 244 382 2 Subject General Summary The way this draft plan is written is a blinding disguise for the most simplistic way of spelling out a complex economical, social, cultural and political process which is described by the generally recognised term 'structural change' - key these words into Google and you get 13 ½ million hits. Yet this term does not appear in this document - instead the reader is asked to 'face up to challenges'.

Draft Response: Acceptance: Do not accept Changes to be made

The plan has been prepared to the standard of the Crystal Mark: Plain English Campaign to enable the document to be both clear and concise. Accordingly reference to terminology such as 'structural change' would be counterproductive. 382 10 Subject General Summary Concern raised as to the level of input from developers during the plan process.

Representatives of developers attended the consultation meeting in Stonehaven without declaring their interest.

Developers should be at the receiving end when all planning has been done and the jobs for building need to be allocated. Planning should happen independently from the profit interest of developers and expertise should be sought from architects specialising in city and town planning.

Developers have been allowed active involvement at various stages of this plan; this fact correlates with the complete abscence of any factual information regarding planning principles, design standards, specification of other investment schemes and with the explicit intention to: make "quick progress in preparing local development plans", make "land available for homes through local development plans", make "land available for housing as quickly as possible at the start of the structure plan period" and use "possibly compulsory purchase powers to focus attention on housing"

'how to meet the targets' on page 14.

If the Draft Structure Plan in its present form is given approval developers will have successfully negiotated the provision of a vast playground for their own interests with a minimum of restrictions and a maximum of options and loopholes.

Draft Response: Acceptance: Do not accept Changes to be made

It is Important that all interests are engaged in the development process and developers are one of these, however all interests are taken into account in the development of the finalised structure plan. 382 14 Subject General Summary The structure of the document itself is confusing: Especially statements, targets and facts regarding housing which should be in a coherent chapter for reasons of readability have been tucked into separate, insubsequent topics. Sparse and vague information has been scattered and imbedded in inflated lingo in order to write towards and sell the Councils‘ tunnel 'vision'.

Draft Response: Acceptance: Do not accept Changes to be made

It is important to read the plan as a whole, not as a thematic document. 'Housing' is an important issue in the plan, and has important implications for each of the objectives and the spatial strategy.

Every effort has been made to make the plan easy to read and it has been prepared to the standard of the Crystal Mark: Plain English Campaign

Rep. Number

383 1 Subject General Summary I do not accept the concept of the Plan.

Seriously reconsider this Draft Plan, go back to the drawing board and come up with something which connects with the real numbers of houses required for the development of Aberdeen City and Shire and not just a figment of some planner’s imagination. A huge amount of resource has been spent of producing a document, which bears no relation to what the public want and has taken into consideration the wishes of the large developers to the exclusion of the smaller ones.

Draft Response: Acceptance: Do not accept Changes to be made

The Councils, in consultation with communities and stakeholders, have decided that the high forecast, taking the population to over 480,000 by 2030, is the preferred option. The housing need and demand assessment is currently underway but will impact more fully on the first Strategic Development Plan. The targets for new housing reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland. Further information is provided in the Background Paper.

14 January 2009 Page 28 of 244 383 4 Subject General Summary Schooling

Primary schools in Stonehaven are already beyond capacity and Mackie Academy is currently providing education for our children from Portacabins. We simply do not have the infrastructure to build more housing within Stonehaven.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure play a key role in assisting to deliver the plans vision and spatial strategy. Contributions towards necessary infrastructure, services and facilities within developments will be undertaken by developers, however, in cases where development has wider effects, we will have to secure extra contributions to provide a large percentage of the new infrastructure needed, and in addition the public sector will also need to make an important contribution.

Phasing of development within particular corridors is based on ensuring sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure (such as schools), which means that development tends to be focused on a particular area during a particular period.

It is also necessary to ensure that where there is infrastructure constraints these will need to be resolved prior to development taking place. 383 5 Subject General Summary Any building on or near Braehead/Newtonleys will have an adverse affect on our already failing Tourism industry.

Draft Response: Acceptance: Do not accept Changes to be made

The tourism industry is very important in some areas and should not be impeded. The plan aims to make sure development maintains the region’s important built and natural assets, and so the regions potential tourism will not be compromised.

Tourism is recognised as part of the local economy and an industry that could be more prominent in some areas of Aberdeenshire. The extent to which the structure plan can influence this is limited. Local plans may have a greater role to play, but attempts to use these land use plans should not be over-emphasised when other plans and strategies are better placed. 383 7 Subject General Summary Sewerage

Great cause for concern when informed that sewerage facilities are already in place at the Braehead Development for thousand of houses. In these days of credit squeeze and cost effective solutions I ask myself why someone would build a sewerage system capable of dealing with thousands of houses 'without planning permission'?

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

This is not an issue for the structure plan.

Rep. Number

386 1 Subject General Summary Further development in Kintore needs to be appropriately assessed, the structure plan makes comparisons with Portlethen for the future scale of our town and the mistakes made in Portlethen because of overdevelopment. Many other examples of places with high development, but poor infrastructure and amenities exist in the region- Bridge of Don, Westhill to name but two.

Kintore- Midmill gets particular mention with regard to the current fractured appearance of the industrial estate and the additional dangerous additional road traffic any further building would bring. The latest firm to set up home in Midmill will have 300 plus employees, bringing huge numbers of personal vehicles and service lorries, with the operational hours of 16hrs daily, the disruption to locals is incalcuable.

Tuach Hill has important geological and archeological importance to Kintore and any development will be fiercely contested by local people here. Increased development in Kintore will place additional pressure on the current lack of community facilities here, not least to our recently built school, running over capacity barely two years since being built.

Draft Response: Acceptance: Noted Changes to be made

Note: This representation is actually discussing the Inverurie and Kintore Capacity Study!

The structure plan does not promote development at Kintore, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A96 corridor in which Kintore lies (from Blackburn to Inverurie) is allocated 6,500 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

14 January 2009 Page 29 of 244 387 2 Subject General Summary The putting in place of an expanded infrastructure is going to be costly. Queried the envisaged percentage of cost that local council tax would have to account for.

Draft Response: Acceptance: Noted Changes to be made

Contributions towards necessary infrastructure, services and facilities within developments will be undertaken by developers, however, in cases where development has wider effects, we will have to secure extra contributions to provide a large percentage of the new infrastructure needed, and in addition the public sector will also need to make an important contribution. It is not the place of the structure plan to provide financial information. 387 5 Subject General Summary Queried whether tourism can be attracted to this sprawling housing development once all these houses are built? Suggested that improvements may be needed to improve the tourist industry to provide jobs for the people who are going to buy/rent the houses.

Draft Response: Acceptance: Do not accept Changes to be made

The tourism industry is very important in some areas and should not be impeded. The plan aims to make sure development maintains the region’s important built and natural assets, and so the regions potential tourism will not be compromised.

Tourism is recognised as part of the local economy and an industry that could be more prominent in some areas of Aberdeenshire. The extent to which the structure plan can influence this is limited. Local plans may have a greater role to play, but attempts to use these land use plans should not be over-emphasised when other plans and strategies are better placed. 387 6 Subject General Summary There are certain aspects of this plan which are commendable, such as the use of brownfield sites. However, a lot of it is vague and not detailed enough to inspire confidence. Perhaps the Draft Plan now needs to be reviewed in light of the general downturn in the economy and the restriction on the supply of liquid fund to both the private and public sectors.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Detail will be provided through the local development plan process and an Action Programme will be prepared which will provide more detail in relation to what the two councils and partners need to do to implement the plan. The plan considers development up till 2030 and so the current economic situation will have little impact on long term growth.

Rep. Number

389 2 Subject General Summary What in your mind does affordable housing mean?

Draft Response: Acceptance: Noted Changes to be made

A definition of affordable housing is given in the glossary. However, the exact cost of such a house cannot be given as this will vary from site to site across Aberdeen City and Aberdeenshire.

Rep. Number

390 1 Subject General Summary Under no circumstances should there ever be any development considered anywhere near . The area around the south of Stonehaven from Dunnottar woods to Dunnottar castle should be protected as this surely has to be one of most used and beautiful walks around the town.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process.

390 2 Subject General Summary Stonehaven has a beautiful and busy community which is fortunate in attracting many visitors and this has to be protected.

Draft Response: Acceptance: Noted Changes to be made

Noted.

14 January 2009 Page 30 of 244 390 3 Subject General Summary Future development has to be in a location, perhaps in the way of a new town, within easy access to the AWPR but not close to Stonehaven as the town cannot cope with the current amount of traffic in and around the shopping area.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process.

390 4 Subject General Summary For the local people, our environment and our heritage, we cannot possibly have large developments spoiling our beautiful landscape.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

391 2 Subject General Summary Comments received in relation to Stonehaven South:

The area called Stonehaven South is not suitable for additional houses - as the report says 'maintain and improve attractiveness of the region' - development south of Stonehaven would do neither. The area designated as employment opportunity at Stonehaven South is next to the road which totally disregards the area as a tourist town.

The council need to be brave and decide that Stonehaven is a tourist town and work at developing it further as such and not turning it further into a commuter town for Aberdeen. There are few leisure facilities in the town and the council should commit to improving these so that tourism increases and with it employment opportunities. The caravan site is a perfect example of lack of investment and improvement which leads to reduced tourist traffic.

Additionally the report states that housing should be close to rail links - Stonehaven South is not close to the railway station. Houses would be close to road links and this does not enhance the entrance to Stonehaven (the Stewart Milne development at Dunnottar Woods is a prime example of housing devaluing the approach and possibly reducing tourism)

The report recognises that "biodiversity, wildlife and landscape can be vulnerable to new developments" and again Stonehaven south is an area which is very vulnerable and would be the totally wrong place to develop more houses.

I suggest that Stonehaven is developed properly as a tourism area - utilising its natural beauty - and this means no large scale housing development, an attractive entrance to the town, more facilities and amenties and an improved town centre.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

393 1 Subject General Summary Under no circumstances should there ever be any development considered anywhere near Dunnottar Castle.

The area around the south of Stonehaven from Dunnottar woods to Dunnottar castle should be protected as this surely has to be one of most used and beautiful walks around the town.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria. 393 2 Subject General Summary Stonehaven has a beautiful and busy community which is fortunate in attracting many visitors and this has to be protected.

Draft Response: Acceptance: Noted Changes to be made

Noted.

14 January 2009 Page 31 of 244 393 3 Subject General Summary For the local people, our environment and our heritage, we cannot possibly have large developments spoiling our beautiful landscape.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

396 1 Subject General Summary Lodged objection to any further housing development to the East and South East of Alford for the following reasons:

- It is an area of accessible beautiful countryside which is used for recreation and would be ruined by Development. - There is currently easy and immediate access to the countryside. - The view from many windows would be of houses rather than fields and open countryside. - More houses mean an increase in cars, traffic noise and danger to pedestrians and cyclists. - New roads would be built across the countryside bringing much more traffic and destroying it. - The area is the of many bird species, some of which are protected - More Housing Development in the area would make it less attractive to tourists by ruining the countryside. Tourism is a source of income for Alford businesses which would suffer. - Woodland would be removed destroying the diverse ecosystem of trees, plants, fungi, lichen and the habitats of animals, insects, birds and bats. - The settlement of Alford is within the rural housing market area (RHMA), and should not be a primary target for new development over the next structure plan period, as it is not within one of the primary development corridors identified in the Draft Structure Plan. However, a substantial proportion of available new development has been allocated to the RHMA in the plan - with a particular view to encouraging growth in settlements such as Fraserburgh and Banff, and so it is important to object to the plan to try to ensure that this allocation is not exploited by developers in other settlements - such as Alford.

The main reasons for objection would relate to the innate un-sustainability of further housing development in Alford. A primary objective of the plan is to encourage sustainable mixed use development. However it has proved particularly difficult to attract this range of dev to Alford. Over the last few years the settlement has grown dramatically in terms of housing, but there has been very little commercial and business use development. As a consequence the town has developed from a relatively self-sufficient sustainable town - into a commuter dormitory for Aberdeen. More of this is not what the town needs.

Draft Response: Acceptance: Noted Changes to be made

Alford lies in the LG&DA (RHMA). This area is not designated for strategic growth, but may still experience growth in line with the spatial strategy. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

398 1 Subject General Summary Find the summary draft well presented, clear and reasonably strategic.

Draft Response: Acceptance: Noted Changes to be made

Noted.

398 2 Subject General Summary The plan, based on conventional wisdom, touches all the conventional buttons. Sadly though it is more than likely obsolete, at least obsolescent already.

The plan is being driven by the experience of the past, and simply projects that experience into the future. A realistic and visionary assessment of the future would reveal very different strategic and operational objectives.

The plan should focus on the dynamics that will shape our future (rises in energy and food costs and revolution in communication technology).

Draft Response: Acceptance: Do not accept Changes to be made

The Plan focuses on the challenges ahead that need to be tackle to achieve the outlined vision. In doing so it focuses on 'the dynamics that will shape our future' such as climate change, economy and community.

The plan was produced using the most up-to-date available at the time of publication. Additionally the plan will be monitored and reviewed every five years to ensure it is kept up-to-date.

Rep. Number

14 January 2009 Page 32 of 244 399 6 Subject General Summary The plan should more closely follow the stated Vision and seek to build upon the quality of life and the quality of what we have to offer new businesses, rather than spend our money preparing for a surge of population and employment growth before we have dealt with the problems already with us.

Draft Response: Acceptance: Do not accept Changes to be made

To tackle many of the important challenges we face over the duration of the vision period there must be a holistic strategy to tackle the aims outlined in the plan as a whole. It is only by doing so that the vision will be successful.

Quality of life is important and is key to attracting employment and population growth.

Rep. Number

405 1 Subject General Summary I am fully supportive of the aims and vision laid out for Aberdeen and Aberdeenshire.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

411 1 Subject General Summary Needs to be greater emphasis on the importance of centres of business, both workshop/manual and office based, close to centres of population. This will reduce the need to travel and help communities to become more sustainable.

Draft Response: Acceptance: Noted Changes to be made

Mixed use planning and the importance of increasing accessibility is dealt with under the objectives for Accessibility and Sustainable Mixed Communities. Large employment areas tend to be situated near or next to existing settlements in or around the strategic growth areas and the target within Accessibility states that "For major developments in strategic growth areas to show that they are easy to access by walking, cycling or using public transport..."

Within Sustainable Mixed Communities the draft plan states "A focus on communities means that new housing and developments for employment and commercial use should be integrated (well related to each other) to improve people's quality of life and opportunity. These should be a particular focus in masterplans prepared for larger development areas". 411 2 Subject General Summary Local authorities should provide advance factories, offices and shop complexes in main rural areas. Gave example of Grampian Regional Council doing so at the start of the oil boom. Modern integrated facilities cannot simply be left to the whim of profit centred organisations.

Draft Response: Acceptance: Do not accept Changes to be made

The delivery of the structure plan will be coordinated through action programming, however the councils ability to make provisions as suggested is likely to be limited. 411 4 Subject General Summary Referred to Grampian Regional Council and when major local authority premises, leisure centres and sports facilities were sited within the area now designated as Aberdeen City.

It is important that Aberdeenshire Council construct new headquarter buildings within each of the local areas such as . Additional large leisure/sports facilities should be constructed in a variety of Aberdeenshire areas to support the leisure and tourist industries.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

Representation does not relate to structure plan issues.

14 January 2009 Page 33 of 244 411 5 Subject General Summary Secondary schools in main population centres should be designated as community schools and be near population centres, have adequate sports/leisure provision and an adequate number of car parking spaces.

Draft Response: Acceptance: Noted Changes to be made

New schools are more likely to be designed and built on this concept, but this will be for Education in the City and Shire to determine.

411 7 Subject General Summary A new settlement in south Aberdeenshire at Drumlithie should feature in the structure plan:

- planned community of ten thousand homes - schools, medical facilities - community assets

It should be designated under the control of Aberdeenshire Council to meet community needs.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. However, the allocation in the Drumlithie to Marykirk (1,000 units up to 2030) would not be of a sufficient scale to classify as a new settlement. 411 9 Subject General Summary Possibility of forming hydro-electric dams within the existing river catchment areas should be considered. Would provide additional tourism sites, reduce the waste of rainwater run-off during winter weather and increase supply of drinking water in the summer.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The promotion of renewable energy production is a key aim of the structure plan, however as the sites specific issues will be decided through the local development plan process. 411 15 Subject General Summary Building of hotels and tourism facilities in rural country areas and estates should be encouraged and permitted within the structure plan.

Draft Response: Acceptance: Partially accept Changes to be made

Toursim and tourist related developments are mentioned in the LG&DAs and the PRAs on plage 8. It states how important a role it plays in the ecomomic growth of the north east. Local Development Plan would provide the mechanism to deliver more detailed tourist related policies and guidance. 411 18 Subject General Summary The structure plan does not quantify the employment workforce in terms of employment sector (oil/gas, farming, industrial etc) at the start of the plan and at intervals throughout the plan. Raised concern with regards to the longevity of the oil/gas industry and the impact this will have on drivers for other sections of the structure plan.

Draft Response: Acceptance: Do not accept Changes to be made

Employment data has formed an important part of the background to the plan, but there is no need to present such trends in the document. However, the monitoring of sectoral employment analysis will be important in the timetabled review of the finalised plan.

An important objective of the plan is to grow the economy of the City and Shire. Oil and gas are predicted to continue to be important to the area for the future, but the plan also states that ' it is also important that we promote a diverse local economy throughout the life of this plan'. The structure plan addresses the land use implications of economic growth. The plan makes reference to a number of sectors that have the ability to maintain and enhance the economy, including oil & gas, knowledge, R&D, tourism etc, consistent with the ACSEF strategy.

14 January 2009 Page 34 of 244 411 19 Subject General Summary Structure plan needs to identify that additional large hospital/health centre facilities should be provided at key locations within the City/Shire region.

Centralisation of all main functions at Forresterhill in Aberdeen results in major distortion to the behaviour of residents in the region e.g travelling long distances in to the city from outlying areas.

Draft Response: Acceptance: Do not accept Changes to be made

NHS Grampian are a key stakeholders in the structure plan process and as such have had an input in the plan formation. New health facilities will be developed inline with NHS Grampian strategy, and sites can be allocated through the local development plan process if required.

The plan will be reviewed every five years to ensure it is kept up-to-date, and will reflect any change in circumstances.

Rep. Number

412 4 Subject General Summary Engage the Prince’s Foundation for the Built Environment to draft a sustainable development plan, extending the work they have done at Banchory and Ellon, enabling the ACS to create guidelines. That way we may get a more independent, visionary blueprint based on current best thinking by an organisation recognised for sympathetic, modern development . Or indeed engage some other independent organisation.

Draft Response: Acceptance: Noted Changes to be made

The Princes Foundation has responded to the draft structure plan and the guidelines suggested are likely to be one issue to be taken forward in the implementation of the plan. Such guidelines are too detailed to be included in the structure plan. 412 5 Subject General Summary Need for big thinking - build a new town. There is growing recognition, in the press and at the Consultation meeting that a new town is the answer. Why not reconsider this?

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new town, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

415 2 Subject General Summary Strongly opposed to any further housing development to the East and South East of Alford for the following reasons:

- It is an area of beautiful countryside which is used for recreation and would be ruined by Development. - There is currently easy and immediate access to the countryside. - The view from many windows would be of houses rather than fields and open countryside. - More houses mean an increase in cars, traffic noise and danger to pedestrians and cyclists. - Light pollution would be increased

- New roads would be built across the countryside bringing much more traffic and destroying it.

- The area is the habitat of many bird species, some of which are protected (list given) - further housing development will erode their habitat driving them away. The importance of the bird species present in the area has been confirmed by the RSPB in Aberdeen.

- Animals (list given) would be threatened by development in the area.

- More Housing Development in the area would make it less attractive to tourists by ruining the countryside. Tourism is a source of income for Alford businesses which would suffer.

- Woodland would be removed destroying the diverse ecosystem of trees, plants, fungi, lichen and the habitats of animals, insects, birds and bats.

- The Battle of Alford (1645) came this way and is of Historical Importance. School children study the area as it is part of their heritage

Draft Response: Acceptance: Noted Changes to be made

Alford lies in the LG&DA (RHMA). This area is not designated for strategic growth, but may still experience growth in line with the spatial strategy. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

14 January 2009 Page 35 of 244 419 1 Subject General Summary I believe that the plan lacks an integrated approach to economy and infrastructure improvements in relation to the growth in housing due to an anticipated population growth.

The Plan recognises the anticipated decline in the Oil and Gas industry but doesn’t give any firm plan how to compensate for that. Also, already now the public transport system is inadequate for people commuting from outside Aberdeen to the city.

The plan doesn't really give any concrete plan for improvement.

Draft Response: Acceptance: Do not accept Changes to be made

The plan presents a fully integrated vision and spatial strategy for the future of the Aberdeen City and Shire.

Oil and gas are predicted to continue to be important to the area for the future, but the plan also states that ' it is also important that we promote a diverse local economy throughout the life of this plan'. The structure plan addresses the land use implications of economic growth. The plan makes reference to a number of sectors that have the ability to maintain and enhance the economy, including oil & gas, knowledge, R&D, tourism etc, consistent with the ACSEF strategy.

The support, and provision, of infrastructure (including public transport improvements) plays a key role in assisting to deliver the plans vision and spatial strategy to allow for improved access and connections to other places and to allow environmentally friendly methods of transport to be provided. The Structure Plan strategy focuses development in places where there are clear opportunities to encourage people to use public transport and enables efficient provision of services whilst aiming to reduce the percentage of car journeys however it is recognised that given the rural nature of Aberdeenshire this will not always be possible. 419 5 Subject General Summary Object to the proposal to build 500 new houses in Whiteford, part of the Huntly Pitcaple area. Having seen the proposal and reading through your plan it is clear that the proposal violates the visions and plans stated in the Draft Structure Plan. The job market area near Whiteford can’t accommodate the growth of 500 houses. The majority of people will be and are working in Aberdeen or nearby areas like Dyce.

Having lived in the Inverurie area for the last 6 years there is already a marked increase in traffic driving towards Aberdeen as a result of the new houses built in Inverurie and area.

The proposed new housing in Whiteford does not contain any significant improvement in public transport. For example Whiteford/Pitcaple has no railway station and none is planned. No plans exists to upgrade the A96 to dual carriage way to improve the flow from Huntly towards Aberdeen or even removing the bottleneck point of the small railway tunnel with traffic lights. And a last observation is that currently the existing community of around 70 houses will be completely lost by building all these new houses.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not promote development at Whiteford, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A96 corridor in which Whiteford lies (from Pitcaple to Huntly) is allocated 1,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

420 2 Subject General Summary Concerned about the plan for Aberdeenshire to be involved with the City which is in debt.

Queried what guarantee will be made to ensure that the Shire does not end up subsidising the City.

An example of this would be Grampian Police where there appears to be no shortage of manpower in the city and Stations like Fraserburgh close at 6pm.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

This is not a structure plan issue.

420 3 Subject General Summary Application BB/APP/2007/1974 rejected at the same meeting where the proposed 600 house development in Fraserburgh ushered through.

Request that this outline plan be incorporated into the new structure plan. In 2010 this application can then pass through the initial planning hurdle with ease.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The structure plan is not concerned with individual planning applications and specific sites are not identified in any settlement. This will be determined within the Local Development Plan process.

Rep. Number

14 January 2009 Page 36 of 244 422 3 Subject General Summary Why is no consideration given to a new town in the plan?

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new town, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

423 3 Subject General Summary The figure of 74,000 new houses for the whole area would suggest a new town, which would involve Central Government investment in infrastructure and planning instead of this piecemeal approach.

Instead this tagging on massive developments onto existing settlements threatens the very essence of a town such as Stonehaven, which already struggles to cope with its existing infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new town, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. Should a new town emerge, there will still be a requirement for extensions to existing towns in line with the spatial strategy. 423 5 Subject General Summary Stonehaven has carried its share of growth over the years, having almost tripled in size since the 70s. Even now we currently have over 300 houses planned or being built.

There is a limit on how much a town can cope with. The schools are under pressure, parking within the town is becoming difficult and facilities within the town are contracting rather than expanding.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not promote development at Stonehaven, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A90 corridor in which Stonehaven lies is allocated 6,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale. 423 6 Subject General Summary Sincerely hopes that this structure Plan will be looked at again, as, in its present form it is seriously flawed.

Draft Response: Acceptance: Noted Changes to be made

Do not accept that the plan is 'seriously flawed'. Sections of the draft plan may, however, be reviewed in light of the consultation with any changes refered to the SDPA committee.

Rep. Number

425 1 Subject General Summary The draft structure plan comes across as city centred.

Draft Response: Acceptance: Do not accept Changes to be made

The City and Shire are dependent on each other and the corridors could arguably be seen as bringing the development opportunities that would otherwise be confined to the City out into Aberdeenshire. The creation of employment sites at Westhill and Portlethen and concept of employment led development in the to Peterhead corridor all reduce the 'dominance' of the City.

Rep. Number

426 30 Subject General Summary Concern with the level of 'shoulds' in the plan

Draft Response: Acceptance: Noted Changes to be made

Do not accept there there is an excessive use of 'should' in the plan. The plan sets out what 'needs' or 'should' be done over the plan period, and in many cases it is used to express the probability or expectation that an action is required.

14 January 2009 Page 37 of 244 Rep. Number

427 1 Subject General Summary Object to any further development at Stonehaven as it will ruin one of the most beautiful spots on the east . The town is already overstretched.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not promote development at Stonehaven, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A90 corridor in which Stonehaven lies is allocated 6,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

428 5 Subject General Summary Opposed to further substantial growth of residential or employment development around Westhill, which is not in a SGA. Huge amount of office accommodation has been built on B9119 and much of this is still unoccupied. However, traffic is already chronic and will get worse once occupied. There is an urgent need to investigate some sort of high volume rapid transport system between Westhill and Aberdeen and this should be identified as a priority in the plan.

Draft Response: Acceptance: Noted Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. 428 6 Subject General Summary The Westhill Capacity Study should now be formally withdrawn by Aberdeenshire Council. It should now be evident that there is little if any capacity for any significant further development.

Draft Response: Acceptance: Do not accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

Rep. Number

429 2 Subject General Summary Far more emphasis is required to provide more affordable and Council houses and flats. New settlements are not required, there are adequate settlements which should be properly maintained, including much more tree planting. Disagree with the 500+ houses planned at Menie and recommend these could be built in communities such as , Newburgh, Balmedie, , , Tipperty and Bridge End.

Draft Response: Acceptance: Do not accept Changes to be made

There has always been a shortage of affordable housing in the NE and as stated on p.17 the housing need and demand assessment will give more detail on various aspects of housing across the City and Shire and it will be for local development plans to incorporate such material into specific policies on affordable housing etc. However, the benchmark figure is that each site should contribute 25% of the total number of units as affordable housing."

A number of new settlement proposals were submitted in response to the draft plan. Some of these were in line with the plan’s strategy and some were not. However, none are at a stage where they could be given support through the structure plan. This issue will need to be addressed in the Action Programme so that decisions can be made in the strategic development plan.

The decision was made on 16 December 2008 by Scottish Ministers to grant outline planning permission subject to conditions and conclusion of a planning agreement for this proposal. The conditions include phasing conditions which preclude new homes until Phase 1 is complete and limits new housing development until the Balmedie to Tipperty dualling is complete.

This means that 500 new homes are now likely to be built in this corridor. These new homes were not accounted for in the effective land supply on the base date of the plan, so will need to be set against the allowance for the first two plan periods. This phasing between the first and second plan period should reflect the progress expected to be made on site and will allow the allocation of other sites through the local development plan.

14 January 2009 Page 38 of 244 429 3 Subject General Summary Agree with the vision and aims, but aims are too vague.

Draft Response: Acceptance: Do not accept Changes to be made

The vision and aims are designed to set a general direction which is fleshed out in the rest of the plan.

Extensive work has gone into creating a coherent vision for the city region which is consistent with the regional economic strategy.

An Action Programme will be prepared which will provide more detail in relation to what the two councils and partners need to do to implement the plan. In addition monitoring has been embedded in the content of the plan.

Rep. Number

434 2 Subject General Summary The plan is proposed to take place with a background of decreasing jobs in the NE (by 4.7% up to 2021) and a declining population as set out in an Aberdeen City report.

Draft Response: Acceptance: Do not accept Changes to be made

The figures quoted are historic and have been superceeded by more positive forecasts. However, forecasts such as these provide one possivle view of the future. This plan has been proposed to influence the future, not merely to enable us to "achieve the forecasts". Current forecasts suggest an increasein the population to 2031 in both Aberdeen City and Aberdeenshire (+4.5%) (1.5%)

Rep. Number

435 3 Subject General Summary Transport is inadequate [in Stonehaven corridor] and doubts are being raised about Crossrail, the car park at Stonehaven Station is too small and the AWPR will not solve the problem. More likely the AWPR will provide an excellent opportunity for ribbon and infill housing development between Stonehaven and Aberdeen.

Draft Response: Acceptance: Do not accept Changes to be made

Transport infrastructure and transport issues are not the responsibility of the Structure Plan and any transport changes and proposals will be part of the Regional Transport Strategy.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. Additionally Crossrail is now to be delivered in a number of smaller projects over a period of time instead of together, this will increase the number and frequency of trains between the south and Inverurie and reopen Laurencekirk Station. A longer term aim is to open a station at Kintore

The plan acknowledges the need for infrastructure improvements. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements).

Rep. Number

440 7 Subject General Summary Concerned about a wide range of issues in the report of survey, including

loss of the work force in the region during the lifetime of this plan as a result of the ageing population

flats are not the answer to solve smaller households

rural transport must be improved - table 2e fails to record the most journeys made daily from the settlements to the City

recycling must improve in the North East

concern over smaller in town shops when larger supermarkets are developed

areas of deprivation when housing developments become larger than the local employment opportunities availiable

concern of densities on Brownfield sites - loss of industrial land to housing

Draft Response: Acceptance: Noted Changes to be made

The Report of Survey was published in February 2007. Its sole purpose was to gather a series of facts about the north-east and provide a 'snapshot in time' that was then used to aid early plan production. Whilst the respondent may make some valid points and these are reflected in the final plan (population, transport, recycling, retail etc) this document is no longer open to debate.

14 January 2009 Page 39 of 244 Rep. Number

445 1 Subject General Summary No points on the content of the structure plan were raised.

Draft Response: Acceptance: Noted Changes to be made

Noted

Rep. Number

447 2 Subject General Summary The closure of inner city schools should be reconsidered when regeneration and population growth are planned, would be better to improve this environment and encourage families back.

Draft Response: Acceptance: Partially accept Changes to be made

The plan recognises that additional services and facilities will be needed to serve the residents of new development. Many of these developments are likely to emerge in peripheral City locations away from central established residential areas where fewer school age children live, thus creating an shift in emphasis across the the City. Whilst some catchment changes may resolve some of these problems, the full impact on the school estate will only be able to be determined once sites are identified through the local development plan process. The decision on other capital projects is a matter for the Education services of each Council, although it would be expected that a programme of renewal and refurbishment would continue.

Rep. Number

455 5 Subject General Summary We need to ensure that any development does not detract from historical archeological attractions and reduce the number of visitors you visit them.

Ensure that planning prevents change of use from a hotel/inn/B&B to a private dwelling unless it is proven that the business is not financially viable.

Tourism to be given priority in economic development and planning decisions, not overshadowed by oil & gas.

Consider looking outwards for solutions and learn examples from other countries past mistakes and successes. Spain’s mistake tacky hotels to solve a slowing tourist industry and Norway’s success of subsidizing the integrated transport network.

Draft Response: Acceptance: Noted Changes to be made

The need to protect and improve our valued built and cultural heritage is an aim of the plan (p6.). The importance of tourism is recognised in the plan, although the "change of use" issue highlighted is not one for the structure plan to address. The value of the "looking outwards for solutions" is recognised.

Rep. Number

462 1 Subject General Summary No mention of agriculture, forestry or fishing development.

Draft Response: Acceptance: Do not accept Changes to be made

The plan tries not to involve itself with issues that are neither strategic, nor cross-boundary. This in no way is a reflection on the importance of any particular industry or environmental benefit, but an attempt to keep this new-style plan as concise as possible. Local development plans may refer to strategies for agriculture, fishing or forestry.

There is provision to develop rural towns in the spatial plan via either Local Growth Areas or Regeneration Priority Areas. The extent to which individual settlements are developed is a matter to be decided during the local development plan process.

14 January 2009 Page 40 of 244 462 7 Subject General Summary More clarity and detail required regarding Energetica.

Draft Response: Acceptance: Do not accept Changes to be made

At the time the draft structure plan was prepared, the Energetica concept was not well developed. However, a ‘strategic framework’ has since been published which sets out more clearly what it might mean. Although the detail of the framework is not something that can be supported through the structure plan, the concept of supporting economic growth in the corridor is. The Action Programme will need to set out how the concept can be further developed and implemented. 462 9 Subject General Summary Concentrating strategic growth in 3 main corridors more damaging to the environment that spread out development. Concentrating development in these areas means that development is more likely to take place on unsuitable sites spreading development means a greater choice of appropriate development sites.

Draft Response: Acceptance: Do not accept Changes to be made

The plan seeks to provide integrated development of residential and comercial land uses, and as such states that "all new developments contribute towards reducing the need to travel and encourage people to walk, cycle or use public transport." (Pg18 Accessibility).

However, it is recognised that travel to work is likely to comtinue to be important during the plan period and the spatial strategy offers the opportunity to use the most frequent and accessible public transport modes (bus and rail) and concentrate development instead of widespread dispersal, which would encourage greater car useage and travel. 462 10 Subject General Summary Concerns over legality of the structure plan.

Draft Response: Acceptance: Do not accept Changes to be made

The Town and Country Planning (Development Planning) (Scotland) Regulations 2008 set out the detailed requirements for Strategic Development Plans. The emerging structure plan, whilst conforming to current legislation has been prepared in the context of the Scottish Government’s modernising agenda and The Planning etc (Scotland) Act 2006.

The Planning etc. (Scotland) Act 2006 (Development Planning) (Savings, Transitional and Consequential Provisions) Order 2008 sets out the detail for the transitionary arrangements applicable to structure plans currently in preparation. The order provides that the plan will be processed in the ‘normal’ way as if the new legislation had not come into force when the plan is submitted on 27 February 2009. If the emerging structure plan was, for whatever reason, to be submitted to the Scottish Ministers on or after 28 February 2009, the order provides that the finalised structure plan would go through a process more akin to the approval of a strategic development plan.

The secondary legislation published in December 2008 allows for local development plans to be prepared in strategic development plan areas in advance of the strategic development plan. In such cases the local development plan must be consistent with the structure plan. 462 11 Subject General Summary More sustainable transport system required this is not compatible with increasing the capacity of roads. More public transport, cycle ways and footpaths that are not parked on of shared by buses & enforced speed restrictions on rural roads.

AWPR is a development corridor and improvements to the Haudigain roundabout will only bring about short term relief and then increase road use.

Draft Response: Acceptance: Partially accept Changes to be made

The Structure Plan spatial strategy focuses development in places where there are clear opportunities to encourage people to use public transport and enables efficient provision of services whilst aiming to reduce the percentage of car. Furthermore, objectives such as Accessibility plan 'To make sure that all new developments contribute towards reducing the need to travel and encourage people to walk, cycle or use public transport by making these attractive choices.'

However, the structure plan is not the place to develop long term transport strategies; this would be duplication of the work of NESTRANS and the Regional Transport Strategy, or the Aberdeenshire Local Transport Strategy.

Rep. Number

14 January 2009 Page 41 of 244 466 1 Subject General Summary Pleased to note that there are a number of statements which relate to both the provision and protection of water and waste water infrastructure and water sources.

Ministers require that investment decisions are informed by the quality investment programme, spatial priorities identified in the NPF and development priorities identified by local authorities in their structure and local plans. Scottish Water's approach has been to consult with local authorities to review the development plan demand for growth and to request local authorities to provide development priorities to inform the capital programme.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed and the continued support of Scottish Water is appreciated. The structure plan is intended to illustrate where investment priorities will be required and in what timescale to give greater certainty to infrastructure providers.

Rep. Number

468 1 Subject General Summary Content that historic environment issues are well integrated into the plan as a whole and that its text provides appropriate references and commitments to ensure that the need to extend appropriate protection will be reflected in the policies, land allocations and masterplans that will be promoted through the lower tier of development plans.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

473 1 Subject General Summary Fully support the vision to develop a robust and resilient economy and feel that Aberdeen Airport has a key role to play in realising the economic growth set out on p.9. BAA will continue to invest in new airport infrastructure and develop new routes, but this will need to be supported by public investment in the necessary roads which serve the airport and surrounding area. Agree that access to roads, ports, airports and rail needs to be protected and improved. The construction of the AWPR is fundamental to achieving this goal.

BAA is keen to develop the airport in line with the vision set out in the Airport Master Plan.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

474 1 Subject General Summary Support the vision to 2030 and for sustainable growth - setting out the type, scale and general location of proposed development over that period. Previous comments on earlier versions included the need for proposals to be complementary to the findings in the Transport & Health Action Plan in respect of access to health and to note the importance of ensuring that all relevant infrastructure is in place to allow the plan to develop.

The NESTRANS Board confirmed their support for the plan, its proposals and policies and reaffirmed its support for a Third Don Crossing as contained in the plan.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

479 10 Subject General Summary The plan should recognise the need to safeguard the setting of the Cairngorms National Park from the impacts of large scale developments outside its boundary (i.e. for renewable energy). NPF2 identifies the CNP as a National Designation and the CNP Plan identifies the need to safeguard the landscape character and visual amenity of the Park.

Draft Response: Acceptance: Partially accept Changes to be made

This is a matter that Aberdeenshire will need to consider in their local development plan. Although fairly marginal to the stated purpose of this structure plan, a releference will be added to the 'Quality of the environment section' which emphasises the need to take into account sites which may lie outwith the structure plan area. This will cover the National Park as well as the designations.

14 January 2009 Page 42 of 244 Rep. Number

259 2 Subject Introduction Summary There is a sentence stating ‘both councils will use the it (the structure plan) in appropriate cases to help decide whether a planning application would take the area in the right direction.’ Surely the Councils should use it in all cases not only in appropriate cases. Should the Council only use it in appropriate cases then these cases need to be identified in the Structure Plan.

Draft Response: Acceptance: Do not accept Changes to be made

Many planning application, such as householder applications, are of a nature and scale which mean that the content of the structure plan is unlikely to be critical to their determination. The Paragraph already highlights the importance of the development plan in the decision making process and future detail is not required.

Rep. Number

382 3 Subject Introduction Summary The Aberdeen City and Shire Draft Structure Plan does not supply any reference list at the end of the document which would give evidence of the sources, expertise, studies or research projects linked to structural change in the north-east of Scotland.

Accordingly, there are no references to the universities or research institutes which have been approached or involved in research and/or monitoring of the various and complex processes associated with the structural change in the region.

Particularly the exact nature of the mentioned 'international influences' remains unclear.

Draft Response: Acceptance: Noted Changes to be made

It is accepted that the draft plan does not present the references sought. However, the Report of Survey and the Strategic Environmental Assessment do provide the required information.

International influences range from European Directives (relating to waste, for example) to European natural heritage designations and global imperatives of climate change.

Rep. Number

234 4 Subject Key Diagram Summary The key diagram makes it difficult to gauge how SGA's will be applied at the local level as it is not OS based, but diagramatic. How then can someone decipher if their site is in or out of a SGA? for example is a dot on the diagram (outside the SGA) whereas undevelopable land north of Inverurie is within it.

Draft Response: Acceptance: Do not accept Changes to be made

The statutory requirements require a key diagram not to be a map and due to the size of the area to be covered this is the most appropriate scale. Whether a site is in or out of a SGA will be determined through the local development plan process.

Rep. Number

235 5 Subject Key Diagram Summary The key diagram makes it difficult to gauge how SGA's will be applied at the local level as it is not OS based, but diagrammatic. How then can someone decipher if their site is in or out of a SGA?

Draft Response: Acceptance: Do not accept Changes to be made

The statutory requirements require a key diagram not to be a map and due to the size of the area to be covered this is the most appropriate scale. Whether a site is in or out of a SGA will be determined through the local development plan process.

Rep. Number

259 10 Subject Key Diagram Summary On the inside back cover 'Key Diagram', the diagram states that it is such and "not a map". In order to define both the growth areas, the Regeneration Priority Areas and the boundary of the Housing Market Area (presumably between Aberdeen Housing Market Area and Rural Housing Market Area) a map, not a diagram, requires to be available in order that comment can be made in relation to specific areas.

Draft Response: Acceptance: Do not accept Changes to be made

The statutory requirements require a key diagram not to be a map and due to the size of the area to be covered this is the most appropriate scale. Whether a site is in or out of a specific area will be determined through the local development plan process.

Rep. Number

14 January 2009 Page 43 of 244 260 2 Subject Key Diagram Summary The Key Diagram indicates the 'Greenbelt' shown as a dotted green area and the 'Strategic Growth Areas' identified as yellow areas. As the majority of the green belt area is indicated as a growth area clarification is required to indicate the proposed growth within the green belt.

Draft Response: Acceptance: Do not accept Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In parts of the City and Shire this willl involve a review of the green belt as also stated in the plan. There is no need for further clarification in the diagram. 260 4 Subject Key Diagram Summary The Key Diagram indicates the yellow areas as areas of Strategic Growth. These areas are narrow bands and should be increased in width to allow the forthcoming Aberdeenshire Local Development Plan to assess in detail possible sites for development along the strategic growth corridors. This would allow existing settlements like Kemnay and Daviot on the A96 corridor and Newburgh on the A90 to be assessed in detail in relationship to strategic growth areas.

Draft Response: Acceptance: Do not accept Changes to be made

The SGA corridors are intentionally narrow to focus development on the places with greatest opportunities for public transport use. The inclusion of a settlement within or outwith a SGA is a matter for the local development plan.

Rep. Number

272 5 Subject Key Diagram Summary Consider that principal towns like Stonehaven should be specifically mentioned in the plan along with their role in the settlement hierarchy.

Draft Response: Acceptance: Do not accept Changes to be made

The plan operates at the strategic level, where the role of individual settlements is not explored and level of growth is not imposed. This leaves Aberdeenshire Council the flexibility to determine allocations on a case-by-case basis through the local development plan process.

Rep. Number

283 1 Subject Key Diagram Summary The key diagram is not detailed enough as it gives no indication whether a planning application is in or out of a particular zone. The three elements of the spatial strategy should be geographically defined. Provision should also be made for altering these within the timescale of the plan to allow for a flexible response to developing economic circumstances.

Draft Response: Acceptance: Do not accept Changes to be made

The statutory requirements require a key diagram not to be a map and due to the size of the area to be covered this is the most appropriate scale. Whether a site is in or out of a SGA, RPA or LG&DA will be determined through the local development plan process. The plan will be continually monitored and reviewed and as such flexibility is built in.

Rep. Number

286 71 Subject Key Diagram Summary Query whether the key diagram should include an indicative GB boundary when it requires such a major review.

Draft Response: Acceptance: Do not accept Changes to be made

At the scale and in the form presented the changes required by the review of the green belt would be very difficult to identify. In any event, the key diagram is a diagram rather than a map.

Rep. Number

296 2 Subject Key Diagram Summary Note from the key diagram that the green belt is shown to the north and west of portlethen, this should be extended to include the eastern coastal strip and Portlethen Moss and important landscape /recreational land around the town.

Draft Response: Acceptance: Do not accept Changes to be made

The key diagram is only indicative, hence the rough, stipled effect to suggest the green belt rather than a definite line. However, it is based on the designated green belt around the City, which stops north of Findon and does not follow down the coastal strip. The small area of green belt south-west of Portlethen can be seen in the same stippling on the key diagram adjacent to the A90 and railway.

14 January 2009 Page 44 of 244 Rep. Number

452 4 Subject Key Diagram Summary AWPR should be identified on the map, it will be an important factor in determining the location of new homes, business sites etc.

Draft Response: Acceptance: Accepted Changes to be made

The AWPR (including Fastlink) is identified on the key diagram in recognition of its strategic importance for the future prosperity of the north east. The principle of the route is established.

Rep. Number

460 4 Subject Key Diagram Summary The key diagram indicates a dual-route AWPR including the 'fastlink' between Stonehave and Maryculter. This is a departure from the existing NEST which shows the AWPR in the form of a reverse D enclosed within the Aberdeen greenbelt.

Draft Response: Acceptance: Accepted Changes to be made

The principle of the AWPR is established and a great deal more is known about it than in 2001 when NEST was approved. Although still subject to the findings of the PLI, the key diagram reflects the latest position.

Rep. Number

465 6 Subject Key Diagram Summary TSC2 / 3 - Transport Scotland is concerned about the lack of rationale for the interventions (new station at Newtonhill and Cove and Third Don Crossing) detailed in the plan. This could be provided through appropriate transport appraisal. Moreover, Transport Scotland has not committed to these specific interventions.

Draft Response: Acceptance: Partially accept Changes to be made

The Background Paper will be amended to provide the rationale for the transport intervention identified in the plan.

It is accepted that the provision of new rail halts at Newtonhill and Cove are unlikely in the short / medium-term. However, inclusion in the structure plan will allow land to be safeguarded in the relevant local development plan if this is deemed necessary by the Councils.

The Third Don Crossing is subject to a live planning application and has been through a number of assessments and appraisals, including Traffic Modelling and Economic Assessment, Environmental Assessment and STAG Assessment. Following the Aberdeen City LPI, the administration of Aberdeen City Council stated its continued support for this proposal. Its inclusion in the structure plan is therefore based upon this history and the strategic significance of the crossing in improving access from the north in conjunction with other works at the Haudagain junction. 465 11 Subject Key Diagram Summary Note the reference to the AWPR on p.8 and are content that it is correctly identified on the Key Diagram.

Draft Response: Acceptance: Accepted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

479 12 Subject Key Diagram Summary The plan and SEA both rightly identify the River Dee as the most important natural resource in the plan area with respect to water supply, which is already under pressure. As a result of the levels of growth and rising demand for water, there is a strong risk that this could increase. Given its SAC status there is a statutory obligation to safeguard its qualifying interests from deterioration. In order to safeguard this resource, consider that the rough catchment boundary of the River Dee should be indicated in the key diagram.

Draft Response: Acceptance: Do not accept Changes to be made

The plan is explicit in its references to the importance of the River Dee in an environmental context and as the primary source of drinking water for much of the population. The addition of the entire catchment to the key diagram would add little to the plan. It would also not be consistent with the need to produce a succinct land use plan and the omission of other environmentally sensitive designations from the diagram.

14 January 2009 Page 45 of 244 479 13 Subject Key Diagram Summary The very approximate indication of SGA's and RPA's on the key diagram is unnecessarily vague. Both cover large areas of undeveloped land and are in danger of giving a false impression of the scale of development being promoted. Plan should give a clear impression of whether new development is intended to be associated with existing settlements, whether development anywhere along the corridor is deemed acceptable, or whether a new settlement is envisaged. Each has different implications which need to be recognised and assessed.

Draft Response: Acceptance: Partially accept Changes to be made

SGAs and RPAs are indicative only and it is not our intention to set definitive boundaries for these. RPAs are also covered by the LG&D designation and it is made clear in this section that housing will be focused in, or adjacent to, existing settlements. In SGAs, it will be the responsibility of each Council to determine specifically where growth takes place. Due to the significant numbers proposed for the Portlethen - Stonehaven and Blackburn - Inverurie corridors, a new settlement is possible and the plan does not preclude this. However, this will be for the Aberdeenshire local development plan to determine.

Rep. Number

230 3 Subject Objective (Sustainable Mixed Communities) Summary Is not clear how SSCI fits with allocations in the present local plan. Once these projects move forward it is important that a non-restrictive and flexible approach is carried forward into the local plans. Countesswells represents a good opportunity to build a sustainable community that could accommodate 2,500 new homes.

Draft Response: Acceptance: Noted Changes to be made

The Scottish Government have reaffirmed in recently published Scottish Planning Policy that importance of a plan led planning system. "Bids" made for developments to be recognised under the Scottish Sustainable Communities Initiative to the Scottish Government, even if successful, does not guarantee allocation in the development plan. However, high quality sustainable proposals are what this plan requires and why the plan identifies working with partners to bring appropriate proposals forward when they are in line with the plan.

Your comments have been noted and forwarded to the local development plans team.

Rep. Number

462 8 Subject Objective (Sustainable Mixed Communities) Summary The plan is vague e.g. there is a target for the number of house per hectare, minimum of 30. However on page 17 it is proposed to assess the actual number planned after planning permission has been granted.

Draft Response: Acceptance: Do not accept Changes to be made

The vision is designed to set a general direction which is fleshed out in the rest of the plan. Extensive work has gone into creating a coherent vision for the city region which is consistent with the regional economic strategy.

The word ‘generally’ is used within the target so that if there is a strong planning consideration where under 30 houses per hectare would be acceptable then it is possible to have a lower density. Density will be an issue considered in masterplans. SPP3 Planning for homes (revised 2008) states that "The appropriate density of new development should be determined in relation to the character of the place and its relative accessibility, with higher densities more appropriate in the most central and accessible locations."

Rep. Number

184 4 Subject Putting the plan into practice Summary Agree that in terms of meeting the targets the Local Plan should be produced quickly.

Draft Response: Acceptance: Noted Changes to be made

This expression of support is welcome.

Rep. Number

185 3 Subject Putting the plan into practice Summary Agrees that in terms of meeting the targets the Local Plan should be produced quickly.

Draft Response: Acceptance: Noted Changes to be made

This expression of support is welcome.

Rep. Number

14 January 2009 Page 46 of 244 197 16 Subject Putting this plan into practice Summary Welcome the inclusion of their initiatives in this section and also the AWPR. In addition, the land owned by the University at Balgownie could help with the proposed Third Don Crossing.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

201 6 Subject Putting this plan into practice Summary The re-opening of Laurencekirk Station should be included as a proposal on p.20.

Draft Response: Acceptance: Noted Changes to be made

The proposals section does not specifically identify all proposed projects which will assist in achieving the draft plans vision. The re- opening of Laurencekirk Station would be dealt with under the road and rail improvements bullet point within the proposals section.

Rep. Number

202 3 Subject Putting this plan into practice Summary The re-opening of Laurencekirk Station should be included as a proposal on p.20.

Draft Response: Acceptance: Noted Changes to be made

The proposals section does not specifically identify all proposed projects which will assist in achieving the draft plans vision. The re- opening of Laurencekirk Station would be dealt with under the road and rail improvements bullet point within the proposals section.

Rep. Number

205 12 Subject Putting this plan into practice Summary Under 'providing infrastructure' suggest that "health and related public services" be added to the second sentence in order that specific recognition is given to these essential services at the time of planning for infrastructure investment. The second paragraph makes reference to securing a higher percentage of contributions to fund a large proportion of future requirements. This approach is welcomed, but it is suggested that the third sentence is amended to read "..percentage of the new physical and community service infrastructure needed..".

Draft Response: Acceptance: Do not accept Changes to be made

The suggested focus on healthcare facilities is too narrow.

The term 'infrastructure' is included in the glossary and includes the elements proposed. There is no need to go into the proposed level of detail here.

Rep. Number

206 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 47 of 244 206 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

207 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 207 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

14 January 2009 Page 48 of 244 208 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 208 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

209 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 49 of 244 209 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan. 209 11 Subject Putting this plan into practice Summary Support the commitment to monitor and review the plan.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

210 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 210 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

14 January 2009 Page 50 of 244 211 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 211 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

212 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 51 of 244 212 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

213 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 213 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

14 January 2009 Page 52 of 244 214 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 214 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

215 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 53 of 244 215 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

216 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 216 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

It is agreed that Supplementary Planning Guidance will undoubtedly have a more significant role to play and this is recognised in the draft plan.

Rep. Number

14 January 2009 Page 54 of 244 217 3 Subject Putting this plan into practice Summary Welcome the recognition that there will be a need to improve the area's communities and the services they depend on, but suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 217 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 217 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

14 January 2009 Page 55 of 244 218 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. The level of developer contributions is directly related to the overall value of the land. Landowners may not be willing to sell land if the price that is offered by a developer is too low, which may affect the aspiration to grow the population. Welcome that the public sector will need to make an important contribution to new infrastructure.

Needs to be a fair method for levering planning gain. In situations where there are multiple developers of a site, every one needs to pay a fair share and not just those whose developments take place first.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 218 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

219 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 56 of 244 219 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

220 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 220 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

221 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 57 of 244 221 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

222 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 222 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

223 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 58 of 244 223 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

224 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 224 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

225 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 59 of 244 225 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

226 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 226 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

14 January 2009 Page 60 of 244 227 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 227 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

228 10 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure and would be interested to learn the exact nature of this.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 228 11 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

14 January 2009 Page 61 of 244 Rep. Number

229 9 Subject Putting this plan into practice Summary Accept that developers should make a contribution towards necessary infrastructure, but reference to securing higher contributions than in the past is inappropriate as should be related in scale and kind. Welcome that the public sector will need to make an important contribution to new infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 229 10 Subject Putting this plan into practice Summary Welcome the need to prepare masterplans and SPG to help development take place. Will be times when SPG should be used to help proposals be brought forward in advance of the finalised development plan. Also believe that SPG will have to be used to combat delays in local development plan preparation. Encouraged by commitment in ACSEF manifesto to improve efficiency of planning decisions and the range of actions therein. This should be more clearly reflected in the final plan.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan. Facilitating a more efficient planning process is one of the key aims of the ongoing planning reforms, however this relies to a large extent on quality applications and up-to-date development plans. An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

232 1 Subject Putting this plan into practice Summary Pleased with the fourth and sixth proposals on p.20 (Energetica and airport masterplan) and move from a constraining document to a promotional, growth orientated document. If comparisons are drawn with the West Edinburgh Planning Framework, it can be seen that a greater priority should be given to the airport and its surrounding land than any other business location (apart from the City Centre). In land use planning terms it must be acknowledged that the generous zoning of business land elsewhere could well undermine the land at the airport.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The draft plan looks to move away from rigid and prescriptive land use planning and not prejudge any area of Aberdeen or Aberdeenshire. The plan aspires to be strategic, focused, accessible, action-orientated and outcome driven, flexible and appropriate for the area that it serves.

The airport masterplan is highlighted as one of the proposals which will assist in achieving the draft plans vision for the North East. The spatial strategy already emphasises the importance of development of employment land in Strategic Growth Areas in stating that at least 75% of employment land will be developed in SGAs by 2030. The allocation of specific sites will be determined within the Local Development Plan process.

14 January 2009 Page 62 of 244 232 11 Subject Putting this plan into practice Summary The plan misses an important section relating to infrastructure. To provide sustainable communities a great deal of infrastructure is required; the AWPR and Third Don Crossing are crucial. Much greater detail needed on issues such as energy, transport, waste, water and drainage. There are other requirements that will be needed for large scale growth; e.g. proposed water if no more abstraction from the Dee and capacity of AWPR junctions, these should have built-in capacity, even if it has to be set against anticipated Section 75 agreements.

Draft Response: Acceptance: Do not accept Changes to be made

The Plan acknowledges the need to invest heavily in the infrastructure of the region.

Local development plans will develop an action programme to support the structure plan, detailing how the plan will be put into practice, including identifying timescales for investments, preparing masterplans and supplementary guidance to facilitate development. LDPs will contain a programme which will identify who is to take action, when and how it will be funded.

Within the Plan the 'Putting this plan into practice' section provides some details regarding the provision of infrastructure, recognising the need to consider investments very early in the land-development process, even before land is identified in local development plan. Investments will come from both developers providing contributions towards necessary infrastructure, and the public sector also making an important contribution.

Rep. Number

247 6 Subject Putting this plan into practice Summary We feel that in order to assist in achieving the stated aim of reducing the use of the private car (particularly in rural areas) more must be done to subsidise and enhance rural public transport services, which play an essential role in maintaining the viability of many rural communities. This will ensure that, with rising fuel prices, essential services in rural areas are not lost.

In addition to this, the potential to re-open some of the suburban rail lines should be investigated as a priority and where possible implemented in the near future. This would assist in taking freight off the roads and increase the public transport options available in rural areas. This should be added to the list of proposals, as it is essential to the maintenance of sustainable rural communities.

Draft Response: Acceptance: Partially accept Changes to be made

Aberdeenshire Council funds and supports a large number of bus services as well as developing demand-response bus services.

Since the adoption of Aberdeenshire Council’s first Local Transport Strategy (LTS) significant investment in transportation has seen improvements made across the network. These range from major infrastructure projects through investment in walking and cycling to the introduction of innovative passenger transport services, such as A2B Dial-A-Bus. 'A2B' dial-a-bus is a Demand Responsive door to door transport service introduced by Aberdeenshire Council in 2004 with assistance from the Scottish Executive.

Although there may be merit in the suggested improvements, the structure plan is a high level strategic land use planning document and improvements to the rail network are best dealt within regional and/or local transport strategies working in partnership with NESTRANS, Network Rail etc. It is accepted that further emphasis should be put on rail freight within the Accessibility objective however this is a matter being taken forward by NESTRANS.

It is agreed that a number of Park and Ride proposals should be included within this section and shown on the key diagram. Future proposals are for the completion of a ring of Park & Ride services around Aberdeen, linked to the AWPR, enabling easy access to the City. Further details are provided within the Regional Transport Strategy.

Rep. Number

248 25 Subject Putting this plan into practice Summary Where possible key proposals should identify: The means of implementation, the cost of delivery, the sources and availability of funding, the timing of delivery and any endorsement by outside bodies; or commitment.

The plan should also address key infrastructure requirements ie drainage, water and education.

Draft Response: Acceptance: Noted Changes to be made

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

The support, and provision, of infrastructure is an essential part of supporting the level of housing and economic development envisaged and is central to the plan.

14 January 2009 Page 63 of 244 248 26 Subject Putting this plan into practice Summary Trust that the Councils’ Action Plans will confirm there are appropriate staffing levels to ensure this plans on time delivery.

The issue of resourcing also applies to the timeous preparation of Local Development Plans, Supplementary Planning Guidance, and Master Plans as well as to the determination of planning applications.

Draft Response: Acceptance: Noted Changes to be made

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

255 18 Subject Putting this plan into practice Summary As noted, the plan is an ambitious one, and if it is to be successful, it must be kick-started early. The ‘action programme’ therefore requires to be produced early, to avoid slippage.

A key point which the action programme requires to address is the responsibility for infrastructure provision. At several points in this section in the plan it refers to the need for developers to contribute to infrastructure provision on a higher scale than previously. However, as pointed out above, plan should provide firm guidance and wherever possible, certainty for developers, the public and service providers alike. As currently framed, these references to increased levels of ‘planning gain’ are unclear and accordingly unhelpful, undermining the confidence of developers – and particularly landowners – in the potential viability of projects. It is most important that clarity is achieved in this area before ‘developer bids’ are requested for Local Plans. The clarification provided, however, also needs to bear in mind that ‘planning gain’ and the extent to which Councils can require contribution, are controlled by Government guidance, which has only recently been reinforced.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

261 19 Subject Putting this plan into practice Summary In respect of the listed projects we would promote speedy action on the WPR and rail improvements.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy.

Rep. Number

266 6 Subject Putting this plan into practice Summary There appears to be no policy for the provision of playing fields for organised or casual sport. The plan mentions the new football stadium for Aberdeen FC but nothing about the Council's aspirations to provide or encourage sporting facilities in other communities.

Draft Response: Acceptance: Do not accept Changes to be made

The support, and provision, of infrastructure (which includes community facilities such as sporting facilities) is an essential part of achieving sustainable mixed communities and is central to the plan.

The Structure Plan "aims to be more focused, strategic" and only aims to cover those issues that "can be best dealt with by Aberdeen City and Aberdeenshire Councils working together. The spatial strategy provides flexibility for the Local Development Plan process to determine detailed policies and land allocations for local issues.

14 January 2009 Page 64 of 244 266 9 Subject Putting this plan into practice Summary It would be helpful if the reinforcement of the electricity grid could be underground or otherwise imaginatively screened.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The Scottish Government have highlighted Grid Reinforcements as a national development (though the Draft National Planning Framework 2) however the detail of the grid reinforcements is not an issue which can be dealt with through the structure plan.

Whilst these are relevant concerns, they are best tackled through other plans and strategies.

Rep. Number

267 21 Subject Putting this plan into practice Summary One omission would appear to be resolving access from the south.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan contains numerous proposals which will assist in resolving access from the south. These include the Aberdeen Western Peripheral Route, expanding the Park and Ride network, improvements to the road and rail network, 3rd Don Crossing and associated measures. The structure plan sets the framework for local and regional transport strategies which will provide higher levels of guidance. These infrastructure improvements will allow for improved access and connections to other places and to allow environmentally friendly methods of transport to be provided.

The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements).

Rep. Number

273 9 Subject Putting this plan into practice Summary Agree that there is a need to invest in the infrastructure ie sewers, roads and schools as they at present would not be able to cope with the demands of extra development.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcome. The support, and provision, of infrastructure (including schools, community facilities, road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy.

Rep. Number

276 18 Subject Putting this plan into practice Summary Support the AWPR and third don crossing as an important part of the infrastructure to meet the plans aspirations.

Also support the regeneration in N Aberdeen and the Airport masterplan.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy. 276 19 Subject Putting this plan into practice Summary The Structure Plan needs to provide the confident and courageous platform for decision-making, by all sectors, over the next few years. We very much hope this Plan will provide that basis and the levels of certainty to secure co-ordinated investment by all key parties.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. Preparing the plan has involved a great deal of consultation with key stakeholders, the public and private sector as well as with the wider community.

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

14 January 2009 Page 65 of 244 278 21 Subject Putting this plan into practice Summary Clarification is sought on the implementation of the City Centre Masterplan in terms of its funding and delivery.

Draft Response: Acceptance: Noted Changes to be made

A Development Framework is currently under preparation to bring about radical and far reaching improvements to Aberdeen City Centre. As part of the Aberdeen Design Campaign, Aberdeen City Council is working with the Scott Sutherland School of Architecture and the Built Environment at the Robert Gordon University to produce a development framework to define the planning and urban design strategy for the future of Aberdeen City Centre.

This will include identified themes of Aberdeen City Centre as a Key Business Location, Retail Centre, Major Tourist Destination, Historical and Cultural Centre, Leisure and Entertainment Centre, Key Transport Node and a Place where people live and feel safe.

The extent to which the structure plan can influence this is limited. Local plans may have a greater role to play, but attempts to use these land use plans should not be over-emphasised when other plans and strategies are better placed.

Rep. Number

284 10 Subject Putting this plan into practice Summary Some proposals are given too much detail. For example, it makes no sense to mention the community stadium or Union St pedestrianisation.

Draft Response: Acceptance: Do not accept Changes to be made

The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

Improvements to the shopping environment of Union Street are key to enhancing its importance as a retail destination meeting structure plan targets.

Rep. Number

285 14 Subject Putting this plan into practice Summary The expectation that developers will meet infrastructure costs through higher land values may result in schemes no longer being viable and not proceeding. While this may not be a problem in Aberdeen, it may be a real factor in Aberdeenshire. The implications for certainty in investment and long term delivery of the plan will be affected.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

286 64 Subject Putting this plan into practice Summary This should be the strongest part of the plan to ensure the plans aims and objectives are delivered; however this is not achieved. Needs to be more than the purpose of development plans, should set clear timescales for delivery of local development plans and for provision of a measurable Action Plan.

Draft Response: Acceptance: Do not accept Changes to be made

Each section within the plan details how the targets will be met in addition to monitoring methods.

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan. Provision of timescales for local development plans, prepared separately by Aberdeen City Council and Aberdeenshire Council, would not be appropriate within the structure plan.

14 January 2009 Page 66 of 244 286 65 Subject Putting this plan into practice Summary The Action Programme will have to confirm that the Councils have the appropriate levels of staff to ensure the plan is delivered. There also needs to be commitment that the necessary SPG, master plans and decisions on planning applications will not be unduly delayed.

Draft Response: Acceptance: Noted Changes to be made

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan. 286 66 Subject Putting this plan into practice Summary Have concerns regarding the "providing infrastructure" section on p.19. Recognise that delivery of development on this scale will require a significant level of investment. However, contributions must relate directly to the development and fairly and reasonably relate to the scale of development. Care therefore needs to be taken with some of the statements made.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 286 67 Subject Putting this plan into practice Summary There is no land tax in place as the "providing infrastructure" section on p.19 suggests; this section therefore needs to be re-written. Contributions can only be sought in line with Circular 12/1996 until any central government changes are made.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 286 68 Subject Putting this plan into practice Summary The "proposals" section appears to be an afterthought. Only strategic proposals should be included and would therefore question the need for the new prison for Peterhead to be included. Proposals (such as Crossrail, AWPR, Third Don Crossing and Airport Access) should be in the relevant section.

Draft Response: Acceptance: Do not accept Changes to be made

Strategic land use proposals which will help to meet the aims and vision of the structure plan have been included within the proposals section. As Peterhead prison is of regional and cross boundary importance it is relevant to be included as a proposal.

Rep. Number

287 23 Subject Putting this plan into practice Summary This section must be strong and set out clear timescales for deliver of the local development plans and action programme. The action programme will need to confirm the appropriate levels of staffing are in place to ensure plans are delivered. There also needs to be a commitment that any necessary SPG, master plan and planning applications will not be unduly delayed.

Draft Response: Acceptance: Partially accept Changes to be made

Each section within the plan details how the targets will be met in addition to monitoring methods.

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan. Provision of timescales and commitments for local development plans, SPGs, masterplans and planning applications, prepared and dealt with separately by Aberdeen City Council and Aberdeenshire Council, would not be appropriate within the structure plan.

14 January 2009 Page 67 of 244 287 24 Subject Putting this plan into practice Summary The section related to "providing infrastructure" must be re-written. Recognise that increased housing numbers will need a significant level of investment in infrastructure. There should be no policy of taxing the uplift in land value created by the granting of planning permission, rather must meet the terms of Circular 12/1996 and be related in scale and kind until the Government review this legislation.

Draft Response: Acceptance: Do not accept Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

289 1 Subject Putting this plan into practice Summary Lack of infrastructure such as schools, shops public transport etc in Fintry and Blackburn.

New development must have sufficient infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. The plan strongly emphasises the need to ensure required infrastructure improvements are in place prior to development.

Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements).

Rep. Number

291 6 Subject Putting this plan into practice Summary More emphasis must be put on the requirement for developers to contribute towards the necessary infrastructure.

Well planned services and infrastructure must be planned at the planning stage.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure play a key role in assisting to deliver the plans vision and spatial strategy. The plan acknowledges that there is a need to invest in the infrastructure of the region, particularly if we want to maintain and improve people’s quality of life. The need for new infrastructure will ‘have to be carefully considered very early in the land-development process, even before land is identified in local development plans’ (pg19). It is expected that much of the investment will come from developers, through the need to make contributions towards necessary infrastructure and services, although the public sector will also contribute.

It is not the place of the structure plan to provide financial information. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements).

Rep. Number

14 January 2009 Page 68 of 244 297 32 Subject Putting this plan into practice Summary The aim about securing a higher percentage of increase in land values than in the past, is a laudible aim but without any definate targets it lacks substance.

There is obviously restrictions in public expenditure how much will need to be raised from developers to achieve the objectives of the plan.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 297 33 Subject Putting this plan into practice Summary Nothing within the proposals that states how the WPR will provide an environmentally friendly method of transport.

Draft Response: Acceptance: Do not accept Changes to be made

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Rep. Number

299 29 Subject Putting this plan into practice Summary These are all at this stage just proposals.

They all involve much investment, very little of which is currently sourced, let alone guaranteed.

The draft does not contain any measure of the risks associated with building these into the plan.

There needs to be a discussion of the effect of any one or more of these not coming to fruition within the 25 year planning period.

Draft Response: Acceptance: Partially accept Changes to be made

The section states that the proposals are a "range of projects which have been proposed" and whilst "some are well under way, others are at an early stage". A number of the proposals will be funded externally and have received commitment from the Scottish Government.

It is agreed that the proposals will involve investment, however they will assist in delivering the plans vision and allow for short and long term developments with varying timescales over the plan period.

The proposals are strategic, cross boundary issues which will provide benefits for the entire city region. It is not the place of a structure plan to measure risks associated to building these into the plan. Risks will be measured when further details are available with regards to each proposal through the appropriate plans and strategies.

14 January 2009 Page 69 of 244 299 33 Subject Putting this plan into practice Summary It is vital to link the draft plan to other plans including:

The Strategic (Population) Forecasts, The ACSEF 'Building on Energy' business growth Strategy, A Housing Need Analysis and Strategy, A Waste Management Strategy for City and Shire, An Environmental Strategy and The NESTRANS Strategy etc.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan is a statutory land use planning document and aims to reflect the modernising planning agenda by removal of superfluous information and duplication of other plans and strategies. This is not to say these are not important elements in the growth and protection of the north-east and it is likely that the "action programme" referred to throughout the plan (but particularly on p.19) will include projects as well as who will lead them, when they should happen and how they will be funded.

The introduction states that regional strategies and plans have had an important influence on the structure plan and includes the other plans suggested.

Rep. Number

304 8 Subject Putting this plan into practice Summary The third don crossing was rejected in the Local plan so not sure why it is included here.

Draft Response: Acceptance: Noted Changes to be made

The Third Don Crossing is a fundamental element of both the regional and local transport strategies.

The crossing was removed from the finalised Aberdeen City Local Plan prior to adoption at the recommendation of the reporters since the proposal is not found in the current structure plan and (at that time late 2007) did not feature in the RTS or LTS. However, in relation to the RTS and LTS this situation has been rectified and inclusion in the structure plan will make its consideration in the new Aberdeen Local Development Plan a possibility.

The Third Don Crossing is a key element of a package of integrated transport measures being developed to improve access to the City from the north. The new crossing is also an integral part of the package of measures designed to tackle congestion at the A96 (T)/A90 (T) Haudagain roundabout junction. As such it is a fundamental piece of infrastructure which will facilitate growth in and to the north and north west of Aberdeen. The associated infrastructure improvements will also improve access into Aberdeen by public transport which addresses significant aims of the structure plan.

It is proposed to expand the text to make it clearer that developer contributions will be sought to contribute towards the cost of the bridge, although it can be anticipated that Aberdeen City Council will make a significant financial contribution towards its cost. Development sites in both Aberdeen City and Aberdeenshire can be expected to make a contribution.

The structure plan supports the principle of a third crossing of the River Don. However, the structure plan is not site-specific and consideration of the detail of a particular proposal is not a matter for the structure plan. Consideration of the detail is rightly a matter for the Local Development Plan in Aberdeen City as well as the processes surrounding any planning application.

Further details of the Third Don Crossing and other transport interventions proposed in the structure plan are outlined in the Background Paper to be published in parallel with the Finalised Structure Plan.

Any assessment of a proposal in the context of the local development plan or a planning application would rightly consider the detailed impacts of the package of interventions proposed in the context of a full STAG appraisal of the scheme. Any such proposal would need to take into account the findings of the Reporters at the Aberdeen City Local Plan Inquiry in 2006. However, the findings of that Inquiry do not invalidate the inclusion of the principle of the proposal within the structure plan. 304 13 Subject Putting this plan into practice Summary Reservations about promoting a community stadium where the major beneficiary will be a private company

Draft Response: Acceptance: Noted Changes to be made

The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

Rep. Number

14 January 2009 Page 70 of 244 307 18 Subject Putting this plan into practice Summary Support the list of proposals but have concerns with the statement -

This plan sets the framework for other plans and strategies, and promotes targets to achieve our aims. This plan will be put into practice through local development plans and supplementary guidance. These will be prepared separately by Aberdeen City Council and Aberdeenshire Council and must be consistent with this plan.

The phasing and goals of the Aberdeenshire Council - Westhill Capacity Study (WCS) appear to be at odds with the Aberdeen City & Shire Draft Structure Plan (DSP). The WCS is being sold as a "Draft" and for "consultation".

Draft Response: Acceptance: Partially accept Changes to be made

The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

Rep. Number

312 2 Subject Putting this plan into practice Summary For those living north of Aberdeen the third don crossing would just about be number 1 on the list.

Do not share the view that the AWPR will relieve some of the will help and the new crossing is the only way to resolve the problem.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic. 312 4 Subject Putting this plan into practice Summary The strategic plan makes reference to the 'master plan' for Aberdeen Airport.

CC considers that the master plan should be redrawn to take into account the Trump development and the number of guests expected.

Trump proposal should be a catalyst for making the improvements now.

The continued investment in the current terminal to the west of the main runway is seen as muddled, in that the railway line is to the East.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

This is not a structure plan issue.

The structure plan takes account of the positive impacts of the Airport Masterplan in relation to assisting in achieving the draft plans vision however it is not the place of the structure plan to request that the masteplan be redrawn to take into account specific developments.

Rep. Number

14 January 2009 Page 71 of 244 319 5 Subject Putting this plan into practice Summary Imaginative rapid public transport developments e.g. from Westhill, Kingswells to centre past hospital and Woodhill House has not been considered.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan is a high level strategic land use planning document and improvements to public transport are best dealt with through regional and/or local transport strategies working in partnership with NESTRANS.

Aberdeenshire Council funds and supports a large number of bus services as well as developing demand-response bus services. Since the adoption of Aberdeenshire Council’s first Local Transport Strategy (LTS) significant investment in transportation has seen improvements made across the network. These range from major infrastructure projects through investment in walking and cycling to the introduction of innovative passenger transport services, such as A2B Dial-A-Bus. 'A2B' dial-a-bus is a Demand Responsive door to door transport service introduced by Aberdeenshire Council in 2004 with assistance from the Scottish Executive.

In addition, the north east is currently served by three bus-based park and ride sites, at Ellon, Bridge of Don and Kingswells. Rail park and ride facilities are also provided at Stonehaven and Inverurie railway stations. They contribute to reducing traffic in and on approaches to the City, and free up parking demand in the City Centre. Future proposals are for the completion of a ring of Park & Ride services around Aberdeen, linked to the AWPR, enabling easy access to the City. Further details are provided within the Regional Transport Strategy.

Rep. Number

320 12 Subject Putting this plan into practice Summary Agree that there needs to be significant investment in the infrastructure of the structure plan area as well as in facilities and services for communities.

This is vital because in the past facilities, services and infrastructure have not automatically kept pace, with development which, as noted in the plan, has immediate implications for quality of life.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. 320 13 Subject Putting this plan into practice Summary Encourage the inclusion of renewable energy proposals, which will help to deliver the sustainable development and climate change objective.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

320 14 Subject Putting this plan into practice Summary Concern with City centre masterplan and feel public transport should extend along the length of Union Street.

Draft Response: Acceptance: Noted Changes to be made

Improvements to the shopping environment of Union Street are key to enhancing its importance as a retail destination meeting structure plan targets.

A Development Framework is currently under preparation to bring about radical and far reaching improvements to Aberdeen City Centre. As part of the Aberdeen Design Campaign, Aberdeen City Council is working with the Scott Sutherland School of Architecture and the Built Environment at the Robert Gordon University to produce a development framework to define the planning and urban design strategy for the future of Aberdeen City Centre.

This will include identified themes of Aberdeen City Centre as a Key Business Location, Retail Centre, Major Tourist Destination, Historical and Cultural Centre, Leisure and Entertainment Centre, Key Transport Node and a Place where people live and feel safe.

The extent to which the structure plan can influence this is limited. Local plans may have a greater role to play, but attempts to use these land use plans should not be over-emphasised when other plans and strategies are better placed.

14 January 2009 Page 72 of 244 320 15 Subject Putting this plan into practice Summary No need to include new city stadium.

Draft Response: Acceptance: Do not accept Changes to be made

The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

Rep. Number

322 2 Subject Putting this plan into practice Summary In the section entitled "Putting this Plan into Practice" we note that on page 20 the proposals include the regeneration of "some of the city region's most disadvantaged areas."

These proposals include our own proposed New Mosque and Community Centre which will reflect Aberdeen's more inclusive society and contribute to the vision as set out on page 5.

This proposal should be mentioned in the proposal on page 20. It will be of an innovative and prestigious nature, with inspiring architectural beauty and uniquely attractive landscaping.

Draft Response: Acceptance: Do not accept Changes to be made

The proposals section details a range of projects which have high level, strategic land use cross boundary planning implications for the region.

The plan aims to be short and focused and therefore the amount of information included must be carefully monitored, this is not intended to diminish the importance of other proposals, but some are better dealt with by other plans and strategies such as the Local Development Plan which will determine land allocations for local issues.

Rep. Number

330 36 Subject Putting this plan into practice Summary The draft Structure Plan is predicated on higher developer contributions early in the land development process to fund affordable housing, infrastructure, serves and facilities. SCDI has supported the use of Section 75 levies to replace arbitrary proportions of hosing schemed which are required to be reserved for affordable housing. However, in the wake of collapse of the house-building sector the Scottish Government has recently postponed the review of the system of developer contribution in Scotland to avoid placing new burdens on development at this time.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 73 of 244 330 37 Subject Putting this plan into practice Summary SCDI would support all projects which are identified to help achieve that vision for the North East, SCDI has the following specific comments:

New community stadium – of the two locations currently being investigated, SCDI prefers the Loirston site. It is a gateway that would open up the area, is not on common good land and offers the potential for a better funding mix.

Third crossing of the River Don – SCDI welcomes the progress which has been made in identifying the preferred scheme for Haudagain roundabout. However, as work by NESTRANS has identified, a Third Don Crossing would be an integral part of the solution, reduce congestion and improve air quality.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Comments relating to the location of a new community stadium are noted however this decision will not be taken through the structure plan process. The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

Rep. Number

332 5 Subject Putting this plan into practice Summary We agree that transport connection can drive economic growth. New development may also bring additional infrastructure requirements and our view is that developers ought to be asked to contribute proportionately and with reference to their development as per the provision of circular 12/96, which we understand is to be the reviewed in the next few months by the Scottish Government further to the First Minister’s statement on 19 August.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 332 8 Subject Putting this plan into practice Summary The potential for economic growth could be deterred by the excessive demands for developer contributions and the councils must find a fair deal to offer to investors as well as meet public infrastructure requirements. The draft structure plan currently suggests that the strategic growth areas will account for 75 to 80 percent of future growth in the region and this will require major investments in transport, schools and water systems etc. the structure plan goes on to argue that landowners will need to fund much of this p7.

We recommend early consultation on this with landowners and the development community in order to avoid any uncertainty over the level of contribution that will be required. Landowners may deem the costs too high and developers may be deterred from assembling sites for commercial development should they feel than an unsustainable burden may come via contribution requirements and we would wish to avoid the perception of a retrospective development land tax. These points are more important in the current financial climate where achieving funding for development is more challenging than it has been in recent years.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 74 of 244 332 9 Subject Putting this plan into practice Summary We believe that a greater appreciation of development economics needs to be realised by the planning authority before it determines policy in relation to developer contributions. It could be that the Aberdeen City and Shire is in one of the more identifiable City regions in which to formulate appropriate contributions that are proportionate to developments. Hence we call for engagement with the development community so that a private sector perspective can be ascertained by the councils and set against public sector requirements arising from new development and the relative demands made upon infrastructure.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

333 5 Subject Putting this plan into practice Summary It is absolute fundamental that this plan should set out specific projects for the area which promotes sustainable economic growth and in particular business growth.

Draft Response: Acceptance: Partially accept Changes to be made

An important objective of the plan is to grow the economy of the City and Shire.

The structure plan is a landuse strategy for growth, and is not specifically about economic growth, however, it makes reference to a number of sectors that have the ability to maintain and enhance the economy, including oil & gas, knowledge, R&D, tourism etc. However, clearly success is dependent on a number of external factors outwith the control of planning or Council's in general. It is the role of ACSEF, Scottish Enterprise, Council Economic Development Services and other agencies to pursue such leads, and ensure strategies are in place to help achieve this growth and the planning system has a role to play in helping to deliver them.

An action programme to be prepared in 2009 will help to expand upon this issue. For example, the Aberdeen City and Shire Economic Forum, Scottish Enterprise and the two councils have a key role in boosting economic growth but the planning system can help to provide the framework and opportunities.

Rep. Number

346 3 Subject Putting this plan into practice Summary I would welcome more details on how developers will be encouraged to make contributions towards community facilities within their development sites.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

14 January 2009 Page 75 of 244 353 1 Subject Putting this plan into practice Summary Objection to AWPR.

No benefits of the AWPR are foreseen. Worried about the destruction of the greenbelt. Concerned about the cost for the AWPR and who is paying for it. Alarmed that the Public Inquiry for the AWPR does not seem to take into account the opinion of the people of Aberdeen.

Draft Response: Acceptance: Noted Changes to be made

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Rep. Number

354 1 Subject Putting this plan into practice Summary AWPR is too expensive under current economic conditions. AWPR will encourage long-distance commuting.

Draft Response: Acceptance: Noted Changes to be made

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Rep. Number

356 5 Subject Putting this plan into practice Summary Substantial upgrading of transport links, and most specifically the railway, is required.

Numerous improvements were outlined: - Redoubling of the track from Aberdeen to Inverurie (at least). - Update signalling along the whole ‘corridor’ (especially Stonehaven to Inverurie) to allow closer spacing of trains. - Introduce cross rail and include new stations (not just at the present satellite towns, villages and ‘new town’ but also to include town stops for commuters to alight at. (a number of possible stations were suggested) - Introduce rail link to the airport from Stoneywood. Alternatively there should be a moving pedestrian way beneath the runways from Dyce station to the terminal building. - Electrify the cross rail in order to initiate further electrification to Edinburgh and satisfy one of the Governments long term aims for Scotland.

Draft Response: Acceptance: Partially accept Changes to be made

The draft structure plan support upgrades to the transport networks including some of those listed. However, the Regional Transport Stretegy takes the lead on many of these issues.

The provision of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy.

The structure plan is not the appropriate medium to give detailed information with regards to how rail links will be improved.

Rep. Number

14 January 2009 Page 76 of 244 364 2 Subject Putting this plan into practice Summary Construction of the Third Don Crossing must be considered as possibly the most important piece of transportation infrastructure in delivering the aspirations of the Aberdeen to Peterhead SGA for the following reasons: - To reduce traffic congestion - Improve journey times - Improve air quality in the city (all of the above are key transport objectives and priorities supported by the NTS) - Allow growth in and to the north of the city - Significantly reduce congestion at Haudagain roundabout

Construction of the Third Don Crossing should be implemented prior to construction of more housing in the Aberdeen to Peterhead SGA.

Draft Response: Acceptance: Noted Changes to be made

Support for this proposal is welcomed, the Third Don Crossing will remain in the plan in recognition of its importance and presence in the Regional and Local Transport Strategies.

Phasing of development in the Aberdeen to Peterhead SGA has been given careful consideration, hence the minimal numbers allocated until the Balmedie to Tipperty dualling, AWPR, Third Don Crossing and Haudagain projects are delivered around 2013-14. 364 3 Subject Putting this plan into practice Summary The Aberdeen Western Peripheral Route is the single most important issue facing the economic development of the region. It will: - Help deliver the Modern & Regional Transport Strategy - Ensure we will have a transport infrastructure that enables businesses to be more competitive and individuals to have a better choice; - It will reduce congestion - Improve journey times across the city - Reduce costs thereby retaining businesses, safeguarding jobs - Ensure the continued prosperity of the region which will otherwise be adversely affected should the project be delayed or not go ahead.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Rep. Number

365 2 Subject Putting this plan into practice Summary Building on Energy is surely a key document which should be referenced in this plan to help achieve the vision of the draft structure plan.

Draft Response: Acceptance: Noted Changes to be made

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan.

Building on Energy - The Economic Manifesto for Aberdeen City and Shire was produced by ACSEF and the draft structure plan Introduction states that "The regional strategies and plans which have an important influence on this plan include... The Aberdeen City and Shire Economic Forum's (ACSEF) Economic Manifesto."

14 January 2009 Page 77 of 244 365 7 Subject Putting this plan into practice Summary The plan rightly recognises the need to invest in the infrastructure of the structure plan area in order to maintain peoples quality of life together with investment in facilities and services for communities however the statements relating to this have an aspirational quality rather than inspiring real confidence that this will be delivered.

Recognition of the fundamental importance of facilities, services and infrastructure is being in place is not enough. The document needs to make clear how this will be ensured and needs to categorically state that in their absence permission to be built will not be given.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. The plan strongly emphasises the need to ensure required infrastructure improvements are in place prior to development.Within the sustainable mixed communities section of the plan it is stated that "This plan will not support house-building that fails to provide these services and facilities which help make successful and sustainable communities."

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

372 1 Subject Putting this plan into practice Summary Priority to progress Energetica must be a dual carriageway all the way to Peterhead. Without this there will always be limited scope for new businesses to locate ouwith Aberdeen or in attracting more people to the area to work/live.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure is an essential part of supporting the level of housing and economic development envisaged and is central to the plan. The plan makes it clear that the resolution of transportation problems across the north-east must be a priority and it has attempted to devise a strategy that does not impact negtively on these problems. Proposals to the north of Aberdeen are dependent on the AWPR and A90 upgrading at Balmedie / Tipperty. Until these take place, only limited development is proposed for this corridor. Trunk roads are outwith the control of Local Authorities however the plan acknowledges and takes into account relevant regional strategies and plans which have an importance influence on this plan (Nestrans and Scottish Government etc).

At the time the draft structure plan was prepared, the Energetica concept was not well developed. However, a ‘strategic framework’ has since been published which sets out more clearly what it might mean. Although the detail of the framework is not something that can be supported through the structure plan, the concept of supporting economic growth in the corridor is. The Action Programme will need to set out how the concept can be further developed and implemented. It is important to note that Energetica is an initiative being promoted by ACSEF and Scottish Enterprise, not Aberdeen City and Aberdeenshire Councils.

The plan presents a clear and rounded view of future development and represents a vision of the future shared across the whole of the city and shire area. It is acknowledged that housing and employment run in parallel with each other however there are infrastructure constraints in this corridor that require to be addressed prior to houses being built. This is reflected in the lower numbers in the first plan period.

Rep. Number

383 6 Subject Putting this plan into practice Summary Rail Links

Stations should be opened up from Laurencekirk in the south expanding the network with new stations at Newtonhill, Cove and to the north open new stations along the rail line. A 30-minute service should run from 7am-9am and 4pm - 6pm with bus services connecting to the rail service providing public transport links to Altens/Tullos and Dyce Industrial parks. This would provide a solution to the congestion on the road and would be much better for the environment.

Draft Response: Acceptance: Partially accept Changes to be made

The support, and provision, of infrastructure (including road and rail improvements play a key role in assisting to deliver the plans vision and spatial strategy.

Although there may be merit in some of the suggested improvements, the structure plan is a high level strategic land use planning document and improvements to the rail network are best dealt within within regional and/or local transport strategies.

The structure plan is a high level strategic document and is not the appropriate medium to give detailed information with regards to how rail links will be improved, however the objective must be outlined in the structure plan to set the framework for local and regional transport strategies which will provide higher levels of guidance.

Rep. Number

14 January 2009 Page 78 of 244 397 18 Subject Putting this plan into practice Summary The list on page 20 is a good basis.

However, the region needs not only "a new community stadium" but a range of international-standard sports facilities which will allow budding athletes to train, as well as providing more opportunities for the public at large. These facilities could reasonably be distributed across the region or, if more cost-effective, located in a single multi-sport complex. Most obvious of the needs is an Olympic-standard swimming pool to replace the dated and now-closed Bon Accord Baths. With the coming to the UK of the 2012 Olympics and 2014 Commonwealth Games, this is surely an essential and realistic aspiration for a modern City region.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welomed.

The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

There may be some merit to the new facilities which are suggested, however the extent to which the structure plan can influence this is limited. Local plans may have a greater role to play, but attempts to use these land use plans should not be over-emphasised when other plans and strategies are better placed. 397 19 Subject Putting this plan into practice Summary Concerned about, and did not understand, the expressed expectation (p. 19) "that the increase in land value .. will fund a large percentage of the new infrastructure". Land values will indeed increase and expects that developers will protest that because of the high price they paid for land, they cannot afford to make major contributions to infrastructure. How, therefore, is the money in the hands of the newly rich former land-owners to be released to fund that infrastructure? This needs to be explained in the plan.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

398 3 Subject Putting this plan into practice Summary Concern expressed that as the fossil fuel era is coming to an end (with no alternative energy source in place), and in the very likely scenario that energy (and food) prices will continually increase, the potential decline on traffic volumes and essential related developments in public transport may be significant enough to put into question whether the AWPR route is needed.

Queried whether the money required to develop the AWPR would be better spent on upgrading existing routes, public transport and new energy sources. Suggested that the plan should address energy supply, delivery of an electrified cross rail and a sophisticated system of on call mini bus services throughout the city and region.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy. However, this is more an issue for the Regional Transport Strategy than the structure plan which sets the framework for local and regional transport strategies to provide higher levels of guidance.

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Rep. Number

14 January 2009 Page 79 of 244 409 7 Subject Putting this plan into practice Summary If the AWPR does go ahead there will be pressure from many quarters to develop along it, particularly near to access junctions.

Development is inevitable to achieve the vision and must be done correctly.

Suggested that development could be focussed on being attached to an existing settlement like Peterculter. A new road/street could link the Banchory/Drumoak side of the North Deeside Road with the Milltimber AWPR junction which would ease the congestion in Peterculter's main street in addition to providing facilities, green spaces and services.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. The structure plan focusses development on existing communities and emphaises that services and facilities are an essential part of achieving sustainable mixed communities. The level of growth appropriate will be determined through the Local Development Plan process which will determine policies and land allocations for local issues.

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Rep. Number

411 10 Subject Putting this plan into practice Summary Structure plan should have a connection with Scottish Water for provision of drinking and waste water facilities. Major dalays will occur due to problems with Scottish Water if the structure plan does not adequately address the locations of future business/residential development.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure (including water provision) play a key role in assisting to deliver the plans vision and spatial strategy.

Preparing the plan has involved a great deal of consultation with key stakeholders (Scottish Water included), the public and private sector as well as with the wider community. The allocation of specific sites will be determined through the Local Development Plan process.

An action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed. 411 11 Subject Putting this plan into practice Summary High speed rail service from London/Edinburgh should be included within the structure plan as this would mean a new Aberdeen terminus and a modern rail line route in addition to the existing rail corridor which would become more suited to local traffic.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy.

Although there may be merit in some of the suggested improvements, the structure plan is a high level strategic land use planning document and improvements to the rail network are best dealt within regional and/or local transport strategies working in partnership with NESTRANS, Network Rail etc.

14 January 2009 Page 80 of 244 411 16 Subject Putting this plan into practice Summary Inclusion of Peterhead and Fraserburgh in the national rail network is important to the development of these towns and should be included in the structure plan.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy.

Although there may be merit in some of the suggested improvements, the structure plan is a high level strategic land use planning document and improvements to the rail network are best dealt within regional and/or local transport strategies working in partnership with NESTRANS, Network Rail etc.

Rep. Number

422 2 Subject Putting this plan into practice Summary How will the required infrastructure changes be funded?

Both councils are in a desperate financial position, and a declining/aging population will not help. Expecting "planning gain" to fund major infrastructure investment is naive in the extreme, as history has shown. For example, how many schools have been built by developers in NE Scotland (at their cost) rather than simply making land available to the council?

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions. 422 15 Subject Putting this plan into practice Summary "Developers will have to accept the need for contributions towards necessary infrastructure, services and facilities within their own site." How, why? "However, in cases where development has wider effects, we will have to secure extra contributions." How?

"We also expect that the increase in land value, as a result of granting planning permission, will fund a large percentage of the new infrastructure needed, although the public sector will also need to make an important contribution." How does an increase in land value fund infrastructure? Does this mean "planning gain"? If so, it has never funded more than some minor local projects, and invariably comes at the end of a development. How will the public sector make a contribution?

"We will need to secure a higher percentage of the increase in land values than we have in the past, to be able to create sustainable mixed communities." How? This is a repeat of the previous sentence.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

14 January 2009 Page 81 of 244 422 16 Subject Putting this plan into practice Summary No mention is made of any actions that will ensure growth of employment opportunities and hence population. The proposals will have minimal effect, if any. How does a new prison at Peterhead help the economy of the area? If the growth targets are to be met, something significant to replace the declining oil and gas industry will need to be found.

Draft Response: Acceptance: Do not accept Changes to be made

An important objective of the plan is to grow the economy of the City and Shire.

A new prison in the Peterhead area has been identified in the structure plan for a range of reasons. The Scottish Government announced on 24/08/2007 that it would be replacing prisons in Aberdeen and Peterhead with a new prison in the Peterhead area. The announcement made it clear that the Scottish Prison Service would seek to build the new prison as quickly as possible. The new prison will be of regional and national importance and retain vital local employment and economic spin-offs for the area. The Scottish Government’s announcement in August 2007 effectively ended the possibility that replacement prisons could be built in both Aberdeen and Peterhead.

The structure plan is a landuse strategy for growth, and is not specifically about economic growth, however, it makes reference to a number of sectors that have the ability to maintain and enhance the economy, including oil & gas, knowledge, Research & Development, tourism etc. However, clearly success is dependent on a number of external factors outwith the control of planning or Council's in general. It is the role of ACSEF, Scottish Enterprise, Council Economic Development Services and other agencies to pursue such leads, and ensure strategies are in place to help achieve this growth and the planning system has a role to play in helping to deliver them.

The plan acknowledges that changes are taking place in the oil and gas sector and action must be taken on this and other issues. This involves working with partners to help diversify the economy and build upon areas of expertise that already exist. This is set out in various parts of the plan.

An action programme to be prepared in 2009 will help to expand upon this issue. For example, the Aberdeen City and Shire Economic Forum, Scottish Enterprise and the two councils have a key role in boosting economic growth but the planning system can help to provide the framework and opportunities.

Rep. Number

423 4 Subject Putting this plan into practice Summary The premise that new infrastructure would be provided by developers is risible as we know from the past that developers provide very little additional facilities.

The burden will fall on Local Authorities to provide the infrastructure required for this level of growth and it is very obvious that these same local authorities cannot even afford to sustain the existing infrastructure, with toilets closed and existing facilities at risk.

Draft Response: Acceptance: Do not accept Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

14 January 2009 Page 82 of 244 424 10 Subject Putting this plan into practice Summary As this Plan is for a strategic level consideration, what is the significance for proposing a new prison in Peterhead?

Why stadium sites are identified in this structure plan, but not other major "bad neighbour" developments, such as incinerators, which are equally important? Why the Trump's golf course development, which has estimated cost of £1bn is not shown in the structure plan (although it potentially could be refused)? I think this is large and significant enough development, similar to the AWPR.

Although the Aberdeen Airport is currently under the ownership of BAA, there is no guarantee that it would not be owned by the local council by 2030. Are the local authorities getting prepared? What is the vision for the future of the airport? Is there any expansion or even relocation plan in the future? Any land reserved for it?

Draft Response: Acceptance: Noted Changes to be made

A new prison in the Peterhead area has been identified in the structure plan for a range of reasons. The Scottish Government announced on 24/08/2007 that it would be replacing prisons in Aberdeen and Peterhead with a new prison in the Peterhead area. The announcement made it clear that the Scottish Prison Service would seek to build the new prison as quickly as possible. The new prison will be of regional and national importance and retain vital local employment and economic spin-offs for the area. The Scottish Government’s announcement in August 2007 effectively ended the possibility that replacement prisons could be built in both Aberdeen and Peterhead.

However, the advantages of retaining a prison in Aberdeen are recognised in terms of facilitating prison visits and reducing transport costs and emissions (social, economic and environmental factors). Consideration will therefore be given as to how support can be given for a new facility in Aberdeen as well.

The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

The structure plan takes account of the positive impacts of the Airport Masterplan in relation to assisting in achieving the draft plans vision however it is not the place of the structure plan to duplicate information contained within other plans and strategies. The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Rep. Number

426 29 Subject Putting this plan into practice Summary Do not see anything being achieved from this plan and the other plans either. Should show more confidence in the existing plans and produce the programmes showing who, what, when, where and how much now.

Draft Response: Acceptance: Noted Changes to be made

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’.

Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Rep. Number

432 1 Subject Putting this plan into practice Summary Concerned about possible effects on quality of life and the unique features of the River Don from a Third Crossing, more thought should be given to its environmental impact.

Draft Response: Acceptance: Partially accept Changes to be made

The Third Don Crossing is a fundamental element of both the regional and local transport strategies. It is a key element of a package of integrated transport measures being developed to improve access to the City from the north. The new crossing is also an integral part of the package of measures designed to tackle congestion at the A96 (T)/A90 (T) Haudagain roundabout junction. As such it is a fundamental piece of infrastructure which will facilitate growth in and to the north and north west of Aberdeen. The associated infrastructure improvements will also improve access into Aberdeen by public transport which addresses significant aims of the structure plan.

The structure plan supports the principle of a third crossing of the River Don. However, the structure plan is not site-specific and consideration of the detail of a particular proposal is not a matter for the structure plan. Consideration of the detail (including any environmental impact) is rightly a matter for the Local Development Plan in Aberdeen City as well as the processes surrounding any planning application.

Further details of the Third Don Crossing and other transport interventions proposed in the structure plan are outlined in the Background Paper to be published in parallel with the Finalised Structure Plan.

Any assessment of a proposal in the context of the local development plan or a planning application would rightly consider the detailed impacts of the package of interventions proposed in the context of a full STAG appraisal of the scheme. Any such proposal would need to take into account the findings of the Reporters at the Aberdeen City Local Plan Inquiry in 2006. However, the findings of that Inquiry do not invalidate the inclusion of the principle of the proposal within the structure plan.

14 January 2009 Page 83 of 244 Rep. Number

437 1 Subject Putting this plan into practice Summary Where will the new road linking the A92 to the A957 south of Stonehaven be located? Bervie Braes has problems with land slips and would ruin the south east edge of Dunnottar Woods.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

Representation is with regards to a specific proposed development and is therefore not a structure plan issue.

Detailed proposals will be dealt with within the Local Development Plan process.

Rep. Number

440 5 Subject Putting this plan into practice Summary The new sporting complex should be in the South of the city for crowd control purposes.

Draft Response: Acceptance: Noted Changes to be made

Comments relating to the location of a new community stadium are noted however this decision will not be taken through the structure plan process.

Rep. Number

441 12 Subject Putting this plan into practice Summary Need to grow 'knowledge jobs' as these shall provide greater incomes than those available in the tourist industry. Commercial premises for supporting locally based employee's should be encouraged. Also need to develop the NE as a centre of excellence for renewable energy and support services. The new prison should not be an aim, the aim should be to reduce the prison population.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan is a landuse strategy for growth, and is not specifically about economic growth, however, it makes reference to a number of sectors that have the ability to maintain and enhance the economy, including oil & gas, knowledge, Research & Development, tourism etc. However, clearly success is dependent on a number of external factors outwith the control of planning or Council's in general. It is the role of ACSEF, Scottish Enterprise, Council Economic Development Services and other agencies to pursue such leads, and ensure strategies are in place to help achieve this growth and the planning system has a role to play in helping to deliver them.

At the settlement level, the allocation of specific sites and detailed policies will be undertaken by the relevant council as part of the local development plan process.

The new prison is not an aim, it is a proposal which will help to meet the aims and vision of the structure plan. The new prison will be of regional and national importance and retain vital local employment and economic spin-offs for the area.

Rep. Number

443 2 Subject Putting this plan into practice Summary Note that the AWPR is identified on p.20, but this is not yet a certainty and fail to see how it will facilitate "environmentally friendly methods of transport"

Draft Response: Acceptance: Noted Changes to be made

The AWPR is a Scottish Government supported project and the principle has been agreed by Scottish Ministers. The AWPR will release significant infrastructure constraints, in combination with 3rd Don Crossing (and associated measures) and dualling of A90, to the North of Aberdeen.

The Aberdeen Western Peripheral Route is the most important infrastructure project taking place in the North East and will facilitate development in line with the Structure Plan whilst bringing in a range of substantial benefits to the region. Its impact will be felt in the economy by relieving the currently constrained infrastructure. It will improve the air quality for over 55,000 properties. It will improve road safety through a reduction of thousands of vehicles passing through Aberdeen (including the city centre) and access to the North East. It will also enable many improvements to, and integration of, private and public transport schemes (such as Park and Ride). Plans to pedestrianise Union Street will also be assisted by the route.

The route will remove thousands of vehicles from the area’s rural roads which are unsuitable for high volumes of traffic.

Rep. Number

14 January 2009 Page 84 of 244 447 3 Subject Putting this plan into practice Summary Development along rail routes is welcomed and consideration should be given to the reinstatement of the & Way. The Airport Terminal should be located at Dyce Station and it might be beneficial to install a tramline along the Old Deeside railway line. Road corridors just lead to bottlenecks.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy. A range of proposals are outlined within the plan including ones which will deal with congestion and allow growth in and to the north of the city.

Although there may be merit in suggesting alternative transportation methods, the structure plan is a high level strategic land use planning document and improvements to the road and public transportation network are best dealt within within regional and/or local transport strategies.

Rep. Number

451 12 Subject Putting this plan into practice Summary Proposals should consider stimulating the local food economy and self sufficiency for the area.

Forestry should be considered as important for building materials and energy.

Draft Response: Acceptance: Do not accept Changes to be made

The plan aims to achieve sustainable mixed communities and encourages diversification of the regions economy however the plan tries not to involve itself with issues that are neither strategic, nor cross-boundary. This in no way is a reflection on the importance of any particular industry or environmental benefit, but an attempt to keep this new-style plan as concise as possible.

Local forestry may have a role to play.The extent to which the structure plan can influence this is limited. Local plans may have a greater role to play, but attempts to use these land use plans should not be over-emphasised when other plans and strategies are better placed. Local development plans may continue to refer to the Indicative Forestry Strategy etc.

Rep. Number

452 15 Subject Putting this plan into practice Summary Questions whether a new community stadium is really needed, will it bring about the level of benefits suggested.

Attention should be drawn to AECC whose future was cast in doubt with the dissolution of the Grampian region. Who will maintain and run the stadium and who will be accountable should it be unsuccessful.

Draft Response: Acceptance: Noted Changes to be made

The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

Day to day maintance and running of the stadium is not a structure plan issue.

Rep. Number

457 12 Subject Putting this plan into practice Summary The statement about developer contributions for necessary infrastructure are welcomed.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 85 of 244 458 15 Subject Putting this plan into practice Summary Providing Infrastructure: Proposals such as the pedestrianisation of Union Street and the provision of a community stadium seem too specific for this plan. Instead recommend long-term framework plans for key settlements, regeneration areas and potential growth areas to direct growth.

Draft Response: Acceptance: Do not accept Changes to be made

Strategic land use proposals which will help to meet the aims and vision of the structure plan have been included within the proposals section.

Improvements to the shopping environment of Union Street are key to enhancing its importance as a retail destination meeting structure plan targets.

The stadium will be a regional facility and will be used by, and benefit, communities throughout the region. Its development is of strategic importance for the region in economic and social terms and due to its nature, scale and location will have wide reaching impacts and is an appropriate proposal within the Structure Plan.

Rep. Number

465 2 Subject Putting this plan into practice Summary As a strategic tier plan, we would expect the draft to resolve cross-boundary issues between Aberdeen City and Aberdeenshire and allow an assessment to be made of the effect of the proposals on strategic infrastructure. Particularly in the latter area, the plan is considered light on detail and justification. For example, does the level of detail on housing and business allocations allow the likes of Transport Scotland and Scottish Water to assess the impact of the plan?

Draft Response: Acceptance: Partially accept Changes to be made

The support, and provision, of infrastructure plays a key role in assisting to deliver the plans vision and spatial strategy. Preparing the plan has involved a great deal of consultation with key stakeholders (Scottish Water and Transport Scotland included), the public and private sector as well as with the wider community.

The structure plan and spatial strategy in particular are interdependent on an effective and efficient transport system. The work done with Transport Scotland and close liaison with Nestrans has greatly benefited plan production. The recent workshop was another component of this consultation and further meetings will be held to ensure interventions can be identified as soon as practicably possible and fed into local development plans. There may still need to be a requirement for SPG to accommodate unforeseen eventualities. It is proposed to publish an addendum to the Background Paper in due course to support the structure plan.

An action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed. 465 14 Subject Putting this plan into practice Summary TSC11 - Welcome the intention to "consider the level of investment required in infrastructure very early in the land -development process", this is entirely consistent with the approach now being taken by TS.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

465 15 Subject Putting this plan into practice Summary TSC12 - Note a number of statements referring to the funding of infrastructure improvements, including in the final paragraph of p.19. It is a requirement that any intervention for which funding or consent is sought from TS should have emerged from an appropriate appraisal using principles of STAG. Therefore, ask that the following statement is included within the plan:

"It is a requirement for any transport intervention for which Scottish Government / Transport Scotland funding, and / or consent is sought, that such an intervention has emerged from an appropriate transport appraisal process using the principles of Scottish Transport Appraisal Guidance (STAG)."

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan and spatial strategy in particular are interdependent on an effective and efficient transport system. The work done with Transport Scotland and close liaison with Nestrans has greatly benefitted plan production. The recent workshop was another component of this consultation and further meetings will be held to ensure interventions can be identified as soon as practicably possible and fed into local development plans. There may still need to be a requirement for SPG to accommodate unforeseen eventualities.

It is proposed to publish an addendum to the Background Paper in due course to support the structure plan.

Rep. Number

14 January 2009 Page 86 of 244 470 13 Subject Putting this plan into practice Summary The ACSEF Board would welcome the opportunity to discuss the most effective way of aligning the plan with the ACSEF Action Plan.

Draft Response: Acceptance: Noted Changes to be made

The ACSEF Board continue to be involved within the Keystakeholder Reference Group and the structure plan has taken account of 'Building on Energy' within the remit of land use planning.

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’.

Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Rep. Number

472 10 Subject Putting this plan into practice Summary There are other recreational and commercial developments that could be referenced (incl. a number of golf course local resorts). There are also proposals for a new HQ for the Fire Service, Aberdeen City Council and accommodation for Grampian Police in Peterhead and Aberdeen. A new health centre in Inverurie could also be included, along with new educational facilities. A new 50m pool and upgrade of Aberdeenshire pools is an opportunity to market the area and working in partnership with the universities and NHS Trust to develop new treatments will enhance the region as a preferred location for learning.

Draft Response: Acceptance: Do not accept Changes to be made

The suggestions are noted. However, they are not of a nature which make them critical to the delivery of the plan.

This is not to say these are not important elements in the growth and protection of the north-east and it is likely that the "action programme" referred to throughout the plan (but particularly on p.19) will include projects as well as who will lead them, when they should happen and how they will be funded.

Rep. Number

476 15 Subject Putting this plan into practice Summary Need to clearly articulate the principle of expecting developers to contribute towards wider infrastructure provision given the scale of new infrastructure required within the plan. Infrastructure provision to be addressed by the public sector should also be defined.

Draft Response: Acceptance: Noted Changes to be made

The Action Programme will provide further details. The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Circular 12/1996 is currently under review, with a draft replacement published for consultation in December 2008. It is anticipated that the final document will be published before the Structure Plan is approved by Scottish Ministers. Due to current economic conditions the Scottish Government have put their wider review of developer contributions on hold. However, the Aberdeen City and Shire Strategic Development Planning Authority have made representations to Ministers on this issue.

In reference to developer contributions in scale and kind, it must be noted that large scale developments will require large scale contributions.

Rep. Number

478 1 Subject Putting this plan into practice Summary The vision and aims are clearly set out and easy to read. However, it would be useful to clarify if the action programme referred to will be produced following the final version of the plan, if stakeholders will be involved in preparing this programme and its likely content.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Rep. Number

14 January 2009 Page 87 of 244 479 21 Subject Putting this plan into practice Summary This is the section where we would like to see a proposal for establishing a green network covering Aberdeen City and the 3 Strategic Growth Areas.

Draft Response: Acceptance: Do not accept Changes to be made

The proposals listed are important in terms of strategic cross boundary land use planning in the North East.

Agree that green networks are important but this is not the section of the plan to include this in. Slight rewording of the Quality of the Environment objective may include a reference to green networks or a reference to existing and proposed open spaces.

It will be the responsibility of the local development plan to allocate specific sites and take account of the green space network, connectivity etc.

Rep. Number

183 3 Subject Schedule 1 Summary Concern that three options are shown in Schedule 1. It is unclear what is proposed with the choices.

Is it the case that the finalised plan will only contain one option? It is also surprising that the Structure Plan does not indicate how the 72,000 houses will be delivered, leaving the distribution for subsequent Local Plans.

Draft Response: Acceptance: Noted Changes to be made

The alternatives were provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan. Allocations to individual settlements will be a matter for the Local Development Plans. 183 4 Subject Schedule 1 Summary One or two new settlements may be required to meet the scale of housing proposed whilst meeting the objectives of sustainability. The plan fails to mention this as an option.

Draft Response: Acceptance: Noted Changes to be made

The draft structure plan did not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. The consulation questions explicity raised the issue of new settlements. 183 5 Subject Schedule 1 Summary Schedule 1 provides very little strategic guidance for Local Development Plans or subsequent planning applications it simply identifies the Strategic Growth Areas.

When this is also considered along with the extent of Green Belt that need reviewed to accommodate the growth it would appear to be impossible for this plan to identify either areas for no development or areas where it would be appropriate.

Draft Response: Acceptance: Do not accept Changes to be made

The flexibility in this plan is appropriate as it gives each Council latitude to determine their own interpretation of the plan without it being overly prescriptive when many decisions are not strategic or cross-boundary. The structure plan does not need to determine how many homes go to main settlements, or the Aberdeenshire areas as NEST did. These decisions should be taken by Aberdeenshire Council as part of the local development plan process, provided the spatial strategy is adhered to.

Rep. Number

188 6 Subject Schedule 1 Summary Need to update the strategic forecasts to reflect national projections.

Sufficient land should be allocated to meet the GRO recent projections of a population of 500,000 by 2031. Increased population equals increased people so an increased housing requirement.

Draft Response: Acceptance: Do not accept Changes to be made

The housing allocations are already generous and based on a high growth scenario. The plan aims to grow the population by 40,000 by 2030 with a longer term ambition to achieve 500,000. The plan will be subject to regular review, this will give the opportunity to revisit these targets as time progresses.

Rep. Number

14 January 2009 Page 88 of 244 189 4 Subject Schedule 1 Summary 6,000 houses in schedule 1 on the Portlethen to Stonehaven corridor should be considered as the absolute minimum.

Draft Response: Acceptance: Noted Changes to be made

Noted.

189 5 Subject Schedule 1 Summary There is an argument to increase the allocations set out in V1 and V2 within the Portlethen-Stonehaven area, this could be addressed by increasing the overall allocation.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

Rep. Number

191 1 Subject Schedule 1 Summary Seek an increase in the number of allocations for the Inverurie - Blackburn area.

Draft Response: Acceptance: Do not accept Changes to be made

Allocations in this SGA are already generous. However, it must be remembered that the plan will be subject to regular review and this will give the opportunity to reconsider allocations if necessary. 191 4 Subject Schedule 1 Summary Concern must be expressed at the current uncertainty as regards the scale of allocation to the Inverurie-Blackburn area.

Alternatives shown in Schedule 1 show 10,000 or 1,000. 1000 is entirely unacceptable and there is evidence to suggest that the 6,500 units favored within Schedule 1 should be increased as part of an overall increase in housing allocations.

An increase would help to exceed current completions and meet government policy.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

The total housing allowances in the draft plan were in line with Scottish Government policy and aspiration. An "overall increase in housing allocations" is not justified.

Rep. Number

192 4 Subject Schedule 1 Summary Concern must be expressed at the current uncertainty as regards the scale of allocation to the Inverurie-Blackburn area.

Alternatives shown in Schedule 1 show 10,000 or 1,000. 1000 is entirely unacceptable and there is evidence to suggest that the 6,500 units favored within Schedule 1 should be increased as part of an overall increase in housing allocations.

An increase would help to exceed current completions and meet government policy.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

The total housing allowances in the draft plan were in line with Scottish Government policy and aspiration. An "overall increase in housing allocations" is not justified.

Rep. Number

14 January 2009 Page 89 of 244 193 7 Subject Schedule 1 Summary Further justification for increasing the housing numbers is that the headline figure includes 5,000 houses emerging for regeneration areas within the city. These are simple replacements and because of this the net increase being promoted by the plan is 67,000 not 72,000.

Draft Response: Acceptance: Partially accept Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest 193 8 Subject Schedule 1 Summary The requested increase in figures should be distributed between the larger settlements in the SGA within the RHMA together with a greater allocation of housing in the AHMA where some of the larger settlements in the Local Growth Areas are able to absorb additional residential development.

Draft Response: Acceptance: Do not accept Changes to be made

The proportion of development allocated to the LG&DA is around 25% of the gross amount; this still represents several thousand homes and a substantial amount of employment land. The local development plan for Aberdeenshire will make decisions on the allocations for specific settlements within the framework set out in the structure plan. This level of detail would be too prescriptive for this plan. 193 10 Subject Schedule 1 Summary Over the past 7 years house completions in Laurencekirk have averaged 38 units per year. Anticipated completions over the next 5 years average out at 65 units per year, thus an increase in the current rate. An analysis against the headline figures for housing allowances in the draft plan for the south of Drumlithie to Marykirk corridor indicates 15.4 years supply. Incorporating the effective land supply indicates 19 years, 5 years short of the lifespan of the plan.

Based upon the lifespan of the plan and anticipated completions, Laurencekirk along requires a headline figure of 1,560 dwellings along, thus significantly greater than the 1,000 proposed.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan is not predicated on past rates of completion. However, it must be remembered that the plan will be subject to regular review, which will give the opportunity to reconsider allocations, particularly in the third period beyond 2023. 193 11 Subject Schedule 1 Summary In an analysis of the average house completions over the past 7 years compared with the Draft plans requirements highlights that in the Aberdeenshire part of the AHMA there is a 21.5 year supply, which is considerably less than the RHMA of 31.5 years. The RHMA figures go beyond the lifetime of the plan and justify an increase in the AHMA numbers, in order to provide a comparable supply between each HMA.

Draft Response: Acceptance: Do not accept Changes to be made

The situation in Pitmedden (or Formartine even) cannot be taken as a barometer for the whole of the AHMA or Aberdeenshire. The 2008 Housing Land Audit on p.16-17, clearly demonstrates that the effective land supply in the AHMA is x.x years and the RHMA is x.x years. There is no requirement for the HMA's to have exactly the same figure, only to ensure the maintenance of an effective five year housing land supply. The fact that the figure in the AHMA has fallen below this level means that …

Rep. Number

14 January 2009 Page 90 of 244 195 9 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031 (20,000 more than planned). This could amount to in excess of 8,000 houses based on 2.4 person per house average and housing allocations should be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest

Rep. Number

196 7 Subject Schedule 1 Summary The allocation of 6,000 homes in the Portlethen to Stonehaven corridor emphasises its ability to accommodate further strategic growth. The provision of adequate employment land to Portlethen should be in balance with the population and housing increases envisaged. This will also help with the accessibility objective and targets.

Draft Response: Acceptance: Noted Changes to be made

The plan seeks to promote mixed use development along the lines envisaged, although it will be for Aberdeenshire Council to determine the scale of growth in Portlethen in the context of the structure plan.

Rep. Number

197 7 Subject Schedule 1 Summary Due to the considerable interests the University have in the City, it is suggested a greater proportion of housing land is provided within the City boundary. Consideration should be given to the production of a similar proposal for employment land in order to appreciate where these are intended to be located.

Draft Response: Acceptance: Do not accept Changes to be made

The location of residential and employment land within Aberdeen City will be determined through the local development plan process. The plan already proposes considerable growth in Aberdeen, especially when compared with the recent past.

Rep. Number

14 January 2009 Page 91 of 244 198 5 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031 (20,000 more than planned). This could amount to in excess of 8,000 houses based on 2.4 person per house average and housing allocations should be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest 198 6 Subject Schedule 1 Summary The increase in housing allocations justified in 198.6 should be allocated to the LG&DA's within the AHMA as an analysis of housing completions highlights there is a 21.8 year supply in the Aberdeenshire part of the AHMA and a 31.5 year supply in the RHMA; this justifies why any increase should go to this area.

Other than the main settlements in the RHMA, the focus should be on the AHMA as settlements there are well served by community facilities and relatively well established road and public transport links with the City. These will require upgrading, but this can only be achieved by encouraging further development.

Draft Response: Acceptance: Do not accept Changes to be made

It is important that both Housing Market Areas are able to grow and diversify to meet the vision of the plan. The two areas have different challenges and opportunities which need to be reflected in the plan.

The spatial strategy does not identify particular settlements and the scale of development for them, this is a task for Aberdeenshire Council. This will involve extensive consultation and site selection will be based on social, economic and environmental criteria and infrastructure requirements. 198 10 Subject Schedule 1 Summary The present allocation of 4,700 in the LG&DA (AHMA) against 12,400 in the LG&DA (RHMA) is disproportionate and does not reflect demand or completion rates. Further to this the RHMA has the largest amount of constrained sites, adding 12,400 will exacerbate this.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan proposes that demand in the AHMA will largely be met in the SGAs, rather than in the LG&DAs. As a consequence, the analysis presented is not relevant. The structure plan covers the period to 2030 and a considerable volume of new sites will be required in the RHMA over this period.

Rep. Number

14 January 2009 Page 92 of 244 199 7 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031. This increased population will have consequences in terms of households and housing allocations should therefore be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of house building to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest

Rep. Number

200 6 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031. This increased population will have consequences in terms of households and housing allocations should therefore be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest

Rep. Number

14 January 2009 Page 93 of 244 202 4 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031. This increased population will have consequences in terms of households and housing allocations should therefore be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest

Rep. Number

203 5 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031. This increased population will have consequences in terms of households and housing allocations should therefore be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest

Rep. Number

14 January 2009 Page 94 of 244 204 2 Subject Schedule 1 Summary Concerned about the indicative housing allocations to the Inverurie area as this area is to include Kintore and Blackburn also. Allocations appear to be unevenly distributed through plan periods, artificially restricting the release of land until 2024. Levels of growth are significantly below recent recorded levels of actual development (see tables in document). This restriction does not align with the plan's objective to "increase the population of the city region by 9%".

Draft Response: Acceptance: Do not accept Changes to be made

Allocations are phased, in part, to account for the provision of key infrastructure to enable development to proceed. This particularly relates to secondary school provision and the need to phase the provision of new schools across Aberdeenshire. The plan has a strategy for growth, but needs to be phased in particular areas over different timescales to make it deliverable. 204 3 Subject Schedule 1 Summary Do not support the v.1 figures in Schedule 1. Allocating only 1,000 units over the entire plan period does not recognise the strategic significance of the Inverurie corridor, nor the definition of the SGA in the spatial strategy. Inverurie is one of the most sustainable settlements in Aberdeenshire and is therefore well placed to absorb a higher proportion than has been allocated. Recommend v.1 is abandoned.

Higher allocations will allow the market to operate at an efficient rate and allow required physical and community service infrastructure investment that will be required to be planned.

Draft Response: Acceptance: Accepted Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

The allocation in the draft plan of 6,500 will remain. 204 4 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031. This increased population will have consequences in terms of households and housing allocations should therefore be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest

Rep. Number

14 January 2009 Page 95 of 244 205 5 Subject Schedule 1 Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

Rep. Number

210 12 Subject Schedule 1 Summary Alternative v.2 should be deleted from the plan as it allows for virtually no growth in large parts of Aberdeenshire. However, if retained, the figure of 1,100 should be replaced with 4,700 or greater.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

Rep. Number

211 12 Subject Schedule 1 Summary Alternative v.2 should be deleted from the plan as it allows for virtually no growth in large parts of Aberdeenshire. However, if retained, the figure of 1,100 should be replaced with 4,700 or greater.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

Rep. Number

242 4 Subject Schedule 1 Summary Also have some concerns about the ability of the plan to deliver 10,000 homes on City brownfield land and capacity within the Aberdeen to Stonehaven corridor to accommodate the level of housing proposed.

Draft Response: Acceptance: Noted Changes to be made

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. This level is substantially lower than in previous years, when brownfield development represented between 60-90%. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result.

The Urban Capacity Study contained in the Background Paper provides the justification for the brownfield allowances until 2016. The allowances beyond 2016 will be reviewed in future strategic development plans in light of updated urban capacity information.

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

Rep. Number

14 January 2009 Page 96 of 244 246 3 Subject Schedule 1 Summary We support the focus placed on the corridor to the south of Aberdeen and the potential to increase housing provision through alternatives v1 and v2. It is considered that each settlement should take its appropriate share of new housing to provide for quality and choice at a settlement level and in order to achieve the sustainability and environmental objectives of the plan. The share and location of housing throughout the plan area should be determined by a detailed planning assessment through the local plan review.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

There will however be no alternatives provided within the Approved Structure Plan.

Rep. Number

254 5 Subject Schedule 1 Summary It is unclear how the Shire’s allocation can be effectively split 50/50 between the Aberdeen and Rural Housing Market Areas given the expectation that there will be a higher need generated within the Aberdeen HMA in contrast to the Rural HMA. We would anticipate that any increased strategic allocation that is generated through a review of strategic requirements was directed to the Aberdeen HMA.

Taking the above, we would support the proposed distribution of proposed housing allocations for the Shire and in particular the Inverurie area as detailed within the Draft Structure Plan as minimum.

For Inverurie, the V1 Alternative would be unfortunate given that it would not generate any critical mass to support the significant infrastructure investment that is need within Inverurie to take it beyond the current committed developments; the area having effectively reached a critical threshold point.

Draft Response: Acceptance: Partially accept Changes to be made

The Shire allocations are not split 50/50 between the AHMA and RHMA, but are 50/50 between SGAs and LG&DAs. The respective figures are contained within Schedule 1. The AHMA includes Aberdeen City.

The allocations for the Blackburn to Inverurie SGA are proposed to remain as shown in the draft plan; 6,500 units.

The alternatives were provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

Rep. Number

255 2 Subject Schedule 1 Summary Firstly, looking at the schedule, one cannot immediately ascertain whether one’s home would be affected by the plan. Identifying the main areas of development in corridors disguises the fact that individual settlements might be significantly affected. This seems contrary to the advice that plans should generally try to provide more certainty for developers, the public and service providers alike.

Secondly, there is no reasoned justification for the allocations in the schedule, and no obvious explanation of how they are derived from the spatial strategy.

Thirdly, there is no explanation for the alternative strategies set out in the schedule. Bancon have been advised variously (at public meetings) that these are either: a one/two academy strategy, an alternative new settlement strategy, or have been included to stimulate debate. However, for the layman looking at the plan, they are difficult to understand, if not plain confusing.

Bancon feel that it would be inappropriate for the finalized plan to proceed in this way and that there requires to be greater clarity on all these issues, and in particular a preferred strategy in place, before the public, developers and other stakeholders can make any meaningful comment on the plan.

Draft Response: Acceptance: Do not accept Changes to be made

This plan is intended to operate at the strategic level, where the role of individual settlements is not explored and level of growth is not imposed; this is a task for Aberdeenshire Council through the local development plan. The plan does provide certainty as it allows Council Services and strategic infrastructure providers to forward plan, whilst giving developers the opportunity to submit bids for scrutiny by each Council and be debated publicly.

A justification for the overall figure the plan promotes is to be found in the Background Paper. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The alternatives were provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan. However, the draft plan did include a 'preferred' solution.

The fundamental principles of the plan and level of detail will not be amended, the information that the respondant seeks is a matter for local development plans.

14 January 2009 Page 97 of 244 255 14 Subject Schedule 1 Summary The idea of ‘front loading’ the land release is welcomed. However, it is questioned whether this is in fact achieved in Schedule 1. If anything then Schedule 1 is geared to providing more intense development in the mid to later periods of the plan.

Draft Response: Acceptance: Partially accept Changes to be made

Phasing within particular corridors is based on infrastructure constraints that will need to be resolved prior to significant levels of development taking place. An example of this is the limited numbers in the A90 (north) corridor until the AWPR, Balmedie to Tipperty dualling and Third Don Crossing are in place. It is also necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period.

Rep. Number

259 7 Subject Schedule 1 Summary In 'Schedule 1: Housing Allowances', page 22, it is unclear what the columns 'Alternatives' relate to and therefore requires clarification.

Draft Response: Acceptance: Noted Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan. 259 8 Subject Schedule 1 Summary In 'Schedule 1: Housing allowances', page 22, it is unclear why some areas have a high proposed uptake early whilst other areas have a high proposed uptake much later in the plan period and this therefore requires clarification.

Draft Response: Acceptance: Noted Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

Rep. Number

264 5 Subject Schedule 1 Summary The housing section of the structure plan has been unduly influenced by a perverse need to locate the majority of new developments within sight of a railway line regardless of the fact that rail transportation account for an extremely small fraction of all journeys within the NE.

Draft Response: Acceptance: Do not accept Changes to be made

The spatial strategy emerged after extensive consultation within the Council's and with communities and other stakeholders. It does focus development in the City and corridors where the opportunities to encourage public transport are greatest. The concentration of 75-80% of development in these locations has other benefits related to economies of scale for provision of services and facilities. This is believed to be the most appropriate response to the challenges facing the north-east. 264 10 Subject Schedule 1 Summary The Formartine part of the AHMA requires a minimum 5000-5500 houses spread throughout the area in large and small settlements if the Energetica project is to be successful and the impact of the Trump development is to be accommodated.

Draft Response: Acceptance: Do not accept Changes to be made

There is no justification provided for the comments made. However, an increase of 1,000 units in the Blackdog to Ellon corridor is proposed, taking the total allocation to 3,400 units. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects. Allocations will be subject to regular review. 264 24 Subject Schedule 1 Summary The housing land requirements for each HMA require to be identified for each plan period and the basis upon which these requirements have been calculated need to be made available.

Draft Response: Acceptance: Do not accept Changes to be made

Schedule 1 attempts to convey a great deal of information in as succinct a form as possible. It is important that Schedule 1 contains all necessary information for the production of local development plans. Whilst this may appear cumbersome, there is a high degree of logic to the separations of the SGAs and phasing contained therein.

14 January 2009 Page 98 of 244 264 25 Subject Schedule 1 Summary While the city has substantial allocations in the first plan period the Shire has effectively bailed out of the housing provision in the AHMA by substantially inadequate total allocations and by directing substantial allocations to the Inverurie -Blackburn corridor and the Portlethen- Stonehaven corridor where over 50% of the current total established land supply in the Shire part of the AHMA is located.

Draft Response: Acceptance: Do not accept Changes to be made

Phasing within particular corridors is based on infrastructure constraints that will need to be resolved prior to significant levels of development taking place. An example of this is the limited numbers in the A90 (north) corridor until the AWPR, Balmedie to Tipperty dualling and Third Don Crossing are in place. It is also necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period.

Rep. Number

268 4 Subject Schedule 1 Summary The inclusion of Mintlaw in the Northern SGA would require an increase of total allocations in the Northern SGA.

The proposed development would have potential to create 1000 houses over a long term plan, so propose an increase in housing totals in this area of up to a 1000, spread through the 3 phases.

Draft Response: Acceptance: Noted Changes to be made

The distance of Mintlaw from the A90 corridor is too great to justify inclusion in the northern SGA; this is backed up by the recommendation of the Aberdeenshire Policy Team in their report to Buchan Area Committee, where it is not designated for 'growth to meet the structure plan strategy'. As part of the local development plan process, Aberdeenshire Council will have to consider the distribution of the significant allocation to the RHMA.

Rep. Number

269 5 Subject Schedule 1 Summary Concern that there are insufficient numbers allocated to the Drumlithie/Marykirk corridor.

The site at Edzell woods could accommodate 500 alone, feel an increase to 1000 would be more appropriate allowing growth in Laurencekirk as well as Edzell woods.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations to this corridor are already generous and have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

It will be for the local development plan to consider the scale of growth in Laurencekirk and Edzell Woods.

Rep. Number

278 6 Subject Schedule 1 Summary Figure of 4,700 units over 25 years is too low for local growth in the AHMA, comparing poorly with the 12,400 houses in the RHMA for the same period.

DSP has adopted an approach which is based on broad 'almost theoretical' principles. Although having the advantage of clarity it has the effect of over-simplifying the geographical reality of the area.

Draft Response: Acceptance: Do not accept Changes to be made

1,000 units of the Local Growth (AHMA) figure has been redistributed into the Aberdeen to Ellon SGA. The remaining figure of 3,700 must be spread amongst a small number of settlements, although this is a task for the local development plan to undertake. The plan will be subject to regular review.

14 January 2009 Page 99 of 244 278 12 Subject Schedule 1 Summary Housing allowances makes an artificial distinction in Aberdeen City between the Housing Allocations for Brownfield and Regeneration Areas.

Presumably most brownfield development will take place in the Regeneration Areas thereby reducing the contribution as it cannot be counted twice!

The Draft Brownfield Urban Capacity Study states that brownfield requirements can be met within the City. However this is an indicative assumption based on an essentially theoretical approach.

It goes onto say: "It therefore needs to be considered whether it is desirable to continue with historical levels of brownfield housing development , in particular the rates of development of the last 10 years. Many of the brownfield housing developments over the last 25 years have been on sites which had a non housing use. Of the 45 potential sites identified in this study, only around 3 were last in residential use. This has sustainability implications in respect of the mix [or lack of mix] of uses within the urban area." In the light of these reservations Barratt considers that less reliance should be placed upon the contribution from brownfield development with a commensurate increase in the City’s greenfield requirement.

Draft Response: Acceptance: Do not accept Changes to be made

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. This level is substantially lower than in previous years, when brownfield development represented between 60-90%. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result.

The Urban Capacity Study contained in the Background Paper provides the justification for the brownfield allowances until 2016. The allowances beyond 2016 will be reviewed in future strategic development plans in light of updated urban capacity information. Each of the three headings (greenfield, brownfield and regeneration) are distinct and separate and no double-counting is intended. The brownfield sites identified in the Background Paper are not found in the six community regeneration areas and other sites that come forward for redevelopment are also likely to be more central. 278 14 Subject Schedule 1 Summary No explanations for the Schedule 1 alternatives.

Westhill should be given a specific allocation of at least 1,200 dwellings over the Plan period with a corresponding reduction in the figure for the RHMA.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives were provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

No justification has been provided for this comment. However, the structure plan makes no specific allocation to any settlement in the Shire, this is the role of Aberdeenshire Council through its local development plan. 278 15 Subject Schedule 1 Summary Allocations for Inverurie- Blackburn should provide for 4000 houses as opposed to 1000 in the first phase to provide front-loading and early delivery of house-building targets; greater certainty for communities and the development industry, greater choice and it will also capitalise upon a multi-site approach using the wider range of opportunities provided by the three key settlements of Inverurie, Kintore and Blackburn.

A multi- site approach could also be used in the Stonehaven corridor, and would kick start the early delivery of house building tagets.

Draft Response: Acceptance: Do not accept Changes to be made

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire. The decision has been taken to promote the Aberdeen to Stonehaven corridor before the Inverurie corridor.

A 'multi-site approach' is an option for the corrridor, but the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process within the framework set down in the structure plan.

Rep. Number

14 January 2009 Page 100 of 244 281 3 Subject Schedule 1 Summary Propose that Portlethen be the main focus for development in the Stonehaven corridor as it represents the most sustainable long term strategic opportunity for development when compared with other settlements and the key considerations of SPP3 (para.56).

Draft Response: Acceptance: Partially accept Changes to be made

Portlethen is likely to be a key settlement on the A90 south SGA. However, this along with the scale of any development proposed and the identification of specific sites will be undertaken by Aberdeenshire Council as part of the local development plan process.

Rep. Number

282 9 Subject Schedule 1 Summary The figures do not match the 2007 HLA and it is not clear why figures for the City are missing altogether.

Draft Response: Acceptance: Noted Changes to be made

The effective and constrained figures in Schedule 1 are drawn from the 2007 HLA, but must be interpreted alongside the 'best guess' at which settlements are within SGAs and which are not. The figures will be updated using the 2008 HLA and taking account of work of the Policy Team of Aberdeenshire Council in establishing settlement strategies based on the spatial strategy framework. Figures for the City will be included in the final plan. 282 18 Subject Schedule 1 Summary Schedule 1 bears no relation to the HLA results outlined in the Councils own 2004 HNA.

Draft Response: Acceptance: Noted Changes to be made

There are many factors which influenced the allowances in Schedule 1. Housing need was one of these but so were infrastructure constraints and the need to ensure that the requirements were met in the most sustainable way possible.

Rep. Number

284 8 Subject Schedule 1 Summary It is worth noting that the numbers against the regeneration areas are not new, but replacement unless an increase in density occurs. This must be accounted for correctly in housing land audits, otherwise there will be a shortfall in the number of units that need to be provided in the period of the plan.

Draft Response: Acceptance: Do not accept Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest. 284 9 Subject Schedule 1 Summary The housing land audit should be changed. It should not only consider future allocations, but also review actual completions over the preceding two year period and compare these against figures indicated in the structure plan.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The HLA is a monitoring tool that has evolved over time in accord with PAN38 and in consultation with the development industry. Any further amendments to the process would have to be considered similarly. The structure plan makes it clear (on p.14 and p.17) that the HLA will be used in monitoring the targets in the plan and to inform any subsequent review. 284 11 Subject Schedule 1 Summary The 18,000 units for Aberdeen City will never be achieved bearing in mind it is nearly 2009. Would doubt the City will manage to allocate the full 36,000 units in the whole plan period.

Draft Response: Acceptance: Do not accept Changes to be made

Aberdeen City is currently covered by NEST and the Aberdeen City Local Plan (2008), which has recently released 795 units through supplementary planning guidance. The structure plan will inform the City local development plan that will replace the 2008 local plan. The figures for the first period shown in Schedule 1 are allocations only and do not have to be completed by 2016. The structure plan will be subject to regular reviews and this will give the opportunity to reconsider the scale of allocations, however, Aberdeen City Council are well aware of the amount of development proposed on brownfield and greenfield sites and are committed to its delivery. 14 January 2009 Page 101 of 244 284 12 Subject Schedule 1 Summary The Huntly to Pitcaple allocation should be at least 500 units in each period, with a total of 1,500 units overall.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire. 284 13 Subject Schedule 1 Summary The S. of Drumlithie to Marykirk allocation should be at least 600 units in each period, with a total of 1,800 units overall.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire. 284 15 Subject Schedule 1 Summary Reductions should take place in the Inverurie to Blackburn and Portlethen to Stonehaven corridors to allow for the increases elsewhere.

Draft Response: Acceptance: Do not accept Changes to be made

No justification is given for this statement. The cornerstone of the spatial strategy is to better utilise the existing A96 and A90 transport corridor and to develop in the most accessible locations where there is demand and capacity. To reduce the allocations as suggested would significantly negate the fundamental aims of the plan.

Rep. Number

286 69 Subject Schedule 1 Summary Propose that Schedule 1 should be revised. Main changes are increase in City G/F allocation by 2,500 over entire plan (with 2,500 taken from B/F in the City). Removal of 2,000 in the Inverurie to Blackburn corridor in the 2024-2030 period, to go to the Portlethen to Stonehaven corridor in the same period. Finally, removal of 4,000 from the local growth (RHMA) to go to the local growth (AHMA).

Draft Response: Acceptance: Do not accept Changes to be made

No particular justification has been provided for these revisions, which are presumed to be based on controlled land. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire. To make significant amendments to the numbers in the SGA's would jeopardise the delivery of some necessary projects.

Rep. Number

287 15 Subject Schedule 1 Summary Support the principle of RPA's as they can make a positive contribution and community focus. However, any replacement of existing stock should not be counted towards meeting overall housing requirement.

Draft Response: Acceptance: Do not accept Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

14 January 2009 Page 102 of 244 287 19 Subject Schedule 1 Summary In regeneration areas, only units provided over and above the number demolished can be counted. Thus, there is a requirement for an additional 5,000 units to be included in Schedule 1.

Draft Response: Acceptance: Do not accept Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

Rep. Number

289 8 Subject Schedule 1 Summary The majority of the surveys received by the Community Council rejected further development in both Blackburn and Fintray.

In the medium term there should either be minimal house building or none or at most minimum in Blackburn and Fintray.

A number of surveys preferred a new town so this would minimise development in towns where it is unwelcome.

Draft Response: Acceptance: Noted Changes to be made

The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. The phasing of development is dependent upon various factors, but primarily the removal of infrastructure constraints.

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. However, the allocations in Schedule 1 would only allow a new settlement in the corridors from Aberdeen to Inverurie or Aberdeen to Stonehaven.

Rep. Number

290 1 Subject Schedule 1 Summary Housing allocations have been grossly exaggerated.

Also strongly contest that the release of land in the green belt will sustain the north east economy.

The greenfield allocations are excessive and at odds with the local plan.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

It is acknowledged in the plan that a significant level of development will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped. Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

The structure plan precedes a replacement local development plan, which itself will have to comply with the approved structure plan.

14 January 2009 Page 103 of 244 290 5 Subject Schedule 1 Summary From 2006-2031 GROS predicts that 5,040 new houses will be required in the city and 32,820 in the shire.

The council predict 16,470 in the city rather which is a high increase. It can only be assumed that this is based on intention.

Even at the extreme limits of inward migration it is clear that nowhere near 72,000 additional homes will be required.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper. 290 7 Subject Schedule 1 Summary Concerns with the level of housing allocated for the period to 2016. The numbers in the city are clearly excessive of the GROS predictions and lower than required in the Shire. This could lead to serious housing shortages in the Shire during the period to 2016.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper. 290 8 Subject Schedule 1 Summary There is discrepancies between the Draft Structure Plan and the Aberdeen Local Plan.

The City local plan states that there is a requirement for 2,195 houses in total on greenfield land in comparison to the 12,000 set out in the Draft Structure Plan.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan precedes a replacement local development plan, which itself will have to comply with the approved structure plan.

Rep. Number

14 January 2009 Page 104 of 244 291 3 Subject Schedule 1 Summary Housing allocation V2 would be preferred.

Concerns that the Portlethen to Stonehaven corridor could be overdeveloped when taking into consideration the present and furture infrastructure.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process. The provision of new infrastructure will be critical to the delivery of development in the Aberdeen to Stonehaven corridor.

Rep. Number

295 4 Subject Schedule 1 Summary There are no models or figures apparent to justify the front loading of 12,000 houses on Green field sites from 2007 - 2016.

Draft Response: Acceptance: Do not accept Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

Rep. Number

296 1 Subject Schedule 1 Summary The capacity study carried out for the Portlethan corridor stated that it was not possible to accommodate 6,000 houses within the corridor.

Development would be opposed without significant improvements to infrastructure, including better rail links, crossing of the Dee, education provision etc.

Completion of the AWPR and fast link are essential.

Draft Response: Acceptance: Partially accept Changes to be made

The Portlethen capacity study has identified a number of different growth scenarios to inform future local development plans; this is in no way a definite statement of how the town will grow. The allocation on the Portlethen to Stonehaven corridor takes in a number of settlements and the possibility of a new settlement. However, it will be for the local development plan to determine exactly where development takes place and on what scale taking into consideration a range of factors, including infrastructure constraints.

Rep. Number

297 2 Subject Schedule 1 Summary The information in the draft plan is not sufficient to allow any decisions to be taken on the appropriateness of these allocations.

This is extremelly important given the potential impact on the greenbelt and and rural settlements .

Draft Response: Acceptance: Partially accept Changes to be made

The plan operates at the strategic level that does not require the allocation of numbers to individual settlements or specific areas of Aberdeen City. This flexibility leaves the Council's the ability to identify specific sites through the local development plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

14 January 2009 Page 105 of 244 297 24 Subject Schedule 1 Summary Concern that the housing forecasts are founded on flawed assumptions, are unrealistic and too high..

The 72,000 houses split between the city and shire is dangerously high and as such may destory the qualities that the plan seeks to promote.

The 72,000 houses is 40% higher than even the most wildly optimistic forecasts of what will be required.

The plan should be for 40,000 at most, with a proportion held in reserve, identified and ready to be brought forward if needed.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper. 297 25 Subject Schedule 1 Summary The 21,000 houses on greenfield sites in the city will reinforce the movement of people from the city to the shire which is what the plan is trying to avoid.

Draft Response: Acceptance: Do not accept Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan. There is no evidence that people will move to the Shire as a result, quite the opposite is anticipated. 297 26 Subject Schedule 1 Summary Have serious concerns that the housing numbers will be front loaded and not allow back tracking and that the developments will be begun and not finished.

Draft Response: Acceptance: Do not accept Changes to be made

There is an element of front-loading in Aberdeen City and the Stonehaven SGA. Despite the current economic difficulties the first period of the plan runs until 2016 and it is necessary to make an allowance that will provide for an improvement in the situation and attempt to satisfy any un-met demand. It is unlikely that developments will be begun and not finished, but these are usually commercial decisions by developers and outwith the scope of the structure plan.

14 January 2009 Page 106 of 244 297 34 Subject Schedule 1 Summary Uncertainty in the plan on numbers the final plan needs to be clearer.

The variations are not clear.

Draft Response: Acceptance: Partially accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan. 297 35 Subject Schedule 1 Summary Concerns with the grouping of settlements in the plan ie Portlethen - Stonehaven.

The general public, developers and landowners need certainty.

Draft Response: Acceptance: Partially accept Changes to be made

The groupings are based on the identified strategic growth areas and these represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services. They are then separated by the boundary between the Aberdeen and Rural Housing Market Area.

The plan does provide certainty as it allows Council Services and strategic infrastructure providers to forward plan, whilst giving developers the opportunity to submit bids for scrutiny by each Council.

Rep. Number

299 4 Subject Schedule 1 Summary No explanation has been provided on the alternative patterns.

Draft Response: Acceptance: Noted Changes to be made

The alternatives have been provided to demonstrate that a number of options and combinations exist and to stimulate debate. The alternatives will not feature in the final published plan.

14 January 2009 Page 107 of 244 299 5 Subject Schedule 1 Summary No explanation on the 72,000 houses.

No justification included for the sub division over various SGAs. Unhelpful not to have subdivision of numbers in the Portlethen/Stonehaven corridor.

Does not reflect community needs, ie ageing population.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

The groupings are based on the identified strategic growth areas and these represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services. They are then separated by the boundary between the Aberdeen and Rural Housing Market Area. Further subdivision is a task for Aberdeenshire Council through their local development plan.

Community expectations will be met through the sustainable mixed communities section. 299 11 Subject Schedule 1 Summary It should be pointed out that the 67000 houses in the Portlethen/Stonehaven corridor is equivalent to building 1½ times the size of Stonehaven at present.

This is not just an extension, but a radical revision of the geography of the area.

Draft Response: Acceptance: Do not accept Changes to be made

This is a gross exaggeration of what is proposed. The plan promotes 6,000 homes in the Portlethen to Stonehaven corridor over a 23 year period, this is subject to regular review through the development plan process.

It will be for the local development plan to determine exactly where development takes place and on what scale. 299 12 Subject Schedule 1 Summary No reason to assume that the constrained land will be unconstrained by 2031 and as such constrained land should be removed from the plan.

Draft Response: Acceptance: Do not accept Changes to be made

No assumption is being made about constrained land being developed. However, this is a source of land supply that has the potential to be developed and the two Councils, in line with SPP3, should seek to facilitate this.

14 January 2009 Page 108 of 244 299 13 Subject Schedule 1 Summary Housing targets for the City and Shire should be 47,110, the "probable" forecast target and figures reduced accordingly.

The figure of 72,000 is in excess of the high-end forecast (in 'Strategic Forecasts 2006' 2031) that has already been discounted by Aberdeenshire Council itself

The forecast has been generated to meet the alleged needs of the Development Plan.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper. 299 19 Subject Schedule 1 Summary Having arbitrary year breakdowns in the Structure Plan hinders the correct linkage to future Local Plans.

Should be seperated into 5-year, 10-year, 15-year and 20-year totals.

Draft Response: Acceptance: Do not accept Changes to be made

The breakdown of years in Schedule 1 is linked to the anticipated approval and adoption of subsequent strategic and local development plans. 299 32 Subject Schedule 1 Summary It would be better if values for the current situation were shown ie available brownfield land and existing housing numbers.

Draft Response: Acceptance: Do not accept Changes to be made

Information on available brownfield land is difficult to maintain due to the frequency at which sites become available and are developed. However, the Background Paper gives a 'snapshot' which makes it clear that further studies will have be undertaken in due course. Existing housing numbers are outlined in various forms in the annual housing land audit and schedule 1 shows the currently available supply.

Rep. Number

303 2 Subject Schedule 1 Summary Building 72,000 new houses will not maintain and improve the quality of life.

The housing boom in Kintore has seen a significant reduction in public open space and the non provision of community facilities both of which have caused a deterioration in quality of life. This issue is apparent elsewhere too.

Draft Response: Acceptance: Partially accept Changes to be made

The plan promotes sustainable growth as a basic principle. The location and quality of this growth will determine whether an improvement in quality of life emerges, but this is a strategic level document that aims to provide a framework for lower tier plans and supplementary planning guidance.

Capacity studies may be used and masterplans produced for use at the settlement and large site level to try and ensure that the situation outlined above is not repeated.

Rep. Number

14 January 2009 Page 109 of 244 307 5 Subject Schedule 1 Summary Schedule 1 not easy to understand or challenge.

The shire figures seem higher than the city and do not appear to equate to a 50/50 split.

Given the credit crunch scale and timing will need to be revised.

Draft Response: Acceptance: Do not accept Changes to be made

It is important that Schedule 1 contains all necessary information for the production of local development plans. Whilst this may appear cumbersome, there is a high degree of logic to the separations of the SGAs and phasing contained therein.

The figures for each Council area equate to approximately 50% of the total allocation.

Given that this is a plan over the medium / long-term, it is not intended to reduce the scale of allocations or phasing as indications are that the economic situation will recover sufficiently by 2010. It must also be noted that the figures shown are allocations and need not all be built by 2016. Subsequent reviews of the plan will consider this further.

Rep. Number

314 7 Subject Schedule 1 Summary Proposal should include the Donald Trump championship golfcourse and the numbers in the schedule should reflect this.

Draft Response: Acceptance: Partially accept Changes to be made

The decision was made on 16 December 2008 by Scottish Ministers to grant outline planning permission subject to conditions and conclusion of a planning agreement for this proposal. The conditions include phasing conditions which preclude new homes until Phase 1 is complete and limits new housing development until the Balmedie to Tipperty dualling is complete.

This means that 500 new homes are now likely to be built in this corridor. These new homes were not accounted for in the effective land supply on the base date of the plan, so will need to be set against the allowance for the first two plan periods. This phasing between the first and second plan period should reflect the progress expected to be made on site and will allow the allocation of other sites through the local development plan.

Rep. Number

320 3 Subject Schedule 1 Summary The scale of housing being proposed is exceptionally high reflecting, as it does, the very ambitious economic and population growth targets assumed throughout the document.

Draft Response: Acceptance: Partially accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

Rep. Number

14 January 2009 Page 110 of 244 321 8 Subject Schedule 1 Summary It should be emphasised that should the Menie development be given the go-ahead, the current allocation up to 2016 will be used up by that application alone, thus ensuring that no other developments will take place during the period to 2016.

This would have an extremely detrimental effect on the economic growth of Ellon and the surrounding area and would not reflect the aspirations of the Aberdeen City and Shire Plan.

Draft Response: Acceptance: Do not accept Changes to be made

The decision was made on 16 December 2008 by Scottish Ministers to grant outline planning permission subject to conditions and a planning agreement for this proposal. The conditions include phasing conditions which preclude new homes until Phase 1 is complete and limits new housing development until the Balmedie to Tipperty dualling is complete.

This means that 500 new homes are now likely to be built in this corridor. These new homes were not accounted for in the effective land supply on the base date of the plan, so will need to be set against the allowance for the first two plan periods. This phasing between the first and second plan period should reflect the progress expected to be made on site and will allow the allocation of other sites through the local development plan.

As a result of this decision and other factors, an increase of 1,000 units in the Blackdog to Ellon corridor is proposed, taking the total allocation to 3,400 units. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects.

Rep. Number

327 1 Subject Schedule 1 Summary The Housing Allowances for Stonehaven/Portlethen as outlined in Schedule 1 and illustrated on the Key Diagram seem excessive. Particular concerned at any possible large housing allocation for Stonehaven which in our opinion would have an adverse effect on the town. Despite the reassurances of this Plan that development would be controlled by phased infrastructure provision, we fear that this simply will just not happen.

Draft Response: Acceptance: Do not accept Changes to be made

The allocation on the Portlethen to Stonehaven corridor takes in a number of settlements and the possibility of a new settlement. However, it will be for the local development plan to determine exactly where development takes place and on what scale taking into consideration a range of factors, including landscape setting, infrastructure constraints etc.

Rep. Number

344 2 Subject Schedule 1 Summary There has been criticism of the projected population figures for Stonehaven and I appreciate that with a mobile population in this area and the influx [and sometimes loss] of migrant workers this can never be an exact science. Communities need growth but the general opinion in Stonehaven is that with the houses built at Glenury and those planned fro the Ury estate the town needs a break from large scale development. The total of 6000 houses by 2030 in the Portlethen - Stonehaven corridor is seen as excessive. A new town has been mentioned but the consensus seems to be that Stonehaven [and the views from it] can be easily spoiled by over development. Views have also been expressed that housing should be targeted on communities where it is welcome e.g. Ellon and the Buchan area.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

The structure plan does not commit Stonehaven to any development as it is the task of the local development plan (LDP) to consider the location and scale of proposals in specific towns. The LDP will be subject to significant consultation throughout 2009.

Rep. Number

345 1 Subject Schedule 1 Summary Laurencekirk should be included in the Aberdeen Housing Market Area. The Railway station will be opened next year with a journey time to and from Aberdeen of approximately 35 minutes. The housing allocation for Laurencekirk should be substantially increased as a consequence. The proposed housing allocation for Stonehaven should be reduced by the number allocated to Laurencekirk.

Draft Response: Acceptance: Do not accept Changes to be made

In 2006, Aberdeen City and Aberdeenshire Councils jointly commissioned DTZ Consulting and Research to undertake a review of housing market areas. The review found some evidence to support the extension of the existing Aberdeen Housing Market Area (HMA) boundary however it was felt that the scale of change proposed did not warrant a change of Housing Market boundary for this Structure Plan. The first Strategic Development Plan will provide an opportunity to revaluate this position.

The allocation to this corridor is already generous, but will be subject to regular review.

14 January 2009 Page 111 of 244 Rep. Number

348 1 Subject Schedule 1 Summary I believe that we are allocating too many houses to greenbelt on the Aberdeen City side. I would like to see better use of brownfield sites/poor quality flatted housing areas to create terraced cottages etc to bring families into the city.

Draft Response: Acceptance: Partially accept Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The Urban Capacity Study contained in the Background Paper provides the justification for the brownfield allowances until 2016. The allowances beyond 2016 will be reviewed in future strategic development plans in light of updated urban capacity information. 348 2 Subject Schedule 1 Summary I would like to see a small number of houses being placed round Peteculter but would emphasis that I would not support any attempt to bring in urban sprawl type developments which would be deterimental to the village character.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

It will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

349 16 Subject Schedule 1 Summary The Group supports local growth and diversification in our rural communities and will seek to promote sustainable development in the country side which will secure the long term sustainability of those rural communities. It is important that this must not be perceived as a token gesture, but must be implemented effectively as the most suitable development vehicle for the specialisation needs of such communities. To adequately cater for such growth we would seek to increase the RHMA allowance by a further 300 units in the 2017 -2023 period.

Draft Response: Acceptance: Do not accept Changes to be made

The plan seeks to provide a balance between the provision of sufficient development over the plan period for local growth in the RHMA and ensuring that over-allocation leading to constrained sites does not occur. It is felt that the allocations are generous, however, given the need to review the plan regularly and replace it with a strategic development plan is due course, there will be every opportunity to reconsider the allocations once experiences from the local development plan process have been considered.

Rep. Number

350 5 Subject Schedule 1 Summary A Structure Plan must be fair and equitable in allocating development across Aberdeenshire, this one is not.

Draft Response: Acceptance: Do not accept Changes to be made

The role of a structure plan is to set a clear direction for future development; this requires consideration of a very wide range of issues and decisions to be taken on the most appropriate framework based on balancing economic, social and environmental needs. The spatial strategy has been devised following extensive consultation and the basic principles on which it is based shall remain. The split of 50% of development in Aberdeen, 25% in Shire SGAs and 25% in the remaining Shire area is seen as equitable.

Rep. Number

14 January 2009 Page 112 of 244 358 2 Subject Schedule 1 Summary Welcomed absence of any specific reference to Alford.

Concern raised that Alford should not fall into the Local Growth category as it is not suited for further growth due to current level of saturation of housing resulting in imposing strains on schools, transport, roads and social cohesion.

Particular concern was raised that Alford should not be expanded to the south-east due to the effect it would have on the landscape, setting and on Balfluig Castle which is A Listed.

Draft Response: Acceptance: Noted Changes to be made

Alford lies in the LG&DA (RHMA). This area is not designated for strategic growth, but may still experience growth in line with the spatial strategy. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on social, economic and environmental criteria and infrastructure requirements taking full account of local need.

Rep. Number

361 5 Subject Schedule 1 Summary The table in its published form is relatively meaningless without associated text.

With few exceptions, the two alternatives appear very similar.

Draft Response: Acceptance: Do not accept Changes to be made

It is important that Schedule 1 contains all necessary information for the production of local development plans and must be read in conjunction with the explanation of the spatial strategy on p.6-8 of the plan.

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

369 1 Subject Schedule 1 Summary Object to the large amount of houses in the Pitcaple to Huntly corridor (1000 in the planning period).

This amount of houses is directly in conflict with one of the targets in the Accessibility chapter "To reduce the percentage of journeys which are made by car".

As the only realistic employment area is Aberdeen/Dyce, building this amount of houses will lead to commuting which is not sustainable especially as there is sufficient building land available closer to Aberdeen.

There is not a sufficient frequency or level of public transport servicing this corridor on the rail network. The number of trains will not be able to be sufficiently increased given that it is single track therefore it does not present a viable alternative for car users.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

The developments proposed, particularly in the strategic growth areas, are intended to be mixed use and promote a much higher proportion of employment land than previously delivered. This, along with additional opportunities in the local growth areas, should help to reduce commuting into Aberdeen.

The SGA's represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services. These services will be subject to improvement where necessary through the work of Nestrans and Aberdeenshire Council in partnership with transport providers. Significant rail service improvements on the route between Aberdeen and Inverness which will increase capacity and the attractiveness of rail travel.

Rep. Number

14 January 2009 Page 113 of 244 374 3 Subject Schedule 1 Summary With reference to Kinellar School and Kemnay Academy being overcrowded and in need of replacement and the slow progression in relation to the reopening of Kintore Station the respondant did not agree with the housing proposals for Inverurie-Blackburn unless, and until, adequate facilities and infrastructure is in place to cope with existing developments.

New housing developments should not proceed unless there are plans to provide a good standard of accommodation for new pupils.

Draft Response: Acceptance: Partially accept Changes to be made

A justification for the overall figure the plan promotes is to be found in the Background Paper. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

It is therefore intended that, more than ever before, the provision of development, infrastructure and community facilities are better managed.

Rep. Number

375 1 Subject Schedule 1 Summary Housing allocation of 72,000 is excessive. Aiming for 72,000 is aiming for an unprecedented change in the scale of development in the region. Suggestion that 50,000 is more appropriate.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper. 375 8 Subject Schedule 1 Summary Suggestion that the way Schedule 1 is detailed (against towns or settlements) will cause upset and unsettle the public. For example stating Inverurie - Blackburn does not indicate where houses will be developed within the area. Additionally no certainty is given when two alternatives are provided which vary significantly.

Draft Response: Acceptance: Partially accept Changes to be made

The plan operates at the strategic level, where the role of individual settlements is not explored and level of growth is not imposed. This leaves Aberdeenshire Council the flexibility to determine allocations on a case-by-case basis through the local development plan process. The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

380 3 Subject Schedule 1 Summary Developments should be in proportion to the communities to which they are added.

Example given of 1000 houses allocated to the Pitcaple to Huntly 'corridor'. This is a rural area with settlements of limited size and any new developments should respect the size of the existing settlement to which they add to prevent swamping communities and negatively impacting the nature of the settlements.

Draft Response: Acceptance: Do not accept Changes to be made

Consideration has been given to where there is need and demand for development. This corridor has good rail connections. The location of development within this corridor will be carefully considered by the Local Development Plan team and subject to consultation.

Rep. Number

14 January 2009 Page 114 of 244 381 1 Subject Schedule 1 Summary Referred to the inclusion of Pitcaple/Whiteford in the Huntly-Pitcaple SGA with the suggestion of 500 houses over the next 23 years.

This is an astounding number given the size and character of the area.

Total opposition to a scheme of this magnitude. Any additional housing there should be much smaller, allocated perhaps, on a scale proportional to the sizes of Huntly, Insch and Pitcaple.

Do not wish to see the area turned into a disaster like Westhill or Kingswells.

Draft Response: Acceptance: Noted Changes to be made

The proposal for 500 houses in the Pitcaple / Whiteford area is one of many individual projects of which we have been made aware. The structure plan does not promote development at Whiteford, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A96 corridor in which Whiteford lies (from Pitcaple to Huntly) is allocated 1,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

382 6 Subject Schedule 1 Summary Schedule 1 contains figures indicating new houses to be built in stages until 2030.

No alternative figures reflecting a low or probable forecast are given. Instead, the planning team has made the 'high scenario‘ forecast its 'vision' and has written the Draft Structure Plan towards this vision with no consideration for possible alternatives.

Draft Response: Acceptance: Partially accept Changes to be made

The phases indicated in Schedule 1 are designed to fit with probable approval and adoption of strategic and local development plans.

The decision to pursue the high growth scenario was made following extensive consultation and debate and matches the aspirations of both Council's for the north east. It should be noted that the structure plan will be subject to regular reviews to ensure it is consistent with economic and social changes that may affect the strategy. 382 7 Subject Schedule 1 Summary Particular concern was raised about the target of 6,000 new houses in the 'Portlethen-Stonehaven' area.

Portlethen and Stonehaven are separate communities with Newtonhill and as equally separate communities located between them.

Any numbers reflecting the anticipated need of new houses should therefore be specified for Portlethen, Newtonhill, Muchalls and Stonehaven separately. In addition, a low and probable population growth forecast should be taken into account.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The plan does not make allocations to specific settlements, this is a task for the Aberdeenshire local development plan.

Rep. Number

14 January 2009 Page 115 of 244 387 4 Subject Schedule 1 Summary Queried why the Portlethen/Stonehaven area requires such a high proportion of housing?

Queried whether the proportion of housing fits in with the quote on page 6 "The strategy also recognises the need to maintain and improve the area's communities and the services they depend on". Expressed fear that Stonehaven will become a dormatory town with no heart and no community.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The plan does not make allocations to specific settlements, this is a task for the Aberdeenshire local development plan.

Rep. Number

388 3 Subject Schedule 1 Summary Portlethen-Stonehaven, Given the unrealistic 9% growth scenario, the growth of 6,000 houses proposed for the corridor up to 2030 is also unrealistic.

There is no indication of how the 'Alternatives' of 13,500 and 8,000 were reached, but these numbers are extremely alarming, and way beyond the capacity of these Coastal communities to grow without having a very adverse effect on the Quality of the Environment (Page 15).

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The plan does not make allocations to specific settlements, this is a task for the Aberdeenshire local development plan.

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

389 1 Subject Schedule 1 Summary No clear explanation where the figure of 72000 houses comes from.

Draft Response: Acceptance: Noted Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward, it is recognised that there is a significant unmet demand for housing

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

14 January 2009 Page 116 of 244 389 3 Subject Schedule 1 Summary How was 6000 houses for the Portlethen to Stonehaven corridor arrived at? Are any of the proposed house expansions for that area included?

There is no visible explanation of over how many years this will take. Very important to confirm how long.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

Existing allocations are not a part of this plan and these numbers are over and above any current sites. The plan is concerned with the allocation of numbers to corridors, which the local development plan will take forward to sites in the defined periods. The speed with which these sites are developed will be largely determined by the private sector.

The figure of 600 is over the period to 2030.

Rep. Number

391 1 Subject Schedule 1 Summary 6000 houses suggested for Stonehaven does not compute with recent population forecasts for Scotland or this area. If 6000 houses were to be built then additional public services would be required ie primary schools and additional secondary schools and where are they on the plan?

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The plan makes it very clear that new schools will be required; the location of these will depend on the sites chosen through the local development plan process.

Rep. Number

397 4 Subject Schedule 1 Summary The Table on page 22 is disconnected from the rest of the draft, i.e. there appears to be no explanatory text leading up to it.

While placing 50% of the growth in Aberdeen City seems at first sight reasonable, it would be useful to know the reasoning - or is this an arbitrary split simply for an appearance of equitability?

Suggests that a structure plan should not prescribe numerical allocations at the level of individual settlements. If it must, then an indication of the reasoning is needed for understanding. For example, is the "v2" allocation of 10,000 to Inverurie / Blackburn based on the assumption that a new town will be created near Blackburn? Such information would affect the acceptability, or otherwise, of that alternative.

Draft Response: Acceptance: Do not accept Changes to be made

Schedule 1 attempts to convey a great deal of information in as succinct a form as possible. It is linked to the spatial strategy, which is explained in detail on p.6-8.

In 2007 the split of households between Aberdeen City and was 50.5% and 49.5%, while in terms of dwellings the figures were 50.9% and 49.1%. The background research for the plan clearly established that development in or close to Aberdeen had significant benefits. In light of these factors, a split of new developments around the 50/50 level was deemed appropriate as a basis for the structure plan

It is not the role of this structure plan to determine allocations at the settlement level, this is a decision for Aberdeenshire Council during preparation of its local development plan. The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

14 January 2009 Page 117 of 244 408 1 Subject Schedule 1 Summary Housing allowance of 6000 houses for the Stonehaven/Portlethen area is unrealistic considering the constraints imposed by the topography and scenic landscape quality.

Should be separate allowances for Stonehaven and Portlethen in order to judge the impact of the 6000 allowance and enable debate of issues such as topographical constraints, education capacity and other key issues. Uncertainty of between 1000 to 5000 houses denies the community the opportunity to argue its case.

No account appears to have been taken with regards to various Public Inquiry conclusions between 1996 and 2006 regarding areas of Stonehaven that should not have large-scale housing.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process. This will provide the opportunity for wide public debate as desired.

The plan operates at the strategic level, where the role of individual settlements is not explored and level of growth is not imposed. This leaves Aberdeenshire Council the flexibility to determine allocations on a case-by-case basis through the local development plan process.

This plan and the local development plan, which will allocate specific sites is an opportunity to revisit settlements and reconsider if they should grow and how best this may happen in light of the most recent information. For Stonehaven, this may be publication of the Capacity Study, improved accessibility by rail or as a result of the AWPR, the desire for some development to bring about new infrastructure or consideration of developer bids that the Council will have to respond to.

Rep. Number

422 17 Subject Schedule 1 Summary The housing allowances for Portlethen - Stonehaven in the periods 2007-2016 and 2017-2023 are higher than for any other single area outside Aberdeen City.

This corridor has suffered considerable growth in recent years, with very little infrastructure improvement. The A90 is already extremely busy at rush hour times and the trains often have standing room only. Stonehaven's leisure facilities and schools have scarcely changed in the last 10 years, and the unique character and setting of the town will be destroyed by any significant growth. The clear solution, IF the population growth forecasts are correct, is to build a new town, rather than destroy existing communities. How was the allowance of 2,600 houses over the next eight years determined?

Draft Response: Acceptance: Noted Changes to be made

The allocation on the Portlethen to Stonehaven corridor takes in a number of settlements and the possibility of a new settlement. However, it will be for the local development plan to determine exactly where development takes place and on what scale taking into consideration a range of factors, including landscape setting, infrastructure constraints etc.

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

Rep. Number

423 2 Subject Schedule 1 Summary Housing requirement is massive and the housing allocation of 6,000 for the 'corridor' between Aberdeen and Stonehaven is almost impossible to conceive.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

The plan does not make allocations to specific settlements, this is a task for the Aberdeenshire local development plan.

Rep. Number

424 9 Subject Schedule 1 Summary The housing allowance is extremely hard to understand. It would be more effective to the public if "pie charts" were provided illustrating the housing figures as well as the percentage mentioned in the text for Shire and the City.

Draft Response: Acceptance: Do not accept Changes to be made

Fail to see how pie charts would aid understanding or comprehension as these would not adopt the conventional approach of rows and columns that one would expect when dealing with a substantial amount of data.

14 January 2009 Page 118 of 244 Rep. Number

426 5 Subject Schedule 1 Summary All depends on what the economy does and the choices made by developers. Why not front load it all?

Draft Response: Acceptance: Partially accept Changes to be made

The economy is clealry a major factor in the success of the north east and a driver of development of all types. The development industry has expressed a confidence in the medium term that this plan aims to continue to reflect. Front-loading all allocations would not be sensible as it would not allow for the provision of essential facilities and infrastructure and would spread development too thinly.

Rep. Number

428 1 Subject Schedule 1 Summary Question the appropriateness of establishing an increase in the region's population as a policy objective in its own right and linked to this the need for around 72,000 new dwellings in the region. There is a distinct danger of over-developing the region and making it less appealing to those that already live here. In particular, enormously concerned about the implications for the green belt and unique setting it provides for the City. The total number of dwellings should be scaled back to the levels achieved in the past 10-15 years, this would produce a need for about 35-40,000 over the plan period.

Draft Response: Acceptance: Do not accept Changes to be made

Population growth is a challenge that must be met to ensure prosperity of the city region over the plan period. A growing and balanced population is key, underpinning economic growth and ensuring that quality of life is maintained/improved. Without a viable population both public and private services suffer, leading to a decline in quality of life.

The targets for new housing reflect both the Councils projections and the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland. Further information is provided in the Background Paper. The housing need and demand assessment is currently underway but will impact more fully on the first Strategic Development Plan.

It is recognised that the area must maintain the regions natural and cultural asset, which is why development must be of exceptional quality, helping to make Aberdeen City and Shire an excellent place to live, visit and do business.

The green belt will be reviewed to accommodate the levels of growth anticipated in the plan. The review needs to be carried to ensure that the greenbelt is effective and meets today’s needs. 428 3 Subject Schedule 1 Summary Object to the two different scenarios in Schedule 1 as this prevents users from having any clear idea as to the likely scale of proposed development, thus rendering it of limited value. There is nothing to explain this approach, or whether it will carry forward to the final document. Is there a link to Capacity Studies being under taken in the Shire? In current form the plan provides no certainty to developers, land owners and the community.

Draft Response: Acceptance: Partially accept Changes to be made

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan. The Capacity Studies have not informed this plan, they are intended to be used by Aberdeenshire Council when considering the ability of settlements to grow and the selection of specific sites for development, open space, community facilities etc. The plan provides an appropriate degree of certainty in terms of the broad scale of allocations to allow infrastructure providers and developers to plan ahead. The community can also take some information from the plan, but this plan should not go beyond the detail shown, instead this should be determined solely by Aberdeenshire Council in consultation with stakeholders.

Rep. Number

430 1 Subject Schedule 1 Summary Unable to comprehend how it is suggested that 6,000 new houses can go in the Stonehaven / Portlethen corridor when the infrastructure cannot cope at present with the current level of population. Also, there seems to be a 6% difference in the projected growth figures and given the credit crunch, will the plan be revised?

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The structure plan covers the period to 2030. It is not just a plan for the next few years.

Rep. Number

14 January 2009 Page 119 of 244 434 1 Subject Schedule 1 Summary Question the appropriateness of establishing an increase in the region's population as a policy objective in its own right and linked to this the need for around 72,000 new dwellings in the region. There is a distinct danger of over-developing the region and making it less appealing to those that already live here. In particular, enormously concerned about the implications for the green belt and unique setting it provides for the City. The total number of dwellings should be scaled back to the levels achieved in the past 10-15 years, this would produce a need for about 35-40,000 over the plan period.

Draft Response: Acceptance: Do not accept Changes to be made

Population growth is a challenge that must be met to ensure prosperity of the city region over the plan period. A growing and balanced population is key, underpinning economic growth and ensuring that quality of life is maintained/improved. Without a viable population both public and private services suffer, leading to a decline in quality of life.

The targets for new housing reflect both the Councils projections and the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland. Further information is provided in the Background Paper. The housing need and demand assessment is currently underway but will impact more fully on the first Strategic Development Plan.

It is recognised that the area must maintain the regions natural and cultural asset, which is why development must be of exceptional quality, helping to make Aberdeen City and Shire an excellent place to live, visit and do business.

The green belt will be reviewed to accommodate the levels of growth anticipated in the plan. The review needs to be carried to ensure that the greenbelt is effective and meets today’s needs.

Rep. Number

435 1 Subject Schedule 1 Summary Have serious concerns over discrepencies in population growth forecasts which seem to be the basis for the number of houses proposed in the plan. If 6,000 homes is based on a 9% forecast then what is the basis for the alternatives? 9% is based on a high growth scenario in the strategic forecasts, whereas 3.1% is quoted as being the most likely scenario and 9% as extremely unlikely. For a long term plan it would be more sensible and realistic to use the base figure. Therefore there is huge difference between 6,000 and 2,000 houses.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan is not trying to achieve the" likely" but the "high growth" scenario being predicated on growth. Even if the plan was based on 3% growth this would not necessarily be translated into reductions in new housing across all areas as suggested.

Rep. Number

436 1 Subject Schedule 1 Summary Opposes the 6,000 new homes in the Stonehaven Corridor and believes that Stonehaven's infrastructure has been 'overstretched'. Also believes that the development would 'destroy the town's dynamics', surrounding countryside and tourist attractions and that Health, Education and Social Services will be put under pressure with the new housing developments.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored through the local development plan process.

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The plan does not make allocations to specific settlements, this is a task for the Aberdeenshire local development plan.

Rep. Number

437 3 Subject Schedule 1 Summary Has the population growth from Ury House development been taken into consideration?

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The structure plan does not deal with the allocation of individual sites. However, Ury House was not in the effective supply on 1 Jan 2007, so does not appear in column 1 and Schedule 1. As such, it could reasonably be expected to be counted against the relevant allowance in Schedule 1 for the period 2007-2016 since it now has consent.

14 January 2009 Page 120 of 244 437 4 Subject Schedule 1 Summary Does Dunnottar Visitor Centre really need 6,000 houses to support it?

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The structure plan does not promote development at Stonehaven, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A90 corridor in which Stonehaven lies is allocated 6,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale. 437 7 Subject Schedule 1 Summary Stonehaven will not sustain with 6,000 more houses. Will become overcrowded.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The structure plan does not promote development at Stonehaven, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The A90 corridor in which Stonehaven lies is allocated 6,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

441 4 Subject Schedule 1 Summary The selected locations should be determined by reference to: land resources, location of commercial activities and employment, availability of transport and resident preferences.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the local development plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

442 1 Subject Schedule 1 Summary It is not acceptable to suggest 6,000 houses between Portlethen and Stonehaven; this should be reconsidered. In particular, East Newtonleys should be avoided.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for each corridor have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. In addition, bids submitted to Aberdeenshire Council demonstrate that there is demand for development here and a number of different scenarios for how this could be delivered can be explored. through the local development plan process.

Specific allocations are phased, in part, to account for the provision of key infrastrcuture to enable development to proceed. This particularly relates to secondary school provision and the need to phase provision of new schools across Aberdeenshire.

The plan does not make allocations to specific settlements and the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

443 6 Subject Schedule 1 Summary Strongly object to very poorly presented data in Schedule 1. This table is not adequately explained anywhere in the document, nor is the basis for the alternatives. It also gives no idea of the proposed development for major settlements and as this will impact on requirements for additional infrastructure this needs to be specified more precisely.

Draft Response: Acceptance: Do not accept Changes to be made

Schedule 1 attempts to convey a great deal of information in as succinct a form as possible. It is linked to the spatial strategy, which is explained in detail on p.6-8.

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan. It is not the role of this structure plan to determine allocations at the settlement level, this is a decision for Aberdeenshire Council during preparation of its local development plan.

Rep. Number

14 January 2009 Page 121 of 244 449 4 Subject Schedule 1 Summary Doubt if enough housing is being planned and feel there is now a growing need for smaller houses, especially for older people who want to leave a large house, but do not want to live in a flat.

Draft Response: Acceptance: Partially accept Changes to be made

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030. The section on sustainable mixed communities states that new housing has to meet the needs of the whole community in terms of provision of affordable housing as well as the mix of types and sizes built.

Rep. Number

452 17 Subject Schedule 1 Summary Suggest further explanation of V1&2 in the table on page 22.

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

458 17 Subject Schedule 1 Summary No alternatives shown for the allocation for half the planned growth within Aberdeen City (36,000).

Not sure that this number is deliverable even when using brownfield and regeneration areas it is implied that much of this development will spill onto Green Belt. Allocations for green field land are front-loaded in the period 2007-2016 (12,000) seems unrealistic giving extensive planning and consultation required (pressure compounded by slowdown of house building industry).

Draft Response: Acceptance: Do not accept Changes to be made

The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate on Shire numbers, which they have done. No alternatives will appear in the final plan.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan. Aberdeen City Council is committed to delivery of its proportion of the allocations and it must be noted that for each plan period, these are allocations and housing need not necessarily be built by the final year stated. 458 18 Subject Schedule 1 Summary Study has been conducted by the foundation, 'Imagine Ellon' plan for the sustainable growth and restructuring of the town - new academy, additional employment and retail space and more than 400 homes by 2016.

Draft Response: Acceptance: Noted Changes to be made

An increase of 1,000 units in the Blackdog to Ellon corridor is proposed, taking the total allocation to 3,400 units. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects. However, it will be for the local development plan to consider the scale of growth in Ellon. 458 19 Subject Schedule 1 Summary If the Menie application is successful recommend that the additional homes be considered exceptional and extra to houses in the plan.

Draft Response: Acceptance: Do not accept Changes to be made

The decision was made on 16 December 2008 by Scottish Ministers to grant outline planning permission subject to conditions and conclusion of a planning agreement for this proposal. The conditions include phasing conditions which preclude new homes until Phase 1 is complete and limits new housing development until the Balmedie to Tipperty dualling is complete.

This means that 500 new homes are now likely to be built in this corridor. These new homes were not accounted for in the effective land supply on the base date of the plan, so will need to be set against the allowance for the first two plan periods. This phasing between the first and second plan period should reflect the progress expected to be made on site and will allow the allocation of other sites through the local development plan.

Rep. Number

14 January 2009 Page 122 of 244 460 2 Subject Schedule 1 Summary Object to scale of housing proposed by the plan. (21,000 new houses in 'Aberdeen Greenfield' between 2007-2030. Impacts upon loss of greenbelt, unique setting of Aberdeen, erosion of the identities of communities such as Cults, Peterculter and Kingswells and lack or recreation space.

Draft Response: Acceptance: Do not accept Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

Rep. Number

464 1 Subject Schedule 1 Summary Response is in the form of a committee report and highlights concern regarding:

Para. 4.10 - The level of housing development in Laurencekirk, particularly in the initial period of the plan and the potential for further safety issues with the A90 / A937 junction south of Laurencekirk. Additional clarification is needed on the amount of business land to be released in the settlement.

Draft Response: Acceptance: Partially accept Changes to be made

The A90 south (RHMA) corridor is proposed to accommodate 500 units in the first period and 500 in the two later periods. The settlements outwith the SGA will also be considered for development in line with the spatial strategy. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. The junction of the A90 / A937 is recognised as a significant safety issue and a determination will have to be made if / how this specific intervention can be progressed. The amount of business land allocated to this area will also be determined through the LDP based on distribution of the overall figure on p.10 of the plan.

Rep. Number

465 4 Subject Schedule 1 Summary Whilst the plan does not explain where housing figures come from, we are content with the workings and figures of the chart on p.13. The plan appears to be based on the high case population and household figures, but they are somewhat higher and the workings for this are not shown.

We found Schedule 1 on p.22 difficult to interpret , it would be helpful if it explained how the figures were derived and what the rows and columns mean. There is a question on the relationship to housebuilding targets included on p.13 and further explanation of the two 'alternatives' columns is needed.

Draft Response: Acceptance: Do not accept Changes to be made

The average rate of new house completions in Aberdeen and Aberdeenshire over recent years has been approximately 2,200 per annum. If this were to continue over the nest 24 years to 2030, this would represent an additional 52,800 homes. However, this plan is seeking to achieve economic and population growth over this period as well as a significant improvement in the quality of new development. In order to facilitate this, additional land needs to be identified.

The headline figure of 72,000 has been decided upon as a result of selection of the high demographic forecast as the preferred option for the region, taking the population to over 480,000 by 2030.

When account is taken of a range of factors, including vacant and second homes and demolitions, the ‘housing requirement’ published in the forecasts for the high population scenario was 59,000 over the period. In addition to this scale of development an allowance is required for the fact that not all identified sites will come forward.

However, the annual targets for new housing also reflect the desire of the Scottish Government in ‘Firm Foundations’ to increase levels of housebuilding to 35,000 per annum across Scotland (a 40% increase). Further information is provided in the Background Paper.

Schedule 1 attempts to convey a great deal of information in as succinct a form as possible. It is linked to the spatial strategy, which is explained in detail on p.6-8. The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

14 January 2009 Page 123 of 244 141 17 Subject Spatial Strategy Summary New settlements sound like a solution to an immediate problem but will not solve the bigger challenge in the future.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. There is an argument that a new town would mitigate some of the impacts of incremental growth of established towns and villages, by planning several thousand homes and all the services and facilities they need from scratch.

Rep. Number

184 8 Subject Spatial Strategy Summary Recognise the reasoning behind Strategic Growth Areas but feel the settlements around the city should have also been considered.

Draft Response: Acceptance: Do not accept Changes to be made

The SGA's represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services. Settlements such as Newmachar are limited under these criteria and do not have a strategic role in any sense. However, Newmachar will have the chance to bid for a proportion of the LG&D (AHMA) allocation, although this will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

188 3 Subject Spatial Strategy Summary Understandable that it seeks to make use of existing public transport networks. Concern that the cross rail project will not proceed as it no longer appears to be supported by Transport Scotland.

Draft Response: Acceptance: Accepted Changes to be made

Support for this aspect of the plan is welcomed. Whilst the plans refers to Crossrail and identifies proposed stations on the key diagram, the ultimate decision on this project is not a structure plan issue; but one that it will need to reflect. The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service. 188 4 Subject Spatial Strategy Summary Remaining settlements in the AHMA have proved attractive and sustainable communities in which people live and invest.

Further development in these areas could be focused on significantly enhancing the provision of existing public transport rather than ignoring areas where difficulty has arisen.

Draft Response: Acceptance: Partially accept Changes to be made

A significant number of settlements will fall outside SGA's and these have received 20-25% of the entire structure plan allocation for housing and an unspecified amount of employment land. Further development will occur in many of these places to meet local need. The improvement of public transport is naturally desirable, but simply allocating houses is not sufficient to bring about enhanced services; this is a task for other Council services in conjunction with bus operators. 188 5 Subject Spatial Strategy Summary The overall housing allocation should be increased with a higher proportion allocated to the AHMA and in particular the Local Growth Areas.

Draft Response: Acceptance: Do not accept Changes to be made

The overall housing allocation is already generous and based on a high growth scenario. An increase in the AHMA element could only be achieved through a reduction in the RHMA allowance. An adjustment in some figures may be warrented, but the scale of this is yet to be determined.

Rep. Number

14 January 2009 Page 124 of 244 189 2 Subject Spatial Strategy Summary The spine road will improve linkages to the town centre and through this a new transport artery will be created into Stonehaven to facilitate southwards growth.

In the assessment submitted in 2007 it was demonstrated that development could be accommodated to the south with limited landscape and visual impact.

Details of the potential development have been submitted including around 1000 houses, a primary school, community facilities and a coastal park and visitor centre at Dunottar Castle.

Acknowledge that there will be more detail required for the LDP, but feel that it is important to emphasise that the partners are committed to the Stonehaven south proposal.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 189 10 Subject Spatial Strategy Summary In general clients support the Spatial Strategy and in particular the identification of Stonehaven within the SGA.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

190 1 Subject Spatial Strategy Summary Client owns in excess of 53,000 acres of land and in past has shown willingness to release land for development and has sought to work with communities to ensure that this is sympathetically designed, sustainable, integrated and provides lasting benefits for the community.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 190 4 Subject Spatial Strategy Summary In very broad terms support the spatial strategy.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

190 11 Subject Spatial Strategy Summary Too much of a reliance on Brownfield development within the city, this is a finite resource and past levels of brownfield development are unlikely to be maintained.

As a consequence there should be provision for any shortfall to be provided on Greenfield sites within the AHMA.

Draft Response: Acceptance: Do not accept Changes to be made

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. This level is substantially lower than in previous years, when brownfield development represented between 60-90%. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result.

Rep. Number

14 January 2009 Page 125 of 244 191 8 Subject Spatial Strategy Summary Too much of a reliance on Brownfield development within the city, this is a finite resource and past levels of brownfield development are unlikely to be maintained. As a consequence there should be provision for any shortfall to be provided on Greenfield sites within the AHMA.

Draft Response: Acceptance: Do not accept Changes to be made

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. This level is substantially lower than in previous years, when brownfield development represented between 60-90%. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result.

Rep. Number

192 1 Subject Spatial Strategy Summary Support Spatial Strategy and seek an increase in the housing and employment allocations for the Inverurie - Blackburn corridor.

Draft Response: Acceptance: Do not accept Changes to be made

The support for the spatial strategy of the plan is welcome. The allocations within the Inverurie-Blackburn corridor will remain at the level outlined in the plan, however the plan is subject to regular review and these figures can be adjusted as circumstances change. 192 8 Subject Spatial Strategy Summary Too much of a reliance on Brownfield development within the city, this is a finite resource and past levels of brownfield development are unlikely to be maintained. As a consequence there should be provision for any shortfall to be provided on Greenfield sites within the AHMA.

Draft Response: Acceptance: Do not accept Changes to be made

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. This level is substantially lower than in previous years, when brownfield development represented between 60-90%. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result.

Rep. Number

193 1 Subject Spatial Strategy Summary Clients have options in land adjacent to Laurencekirk and Pitmedden.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 193 4 Subject Spatial Strategy Summary In broad terms support the principle of the Spatial Strategy. Particularly welcome the inclusion of Peterhead corridor in the SGA.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

193 9 Subject Spatial Strategy Summary Welcome in the inclusion of Laurencekirk in the SGA.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 126 of 244 194 1 Subject Spatial Strategy Summary Clients are major landowners in the area and in particular Westhill. There is a huge demand for employment land at Westhill. In recent years they have demonstrated willingness to release further land for development.

Draft Response: Acceptance: Noted Changes to be made

Noted.

194 5 Subject Spatial Strategy Summary In very broad terms support the principle of the Spatial Strategy.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

194 7 Subject Spatial Strategy Summary Major concerns that there are no specific allocations of employment land for Westhill or outwith the SGAs.

It is essential that future allocations do not forget the contribution Westhill has and continues to make to the region. This issue cannot be addressed in the absence of a specific allocation to Westhill.

Draft Response: Acceptance: Partially accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

Rep. Number

196 4 Subject Spatial Strategy Summary In very broad terms support the principle of the spatial strategy and particularly welcome the identification of the Aberdeen to Laurencekirk SGA.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

197 4 Subject Spatial Strategy Summary Support the spatial strategy identified, particularly concentrating development in Aberdeen and along main transport corridors. In relation to the City, the University can contribute to land requirements by releasing land that is now surplus to requirements, particularly a vast area around Bucksburn (Rowett Research Institute, south of A96 and west of OP1 and west of Forrit Brae). Also have land at Balgownie likely to become surplus when the new sports village opens in 2009.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 197 5 Subject Spatial Strategy Summary Support requirement for half of growth to be directed to Aberdeen and the majority of residential to be on greenfield sites. In relation to regeneration area, only the net increase in houses should contribute, not one-for-one replacements.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

14 January 2009 Page 127 of 244 197 9 Subject Spatial Strategy Summary Given the importance of increasing the City population and sustainable development, it is considered more appropriate to have a greater focus on maximising allocations within Aberdeen City rather than a new settlement. The University's surplus land at Bucksburn and Balgownie can contribute to any increase allocations and additional surplus land could contribute to requirements in the later periods of the plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 197 11 Subject Spatial Strategy Summary The University owns land at Newburgh that is well located on the Aberdeen to Peterhead SGA. Therefore request that Newburgh is considered as part of this SGA.

Draft Response: Acceptance: Noted Changes to be made

The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

198 4 Subject Spatial Strategy Summary Outwith the main road and rail corridors there are a number of settlements that have proved attractive and sustainable locations in which to live and invest. These settlements already benefit from public transport provision and further development in these areas could be focused on significantly enhancing that provision, bring benefits to existing residents.

Suggest that the overall scale of housing allocations should be increased to reflect the most optimistic forecasts and to encourage growth in the area with a view to meeting the vision, particularly in relation to population increase. This increase should be allocated to the LG&DA part of the AHMA.

Draft Response: Acceptance: Partially accept Changes to be made

There is provision for a significant scale of development outside of the SGA's, however, the allocation of specific sites will be determined within the Local Development Plan process. The overall housing allocation is already generous and based on a high growth scenario. An adjustment in some figures may be warrented, but the scale of this is yet to be determined. 198 7 Subject Spatial Strategy Summary The AWPR will bring benefits to the whole of the AHMA, not just SGA's. The scale of investment would dictate that maximum return should be sought and there is therefore justification to make significant housing and employment allocations in those settlements which directly benefit from the route.

Given the benefits, there are grounds for arguing for City allocations to be spread over a wider area, especially when recent experience is that there is a reluctance to accommodate new greenfield development. Should be a greater focus on locations where there is demand and willingness to accommodate that demand.

Draft Response: Acceptance: Do not accept Changes to be made

The options for the spatial strategy were considered at considerable length and over-reliance on settlements in close proximity to the AWPR rejected. However, accessibility is a key objective and settlements will be judged on their merit as well as the spatial strategy chosen. The allocation of specific sites will be determined within the Local Development Plan process.

Aberdeen City Council is committed to achieving its proportion of the allocations set out in the plan.

Rep. Number

14 January 2009 Page 128 of 244 199 3 Subject Spatial Strategy Summary Generally supportive of the spatial strategy and particularly welcome the identification of the Aberdeen to Peterhead corridor as a SGA. Newburgh should be included within this SGA given its proximity to the A90 and importance in terms of satisfying past employment and housing allocations.

Believe there should be a balance of housing and employment in the Peterhead SGA over the whole plan period. Therefore the focus in the first plan period should not solely be on the diversification and development of the economy, although this is important; housing is equally important in this corridor at this time.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

The plan is clear that the Aberdeen to Peterhead corridor is based on an employment led rationale. However, housing allocations are also made in the first plan period, but these are lower than later periods until the AWPR and other improvements to enable access from the north are in place. 199 4 Subject Spatial Strategy Summary The inclusion of Energetica as a proposal on p.20 is supported, but housing should be given equal importance in the first plan period and housing allocations in this corridor increased to encourage growth in line with the plan's vision, particularly in relation to population increase. Consider that the allocations should be front-loaded to balance the weight given to employment.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. However, front-loading of this corridor is not deemed appropriate until infrastructure improvements are in place and an indication of the success of employment land promotion is better known. 199 5 Subject Spatial Strategy Summary The Blackdog to Ellon area is a popular location for development and the completion of the AWPR and dualling of the A90 will improve the popularity of the area further. In addition to these transport proposals, there is a considerable amount of development planned for this corridor, including a new prison and retail park at Peterhead, mixed use development at Buchan Braes and potentially Trump at Balmedie. Therefore consider that not enough is being made of this area in terms of housing allocations and this does not meet the vision of the plan to be courageous or the aim to ensure the area has enough people and homes.

Draft Response: Acceptance: Partially accept Changes to be made

It is accepted that some significant developments are proposed in this area and this is acknowledged by designation of the corridor to Peterhead. An increase of 1,000 units in the Blackdog to Ellon corridor is proposed, taking the total allocation to 3,400 units, plus 2,000 units from Hatton to Peterhead. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects.

Rep. Number

200 3 Subject Spatial Strategy Summary Generally supportive of the spatial strategy and particularly welcome the identification of the Aberdeen to Peterhead corridor as a SGA. Cruden Bay should be included within this SGA given its proximity to the A90. Proximity makes it a suitable location to absorb some of the allocations to the Peterhead area.

Believe there should be a balance of housing and employment in the Peterhead SGA over the whole plan period. Therefore the focus in the first plan period should not solely be on the diversification and development of the economy, although this is important; housing is equally important in this corridor in all three plan periods.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

The plan is clear that the Aberdeen to Peterhead corridor is based on an employment led rationale. However, housing allocations are also made in the first plan period, but these are lower than later periods until the AWPR and other improvements to enable access from the north are in place.

14 January 2009 Page 129 of 244 200 4 Subject Spatial Strategy Summary The inclusion of Energetica as a proposal on p.20 is supported, but housing should be given equal importance in the first plan period and housing allocations in this corridor increased to encourage growth in line with the plan's vision, particularly in relation to population increase. Consider that the allocations should be front-loaded to balance the weight given to employment.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. However, front-loading of this corridor is not deemed appropriate until infrastructure improvements are in place and an indication of the success of employment land promotion is better known. 200 5 Subject Spatial Strategy Summary Completion of the AWPR and dualling of the A90 will improve the popularity of the area. In addition to these transport proposals, there is a considerable amount of development planned for this corridor, including a new prison and retail park at Peterhead, mixed use development at Buchan Braes and potentially Menie at Balmedie. Therefore consider that not enough is being made of this area in terms of housing allocations and this does not meet the vision of the plan to be courageous or the aim to ensure the area has enough people and homes.

The housing allocations for the Peterhead SGA should be increased and Cruden Bay identified for residential development.

Draft Response: Acceptance: Partially accept Changes to be made

It is accepted that some significant developments are proposed in this area and this is acknowledged by designation of the corridor to Peterhead. For reasons previously given, housing is being restricted early in the plan. An increase of 1,000 houses in the Blackdog to Ellon corridor is proposed, taking the total allocation to 3,400 units, plus 2,000 units from Hatton to Peterhead. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects.

Rep. Number

201 3 Subject Spatial Strategy Summary Generally supportive of the spatial strategy and particularly welcome the identification of the Aberdeen to Laurencekirk corridor as a SGA. Fordoun should be included within this SGA given its proximity to the A90.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team. 201 4 Subject Spatial Strategy Summary The scale of overall housing allocations should be increased to reflect the most optimistic forecasts and encourage growth. Appears to be based on the highest of the Council's strategic forecasts plus 20% flexibility, which equates to the 72,000 proposed. These forecasts were however prepared in 2007 and require to be updated to reflect more recent projections; including the GRO(S) 2006 based population projections published in January '08, which envisage a population of 500,000 by 2031. This increased population will have consequences in terms of households and housing allocations should therefore be reconsidered and increased.

Understand that the 5,000 houses emerging for regeneration areas are simply replacements, there is therefore scope for an increase in allocations by at least these 5,000 units.

Draft Response: Acceptance: Do not accept Changes to be made

The overall housing allocation is already generous and based on a high growth scenario. The plan will be subject to continuous monitoring and can be reviewed within in the short-term when the replacement strategic development plan is prepared, or subsequently during the five year development plan cycle.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

Rep. Number

14 January 2009 Page 130 of 244 204 1 Subject Spatial Strategy Summary Broadly support the spatial strategy and the identification of the Huntly to Laurencekirk SGA. The commitment to support strategic growth through improvements to public transport is welcomed, although it is noted that there is no mechanism to ensure the delivery of these improvements by partner organisations.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The SDPA works closely with partners in the public and private sector and where appropriate will reflect delivery mechanisms in the Action Programme that will be developed early in 2009.

Rep. Number

205 4 Subject Spatial Strategy Summary Broadly support the spatial strategy. However, it does not go far enough to distribute the projected household figures outwith the SGA's to identified settlements or project the likely rate of growth within main settlements. Early co-ordination of the locations of population growth and demographic change allows NHS Grampian to proactively plan and provide for increased and / or new facilities. Insufficient or untimely data does not allow the service to plan and budget.

Draft Response: Acceptance: Do not accept Changes to be made

The strategic level of the structure plan means that indicative figures for reasonably small corridors can be determined. Beyond this, at the settlement level, the allocation of specific sites will be undertaken by Aberdeenshire Council as part of the local development plan process. The NHS have been involved as recognised stakeholders in plan preparation and continue to be involved through the work of the FIRS Group.

Rep. Number

206 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. However, greater emphasis is needed on the role of settlements (such as ) that lie outwith the SGA’s.

Welcome that the plan recognises the need to improve the area's communities and the services they depend on, However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements, especially in the current economic climate and the effect this has had on land values.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. Few settlements get explicit mention in the plan, but it can be seen that significant allocations are made to the LG&DA (RHMA) in which Turriff lies, thus opportunities for local need will be made through the local development plan.

The current economic climate has little bearing on the medium to long-term prospects for development as developers have informed us. The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

207 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Peterhead. Aware of work on Energetica and ask that it be more explicitly reflected in the final plan. Would suggest that the boundaries of the SGA be extended eastwards on the diagram to include Newburgh and Cruden Bay, which logically fall within its sphere of influence.

Welcome that the plan recognises the need to improve the area's communities and the services they depend on, However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements, especially in the current economic climate and the effect this has had on land values.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Energetica is mentioned in three sections of the plan along with also being mentioned in the glossary. The glossary definfition is explicit and refers to who is promoting the initiative should further information be required.

The current economic climate has little bearing on the medium to long-term prospects for development as developers have informed us. The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

14 January 2009 Page 131 of 244 209 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors of the NE and that Aberdeen City is the main focus for growth.

Welcome that the plan recognises the need to improve the area's communities and the services they depend on, However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements, especially in the current economic climate and the effect this has had on land values.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The current economic climate has little bearing on the medium to long-term prospects for development as developers have informed us. The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

218 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with the three SGA’s along the main transport and economic corridors as a sensible approach. Aware of work on Energetica and strongly support it and ask that it be more explicitly reflected in the final plan.

For example, would suggest that the boundaries of the Aberdeen to Peterhead corridor be extended both eastwards and westwards on the key diagram to include Mintlaw, Newburgh and Cruden Bay, which fall within the corridor's sphere of influence.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. Energetica is mentioned in three sections of the plan along with also being mentioned in the glossary. The glossary definfition is explicit and refers to who is promoting the initiative should further information be required.

The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. 218 3 Subject Spatial Strategy Summary Welcome recognition of need to improve the area's communities and the services they depend on. Greater emphasis should be given to settlements outwith the SGA's, in particular market towns and major service centers like Turriff, Mintlaw, , Alford, Fraserburgh etc. and achievement of the sustainable mixed communities objectives of the plan. However, suggest it is unrealistic for landowners to fund the majority of infrastructure improvements required.

With regard to the Aberdeen City SGA, concerned aspirations are not achievable - sufficient land, particularly brownfield, will be difficult to find. It will therefore be important to ensure sites allocated are released quickly and the plan making process becomes more streamlined.

Draft Response: Acceptance: Do not accept Changes to be made

Greater emphasis on these settlements would not be beneficial, merely add to length of the plan. The local development plan will examine issues and potential for each settlement in Aberdeenshire within the development framework this plan proposes. The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Aberdeen City Council is committed to delivery of their proportion of the allocations, both brownfield and greenfield. The structure plan will make every effort to ensure that each Council has all the information required to progress local development plans timeously.

Rep. Number

219 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. Consider that Kintore is well placed to accommodate future growth along the Aberdeen to Inverurie corridor and the recently approved Capacity Study identifies our clients land to create an extension to Kintore.

Also welcome that the plan recognises the need to improve the area's communities and services they depend. However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. Kintore is clearly shown within the SGA, but decisions on the scale of any proposed development and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

14 January 2009 Page 132 of 244 220 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. However, greater emphasis should be given to settlements that lie outwith the SGA's, in particular Keithhall, which is within the sphere of influence of the SGA. Also a requirement to satisfy the local need for housing in rural communities such as Keithhall over the period of the plan.

Also welcome that the plan recognises the need to improve the area's communities and services they depend. However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. If not in the SGA, will fall within the LG&DA. A copy of your representation will be forwarded to the relevant Team.

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

221 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. However, greater emphasis should be given to settlements that lie outwith the SGA's. Also a requirement to satisfy the local need for housing in rural communities such as Craigdam over the period of the plan.

Welcome that the plan recognises the need to improve the area's communities and services they depend. However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. Locations such as Craigdam have no strategic significance and should not feature in the plan. However, the plan makes provision for significant allocations outside the SGA, although the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

222 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. Inverurie is the main service centre for Garioch and is well placed to take a large proportion of the growth within this SGA over the plan period.

Welcome that the plan recognises the need to improve the area's communities and services they depend. However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. Inverurie is clearly shown within the SGA, but decisions on the scale of any proposed development and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

14 January 2009 Page 133 of 244 223 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Peterhead. Aware of work on Energetica and ask that it be more explicitly reflected in the final plan.

Would ask that greater emphasis be placed on key settlements outwith the SGA's, such as Newmachar and Kingseat, which are likely to be vital in meeting the local and strategic need for housing and the future economic prosperity of the region.

Welcome that the plan recognises the need to improve the area's communities and services they depend. However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. Energetica is mentioned in three sections of the plan along with also being mentioned in the glossary. The glossary definfition is explicit and refers to who is promoting the initiative should further information be required.

Settlements such as those mentioned may have a role to play, but the allocation of specific sites will be determined within the Local Development Plan process.

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

224 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Stonehaven. Aware of the master plan for Stonehaven South and believe this area and client's land is well placed to accommodate future growth.

Welcome that the plan recognises the need to improve the area's communities and services they depend. However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. Stonehaven is clearly shown within the SGA, but decisions on the scale of any proposed development and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

226 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors and also welcome the recognition that all parts of the NE are important to the future of the region.

St Combs (between Fraserburgh and Peterhead) is recognised as an attractive place to live and will continue to create local demand for housing throughout the plan period. Would therefore ask that greater emphasis is given to the role of settlements that lie outwith SGA's.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

Locations such as have no strategic significance and should not feature in the plan. However, the plan makes provision for significant allocations outside the SGA, although the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

14 January 2009 Page 134 of 244 227 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors and in particular the Aberdeen to Peterhead corridor.

Welcome the recognition that all parts of the NE are important to the future of the region. (between Fraserburgh and Peterhead) is recognised as an attractive place to live and will continue to create local demand for housing throughout the plan period. Would therefore ask that greater emphasis is given to the role of settlements that lie outwith SGA's.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

Locations such as Crimond have no strategic significance and should not feature in the plan. However, the plan makes provision for significant allocations outside the SGA, although the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

228 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Peterhead.

Welcome the recognition that all parts of the NE are important to the future of the region. is recognised as an attractive place to live and will continue to create local demand for housing throughout the plan period. Would therefore ask that greater emphasis is given to the role of settlements that lie outwith SGA's.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

Locations such as Fetterangus have no strategic significance and should not feature in the plan. However, the plan makes provision for significant allocations outside the SGA, although the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

229 2 Subject Spatial Strategy Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors and Aberdeen City as the main focus for growth.

Welcome that the plan recognises the need to improve the area's communities and services they depend. However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements that will be required, particularly in the current economic climate and effect this has had on land values.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The current economic climate has little bearing on the medium to long-term prospects for development as developers have informed us. The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

230 2 Subject Spatial Strategy Summary Support high levels of growth within Aberdeen City on both brownfield and greenfield land. To accommodate this growth it is clear the green belt and greenspace network will have to be reviewed. As initial work has been done by each Council on new local plans and bids are required, this review is needed prior to the end of 2008 so all plans correspond and there is certainty where large-scale growth can be accommodated.

To accommodate 21,000 new homes on greenfield sites will take 700ha at 30 dpha. A review should be done openly and involve extensive consultation and in the knowledge that at present less than 50% of Aberdeen is built-up at present, the remainder still being green.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The plan commits the Council's to undertake a review of the green belt by the end of 2010, but it is likely that it will be undertaken in 2009 to fit with preparation of the two local development plans.

The proportion of land remaining as green belt is expected to be reduced by around 6% to accommodate the levels of housebuilding proposed. It will be a matter for the Council's how the review is conducted.

14 January 2009 Page 135 of 244 Rep. Number

231 2 Subject Spatial Strategy Summary Support high levels of growth within Aberdeen City on both brownfield and greenfield land. To accommodate this growth it is clear the green belt and greenspace network will have to be reviewed. As initial work has been done by each Council on new local plans and bids are required, this review is needed prior to the end of 2008 so all plans correspond and there is certainty where large-scale growth can be accommodated.

To accommodate 21,000 new homes on greenfield sites will take 700ha at 30 dpha. A review should be done openly and involve extensive consultation and in the knowledge that at present less than 50% of Aberdeen is built-up at present, the remainder still being green. The north of the City has perhaps the greatest potential for large-scale growth in terms of urban extensions or new sustainable communities.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The plan commits the Council's to undertake a review of the green belt by the end of 2010, but it is likely that it will be undertaken in 2009 to fit with preparation of the two local development plans.

The proportion of land remaining as green belt is expected to be reduced by around 6% to accommodate the levels of housebuilding proposed. It will be a matter for the Council's how the review is conducted. The allocation of specific sites will be determined within the Local Development Plan process.

Rep. Number

232 3 Subject Spatial Strategy Summary Support high levels of growth within Aberdeen City on both brownfield and greenfield land. To accommodate this growth it is clear the green belt and greenspace network will have to be reviewed. As initial work has been done by each Council on new local plans and bids are required, this review is needed prior to the end of 2008 so all plans correspond and there is certainty where large-scale growth can be accommodated.

To accommodate 21,000 new homes on greenfield sites will take 700ha at 30 dpha. A review should be done openly and involve extensive consultation.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The plan commits the Council's to undertake a review of the green belt by the end of 2010, but it is likely that it will be undertaken in 2009 to fit with preparation of the two local development plans.

The proportion of land remaining as green belt is expected to be reduced by around 6% to accommodate the levels of housebuilding proposed. It will be a matter for the Council's how the review is conducted.

Rep. Number

233 2 Subject Spatial Strategy Summary Concerned that the stated recognition "the need to maintain and improve the communities and services they depend on" is not reflected in the aims, strategy or targets.

Draft Response: Acceptance: Do not accept Changes to be made

It is important to read the plan as a whole, not as a thematic document. Whilst the comment noted may not be explicit in either of these sections, references to it can be found in the Objectives as "investment decisions" and "help create sustainable mixed communities, and the associated infrastructure..cater for the needs of the whole population". Along with the various references (p.7, p.16 & p.19) to providing infrastructure, this plan makes it clear what is expected.

Rep. Number

234 3 Subject Spatial Strategy Summary Generally support the principle of growth along the SGA with local growth in all other areas of the Shire. In particular the corridor from Aberdeen to Huntly is supported as it is linked to the main road and rail network.

Also support front-loading of the plan and the 1,000 new houses in the Blackburn to Kintore to Inverurie corridor, indeed the area has the potential to accommodate many more houses and take pressure off Aberdeen City who will find it difficult to accommodate the 10,000 brownfield allocation.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

No change to the housing allocation in this corridor are proposed and Aberdeen City Council is committed to delivering their proportion of the allocations.

Rep. Number

14 January 2009 Page 136 of 244 236 3 Subject Spatial Strategy Summary Support high levels of growth within Aberdeen City on both brownfield and greenfield land. To accommodate this growth it is clear the green belt and greenspace network will have to be reviewed. As initial work has been done by each Council on new local plans and bids are required, this review is needed prior to the end of 2008 so all plans correspond and there is certainty where large-scale growth can be accommodated.

To accommodate 21,000 new homes on greenfield sites will take 700ha at 30 dpha. A review should be done openly and involve extensive consultation.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The plan commits the Council's to undertake a review of the green belt by the end of 2010, but it is likely that it will be undertaken in 2009 to fit with preparation of the two local development plans.

The proportion of land remaining as green belt is expected to be reduced by around 6% to accommodate the levels of housebuilding proposed. It will be a matter for the Council's how the review is conducted. 236 4 Subject Spatial Strategy Summary Housing allowances in the RPA's should make it clear that account has been taken of potential demolitions. Schedule 1 is misleading because replacement of 5,000 existing units will only maintain the status quo.

Sustainability objectives encourage up to 80 dpha which should be feasible in a City.

Draft Response: Acceptance: Do not accept Changes to be made

In 2007 the split of households between Aberdeen City and was 50.5% and 49.5%, while in terms of dwellings the figures were 50.9% and 49.1%. The background research for the plan clearly established that development in or close to Aberdeen had significant benefits. In light of these factors, a split of new developments around the 50/50 level was deemed appropriate as a basis for the structure plan.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

The dpha figure will be dependent on a range of factors and site specifics. However, the Background Paper does highlight that an indicative density of 70-95 should be achieved. The City LDP or supplementary planning guidance may go into this in greater detail and this would be the most appropriate place for such a policy / guidance.

Rep. Number

238 3 Subject Spatial Strategy Summary Support the concept of designating SGA's that will accommodate the majority of new development in the area. Also support the front- loading element of the strategy, which refers to 500 houses in the Drumlithie to Laurencekirk corridor in 2007-2016. Would anticipate that Fordoun has an important role to play given its ideal location on the A90 and close to the railway line.

Also suggest that this corridor has more potential to deliver than some other SGA's. In particular, have concerns about ability to deliver 10,000 homes on City brownfield land and concerns about the numbers proposed in the Aberdeen to Stonehaven corridor, there is simply not capacity for this scale of development, as demonstrated by recent work on capacity studies.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

The housing allocations are already generous and based on a high growth scenario and no change is proposed to the housing allocations in this corridor. Aberdeen City Council is committed to delivery of its proportion of the allocations and the Aberdeen to Stonehaven corridor is believed to have capacity for the numbers proposed, as evidenced in the bids recently received.

Rep. Number

240 3 Subject Spatial Strategy Summary Support the concept of designating SGA's that will accommodate the majority of new development in the area. Also support the front- loading element of the strategy, which refers to 2,600 houses in the Stonehaven area in the period 2007-2016.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

14 January 2009 Page 137 of 244 Rep. Number

241 3 Subject Spatial Strategy Summary Support the concept of designating SGA's that will accommodate the majority of new development in the area. Also support the front- loading element of the strategy, which refers to 1,000 houses in the Blackburn-Kintore-Inverurie corridor in the period 2007-2016. Also welcome that allowances increase in subsequent years as Blackburn has a key role to play in the delivery of housing as it has not experienced the same recent development pressures as Kintore and Inverurie. Recognise that investment will be needed in Blackburn's infrastructure, including education provision.

Would suggest that the Blackburn to Inverurie corridor has more potential to deliver required housing numbers than some other SGA's. In particular have concerns about the 10,000 homes on brownfield City land and the numbers proposed for the Portlethen to Stonehaven corridor where there simply is not capacity for this scale of housing as recent capacity studies have shown.

Draft Response: Acceptance: Partially accept Changes to be made

Support for these aspects of the plan is welcomed. The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

The housing allocations are already generous and based on a high growth scenario and no change is proposed to the housing allocations in this corridor. Aberdeen City Council is committed to delivery of its proportion of the allocations and the Aberdeen to Stonehaven corridor is believed to have capacity for the numbers proposed, as evidenced in the bids recently received.

Rep. Number

242 3 Subject Spatial Strategy Summary Focus on SGA's is supported, but have some concerns about the approach taken and how they will be applied at the local level. Note that Aberdeen SGA follows the political boundary rather than those areas most suitable for development. Other areas close to the City offer better solutions for development, based on sound planning reasons, than some areas within the City SGA.

e.g. it is not logical to exclude towns such as Westhill from the Aberdeen SGA given its proximity, transport provision and status as a service and employment centre. Identification as part of a SGA would provide opportunities for new development to fund infrastructure improvements, thus overcoming some capacity problems that it currently has.

Therefore suggest that the City SGA is altered to include Westhill and other settlements close to the City. Consideration should also be given to the fact that green belt overlaps the SGA in some places, thus if applied too rigorously development could be restricted in areas perfectly suited to growth.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. The plan states that a review of the whole green belt will take place, but whilst places may be suited to development, this does not mean they should be released automatically.

Rep. Number

243 3 Subject Spatial Strategy Summary The focus on SGA's is supported and the connection between settlements and transport underscores the sustainability objectives of the plan. Also strongly support the recognition that "development in SGA's will bring about significant need for improvements to the infrastructure, including new primary and secondary schools etc." as this recognises development will need planning gain funded improvements.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

14 January 2009 Page 138 of 244 243 4 Subject Spatial Strategy Summary It is our view that a fourth SGA should be identified, from Aberdeen to Banchory. There are a number of benefits of including this area and concerns that have been raised are unfounded, particularly related to transport infrastructure and landscape impact. On transportation, the creation of the AWPR junctions on Deeside and A944 will provide opportunities for public transport and park and ride.

SGA to Banchory will provide additional choice for housing and employment investment and recognise the role of Banchory as an employment and service centre with a thriving business park. Deeside is a popular area to live and realise that there are concerns that development will erode this; thus a slightly reduced scale of development may be appropriate. Development in this area would also help to address current difficulties with secondary school capacities in the area through new school provision.

Draft Response: Acceptance: Do not accept Changes to be made

The north and south Deeside areas are attractive areas to live, but are not of the same strategic significance as the identified corridors. Development on the scale proposed in the SGA's would have the potential for significant landscape and envrionmental impacts and do not have the same opportunities for public transport, nor road capacity.

However, growth will still be permitted in this area commensurate with local levels of need in the AHMA and RHMA. 243 5 Subject Spatial Strategy Summary Have some concerns about the ability to deliver 10,000 homes on City brownfield land and the number of houses proposed for the Aberdeen to Stonehaven corridor as there is simply not the capacity as shown by recent capacity studies. Should an additional SGA to the west not be identified then housing allocations for the AHMA should be increased to provide additional choice for people to live. The area to the west of Aberdeen has a strong demand for housing and employment and proposals can be suitably managed through LDP's

Draft Response: Acceptance: Do not accept Changes to be made

The housing allocations are already generous and based on a high growth scenario. Aberdeen City Council is committed to delivery of its proportion of the allocations and the Aberdeen to Stonehaven corridor is believed to have capacity for the numbers proposed. The housing allocations are already significant and no change is proposed to the housing allocations in this corridor. 243 6 Subject Spatial Strategy Summary Plan makes no reference to the role that new settlements can provide to the delivery of the scale of development proposed. A key benefit of this approach would be the opportunity to provide for infrastructure and incorporate renewable energy technologies. Whilst the plan does not preclude this, believe much more specific reference should be made to the potential for new settlements.

New settlements do not necessarily require to be considered as new towns, but can be developed on a smaller scale, such as a new village. Recent discussions at capacity study and structure plan events have highlighted the limited benefits of conventional urban extensions, particularly where services and facilities are already at capacity; a new settlement would provide a much better alternative.

Draft Response: Acceptance: Do not accept Changes to be made

The inclusion of a new settlement is not precluded by the plan and could be accommodated within the allowances for a number of locations. It will be for the local development plan process to determine the ultimate suitability of such a strategy.

Such a settlement would have to be of a substantial scale to support the delivery of infrastructure and mix of uses that new residents would need, it should therefore be no less than 5-6,000 units in size.

Rep. Number

244 1 Subject Spatial Strategy Summary We understand and generally agree with, the broad thrust of the three-part growth areas proposed as outlined in Figure 2:Spatial Strategy on page 6 and filled out a little in the Key Diagram on the penultimate page. The main transport corridors make a logical basis for Strategic Growth Areas though there are three, rather than two. It seems unhelpful to define them as Huntly to Laurencekirk and Aberdeen to Peterhead. This gives a misleading impression as only the Aberdeen to Peterhead road has a termination, in a sense though onwards journeys by sea are important too. In the Huntly to Laurencekirk example it would be better if two separate, but linked, corridors were described as Aberdeen to Laurencekirk (and Central Scotland) and Aberdeen to Huntly (and North of Scotland).

Draft Response: Acceptance: Do not accept Changes to be made

Although there is a logic to the suggestion, it would not add value to the plan.

14 January 2009 Page 139 of 244 244 2 Subject Spatial Strategy Summary Aberdeen City is very clearly a connecting nodal point and derives a great deal of its economic significance from that fact of geography. The real strategic importance of these corridors is, of course that they go far beyond the north-east corner that is Aberdeenshire. This is not a mere terminological anxiety but underlines a point that is fundamental to a genuine understanding of how Aberdeen and North-east Scotland work in the wider contexts of the whole of Scotland, the rest of Britain and of our pivotal position in relation to continental Europe. Aberdeenshire does not end at Laurencekirk or at Huntly - we are fortunate in having an outward looking population - and care should always be taken not to give a contrary impression.

Draft Response: Acceptance: Partially accept Changes to be made

The plan does not intend to convey an inward looking or parochial approach, but to reflect the land use situation where our statutory responsibilities end at the Aberdeenshire / SDPA boundary. 244 3 Subject Spatial Strategy Summary Of more practical significance, perhaps is what we can only regard as the unfortunate omission of Oldmeldrum, left off the Spatial Strategy and the Key Diagram, presumably because its population is less than 3000 at present, though it must soon exceed that figure. Irrespective of the actual level of population however is the town’s real economic significance, where it is apparent that it punches well above its weight. (Perhaps the Key Diagram should have referred to Towns of Economic Significance or some other, better phrase, that would not likely be viewed as pejorative by settlements not designated in that way.) Oldmeldrum, (only 7 kilometers from Inverurie) because it is regarded as alternative location to Inverurie - where the acknowledged shortfall in the supply of employment land continues to restrict development - has experienced a high level of business growth in recent years with the result that the Colpy Road Business Park will soon be fully developed. The town also benefits from a splendid, new secondary school that is being increasingly used by the local community. New housing within the western bypass has also flourished in the last few years and the town’s location is clearly popular with house buyers. More housing land should be allocated. Oldmeldrum is strategically located town on the cross-country route between Ellon on the Peterhead corridor and Inverurie on the Huntly corridor and its significance should be acknowledged in the Draft Structure Plan by that cross-country route being shown as a SGA corridor, in its own right. Not doing so could be very damaging to the future prospects for continuing business and residential development in the town.

Draft Response: Acceptance: Do not accept Changes to be made

The omission of Oldmeldrum should in no way be taken to suggest that it is not a locally important town, but it is not considered of strategic significance and because the population does not exceed 3,000, for continuity, it is not shown on the key diagram. However, as with a great number of other towns and villages across the north-east, development for local need will be encouraged within the allocations set out in the plan; but this will be for the local development plan to decide.

Rep. Number

246 1 Subject Spatial Strategy Summary The principle of a strategic growth area (SGA) from Huntly to Laurencekirk is supported. This SGA provides the opportunity to link new development with strategic transport routes and deliver sustainable mixed use communities along its corridor.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 140 of 244 247 3 Subject Spatial Strategy Summary We understand the merits and benefits in the identification of the Strategic Growth Areas and broadly support this approach.

However, we feel that there is an over reliance on development in Aberdeen City to the detriment of the local growth and diversification area. We do not consider that the current distribution of development, between three strands, provides sufficient flexibility for the individual Local Development Plans to respond to local circumstances to meet the needs of the Local Growth and Diversification areas, to maintain population and services, and to deliver sustainable rural communities. This is something, which is supported by the recently published SPP3 - Planning for Homes.

We recommend that the following changes are made:

For at least 70% of all homes built and employment land developed to be in the SGA’s by 2030; For at least 40% of all homes to be in Aberdeen City by 2030; For all strategic developments meeting the needs of the City Region to be in SGA’s

We strongly object to the direction of 50% of the growth to Aberdeen City over the plan period. While we have no objection to the redevelopment of brownfield land and regeneration of depressed areas within the City, we have serious concerns about the ability of Aberdeen City to deliver, or accommodate, 32,000 houses over the plan period, and that provision of such numbers in an areas with significant congestion issues would only exacerbate these problems. This volume of development represents approximately 1,600 units per annum – double the anticipated 2008 completions in the whole of the City Council area.

Out of the options available on page 22, we do not support the Total (v2) option. However, as set out above, we do not consider any of the options put forward provides sufficient scope for the Rural Service Centers to grow and maintain the services present.

Therefore, whilst we do not propose to recalculate the whole table, we would seek an alteration to this strategy that would allow for a distribution as follows:

Aberdeen City - 40% (28,800) Huntly - Laurencekirk & Blackdog - 30% (21,600) Local Growth (AHMA % RHMA) - 30% (21,600)

We would seek the local growth element to be split along proportions of the Total or Total (V1) column between the AHMA and RHMA.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to increase the housing allocations in the Blackdog to Ellon corridor by 1,000 units in the two later plan periods and to reduce the local growth (AHMA) allowance by the same amount. No change to the City / Shire split is planned, although the regeneration area numbers in the City will be revised downwards. The alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

248 3 Subject Spatial Strategy Summary We understand the merits and benefits in the identification of the Strategic Growth Areas and broadly support this approach.

However, we feel that there is an over reliance on development in Aberdeen City to the detriment of the local growth and diversification area. We do not consider that the current distribution of development, between three strands, provides sufficient flexibility for the individual Local Development Plans to respond to local circumstances to meet the needs of the Local Growth and Diversification areas, to maintain population and services, and to deliver sustainable rural communities. This is something, which is supported by the recently published SPP3 - Planning for Homes.

We recommend that the following changes are made:

For at least 70% of all homes built and employment land developed to be in the SGA’s by 2030; For at least 40% of all homes to be in Aberdeen City by 2030; For all strategic developments meeting the needs of the City Region to be in SGA’s

We strongly object to the direction of 50% of the growth to Aberdeen City over the plan period. While we have no objection to the redevelopment of brownfield land and regeneration of depressed areas within the City, we have serious concerns about the ability of Aberdeen City to deliver, or accommodate, 32,000 houses over the plan period, and that provision of such numbers in an areas with significant congestion issues would only exacerbate these problems. This volume of development represents approximately 1,600 units per annum – double the anticipated 2008 completions in the whole of the City Council area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to increase the housing allocations in the Blackdog to Ellon corridor by 1,000 units in the two later plan periods and to reduce the local growth (AHMA) allowance by the same amount. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs. No change to the City / Shire split is planned, although the regeneration area numbers in the City will be revised downwards.

14 January 2009 Page 141 of 244 Rep. Number

249 3 Subject Spatial Strategy Summary We understand the merits and benefits in the identification of the Strategic Growth Areas and broadly support this approach.

However, we feel that there is an over reliance on development in Aberdeen City to the detriment of the local growth and diversification area. We do not consider that the current distribution of development, between three strands, provides sufficient flexibility for the individual Local Development Plans to respond to local circumstances to meet the needs of the Local Growth and Diversification areas, to maintain population and services, and to deliver sustainable rural communities. This is something, which is supported by the recently published SPP3 - Planning for Homes.

We recommend that the following changes are made:

For at least 70% of all homes built and employment land developed to be in the SGA’s by 2030; For at least 40% of all homes to be in Aberdeen City by 2030; For all strategic developments meeting the needs of the City Region to be in SGA’s

We strongly object to the direction of 50% of the growth to Aberdeen City over the plan period. While we have no objection to the redevelopment of brownfield land and regeneration of depressed areas within the City, we have serious concerns about the ability of Aberdeen City to deliver, or accommodate, 32,000 houses over the plan period, and that provision of such numbers in an areas with significant congestion issues would only exacerbate these problems. This volume of development represents approximately 1,600 units per annum – double the anticipated 2008 completions in the whole of the City Council area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to increase the housing allocations in the Blackdog to Ellon corridor by 1,000 units in the two later plan periods and to reduce the local growth (AHMA) allowance by the same amount. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs. No change to the City / Shire split is planned, although the regeneration area numbers in the City will be revised downwards.

Rep. Number

250 3 Subject Spatial Strategy Summary We understand the merits and benefits in the identification of the Strategic Growth Areas and broadly support this approach.

However, we feel that there is an over reliance on development in Aberdeen City to the detriment of the local growth and diversification area. We do not consider that the current distribution of development, between three strands, provides sufficient flexibility for the individual Local Development Plans to respond to local circumstances to meet the needs of the Local Growth and Diversification areas, to maintain population and services, and to deliver sustainable rural communities. This is something, which is supported by the recently published SPP3 - Planning for Homes.

We recommend that the following changes are made:

For at least 70% of all homes built and employment land developed to be in the SGA’s by 2030; For at least 40% of all homes to be in Aberdeen City by 2030; For all strategic developments meeting the needs of the City Region to be in SGA’s

We strongly object to the direction of 50% of the growth to Aberdeen City over the plan period. While we have no objection to the redevelopment of brownfield land and regeneration of depressed areas within the City, we have serious concerns about the ability of Aberdeen City to deliver, or accommodate, 32,000 houses over the plan period, and that provision of such numbers in an areas with significant congestion issues would only exacerbate these problems. This volume of development represents approximately 1,600 units per annum – double the anticipated 2008 completions in the whole of the City Council area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to increase the housing allocations in the Blackdog to Ellon corridor by 1,000 units in the two later plan periods and to reduce the local growth (AHMA) allowance by the same amount. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs. No change to the City / Shire split is planned, although the regeneration area numbers in the City will be revised downwards.

Rep. Number

14 January 2009 Page 142 of 244 251 3 Subject Spatial Strategy Summary We understand the merits and benefits in the identification of the Strategic Growth Areas and broadly support this approach.

However, we feel that there is an over reliance on development in Aberdeen City to the detriment of the local growth and diversification area. We do not consider that the current distribution of development, between three strands, provides sufficient flexibility for the individual Local Development Plans to respond to local circumstances to meet the needs of the Local Growth and Diversification areas, to maintain population and services, and to deliver sustainable rural communities. This is something, which is supported by the recently published SPP3 - Planning for Homes.

We recommend that the following changes are made:

For at least 70% of all homes built and employment land developed to be in the SGA’s by 2030; For at least 40% of all homes to be in Aberdeen City by 2030; For all strategic developments meeting the needs of the City Region to be in SGA’s

We strongly object to the direction of 50% of the growth to Aberdeen City over the plan period. While we have no objection to the redevelopment of brownfield land and regeneration of depressed areas within the City, we have serious concerns about the ability of Aberdeen City to deliver, or accommodate, 32,000 houses over the plan period, and that provision of such numbers in an areas with significant congestion issues would only exacerbate these problems. This volume of development represents approximately 1,600 units per annum – double the anticipated 2008 completions in the whole of the City Council area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to increase the housing allocations in the Blackdog to Ellon corridor by 1,000 units in the two later plan periods and to reduce the local growth (AHMA) allowance by the same amount. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs. No change to the City / Shire split is planned, although the regeneration area numbers in the City will be revised downwards.

Rep. Number

252 3 Subject Spatial Strategy Summary We understand the merits and benefits in the identification of the Strategic Growth Areas and broadly support this approach.

However, we feel that there is an over reliance on development in Aberdeen City to the detriment of the local growth and diversification area. We do not consider that the current distribution of development, between three strands, provides sufficient flexibility for the individual Local Development Plans to respond to local circumstances to meet the needs of the Local Growth and Diversification areas, to maintain population and services, and to deliver sustainable rural communities. This is something, which is supported by the recently published SPP3 - Planning for Homes.

We recommend that the following changes are made:

For at least 70% of all homes built and employment land developed to be in the SGA’s by 2030; For at least 40% of all homes to be in Aberdeen City by 2030; For all strategic developments meeting the needs of the City Region to be in SGA’s

We strongly object to the direction of 50% of the growth to Aberdeen City over the plan period. While we have no objection to the redevelopment of brownfield land and regeneration of depressed areas within the City, we have serious concerns about the ability of Aberdeen City to deliver, or accommodate, 32,000 houses over the plan period, and that provision of such numbers in an areas with significant congestion issues would only exacerbate these problems. This volume of development represents approximately 1,600 units per annum – double the anticipated 2008 completions in the whole of the City Council area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to increase the housing allocations in the Blackdog to Ellon corridor by 1,000 units in the two later plan periods and to reduce the local growth (AHMA) allowance by the same amount. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs. No change to the City / Shire split is planned, although the regeneration area numbers in the City will be revised downwards.

Rep. Number

14 January 2009 Page 143 of 244 253 5 Subject Spatial Strategy Summary In terms of accessibility, the draft Plan’s objective is to ‘make sure all new developments contribute towards reducing the need to travel and encourage people to walk, cycle or use public transport by making these attractive choices’. Indeed, the plan seeks to ‘promote the link between land use and transport’. In achieving this, ‘the spatial strategy will direct development to areas that can be accessed by a greater choice of more environmentally friendly forms of transport’. In this respect, the proposed Park and Ride facility would reduce car usage and increase the number and length of bus journeys, whilst walking and cycling opportunities to the coast and countryside beyond are fully achievable.

Draft Response: Acceptance: Noted Changes to be made

No response required.

Rep. Number

255 6 Subject Spatial Strategy Summary Bancon agree with the general approach of locating most development in Aberdeen and along the principal transport corridors. However, they do not agree that the corridors selected represent the most sustainable choice for promoting growth.

Bancon agree that the principle focus for growth should be Aberdeen. However, they consider that the residential growth targets are unrealistic. They feel that a 40% (City) to 60% (shire) split would be more deliverable. This would be particularly appropriate in the first 9 years of the plan’s life, when delivery of new housing sites in the City will be highly dependent on the Green Belt review which will inevitably be controversial.

The guidance provided by SPP3 on Strategic Development Plans is of particular relevance when considering this point.

The growth targets being suggested in the draft plan need to be properly assessed against realistic estimates for delivery to ensure that they can be met within the projected timescales and ensure sufficient supply is made available throughout the life of the plan.

Bancon agree that the next focus for sustainable residential growth should be along the railway corridor between Laurencekirk and Huntly, and consider that the scale of development allocated to this corridor is largely appropriate.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

Aberdeen City Council is committed to delivery of its proportion of the allocations and the green belt review will be undertaken in time to allow the allocation of the necessary number of units up to 2016. No change to the City / Shire split is planned, although the regeneration area numbers in the City will be revised downwards.

Rep. Number

261 7 Subject Spatial Strategy Summary We agree with the general principles of the spatial strategy.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

261 8 Subject Spatial Strategy Summary We agree on the importance of Aberdeen City and the need for concentration in this area and also the Peterhead corridor which indeed has strategic assets. In the Shire we are also pleased to see the recognition of local growth and diversification areas for other settlements outwith the SGA's.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

14 January 2009 Page 144 of 244 261 9 Subject Spatial Strategy Summary In order to meet the targets set out in the strategy and deal with the very real pressure for both employment and housing land we suggest a mechanism for early release of land particularly within the City and SGA's is put in place. We point out as an example the severe under supply of employment land in the Inverurie Corridor which is constraining local business growth and if not dealt with urgently could displace businesses out of the area.

Draft Response: Acceptance: Do not accept Changes to be made

Development plans will be more regularly reviewed than in the past and this will give opportunities for flexibility and increase in supply if monitoring shows a shortfall in employment land. In addition the Aberdeenshire local development plan will have the scope to allocate as much employment land as it sees fit outside the SGA's to meet local need. 261 10 Subject Spatial Strategy Summary In principle we agree with the volume of development targeted to the city. Whilst most of our interests are based in the shire at present a Strong City is vital to support and enhance a strong shire hence the importance we place on this matter.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

261 11 Subject Spatial Strategy Summary We feel that an early, front loaded release of both housing and employment land is required firstly to maintain the areas viability and secondly to allow the growth potential for the area to be quickly realised.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan proposes an early, front-loaded release of land to facilitate growth and meet the expectations of all stakeholders, both in communities as well as in the public and private sector. 261 14 Subject Spatial Strategy Summary We do not see the need for new settlements but rather utilise the main towns within the SGA's and indeed some principal towns within the local growth areas which will support, improve and expand their services and infrastructure. Make the existing settlements sustainable communities rather than create new ones. Inverurie is a prime example of this and indeed a capacity study has already been undertaken for Inverurie albeit we are not in agreement with its findings.

Draft Response: Acceptance: Partially accept Changes to be made

The spatial strategy promotes a sustainable pattern of using brownfield land within and accessible greenfield land around existing settlements. However, it does not rule out the possibility of a new settlement to accommodate some of the considerable amount of new development planned and such a scheme could be inherently more sustainable than some urban extensions. 261 17 Subject Spatial Strategy Summary We support the growth of the working population in the city and shire to facilitate economic growth. In order to achieve it, it is our opinion that Local Development Plans should secure the early release of land releases in line with the spatial strategy, vision and aims of the plan.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan proposes an early, front-loaded release of land to facilitate growth and this development will be expected to meet with the spatial strategy, vision and aims.

Rep. Number

262 2 Subject Spatial Strategy Summary Half of all new development in the City region will be within Aberdeen City. This hierarchical approach appears entirely reasonable and we support it provided the Plan also retains its focus on developing local centers and towns.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The plan allows local development plans the flexibility to determine the correct approach to the growth of local centres and towns and the allocations that will be made.

14 January 2009 Page 145 of 244 262 3 Subject Spatial Strategy Summary We support all the targets set out on page 8 of the Draft Plan.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

263 2 Subject Spatial Strategy Summary Half of all new development in the City region will be within Aberdeen City. This hierarchical approach appears entirely reasonable and we support it provided the Plan also retains its focus on developing local centers and towns.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The plan allows local development plans the flexibility to determine the correct approach to the growth of local centres and towns and the allocations that will be made. 263 3 Subject Spatial Strategy Summary We support all the targets set out on page 8 of the Draft Plan.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

Rep. Number

264 13 Subject Spatial Strategy Summary There are large areas of the countryside which are not well served by public transport and denying these areas of development potential must be discouraged by the structure plan in recognition of the provisions of SPP15.

Draft Response: Acceptance: Partially accept Changes to be made

The plan does not intend to deny any area of development where there is local need. However, this must remain as plan led as SPP15 explains and this will be a matter for the Aberdeenshire LDP to consider.

Rep. Number

267 10 Subject Spatial Strategy Summary If the strategic growth areas are to deliver the anticipated benefits to the economy, environment and society then care must be taken to ensure that the development contributions are commercially realistic.

Draft Response: Acceptance: Accepted Changes to be made

The plan is explicit in its call for landowners and developers to recognise that to create sustainable mixed communities, a much higher level of contribution will probably be required than in the past. Provided this is known up-front developers and their agents should be in a strong position to negotiate accordingly. However, the last thing anyone wants is unviable projects. 267 11 Subject Spatial Strategy Summary There should be a mechanism through which failure to deliver in one part of the strategic growth areas can be compensated by development in another part. Without such a mechanism unforeseen problems with delivery would severely inhibit the delivery of the fundamental vision and aims of the plan.

Draft Response: Acceptance: Do not accept Changes to be made

Such a mechanism would provide no certainty to the public, developers or infrastructure providers; quite the antithesis of what is hoped. The strategic allocations are based on economies of scale to deliver significant associated projects. It is acknowledged that some proportion of the overall allocations will inevitably end up constrained, thus the high level of housing figures initially proposed.

14 January 2009 Page 146 of 244 267 12 Subject Spatial Strategy Summary There is no justification or reasoning given in the plan as to why 50% of the strategic growth areas should be located within Aberdeen City. There is a strong suspicion that the split in growth is politically motivated and not directed by any overriding strategic planning vision.

Draft Response: Acceptance: Do not accept Changes to be made

In 2007 the split of households between Aberdeen City and was 50.5% and 49.5%, while in terms of dwellings the figures were 50.9% and 49.1%. The background research for the plan clearly established that development in or close to Aberdeen had significant benefits. In light of these factors, a split of new developments around the 50/50 level was deemed appropriate as a basis for the structure plan. 267 13 Subject Spatial Strategy Summary There should at least be a mechanism for allowing deliverable sites close to but not within Aberdeen, such as Banchory Leggart if the councils are determined to maintain the 50% split. Without such mechanism the ability to function in a truly strategic manner is limited.

Draft Response: Acceptance: Partially accept Changes to be made

Banchory Leggart lies in the Aberdeenshire Council area and any development in this location would be covered by the Aberdeenshire local development plan and allocations therein. This area may well fall within the SGA to Stonehaven, but it will be for the local development plan to determine exactly where development takes place and on what scale. 267 14 Subject Spatial Strategy Summary There is no explanation as to the logic to how alternatives V1 and V2 were arrived at and consequently it is difficult to comment on their appropriateness or otherwise. As the next plan will only have the preferred housing allowances it is now in effect to late to resolve this flaw.

Draft Response: Acceptance: Partially accept Changes to be made

The alternatives in Schedule 1 were intended to stimulate debate, which they have done. No alternatives will appear in the final plan.

Rep. Number

268 1 Subject Spatial Strategy Summary Propose the inclusion of a 85.75 hectare site at Mintlaw.

The proposal would constitute a sustainable mixed development including mixed house types, sizes and tenures, employment land, significant community facilities and a park and ride.

Draft Response: Acceptance: Noted Changes to be made

The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

269 2 Subject Spatial Strategy Summary In agreement with the overall strategy which proposes half the development to be in the city with significant elements to the SGAs.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

270 1 Subject Spatial Strategy Summary Support spatial strategy and the allocation of housing along the A96 corridor.

Also note the content of the Inverurie and Kintore capacity study and recognise that there are several points in favour of the allocation of further land within these settlements.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

However, the decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process.

14 January 2009 Page 147 of 244 Rep. Number

271 3 Subject Spatial Strategy Summary Concern that the plan places so much emphasis on development where there is existing public transport provision.

Concentrating 80% of development in the SGAs is considered to be unrealistic, unachievable and to the detriment of the wider Aberdeenshire area.

The emphasis on SGAs appears to conflict with the aims, it is possible to meet the aims without being on a transport corridor or have a railway station.

Also feel that through the application of development appraisal skills and up front analysis that sustainable mixed communities could be achieved in rural locations and locations outwith the SGAs.

Draft Response: Acceptance: Do not accept Changes to be made

A little over 75% of development is proposed in the SGA's with Aberdeen City being one SGA taking 50% of entire allocations. Therefore the split between the SGA's and LG&DA's in Aberdeenshire is almost 50/50. A considerable amount of development remains in both the AHMA and RHMA.

The allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process.

Rep. Number

273 5 Subject Spatial Strategy Summary Agree with the identified SGAs, LGAs and RPAs.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

273 6 Subject Spatial Strategy Summary Agree with the approach to relate the growth to the ability of individual settlements to accommodate new development, this should also apply to the SGAs.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The allocation of specific sites, including in the SGA's will be taken by Aberdeenshire Council as part of the local development plan process. 273 7 Subject Spatial Strategy Summary A new settlement is required to accommodate a significant level of growth in a way that does not affect the existing communities while meeting the plans objectives.

This should be identified in the SP to provide a strong framework for investment decisions which the plan aims to do, this is the only way that the plan can be confident that it will meet the ambitious growth.

Draft Response: Acceptance: Partially accept Changes to be made

The inclusion of a new settlement is not precluded by the plan and could be accommodated within the allowances for a number of locations. It will be for the local development plan process to determine the ultimate suitability of such a strategy.

Rep. Number

276 4 Subject Spatial Strategy Summary Support SGAs.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 148 of 244 277 1 Subject Spatial Strategy Summary Support the City being identified as one of the SGAs but consider the plan should provide more guidance on where future growth in the SGAs should take place and what form or forms would be acceptable.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. However, the decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. The plan gives sufficient detail at this level as to what form proposals should take. 277 2 Subject Spatial Strategy Summary The plan should lend support to brownfield land, infill sites, and where brownfield and infill sites cannot meet the requirements greenfield expansions to built up areas and stand alone settlements (in accordance with SPP3)

The new settlement requires further consideration should be given to new standalone communities.

Draft Response: Acceptance: Partially accept Changes to be made

The plan does support the reuse of previously developed land across the structure plan area, whilst acknowledging that greenfield development will be needed to accommodate the scale of growth envisaged.

The inclusion of a new settlement is not precluded by the plan and could be accommodated within the allowances for a number of locations. It will be for the local development plan process to determine the ultimate suitability of such a strategy.

Rep. Number

278 3 Subject Spatial Strategy Summary SGAs LG&Ds and RPAs and the reliance on the travel corridor are considered to be broadly acceptable.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

278 4 Subject Spatial Strategy Summary Strategic forecasts were prepared in 2007 and now need to be updated to reflect national projections.

GRO envisaged a population of 500,000 by 2031 and the plan should provide sufficient land to accommodate the most optimistic growth scenario, thus the housing allocations should be increased.

Government policy has expressed in Firm Foundations that they want to increase the rate of new housebuilding in Scotland to at least 35,000 by 2015, the plan should be front loaded to kick-start the process.

Draft Response: Acceptance: Do not accept Changes to be made

The overall housing allocation is already generous and based on a high growth scenario. The process of monitoring and reviewing the plan will allow for demographic, economic, policy or other changes to feed into subsequent plans.

The plan is already front-loaded and notwithstanding current economic challenges, the level of growth proposed appears to be about correct. 278 13 Subject Spatial Strategy Summary Additional greenfield land to that specified in DSP will be required within Aberdeen City for the following reasons: - To avoid delays in the delivery of housing land by providing enhanced front-loaded allocations; - To compensate for the delay to post-2010 in bringing forward housing; - To compensate for any shortfall in the brownfield target.

Need to review the Green Belt immediately.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan proposes the building of 21,000 new homes on greenfield land within Aberdeen City, with 12,000 up to 2016 - this is front-loading on an unprecedented scale. This level of housing is proposed to allow an element of 'catch-up' to compensate for low levels of recent development in the City. The brownfield target is thought to be realistic.

The review of the green belt will be undertaken jointly in the near future.

14 January 2009 Page 149 of 244 278 17 Subject Spatial Strategy Summary Instread of proposing new settlements it is more appropriate in the short and medium term to expand major settlements such as Ellon, Inverurie, Kintore, Portlethen, Stonehaven and Westhill which benefit from existing services, facilities and employment.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. There is an argument that a new town would mitigate some of the impacts of incremental growth of established towns and villages, by planning several thousand homes and all the services and facilities they need from scratch. However, in the eventual allocations will depend on decisions taken during the local development plan process and will largely feature expansions to existing settlements.

Rep. Number

279 10 Subject Spatial Strategy Summary The Structure Plan will require identification of both Greenfield and brownfield sites, of which Craibstone contains both to meet the target numbers. CALA is confident that the Craibstone site can play a significant role in helping the council to meet its target, through the imaginative use of previously developed site. Greenfield development at Craibstone will enable brownfield redevelopment to take place, including the renovation of some existing buildings for community uses, and possibly a primary school. The existing built footprint is a sizeable part of the site (approximately 34%), which in itself is unlikely to be viable. Combined with some contained green field release, the potential for an exciting and viable new urban village is realized.

Draft Response: Acceptance: Partially accept Changes to be made

There will indeed be the need for greenfield and brownfield sites and this is reflected in the plan. However, the allocation of specific sites will be undertaken by Aberdeen City Council as part of the local development plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

281 2 Subject Spatial Strategy Summary Generally support the spatial strategy as the focus for development in the area up to 2030. However, feel that the plan could go further by identifying the approximate scale for settlements within these growth areas. The would greatly assist local plan preparation and avoid delay in implementation.

Draft Response: Acceptance: Do not accept Changes to be made

The decision whether a settlement is in or out of an SGA and whether to allocate specific sites will be taken by Aberdeenshire Council as part of the local development plan process. Work has already commenced on this process to keep any delay to a minimum.

Rep. Number

282 6 Subject Spatial Strategy Summary The land allocations strategy which has been developed for Aberdeenshire is neither sustainable, nor does it meet the needs of business in the A90 corridor north of Aberdeen. The strategy overloads the A90 south of Aberdeen and the A96 and these are already the most congested as a result of problems at the Haudigan and .

The Energetica project, AWPR and A90 improvements north of Aberdeen has already increased demand for business land. It is incredible that none of this has been taken on board and the allocations are derisory and back-loaded. There would need to be in excess of 3,500 units just in the first plan period alone.

Draft Response: Acceptance: Do not accept Changes to be made

The plan makes it clear that the resolution of transportation problems across the north-east must be a priority and it has attempted to devise a strategy that does not impact negtively on these problems. Proposals to the north of Aberdeen are dependent on the AWPR and A90 upgrading at Balmedie / Tipperty as well as improvements at the Haudagain and the Third Don Crossing. Until these take place, only limited development is proposed for this corridor.

The Energetica Project is about much more than housing and it is believed that an employment-led approach is the key justification. This is reflected in the plan and the work of ACSEF and Scottish Enterprise will be closely followed.

14 January 2009 Page 150 of 244 282 7 Subject Spatial Strategy Summary The amount of housing allocated to the City is not justified in any of the supporting documents and will be impossible to justify at the forthcoming EiP. This strategy is unproven without the essential green belt review. A better solution would have been a 50% allocation to a ‘greater city region’ incorporating Aberdeen, Westhill, Portlethen and Newmachar as these settlements have good travel times to edge-of- city employment sites and is justified on sustainability grounds.

Draft Response: Acceptance: Do not accept Changes to be made

In 2007 the split of households between Aberdeen City and Aberdeenshire was 50.5% / 49.5%, while in terms of dwellings the figures were 50.9% / 49.1%. The background research for the plan clearly established that development in Aberdeen had significant benefits. In light of these factors, a split of new developments around the 50/50 level was deemed appropriate as a basis for the structure plan. Settlements around the City, particularly those in SGAs, will be considered for levels of strategic growth, whilst other larger settlements in the LG&DA will be considered for allocations based on social, economic and environmental criteria and infrastructure requirements taking full account of local need. 282 8 Subject Spatial Strategy Summary Overloading the Stonehaven to Portlethen and Blackburn to Inverurie corridors is completely irrational given the existence of a high number of already constrained units. This will not deliver effective housing units, particularly in the first period. This is clearly demonstrated in the 2008 HLA. This may be due to the fact that the effective and constrained figures in Schedule 1 are incorrect, particularly in these two corridors.

Draft Response: Acceptance: Do not accept Changes to be made

Acknowledge that the 2008 HLA details a number of constrained sites in these corridors, but these are due to ownership, physical or infrastructure issues that can be resolved. In any event, the presence of constrained sites does not preclude the allocation of new sites, particularly when the scales differ so much.

There have been a high number of 'bids' for development in these corridors and whilst this is an issue for the local development plan to take up, it does appear to demonstrate that effective housing units would follow.

Rep. Number

284 2 Subject Spatial Strategy Summary Believe that the reliance on the need to direct development to Aberdeen City and the Huntly to Laurencekirk corridor is unsustainable in the longer term. Implies a lasting desire for people to commute into Aberdeen and this is becoming increasingly inefficient. It would be far better for jobs to be located in all settlements.

Draft Response: Acceptance: Partially accept Changes to be made

The plan aims to encourage mixed developments, not just in the SGA's, but in all appropriate cases. This cannot guarantee that people will live and work in close proximity, but allows them the choice to do so. Must recognise that people will still want / need to travel to Aberdeen for work, shopping etc. and concentrating 75-80% of development in the most accessible locations, with best transport connections is the most sustainable option. 284 3 Subject Spatial Strategy Summary Better to look at all settlements across the region (and City) and explore how they can be made more sustainable, i.e. walkable neighbourhoods, open space provision, balance between places to work and live in each. This is being encouraged by the Scottish Government and Councils need to move from old-fashioned methods of development planning; this plan is a good place to start.

A better strategy would be to disperse mixed use development throughout the region instead of reliance on preferred development corridors.

Draft Response: Acceptance: Partially accept Changes to be made

The plan seeks to make better connections between and within settlements to encourage walking and cycling. The spatial strategy has been widely discussed with many groups and is believed to offer the best opportunities for the use of public transport and passive modes of travel.

Dispersal was dismissed partly on the basis that it would be less sustainable as it could not deliver the critical mass of development to make new / improved services viable. 284 7 Subject Spatial Strategy Summary The practice of redeveloping brownfield sites with a new use that is 100% residential should be resisted. Sites where a previous industrial use existed should maintain permanent job creation within it and preferably the number of people employed should be no less than before.

Draft Response: Acceptance: Partially accept Changes to be made

The plan stresses a preference for mixed use developments. However, every brownfield site is different and the exact composition of such sites can best be determined as they arise, when a brief is produced or during the planning application process. In the majority of cases it would be unrealistic to expect a similar amount of people to be employed as before, or for this to be quantified accurately.

14 January 2009 Page 151 of 244 Rep. Number

285 6 Subject Spatial Strategy Summary New settlements tend to attract substantial opposition, whereas organic growth of existing settlements gives a master planned approach that may be a more effective way forward.

Draft Response: Acceptance: Partially accept Changes to be made

Either strategy has the potential to attract significant support or opposition and either could benefit from a master planned approach. However, it will be for the local development plan to determine exactly where development takes place and on what scale. 285 9 Subject Spatial Strategy Summary The target that "all strategic developments meeting the needs of the city region be in SGA’s" appears very restrictive.

Draft Response: Acceptance: Do not accept Changes to be made

Whilst that is an identified target, it is clear in the paragraph above that there may be some cases where a proposal cannot be provided for in an SGA. As it states, these proposals must be justified against the aims, objectives and targets of the plan.

Rep. Number

286 8 Subject Spatial Strategy Summary Accept that previous structure plans were too prescriptive / restrictive. However, believe that this plan is leaving too much for local (development) plans to consider and will lead to significant delays and debates in the plan making process and uncertainty for communities and service providers. More specific information is required within the SGA’s and local growth areas as to which settlement will get an allocation or indeed a new settlement.

Draft Response: Acceptance: Do not accept Changes to be made

The flexibility in this plan is appropriate as it gives each Council latitude to determine their own interpretation of the plan without it being overly prescriptive when many decisions are not strategic or cross-boundary. The structure plan does not need to determine how many homes go to main settlements, or the Aberdeenshire areas as NEST did. These decisions should be taken by Aberdeenshire Council alone as part of the local development plan process, provided the spatial strategy is adhered to. Delays may come in many forms, from within the Council, from developers competing for sites, or from communities, these must be managed effectively to deliver the plan within a reasonable timescale. 286 10 Subject Spatial Strategy Summary There is significant un-met demand for family housing in Aberdeen City and opportunities in terms of infrastructure. Welcome the recognition that development will have to take place on greenfield sites and would urge an immediate review of the greenbelt to achieve this.

Draft Response: Acceptance: Partially accept Changes to be made

The plan recognises that there is a demand for a range of housing in the City, not just family housing. The joint greenbelt review will be undertaken in 2009, but the timescales and mechanisms will be determined by the Council's. 286 26 Subject Spatial Strategy Summary The following settlements are capable of accommodating significant development within Aberdeenshire; Stonehaven, Portlethen, Drumoak, Westhill, Potterton, Ellon, Newburgh, Pitmedden.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not promote development at these, or any other specific settlement. At the level it operates, only designations for 'corridors' are made. The allocations made to SGA's provide this and it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

14 January 2009 Page 152 of 244 287 9 Subject Spatial Strategy Summary Generally supportive of the underlying principles as we accept that preceding structure plans have been too prescriptive / restrictive. However, this plan is leaving too much for local development plans to consider and this could lead to significant delays and debates in the local plan making process.

Draft Response: Acceptance: Partially accept Changes to be made

The flexibility in this plan is appropriate as it gives each Council latitude to determine their own interpretation of the plan without it being overly prescriptive when many decisions are not strategic or cross-boundary. The structure plan does not need to determine how many homes go to main settlements, or the Aberdeenshire areas as NEST did. These decisions should be taken by Aberdeenshire Council alone as part of the local development plan process, provided the spatial strategy is adhered to. Delays may come in many forms, from within the Council, from developers competing for sites, or from communities, these must be managed effectively to deliver the plan within a reasonable timescale. 287 13 Subject Spatial Strategy Summary Agree with the approach taken in the City, with brownfield, regeneration and greenfield allocations. However, the mismatch in City allocations results in the growth of Aberdeenshire and also insufficient range and choice of house types.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The mismatch referred to is a result of past problems in identifying and allocating greenfield sites in the City, thus concentrating on brownfield here and greenfield in the remainder of the Aberdeenshire part of the AHMA. This should no longer happen now that local development plans are being produced in tandem and the City has expressed a willingness to deliver its share. 287 14 Subject Spatial Strategy Summary The split between brownfield and greeenfield is too ambitious as there is limited capacity of brownfield in the city. Figures in the UCS do not address concerns as we have fundamental concerns about the methodology behind the study, particularly the density assumptions for brownfield sites which are flawed.

Draft Response: Acceptance: Do not accept Changes to be made

Irrespective of discussions on the selected methodology and use of comparisons, the data suggests that around 400+ units per annum is not unrealistic based on past permissions and 10,000 over 22/23 years should be achieveable. However, this is a fairly lengthy period and the UCS concedes that beyond 10 years, Aberdeen's urban potential would have to be reviewed to see if it can continue to provide this level of brownfield development. 287 17 Subject Spatial Strategy Summary More guidance is needed to provide assistance with local plan preparation and more certainty to communities and service developers.

Draft Response: Acceptance: Do not accept Changes to be made

The flexibility in this plan is appropriate as it gives each Council latitude to determine their own interpretation of the plan without it being overly prescriptive when many decisions are not strategic or cross-boundary. The structure plan does not need to determine how many homes go to main settlements, or the Aberdeenshire areas as NEST did. These decisions should be taken by Aberdeenshire Council alone as part of the local development plan process, provided the spatial strategy is adhered to.

Rep. Number

289 7 Subject Spatial Strategy Summary It is important that affordable housing is included in the plan.

Draft Response: Acceptance: Accepted Changes to be made

There is a strong commitment to provide affordable and social housing in the plan and this is central to the concept of sustainable mixed communities and will be pursued through masterplans at the level determined by the housing need and demand assessment.

The Objective on Sustainable Mixed Communities has a target to ensure that; "new housing meets the needs of the whole community by providing at least 25% of affordable housing". Local development plans will give additional information.

Rep. Number

14 January 2009 Page 153 of 244 291 2 Subject Spatial Strategy Summary The SS would appear to be appropriate approach with half of the growth area directed to Aberdeen City,

Historically it has been proven that when Aberdeen prospers the surrounding areas prosper too.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

291 4 Subject Spatial Strategy Summary Proposals to have greater development to the north of the city should be supported with planned improvements in transport links.

Draft Response: Acceptance: Partially accept Changes to be made

Development to the north of the City, either within the boundary or in Aberdeenshire, would greatly benefit from and may even be dependent upon delivery of the AWPR, Third Don Crossing (and associated measures) and Balmedie to Tipperty upgrade. This is reflected in the relatively low figures in these corridors in the early period of the plan. No details for Aberdeen can be discerned as the allocation of specific sites will be determined within the local development plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria. 291 5 Subject Spatial Strategy Summary The commitment to mixed communities must be adhered to and affordable housing spread throughout the city and shire.

Draft Response: Acceptance: Accepted Changes to be made

The plan seeks to ensure this, local development plans will give greater guidance on these issues.

291 11 Subject Spatial Strategy Summary Concern that the funding for the new schools would impair the proposed replacement of existing schools.

Draft Response: Acceptance: Do not accept Changes to be made

The plan states that a number of new schools will be needed in the City and Shire and that a significant proportion of the cost of these will be funded by developer contributions from the thousands of homes proposed. The decision on other capital projects is a matter for the Education services of each Council, although it would be expected that a programme of renewal and refurbishment would continue.

Rep. Number

295 1 Subject Spatial Strategy Summary Concerns with the apparent annihilation of the Green belt within the City boundary.

Would like NEST Structure Plan page 52 Green Belt policy 27 and 28 to be considered. This Structure Plan is to run till 2016. Concern that these policies not being present in the new Structure Plan will allow developers and speculators to submitting planning applications within the Green Belt.

Draft Response: Acceptance: Do not accept Changes to be made

In order to deliver the 21,000 homes proposed a small percentage of the green belt will have to be lost; this will be given careful consideration through the review to take place in 2009.

This plan will supercede NEST and in some respects is a new style of plan. It does not contain policies in the same way that NEST did, but has got policy material that local development plans will interpret to ensure remaining green belt is fit for purpose and meets the requirements of national policy.

Rep. Number

297 7 Subject Spatial Strategy Summary Appears to be sounds rational with the selection of the current development areas ie Laurencekirk - Huntly Rail corridor and Aberdeen to Peterhead economic regeneration.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

14 January 2009 Page 154 of 244 297 8 Subject Spatial Strategy Summary Surprising that there is no mention of creating public transport infrastructure to Peterhead.

Concern that the strucutre plan does not develop a long term transport strategy.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan is not the place to develop long term transport strategies; this would be duplication of the work of NESTRANS and the Regional Transport Strategy, or the Aberdeenshire Local Transport Strategy. Once projects appear in these documents, they may be incorporated in a future structure plan. 297 9 Subject Spatial Strategy Summary The width of the corridors require further definition.

Draft Response: Acceptance: Do not accept Changes to be made

The corridors are only indicative. The decision whether a settlement is in or out of an SGA and the allocation of specific sites will be taken by Aberdeenshire Council as part of the local development plan process. 297 10 Subject Spatial Strategy Summary Concerns that Westhill is not mentioned.

It has been developed in the past with retail developments, park and ride facilities etc.

Is this missing an opportunity to further develop this area with employment and education.

This area could be functional and independent not relying on services in the city.

Draft Response: Acceptance: Partially accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

Rep. Number

298 6 Subject Spatial Strategy Summary Affordable housing is important.

Draft Response: Acceptance: Accepted Changes to be made

The provision of affordable housing is central to the concept of sustainable mixed communities and will be pursued through masterplans at the level determined by the housing need and demand assessment. Local development plans will give additional information. 298 8 Subject Spatial Strategy Summary Agree in principle that villages should be extended rather than individual houses, though it should be noted that there is ofter a very good social reason for individual houses in the countryside.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan is responsible for taking a strategic view and has little to say on individual houses; only that local development plans should focus new housing in, or as an extension to, existing settlements. It also says that the approach taken must be in line with national policy, of which SPP15 will be important.

Rep. Number

14 January 2009 Page 155 of 244 299 2 Subject Spatial Strategy Summary This spatial strategy is presaged on the assumption that the infrastructure (e.g. Crossrail) will be in place.

No consideration has been given to an alternative should any of the infrastructure not be forthcoming.

Draft Response: Acceptance: Partially accept Changes to be made

The spatial strategy does focus development in the City and corridors where there opportunities to encourage public transport are greatest. The concentration of 75-80% of development in these locations has other benefits related to economies of scale for provision of services and facilities. This is believed to be the most appropriate response to the challenges facing the north-east. It must also be noted that the plan will be subject to review within the next two years, which gives the opportunity to revisit the strategy. 299 3 Subject Spatial Strategy Summary No specific comments on the half the growth being in the City and half in the Shire, as this was a political decision.

Doubts expressed as to the risks associated with the capability of Aberdeen City to deliver their 50%.

Draft Response: Acceptance: Do not accept Changes to be made

The 50/50 split is equitable and believed to be deliverable. Aberdeen City Council is committed to delivery of its proportion of the allocations.

299 9 Subject Spatial Strategy Summary Some people believe a new settlement would be a better option. Surprised that there is no apparent option appraisal for such a solution.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. 299 34 Subject Spatial Strategy Summary There should be a subdivision of the plan into the sections ie Inverurie - Blackburn corridor and Portlethen - Stonehaven corridor to show where infrastructure improvements will go ie which area the 2 new schools will be located in.

Draft Response: Acceptance: Do not accept Changes to be made

Detailed proposals will be dealt with through the Local Development Plan process.

Rep. Number

301 3 Subject Spatial Strategy Summary The plan only encourages new industry to the narrower corridors so clearly identified.

It would be easy to require the Rural towns to make sure that there was land available for businesses at all times, then for Aberdeenshire Council to provide incentives for development in those rural areas.

Draft Response: Acceptance: Partially accept Changes to be made

The plan encourages 75-80% of new development to the identified corridors. Clearly this gives an opportunity to provide a substaintial amount of land for employment use in other areas. In addition, the local development plan may look at more innovative ways of encouraging employment through integrated developments of mixed residential and small scale employment, work from home, starter units etc. Any financial incentives would emerge through an economic development route, although planning can have a role in facilitating appropriate developments.

Rep. Number

14 January 2009 Page 156 of 244 302 15 Subject Spatial Strategy Summary Not convinced that 75 - 80% of growth over the next 20 years should be concentrated in 3 SGAs.

Believe that development should be focused around existing town within the city region to create self sustaining communities that provide employment, high quality living and reduced the need to travel a long distance.

Draft Response: Acceptance: Partially accept Changes to be made

The SGA's represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services. In 2007 the split of households between Aberdeen City and was 50.5% and 49.5%, while in terms of dwellings the figures were 50.9% and 49.1%. The background research for the plan clearly established that development in or close to Aberdeen had significant benefits. In light of these factors, a split of new developments around the 50/50 level was deemed appropriate as a basis for the structure plan. Settlements around the City, particularly those in SGAs, will be considered for levels of strategic growth, whilst other larger settlements in the LG&DA will be considered for allocations based on social, economic and environmental criteria and infrastructure requirements taking full account of local need. 302 17 Subject Spatial Strategy Summary Support the focus in Aberdeen City on Brownfield and regeneration sites.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

302 18 Subject Spatial Strategy Summary Do not support the focus of 25% new housing being in the greenbelt. Recognise that some housing will have to be built on greenbelt land within the existing city boundary, it is the concentration and scale that is not accepted.

Feel that the boundary is artificial and there is a need in the lifetime of the plan the viability and boundaries of the councils should be reviewed.

Draft Response: Acceptance: Do not accept Changes to be made

The Council's are committed to the future growth of the north-east and to deliver this there will need to be a review of the green belt to identify sites for development. Around 21,000 new homes are proposed in the City greenbelt up to 2030 in this plan, but this will be subject to regular monitoring. However, the allocation of specific sites will be determined within the local development plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

This is not a structure plan issue.

Rep. Number

303 4 Subject Spatial Strategy Summary Scottish Government no longer support the rail Halt at Kintore, which means that this village will be passed by the railway.

Kintore should be removed from the corridor and any further consideration for housing.

More housing in Kintore would increase car usage which is contrary to the targets in the plan.

Draft Response: Acceptance: Do not accept Changes to be made

The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service.

The settlement is within the SGA, but the scale of growth that will occur is a matter for Aberdeenshire Council as they prepare their local development plan. Whilst rail is an attractive mode of transport, the proximity to the A96 means Kintore is well-served by bus services, will benefit from any new park and ride facility and the AWPR junction near Dyce.

Rep. Number

14 January 2009 Page 157 of 244 307 2 Subject Spatial Strategy Summary E&SCC also generally support the 'Three Strands' approach to Spatial Strategy. However have concerns with the developer wanting to make Westhill part of a SGA, this is strongly disputed by the Community Council.

Draft Response: Acceptance: Noted Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. 307 3 Subject Spatial Strategy Summary Have a strong preference for a dedicated "New Town" - to satisfy housing needs for Aberdeenshire which should be constructed on the main A90 / A96 transport corridor, somewhere between Huntly and Laurencekirk - straddling the railway line.

The new town concept was supported by this community council at the consultation events in 2006.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. However, the allocations in Schedule 1 would only allow a new settlement in the corridors from Aberdeen to Inverurie or Aberdeen to Stonehaven. 307 4 Subject Spatial Strategy Summary Propose/support a greater percentage of housing allocated within the city.

Emphasis and priority should be placed upon development of Brownfield sites - followed by land that has low agricultural potential.

Draft Response: Acceptance: Partially accept Changes to be made

The amount of brownfield housing in the City is broadly comparable with recent years. However, the greenfield allowances are significantly higher than in the existing local plan.

The selection of greenfield sites will be made following a green belt review and a number of criteria will be used in this assessment. However, it is understood that no prime quality agricultural land is found in the City, most being in the 3.1 class or below. 307 7 Subject Spatial Strategy Summary Support the Spatial Strategy targets but believe that the city share should be higher, for reasons given previously.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. A 50/50 equitable split is the preferred option.

307 8 Subject Spatial Strategy Summary Totally opposed to the coalescence of Westhill and Kirkton of Skene, this has been opposed for a long time by many people and organisations.

Draft Response: Acceptance: Noted Changes to be made

This area is designated for local growth only (AHMA), it will be for the local development plan to determine exactly where development takes place and on what scale 307 10 Subject Spatial Strategy Summary Many issues and pinch points surrounding Westhill and many agree it has reached capacity.

Concerns with the road networks, emergency service response times, no bus land opportunities, primary schools at capacity, lack of leisure facilities any further housing cannot be accommodated and would make the current situation and concerns so much worse.

Draft Response: Acceptance: Noted Changes to be made

This area is designated for local growth only (AHMA), it will be for the local development plan to determine exactly where development takes place and on what scale

Rep. Number

14 January 2009 Page 158 of 244 312 5 Subject Spatial Strategy Summary Feel there is a requirement for some guidance on the appropriateness of house building in the countryside.

The community council believe that each house should be decided on their own merits, and there should not be a presumption against individual houses in the countryside.

Draft Response: Acceptance: Do not accept Changes to be made

The plan supports development in, or adjacent to, existing settlements within Local Growth and Diversification Areas. The level of growth appropriate and more detailed policies will be determined through the Local Development Plan process. Any such policy must be consistent with the provisions of relevant national policy, in the form of SPP3 and SPP15.

Rep. Number

314 1 Subject Spatial Strategy Summary Generally agree with the spatial strategy and accessibility strategy which is aimed at reducing the need to travel.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

314 5 Subject Spatial Strategy Summary We support the objective of landowners funding infrastructure costs from increased land values.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

318 5 Subject Spatial Strategy Summary The Council should investigate more houses being built for rent rather than to buy.

Draft Response: Acceptance: Partially accept Changes to be made

The plan promotes a greater mix of housing and this will be investigated through the housing need and demand assessment referred to on p.17. The housing service of each Council has been involved in the preparation of the plan to date and are satisfied with its contents.

Rep. Number

319 4 Subject Spatial Strategy Summary The use of designated greenbelt land for controlled planned development with high quality landscaping and recreational use has not been considered.

Draft Response: Acceptance: Do not accept Changes to be made

The plan is very clear that a review of the green belt will be required to accommodate the levels of growth anticipated, particularly in the City. However, the review will be a joint exercise with Aberdeenshire Council. 319 6 Subject Spatial Strategy Summary Existing lack of provision in older and recently expanded communities has been ignored - most significantly the needs of the growing elderly population.

Draft Response: Acceptance: Noted Changes to be made

Unsure exactly what provision is considered as lacking. The structure plan aims to ensure new communities are mixed in land uses and provide a range of housing. It is recognised that the ageing population will have different needs, but the influence the plan can have on this is somewhat limited.

14 January 2009 Page 159 of 244 319 7 Subject Spatial Strategy Summary Given this history of developmpent together with rising fuel costs, why has the use of greenbelt land not been considered to reduce the environmental and human costs of crossing it?

Why is ‘ribbon development’ beyond the greenbelt proposed instead?

Draft Response: Acceptance: Do not accept Changes to be made

The plan is very clear that a review of the green belt will be required to accommodate the levels of growth anticipated, particularly in the City. The pattern of development proposed in the SGA's is not a ribbon along the entire corridor.

Rep. Number

320 7 Subject Spatial Strategy Summary Concern that the level of growth proposed in the city and changes to the Greenbelt will result in a loss of leisure and recreational amenity.

Draft Response: Acceptance: Noted Changes to be made

The review of the green belt will be undertaken with amenity and access in mind as required by SPP21. Developments of over 1ha on former green belt land will require to be masterplanned and this will provide opportunities for introducing green networks and access beyond and between developed areas.

Rep. Number

325 1 Subject Spatial Strategy Summary Aberdeen City and Aberdeenshire Structure plan, should concentrate on the Aberdeen to Peterhead corridor and to regenerate places such as the Fraserburgh area.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan does suggest these elements as part of the spatial strategy, along with the Huntly to Laurencekirk corridor.

325 6 Subject Spatial Strategy Summary New housing and any further development should be concentrated in areas such as Peterhead and Fraserburgh. These areas have been run down for years and would benefit most from regeneration.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan has a responsibility to the whole north-east and must propose a strategy for development that balances the needs of each of these areas - this is what this spatial strategy aims to achieve. The allocation of housing does not necessarily bring benefits without associated measures. Peterhead is designated as a regeneration area and strategic growth area, this recognises the opportunities and challenges that exist. In contrast, Fraserburgh is designated as a regeneration priority area and this should be the main focus for development, but may need further clarification of what tangibles this may deliver. 325 7 Subject Spatial Strategy Summary Possibly consider a new town altogether.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. However, the allocations in Schedule 1 would only allow a new settlement in the corridors from Aberdeen to Inverurie or Aberdeen to Stonehaven.

Rep. Number

330 3 Subject Spatial Strategy Summary SCDI supports the spatial strategy which is set out in the draft structure plan, with Aberdeen one of the strategic growth areas, strategic growth corridor from the City along the A90 towards Dundee and the A96 towards Inverness and the regeneration priority areas in the Banffshire and south-eastern coats of Aberdeenshire.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

14 January 2009 Page 160 of 244 330 7 Subject Spatial Strategy Summary The spatial strategy in the draft Structure Plan states clearly that: all parts of the North east are important for the further development of the area. SCDI is aware of the comments and criticism that development in the three strategic growth areas, above all the Energetica initiative between Aberdeen and Peterhead, will take place at the expense of other areas of the region, especially the Banffshire coast.

Draft Response: Acceptance: Noted Changes to be made

Noted.

330 8 Subject Spatial Strategy Summary The comparative lack of house-building in Aberdeen in recent years as opposed to Aberdeenshire has resulted in significantly increased traffic congestion around the City, SCDI supports the aim of rebalancing housing supply in the region, with substantially more building in Aberdeen. A 50 -50 split in new development between the City and Shire seems to be reasonable. An expanded City should be supported by more effective public transport.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed. Public transport will be required to serve new developments.

330 9 Subject Spatial Strategy Summary SCDI is concerned that the reported rejection of Aberdeen Crossrail will to an extent undermine the Huntly-Laurencekirk strategic growth area. Should this be the case, it will be essential that as many of the benefits as possible of the original scheme are delivered, such as the construction of a new station and a passing loop at Kintore. Timetabling changes could increase the number of trains running between Inverurie and Stonehaven at peak times, and these must be published to commuters.

Draft Response: Acceptance: Accepted Changes to be made

The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service. Pursuing the Crossrail project is the responsibility of NESTRANS and they have made it clear that whilst the original concept cannot now be delivered, some key elements; opening of Laurencekirk Station, improved service between Inverurie and Aberdeen and a new Kintore Station are still viable and contained within the RTS (October 2008). 330 12 Subject Spatial Strategy Summary SCDI would like to have seen a little more thinking about how the Aberdeen city region will relate to the Inverness and Dundee city regions. The A96 corridor is also a priority for towns in Moray and the East Highlands. The north coast regeneration priority area should extend along the Moray coast to Buckie and Lossiemouth. Montrose is about the same journey time by road and rail from Aberdeen as the Huntly end of the strategic growth area. In preparing the final Structure Plan, the opportunities for co-ordination should be fully considered.

Draft Response: Acceptance: Partially accept Changes to be made

The SDPA has a statutory duty to consult neighbouring authorities and a response was received from Angus Council supporting the spatial strategy and housing allocations in the southern A90 corridor to help with affordable housing provision. The structure plan has no jurisdiction beyond the boundary determined for the Aberdeen City and Shire SDPA area, it will be for adjacent authorities to consider their own priorities and responses to individual areas. 330 13 Subject Spatial Strategy Summary All major developments require materials in the form of aggregates, minerals and other construction materials. The role of quarries must be properly recognized. These facilities must be allowed to expand to meet the substantial increase in demand for their outputs from domestic and overseas sources.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

Such a proposal would not be a strategic issue and the determination of specific planning applications is the role of the Development Management. Each proposal must be judged on its merits.

Rep. Number

14 January 2009 Page 161 of 244 331 3 Subject Spatial Strategy Summary The fundamental relationship which exists between land use, transport and human resources must receive higher emphasis.

We feel that the fourth stated aim to make the most efficient use of the transport network is inadequate and should be given higher profile, transport has always dictated the location of settlements. However, in the last 50 years, the use of vehicles had facilitated a dispersal of settlements which is no longer sustainable. Whilst this is acknowledged in the structure plan, the significance of transport and access have to be elevated to a higher level since in the future, it will again define settlement location and expansion, travel to work zones and indeed, the way in which we use town and cities.

The planning process has to be protected and redefine key parts of the infrastructure which will be required in future. One example of this is the continuing loss of filling station not only in rural areas but also in the city centre. Alternative fuels such as advanced diesel, LPG and hydrogen, make filling stations as essential part of the infrastructure.

Draft Response: Acceptance: Partially accept Changes to be made

These elements are intrinsic in the vision and aims of the plan and have been carried through into the six objectives forming the core principles of the plan.

The plan proposes 75-80% of all development in SGA's where the greatest choice of transport modes is available. As such, transport is one of the key considerations in the spatial strategy and its improvement a fundamental goal.

The protection of future infrastructure would be better dealt with at the local development plan level. However, it is not the place of the planning system to prevent the loss of private businesses such as petrol stations.

Rep. Number

333 6 Subject Spatial Strategy Summary We are worried that this plan has been written as a City centric plan and as such, other areas have received only a token mention. This is backed up by the 75 to 80 percent investment in Strategic Growth Areas proposal which we note is consistent with the councillors’ representative area within SGAs and with the location of presentations being given. This is clear abuse of democratic powers.

Draft Response: Acceptance: Do not accept Changes to be made

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan. The SGA's also represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services and hence the significant proportion of the development allocated. The SDPA consists of elected members from various wards and political parties and is there to represent the whole of Aberdeenshire equally. 333 10 Subject Spatial Strategy Summary We strongly oppose the concept of Strategic Growth Areas and regeneration areas. What you have achieved on suggesting this is creating a tiered society in terms of those who have and those who have not. We seriously question the legality of this type of selection policy.

This plan must be rewritten from an equitable position so that all areas are allowed to flourish under similar economic circumstances.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan has a responsibility to the whole north-east and must propose a strategy for development that balances the needs of each of these areas - this is what this spatial strategy aims to achieve. The three elements of the spatial strategy in the plan are in no way hierarchical, but enable an appropriate response to individual issues and circumstances. Improving the economic, environmental and social future of Fraserburgh is very important for the future of Fraserburgh itself and Aberdeenshire Council. The final paragraph on p.5 of the draft plan makes it clear that the importance given to each aim of the plan will be critical in coming to decisions on development proposals. In this respect, RPA status for Fraserburgh can influence the weight given to each aim, resulting in a positive impact that may not be appropriate in other areas. 333 11 Subject Spatial Strategy Summary In the initial period, we believe that more than half of the development is directed towards the City. As such we do not think that is appropriate. We should not be promoting Greenfield sites in the City when there is a plentiful supply of Brownfield sites in the Shire which are in greater need of the economic growth. Rather investment should be made in infrastructure which enables growth on a more equitable basis.

Draft Response: Acceptance: Do not accept Changes to be made

Correct, 18,000 units are shown for the City and 11,500 for Aberdeenshire in the first period. However, over the entire plan, 36,000 is allocated for each Council area, phased to make best use of existing and planned infrastructure. The level of growth anticipated cannot be achieved on Shire brownfield sites alone; this would severely constrain the social and economic development of the north-east. Brownfield sites will continue to receive the attention that they deserve, particularly in the RPAs.

14 January 2009 Page 162 of 244 333 12 Subject Spatial Strategy Summary We believe that there are other patterns which should have been drawn out for discussion in this plan beyond the corridor concept.

Draft Response: Acceptance: Do not accept Changes to be made

The corridors are only one of three elements of the spatial strategy; the others being local growth and diversification and regeneration priority areas. This approach was decided upon following consideration of a greater number of options and is believed to be the most appropriate solution, providing as it does the flexibility for Aberdeenshire Council through its local development plan to distribute the considerable level of allocations following consultation with communities. 333 13 Subject Spatial Strategy Summary The plan does not offer flexibility it simple ignores the opportunity to do something positive for the area which is badly in need of it. The primary focus of this plan is on the economic growth of the SGAs. We therefore reject the suggestion at the plan meeting that regeneration areas and SGs have equal priority.

Draft Response: Acceptance: Do not accept Changes to be made

The plan operates at the strategic level, where the role of individual settlements is not explored and level of growth is not imposed. This leaves Aberdeenshire Council the flexibility to determine the response to Fraserburgh (and other settlements) within the identified spatial strategy and to consider allocations on a case-by-case basis through the local development plan process. 333 14 Subject Spatial Strategy Summary We are very concerned about town being labelled regeneration areas. In itself thus simple devalues areas and exacerbates the problems. We are deeply concerned by the suggestion of new towns. This simple adds to our concern that regeneration areas are in essence forgotten areas. Better to build something new.

Draft Response: Acceptance: Noted Changes to be made

The residents of Fraserburgh appear well aware of its challenges and opportunities and the structure plan can assist by saying more about Fraserburgh in particular and regeneration in general. Presentation in a positive light and setting out the town’s potential role in attracting public sector funding will be highlighted.

A number of new settlement proposals were submitted in response to the draft plan. Some of these were in line with the plan’s strategy and some were not. However, none are at a stage where they could be given support through the structure plan. This issue will need to be addressed in the Action Programme so that decisions can be made in the strategic development plan.

Rep. Number

334 1 Subject Spatial Strategy Summary The vision is from Aberdeen City outwards and does not recognise some of the major economic drivers in the region farming, fishing, food, training, education, vehicles manufacture etc

Draft Response: Acceptance: Do not accept Changes to be made

The plan is a strategy for land use development across the entire north-east for the next 20+ years. It aims to provide an appropriate framework for development, with significant levels of growth in Aberdeenshire, but recognising the important role that Aberdeen plays as a regional centre. The plan is not intended to be the same as NEST and does not aim to 'tell a story', instead it has to be a focused, concise document in the spirit of the new planning act. 334 4 Subject Spatial Strategy Summary In theory, the Strategic Growth Areas give the impression of housing and industry on either side of the corridors but in practice this development will still be centred on existing settlements within the corridors. The corridor for development, the Strategic Growth Areas, should be replaced by a strategy for the development of exiting settlements throughout Aberdeenshire and of the links between.

Draft Response: Acceptance: Partially accept Changes to be made

The spatial strategy emerged after extensive consultation within the Council's and with communities and other stakeholders. It is not intended to promote ribbon development along each SGA, but does give Aberdeenshire Council the flexibility to look at all opportunities and scenarios when producing their local development plan. It is likely that the majority of development in SGAs will be as extensions to existing settlements as this allows for the use of established services and facilities and maintains the sense of community.

The local development plan will ultimately make informed decisions on site specific allocations and it should be noted that significant amounts of development are being made available for distribution outside the SGA's, in the AHMA and RHMA. Links between settlements are recognised as important and whilst the plan can influence this to a degree, the Council's local transport strategy is the more appropriate mechanism for pursuing any enhancements sought.

Rep. Number

14 January 2009 Page 163 of 244 336 9 Subject Spatial Strategy Summary The creation of an 80 20 split using the SGA principle for future development in the Shire will prejudice those areas not involved in a SGA and accordingly the SGAs principle should be scrapped.

Draft Response: Acceptance: Do not accept Changes to be made

The SGAs are located in accessible locations and in particular the Huntly - Laurencekirk corridor which is along the railway line. Areas outwith the SGAs will still have the potential to have development at an appropriate levels for local need. The shire has a significant level of growth proposed that is highly appropriate to meet the needs andaspirations of the area.

Rep. Number

346 4 Subject Spatial Strategy Summary Along with additional housing and population increase comes new pressures on infrastructure. While the plan refers to the provision of new schools, I believe there needs to be more detail on how new school provision will match new requirements. In the recent consultation processes on school closures it became clear that schools were being closed in areas where significant new housing is being proposed, and this strikes me as being a key weakness in the plan. Investment in facilities and services for both new and current communities is crucial in maintaining and improving the quality of life of those living and moving to Aberdeen and the Shire and if the plan is successful in increasing population there will hopefully be more demand for such services. However the fact is that services and facilities in the city are actually facing cuts and closure and I believe the plan does not sufficiently face up to this issue in its current form and this needs to be addressed if it to meet its goals for sustainable and long term growth in our area.

Draft Response: Acceptance: Do not accept Changes to be made

The plan recognises that additional services and facilities will be needed to serve the residents of new development. Many of these developments are likely to emerge in peripheral City locations away from central established residential areas where fewer school age children live, thus creating a shift in emphasis across the City. The full impact on the school estate will only be able to be determined once sites are identified through the local development plan process.

However, engagement during plan preparation has taken place with the relevant service in the City Council and it will be important that this continues through the local development plan process.

Rep. Number

349 3 Subject Spatial Strategy Summary The Group is broadly supportive of the spatial strategy as outlined in the draft Plan, subject to the recommendations contained within this response.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

350 8 Subject Spatial Strategy Summary With relation to the grid reinforcements Fraserburgh and the surrounding area desperately need diversification of its economy and renewable energy development would have been a marvellous way to do this but this aspect is in the SGA for Peterhead/ Aberdeen. A similar argument can be used for the Energetica Project.

Draft Response: Acceptance: Partially accept Changes to be made

That Fraserburgh need to diversify its economy is recognised and supported by the draft plan. Grid reinforcement is unrelated to the strategic growth areas but is identified in the National Planning Framework to enable renewable energy to connect to the grid throughout Aberdeenshire and beyond. Fraserburgh stands to gain from this as well as other areas.

14 January 2009 Page 164 of 244 350 12 Subject Spatial Strategy Summary Fraserburgh is officially described as one of the worst areas for urban deprivation whose youngsters need extra provision to escape the problem situations they find themselves in and break the cycle. Under this plan, there will be a poorer chance quality of education and much fewer jobs opportunities which will militate against their chance of success.

Draft Response: Acceptance: Do not accept Changes to be made

Fraserburgh is the second largest town in Aberdeenshire and continues to be a major shellfish and white fish port. The dependence on the fishing industry has resulted in a fragile local economy and its distance from Aberdeen (40 miles) and Peterhead (17 miles) means that it faces a number of significant social and economic challenges.

A number of regeneration and ATP projects have been ongoing for some time and a whole package of measures will need to continue to be pursued. The structure plan must be clear in the specific, strategic land use elements that it can directly influence. As such, the objectives apply equally to all areas of the plan and encourage economic growth and mixed use developments that meet the needs of the whole community. The plan also emphasises the need to develop better links within and to the north-east and improve public transport provision.

The spatial strategy recognises the circumstances in Fraserburgh (and other similar communities) through their dual designation as regeneration priority areas and areas for local growth and diversification. These designations provide flexibility for the Aberdeenshire local development plan (LDP) to respond accordingly, with relevant policies and proposals. Also importantly, the LDP will have complete autonomy to promote the reuse of brownfield land and to designate a proportion of the significant level of residential allocation made to the RHMA and an appropriate amount of employment land.

The initial preparation for production of the LDP has begun and further work will be undertaken throughout 2009, this will involve community council’s and other representatives, local businesses and individuals with an interest. Consultation will be key to ensuring the framework set down by the structure plan is translated into realistic LDP policies and allocations and tangible proposals are delivered for Fraserburgh.

The three elements of the spatial strategy in the plan are in no way hierarchical, but enable an appropriate response to individual issues and circumstances. Improving the economic, environmental and social future of Fraserburgh is very important for the future of Fraserburgh itself and Aberdeenshire Council. The final paragraph on p.5 of the draft plan makes it clear that the importance given to each aim of the plan will be critical in coming to decisions on development proposals. In this respect, RPA status for Fraserburgh can influence the weight given to each aim, resulting in a positive impact that may not be appropriate in other areas.

The residents of Fraserburgh appear well aware of its challenges and opportunities and the structure plan can assist by saying more about Fraserburgh in particular and regeneration in general. Presentation in a positive light and setting out the town’s potential role in attracting public sector funding will be highlighted.

Rep. Number

356 4 Subject Spatial Strategy Summary Favour towards completing a 'new town' to absorb population expansion if necessary. Advantages include developing a 'package' with all necessary social amenities and not overburdening those of existing places. Suggested Kinaldie as a possible location.

Draft Response: Acceptance: Noted Changes to be made

A number of new settlement proposals (but not at Kinaldie) were submitted in response to the draft plan. Some of these were in line with the plan’s strategy and some were not. However, none are at a stage where they could be given support through the structure plan. This issue will need to be addressed in the Action Programme so that decisions can be made in the strategic development plan.

Rep. Number

14 January 2009 Page 165 of 244 361 3 Subject Spatial Strategy Summary Concentrating a spatial strategy on major public roads does not necessarily make development more sustainable as transport can be only one aspect of social, economic and environmental considerations.

The process of creating 3 strategic growth areas is questionable as it does not appear to have been realistically tested against any stated sustainability criteria.

The infrastructural capacity of rural settlements may not be able to cope with the proposed increases in population and development.

The strategy suggests that settlements outside SGAs may be marginalised in relation to future growth and investment and appears to be confirmed in the paragraph headed 'Outside strategic growth area'. A tiered approach for inward investment for all settlements is required based on their infrastructural capacity for expansion and on the application of a reliable checklist of sustainability.

Draft Response: Acceptance: Partially accept Changes to be made

The spatial strategy has the potential to be more sustainable if based on these corridors as it offers the opportunity to use the most frequent and accessible public transport modes (bus and rail) and concentrate development instead of widespread dispersal, which would encourage greater car useage.

Accept that overall sustainability will involve many more criteria, such as environmental protection, layout, design and build approach, access to services and facilities etc. These are all referred to in the plan and will be pursued through the local development plans and other supplementary planning guidance.

Rural settlements will only be considered for 'local growth and diversification' scale development, this aims to support local services and serve other local needs.

The strategy has little bearing on inward investment, apart from that developer contributions will be utilised to mitigate against the impacts of new development and provide necessary infrastructure. 361 4 Subject Spatial Strategy Summary There does not appear to be adequate justification for the 50% split of future growth between Aberdeen City and Aberdeenshire. Suggestion that 75% growth in the city is more appropriate to prevent population decline and commuter congestion.

Designating land as green belt around the city and expanding satellite settlements in close proximity to the green belt is not a sustainable proposal. It would only exacerbate the trend of moving away from the city and into rural settlements where property is cheaper thus leading to increased commuting into employment areas in the city and increasing traffic congestion on the city’s arterial roads at peak time.

SPP21 says that strategic development plans will consider the issue of need for green belts and this does not appear to have been done in the plan.

Sustainability of new development should be at the core of any growth policy.

Draft Response: Acceptance: Partially accept Changes to be made

The 50/50 split is deemed equitable and justified on the basis of allowing each area to grow to the same degree. To raise this to 75% would burden the City with unrealistic levels of development, when the amounts proposed are much higher than in recent years. It would also restrict the growth of Aberdeenshire unnecessarily.

The retention of a green belt around Aberdeen is of fundamental importance, although the plan recognises that it will need to be reviewed to accommodate the levels of growth proposed. Commuting is an issue that will continue to exist, but the spatial strategy will allow choice of modes and the integration of land uses sought in the plan will counter this somewhat.

The plan has considered the issue of need and maintains in the 'quality of the environment' section that the green belt has a "vital role to play".

Sustainability is highlighted as one of the main aims of the plan on p.5. 361 8 Subject Spatial Strategy Summary The sustainability of new development should be at the core of any growth policy. Options for growth should be the subject of a test for sustainability using nationally recognised sustainability criteria rather than based on a theoretical model.

Draft Response: Acceptance: Partially accept Changes to be made

Sustainability is highlighted as one of the main aims of the plan on p.5. Beyond the level of the spatial strategy, the allocation of specific sites will be determined within the local development plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

14 January 2009 Page 166 of 244 361 9 Subject Spatial Strategy Summary The balance is not clear: - There does not appear to be adequate justification for the 50% split of future growth between Aberdeen City and Aberdeenshire. - Designating land as green belt around the city and expanding satellite settlements in close proximity to the green belt is not a sustainable proposal. It would only exacerbate the trend of moving away from the city and into rural settlements where property is cheaper thus leading to increased commuting into employment areas in the city and increasing traffic congestion on the city’s arterial roads at peak time. - Suggestion that 75% growth in the city is more appropriate to prevent population decline and commuter congestion.

Draft Response: Acceptance: Do not accept Changes to be made

In 2007 the split of households between Aberdeen City and was 50.5% and 49.5%, while in terms of dwellings the figures were 50.9% and 49.1%. The background research for the plan clearly established that development in or close to Aberdeen had significant benefits. In light of these factors, a split of new developments around the 50/50 level was deemed appropriate as a basis for the structure plan.

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Development in Aberdeen is seen as critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

The suggested 75% would create an imbalance in the Shire and an over-provision in the City, which is already poised to take significantly more development than in recent years.

Rep. Number

366 2 Subject Spatial Strategy Summary Queried whether the issue of the number of people who will choose to leave the area if housing development on the scale proposed takes place had been taken into consideration.

Draft Response: Acceptance: Noted Changes to be made

No, this has not been considered and fail to see why this would be a consequence.

Rep. Number

368 4 Subject Spatial Strategy Summary A new town is the only sensible solution for 6000 homes and should be located along the AWPR road or at Laurencekirk or Drumlithie to the south (a number of reasons for these locations are given)

By creating a new town infrastructure that meets the towns requirements can be put in place instead of creating further problems within existing towns.

Draft Response: Acceptance: Noted Changes to be made

A number of new settlement proposals (but not near Laurencekirk / Drumlithie) were submitted in response to the draft plan. Some of these were in line with the plan’s strategy and some were not. However, none are at a stage where they could be given support through the structure plan. This issue will need to be addressed in the Action Programme so that decisions can be made in the strategic development plan.

Rep. Number

375 2 Subject Spatial Strategy Summary Split of 50% to City and Shire is not logical.

There is no reason to suggest that the trend towards rural living away from the city will change especially as this is a national trend and suggests social engineering. Supporting documents show that GROS recognises the trend however this fact is ignored in the draft plan. Additionally destruction of the greenbelt will occur as the plan shows that nearly 30% of the regions total housing requirement is planned for the city greenbelt. This will encourage the trend towards the Shire.

Draft Response: Acceptance: Do not accept Changes to be made

The 50/50 split is deemed equitable and justified on the basis of allowing each area to grow to the same degree. To do otherwise may burden the City with unrealistic levels of development, when the amounts proposed are much higher than in recent years, or could restrict the growth of Aberdeenshire unnecessarily.

By creating sustainable mixed communities in close proximity to the City, where there is a recognised shortage of family housing, it is expected that the trend for moving to the Shire will be reduced or reversed. The green belt will have to be reviewed to accommodate the level of housing proposed and this is explicit in the plan.

14 January 2009 Page 167 of 244 375 6 Subject Spatial Strategy Summary Reserve some of the strategic developments for areas other than SGAs?

Draft Response: Acceptance: Partially accept Changes to be made

The plan acknowledges on p.8 that "in some cases developments which aim to meet the needs of the City region may need to be on a specific site. If this is not in an identified strategic growth area, we will need justificiation for this development against the aims, objectives and targets of the plan." This statement makes provision for other scenarios. 375 7 Subject Spatial Strategy Summary A percentage of housing and business land allocation should be held back ready to be released when necessary as a precaution against over-optimistic economic and housing targets.

Draft Response: Acceptance: Partially accept Changes to be made

The plan promotes a phased approach to development of residential and employment land, albeit that this is based on high growth scenarios and an element of front-loading. Given the current economic difficulties it is difficult to predict the rate that developments may proceed at, but the first plan period goes to 2016, by which time things should be much more positive. The development planning process requires all plans to be regularly reviewed and this affords the opportunity to reconsider any external factors.

Rep. Number

377 3 Subject Spatial Strategy Summary Would like to see extra highlighting of certain words within the spatial strategy (details given).

Draft Response: Acceptance: Do not accept Changes to be made

Your point has been noted, however it has been decided not to highlight the section as this could impact on the clarity of the document.

377 7 Subject Spatial Strategy Summary Infrastructure of the area must go hand in hand with the structure strategy.

Draft Response: Acceptance: Accepted Changes to be made

This is expected at the strategic level throughout the plan area and also in relation to particular development proposals.

Rep. Number

383 2 Subject Spatial Strategy Summary New Town

I believe the best solution for the number of houses within the plan should be to create a new town somewhere on the AWPR road. By creating a new town you would be able to build the infrastructure that meets the towns requirements and not create further problems within the existing towns.

Draft Response: Acceptance: Partially accept Changes to be made

A number of new settlement proposals were submitted in response to the draft plan. Some of these were in line with the plan’s strategy and some were not. However, none are at a stage where they could be given support through the structure plan. This issue will need to be addressed in the Action Programme so that decisions can be made in the strategic development plan.

Rep. Number

14 January 2009 Page 168 of 244 385 1 Subject Spatial Strategy Summary I find the plan contradictory and misleading in its treatment of the growth expected in Banchory.

Banchory is not designated as being within a strategic growth area. As such it is not expected to benefit from capital expenditures to the same extent as towns like Peterhead,Ellon,Huntly and the city of Aberdeen.

On a per head of population basis Banchory has an allowable housing expansion over the next 10 years which is approximately four of five times greater than any of the above-mentioned towns and one of the two greatest housing expansions in the Shire.

The structure plan targets that 75 to 80% of the growth in the region will be targeted to strategic growth areas and that in excess of 50% of the long-term growth will be in the city of Aberdeen.

Banchory is designated as a local growth and diversification area: in such areas "levels of growth in individual settlements should relate to local needs" according to the plan. This is not consistent with allowing 1700 new houses to be built in Banchory over the period 2007-2016. Either this growth in new houses should be reduced (my preference) or Banchory should enjoy an improved infrastructure as a result of an increase in its population.

Draft Response: Acceptance: Partially accept Changes to be made

The exact meaning of the response is not entirely clear. However, Banchory is not designated for strategic growth and will only receive a proportion of the total number of homes identified for the LG&DA (AHMA). It should be noted that it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

392 1 Subject Spatial Strategy Summary The concept of corridors is misleading and gives the impression that industry and housing will be developed alongside these routes. This, in practice, will not happen and expansion would still be developed in established settlements.

It may indeed be advantageous to develop where existing facilities are available ie Peterhead Bay, but the plan should concentrate on what advantages each settlement has available. The current proposal is focused from Aberdeen outwards, based largely on a one horse industry concept for the future. Aberdeenshire has a much wider economy in farming, fishing, training and tourism, and the corridor concept does not in any way do this justice.

Draft Response: Acceptance: Do not accept Changes to be made

The corridor concept has been devised for a number of reasons. One of those is to allocate a strategic level of development that can then be broken down into specific proposals by the local development plan. Whilst it is expected that the majority of growth in SGA's will relate to existing towns and villages, there is scope in the plan for alternative proposals to be considered - this will be done as part of the local development plan process.

Allocations will be made on a site-by-site basis and this will involve extensive consultation and site selection will be based on a significant number of criteria. Aberdeen is recognised as the core of the region and its geographic centre and the road and rail network passes through it, in this respect corridors may be perceived to flow outward. But, each is inter-dependent on the other, so could be perceived either way. No one industry is mentioned, it is recognised that diversification is important as is growing tourism and our knowledge base.

Rep. Number

394 1 Subject Spatial Strategy Summary Does not agree with the proposed spatial approach.

The strategic growth corridors from Aberdeen to Peterhead and Huntly will lead to the economic isolation and stagnation of Aberdeenshire North’s four major settlements, namely Fraserburgh, Macduff, Banff and Turriff. That legacy must not be allowed to be handed to our descendant, and is unacceptable in the face of the challenge to build a low-carbon economy.

Draft Response: Acceptance: Do not accept Changes to be made

Would refute the claim that the spatial strategy will lead to economic isolation and stagnation of areas outwith SGA's. Outside the SGA's no upper limit is given for the provision of business land, this is not a strategic issue for this plan, but is better addressed in the Aberdeenshire LDP. It's exclusion from this plan gives maximum flexibility and opportunity for local need in individual settlements, but may also promote a more innovative approach also.

14 January 2009 Page 169 of 244 394 2 Subject Spatial Strategy Summary Alternative approach is suggested:

The wide geographical spread of Fraserburgh, Macduff, Banff and Turriff, with existing inadequate transport links to the South and North, will require innovative proactive Enterprise Zones to be established in each of the four settlements to encourage economic growth. Regeneration of brownfield sites, as proposed in the draft structure plan, is insufficient resource as a stand alone policy.

The proposed spatial approach strategy will certainly increase commuter flow from Aberdeenshire North’s four main settlements to and from employment within the S.G.A. corridors. Adopting an interconnected enterprise zone strategy in Aberdeenshire North would enable workers to remain within their local area, finding employment in the new technology industries. That effect would reduce the volume of road traffic and help reduce carbon monoxide emissions. Regeneration of the settlements would follow, reversing the trend of living in the countryside with disappearing basic facilities; such as shops, post offices and primary schools.

Enterprise Zones The strategic objective would be to build on the existing strength of each settlement’s economy. Develop Enterprise Centre’s of Excellence with new industry relevant to that settlement.

Centres of Excellence Diversification into renewable energy can lead to new industry and employment. For example: -Turriff - Agriculture and woodland can be linked with biofuels: Develop carbon neutral industrial plant co-operatives where farmers have incentives to invest and increase yield.

- Fraserburgh - Fishing and food processing can be linked to new food products, with new market opportunities. Climate change is attracting Mediterranean fish species to our shores.

Draft Response: Acceptance: Partially accept Changes to be made

A whole package of measures will be needed to ensure the economic competitiveness of the principle north Aberdeenshire towns. The structure plan must be clear in the specific, strategic land use elements that it can directly influence. As such, the objectives apply equally to all areas of the plan and encourage economic growth and mixed use developments that meet the needs of the whole community. The plan also emphasises the need to develop better links within and to the north-east and improve public transport provision.

The spatial strategy recognises the circumstances in Fraserburgh, Macduff and Banff through their dual designation as regeneration priority areas and areas for local growth and diversification. These designations provide flexibility for the Aberdeenshire local development plan (LDP) to respond accordingly, with relevant policies and proposals. Also importantly, the LDP will have complete autonomy to promote the reuse of brownfield land and to designate a proportion of the significant level of residential allocation made to the RHMA and an appropriate amount of employment land. It may also examine innovative approaches to economic growth.

The initial preparation for production of the LDP has begun and further work will be undertaken throughout 2009, this will involve community council’s and other representatives, local businesses and individuals with an interest. Consultation will be key to ensuring the framework set down by the structure plan is translated into realistic LDP policies and allocations and tangible proposals are delivered. 394 3 Subject Spatial Strategy Summary Experts predict that there is only 40 years of oil left (Dynamic Earth, Glasgow). There is compelling evidence of global warming with high levels of carbon dioxide in the atmosphere caused by burning of fossil fuels. Between now and 2020 short-term changes will be no more than inconvenient. In the longer term sea-level will rise. We can reduce carbon emissions in Aberdeenshire by reducing use of automobile transport to and from the workplace before the oil runs out by 2040.

Draft Response: Acceptance: Noted Changes to be made

Noted, the plan identifies sustainable development and climate change as a main aim.

Rep. Number

397 3 Subject Spatial Strategy Summary Generally agree with this approach.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

14 January 2009 Page 170 of 244 397 7 Subject Spatial Strategy Summary For a new settlement to have any chance of meeting the plan’s vision of a "high quality of life", it would need a huge initial investment in facilities since it would begin with none at all.

Page 7 of the draft already alludes to the high cost of the proposals, and a new settlement would be an expensive solution.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. Such a development would have to be on a scale that could help fund and support the wide range of services and facilities needed and makes these viable in the long term. It cannot be known at this stage if a new settlement would be more expensive than extensions to existing settlements where local services are stretched. It will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

412 6 Subject Spatial Strategy Summary Are the houses in the right place? Reading the press it looks like there is a need for more housing and development at Ellon and Fraserburgh, and with the new station in Laurencekirk there is scope for more development there - and land

Draft Response: Acceptance: Partially accept Changes to be made

It is agreed that allocations in the Ellon area could increase in later plan periods. Fraserburgh has the potential to draw on significant allowances of new housing in the Rural market area already. There are significant allowances in the Laurencekirk area already.

Rep. Number

419 4 Subject Spatial Strategy Summary Another area for concern is the Spatial Strategy.

Aberdeen will always be the major centre of employment. The majority of people living outside Aberdeen commute on a daily basis to Aberdeen.

Currently the transport infrastructure both public and private is below the standard that would be required in the statement of Sustainable development and Climate change let alone after the amount of planned new housing is build.

Examples are: - no railway line north of Aberdeen (the Aberdeen - Peterhead growth area). - only single-track railway towards Huntly with timetables not reflecting the flexibility needed for commuting towards Aberdeen. - road network needs further improvements already with the current population and a result of this is that a lot of people are using the minor roads to avoid the congestion leading to dangerous driving conditions and excessive road surface wear.

The Plan doesn't really address any of these issues.

Draft Response: Acceptance: Partially accept Changes to be made

The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service.

The plan is working with NESTRANS and Transport Scotland to ensure that development is broadly in line with committed projects such as AWPR, A90 Balmedie to Tipperty upgrade, opening of Laurencekirk Station and other projects being promoted, such as Third Don Crossing and Haudigan improvements and Laurencekirk grade separated junction. Further information is provided in the Background Paper.

Rep. Number

425 2 Subject Spatial Strategy Summary Spatial strategy emphasises the city centred impression by creating commuting corridors that could otherwise be seen as arteries draining the life out of Aberdeenshire to support an over dominant city and without an over dominant city the future would be impoverished or uncertain.

Draft Response: Acceptance: Do not accept Changes to be made

The City and Shire are dependent on each other and the corridors could as easily be seen as bringing the development opportunities that would otherwise be confined to the City out into Aberdeenshire. The creation of employment sites at Westhill and Portlethen and concept of employment led development in the Blackdog to Peterhead corridor all reduce the 'dominance' of the City.

Rep. Number

14 January 2009 Page 171 of 244 426 3 Subject Spatial Strategy Summary Agree with spatial strategy three strands approach as an appropriate response to the future of the area, but the developments in growth areas or otherwise will be under the control of developers or public money. There is nothing new in terms of a mechanism to make these stated desirable things happen.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The quality of development is expected to improve and masterplans and initiatives such as SSCI will ensure this irrespective of whether it is a private or public sector development. 426 8 Subject Spatial Strategy Summary A new settlement could have a role to play in delivering the plan, but that would really take courage and confidence, and it has been talked about for 30+ years.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. However, the allocations in Schedule 1 would only allow a new settlement in the corridors from Aberdeen to Inverurie or Aberdeen to Stonehaven. 426 17 Subject Spatial Strategy Summary Came across the term ‘city region’ for the first time in this document.

Could cope with city region for the Aberdeen Housing Market Area, but, when it includes areas beyond Huntly and Turriff, people will be seriously disadvantaged.

Drop it before there is harm done.

Draft Response: Acceptance: Do not accept Changes to be made

The term 'city region' has been coined by the Scottish Government and refers to the geographic area covered by the four SDPA's in Scotland; for the north-east this is Aberdeen City and Aberdeenshire (excluding the Cairngorms National Park). It is enshrined in legislation and has no sinister or negative meaning. By removing the areas beyond Huntly and Turriff these communities would not form part of the structure plan and would arguably feel more disadvantaged. 426 18 Subject Spatial Strategy Summary Queried why the strategic growth areas are defined as they are. Suggests a commuting policy which will continue to bring pressures to these areas.

If there were to be any support for the new settlement proposal, it could not realistically be located anywhere else - unless more money is invested in infrastructure

Draft Response: Acceptance: Partially accept Changes to be made

The strategic growth areas follow the trunk roads and main public transport and rail connections. This recognises that commuting will remain a feature of the north-east, but at the same time encouraging mixed use development to provide maximum choice.

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale. However, the allocations in Schedule 1 would only allow a new settlement in the corridors from Aberdeen to Inverurie or Aberdeen to Stonehaven.

Rep. Number

14 January 2009 Page 172 of 244 429 1 Subject Spatial Strategy Summary Agree the spatial strategy will help the transport, schools and infrastructure problems, but will create linear effects or communities spreading. The green belt should be preserved, i.e. the City should not spread northwards or southwards, but go westward. Do not want Aberdeen to spread to Balmedie, Potterton, Belhelvie or Ellon, but should go west, keeping as much of the GB as possible.

In Aberdeenshire the existing identity and boundaries of towns and villages should be kept.

In regeneration areas, more trees should be planted and sand dunes preserved.

Draft Response: Acceptance: Noted Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped. It will be for the local development plan to determine exactly where development takes place and on what scale.

The plan aims to maintain the character of exisitng settlements, but cannot allow growth whilst keeping existing boundaries.

Regeneration applies to the main settlements in the identified areas, in environmentally sensitive coastal areas the planting of trees and preservation of sand dunes are not a structure plan issue.

Rep. Number

440 1 Subject Spatial Strategy Summary Difficulty with terminology, not explained in the glossary.

Draft Response: Acceptance: Do not accept Changes to be made

"Spatial strategy" is not included in the glossary, but is covered in great detail on p.6-8.

Rep. Number

441 3 Subject Spatial Strategy Summary Agrees with approach of the Spatial Strategy and the proposals in principle.

Accept the need to apply a comprehensive programme of regeneration in some areas, but question whether this is within the resources of the local authority.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The structure plan promotes the regeneration of the identified areas and will give further guidance on this. However, accept that the plan is only a small part of achieving regeneration aspirations and other agencies and stakeholders will have to work together.

Rep. Number

449 3 Subject Spatial Strategy Summary Fig.2 is alarming, far too much concentration on a small area while the rest of the county is neglected. Doubt if the City can absorb that level of growth and the people of Inverurie etc. are already swamped, growth must be extended to other settlements.

New settlements would be artificial. Growth should always be on existing settlements which already have a heart.

Draft Response: Acceptance: Do not accept Changes to be made

The spatial strategy has been subject to considerable consultation since October 2006 and outside the SGA's still allows for around 25% of the overall development. However, it will be for the local development plan to determine exactly where development takes place and on what scale.

The structure plan does not mention a new settlement, but does not preclude one either. There is an argument that a new town would mitigate some of the impacts of incremental growth of established towns and villages, by planning several thousand homes and all the services and facilities they need from scratch.

Rep. Number

14 January 2009 Page 173 of 244 451 3 Subject Spatial Strategy Summary Recognises need for strategic growth areas but does not want local growth and diversification areas to be prejudiced if sensible proposals for these areas are put forward.

Draft Response: Acceptance: Partially accept Changes to be made

The spatial strategy still allows for significant levels of growth in the LG&DA, but these must continue to be plan led wherever possible. It will be for the local development plan to determine exactly where development takes place and on what scale. 451 7 Subject Spatial Strategy Summary Better to concentrate on existing communities than create new ones.

Draft Response: Acceptance: Noted Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. There is an argument that a new town would mitigate some of the impacts of incremental growth of established towns and villages, by planning several thousand homes and all the services and facilities they need from scratch.

Rep. Number

452 5 Subject Spatial Strategy Summary Agree with the division of development opportunities between Aberdeen City & Shire.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcomed.

452 6 Subject Spatial Strategy Summary No preference given to potential alternatives on p.22 although consideration must be given to associated needs of transport infrastructure, schools and retail.

Draft Response: Acceptance: Noted Changes to be made

Noted, but the alternatives presented in Schedule 1 of the draft plan were intended to stimulate debate, which they have done. No alternatives will appear in the final plan. 452 7 Subject Spatial Strategy Summary Developers need clearer instruction rather than 'guidance' to preserve identity and landscape of local areas.

Draft Response: Acceptance: Accepted Changes to be made

This will be provided in the form of two local development plans and where appropriate supplementary planning guidance.

452 8 Subject Spatial Strategy Summary Agree that the right places have been selected as, 'regeneration priority areas' but unclear as to what is covered by a 'mix of uses' (section 3, paragraph 2)

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. Mix of uses refers to integration of employment, community (schools, healthcare etc.) and residential uses on the same site where appropriate.

14 January 2009 Page 174 of 244 452 9 Subject Spatial Strategy Summary Important to look inward and develop city housing by developing vacant building and spaces. This will put less pressure on the travel network.

The development of new settlements may have negative affect on other established less attractive settlements.

Draft Response: Acceptance: Partially accept Changes to be made

In the City, 40% of new housing is proposed on brownfield sites, this will amount to several thousand homes.

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and to ensure no negative impact on neighbouring settlements occur.

Rep. Number

455 1 Subject Spatial Strategy Summary The plan does not include any real strategy for growth for the area, yet forecasts a large increase in population even though population has declined in recent years.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan proposes growth in the number of homes in the north-east and growth and diversification of the economy; from these elements it is hoped that population growth will follow. 455 3 Subject Spatial Strategy Summary It is important to consider the Cairngorms National Park within the plan because the largest part of the park falls within the Aberdeenshire local authority. Although the park has its own planning strategy the strategic plans for Aberdeen & Shire should fit with those of the park. This will improve quality of life for residents and add an extra dimension to the visitor’s experience.

Draft Response: Acceptance: Partially accept Changes to be made

The SDPA area does not extend into the CNP and this has been accepted by the Scottish Government. However, it is acknowledged that these artificial boundaries do not impede the passage of people, goods or environmental issues, in the same way that Angus and Moray border the SDPA. The plan highlights River Basin Management Plans and other strategic issues, but it will be for local development plans and supplementary planning guidance to consider renewable energy developments or other potential impacts.

Rep. Number

458 2 Subject Spatial Strategy Summary The main focus of the spatial strategy is to create modal change from road to rail from Huntly to Laurencekirk and to lesser extent along the Aberdeen to Peterhead Corridor - No evidence that this modal shift will work. This assumption could indeed cause more congestion along restricted arteries.

Development shouldn’t be restricted to corridors.

Draft Response: Acceptance: Partially accept Changes to be made

The main focus of the plan is to deliver development to facilitate sustainable growth in the best possible locations. From this, the spatial strategy has emerged with a preference for around 75% of new development in SGA's. There can be no certainty that this will work, but the conditions should be in place in the form of transport infrastructure improvements and greater mixed use developments that reduce the need to travel.

A significant amount of development is proposed for the areas outwith the SGA's as can be seen in Schedule 1. 458 3 Subject Spatial Strategy Summary Projects such as the crossrail network and the AWPR at time of writing have no guarenteed funding.

The level of dependance of the Spatial Strategy on these projects should be clarified.

Draft Response: Acceptance: Do not accept Changes to be made

The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service. Crossrail is now to be delivered in a number of smaller projects over a period of time instead of together, this will increase the number and frequency of trains between the south and Inverurie and reopen Laurencekirk Station. The AWPR PLI recently finished and the outcome is awaited, although the principle is established.

The spatial strategy is reliant on the completion of the AWPR in particular to improve access from the north.

14 January 2009 Page 175 of 244 458 4 Subject Spatial Strategy Summary Underlying presumption towards land-use based zoning implicit in parts of the draft plan. Land-use zoning is a largely outdated model which does not promote sustainable communities, encourages car use and absence of pedestrian orientated areas.

Draft Response: Acceptance: Do not accept Changes to be made

The plan allocates a sustantial number of homes and significant amount of employment land at the corridor level, but makes no provision for specific sites or any more detailed information. This will be the purpose of local development plans and supplementary planning guidance and until these have been undertaken, it is too early to consider whether the strategy promotes sustainable communities, reduces dependence on the private car and encourages walking and cycling.

Rep. Number

459 1 Subject Spatial Strategy Summary The plan is clear and aspirational however the city region concept is not justified. No research on how this strategy will affect the periphery of the region (lack of research backing up the vision. Statements with no justification, 'Aberdeen City and Shire has above average incomes' may be true of Aberdeen City, the two areas are split and this plan promotes the differential.

Promotes investment in a minority of areas which promotes inequality, migration and travel in and out with Aberdeenshire. Drivers for this type of investment should be reconsidered and a more balanced approach to economic development taken.

Draft Response: Acceptance: Partially accept Changes to be made

The plan is a strategy for land use development across the entire north-east for the next 20+ years. It aims to provide an appropriate framework for development, with significant levels of growth in Aberdeenshire, but recognising the important role that Aberdeen plays as a regional centre. The SGA's represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services.

Concentration of 75-80% of development in the SGAs will be more sustainable as it will deliver the critical mass of development to make new / improved services viable. 459 4 Subject Spatial Strategy Summary SGAs allow the remainder of Aberdeenshire to be neglected. Proposals include improving the economy and competitiveness of industry etc but there is no mention of how this will be achieved only mentions transportation. SGAs distract from encouraging uptake or brownfield sites for development.

Suggestion of 75-80% of development to take place in SGAs is without foundation although led to believe reason is planning gain for schools. Reject statement at public meeting that 75-80% investment was no higher a priority than the remaining regeneration areas investment.

Plan promotes use of greenbelt for development in city ignoring brownfield sites available in the shire. Investment required in shire subsidise business to utilize existing land available.

Draft Response: Acceptance: Do not accept Changes to be made

The area designated for 'local growth and diversification' (outside the SGA's) is allocated significant amounts of residential and unlimited amounts of employment land that can be distributed through the local development plan process. There is still a presumption in favour of the reuse of brownfield land, particularly in the identified regeneration area.

The key purpose of concentrating this scale of development in the SGA's is to allow people a wider range of transport choices in accessible locations where people want to live. The numbers proposed are anticipated to deliver the economies of scale needed to provide schools, transport upgrades and other services and facilities that a policy of dispersal could never achieve. In this respect investment will occur in the SGA's, but this will only only allow these to keep up with demand created by new development.

The plan must make judgements about the distribution of development, many sites in the countryside are isolated and brownfield would provide limited benefits. The plan does promote the reuse of brownfield sites in settlements in line with national policy.

14 January 2009 Page 176 of 244 459 5 Subject Spatial Strategy Summary Bias to city in terms of initial development - 61% to city in first 10 years.

Banff and Macduff not mentioned.

No need for new settlements, use existing brownfield sites. Aberdeenshire to be the focus in the short to medium term

Draft Response: Acceptance: Partially accept Changes to be made

Front-loading of City development is deemed necessary to 'catch-up' with recent lack of completions and resulting problems this creates. Over the entire plan period the same number of homes will be allocated, but these must be phased as reflected in Schedule 1.

These settlements are identified in the key diagram and designated for local growth and diversification and as regeneration priority areas. Many, many settlements do not get a specific mention in this document, but the local development plan will rectify this.

The structure plan does not mention a new settlement, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

462 3 Subject Spatial Strategy Summary Concerns over local growth and diversification areas not growing in relation to local needs. Worries that this does not exist presently.

Concerns over plans for 'new homes being designed to a high standard' when current building standards are not enforced. All building should be a least code 4 or 5 and affordable housing and housing to rent should be promoted.

Will car parks be placed in flood plains?

Concerns that economic interests damage environmental ones.

No need to encourage retail opportunities should support current NE businesses and local food markets.

Draft Response: Acceptance: Partially accept Changes to be made

Local development plans will have the primary role in assessing local need in consultation with local communities and other representatives.

The plan promotes higher standards and mixed tenures. Greater detail than this is not a structure plan issue.

Some development may be appropriate in flood plains, the plan makes it clear these should be "exceptional circumstances".

In planning, it is important to weigh up these often competing interests and come to a reasoned recommendation.

The plan promotes the use of the sequential approach in assessing retail development as national policy suggests.

Rep. Number

465 5 Subject Spatial Strategy Summary Transport Scotland fully support the two main aims of the plan. Whilst the principles of the plan are undoubtedly correct, Transport Scotland has a number of representations and objections, specifically:

TSC1 - TS has concerns with regard to the cumulative impact of development proposals on the strategic transport network. Encouraged that development is focused on areas where opportunities for public transport use are available, there needs to be a more full appraisal to allow an informed view to be taken.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan and spatial strategy in particular are interdependent on an effective and efficient transport system. The work done with Transport Scotland and close liaison with Nestrans has greatly benefited plan production. The recent workshop was another component of this consultation and further meetings will be held to ensure interventions can be identified as soon as practicably possible and fed into local development plans. There may still need to be a requirement for SPG to accommodate unforeseen eventualities.

It is proposed to publish an addendum to the Background Paper in due course to support the structure plan.

Rep. Number

14 January 2009 Page 177 of 244 467 1 Subject Spatial Strategy Summary Concerned about the designation of specific areas for additional development without identifying potential problems due to the proximity of major hazard sites and pipelines. This particularly affects existing industrial areas and Aberdeen and Peterhead harbour and those areas where pipelines run through what were rural areas in the 1970's, such as Laurencekirk, Westhill, Stonehaven etc.

Development areas within consultation distances of major hazard sites and pipelines will see restrictions on the types of development which can be made, this is already becoming a problem where developers are drawing up plans for new housing around Laurencekirk and Westhill. Pipeline operators can often relay sections of pipeline with thicker walled pipe, but this can cost millions.

Appreciate that much of this detail can be dealt with at the LDP, but there is a need to identify in this plan that health and safety issues may impact on the type and density of developments within the consultation distances of major hazard sites and pipelines. Reference should also be made to Article 12 of the Seveso Directive (Council Directive 96/82/EC) which requires planning authorities to maintain appropriate distances between major hazard sites and residential areas, areas of public use and areas of particular sensitivity or interest.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan is intended to operate at the strategic level, leaving more detailed assessments on sites and constraints to the local development plan.

This is not a structure plan issue.

This level of detail would also be inappropriate for a structure plan.

Rep. Number

468 3 Subject Spatial Strategy Summary Do not consider that the spatial strategy raises any significant issues for our interests as much will be dependent on the location detail of actual land allocations and can be most appropriately addressed at the LDP stage.

Draft Response: Acceptance: Noted Changes to be made

Noted.

Rep. Number

469 3 Subject Spatial Strategy Summary The concept of focusing development along existing transport corridors is sensible. However, it is important here to take full account of the natural habitats and biodiversity within these proposed SGA's and ensure their conservation. Currently, large areas of land are being lost to development with little in the way of compensation. A radical rethink of development within the area is necessary to tackle the very real challenges of the 21st C.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The structure plan is intended to operate at the strategic level, leaving more detailed assessments on sites and constraints to the local development plan.

Rep. Number

470 3 Subject Spatial Strategy Summary The SGA's need to be capable of accommodating the growth necessary to attract high value jobs and require the necessary levels of infrastructure and connectivity to sustain growth.

Concentrating growth in the three SGA's should not cause any detriment to other potential growth areas within the boundaries of the plan, particularly in areas where communities are well established. In addition, growth in these areas is dependent on improvements in transportation and any planned reduction in Government funded transport development will have a negative impact on targeted SGA's.

Draft Response: Acceptance: Partially accept Changes to be made

These elements are implicit in the plan.

This is a plan for the whole of the north-east and one area is not intended to benefit at the expense of another. The spatial strategy aims to provide a framework for development that the local development plan can respond to, to best meet the needs of individual communities. Transport improvements would greatly benefit delivery of the spatial strategy, but many of these are the responsibility of Transport Scotland and NESTRANS, with whom we have a close dialogue.

Rep. Number

14 January 2009 Page 178 of 244 472 3 Subject Spatial Strategy Summary This section is well documented and easily understood and there are obvious links to Community Planning. There could be more reference to the Community Planning Partnerships and the NE Joint Public Sector Working Group in the introduction section.

It will be important to give more cognisance to the infrastructure and available amenities in the areas identified for growth.

Draft Response: Acceptance: Partially accept Changes to be made

It is sufficient for this plan and for the purpose of brevity to retain the phrase "which the public and private sectors can work towards.." instead of explicit reference to the suggested groups.

The plan refers to this in several sections and aims to improve on past performance. 472 5 Subject Spatial Strategy Summary Any proposal for a new settlement would need careful consideration as there is much learning from new towns in Scotland that report social and economic difficulties. Their experience suggests such communities find it difficult to instill a feeling of ownership and responsibility among its residents, which can lead to higher crime rates and unemployment. Should such an approach be considered a viable option, considerable early collaborative intervention would increase the potential for a successful outcome.

Draft Response: Acceptance: Partially accept Changes to be made

The structure plan does not mention a new settlement, but does not preclude one either. There is an argument that a new town would mitigate some of the impacts of incremental growth of established towns and villages, by planning several thousand homes and all the services and facilities they need from scratch. The social and psychological aspects of creating such a community are somewhat beyond the scope of planning, although by designing discernable neighbourhoods, all the necessary infrastructure, access to quality open spaces, transportation links etc. the negative aspects as outlined could be minimised and some criminal activity prevented.

Should Aberdeenshire Council pursue a new settlement, it will be for them to co-ordinate the approach to be taken.

Rep. Number

476 3 Subject Spatial Strategy Summary Welcome the proposed spatial strategy and SGA's. SEG and ACSEF see the Aberdeen to Peterhead corridor as providing the opportunity for significant scale of development to accommodate growth and diversification in the energy sector.

Draft Response: Acceptance: Noted Changes to be made

The support for this aspect of the plan is welcome.

Rep. Number

482 2 Subject Spatial Strategy Summary To facilitate City growth and reverse decline, particularly to the Shire, the allocations should not be split equally and wording needs amended. Proposed changes to figures can be found in the representation. Wording on p.7 should state "Aberdeen City - just over half of all new development.." Target on p.8 should state "For at least 52%.." or "For just over 50%.."

Draft Response: Acceptance: Do not accept Changes to be made

The respondant gives no specific justification for the changes proposed to the strategic allocations, many of which appear to be 'tinkering' of the originals and not providing a well reasoned alternative. The total figure has dropped from 72,000 to 63,000 although it is not clear why and the split in the City between brownfield, greenfield and regeneration areas has not been given.

Rep. Number

184 3 Subject SS(LG&D) Summary Welcome the emphasis on expanding existing settlements.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 179 of 244 185 8 Subject SS(LG&D) Summary Support the levels of growth proposed in recognition of the need to encourage a range of developments.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The level of growth appropriate will be determined through the Local Development Plan process.

Rep. Number

186 8 Subject SS(LG&D) Summary Expansion at Old Leslie would be supported under this part of the Structure Plan..

Would however be preferable for the Structure Plan to give stronger direction for the Local Plans to ensure a range of settlement expansion.

Draft Response: Acceptance: Noted Changes to be made

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. This Structure Plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'. As expressed in the structure plan, the level of growth appropriate will be determined through the Local Development Plan process .

Rep. Number

188 2 Subject SS(LG&D) Summary Object to the limited allocation of housing within the Aberdeen Housing Market Area outwith the main SGAs.

There are a number of significant and sustainable settlements within the area, but under the draft plan these would only be capable of accommodating local growth.

In the past places like Banchory and Westhill have accommodated Strategic Growth and this has played an important part in the economy of the North East. In Westhill there has been business and industrial land too. Demand continues in the area with 25% of the population actually living and working in Westhill.

Draft Response: Acceptance: Do not accept Changes to be made

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

The level of growth appropriate will be determined through the Local Development Plan process. 188 8 Subject SS(LG&D) Summary An analysis of housing completions over the past 7 years in the Aberdeenshire part of the AHMA highlights approximately 900 units per annum on average, it demonstrates there will only be a 22 year supply. Currently 520 completions per annum in the RHMA equates to the equivalent of 31.5 years. This is an anomaly which requires to be addressed; the allocation does not reflect recent demand nor completion rates.

Other than the main settlements in the RHMA the main focus needs to be in the AHMA. This is where the existing settlements are already served by community facilities and relatively well established road and public transport links.

Draft Response: Acceptance: Do not accept Changes to be made

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

14 January 2009 Page 180 of 244 188 9 Subject SS(LG&D) Summary Western Peripheral Route (WPR) will provide benefits to the whole of the AHMA and not just the Strategic Growth Areas. These improvements will benefit main settlements which lie along road corridors that link directly to the WPR, ie Banchory (A93) and Westhill (A944).

Significant housing and employment land should be provided along these linked settlements.

Draft Response: Acceptance: Partially accept Changes to be made

The support, and provision, of infrastructure (including road and rail improvements) play a key role in assisting to deliver the plans vision and spatial strategy.

The inclusion of the proposal for the AWPR is one of a variety of proposals detailed within the plan in relation to infrastructure improvements which will help with the delivery of the plans vision to allow for improved access and connections to other places and to allow environmentally friendly methods of transport to be provided. 188 10 Subject SS(LG&D) Summary Given the benefits likely to be gained by the WPR, there are grounds for arguing that the Aberdeen City allocation should be spread over a wider area.

Recent experience ie Local Plan delay, suggests that there is a prospect the city will not be able to accommodate the scale of development.

Draft Response: Acceptance: Do not accept Changes to be made

The options for the spatial strategy were considered at considerable length and over-reliance on settlements in close proximity to the AWPR rejected. However, accessibility is a key objective and settlements will be judged on their merit as well as the spatial strategy chosen. The allocation of specific sites will be determined within the Local Development Plan process.

Aberdeen City Council is committed to achieving its proportion of the allocations set out in the plan.

Rep. Number

189 8 Subject SS(LG&D) Summary An analysis of housing completions over the past 7 years in the Aberdeenshire part of the AHMA highlights approximately 900 units per annum on average, it demonstrates there will only be a 22 year supply. Currently 520 completions per annum in the RHMA equates to the equivalent of 31.5 years. This is an anomaly which requires to be addressed; the allocation does not reflect recent demand nor completion rates.

Other than the main settlements in the RHMA the main focus needs to be in the AHMA. This is where the existing settlements are already served by community facilities and relatively well established road and public transport links.

Draft Response: Acceptance: Do not accept Changes to be made

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

190 8 Subject SS(LG&D) Summary An analysis of housing completions over the past 7 years in the Aberdeenshire part of the AHMA highlights approximately 900 units per annum on average, it demonstrates there will only be a 22 year supply. Currently 520 completions per annum in the RHMA equates to the equivalent of 31.5 years. This is an anomaly which requires to be addressed; the allocation does not reflect recent demand nor completion rates.

Other than the main settlements in the RHMA the main focus needs to be in the AHMA. This is where the existing settlements are already served by community facilities and relatively well established road and public transport links.

Draft Response: Acceptance: Do not accept Changes to be made

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

14 January 2009 Page 181 of 244 190 9 Subject SS(LG&D) Summary The location of Westhill make it unique to the role it performs. In recent years it has performed a Strategic role in terms of provision of employment and housing land. Though no railway it has excellent road links to the city, public transport and park and ride facilities furthermore it will benefit from the building of the WPR.

Over the past 5 years house completions have averaged 83 units per annum, exceeding completions in any other settlements outwith the main road and rail corridors but within the AMHA.

Westhill should be the focus of more than just local growth.

Draft Response: Acceptance: Do not accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. 190 10 Subject SS(LG&D) Summary In the absence of any increase in overall housing figures and the specific identification of Westhill it is contended that it should share part of the City allocation.

Given the benefits likely to be gained by the WPR, there are grounds for arguing that the Aberdeen City allocation should be spread over a wider area. Recent experience ie Local Plan delay, suggests that there is a prospect the city will not be able to accommodation the scale of development.

Draft Response: Acceptance: Do not accept Changes to be made

The options for the spatial strategy were considered at considerable length and over-reliance on settlements in close proximity to the AWPR rejected. However, accessibility is a key objective and settlements will be judged on their merit as well as the spatial strategy chosen. The allocation of specific sites will be determined within the Local Development Plan process.

Rep. Number

191 7 Subject SS(LG&D) Summary Additional housing should be allocated to the AHMA, settlements within this area are already well serviced by community facilities and relatively well established road and public transport.

An analysis of housing completions over the past 7 years in the Aberdeenshire part of the AHMA highlights approximately 900 units per annum on average, it demonstrates there will only be a 22 year supply. Currently 520 completions per annum in the RHMA equates to the equivalent of 31.5 years. This is an anomaly which requires to be addressed; the allocation does not reflect recent demand nor completion rates.

Draft Response: Acceptance: Do not accept Changes to be made

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

192 7 Subject SS(LG&D) Summary Additional housing should be allocated to the AHMA, settlements within this area are already well serviced by community facilities and relatively well established road and public transport.

An analysis of housing completions over the past 7 years in the Aberdeenshire part of the AHMA highlights approximately 900 units per annum on average, it demonstrates there will only be a 22 year supply. Currently 520 completions per annum in the RHMA equates to the equivalent of 31.5 years. This is an anomaly which requires to be addressed; the allocation does not reflect recent demand nor completion rates.

Draft Response: Acceptance: Do not accept Changes to be made

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

14 January 2009 Page 182 of 244 198 3 Subject SS(LG&D) Summary Further consideration needs to be given to the scale of permissible development within the AHMA but outwith the SGA's. In the LG&DA's is limited to local needs, however, there are a number of significant and sustainable settlements within that area that are capable of accommodating housing on a larger scale. In the past, many of these have accommodated levels of strategic growth; Banchory is such a location.

Draft Response: Acceptance: Partially accept Changes to be made

Banchory lies in the LG&DA (AHMA). This area is not designated for strategic growth, but may still experience growth in line with the spatial strategy. The spatial strategy does not identify particular settlements and the scale of development for them however there is provision for a significant scale of development outside of the SGA's. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on social, economic and environmental criteria and infrastructure requirements taking full account of local need.

An adjustment in some figures may be warrented.

Rep. Number

203 2 Subject SS(LG&D) Summary There is little mention in the plan of how housing allocations outwith the SGA's will be distributed. In particular, there are 12,400 houses over the three periods, representing approx. 34% of projected house-building and concern is expressed that they can fall anywhere in the RHMA with the exception of the SGA's around Peterhead, Huntly and Laurencekirk.

Draft Response: Acceptance: Noted Changes to be made

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. This Structure Plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'. The level of growth appropriate will be determined through the Local Development Plan process. 203 3 Subject SS(LG&D) Summary Support the headline figure allocated to the RHMA and the intention that new housing should be focused "in, or as an extension to, existing settlements, particularly those which are well served by public transport". Strongly suggest that the majority of allocations in the RHMA be directed towards 'main settlements' in order to secure confidence for developers and other bodies to commit to required levels of infrastructure investment. Directing development to larger settlements, such as Aboyne, is not only sustainable in terms of water, sewerage and transport, but gives increased critical mass to foster investment in public services, public transport etc.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. This Structure Plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'. The level of growth appropriate will be determined through the Local Development Plan process.

Rep. Number

205 6 Subject SS(LG&D) Summary Welcome the intention to focus "new housing in, or as an extension to, existing settlements, particularly those which are well served by public transport". A critical mass in communities allows health provision at a local level as well as securing necessary improvements in physical and community service infrastructure.

In the RHMA it is particularly important to focus development towards existing settlements with GP facilities that can sustain growth. The need to have easy access and minimise the need to travel is important to reduce emissions and the detrimental affect on health and wellbeing and to maintain a high level of emergency response to outlying settlements.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed. The structure plan allows for growth within small villages at an appropriate scale for that settlement. The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

This Structure Plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'. The level of growth appropriate will be determined through the Local Development Plan process.

Whilst desirable that all locations are served by public transport it is recognised that given the rural nature of Aberdeenshire this will not always be possible. The structure plan sets the framework for local and regional transport strategies which will provide higher levels of guidance.

Rep. Number

14 January 2009 Page 183 of 244 208 2 Subject SS(LG&D) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. However, greater emphasis is needed on the role of settlements (such as Alford) that lie outwith the SGA’s.

Welcome that the plan recognises the need to improve the area's communities and the services they depend on, However, suggest it is unrealistic to expect landowners to fund the majority of infrastructure improvements, especially in the current economic climate and the effect this has had on land values.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. Few settlements get explicit mention in the plan, but it can be seen that significant allocations are made to the LG&DA (RHMA) in which Alford lies, thus opportunities for local need will be made through the local development plan.

The current economic climate has little bearing on the medium to long-term prospects for development as developers have informed us. The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

210 2 Subject SS(LG&D) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. However, greater emphasis is needed on the role of settlements (like Newmachar) that lie outwith the SGA’s.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. Few settlements get explicit mention in the plan, but it can be seen that significant allocations are made to the LG&DA (AHMA) in which Newmachar lies, thus opportunities for local need will be made through the local development plan.

Rep. Number

211 2 Subject SS(LG&D) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. However, greater emphasis is needed on the role of market towns and major service centers (such as Oldmeldrum) that lie outwith the SGA’s.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. Few settlements get explicit mention in the plan, but it can be seen that significant allocations are made to the LG&DA (AHMA) in which Oldmeldrum lies, thus opportunities for local need will be made through the local development plan.

Rep. Number

214 2 Subject SS(LG&D) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors. However, greater emphasis is needed on the role of settlements that lie outwith the SGA’s.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed. Few settlements get explicit mention in the plan, but it can be seen that significant allocations are made to the LG&DA (in the AHMA and RHMA respectively), thus opportunities for local need will be made through the local development plan.

Rep. Number

215 2 Subject SS(LG&D) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Peterhead. Aware of work on Energetica and ask that it be more explicitly reflected in the final plan.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed.

Energetica is mentioned in three sections of the plan along with also being mentioned in the glossary. The glossary definfition is explicit and refers to who is promoting the initiative should further information be required.

Rep. Number

14 January 2009 Page 184 of 244 216 2 Subject SS(LG&D) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Peterhead. Aware of work on Energetica and ask that it be more explicitly reflected in the final plan. Achievement of the desired objectives will create a requirement for growth beyond Peterhead at the northern end of the corridor.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed.

Energetica is mentioned in three sections of the plan along with also being mentioned in the glossary. The glossary definfition is explicit and refers to who is promoting the initiative should further information be required.

Currently there are 4,400 houses proposed in the Aberdeen to Peterhead corridor which is a substantial allocation. However, an increase of 1,000 units in the Blackdog to Ellon corridor is proposed, taking the total allocation to 5,400 units. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects. There are no plans to increase the allocations at Peterhead, however the plan will regularly be amended to include improvements to the A90.

Rep. Number

233 3 Subject SS(LG&D) Summary Outwith the SGA's new development will have to be focused "in, or as an extension to, existing settlements, particularly those well served by public transport". SPP3 sets out far more clearly a new strategy for housing in rural areas; this is important in Aberdeenshire. In particular, para. 96-99 of SPP3 aims to support the rural economy, rural regeneration and embodies the principles of sustainable development.

Strongly suggest that a criteria based approach rather than static settlement boundaries is more appropriate for the rural areas and should be promoted through the plan.

Draft Response: Acceptance: Noted Changes to be made

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development. 233 4 Subject SS(LG&D) Summary Redevelopment of brownfield sites in the countryside should be supported.

The plan should be revised to reflect the concept of new housing in rural areas as set out in SPP3 in order that rural Aberdeenshire does not suffer from a lack of investment and begin to lose vital services. Suggest that the housing allocations across the RHMA are increased.

Draft Response: Acceptance: Do not accept Changes to be made

The glossary defines brownfield sites as "land, normally in towns and villages" thus very few opportunities for redevelopment of brownfield sites in the countryside would occur. Local development plans will set policies for housing in the countryside.

Significant allocations have been made to the LG&DA (RHMA) and opportunities for local need will be made through the local development plan process.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

Rep. Number

235 6 Subject SS(LG&D) Summary Outwith the SGA's new development will have to be focused "in, or as an extension to, existing settlements, particularly those well served by public transport". SPP3 sets out far more clearly a new strategy for housing in rural areas; this is important in Aberdeenshire. In particular, para. 96-99 of SPP3 aims to support the rural economy, rural regeneration and embodies the principles of sustainable development.

Draft Response: Acceptance: Noted Changes to be made

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

14 January 2009 Page 185 of 244 235 7 Subject SS(LG&D) Summary The plan should be revised to reflect the concept of new housing in rural areas as set out in SPP3 in order that rural Aberdeenshire does not suffer from a lack of investment and begin to lose vital services. Suggest that the housing allocations across the RHMA are increased.

Draft Response: Acceptance: Do not accept Changes to be made

Significant allocations have been made to the LG&DA (RHMA) and opportunities for local need will be made through the local development plan process.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

Rep. Number

237 5 Subject SS(LG&D) Summary Generally supports LG&D in areas outwith SGA's and suggest that growth in settlements close to SGA's and main transport corridors would be more favorable than development in more remote locations with the Shire. However, this should not preclude some development of small-scale sites in more rural areas to support rural diversification and economic and social regeneration.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed.

All areas outwith Strategic Growth Areas are classified as Local Growth and Diversification Areas. The Structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another.

Rep. Number

239 5 Subject SS(LG&D) Summary Support the LG&D areas, however, suggest that some distinction should be made between existing settlements close to SGA's and those more remote from the corridors. Allowances for further development in settlements close to SGA's would create a more effective hierarchy of development. By settlements we refer to towns and villages already identified in the local plan and small clusters that could be sympathetically extended in accord with SPP3 and SPP15 to support real diversification and social regeneration.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed.

All areas outwith Strategic Growth Areas are classified as Local Growth and Diversification Areas. The Structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another.

Rep. Number

246 2 Subject SS(LG&D) Summary The principle of providing growth in individual settlements to meet local needs and providing a mix of housing opportunities is supported.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 186 of 244 247 8 Subject SS(LG&D) Summary Broadly speaking we feel that an appropriate balance has been struck between clarity and flexibility. However, as set out before we do not believe that the balance between the housing needs and numbers has been struck, particularly in terms of provision for the Local Growth and Diversification Area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

248 8 Subject SS(LG&D) Summary Broadly speaking we feel that an appropriate balance has been struck between clarity and flexibility. However, as set out before we do not believe that the balance between the housing needs and numbers has been struck, particularly in terms of provision for the Local Growth and Diversification Area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

249 8 Subject SS(LG&D) Summary Broadly speaking we feel that an appropriate balance has been struck between clarity and flexibility. However, as set out before we do not believe that the balance between the housing needs and numbers has been struck, particularly in terms of provision for the Local Growth and Diversification Area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

250 8 Subject SS(LG&D) Summary Broadly speaking we feel that an appropriate balance has been struck between clarity and flexibility. However, as set out before we do not believe that the balance between the housing needs and numbers has been struck, particularly in terms of provision for the Local Growth and Diversification Area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

14 January 2009 Page 187 of 244 251 8 Subject SS(LG&D) Summary Broadly speaking we feel that an appropriate balance has been struck between clarity and flexibility. However, as set out before we do not believe that the balance between the housing needs and numbers has been struck, particularly in terms of provision for the Local Growth and Diversification Area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

252 8 Subject SS(LG&D) Summary Broadly speaking we feel that an appropriate balance has been struck between clarity and flexibility. However, as set out before we do not believe that the balance between the housing needs and numbers has been struck, particularly in terms of provision for the Local Growth and Diversification Area.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

257 1 Subject SS(LG&D) Summary James Barr acting on behalf of CWP Properties propose that the inclusion of NO.3 Dee Street in Banchory town centre for future development of a food store with flatted residential units above is of strategic importance to provide an adequate level of choice and local services for the projected growth in population of the area (Banchory has been highlighted as an appropriate are for ‘Local Growth and Diversification’ in the Draft Structure Plan)

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The support, and provision, of infrastructure is an essential part of supporting the level of housing and economic development envisaged in conjunction with achieving sustainable mixed communities and is central to the plan.

However the Local Development Plan process will determine land allocations for local issues as identification of locations for new food stores is not appropriate within a high level strategic plan which covers issues "best dealt with by Aberdeen City and Aberdeenshire Councils working together".

Rep. Number

258 1 Subject SS(LG&D) Summary We are surprised and disappointed that the Draft Structure Plan focuses its objectives and policies almost exclusively on a settlement based strategy and makes little if any reference to the needs and requirements of those living in the countryside and those wishing to live in it for occupational or other personal reasons. Whilst the Draft Plan acknowledges that ‘there will continue to be pressure for housing in the countryside which is not connected to existing settlement’ it proposes to respond to this pressure by focusing new housing in, or as an extension to existing settlements. The Draft Plan fails to provide any form of policy which encourages or permits the development of new housing in the countryside which is of great concern to our client and others living in rural areas.

Draft Response: Acceptance: Do not accept Changes to be made

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. This Structure Plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. Creating sustainable communities will not preclude local jobs for local people from local homes.

The Local Development Plan process will determine the level of growth appropriate, detailed policies and land allocations for local issues.

14 January 2009 Page 188 of 244 258 2 Subject SS(LG&D) Summary The current Structure Plan lays out policies in relation to this matter and we are firmly of the opinion that the emerging Structure Plan should also contain policy in relation to house building in the countryside locations. The main concern is that the draft plan makes not provision for housing in the countryside, whilst policies SPP3 and SPP15 clearly set out support in this matter.

In further support of our claims that the merging Structure Plan should address Housing in the Countryside in a positive and pro-active manner we attach for your attention extracts from the Structure and Local Plans which apply in the Scottish Borders Council Area. In view of the proximity of the Scottish Borders to Edinburgh it is not dissimilar to the relationship between the Shire and Aberdeen. As evident from the attached policies the Scottish Borers Council are positively encouraging of new housing in the countryside in the appropriate circumstances.

We are of the view that both Aberdeen and Aberdeenshire Councils (the Structure Plan Authorities) should adopt an equally positive attitude towards development in countryside locations.

Draft Response: Acceptance: Do not accept Changes to be made

The current structure plan is prescriptive in nature whereas the emerging Structure Plan "aims to be more focused, strategic" and only aims to cover those issues that "can be best dealt with by Aberdeen City and Aberdeenshire Councils working together". The emerging Structure Plan has been written conforming to current legislation whilst in the form and style of what a Strategic Development Plan is anticipated to be when the new planning legislation (Planning etc (Scotland) Act 2006) comes into force next year.

The emerging structure plan has taken Scottish Planning Policies into consideration whilst also taking the new legislation into consideration which will see Strategic Development Plans dealing with high level strategic issues whilst Local Development Plans will deal with localised and more detailed issues such as Housing in the Countryside.

Rep. Number

261 12 Subject SS(LG&D) Summary We support the strategy in relation to local growth and diversification areas. The strategy should be flexible on a settlement basis and recognise each individual settlements services and infrastructure potential.

Draft Response: Acceptance: Accepted Changes to be made

The Strucutre Plan states that "levels of growth in individual settlements should relate to local needs, although the scale of growth will vary from place to place" priority should also be given to "developments which respect the character of the landscpae and local identity."

The allocation of specific sites will be determined within the Local Development Plan process.

Rep. Number

264 12 Subject SS(LG&D) Summary On page 8 the structure plan need not make reference to a need to focus on providing smaller homes to buy or rent. The structure plan has to facilitate the provisions of an adequate supply of land for all tenures and types of housing. Attempting to focus need in an artificial manner is not the role of a competent structure plan.

Draft Response: Acceptance: Do not accept Changes to be made

The emerging structure plan makes explicit mention of the need to focus on providing smaller homes to buy or rent to emphasis the importance of the issue throughout the region.

It is important to read the plan as a whole, not as a thematic document. The spatial strategy must be read alongside the objectives which will assist in achieving the vision and aims.

Rep. Number

14 January 2009 Page 189 of 244 265 2 Subject SS(LG&D) Summary Whilst the majority of new housing should be settlements based, there is an increasing role for small clusters of housing outwith settlements that meet the appropriate criteria in SPP 15 (para 21) for location, access, proximity to services, drainage and fit in the landscape, particularly on disused rural brownfield sites. There is scope for opportunities to be identified in the local development plan or criteria set out in the local development plan against which proposals for such clusters can be assessed, based on rural typologies research. There is also a role for SPG to set out the detail of how such sites could be brought forward.

Draft Response: Acceptance: Partially accept Changes to be made

The emerging structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

The glossary defines brownfield sites as "land, normally in towns and villages" thus very few opportunities for redevelopment of brownfield sites in the countryside would occur. Local development plans will set policies for housing in the countryside.

Local Development Plans and Supplementary Planning Guidance will be produced by Aberdeenshire Council and Aberdeen City Council respectively. 265 3 Subject SS(LG&D) Summary One way of enabling diversification and growth in the local rural economy is to promote new small-scale development on brownfield land. By allowing relatively small-scale housing developments with integral office space that promote the Live/Work concept would help reduce commuter travel whilst also providing employment opportunities in rural areas. The recently published Taylor Review supports this saying that home-based business growth should be supported in order to nurture the rural economy. It highlights figures showing that a higher proportion of rural dwellers work home than urban residents. Just over one in six (17%) of rural working residents work from home, more than double the level in urban areas (8%).

Draft Response: Acceptance: Partially accept Changes to be made

The glossary defines brownfield sites as "land, normally in towns and villages" thus very few opportunities for redevelopment of brownfield sites in the countryside would occur. It would be for the Local Development Plans to determine the appropriateness of sites outhwith urban areas, whether brownfield or greenfield and set policies for housing in the countryside.

The structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another.

Rep. Number

271 4 Subject SS(LG&D) Summary Support the focus on provision of a mix of housing opportunities with a particular focus on providing smaller houses.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

271 5 Subject SS(LG&D) Summary Concerned that there is again an over reliance on new development being within or an extension to an existing settlement that are well serviced by public transport.

This limits areas that are currently not serviced by public transport but could be if development were permitted.

Draft Response: Acceptance: Do not accept Changes to be made

The draft plan does not preclude the expansion or consolidation of existing towns and villages not serviced by public transport. The plan supports development in, or adjacent to, existing settlements within Local Growth and Diversification Areas "particularly those which are well served by public transport". Whilst desirable that these locations are served by public transport it is recognised that given the rural nature of Aberdeenshire this is not always possible.

The level of growth appropriate will be determined through the Local Development Plan process.

Rep. Number

14 January 2009 Page 190 of 244 278 7 Subject SS(LG&D) Summary Consider that Westhill is of strategic significance and should be recognised by either:

- Either treating Westhill as an exceptional case with an area of Local Growth and Diversification with its own specific allocation [ increasing the overall growth figure commensurately] or - Incorporating Westhill as an 'off-shoot' Strategic Growth Point.

The Westhill capacity study recognises the strategic role of Westhill, it has business parks with a deverse range of occupiers (the Draft SP should recognise the internationally significant sub sea engineering excellence in Westhill), is located close to Aberdeen.

The Structure Plan should draw on findings of the Westhill Capacity study and recognise its key role.

Need to recognise that further employment land needs to be matched with sufficient housing land in the interests of sustainabillity.

The Aberdeenshire Local Plan reporter recognised the suitability of Kirkton of Skene (area 10) for development.

Draft Response: Acceptance: Do not accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

Rep. Number

282 10 Subject SS(LG&D) Summary It is clear there are serious disincentives to investment in areas of Aberdeenshire outside SGA’s. This will lead to economic decline and serious population decline over much of the area. If approved in its current form, a very serious decline in local services will result with schools, shops and other services closing and bus routes becoming uneconomic. Many rural businesses already have difficulties attracting employees as a result of lack of available housing.

Draft Response: Acceptance: Do not accept Changes to be made

A significant number of settlements will fall outside SGA's and these have received 20-25% of the entire structure plan allocation for housing and an unspecified amount of employment land. Further development will occur in many of these places to meet local need.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

The Local Development Plan process will determine detailed policies and land allocations for local issues.

Rep. Number

286 17 Subject SS(LG&D) Summary Serious concerns regarding the status of some settlements. For example, Westhill has a strategic role to play over the lifetime of the plan and should be included within a SGA, maybe included as part of Aberdeen City.

Draft Response: Acceptance: Partially accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

The spatial strategy does not identify particular settlements and the scale of development for them however the overall housing allocation is already generous and based on a high growth scenario. The allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on social, economic and environmental criteria and infrastructure requirements taking full account of local need.

14 January 2009 Page 191 of 244 286 18 Subject SS(LG&D) Summary The A93 corridor between Aberdeen and Banchory should be included as a SGA to help improve connections between the local towns, Aberdeen and the AWPR. Would also support employment and tourism in the area.

Draft Response: Acceptance: Do not accept Changes to be made

The spatial strategy allows for development which is appropriate to local needs as identified within Local Growth and Diversification areas.

The A93 corridor was not identified in the Spatial Strategy as appropriate for strategic growth given the size and location of settlements and the ability to encourage the use of public transport given infrastructure constraints. 286 21 Subject SS(LG&D) Summary There requires to be flexibility in this area as NEST was limited developments to around 15 houses in any quinquennium (5 year period), which was too restrictive given the need in many instances to improve water supply, foul drainage or other infrastructure. This made such developments unviable, local needs need to be met and projects viable.

Draft Response: Acceptance: Accepted Changes to be made

Support for this aspect of the plan is welcomed.

It is accepted that NEST was rigid, precise and prescriptive. This draft plan looks to move away and not prejudge any area of Aberdeen or Aberdeenshire. The plan aspires to be strategic, focused, accessible, action-orientated and outcome driven, flexible and appropriate for the area that it serves. 286 22 Subject SS(LG&D) Summary Allocations within the local growth areas in the AHMA need to be significantly increased. There is an imbalance between the AHMA (6.5% of the total allocation) and RHMA (17.4% of the total allocation). Previous plans have over-allocated land in the rural areas and site remain undeveloped. Some of the RHMA allocation should go to the AHMA.

Draft Response: Acceptance: Partially accept Changes to be made

It is proposed to reduce the allocation to the LG&DA (AHMA) to 3,700 units over the plan period. This because the number and size of settlements in this area would suggest that growth on the scale identified in the draft structure plan would be excessive and be meeting more than local needs.

Rep. Number

287 16 Subject SS(LG&D) Summary Support the general strategy for local growth and diversification, but there requires to be more flexibility in such a policy. NEST limited developments to around 15 houses in any 5 year period, which was too restrictive given the need in many instances to improve water supply, foul drainage or other infrastructure. This made such developments unviable, local needs need to be met and projects viable.

Draft Response: Acceptance: Accepted Changes to be made

Support for this aspect of the plan is welcomed.

It is accepted that NEST was rigid, precise and prescriptive. This draft plan looks to move away and not prejudge any area of Aberdeen or Aberdeenshire. The plan aspires to be strategic, focused, accessible, action-orientated and outcome driven, flexible and appropriate for the area that it serves. 287 18 Subject SS(LG&D) Summary Agree with principle of local growth based on local need. However, the plan must not limit the size and mix of new development but rather should make sufficient overall provision. There should be a range of housing opportunities that meet the demands of the population, but developers have to sell their product and are therefore best placed to know what type of housing the market is expecting.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

The plan does not limit the size and mix of new development. The plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'.

The Local Development Plan process will determine the level of growth appropriate in addition to detailed policies and land allocations for local issues. The mix of housing will be determined through the local development plan process, masterplanning and supplementary planning guidance.

Rep. Number

14 January 2009 Page 192 of 244 288 1 Subject SS(LG&D) Summary Fails to address concerns of maintaining and enhancing the quality of the rural life in Buchan.

In particular insufficient commitment to maintaining and developing infrastructure that would promote appropriate commercial development in the villages.

Unless there is a more quantative commitment to rural development included integrated housing and infrastructure it is expected that more villages will lose schools, shops and pubs and will fade into residentail dormitories for commuting population.

Draft Response: Acceptance: Do not accept Changes to be made

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. The plan strongly emphasises the need to ensure required infrastructure improvements are in place prior to development.

The spatial strategy provides flexibility for the Local Development Plan process to determine the level of growth appropriate and distribute the housing allocations following consultation with communities in addition to providing detailed policies and land allocations for local issues.

Rep. Number

297 12 Subject SS(LG&D) Summary Community Council has long argued for housing developments to be associated with existing settlements.

Clear guidance on this should be incorporated into the final structure plan and that this intent should inform the proposed review of the final Structure Plan.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The Local Development Plan process will determine the detailed policies and land allocations for local issues. The mix of housing will be determined through the local development plan process, masterplanning and supplementary planning guidance.

Rep. Number

299 7 Subject SS(LG&D) Summary There is a need for further details on where the 17,100 new houses will be located in the LG&D area.

It is not helpful to be unsure by how much settlements will grow and where.

Draft Response: Acceptance: Do not accept Changes to be made

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. This Structure Plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'. The level of growth appropriate will be determined through the Local Development Plan process.

Rep. Number

300 2 Subject SS(LG&D) Summary Essential to include appropriate policies in the plan to ensure that any development takes into account the need for social facilities, employment opportunities and appropriate transport infrastructure in the areas where development is planned.

Draft Response: Acceptance: Partially accept Changes to be made

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

This plan does not contain policies, but does contain policy material which will set the framework for Local Development Plans, supplementary planning guidance

Rep. Number

14 January 2009 Page 193 of 244 307 6 Subject SS(LG&D) Summary Westhill must remain categorised as a LGA, and not be recategorised (as per developers desires) to a SGA.

Draft Response: Acceptance: Noted Changes to be made

Note the agreement with Westhill being categorised as within the Local Growth & Diversification Areas.

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. 307 9 Subject SS(LG&D) Summary E&SCC are also opposed to any separate, over development of KoS village, development which would overwhelm the existing village.

KoS is not an Edge of City Community. It is designated a Rural Service Centre and as such, there is an automatic presumption in the Local Plan against most forms of development in this area.

Development at Kirkton of Skene must remain within the guidelines for expansion of a Rural Service Centre - and be of a size & phasing that does not overwhelm the existing village.

Draft Response: Acceptance: Do not accept Changes to be made

Rural Service Centres were designated in the currently adopted NEST Structure Plan. This Structure Plan does not categorise any town, village or settlement thus previous designations do not apply.

However this area is designated for local growth only (AHMA), it will be for the local development plan to determine exactly where development takes place and on what scale.

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. This Structure Plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'.

Rep. Number

314 2 Subject SS(LG&D) Summary We do not support the objective (section 2 page 8) that in LGDA the focus will be on smaller homes to buy or rent and a significant amount of affordable housing, for the following reasons:

- artificially restrictive and would prefer to see a broad range of house types,

- This objective would target such house types into specific areas and may be contrary to existing or changing market forces,

- generally be more poorly served by public transport, which people living in smaller homes or rented/ affordable housing may have a generally greater need,

- agree priority should be on better design.

Draft Response: Acceptance: Do not accept Changes to be made

Note the agreement with the focus on better design.

It is important to read the plan as a whole, not as a thematic document. The Spatial Strategy and objectives are interconnected therefore Local Growth and Diversification areas must be read in conjunction with Sustainable Mixed Communities and Accessibility in relation to the areas of concern raised.

The plan does not limit the size and mix of new development. The plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'. The Local Development Plan process will determine the level of growth appropriate in addition to detailed policies and land allocations for local issues. The mix of housing will be determined through the local development plan process, masterplanning and supplementary planning guidance.

Whilst desirable that these locations are served by public transport it is recognised that given the rural nature of Aberdeenshire this is not always possible.

Rep. Number

14 January 2009 Page 194 of 244 329 3 Subject SS(LG&D) Summary The draft strategic plan does not identify any specific areas in rural towns like Turriff for business development land. The board of Turriff & District would like to see business land identified in the plan, because this will be important in terms of permitting future economic development.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan is a high level strategic land use planning document and as such only identifies business land within the Strategic Growth Areas. Turriff is identified as within the Local Growth and Diversification Area thus the level of growth appropriate will be determined through the Local Development Plan process when the spatial strategy will be used to set policies and identify land for development.

Rep. Number

330 10 Subject SS(LG&D) Summary Local growth and diversification has been identified or much of the Aberdeenshire. The emphasis is on local needs and providing smaller homes to buy or rent, although it does acknowledge that the need will vary from place to place. SCDI accepts that this should be the priority for the countryside. However, there is a significant cluster of high growth businesses in the Westhill are which would also fall into the local growth and diversification area. It is important that sufficient, high quality housing is available in the west Aberdeen area to meet their growing need for skilled employees. Public transport improvements and park and ride are also needed.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcomed.

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

Future proposals within the Regional Transport Strategy are for the completion of a ring of Park & Ride services around Aberdeen, linked to the AWPR, enabling easy access to the City. Park and Ride proposals will be included within the proposals section and shown on the key diagram.

Rep. Number

334 5 Subject SS(LG&D) Summary The three strand approach is not an appropriate response to the future of the area. It does not reflect the reality of the diversity of the area. In directing growth in specific terms, the remainder of Aberdeenshire is not only neglected but is also disadvantaged in terms of the potential for development.

Draft Response: Acceptance: Do not accept Changes to be made

The plan represents a vision of the future shared across the whole of the City and Shire area. This approach was decided upon following consideration of a greater number of options and is believed to be the most appropriate solution, providing as it does the flexibility for Aberdeenshire Council through its local development plan to distribute the considerable level of allocations following consultation with communities.

The spatial strategy emphasises that all parts of the plan area are important and sets out how development will be focused across the region. The spatial strategy promotes development in the right places, that meets the needs of both people and business, while maintaining sustainable development principles. 334 7 Subject SS(LG&D) Summary Instead of allowing flexibility, the plan should proactively advance the development of economic activity in both these Local Growth and Diversification Areas and in the Regeneration Priority Areas. .

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan specifically mentions "there is a need for diversification and growth in the economy in this area to meet local needs". Additionally with the Regeneration Priority Areas section the plan states "Improving the economy and the competitiveness of business should play a particular role".

The strategic level of the structure plan means that indicative figures for reasonably small corridors can be determined. Beyond this, at the settlement level, the allocation of specific sites will be undertaken by Aberdeenshire Council as part of the local development plan process.

Flexibility is required in the way the plan is implemented. The plan will be reviewed every five years to ensure it is kept up-to-date. An Action Programme will be prepared during 2009 which will set out the detailed action required by the Councils and their partners to implement the plan.

Rep. Number

14 January 2009 Page 195 of 244 359 1 Subject SS(LG&D) Summary Expressed concern with regards to the current planning regulations for replacement houses in the countryside.

The criteria laid down makes it nearly impossible to replace a house.

Suggested re-wording to allow replacement of any dwelling irrespective of its condition. If there has been a dwelling on a site in the past then there should be no good reason why a replacement house can not be erected.

Anticipated response is that new houses are acceptable if it is proven that the dwelling is required for a full time worker in a rural industry. Queried how many new full time rural jobs are created. Suggested that most employment in the countryside is of a part time nature.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The issue of replacement houses in the countryside is better dealt with at the Local Development Plan level and is not a strategic issue for this plan.

The Local Development Plan process will determine detailed policies for local issues. A copy of your representation will be forwarded to the relevant Local Development Plan Team.

Rep. Number

377 4 Subject SS(LG&D) Summary Would like to see extra highlighting of certain words within the local growth and diversification section (details given).

Draft Response: Acceptance: Do not accept Changes to be made

To graphically highlight particular words and phrases is unnecessary.

Rep. Number

382 12 Subject SS(LG&D) Summary Within the Shire only one option how to accommodate this vast number of houses is being considered: "... there will continue to be pressure for housing in the countryside which is not connected to existing settlements. However, local development plans ... should approach this by focusing new housing in, or as an extension to, existing settlements " (page 8)

In other words: The need of building new villages or a new town is recognised but dismissed in favour of tacking housing developments to existing communities. How 'exciting' and 'modern' (page 5, The Vision for the plan) is this? And how enlightened will it look in comparison with other 'European city regions'?

More evidence of the expressed will to ignore the option of being truely 'confident' and 'courageous' and of coming up with something really innovative like a model town can be found on page 8: "Providing new housing which doesn’t meet the requirement of the spatial strategy or meet the standards under other objectives will not be supported by this plan."

"We" should be able to do better than committing to mediocrity - build a new Scottish town.

Draft Response: Acceptance: Do not accept Changes to be made

The plan represents a vision of the future shared across the whole of the city and shire area. This approach was decided upon following consideration of a greater number of options and is believed to be the most appropriate solution, providing as it does the flexibility for Aberdeenshire Council through its local development plan to distribute the considerable level of allocations following consultation with communities. The structure plan does not mention a new town, but does not preclude one either. It will be for the local development plan to determine exactly where development takes place and on what scale.

The spatial strategy emphasises that all parts of the plan area are important and sets out how development will be focused across the region. The spatial strategy promotes development in the right places, that meets the needs of both people and business, while maintaining sustainable development principles.

Rep. Number

14 January 2009 Page 196 of 244 397 5 Subject SS(LG&D) Summary The first paragraph on page 8 sets out the aim well. In the second paragraph, the phrase "particularly those (settlements) which are well served by public transport" conflicts with the notion that the strategic growth areas are to be "where there are clear opportunities to encourage people to use public transport" (p.6).

The implication is that settlements in local growth and diversification areas will not be well served by public transport. Development of settlements in the local growth and development areas should therefore be small in scale and permitted only on the basis of clearly demonstrated need: the structure plan should make this clear.

Draft Response: Acceptance: Do not accept Changes to be made

It is important to read the plan as a whole, not as a thematic document. The Spatial Strategy (including strategic growth areas, local growth and diversification areas and regeneration priority areas) and objectives are interconnected therefore Local Growth and Diversification areas must be read in conjunction with Sustainable Mixed Communities and Accessibility in relation to the areas of concern raised.

The Spatial Strategy emphasises that all parts of the plan area are important and sets out how development will be focused across the region. The spatial strategy promotes development in the right places, that meets the needs of both people and business, while maintaining sustainable development principles.

The Strategic Growth Areas are located in accessible locations and in particular the Huntly - Laurencekirk corridor which is along the railway line. Areas outwith the Strategic Growth Areas will still have the potential to have development at an appropriate levels for local need. Aberdeenshire has a significant level of growth proposed that is highly appropriate to meet the needs and aspirations of the area. Whilst desirable that all locations are served by public transport it is recognised that given the rural nature of Aberdeenshire this will not always be possible.

The structure plan states that "Levels of growth in individual settlements should relate to local needs" and thus does make the issue clear.

Rep. Number

409 5 Subject SS(LG&D) Summary The concept of building next to an existing settlement is a good one. Planners can utilise the best bits of the settlement’s structure and design, use facilities and services which are already there as a springboard to develop them further to meet the needs of more people.

In addition development provides opportunities to address some of the problems or issues faced within the existing village/small town. A village feel can still be maintained if done properly. It should not be allowed to become just a housing scheme sprawl.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcome. The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another.

The Structure plan allows for growth within small villages at an appropriate scale for that settlement. The level of growth appropriate will be determined through the Local Development Plan process.

Rep. Number

411 6 Subject SS(LG&D) Summary Policy of increasing residential housing adjacent to existing settlements without any proper provision of increased community facilities and identify town focal points such as a town square or public park is wrong.

Example of Bridge of Don latterly receiving some community facilities after 15years of housing development.

Draft Response: Acceptance: Do not accept Changes to be made

The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

The glossary definition of infrastructure (to the rear of the structure plan) is "The parts of cities, towns or villages that make them work. This includes water, drainage, electricity and phones, as well as roads, schools, community halls, medical centres, libraries, bus stops and so on."

The structure plan does not advocate extending existing settlements without the provision of community facilities.

Further detail will be provided through the Local Development Plan process.

Rep. Number

14 January 2009 Page 197 of 244 422 10 Subject SS(LG&D) Summary "We need to give priority to developments which respect the character of the landscape and local identity". Why is this not also true of the Strategic Growth Areas, especially around Stonehaven?

Draft Response: Acceptance: Noted Changes to be made

It is important to read the plan as a whole, not as a thematic document. The Spatial Strategy (including strategic growth areas, local growth and diversification areas and regeneration priority areas) and objectives are interconnected therefore the Spatial Strategy must be read in conjunction with Sustainable Mixed Communities and Quality of the Environment in relation to the areas of concern raised.

Within Sustainable Mixed Communities it is stated that "new homes are designed to a high standard and that they respect and improve the existing qualities of the area". Within Quality of the Environment it is stated that "The way in which sites are chosen, and high-quality design, will make sure that development does not lead to the decline of the North East's built, natural and cultural assets."

The Local Development Plan process will determine detailed policies and land allocations for local issues.

Rep. Number

424 5 Subject SS(LG&D) Summary The section for Local growth and diversification areas recognises that rural areas need to be well served by public transport.

However, what means of public transport exists in reality? The only public transport for the rural areas for now, and according to this plan, by 2030, is bus. Improving bus services is out of the scope of planning system.

Is there any vision to provide light railways to connect the rural towns which have population of over 4000, but outreached by the two main Corridors?

Rural areas have been extensively covered by sparse new developments, in or around Rural Service Centres as a result of the existing Structure Plan (NEST) and the Local plan.

What is the vision for the new structure plan to bring continuous prosperity to the rural areas, it is not clear. The key diagram shows the housing figures for the RHMA is 4/7th of the total figures of those for the Corridors towns. The statement for the rural areas does not reflect this significance of the rural areas.

Draft Response: Acceptance: Noted Changes to be made

It is agreed that the structure plan is not the appropriate medium to give detailed information with regards to how bus services will be improved, however the Spatial Strategy and Accessibility objective must highlight this issue to enable further details to be given in local and regional transport strategies which will provide higher levels of guidance.

The structure plan takes account of numerous regional strategies and plans (prepared by Scottish Government, Nestrans, ACSEF etc) which have an important influence on the delivery of the plan. Numerous projects have been outlined within the plan which will encourage people to use public transport and enables efficient provision of services whilst aiming to reduce the percentage of car journeys.

It is accepted that in the past developments have not allowed ease of access to efficient and attractive transport options (public transport in particular). The Structure Plan strategy focuses development in places where there are clear opportunities to encourage people to use public transport and enables efficient provision of services whilst aiming to reduce the percentage of car journeys however it is recognised that given the rural nature of Aberdeenshire this will not always be possible.

Rep. Number

426 6 Subject SS(LG&D) Summary The planning response to the issues faced in these areas is unlikely to be appropriate. The plans vision, based largely on population growth, cannot by force be extended to rural areas. The vision is an urban one, for a largely rural area.

Draft Response: Acceptance: Do not accept Changes to be made

The plan presents a clear and rounded view of future development and represents a vision of the future shared across the whole of the city and shire area. This approach was decided upon following consideration of a greater number of options and is believed to be the most appropriate solution, providing as it does the flexibility for Aberdeenshire Council through its local development plan to distribute the considerable level of allocations following consultation with communities.

The Spatial Strategy emphasises that all parts of the plan area are important and sets out how development will be focused across the region. The spatial strategy promotes development in the right places, that meets the needs of both people and business, while maintaining sustainable development principles.

14 January 2009 Page 198 of 244 426 19 Subject SS(LG&D) Summary "Levels of growth in individual settlements should relate to local needs, . ."

This is acknowledged, but queried where has this happened within the AHMA?

Draft Response: Acceptance: Noted Changes to be made

The Structure Plan is more focused and action orientated than previous plans. This plan will take the place of NEST which is the currently adopted strategic land use planning document and thus cannot take retrospective responsibility for developments that have taken place in the past.

Rep. Number

428 4 Subject SS(LG&D) Summary Believe that allocations need to be expressed for individual settlements rather than 'areas' so as to provide greater certainty to plan makers and plan users. In particular, would question the use of 'local growth (AHMA)' as it is not clear what proportion of the total will be allocated to Westhill, Kemnay and Banchory. Accept the need for flexibility, but what is being provided here is far beyond what should be allowed.

Draft Response: Acceptance: Noted Changes to be made

The strategic level of the structure plan means that indicative figures for reasonably small corridors can be determined. Beyond this, at the settlement level, the allocation of specific sites will be undertaken by Aberdeenshire Council as part of the local development plan process.

Few settlements get explicit mention in the plan, however the structure plan allows for growth within small villages at an appropriate scale. This structure plan does not state that there should be any specific number of houses on specific settlements, but purely states that it should 'relate to local needs'.

Flexibility is required in the way the plan is implemented. The approach taken was decided upon following consideration of a greater number of options and is believed to be the most appropriate solution. The plan will be reviewed every five years to ensure it is kept up-to- date.

Rep. Number

449 5 Subject SS(LG&D) Summary These areas need to be considered alongside SGA's and not totally separate communities. Beware of using expressions like 'give priority' to certain developments without allowing for individual requirements. Planners must be flexible.

Draft Response: Acceptance: Noted Changes to be made

The Spatial Strategy still allows for significant levels of growth in the Local Growth and Diversification Area, but these must continue to be plan led wherever possible. It will be for the local development plan to determine exactly where development takes place and on what scale.

The plan presents a clear and rounded view of future development in the area recognising that every settlement is important to achieve the plans vision.

It is agreed that flexibility is required in the way the plan is implemented and the structure plan provides this by allowing Local Development Plans to distribute the allocations identified according to local needs.

Rep. Number

451 5 Subject SS(LG&D) Summary 30% of the housing development should be available to the RHMA. Investment needed for rural areas to become sustainable.

Draft Response: Acceptance: Partially accept Changes to be made

The RHMA has been allocated over 22% of the housing allowances for the period to 2030 and over 26% of the total housing land.

The overall housing allocation is already generous and based on a high growth scenario.

It is agreed that investment is needed for rural areas and the support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

14 January 2009 Page 199 of 244 451 6 Subject SS(LG&D) Summary Important that the structure plan does not limit rural communities from becoming sustainable. With emerging food and energy issues rural communities should not only rely upon cities but are in a stronger position to become more sustainable.

Draft Response: Acceptance: Partially accept Changes to be made

The spatial strategy still allows for significant levels of growth in the Local Growth & Diversification area. The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. It will be for the local development plan to determine exactly where development takes place and on what scale.

It is agreed that investment is needed for rural areas and the support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

Rep. Number

457 5 Subject SS(LG&D) Summary Levels of permitted growth should be consistent with capacity of schools, libraries, community facilities etc.

Draft Response: Acceptance: Accepted Changes to be made

Agreed. The support, and provision, of infrastructure is an essential part of supporting the level of housing and economic development envisaged and is central to the plan.

The level of growth appropriate will be determined through the Local Development Plan process.

Rep. Number

472 4 Subject SS(LG&D) Summary LG&DA's should encourage and give more emphasis to the 'community', which is an important cultural aspect of life in Aberdeenshire. There has to be real flexibility built into these areas as they are so wide and diverse. Any changes through diversifying industry could influence changes to this draft plan, e.g. a site required for a new RAF, Army or Navy asset. The emphasis on public transport is encouraging and fits with the NESTRANS strategy.

Draft Response: Acceptance: Partially accept Changes to be made

Note the agreement with the emphasis on public transport in accordance with the NESTRANS strategy.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan.

The spatial strategy provides flexibility for the Local Development Plan process to determine the level of growth appropriate and distribute the housing allocations following consultation with communities in addition to providing detailed policies and land allocations for local issues.

Rep. Number

476 4 Subject SS(LG&D) Summary It is accepted that whilst the above may address strategic needs, there is also a need to support local growth. There should be allowance for individual developments in rural areas away from established settlements, particularly where this is in support of the rural economy and in such instances, combined live and work developments should be considered as the most suitable.

Draft Response: Acceptance: Partially accept Changes to be made

The spatial strategy emphasises that all parts of the plan area are important and sets out how development will be focused across the region. The spatial strategy promotes development in the right places, that meets the needs of both people and business, while maintaining sustainable development principles.

The strategy for local growth and diversification highlights the need to diversify rural economies to meet local needs whilst the objective on sustainable mixed communities aims to focus on communities with regards to new housing and developments for employment being related to one another. Creating sustainable communities will not preclude local jobs for local people from local homes.

The final decision on where development will and will not be allowed will be taken through the Local Development Plan process.

Rep. Number

14 January 2009 Page 200 of 244 188 7 Subject SS(RPA) Summary Further justification for increasing the housing numbers is that the headline figure includes 5,000 houses emerging for regeneration areas within the city.

These are simple replacements and because of this the net increase being promoted by the plan is 67,000 not 72,000.

Draft Response: Acceptance: Do not accept Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

It is important to show commitment and support of regeneration in the City and as such the number should remain with the 5,000 replacement houses shown in the total.

Rep. Number

189 7 Subject SS(RPA) Summary Further justification for increasing the housing numbers is that the headline figure includes 5,000 houses emerging for regeneration areas within the city. These are simple replacements and because of this the net increase being promoted by the plan is 67,000 not 72,000.

Draft Response: Acceptance: Do not accept Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

Rep. Number

233 5 Subject SS(RPA) Summary Tourism is a major employment generator and of key importance to the economy of Aberdeenshire. It is given no prominence at all in the plan, with only one small reference on p.8.

Draft Response: Acceptance: Noted Changes to be made

Toursim and tourist related developments are mentioned in the LG&DAs and the PRAs on plage 8. It states how important a role it plays in the ecomomic growth of the north east. It is unclear how additional references would give it any more prominance in this plan. The LDP would be the time to have more detailed tourist related policies and guidance.

Rep. Number

237 4 Subject SS(RPA) Summary Plan should also make it clear whether RPA's sit with LG&D areas or are they completely separate designations? If the priority for RPA's is brownfield regeneration then some small do not have such sites to develop, which could leave these settlements with no new housing allowance and no means of creating growth to assist with retention and attraction of local services. Essentially, designation of RPA's will have a negative impact, not a positive one.

Draft Response: Acceptance: Do not accept Changes to be made

Further information on RPA's will be provided in the final plan. The priority given to the RPAs is important because these areas tend to have more brownfield land than is desirable. Redevelopment by its very nature is brownfield development. The priority for brownfield development does not preclude development on greenfield land.

The RPAs sit within the LG&DA and as such an appropriate level of growth will be determined at the Local Development Plan level. It is important to ensure that the level of development meets the local need.

Rep. Number

14 January 2009 Page 201 of 244 255 9 Subject SS(RPA) Summary The targets from the brownfield development provision from Aberdeen city are also questioned, as the draft Urban Capacity Study has not addressed the concerns raised previously by the housebuilding industry in terms of the likely availability/effectiveness of sites and in terms of the densities adopted in the assessment of capacity. On this point we would draw your attention to paragraph 63 of SPP3 which encourages planning authorities to “involve the private sector in the preparation of urban capacity studies” as this “can help to ensure a realistic assessment of development potential”. Bancon would welcome the opportunity to be involved in such a dialogue.

Draft Response: Acceptance: Do not accept Changes to be made

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. This level is substantially lower than in previous years, when brownfield development represented between 60-90%. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result. The Urban Capacity Study contained in the Background Paper provides the justification for the brownfield allowances until 2016. The allowances beyond 2016 will be reviewed in future strategic development plans in light of updated urban capacity information.

The involvement of the private sector was not made on this occasion, as the majority of the information is based on the HLA, which in itself is subject to consultation with the development industry.

Rep. Number

264 14 Subject SS(RPA) Summary The text to the regeneration priority areas is unduly restrictive by refering to opportunities for developing brownfield sites. The paragraph commencing 'Developing on brownfield sites is a particular priority' should be deleted.

Draft Response: Acceptance: Do not accept Changes to be made

The priority given to brownfield land in the RPAs is important because these areas tend to have more brownfield land than is desirable. Redevelopment by its very nature is brownfield development. The priority for brownfield development does not preclude development on greenfield land.

Rep. Number

265 4 Subject SS(RPA) Summary In rural, as well as urban areas there is scope for the redevelopment of brownfield sites that are potentially well connected to service centers. A policy that also promotes the Live/Work concept would mean people could live in rural areas and work from home in greater numbers. This would be in line with SPP3 (para 85).

Draft Response: Acceptance: Accepted Changes to be made

It would be for the Local Development Plans to determine the appropriateness of sites outhwith urban areas, whether brownfield or greenfield.

Rep. Number

267 16 Subject SS(RPA) Summary In general terms it is appropriate that strategic development should seek to benefit disadvantaged areas. The plan should also, however, encourage all development to bring benefit to nearby areas.

Draft Response: Acceptance: Noted Changes to be made

The spatial strategy recognises the need to "maintain and improve the area's communities and services they depend on."

Rep. Number

278 5 Subject SS(RPA) Summary If the 5000 houses in the RPA are simply replacement houses for demolished stock the net increase in housing promoted by DSP will be 67,000 units rather than the headline figure of 72,000.

Draft Response: Acceptance: Noted Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

14 January 2009 Page 202 of 244 278 11 Subject SS(RPA) Summary Would be helpful to have a definition of a Regeneration Area.

Draft Response: Acceptance: Do not accept Changes to be made

"Community regeneration areas" are defined within the Glossary.

The regeneration priority areas are shown within the spatial strategy.

Further information on RPA's will be provided in the final plan.

Rep. Number

285 5 Subject SS(RPA) Summary A balance of policies are needed to ensure that Fraserburgh (and other) town centre is protected, but not at the expense of the wider regeneration of the whole area. By focussing on brownfield sites development will be prevented instead of assisted. In coastal towns brownfield sites may be susceptible to flooding.

Draft Response: Acceptance: Partially accept Changes to be made

Further information on RPA's and the benefits and procedure will be provided in the final plan. However, the structure plan is not the appropriate place to discuss specific town centres, although in general it does state that vitality and viability of existing town centres is important and the sequential approach to new retail development must be followed. The local development plan will consider potential flooding of sites when they are being appraised / considered for development.

Rep. Number

296 3 Subject SS(RPA) Summary Towns and communities which require regeneration should be indicated, not shown as a wide strip.

The structure plan should also recognise the importance of the Grampian coast.

Draft Response: Acceptance: Do not accept Changes to be made

The allocation of specific sites and appropriate settlements will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

298 10 Subject SS(RPA) Summary Tourism is a vital aspect of life in Fraserburgh and area.

At present Fraserburgh is a disappointment to tourists but an upbeat town will attract visitors.

Draft Response: Acceptance: Accepted Changes to be made

It is recognised that Fraserburgh has potential but as stated in the representation there are issues at present with boarded up shops and a run down town centre. This is the reeason that the RPA designation was shown over Fraserburgh. Consideration will be give at LDP level to what is required and when to ensure Fraserburgh can again be a thriving community. 298 11 Subject SS(RPA) Summary Fraserburgh requires regeneration but unsure what being in a Regeneration Priority Area means.

Need more detil on what is propsed physically and financially.

Draft Response: Acceptance: Accepted Changes to be made

Further information on RPA's and the benefits and procedure will be provided in the final plan.

Rep. Number

14 January 2009 Page 203 of 244 307 11 Subject SS(RPA) Summary Development must not stop short of Fraserburgh and Peterhead, there is much opportunity for Brownfield developments in these settlements and surrounding areas.

Draft Response: Acceptance: Accepted Changes to be made

It is strongly agreed that development should not stop short of Fraserburgh and Peterhead. Peterhead is located in an SGA and can accommdate growth to support the spatial strategy. Fraserburgh falls within the RPA and LG&DAs and development will promote regeneration and consider local need.

Rep. Number

308 3 Subject SS(RPA) Summary The term regeneration was understood to apply to a wider suite of principles and values than simply imposing new housing in the area.

Draft Response: Acceptance: Do not accept Changes to be made

Further information on RPA's will be provided in the final plan. However at no point under the description of RPAs does it state that the principles and values of the plan are to simply impose new housing on the area. The RPAs are aimed at improving the economy and competitiveness of business, improving infrastructure and the development of tourism these aspects will contribute to the regeneration of the identified areas. 308 5 Subject SS(RPA) Summary Concerns that there will be a joining up of Gourdon with .

Draft Response: Acceptance: Do not accept Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. There is over a mile between Gourdon and Inverbervie and the plan aims to ensure that the character of the landscape and local identity are protected.

Rep. Number

313 3 Subject SS(RPA) Summary Unclear on what will happen to the RPAs, will they continue to absorb housing.

Draft Response: Acceptance: Noted Changes to be made

Further information on RPA's will be provided in the final plan.

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. An appropriate level of housing and employment will be considered within the LDP to address the current issues.

Rep. Number

316 3 Subject SS(RPA) Summary Not clear what investment will be provided in the RPAs.

Draft Response: Acceptance: Noted Changes to be made

Further information on RPA's will be provided in the final plan.

Rep. Number

320 6 Subject SS(RPA) Summary Would welcome improvements to housing and quality of environment in RPAs.

Draft Response: Acceptance: Accepted Changes to be made

Improvements to these aspects are essential to achieving successful communities.

14 January 2009 Page 204 of 244 Rep. Number

330 11 Subject SS(RPA) Summary While supporting the designation of the regeneration priority areas, SCDI believes that the Structure Plan should be more positive about their prospects. It does recognize the need to improve the economy, the competitiveness of business and transport infrastructure, and to develop tourism in some coastal locations. But it should also highlight the continuing importance of traditional industries, particularity fishing and the potential for modern, up to date, high speed telecommunications to support start ups or attract new businesses

Draft Response: Acceptance: Partially accept Changes to be made

The RPAs are aimed at improving the economy and competitiveness of business, improving infrastructure and the development of tourism these aspects will contribute to the regeneration of the identified areas. Further information on RPAs and the benefits and procedure will be provided in the final plan. Traditional industries must continue to be an important part of the north east economy, but the structure plan must be clear in the specific, strategic land use elements that it can directly influence. As such, the objectives apply equally to all areas of the plan and encourage economic growth and mixed use developments that meet the needs of the whole community. The plan also emphasises the need to develop better links within and to the north-east and improve public transport provision.

Rep. Number

333 8 Subject SS(RPA) Summary We would like to see a governance structure which promotes economic investment rather then stifling it with inconsistent bureaucratic obstacles. Offering flexibility will not ensure growth. What is required is positive discrimination to kick start the town’s flagging economy, rather than simply abandoning it as a regeneration area.

Draft Response: Acceptance: Do not accept Changes to be made

The concept of positive discrimination would stifle the entire north east and would be extremely bad for business. The approach in the structure plan is the most appropriate with the flexibility being built into the local development plan for Aberdeenshire, along with continued support from Council services and other agencies likely to result in the most tangible benefits.

The three elements of the spatial strategy in the plan are in no way hierarchical, but enable an appropriate response to individual issues and circumstances. Improving the economic, environmental and social future of Fraserburgh is very important for the future of Fraserburgh itself and Aberdeenshire Council. The final paragraph on p.5 of the draft plan makes it clear that the importance given to each aim of the plan will be critical in coming to decisions on development proposals. The status of Fraserburgh as a RPA will influence the balancing process in a way that may not be appropriate in other areas.

Rep. Number

334 8 Subject SS(RPA) Summary The right areas have been defined as Regeneration Priority Areas. However there is no real strategy outlined for them and this is an important flaw in the draft plan.

Draft Response: Acceptance: Partially accept Changes to be made

There will be further details provided in relation to the Regeneration Priority Areas to avoid confusion.

Rep. Number

335 3 Subject SS(RPA) Summary There is a need to improve the linkages between the settlements in Banff to Peterhead Regeneration Priority Area.

Draft Response: Acceptance: Noted Changes to be made

The structure plan acknowledges the need to improve linkages throughout the region and the Key Diagram illustrates better linkages between Aberdeen, Banff and Fraserburgh.

The structure plan sets the framework for local and regional transport strategies which will provide higher levels of and more specific guidance.

Rep. Number

14 January 2009 Page 205 of 244 349 17 Subject SS(RPA) Summary The difficulties associated with the Regeneration Priority Areas will require to be addressed in a more specialised manner that will optimise available transferable skills while preserving the sense of community identity. The regeneration of these areas is vitally important and the Group recognises that the needs of the areas so designated will be more suitable and effectually provided for under this aspect of the Plan.

The future of Fraserburgh, Banff and Macduff are of particular concern due to the decimation of the fishing industry. The expertise of these areas must be preserved and appropriate business diversification encouraged.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcome.

The RPAs are aimed at improving the economy and competitiveness of business, improving infrastructure and the development of tourism as these aspects will contribute to the regeneration of the identified areas. Further information on RPAs and the benefits and procedure will be provided in the final plan.

The structure plan can only influence business diversification and economic growth so far, it will be for other plans and strategies to take the land use framework provided in this document forward, secure funding and build on it.

Rep. Number

350 13 Subject SS(RPA) Summary The plan has nothing concrete to offer the RPA’s, which, to my mind are included to try and stave off the criticism that in practical terms all developments is going to the SGA’s. 75 percent of all homes to be built and employment land developed to be in the SGA’s by 2030, this mean only 25 percent for the rest of Aberdeenshire. This is an assault on the rights of all Aberdeenshire citizens to be treated fairly, Fraserburgh desperately needs affordable housing.

Draft Response: Acceptance: Do not accept Changes to be made

The spatial strategy recognises the circumstances in Fraserburgh (and other similar communities) through their dual designation as regeneration priority areas and areas for local growth and diversification. These designations provide flexibility for the Aberdeenshire local development plan (LDP) to respond accordingly, with relevant policies and proposals. Also importantly, the LDP will have complete autonomy to promote the reuse of brownfield land and to designate a proportion of the significant level of residential allocation made to the RHMA and an appropriate amount of employment land.

The initial production of the LDP has begun and further work will be undertaken throughout 2009, this will involve community council’s and other representatives, local businesses and individuals with an interest. Consultation will be key to ensuring the framework set down by the structure plan is translated into realistic LDP policies and allocations and tangible proposals are delivered for communities within RPAs .

The three elements of the spatial strategy in the plan are in no way hierarchical, but enable an appropriate response to individual issues and circumstances. Improving the economic, environmental and social future of RPAs is very important for the future of the RPAs themselves and Aberdeenshire Council. The final paragraph on p.5 of the draft plan makes it clear that the importance given to each aim of the plan will be critical in coming to decisions on development proposals. In this respect, RPA status for Fraserburgh can influence the weight given to each aim, resulting in a positive impact that may not be appropriate in other areas.

There is a strong commitment to provide housing for the whole community in the plan. This can be observed in the Sustainable mixed communities chapter. The particular need for affordable housing in Fraserburgh will be picked up through the local housing strategy and local development plan.

Rep. Number

356 3 Subject SS(RPA) Summary Appears to be a general commitment to retain green space east of the railway line around the coastal villages, this is welcomed.

Draft Response: Acceptance: Noted Changes to be made

The quality of the environment statement does say "Biodiversity, wildlife habitats and landscape can be vulnerable to new development. As a result, we need to focus on maintaining and improving them, especially where there are plans for development." No specific mention of protected areas are mentioned but this is an issue that could be specifically addressed under the LDP.

Rep. Number

14 January 2009 Page 206 of 244 360 1 Subject SS(RPA) Summary Objection to the draft plan as proposed.

Raised concern that Aberdeenshire Council have failed the citizens of Fraserburgh in the following ways: - Standard of education provided by Fraserburgh Academy resulting in the poorest level of educational attainment in the Grampian area with the lowest percentage of pupils moving on to Higher Education. - Planning applications involving development of new and diverse businesses refused despite support from members of the Community Council and individuals. Out of town applications are refused on ground of detrimental effect on the town centre. Town centre in need of adequate parking facilities. Local shops are not open for the entire working week forcing residents to travel to Peterhead. - Sense of intimidation felt in the town. Boarded up windows of council houses, private dwellings and commercial properties. - Tourism is regularly viewed as a means to save the town however very limited accommodation is on offer for visitors due to all year round clients (travelling salesman etc) booking hotel rooms. Recently Aberdeenshire Council refused an application for a new hotel.

Acknowledged that money has been invested in the town via the Fraserburgh Future’s Partnership and Building Buchan – new beginnings however it was questioned what this money has actually done for the town as no evidence of more or better jobs is apparent.

Raised concern for the next generation of adults.

Raised concern that tourism rate has decreased.

Appreciated that new houses are needed but improvements in the town are immediately needed before any further housing developments occur.

Draft Response: Acceptance: Noted Changes to be made

The points made emphasise why Fraserburgh is in need of regeneration and economic diversification, as highlighted in the plan. Improving the economic, environmental and social future of Fraserburgh is very important for the future of Fraserburgh itself and to Aberdeenshire Council.

Rep. Number

361 7 Subject SS(RPA) Summary The proposals should be based on empirical study and data rather than theory. It is suggested that only bodies, which have access to information on social deprivation, economic decline, or physical and environmental depression, can be in a position to define where regeneration areas should be and the associated actions.

Draft Response: Acceptance: Noted Changes to be made

Proposals are based on empirical survey involving up-to-date and relevant statistics, covering the issues discussed. In addition, extensive consultation was carried out with key stakeholders and the public. Regeneration action will be targeted by the Councils and the Scottish Index of Multiple Deprivation will be an important statistical source for this.

Rep. Number

411 8 Subject SS(RPA) Summary Suggested a coastal facilitiy incorporating a new marina to help regenerate the Inverbervie/Gourdon community area. It is important to provide work to suit a variety of people skills in the area. Would improve leisure and recreation in the coastal strip without over-loading Stonehaven.

Draft Response: Acceptance: Noted Changes to be made

The structure plan operates at a strategic level and it is the role of the local development plan process to allocate indivivual sites.

Rep. Number

424 6 Subject SS(RPA) Summary Regeneration priority areas are actually confined within several towns and part of the City.

Why the coastal area as a whole is marked for regeneration? What kind of "regeneration", brown field site development, within the towns?

How to "regenerate" the environment of the coastal areas, where many of the places are natural landscapes? What is the point to regenerate the areas, where proper public transport link to the City is not identified for the next over 20years? Deprived groups will continue to be excluded from the main facilities in the City.

Draft Response: Acceptance: Noted Changes to be made

Many of the coastal towns of Aberdeenshire have suffered in recent years with the down turn in the oil industry and people choosing to holiday abroad. Many of the smaller towns have areas of brownfield land that could be redeveloped to improve the area. Regeneration also involves encouraging people to live and work in these areas by bringing employment and development in. The aims and objectives of the plan are storngly focused on improvign public transport there is a specific objective on accessibility.

14 January 2009 Page 207 of 244 Rep. Number

426 7 Subject SS(RPA) Summary We have been funding ‘regeneration priority areas’ under a range of names for 50+ years and are not good at doing it. Release control and let the free market deal with this.

Draft Response: Acceptance: Do not accept Changes to be made

The intervention is required to redress the unbalanced development that has taken place in the past. The 'free market' has in the past and is likely to continue to widen the inequalities and will not improve the situation. 426 20 Subject SS(RPA) Summary If powers existed to achieve the notions set out, there would be a danger of trying to create a centrally planned economy.

Draft Response: Acceptance: Do not accept Changes to be made

It is the role of the planning system to intervene in the development process in the public interest.

Rep. Number

441 16 Subject SS(RPA) Summary Supports regeneration proposals.

new settlements sound to be a solution to an immediate problem but will not solve the bigger challenge in the future

Draft Response: Acceptance: Noted Changes to be made

The support for this aspect of the plan is welcome.

Rep. Number

449 6 Subject SS(RPA) Summary Regeneration must not be too tightly targeted. Every settlement is important to those who live there and no one will want to feel cut off from progress.

Draft Response: Acceptance: Noted Changes to be made

Regeneration does not cut anyone off from progress. Every settlement is important and this is recognised within the plan. Regeneration is required in some to improve them and make them more attractive for investment not to have any negative effect.

Rep. Number

457 6 Subject SS(RPA) Summary The regeneration areas generally have sufficient infrastructure but important to renew schools, libraries etc to make these settlements more attractive places to live.

Draft Response: Acceptance: Noted Changes to be made

The support, and provision, of infrastructure play a key role in assisting to deliver the plans vision and spatial strategy.

Rep. Number

469 5 Subject SS(RPA) Summary RPA's are OK within existing settlements, but the areas shown include many of the finest coastal natural assets within the region and it is crucial that these areas are not damaged by regeneration development.

Draft Response: Acceptance: Accepted Changes to be made

Environmental quality is vital to the future of the area and the plan acknowleges the need to ensure that development does not reduce the environmental quality throughout the city region.

The plan does not suggest new development in sensitive locations.

Rep. Number

14 January 2009 Page 208 of 244 470 7 Subject SS(RPA) Summary The provision of affordable housing is a pre-requisite to achieving economic growth, particularly in regeneration areas. The plan needs to create more flexibility to expand the opportunities for tourism and more emphasis on building on the rich culture and heritage of these areas for economic gain needs to be addressed in the plan.

The structure plan must recognise the important economic contribution of the rural area and ensure that the right quantity and quality of business land is made available throughout the region to accommodate growth.

Draft Response: Acceptance: Noted Changes to be made

There is a strong commitment to provide affordable and social housing in the plan and this is central to the concept of sustainable mixed communities and will be pursued through masterplans at a local level. The housing need and demand assessment will be used to imform levels of affordable housing required throughout the city region.

The plan acknowledges the potential for development of the tourist industry with the Regeneration Priority Areas. While the concept of building on the cultural and heritage of the area is central to the plan, as can be observed with the Quality of the Environment Objective.

Rep. Number

472 5 Subject SS(RPA) Summary The right areas have been identified as RPA's in Aberdeenshire. The Aberdeenshire Community Planning Partnership will have responsibility for the Fairer Scotland Fund, which is in essence a 'regeneration' fund. A far as the City is concerned, the strategy is appropriate and achievable within the timescales.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. It is encouraging to have confirmation that the strategy is achievable.

Rep. Number

476 5 Subject SS(RPA) Summary In the RPA, the possibility of development away from towns and settlements should be allowed for where specific regeneration objectives will be delivered.

Draft Response: Acceptance: Do not accept Changes to be made

The final decision on where development will and will not be allowed will be taken through the Local Development Plan process.

Rep. Number

185 7 Subject SS(SGA) Summary Assume that any settlement within the Strategic Growth Areas will be supported for expansion under this aspect of the plan.

Welcome the Cross Rail proposals and the further improvements to the bus service.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. It should not be assumed that all settlements within the SGAs will be appropriate for development, this is for the Local Development Plan to determine.

A copy of your representation will be forwarded to the relevant Team.

Support for this aspect of the plan is welcomed.

Rep. Number

186 7 Subject SS(SGA) Summary Pleased to note the identification of the Huntly to Laurencekirk SGA.

Own land near Insch but no detail of area beyond diagram, presume that expansion of unspecified settlements within the SGAs is still in accordance with the strategy.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

14 January 2009 Page 209 of 244 Rep. Number

189 1 Subject SS(SGA) Summary Control a substantial area of land in excess of 100 hectares to the south of Stonehaven and identify it as having significant potential to contribute to the sustainable growth of the town as advocated by the draft Structure Plan.

Put forward a justification for the inclusion of the area of land to the south of Stonehaven at East Newton Leys.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 189 3 Subject SS(SGA) Summary Stonehaven is ideally located on the road and rail network to accommodation significant sustainable growth. It benefits from the existing railway station, being capable of capitalising on the Crossrail proposal, WPR and benefits from direct access onto the A90.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 189 9 Subject SS(SGA) Summary Justification submitted for the land to the South of Stonehaven in terms of the objectives of the Draft plan.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

190 5 Subject SS(SGA) Summary Further consideration needs to be given to the extent of the Strategic Growth Area and the scale of development within the AHMA outwith the Strategic Growth Areas. The overall housing and employment numbers need to be increased to reflect the most optimistic forecasts to encourage growth in the area.

Draft Response: Acceptance: Do not accept Changes to be made

These allocations reflect the Aberdeen City and Shires high projections already. There is a significant level of development proposed within the AHMA for the amount of settlements available. No further allocations will be made within these areas. The employment figures will be for the LDP to decide but they will reflect local need. 190 6 Subject SS(SGA) Summary Take exception to the assertion in this section (page 7, paragraph 3) where it states that landowners will need to provide several hundred million pounds' to help to fund improvements to infrastructure and community facilities. This statement is unhelpful and has no basis in terms of current or emerging legislation.

Government policy is to seek contributions that are in scale and kind to the development proposal and generally provide mitigation not to address, retrospectively shortfalls in infrastructure and community facilities.

This requires further clarification in the plan and a more realistic approach adopted.

Draft Response: Acceptance: Noted Changes to be made

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

14 January 2009 Page 210 of 244 191 2 Subject SS(SGA) Summary Control 65 hectares of land at Blackburn and identify it as having significant potential to contribute to the sustainable growth of the town as advocated by the draft Structure Plan.

Put forward a justification for the inclusion of the area of land to the north of Blackburn.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 191 3 Subject SS(SGA) Summary Blackburn is ideally located on the road and rail network to accommodation significant sustainable growth. It benefits from the existing railway and would maximize the use of infrastructure along the corridor and utilize and enhance the already well established public transport.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 191 5 Subject SS(SGA) Summary Take exception to the assertion in this section (page 7, paragraph 3) where it states that landowners will need to provide 'several hundred million pounds' to help to fund improvements to infrastructure and community facilities. This statement is unhelpful and has no basis in terms of current or emerging legislation.

Government policy is to seek contributions that are in scale and kind to the development proposal and generally provide mitigation not to address, retrospectively shortfalls in infrastructure and community facilities.

This requires further clarification in the plan and a more realistic approach adopted.

Draft Response: Acceptance: Noted Changes to be made

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities. 191 6 Subject SS(SGA) Summary Need to update the Strategic Forecasts to reflect more recent national projections.

Sufficient land should be allocated to meet the GRO recent projections of a population of 500,000 by 2031. Increased population equals increased people so an increased housing requirement. Need to increase the allocations.

Further justification for increasing the housing numbers is that the headline figure includes 5,000 houses emerging for regeneration areas within the city. These are simple replacements and because of this the net increase being promoted by the plan is 67,000 not 72,000.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan provides significant opportunities for development early in the plan period. This will be able to accommodate a range of growth scenarios prepared by the councils. Although the GRO(S) high migration scenarios is higher than the most optimistic of the three forecast scenario prepared by the councils, the Aberdeen City and Shire Strategic Planning Committee, in January 2008, agreed that the GRO(S) projection did not invalidate the AC & S forecasts.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

The plan will be replaced with a strategic development plan within five years and the opportunity will be taken at that point to re-access progress.

Rep. Number

14 January 2009 Page 211 of 244 192 2 Subject SS(SGA) Summary Control land at south of Blackburn and identify it as having significant potential to contribute to the sustainable growth of the town as advocated by the draft Structure Plan.

Put forward a justification for the inclusion of the area of land to the north of Blackburn.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 192 3 Subject SS(SGA) Summary Blackburn is ideally located on the road and rail network to accommodation significant sustainable growth. It benefits from the existing railway and would maximize the use of infrastructure along the corridor and utilize and enhance the already well established public transport

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 192 5 Subject SS(SGA) Summary Take exception to the assertion in this section (page 7, paragraph 3) where it states that landowners will need to provide 'several hundred million pounds' to help to fund improvements to infrastructure and community facilities. This statement is unhelpful and has no basis in terms of current or emerging legislation.

Government policy is to seek contributions that are in scale and kind to the development proposal and generally provide mitigation not to address, retrospectively shortfalls in infrastructure and community facilities.

This requires further clarification in the plan and a more realistic approach adopted.

Draft Response: Acceptance: Do not accept Changes to be made

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities. The plan makes it clear that the public sector also has a role to play. 192 6 Subject SS(SGA) Summary Need to update the Strategic Forecasts to reflect more recent national projections.

Sufficient land should be allocated to meet the GRO recent projections of a population of 500,000 by 2031. Increased population equals increased people so an increased housing requirement. Need to increase the allocations.

Further justification for increasing the housing numbers is that the headline figure includes 5,000 houses emerging for regeneration areas within the city. These are simple replacements and because of this the net increase being promoted by the plan is 67,000 not 72,000.

Draft Response: Acceptance: Do not accept Changes to be made

The structure plan provides significant opportunities for development early in the plan period. This will be able to accommodate a range of growth scenarios prepared by the councils. Although the GRO(S) high migration scenarios is higher than the most optimistic of the three forecast scenario prepared by the councils, the Aberdeen City and Shire Strategic Planning Committee, in January 2008, agreed that the GRO(S) projection did not invalidate the AC & S forecasts.

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

Rep. Number

14 January 2009 Page 212 of 244 193 5 Subject SS(SGA) Summary Further consideration needs to be given to the extent of the Strategic Growth Area and the scale of development within the AHMA outwith the Strategic Growth Areas.

The overall housing and employment numbers need to be increased to reflect the most optimistic forecasts to encourage growth in the area.

Draft Response: Acceptance: Do not accept Changes to be made

These allocations reflect the Aberdeen City and Shires high projections already. There is a significant level of development proposed within the AHMA for the amount of settlements available. No further allocations will be made within these areas. The employment figures will be for the LDP to decide but they will reflect local need.

Rep. Number

194 6 Subject SS(SGA) Summary Further consideration needs to be given to the extent of the Strategic Growth Areas (SGAs). Feel that growth will be restricted because it is not identified as a SGA.

It is considered that Westhilll should be included in the SGA in light of its strategic importance in the City Region.

Draft Response: Acceptance: Do not accept Changes to be made

These allocations reflect the Aberdeen City and Shires high projections already. There is a significant level of development proposed within the AHMA for the amount of settlements available. No further allocations will be made within these areas. The employment figures will be for the LDP to decide but they will reflect local need. 194 9 Subject SS(SGA) Summary Submit a justification for Westhill to be located in an SGA. Some of the reasons being due to linkages, recent strategic role in terms of housing and employment land, and better linkages once WPR constructed.

Westhill employment land uptake exceeds every settlement within the AHMA apart from Portlethen. This includes being higher than Inverurie and Blackburn who are both located in the SGA.

It is felt that Westhill can accommodate further growth while still tying in with the aims of the draft plan.

Draft Response: Acceptance: Do not accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. 194 10 Subject SS(SGA) Summary If Westhill is not given SGA status it should be given a specific allocation along with other main settlements within Aberdeenshire.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites in Westhill will be determined through the Local Development Plan process.

Westhill has seen significant growth in recent years in housing terms and more recently in employment. However, Westhill does not naturally fall within a ‘corridor’ in the same way as those identified in the plan but stands alone just outside the Aberdeen City boundary.

The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time.

Rep. Number

14 January 2009 Page 213 of 244 195 6 Subject SS(SGA) Summary Housing is as equally as important in the Peterhead corridor as employment is, in all three plan periods.

Draft Response: Acceptance: Accepted Changes to be made

It is acknowledged that housing and employment run in parallel with each other however there are infrastructure constraints in this corridor that require to be addressed prior to houses being built. This is reflected in the lower numbers in the first plan period.

There are 2,000 houses proposed in the Peterhead - Hatton corridor is a substantial allocation considering there are few settlements that could take a strategic level of growth. In addition, the 2008 Housing Land Audit illustrates a number of constrained sites at the current time. 195 7 Subject SS(SGA) Summary Welcome the energetica initiative being included in the plan.

Energetica aims to attract and retain people but have concerns that there is insufficient housing allocated for this location.

More housing should be allocated particularly in the first period.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

It is acknowledged that housing and employment run in parallel with each other however there are infrastructure constraints in this corridor that require to be addressed prior to houses being built. This is reflected in the lower numbers in the first plan period.

Currently there are 4,400 houses proposed in the Aberdeen to Peterhead corridor which is a substantial allocation. However, an increase of 1,000 units in the Blackdog to Ellon corridor is proposed, taking the total allocation to 5,400 units. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects.

Rep. Number

203 1 Subject SS(SGA) Summary Broadly supportive of the spatial strategy and identification of SGA's.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

212 2 Subject SS(SGA) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Peterhead. Aware of work on Energetica and ask that it be more explicitly reflected in the final plan.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed.

Energetica is mentioned in three sections of the plan along with also being mentioned in the glossary. The glossary definfition is explicit and refers to who is promoting the initiative should further information be required.

At the time the draft structure plan was prepared, the Energetica concept was not well developed. However, a ‘strategic framework’ has since been published which sets out more clearly what it might mean. Although the detail of the framework is not something that can be supported through the structure plan, the concept of supporting economic growth in the corridor is. The Action Programme will need to set out how the concept can be further developed and implemented.

Rep. Number

14 January 2009 Page 214 of 244 213 2 Subject SS(SGA) Summary Support the principle of the spatial strategy with three SGA’s along the main transport and economic corridors, in particular Aberdeen to Peterhead. Aware of work on Energetica and ask that it be more explicitly reflected in the final plan. Achievement of economic development and growth objectives in the spatial strategy will require additional growth at the northern end at Peterhead.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Energetica is mentioned in three sections of the plan along with also being mentioned in the glossary. The glossary definfition is explicit and refers to who is promoting the initiative should further information be required.

It is acknowledged that housing and employment run in parallel with each other however there are infrastructure constraints in this corridor that require to be addressed prior to houses being built. This is reflected in the lower numbers in the first plan period.

Currently there are 4,400 houses proposed in the Aberdeen to Peterhead corridor which is a substantial allocation. However, an increase of 1,000 units in the Blackdog to Ellon corridor is proposed, taking the total allocation to 5,400 units. The majority of these will be for the later periods of the plan, reflecting infrastructure constraints that exist and expected delivery of committed transport projects. There are no plans to increase the allocations at Peterhead, however the plan will regularly be amended to include improvements to the A90.

Rep. Number

216 3 Subject SS(SGA) Summary Close proximity to Peterhead and recognition as a quality place to live will continue to create demand for housing land in Mintlaw. Therefore request that the Mintlaw is included within the boundary of the Ellon to Peterhead corridor.

Greater emphasis should be given to the role of settlements that lie outwith the SGA’s, in particular the market towns and major service centers, such as Mintlaw.

Draft Response: Acceptance: Do not accept Changes to be made

Mintlaw clearly does not fall within the Aberdeen to Peterhead SGA. However, it is an important town in the area and it will be for the local development plan to identify the appropriate scale of growth for the town to meet local needs.

Rep. Number

234 10 Subject SS(SGA) Summary SGA's if applied too rigorously could restrict development in areas perfectly suited to growth. Suggest the plan therefore apply a criteria based approach to identifying settlements suitable for development.

Draft Response: Acceptance: Do not accept Changes to be made

Site specific allocations will be determined through the Local Development Plan process. Beyond the settlements shown on the key diagram it will be for them to determine what is in and what is out of the SGA corridor and what level of development each settlement should take.

Rep. Number

235 9 Subject SS(SGA) Summary SGA's if applied too rigorously could restrict development in areas perfectly suited to growth. Suggest the plan therefore apply a criteria based approach to identifying settlements suitable for development.

Draft Response: Acceptance: Do not accept Changes to be made

Opportunities for growth outside SGA's are shown in Schedule 1 (housing) and there is no restriction on the amount of employment land that the local development plan can allocate to satisfy local need.

Rep. Number

14 January 2009 Page 215 of 244 245 1 Subject SS(SGA) Summary Clients are concerned that the proposed strategic growth corridors associated with the Huntly to Laurencekirk and Aberdeen to Peterhead trunk roads have been delineated too lightly. The danger is that what should be a flexible and responsive guideline will become a hard and fast rule with, quite possible, a fixed distance measured from the road becoming established practice when determining planning applications. This could be a problem at Kinmuck and Fintray, as well as other, similar, small settlements where the additional modest housing development can be a boon to the local community and, often, a real support for a local primary school. There seems no good reason, in our view, why such a corridor should not have an irregular edge to take advantage of - and be benefit to - existing population centers of whatever size.

Draft Response: Acceptance: Do not accept Changes to be made

It is not proposed to suggest a fixed width for the corridors but the plan will emphasise that they are a concept around good access to high quality public transport. Modest growth for local needs ins provided for outwith the SGAs and not all locations in SGAs can expect to see significant levels of growth.

Rep. Number

253 1 Subject SS(SGA) Summary Representation 253 promotes future growth at Blackdog, Aberdeenshire. Several planning policies which support the proposal are listed and related to the potential development.

Given the strategic nature of the proposals, it is considered that the emerging Structure Plan ought to recognize the locational benefits of the subject land given its proximity to the future A90/AWPR Interchange and the settlement of Blackdog. The proposals strive to provide a high quality, energy efficient and strategically planned development which is a tailored response to the site setting.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 253 3 Subject SS(SGA) Summary With respect to the draft Plan’s Spatial Strategy, the subject land falls within he Aberdeen to Peterhead Strategic Growth Areas (SGA), one of the three designated SGA’s where 75-80% of employment development is to be directed. The Aberdeen to Peterhead SGA is recongised as a prime area for economic growth and diversification due to the important strategic assets in the area.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. There are 5,400 houses proposed in the Aberdeen to Peterhead corridor which is a substantial allocation, compared to what has been proposed in the past for development in this corridor. 253 6 Subject SS(SGA) Summary To conclude, it is acknowledged that the majority of economic growth within the SGA will be focused on both Ellon and Peterhead being the largest concentrations of development within the corridor. However, there is no reason why an element of future growth, as proposed, could not satisfactorily accommodated at the strategically important AWPR Interchange/Blackdog.

Draft Response: Acceptance: Noted Changes to be made

It is agreed that economic growth can also be accommodated outwith the towns of Ellon and Peterhead in that corridor. However the allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 253 7 Subject SS(SGA) Summary The site falls within the Aberdeen to Peterhead Strategic Growth Area, identified in the emerging Structure Plan as a primary area for economic growth with increased levels of housing development in the longer term. In this regard, the subject land would make a positive contribution to business land requirements in this Strategic Growth Areas, delivering economic growth through the provision of tourism and specialist retail facilities at this gateway location. The scale of the proposed development is commensurate with this designation for strategic growth.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

14 January 2009 Page 216 of 244 253 9 Subject SS(SGA) Summary To conclude, it is acknowledged that the majority of growth within the SGA will be focused on both Ellon and Peterhead being the largest concentrations of development within the corridor. However there is no reason why the proposed future growth could not be satisfactorily accommodated at Blackdog to build upon the existing settlement and its proximity to the A90/AWPR junction and to create a more sustainable form of development, including increased facilities, while allowing for a greater degree of flexibility and choice in the best interests of both the local and wider community.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

255 7 Subject SS(SGA) Summary Bancon consider that the next focus for sustainable growth should be the settlements on good transport corridors within the AHMA (which includes Ellon and Balmedie). It is felt that this would be preferable (from a sustainability perspective) to forcing development into areas which are less attractive to the market, and where historically development has been slower. This is not too say that Bancon do not support the ‘Energetica’ proposals. Indeed that economic agenda is highly desirable. Rather, they suggest that exceptional residential growth is not necessarily required to secure these economic development projects. With regard to Energetica, however, Bancon consider that it is necessary to increase the geographical range of the strategic growth area to bring it in line with the aspirations of ACSEF and the Energetica masterplan.

Draft Response: Acceptance: Do not accept Changes to be made

The planning system has a role to guide the market as well as respond to it. The corridor to Peterhead is designed to have an economic development - led focus and is one element of an appropriate response to the challenges in the north of Aberdeenshire. There are no planning reasons to justify a different approach to the definition of the SGA in this area. 255 10 Subject SS(SGA) Summary Bancon have suggested their own figures for future development and therefore could not support the targets as currently set for delivering the spatial strategy. In particular, they would strenuously oppose the concept that all ‘strategic developments’ (which are as yet undefined) meeting the needs of the city Region, should be located within the SGAs as currently constituted.

However, Bancon’s alternative development strategy in essence suggests that there should be 4 rather that 3 SGA’s: Aberdeen, the railway corridor, the AHMA corridors and the Energetica corridor.

In addition to the above assessment, if the scale of growth is not to be reconsidered, then Bancon would question whether there is any benefit in maintaining the distinction between the Aberdeen and the Rural Housing Market Areas.

Draft Response: Acceptance: Do not accept Changes to be made

The A93 corridor was not identified for strategic growth for a number of reasons, not least the fact that public transport is less attractive, the environment is ore sensitive and the strategic advantages more limited. The two HMAs have an important role in delivering the strategy of the plan.

Rep. Number

261 13 Subject SS(SGA) Summary We have no particular issue on the regeneration areas other than where new housing simply replaces existing stock this does not contribute to the housing land supply.

Draft Response: Acceptance: Partially accept Changes to be made

The forecasts on which the housing numbers are based took account of a significant level (4,800) of demolitions in the Community Regeneration Areas in Aberdeen. These units do not represent double counting because the forecast required for housing would have been 4,800 lower if they had not been included.

However, changing expectations of the nature and speed of delivery of the Community Regeneration Strategy mean that these figures will need to be revised downwards. Due to the status of these units however (as outlined above), they do not require to be replaced. Progress and future expectations, however, will be kept under review and this plan would encourage faster progress than the plan may suggest.

14 January 2009 Page 217 of 244 261 15 Subject SS(SGA) Summary It is acknowledged that the draft plan has not tried to be too much of a constraint on the development of local plans however this leaves much for local plans to consider and perhaps clearer direction would avoid prolonged debate. In terms of our own interests firmer guidance on the areas of allocation within the SGA's would be welcomed.

Draft Response: Acceptance: Do not accept Changes to be made

Beyond those settlements specifically shown on the key diagram it is for the LDP to determine whether they are within the SGA or LG&DA. The structure plan only leaves the local plan non strategic issues. 261 16 Subject SS(SGA) Summary With regards the requirement for employment land within the SGA's we are of the opinion that the targets should be more specific to avoid land being taken into consideration over a wide area which creates distortion on availability. Indeed as an example it is our opinion that the current "Inverurie corridor" allocation which covers Blackburn to Inverurie has not been helpful and this is obvious when you consider the amount of Inverurie-based businesses which have been forced to move to Kintore due to the lack of available and suitable sites within Inveruries itself. To achieve balanced sustainable communities clearer direction is required on this matter.

Draft Response: Acceptance: Do not accept Changes to be made

The plan makes it clear that it is seeking sustainable mixed communities with mixed-use development being encouraged. It will be for local develoopment plans to identify the appropriate balance in individual communities as this is not a strategic issue.

Rep. Number

262 1 Subject SS(SGA) Summary We support the focus on development within the Strategic Growth Areas (SGA). In particular we support the focus on the Huntly to Laurencekirk corridor, given the ability to capitalise upon good public transport links (and to justify improving such links where necessary), and given that this corridor includes a number of local centers (e.g Stonehaven, Portlethen and Inverurie), whose role can be strengthened by strategically planned development.

Draft Response: Acceptance: Noted Changes to be made

The comments are in agreement with the Draft Structure Plan but it should be noted that the allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

263 1 Subject SS(SGA) Summary We support the focus on development within the Strategic Growth Areas (SGA). In particular we support the focus on the Huntly to Laurencekirk corridor, given the ability to capitalise upon good public transport links (and to justify improving such links where necessary), and given that this corridor includes a number of local centers (e.g Stonehaven, Portlethen and Inverurie), whose role can be strengthened by strategically planned development.

Draft Response: Acceptance: Noted Changes to be made

The comments are in agreement with the Draft Structure Plan but it should be noted that the allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

264 7 Subject SS(SGA) Summary The comments on page 7 relating to Aberdeen City are frankly banal and serve to deceive with regard to the impact of the greenfield allowance shown on Schedule 1. The greenbelt review really requires to have been completed to establish it's capacity to accommodate such a level of development.

Draft Response: Acceptance: Do not accept Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; this is shown clearly in Schedule 1. In the City this will involve a review of the green belt as also stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

14 January 2009 Page 218 of 244 264 8 Subject SS(SGA) Summary In relation to the Huntly-Laurencekirk corridor there are clearly capacity and infrastructure constraints which preclude the dumping of further massive allocations in the identified settlements in a manner identical to that seen in NEST. A repetition of NEST will not assist the Cross Rail project nor will it deliver economic growth or benefit. It will merely further devastate a limited number of settlements.

Draft Response: Acceptance: Noted Changes to be made

Phasing within particular corridors is based on infrastructure constraints that will need to be resolved prior to significant levels of development taking place. An example of this is the limited numbers in the A90 (north) corridor until the AWPR, Balmedie to Tipperty dualling and Third Don Crossing are in place. It is also necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period.

The spatial strategy emerged after extensive consultation within the Council's and with communities and other stakeholders. This will give the Councils the flexibility to look at all opportunities and scenarios when producing their local development plan. It is likely that the majority of development in SGAs will be as extensions to existing settlements as this allows for the use of established services and facilities and maintains the sense of community.

The local development plan will ultimately make informed decisions on site specific allocations and it should be noted that significant amounts of development are being made available for distribution outside the SGA's, in the AHMA and RHMA. Links between settlements are recognised as important and whilst the plan can influence this to a degree, the Council's local transport strategy is the more appropriate mechanism for pursuing any enhancements sought. 264 9 Subject SS(SGA) Summary The Aberdeen-Peterhead corridor requires to be fully front end supported with an adequate housing and employment land supply.

Draft Response: Acceptance: Do not accept Changes to be made

There are 5,400 houses proposed in the Aberdeen to Peterhead corridor which is a substantial allocation, compared to what has been proposed in the past for development in this corridor.

Phasing is required within particular corridors as infrastructure constraints will need to be resolved prior to significant levels of development taking place. Aberdeen-Peterhead corridor is not front loaded as constraints such as the AWPR, Balmedie to Tipperty dualling and Third Don Crossing need to be resolved before more land is supplied.

Rep. Number

266 8 Subject SS(SGA) Summary I cannot understand why the area between Ellon and Peterhead attracts greater housing numbers over the plan's duration than Drumlithie to Marykirk. Peterhead has no rail link and a poor and congested road yet the council intends to invite further congestion by installing a further 2000 houses.

Draft Response: Acceptance: Noted Changes to be made

The majority of the development for the Ellon-Peterhead are for the later periods of the plan, reflecting infrastructure constraints that exist and the expected delivery of committed transport projects. Allocations will regularly be reviewed can be changed if circumstances change as required. The strategy for the Peterhead corridor is economic development led. Peterhead is a significantly larger town than Laurencekirk. 266 10 Subject SS(SGA) Summary We would suggest that more development could be apportioned to the Drumlithie to Marykirk area where there are better road and rail links.

Draft Response: Acceptance: Do not accept Changes to be made

Significant growth is proposed for this area compared to what has been in the past.

Rep. Number

267 23 Subject SS(SGA) Summary Guidance is required on how far from the A90 the southern growth corridor development should be.

Draft Response: Acceptance: Do not accept Changes to be made

Beyond those shown on the key diagram the specific settlements within the corridors will be determined through the Local Development Plan process.

Rep. Number

14 January 2009 Page 219 of 244 268 2 Subject SS(SGA) Summary Welcome the SGA between Aberdeen and Peterhead.

Would want Mintlaw to be included in this area for the following reasons:

- NPF2 shows the link between Aberdeen and Fraserburgh as a strategic transport route. Improvements would be made to the roundabout and thus improve connectivity,

- Mintlaw is included in the Energetica proposal,

- The proposal would provide a link between the SGA and RPA to the north.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcome.

Mintlaw is unlikely to be included in the Aberdeen to Peterhead Strategic Growth area. However, it will still be able to accommodate a level of growth appropriate to it, but this is a matter for the local development plan process.

Rep. Number

269 3 Subject SS(SGA) Summary Edzell woods is within or close to an SGA and should definitely be included in an SGA.

This should be done because it is located close to the A90 and the development would create bus links with the A90 and beyond.

Draft Response: Acceptance: Noted Changes to be made

The decision to whether a small village like Edzell Woods is included in an SGA is not taken at a strategic level. The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. 269 6 Subject SS(SGA) Summary The creation of a critical mass for sustainable mixed use community will require the construction of at least 1000-1500 houses.

To achieve the sustainable goals a further 500 houses are required for the South of Drumlithie - Marykirk corridor for the periods 2017-2023 and 2023-2030.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations to this corridor are already generous and have been given substantial consideration and been subject to technical assessment to ensure they are deliverable. Allocations will regularly be reviewed can be adjusted if circumstances require.

Rep. Number

270 2 Subject SS(SGA) Summary Further housing allocations are required in Kintore to secure community facilities and retail services in Kintore.

Draft Response: Acceptance: This is not a Structure Plan issue Changes to be made

The allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Kintore falls within the SGA, but the scale and location of any growth is a matter for the Aberdeenshire Local Development Plan, which will be subject to consultation throughout 2009. 270 3 Subject SS(SGA) Summary Creation of the rail hault in Kintore supports the allocation of further housing within the settlement.

Draft Response: Acceptance: Noted Changes to be made

Kintore is located within an SGA and could take an appropriate level of growth. The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service. However, the allocation of specific sites will be determined through the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

14 January 2009 Page 220 of 244 270 4 Subject SS(SGA) Summary Kintore's location within the Ury flood plain requires careful consideration for any future development, however this characteristic will ensure that the landscape impact of any such proposals will be minimal.

Draft Response: Acceptance: Noted Changes to be made

The Sustainable Development and Climate Change target on page 11 states "To avoid developments on land which is at risk from coastal flooding (as identified by SEPA except in exceptional circumctances).

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

272 3 Subject SS(SGA) Summary Note and support the SGA from Huntly to Laurencekirk.

Draft Response: Acceptance: Accepted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

273 10 Subject SS(SGA) Summary Development on the site at Newtonhill would meet the objectives and aims of the plan and be an extension to an existing community.

Draft Response: Acceptance: Noted Changes to be made

This is not a structure plan issue.

Rep. Number

274 1 Subject SS(SGA) Summary Own an area of land at Blackdog.

This site is within the Energetica corridor and with the completion of the AWPR as proposed or modified by the PLI would have significant development potential.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

275 1 Subject SS(SGA) Summary Own an area of land at the south east of the proposed Tipperty junction.

This site is within the Energetica corridor and with the completion of the AWPR as proposed or modified by the PLI might have significant development potential.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

14 January 2009 Page 221 of 244 276 5 Subject SS(SGA) Summary The SGAs should not be presented

-as the only places where development can occur in the city-region, nor -that these identified corridors should completely fill with development in the plan period. They also need to retain countryside, open space and leisure areas.

Draft Response: Acceptance: Noted Changes to be made

The spatial strategy clearly states that the SGAs are not the only place where development can occur, the rest of Aberdeenshire is covered by LG&DA and RPA designations which are separate numbers from the SGAs. The level of growth in these areas would have to meet local need. 276 6 Subject SS(SGA) Summary Broadly support the 75% of development in the SGAs by 2030 and 50% of the homes to be in the city.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

276 7 Subject SS(SGA) Summary There is a need to twin track the greenfield and brownfield release of land to provide attractive neighhbourhoods, a brownfield first sequential approach will not address the city's needs.

Draft Response: Acceptance: Do not accept Changes to be made

The mentions of the brownfield development within the plan does not mention a sequential approach. The words "particular priority", "preferred" and "priority" are used. It is acknowledged that green field land will have to be developed but the preferred option will always be brownfield land. This results in the reuse of land that has been previously developed and has gone out of use, these are often unsightly sites and their reuse is extremelly benefitial for the communities.

Rep. Number

278 9 Subject SS(SGA) Summary Request reconsideration of Westhill as it helps to meet all the objectives of the plan

Draft Response: Acceptance: Do not accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment.

The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. 278 10 Subject SS(SGA) Summary Circular 12/1996 provides a clear statement on Government policy in respect of contributions towards the provision of infrastructure and this should be reflected in DSP.

There is no provision for a land-tax.

Contributions should relate directly to the development proposed. They should also be fair and reasonable in relation to the scale of the proposed development.

Draft Response: Acceptance: Do not accept Changes to be made

The uplift in land values from allocation or granting of planning permission will remain very substantial and the public sector cannot be expected to fund all the necessary services and facilities needed to bring about sustainable mixed communities. This is not a land tax.

Rep. Number

14 January 2009 Page 222 of 244 279 3 Subject SS(SGA) Summary Craibstone is located within a strategic corridor and is immediately available to meet Aberdeen City’s emerging housing land requirements. It is located adjacent to employment sites (Dyce Drive), the airport, park and ride facilities and most crucially, the Western Peripheral Route, making its early release a sustainable option for Aberdeen City.

It will be critical, as part of that delivery process, bearing in mind the projected economic growth in Aberdeen based on the increased life expectancy of the oil industry that sites such as Craibstone are brought forward at an early stage.

We commend Craibstone as a growth option release site in full conformity with the aims and locational guidance contained in the Draft Structure Plan, and one which merits specific reference within the Finalised Structure Plan given the scale and locational aspects.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

Rep. Number

282 11 Subject SS(SGA) Summary There has been no meaningful consideration given to how the over-allocation of housing in the A90 (south) and A96 corridors will affect primary and secondary education requirements and the consequent cost to taxpayers.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations of housing referred to is considered to be acceptable, and the educational requirements of new residents have been fully considered in both phasing and overall numbers. The need for new schools is highlighted in the plan.

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Rep. Number

285 11 Subject SS(SGA) Summary If the SGA’s are to take 75% of the annual housing allocation, how does the 625 houses divide over the remainder of Aberdeeenshire; will one area loose out at the expense of another? Are the targets in addition to the redevelopment of existing housing stock?

Draft Response: Acceptance: Do not accept Changes to be made

It is unclear where the number 625 comes from. The LG&DAs areas (which are the areas outwith the SGAs and the city) currently have a total allocation of 17,100 houses for the period 2007-2030. However, it is proposed to reduce this to 16,100, with the loss being in the AHMA, reflecting the limited number of settlements. These numbers will be allocated by the Local Development Plan to areas of local need.

Rep. Number

286 9 Subject SS(SGA) Summary The proportion of the allocations for SGA’s should be 80%, not 75-80% as suggested in the plan.

Draft Response: Acceptance: Do not accept Changes to be made

The figure of 75% is a minimum target while 75%-80% is an expected range. These are consistent and do not require modification.

14 January 2009 Page 223 of 244 286 13 Subject SS(SGA) Summary Believe the brownfield targets are too ambitious and it has been demonstrated a number of times that there is limited remaining capacity in the City. The figures in the draft urban capacity study do not address our concerns and needs to be amended as it does not list the sites referred to in each annex, site areas or capacities of individual sites. This is needed to fully assess the study and the viability of each site. The UCS is flawed and the densities assumed are flawed.

Draft Response: Acceptance: Do not accept Changes to be made

Over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen. This level is substantially lower than in previous years, when brownfield development represented between 60-90%. The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result.

The Urban Capacity Study contained in the Background Paper provides the justification for the brownfield allowances until 2016. The allowances beyond 2016 will be reviewed in future strategic development plans in light of updated urban capacity information. 286 15 Subject SS(SGA) Summary Generally support approach to development in the Huntly to Laurencekirk corridor. However, would caution against over-allocating in secondary and tertiary market areas on the periphery of the corridor. Would also urge that Crossrail project is enhanced to ensure infrastructure delivery and to prevent lack of network capacity from constraining the strategy.

Draft Response: Acceptance: Noted Changes to be made

Support for these aspects of the plan is welcome. Housing allowances on the periphery of the corridors are already of a lower level. The delivery of the Crossrail programme of rail improvements is critical to the delivery of the strategy. 286 16 Subject SS(SGA) Summary Note that there is no specific guidance on where development in the corridor will take place. Believe that development should be spread to ensure releases are of a sufficient scale in any one location to contribute to facilities and infrastructure required, but also so that housing targets can be met.

Draft Response: Acceptance: Noted Changes to be made

Specific guidance will be part of the Local Development Plan process, it is for them to decide, beyond the settlements on the key diagram what is in the SGA and what is not. 286 19 Subject SS(SGA) Summary Development in the Aberdeen to Peterhead corridor is welcomed, particularly in the context of Energetica. Housing allocations should be focussed on the Blackdog to Ellon part of the corridor as any allocations north of this require to be monitored against the performance of Energetica. The allocations proposed up to 2030 risk non-delivery given the timeframes envisaged for infrastructure delivery and economic growth.

Draft Response: Acceptance: Noted Changes to be made

Site specific allocations will be determined through the Local Development Plan process.

The development proposed up to 2030 is largely dependant on constraints being lifted ie the AWPR being built. However these new style development plans ensure review every 5 years so this will be considered closer to the time when there is more certainty.

Rep. Number

287 10 Subject SS(SGA) Summary The proportion of the allocations for SGA’s should be 80%, not 75-80% as suggested in the plan.

Draft Response: Acceptance: Do not accept Changes to be made

The figure of 75% is a minimum target while 75%-80% is an expected range. These are consistent and do not require modification.

Rep. Number

14 January 2009 Page 224 of 244 289 6 Subject SS(SGA) Summary In recent years both Blackburn and Fintray have doubled in size, there are concerns that there will be a loss of community spirit and identity.

This is due to the lack of amenities and the fact that it has been allowed to develop this way.

This Draft Structure Plan will make the problem worse and will form in many cases dormitory settlements.

Draft Response: Acceptance: Noted Changes to be made

The allocation of specific sites will be determined within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team. Careful consideration will be given to site allocation and identification and a great emphasis is now being placed in infrastructure and facility provision. Along with the objectives of the plan past concerns should be cleared up.

Rep. Number

291 12 Subject SS(SGA) Summary The narrowness of the growth area of the Huntly to Laurencekirk corridor could result in issues of public transport to areas outwith the corridor.

Draft Response: Acceptance: Do not accept Changes to be made

It is unclear what is meant by this statement. There will be improvements to the public transport network within the corridor due to the increase in development. There may also be scope for development outwith the corridor but that is dependant on the LDP process and the appropriateness of any sites. It is unclear how this will have an impact on the area outwith the corridor but there is no reason why public transport would be reduced but it may possibly be increased depending on factors.

Rep. Number

296 4 Subject SS(SGA) Summary Lack of strategic guidance as to where development should be located.

Although growth corridors have been shown it gives little consideration to a new town.

Draft Response: Acceptance: Do not accept Changes to be made

The level of guidance provided is strategic. The allocation of specific sites will be determined within the Local Development Plan process.

Consideration was given to a new town during the consultation process but the decision was taken that the approach should be what is now in the Plan. No justification has been submitted within this rep for further consideration of a new settlement. 296 5 Subject SS(SGA) Summary The 2 new secondary schools that will be required should be located where there is no existing secondary school.

Draft Response: Acceptance: Noted Changes to be made

The location of the new schools will be dependant on the LDPs and where development is to take place. This will be considered in consultation with Education, Learning and Leisure.

Rep. Number

297 11 Subject SS(SGA) Summary The SGA heading assumes that growth is an essential component of the Structure Plan.

An aim states that there should be "enough people, homes and jobs" not that there should be more.

Draft Response: Acceptance: Do not accept Changes to be made

The aim to 'make sure the area has enough people, homes and jobs to support the level of services and facilities needed to maintain and improve the quality of life', must be read along with the rest of the plan, where there is clear indication that growth in population and the economy is essential to achieve the vision.

14 January 2009 Page 225 of 244 297 13 Subject SS(SGA) Summary Wrong that all strategic developments are to be in the SGA.

Majority should be in thesee areas but some development should be held in reserve for use elsewhere.

Draft Response: Acceptance: Do not accept Changes to be made

Not all development is within the SGA. There will be a significant level of development outwith these areas in the LG&DAs and the RPAs.

Rep. Number

299 6 Subject SS(SGA) Summary It is difficult to see where there is space for this very high level of house-building.

The draft calls on landowners to fund infrastructure, new schools etc, but no indication or guarantee that the landowners have the funds or the willingness to undertake these large investments.

Draft Response: Acceptance: Noted Changes to be made

The public sector cannot be expected to fund all the infrastructure and services required. The uplift in land values from allocation or granting of planning permission will remain very substantial and will fund the necessary services and facilities needed to bring about sustainable mixed communities.

Rep. Number

312 3 Subject SS(SGA) Summary Welcome the Energetica proposal and the SGA to Peterhead, but the housing allocation are slightly confusing.

Particularly in the context of the Trump and whether these numbers would be included in the total housing requirement of the SGA.

Our feeling is that Trump is in a different market place and therefore should not impinge on the SGA housing quota.

Draft Response: Acceptance: Noted Changes to be made

The support for this aspect of the plan is welcome.

The decision was made on 16 December 2008 by Scottish Ministers to grant outline planning permission subject to conditions and conclusion of a planning agreement for this proposal. The conditions include phasing conditions which preclude new homes until Phase 1 is complete and limits new housing development until the Balmedie to Tipperty dualling is complete.

This means that 500 new homes are now likely to be built in this corridor. These new homes were not accounted for in the effective land supply on the base date of the plan, so will need to be set against the allowance for the first two plan periods. This phasing between the first and second plan period should reflect the progress expected to be made on site and will allow the allocation of other sites through the local development plan.

Rep. Number

313 1 Subject SS(SGA) Summary Concerns with expanding the growth area between Stonehaven and Laurencekirk.

Concerns that a long band of development right through the mearns.

Draft Response: Acceptance: Noted Changes to be made

The spatial strategy emerged after extensive consultation within the Council's and with communities and other stakeholders. It is not intended to promote ribbon development along each SGA, but does give Aberdeenshire Council the flexibility to look at all opportunities and scenarios when producing their local development plan. It is likely that the majority of development in SGAs will be as extensions to existing settlements as this allows for the use of established services and facilities and maintains the sense of community.

The local development plan will ultimately make informed decisions on site specific allocations and it should be noted that significant amounts of development are being made available for distribution outside the SGA's, in the AHMA and RHMA. Links between settlements are recognised as important and whilst the plan can influence this to a degree, the Council's local transport strategy is the more appropriate mechanism for pursuing any enhancements sought.

Rep. Number

14 January 2009 Page 226 of 244 315 2 Subject SS(SGA) Summary Plan seems to be content to allow Inverurie to grow even further and faster despite the fact that the transport network is unable to cope.

There appears to be no logic on the allocations in terms of numbers, location or timing.

Draft Response: Acceptance: Do not accept Changes to be made

The allocations for the Inverurie to Blackburn corridor is backloaded, reflecting potential infrastructure constraints that exist and expected delivery of committed transport projects.The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. The plan strongly emphasises the need to ensure required infrastructure improvements are delivered and this has influenced the scale and phasing of development. 315 3 Subject SS(SGA) Summary Could not see any element to deal with loss of current employment or ways to attract new ones.

Draft Response: Acceptance: Do not accept Changes to be made

This is a land use plan and as such its scope is limited, it does however hope to create a climate where investment decisions can be taken and a framework where sufficient land in the right locations is available. Major economic initiatives can come from various sources in the public and private sector, the planning service can only hope to facilitate them.

The structure plan is closely aligned with ACSEFs Economic Action Plan and is one of the regional strategies and plans which have had an important influence on this plan.

An Action Programme will be prepared during 2009 which will set out the detailed actions required by the Councils and their partners to implement the plan.

Rep. Number

318 1 Subject SS(SGA) Summary We are unhappy with any development taking place in the "A96" corridor prior to vast improvements being made to the traffic infrastructure.

This particularly relates to the rail network and in this connection we would wish to see more "local" trains on the route from Stonehaven to Inverurie passing through the City.

Draft Response: Acceptance: Do not accept Changes to be made

Improvements will be required to junctions etc depending on the allocations proposed by the Local Development Plans. The large development at Portlethen is an example of this with the improvements that have taken place there.

Improvements in the frequency of rail travel from Aberdeen to Inverurie has already been anounced by Scotrail. Their announcement states that "additional services will run between Aberdeen and Inverurie" and that "services between Edinburgh and Aberdeen will be retimed to provide better connections to Perth and Dundee." Further proposals can be seen in the Regional Transport Strategy with strong encouragement for improvements coming through the Structure Plan. 318 2 Subject SS(SGA) Summary More thought should be given to permitting and in fact encouraging people working from home.

Draft Response: Acceptance: Accepted Changes to be made

The plan does not preclude home working. The principle of the sustainable mixed communities is to create communities where employment and residences are all located within the settlement. It ensures that they are well integrated with existing areas to improve peoples quality of life and opportunity.

Rep. Number

321 1 Subject SS(SGA) Summary We cannot emphasise strongly enough the strategic importance of developing the Blackdog to Peterhead corridor.

Currently the traffic flow level into Aberdeen from the north is high because of the lack of employment opportunities in the Peterhead to Blackdog corridor. By enabling development and creating employment opportunities, this flow can be stemmed and even reversed.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

14 January 2009 Page 227 of 244 321 5 Subject SS(SGA) Summary Research should begin now into the feasibility of the re-introduction of a rail link between Aberdeen and Peterhead.

Draft Response: Acceptance: Do not accept Changes to be made

The re-introduction of the Aberdeen - Peterhead rail link is unlikely at this time. If changes were proposed it would be developed through the Transport strategies. 321 6 Subject SS(SGA) Summary Work needs to begin on a new secondary school in Ellon with community facilities and further education opportunities.

This should be promoted in parallel with the potential new housing development.

It is not satisfactory to say that there should be no housing development because there are inadequate secondary education places.

Draft Response: Acceptance: Do not accept Changes to be made

The support, and provision, of infrastructure is an essential part of achieving sustainable mixed communities and is central to the plan. The plan strongly emphasises the need to ensure required infrastructure improvements are delivered.

The local development plan process will determine the level for growth to take place in Ellon, and so will determine the level of infrastructure required. Delivering the required infrastructure means that short-trem development is limited.

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed.

Rep. Number

325 2 Subject SS(SGA) Summary Concerns that there has been a lot of houses built in Kintore recently and it has problems with existing roads, facilities, existing industrial sites, lack of medical and dental facilities, too small new primary school etc.

Draft Response: Acceptance: Noted Changes to be made

Any future development will have to meet the objectives of the plan. The sustainable mixed communities objective in particular would ensure that past problems are not repeated.

Rep. Number

335 5 Subject SS(SGA) Summary PBTI supports the proposal for a Strategic Growth Area between Aberdeen and Peterhead.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

336 1 Subject SS(SGA) Summary The SGA principle within the plan appears to be largely geared to existing public transport availability with the exception of the SGA between Aberdeen and Peterhead but the application of that principle does not deliver fairness or equality across the Shire and despite a brave but very generalised vision statement in the plan to try and benefit all residing and working the in the Shire the plan is likely to create a two tier structure between those who have and those who have not.

Draft Response: Acceptance: Do not accept Changes to be made

The identified strategic growth areas and these represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services.

The concentration of 75-80% of development in these locations has other benefits related to economies of scale for provision of services and facilities. This is believed to be the most appropriate response to the challenges facing the north-east. It must also be noted that the plan will be subject to review within the next two years, which gives the opportunity to revisit the strategy.

14 January 2009 Page 228 of 244 336 4 Subject SS(SGA) Summary Fraserburgh is one of the most modern and the biggest Nephrops (Prawns) port in Europe and Peterhead is the biggest white fish port Europe. The absence from the plan of any real reference to fishing is almost unbelievable but this is consistent with the flawed SGA proposal for the majority of future development of the Shire.

Draft Response: Acceptance: Do not accept Changes to be made

There are six references to 'fishing' in the current Structure Plan (NEST)

All these references are descriptive, as a consequence, although the term 'fishing' isn't used in the draft structure plan its inclusion in NEST did not actually had any impact. The Structure Plan is more focused and action orientated than previous plans.

The plan details diversification which is a key issue in some of the fishing communities. Indeed, most of the fishing communities are identified as 'Regeneration Priority Areas' in recognition of the challenges they face.

There is scope however within the changes being made to the text on Regeneration Priority Areas to mention that Fraserburgh is a priority for redevelopment. 336 6 Subject SS(SGA) Summary The plan is short on significant detail, with those areas of the Shire not included in an SGA being justifiably concerned that their future economic/social interests are not regarded as sufficiently important compared to those included within a SGA with relation to the availability of existing or anticipated improved transport lines.

Draft Response: Acceptance: Noted Changes to be made

Further detail will be provided in the text specifically in relation to Regeneration Priority Areas, this will clarify the situation. Further information will also be given in relation to what is meant by better linkages to avoid uncertainty. 336 7 Subject SS(SGA) Summary Linking future investment to an unjustifiable and indefensible SGA principle will not achieve what is required especially a significant regular reduction in the outflow of young people from the Shire to the detriment of all areas of the Shire. A major objective of the plan should be to ensure that the Shire has enough homes, jobs, services and facilities to support and improve the quality of life of the people existing throughout the Shire and those welcomed into it.

Draft Response: Acceptance: Noted Changes to be made

The identified strategic growth areas represent the best opportunities for development to be served by public transport in the form of rail, bus and park and ride services. The concentration of 75-80% of development in these locations has other benefits related to economies of scale for provision of services and facilities. This is believed to be the most appropriate response to the challenges facing the north-east. It must also be noted that the plan will be subject to review, which gives the opportunity to revisit the strategy. However, growth is promoted across Aberdeenshire.

The objective outlined in the response is very close to the vision of the draft structure plan. 336 8 Subject SS(SGA) Summary The exclusion of one of the biggest fishing ports in Europe from an SGA is outrageous. It is suggested in a reconsideration of the plan that the SGA principle should not be used at all.

Draft Response: Acceptance: Do not accept Changes to be made

Inclusion of Fraserburgh in a Strategic Growth Area would not be of benefit to the town. The allocation of housing alone is not the way to rectify the issues in Fraserburgh. The 2008 Housing Land Audit identifies 315 allocations that are constrained for marketability reasons. It would be of no benefit to allocate more housing in Fraserburgh without firstly considering the underlying issues. The Regeneration Priority Area is the best place for Fraserburgh. If there is uncertainty with what this would involve this will be resolved with the further details that will now be provided on this topic.

Being in a Regeneration Priority Area does in no way exclude future development in this area in any way but development will be of an appropriate scale in appropriate locations. The final numbers and siting of allocations will be determined by the Local Development Plan.

Rep. Number

14 January 2009 Page 229 of 244 340 1 Subject SS(SGA) Summary There is concern that there was no specific mention of fishing and fish processing within the plan, despite their socioeconomic importance to the region. With the plan proposing that 80 percent of development will be focused in designated strategic growth area that largely fall outside of those dependent on the seafood sector there is concern that the industry will be completely excluded; even thought this sector is fundamental to the overall economic prosperity of the region. The main fishing and processing areas do fall to some extent within the proposed regeneration area, denying them far greater benefits that the SGAs will offer.

Draft Response: Acceptance: Do not accept Changes to be made

It is not the role of the structure plan to tell a story about the importance of individual economic sectors but to guide future development at a strategic level. Economic growth and the diversification of the economic base are key for many coastal communities and this is what the plan seeks to encourage, along with regeneration so that they can meet their potential. 340 2 Subject SS(SGA) Summary The Scottish Government recognises the significance of the seafood industry with support that extends to these fishing dependent communities as part of its rural development policy. The results of a seminar hosted by the Scottish Government in March seem to be at odds with your proposed plan as they came out in clear support of industry and its dependent communities. Surely you should be striving for a joined up approach with Scottish Government.

Draft Response: Acceptance: Partially accept Changes to be made

The draft plan recognises the challenges in coastal communities but it is accepted that it should do this more explicitly . There is a significant need for economic diversification in such communities. The seminar mentioned has been misrepresented as it was designed to inform Scottish Government policy, not present it. The policy approach of the draft structure plan does not diverge from that of the Scottish Government.

Rep. Number

343 4 Subject SS(SGA) Summary Our plan should look more seriously at Westhill as a central location for industry as industry deems that location as very desirable and maybe ever more so with the AWPR.

Draft Response: Acceptance: Do not accept Changes to be made

Westhill has seen significant growth in recent years in housing terms and more recently in employment. The Westhill capacity study has identified some of the significant challenges posed by the further growth of the town with the AWPR and associated measures needing to be in place before transport issues can start to be resolved. It is appropriate therefore to consider the role of Westhill in the context of the first strategic development plan in 2/3 years time. 343 5 Subject SS(SGA) Summary Laurencekirk lends itself to more industry and is ideally placed with good access to road and rail networks. I notice that the development corridor stops just after Laurencekirk and takes no account of the former RAF Edzell base which will see significant development opportunities bearing in mind that the MOD clawback clauses fall next year. The corridor should include this important area on the border with Angus.

Draft Response: Acceptance: Do not accept Changes to be made

Site specific issues are for the local development plan to consider. The future of the former RAF base would need to be considered on its merits because it currently is unlikely to fall within the SGA even if it extended as suggested because of its remoteness from the corridor. 343 7 Subject SS(SGA) Summary Caution will need to be deployed when regenerating the coastal area south of Stonehaven. These communities excel as unspoilt coastal fishing villages, don’t have too much development land and nestle in their natural coastal basin. They have great tourism potential and care must be exercised to retain the character and attractiveness of that area.

Draft Response: Acceptance: Accepted Changes to be made

It will be important to consider all of these coastal towns individually as they all have different merits and issues. The tourism industry is very important in these areas and should not be impeded.

Rep. Number

14 January 2009 Page 230 of 244 347 1 Subject SS(SGA) Summary Two corridors namely the Stonehaven one and Inverurie one are heavily built on already, resulting in severe congestion and schools already bursting at the seams. I cannot support the view that simply because it is more convenient for stakeholders, that we must continue building and in fact rapidly increase building on corridors with significant infrastructure issues.

Draft Response: Acceptance: Do not accept Changes to be made

It is not stakeholder convenience but a whole range of issues which influenced the strategy for the plan. This corridor has existing infrastructure, has proposed infrastructure and new development can help to deliver solutions to these issues. 347 4 Subject SS(SGA) Summary The Peterhead corridor is deemed by the planners to be less popular corridor for developers and therefore the focus should be on the other two. I believe this approach to be essentially flawed and taking the very short view.

The only real way of regenerating the Peterhead corridor is to limit the other corridors in terms of amount of devolvement allowed.

Draft Response: Acceptance: Do not accept Changes to be made

This SGA is not deemed less popular but there is lesser of a demand for development in this corridor as shown in previous Housing Land Audits. There are however a number of constraints for this corridor that will have to be resolved before the majority of development can take place. It is also reliant on a number of other proposals within the plan.

Peterhead will receive an appropriate level of development which will help with its regeneration.

The new style development plans will be updated and reviewed every 5 years which allows for changes in circumstances to be considered and addressed.

The other corrridors within the plan are on an existing railway line and are as such more sustainable and are an essential part of the spatial strategy..

Rep. Number

349 4 Subject SS(SGA) Summary The Group endorses the choice of the three strategic growth areas as identified in the Plan as being those areas most likely to capitalise on the demand of business and industry to be situated in the city hub and main transport corridors. It recognises that the highest demand for housing will also occur in that hub and along those corridors, and welcomes the opportunity to reduce unnecessary travel by the development of mixed land use to encourage more sustainable communities. However, it is not felt that adequate provision has been made for land for industrial and commercial use, which should lead the development, and an increase in allocation would be desirable across the board, but most notably in the Aberdeen – Peterhead corridor.

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcome.

There is a greater area of land proposed for employment than ever before. The Plan states that at all times there should be a minimum of 120ha of employment land at all times. The new development plans are reviewed every 5 years and if it is seen to be too low as part of a review additional land could be identified at that time. The Aberdeen to Peterhead corridor does have some infrastructure constraints that need to be resolved before significant development can occur so in this corridor in particular there is sufficient numbers for employment land at this time. 349 7 Subject SS(SGA) Summary The Group accepts that significant development will take place along the Huntly to Laurencekirk corridor. However, it also recognised that a great deal of development, especially housing, has already taken place along this corridor, and this has resulted in some element of ‘development fatigue’ in certain communities, most notably Stonehaven and Kintore. It might therefore be desirable for some areas within this corridor to be given some opportunity to ‘bed in’ and integrate within the wider community, and target reallocated to the Ellon - Blackdog area.

Also see Appendix attached to original letter.

Draft Response: Acceptance: Noted Changes to be made

Site specific allocations will be dealt with through the Local Development Plan process. Consideration will be given to the capacity for each settlement to expand sustainably. In terms of Stonehaven the previous structure plan NEST only allocated 25 new units within the period 2000-2010. This was mainly due to the large number of effective allocations that were available, this was to allow the already approved development to 'bed in'.

1000 houses from the Local Growth (Aberdeen Housing Market Area) between the period 2007-2016 have been reallocated to Ellon - Blackdog between the period 2017 - 2023 which takes into account the infrastructure projects (Balmedie to Tipperty dualling, AWPR, Third Don Crossing and Haudagain) which will be relieve transportation constraints and will be delivered around 2013-2014.

14 January 2009 Page 231 of 244 349 11 Subject SS(SGA) Summary Two most significant traffic bottlenecks in the city region are the Haudagain roundabout and the Bridge of Dee, both situated on the Huntly to Laurencekirk corridor, yet apparently not thought sufficient reason for constraining development on that corridor. It is also worth noting that the summary of Aberdeen City observes that ‘one or two secondary schools’ and ‘associated primary schools’ will require to be built in order to secure the planned development for the City. The note on the Huntly to Laurencekirk corridor states that ’we will need to provide two secondary schools and associated primary schools in this area’ yet only in the Aberdeen to Peterhead corridor is the needs for a new academy apparently accepted as a deterrent to development. The Group does not share that view.

Draft Response: Acceptance: Do not accept Changes to be made

The support, and provision, of infrastructure is an essential part of supporting the level of housing and economic development envisaged and is central to the plan. The plan makes it clear that the resolution of transportation problems across the north-east must be a priority and it has devised a strategy that does not impact negtively on these problems.

The need for a new academy has not been accepted as a deterrent to development in the Aberdeen to Peterhead corridor. Proposals to the north of Aberdeen are dependent on the AWPR and A90 upgrading at Balmedie / Tipperty. Phasing of development in the Aberdeen to Peterhead SGA has been given careful consideration, hence the minimal numbers allocated until the Balmedie to Tipperty dualling, AWPR, Third Don Crossing and Haudagain projects are delivered around 2013-14. Trunk roads are outwith the control of Local Authorities however the plan acknowledges and takes into account relevant regional strategies and plans which have an importance influence on this plan (Nestrans and Scottish Government etc).

The new development plans will be reviewed every five years. The numbers are seen to be reasonable and implementable, and at an appropriate level to ensure the vision is met, and the aspirations for the North east achieved. 349 12 Subject SS(SGA) Summary The Aberdeen Western Peripheral Route and the dualling of the Balmedie to Tipperty of the A90 will create greater ease of access to Formartine and Banff & Buchan, and with that, increase demand for development along that corridor. Also successful development of Peterhead would not necessarily impact directly on peak flow traffic through the Bridge of Don, and may in fact lessen it as employees may be drawn from north of Aberdeen and will avoid the daily commute through Aberdeen. Any increase in peak flow traffic between Aberdeen and Peterhead will be in the opposite direction from the main flow and will optimise the use of exiting roads infrastructure.

Draft Response: Acceptance: Partially accept Changes to be made

Proposals to the north of Aberdeen are dependent on the AWPR and A90 upgrading at Balmedie / Tipperty. Phasing of development in the Aberdeen to Ellon corridor has been given careful consideration, hence the minimal numbers allocated until the Balmedie to Tipperty dualling, AWPR, Third Don Crossing and Haudagain projects are delivered around 2013-14. 349 14 Subject SS(SGA) Summary There are already sufficient industrial and commercial developments in the pipeline to require that adequate provision is made for additional housing in the Ellon to Blackdog corridor, and that such provision be front loaded,

Draft Response: Acceptance: Partially accept Changes to be made

Phasing within particular corridors is based on infrastructure constraints that will need to be resolved prior to significant levels of development taking place.

There are limited numbers in the A90 (north) corridor until the AWPR, Balmedie to Tipperty dualling and Third Don Crossing are in place.

Rep. Number

350 3 Subject SS(SGA) Summary The plan is very focussed in the SGA’s and discriminates against areas outside those and I believe the Aberdeen/Peterhead SGA to have damaging effects for Fraserburgh.

Draft Response: Acceptance: Do not accept Changes to be made

The three elements of the spatial strategy in the plan are in no way hierarchical, but enable an appropriate response to individual issues and circumstances. Improving the economic, environmental and social future of Fraserburgh is very important for the future of Fraserburgh itself and Aberdeenshire Council. The final paragraph on p.5 of the draft plan makes it clear that the importance given to each aim of the plan will be critical in coming to decisions on development proposals. The status of Fraserburgh as a RPA will influence the balancing process in a way that may not be appropriate in other areas.

The spatial strategy recognises the circumstances in Fraserburgh (and other similar communities) through their dual designation as regeneration priority areas and areas for local growth and diversification. These designations provide flexibility for the Aberdeenshire local development plan (LDP) to respond accordingly, with relevant policies and proposals. Also importantly, the LDP will have complete autonomy to promote the reuse of brownfield land and to designate a proportion of the significant level of residential allocation made to the RHMA and an appropriate amount of employment land.

The initial preparation for production of the LDP has begun and further work will be undertaken throughout 2009, this will involve community council’s and other representatives, local businesses and individuals with an interest. Consultation will be key to ensuring the framework set down by the structure plan is translated into realistic LDP policies and allocations and tangible proposals are delivered for Fraserburgh.

14 January 2009 Page 232 of 244 350 4 Subject SS(SGA) Summary The proposals for three SGA’s shows a development bias in favour of Aberdeen city and is not even handed for the Shire. Areas at the extreme from the City and not in the SGA’s will suffer from poor and late development, if any at all.

Draft Response: Acceptance: Do not accept Changes to be made

The City and Shire are dependent on each other and the SGA corridors can seen as bringing the development opportunities that would otherwise be confined to the City out into Aberdeenshire. The plan states that 50% of the future grwoth will be situated in Aberdeen City, however, the remaining growt will be in Aberdeenshire (25% in the Shire SGAs and 25% in the Local Growth and Diversification areas). The creation of employment sites at Westhill and Portlethen and concept of employment led development in the Blackdog to Peterhead corridor all reduce the 'dominance' of the City. 350 6 Subject SS(SGA) Summary The development in Peterhead will be two fold. It will benefit from being a SGA and a RPA.

Draft Response: Acceptance: Noted Changes to be made

Peterhead is located within the Strategic Growth Area so any numbers for housing and employment allocation will come from here. Peterhead is in need of a level of Regeneration and it important to show this. Being in both areas shows that adding number to this settlement along will not be sufficient it shows that there is the regeneration aspect too. Allocations are not part of the Regeneration areas in the Shire. Further details will be added to the RPA to clarify some issues. 350 7 Subject SS(SGA) Summary Developers will go where the development buzz is, and this will all go to the Aberdeen/Peterhead SGA. Fraserburgh will become an economic desert. Employment opportunities will flow away from Fraserburgh and draw away skilled staff. The Plan will create uncertainty and lack of confidence among existing employers and will discourage new business developments from coming to the area.

Draft Response: Acceptance: Do not accept Changes to be made

The emphasis in Fraserburgh is on regeneration, economic growth, diversification and providing an appropriate mix of housing, each of these components are necessary land use elements to reverse the fortunes of the town. But, only through concerted efforts and working with other Council services and agencies will this be realised. 350 10 Subject SS(SGA) Summary With 75 to 80 percent of growth going to the SGA’s, places outside the SGA’s will be disadvantaged in terms of new schools, road improvements, railways, water and waste systems. With only a finite resource available non SGA’s will suffer.

Draft Response: Acceptance: Do not accept Changes to be made

The plan states that 50% of the future grwoth will be situated in Aberdeen City, however, the remaining growth will be in Aberdeenshire, 25% in the Shire SGAs and 25% in the Local Growth and Diversification areas. 25% of growth focused on the LGDAs represents a significant amount, but itt is necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period.

Phasing within particular corridors is based on infrastructure constraints that will need to be resolved prior to significant levels of development taking place. An example of this is the limited numbers in the A90 (north) corridor until the AWPR, Balmedie to Tipperty dualling and Third Don Crossing are in place. 350 11 Subject SS(SGA) Summary The College is not being used to best advantage under the plan, If the SGA were extended to Frasrerburgh the local college would have a better chance.

Draft Response: Acceptance: Do not accept Changes to be made

There is no reasoning behind this statement and Fraserburgh’s designation out with the SGA does not have a bearing on this issue. Fraserburgh requires regeneration that would not be achieved if it were within the SGA. It will receive the appropriate level of development through the LDP.

Rep. Number

14 January 2009 Page 233 of 244 356 2 Subject SS(SGA) Summary Portlethen to Stonehaven strip overly targeted for development within the plan, neither town is ready for further expansion and doubts exist whether sufficient infrastructure would be forthcoming.

Portlethen is already experiencing completion of a development of 800 houses and any further development above this would put a strain on the towns existing limited facilities.

Development within the corridor would result in a continuous built up area and is contrary to the trend to maintain green space between and around settlements.

Draft Response: Acceptance: Do not accept Changes to be made

The Portlethen capacity study has identified a number of different growth scenarios to inform future local development plans; this is in no way a definite statement of how the town will grow. The allocation on the Portlethen to Stonehaven corridor takes in a number of settlements. However, it will be for the local development plan to determine exactly where development takes place and on what scale taking into consideration a range of factors, including infrastructure constraints.

The plan promotes 6,000 homes in the Portlethen to Stonehaven corridor over a 23 year period. The provision of appropriate infrastructure is critical to the delivery of sustainable mixed communities as envisaged by the plan.

Rep. Number

358 1 Subject SS(SGA) Summary Welcomed that Alford and the Howe of Alford are not included within SGAs.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed. This area is not designated for strategic growth, but may still experience growth in line with the spatial strategy. However, the allocation of specific sites will be determined within the Aberdeenshire Local Development Plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

362 1 Subject SS(SGA) Summary Objection to the inclusion of Pitcaple in a SGA. Intimation that the proposal will swamp the community.

It is vital not to lose sight of the need to 'preserve' the dynamics of small, local communities.

Draft Response: Acceptance: Do not accept Changes to be made

Just because Pitcaple is located within a SGA it does not mean that it will take a Strategic level of growth. It may even be the case that no development is appropriate here. The A96 corridor from Pitcaple to Huntly is allocated 1,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

365 3 Subject SS(SGA) Summary The rationale for the three Strategic Growth Areas is clear. The need to reverse the current trend of population movement to the Shire from the City is critical to the future of the City and housing development that is primarily focussed close to areas of proposed economic development and existing transport corridors is in tune with both the aims of economic growth and accessibility.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcome.

14 January 2009 Page 234 of 244 365 4 Subject SS(SGA) Summary Concern is raised as to how any significant percentage of the housing growth (6000 homes within the Stonehaven - Portlethen corridor) could be accommodated within the immediate area of Stonehaven without causing significant damage to its setting of outstanding natural beauty, the views that are associated with it and inevitably the quality of life of its residents.

The need to protect Stonehaven’s natural setting, its braes and surrounding fields from overdevelopment cannot be overstated. Development in this area would undermine an identified aim of the plan in damaging the quality of the environment. Strongly oppose the scale of housing growth suggested by the draft structure plan for the Stonehaven area and ask that it be reconsidered.

Draft Response: Acceptance: Do not accept Changes to be made

The allocation on the Portlethen to Stonehaven corridor takes in a number of settlements and the possibility of a new settlement. However, it will be for the local development plan to determine exactly where development takes place and on what scale taking into consideration a range of factors, including infrastructure and environmental constraints.

The plan promotes 6,000 homes in the Aberdeen to Stonehaven corridor over a 23 year period. The plan recognises that the built, natural and cultural environment is a valuable resource. Both councils (through local development plans, supplementary guidance, master plans and in the assessment of development proposals) will take account of landscape and sensitive areas in identifying land for development. 365 5 Subject SS(SGA) Summary Funding for crossrail must be secure if the spatial strategy is to be at all acceptable.

It is essential to provide frequent, high quality, reliable and affordable public transport (rail and bus).

Draft Response: Acceptance: Noted Changes to be made

The Plan recognises that public transport needs to be an attractive choice which encompasses issues of cost, reliability and quality.

Whilst the plans refers to Crossrail and identifies proposed stations on the key diagram, the ultimate decision on this project is not a structure plan issue; but one that it will need to reflect. The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service.

The plan acknowledges the need for infrastructure improvements. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements).

Rep. Number

367 1 Subject SS(SGA) Summary Pitcaple should not be included in the SGA on the grounds of: - Transport links are not suitable - Already a significant level of congestion on the A96 which will be exacerbated by further development - Would lead to Pitcaple becoming a commuter town - Quality of life of residents would be affected

Draft Response: Acceptance: Do not accept Changes to be made

Just because Pitcaple is located within a SGA it does not mean that it will take a Strategic level of growth. It may even be the case that no development is appropriate here. The A96 corridor from Pitcaple to Huntly is allocated 1,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

371 1 Subject SS(SGA) Summary Objected to the inclusion of Pitcaple in the draft structure plan on grounds of: - increase in housing will destroy the character of the village - lack of adequate infrastructure in the village (rail link, shops etc) will force residents to travel to Inverurie or Huntly for services. - road safety issues brought about by increase in traffic joining the A96

Suggested that it would be more appropriate to locate the houses proposed in one of these areas where infrastructure is in place.

Draft Response: Acceptance: Do not accept Changes to be made

Just because Pitcaple is located within a SGA it does not mean that it will take a Strategic level of growth. It may even be the case that no development is appropriate here. The A96 corridor from Pitcaple to Huntly is allocated 1,000 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

The support, and provision, of infrastructure along side development will play a key role in assisting to deliver the plans vision.

Rep. Number

14 January 2009 Page 235 of 244 373 3 Subject SS(SGA) Summary Concern raised in relation to the Aberdeen to Laurencekirk SGA: - Number of houses proposed will result in a housing corridor to the detriment of tourism. - Smaller communities along the coast would not be small communities should the level of housing proposed go ahead.

Draft Response: Acceptance: Do not accept Changes to be made

The corridor concept has been devised for a number of reasons. One of those is to allocate a strategic level of development that can then be broken down into specific proposals by the local development plan. Whilst it is expected that the majority of growth in SGA's will relate to existing towns and villages, there is scope in the plan for alternative proposals to be considered - this will be done as part of the local development plan process.

Allocations will be made on a site-by-site basis and this will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

375 4 Subject SS(SGA) Summary Very little emphasis on the improvement of public transport.

The Huntly - Laurencekirk will depend for its growth and success on clean, efficient, convenient and reliable mass transit (especially rail, including Cross-Rail). Existing systems are not attractive enough, reliable enough or sufficiently convenient to attract the general public and buses are expensive.

Draft Response: Acceptance: Do not accept Changes to be made

The Plan recognises that public transport needs to be an attractive choice which encompasses issues of cost, reliability and quality.

The plan acknowledges the need for infrastructure improvements. However, the structure plan is a high level strategic document and is not the appropriate medium to detail individual developments. The structure plan sets the framework for local and regional transport strategies which will provide higher levels of guidance.

Rep. Number

400 2 Subject SS(SGA) Summary Supports the proposal in the draft plan for 50% of new housing to be within the Aberdeen City boundaries for environmental and sustainability reasons.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

403 2 Subject SS(SGA) Summary Strategic Growth Areas Aberdeen City: The Green Belt around Cults requires to be reconsidered, a blanket approach against development here is unrealistic. It is an essentially urban area that has many excellent development sites. The review of the green Belt must be robust, yet should enable the retention of most of the features that are attractive in terms of green open space.

Draft Response: Acceptance: Noted Changes to be made

The Council's are committed to the future growth of the north-east and to deliver this there will need to be a review of the green belt to identify sites for development, whilst retaining the most important areas. Despite the high numbers, only a small percentage of land will be developed.

The allocation of specific sites will be determined within the local development plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria. 403 3 Subject SS(SGA) Summary A new settlement should be proposed. The level of incremental increase to existing settlements and along the SGAs could be countered by a 'new eco-town' in the south and/or south west. There is consumer demand for new development in these locations and it would prevent pressure on well established communiteis such as Stonehaven and Banchory. It would also reduce the pressure for extensive development in Aberdeen City.

Draft Response: Acceptance: Noted Changes to be made

A number of new settlement proposals were submitted in response to the draft plan. Some of these were in line with the plan’s strategy and some were not. However, none are at a stage where they could be given support through the structure plan. This issue will need to be addressed in the Action Programme so that decisions can be made in the strategic development plan.

14 January 2009 Page 236 of 244 Rep. Number

405 2 Subject SS(SGA) Summary Extremely concerned with the implications to the future local plan in particular the possiblity of large scale expansion of Kintore:

The capacity study highlighted significant development to areas which would remove the essence of Kintore as a community. The suggestion of removing the wide open spaces around Tuach Hill to provide a "Public Open Space" takes no regard of the feelings and needs of existing residents. This is the only wide open area remaining and the addition of the scale of housing would not enhance the community but would only detract.

Draft Response: Acceptance: Noted Changes to be made

Note: This representation is discussing the Inverurie and Kintore Capacity Study

The structure plan does not promote development at Kintore, or any other specific settlement. At the level it operates, only designations for 'corridors' are made and Kintore is shown within an SGA. The A96 corridor in which Kintore lies (from Blackburn to Inverurie) is allocated 6,500 units up to 2030, but it will be for the local development plan to determine exactly where development takes place and on what scale.

Rep. Number

409 3 Subject SS(SGA) Summary Agrees with encouraging people to use public transport and utilising the railway links.

Disagrees with the Huntly - Laurencekirk corridor being the focus and thrust of all development within the plan. Views this could potentially create further dormitory developments with little soul, identity or sustainability in their own right.

Draft Response: Acceptance: Do not accept Changes to be made

The support, and provision, of infrastructure (including road and rail improvements and public transport improvements) plays a key role in assisting to deliver the plans vision and spatial strategy to allow for improved access and connections to other places and to allow environmentally friendly methods of transport to be provided.

The Huntly to Laurencekirk SGA will be subject to significant development, however around 50% of all growth will be focused on Aberdeen City.

Dormitory development is not what is being proposed by the plan which focuses on high quality places, mixed-use developments and meeting the needs of the whole community. 409 4 Subject SS(SGA) Summary Agrees the city should be providing its property, that green sites will have to be used to meet the projected population growth and that the green belt will need to be reviewed.

If thoughtful development is permitted around the boundary we can still protect the environment, green spaces and the character of the landscape and use it as a opportunity to try to resolve current problems and issues faced - such as traffic congestion, good shopping facilities, few employment opportunities or leisure facilities on the doorstep.

This is not something which can be seen in and around Aberdeen in settlements such as Kingswells, Bridge of Don and Elrick, where the focus appears to be on house building for people working in Aberdeen city, not community building in the beginning and facilities have gradually been added later.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

A significant level of housing will have to be accommodated on greenfield sites. A review of the green belt as stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

It is also necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period. Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan.

Rep. Number

14 January 2009 Page 237 of 244 410 1 Subject SS(SGA) Summary The plan promotes rail links and expresses a wish to consider the existing sizes of settlements.

Pitcaple should be removed from the SGA:

It has no rail link therefore any further dwellings built here will rely on the use of private cars and will exacerbate current problems with congestion.

The 500 dwellings proposed would dwarf the current settlement therefore inclusion of Pitcaple would create more problems than it would solve.

Draft Response: Acceptance: Noted Changes to be made

Just because Pitcaple is located within a SGA it does not mean that it will take a Strategic level of growth. It may even be the case that no development is appropriate here. The allocation of specific sites will be determined within the Local Development Plan process.

Rep. Number

411 3 Subject SS(SGA) Summary Corridors Laurencekirk - Stonehaven and Aberdeen to Inverurie and Huntly should be the key areas for residential development.

Important to have sufficient railway stations on the Aberdeen crossrail project. A number of locations for new stations are detailed. Suggested that business office accommodation should be provided at the railway station sites to meet future needs. Envisaged the office accommodation to be suitable for varied use by multi-tenants.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcome. The Huntly to Laurencekirk SGA will be subject to significant development.

The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service. Crossrail is an important infrastructure project and is now to be delivered in a number of smaller projects over a period of time instead of together, this will increase the number and frequency of trains between the south and Inverurie and reopen Laurencekirk Station.

Rep. Number

415 1 Subject SS(SGA) Summary Agrees with exclusion of Alford from the Strategic Growth Areas.

Draft Response: Acceptance: Noted Changes to be made

Note agreement

Rep. Number

420 1 Subject SS(SGA) Summary Obvious that the corridors were selected around the dual carriage way trunk road system.

Draft Response: Acceptance: Do not accept Changes to be made

Agree that the dual carriageway is there but the main corridor was chosen because of its links to the existing railway network which has many planned improvments. Also building up existing settlements reduces the need to travel and cencourages walking, cycling and public transport usage.

Rep. Number

14 January 2009 Page 238 of 244 422 9 Subject SS(SGA) Summary Huntly to Laurencekirk -

"Bus services on this corridor are already good". Country bus services in the area are generally very poor - slow, infrequent services, inappropriate times, expensive. The bus between Stonehaven and Aberdeen takes 2-3 times as long as the train and costs more. It is impossible to get to Laurencekirk from Stonehaven before 9:15 or return after 14:30. How can this be described as a good service or an "attractive choice"?

"We will need to provide two secondary schools and associated primary schools in this area". How will these be funded? They will need to be built before the need arises.

Draft Response: Acceptance: Noted Changes to be made

It is recognised that the bus service statement is a generalisation. However, the journey described will be available by train in the near future.

The provision of educational infrastructure will require the public sector and private sector to work together to secure delivery. It is recognised that the timing of this provision is critical.

Rep. Number

424 3 Subject SS(SGA) Summary Although the spatial strategy identifies three strategic growth areas, the justification behind this strategy is not clear (apart from the City, for the obvious reason). Is there any supporting document which would be provided as supplementary to guide the public (using simple language) as to how the strategy was derived?

What is the future vision for those two corridors? Is it going to be new developments forming a chain of super suburban settlements, effectively new villages or towns, along the dual carriageway (A96 & A90) and the existing railway? Would this be a magnified "ribbon development"?

Draft Response: Acceptance: Do not accept Changes to be made

The spatial strategy emerged after extensive consultation within the Council's and with communities and other stakeholders. It is not intended to promote ribbon development along each SGA, but does give Aberdeenshire Council the flexibility to look at all opportunities and scenarios when producing their local development plan. It is likely that the majority of development in SGAs will be as extensions to existing settlements as this allows for the use of established services and facilities and maintains the sense of community.

The local development plan will ultimately make informed decisions on site specific allocations and it should be noted that significant amounts of development are being made available for distribution outside the SGA's, in the AHMA and RHMA.

Rep. Number

425 4 Subject SS(SGA) Summary Development of the commuter corridors relies heavily on business investment and contributions from retail services and housing developers who will demand short term returns for shareholders rather than long term gains for the area.

Draft Response: Acceptance: Noted Changes to be made

The corridor concept has been devised for a number of reasons. One of those is to allocate a strategic level of development that can then be broken down into specific proposals by the local development plan. Whilst it is expected that the majority of growth in SGA's will relate to existing towns and villages, there is scope in the plan for alternative proposals to be considered - this will be done as part of the local development plan process. Allocations will be made on a site-by-site basis and this will involve extensive consultation and site selection will be based on a significant number of criteria.

The Plan acknowledges the need to invest heavily in the infrastructure of the region.

An Action Programme to support the structure plan, detailing how the plan will be put into practice, including identifying timescales for investments, preparing masterplans and supplementary guidance to facilitate development will be prepared.

Within the Plan the 'Putting this plan into practice' section provides some details regarding the provision of infrastructure, recognising the need to consider investments very early in the land-development process, even before land is identified in local development plan. Investments will come from both developers providing contributions towards necessary infrastructure, and the public sector also making an important contribution.

14 January 2009 Page 239 of 244 425 5 Subject SS(SGA) Summary Preservation of the Shire's extraordinary attractive environment of landscape and buildings is in the hands of the farming, forestry, driver, town and village communities who are not given the incentives that are given to the landowners and developers of the SGAs.

Appears that the lessons of the last century's ribbon develeopments have not been learnt.

Draft Response: Acceptance: Do not accept Changes to be made

There will be development within the areas outhwith the SGAs. Each settlement and area will be considered on their merits and need and development will be allocated accordingly.

Showing SGAs does not constitute ribbon development. A definition is in the Adopted Aberdeenshire Local Plan which states that ribbon development is "Development which follows the line of a road on the edge of a settlement or in the open countryside and has a negative impact on the surrounding area." No site specific allocations have been proposed so it is not appropriate to call this ribbon development, just because the SGA is long and thin.

Rep. Number

426 4 Subject SS(SGA) Summary Broadly agrees with half of the growth being directed to Aberdeen City (split between greenfield, brownfield and regeneration areas), in terms of existing populations represented on a pro-rata expansion. However why constrain the unknown future by limiting the flexibility available now and in the future?

Draft Response: Acceptance: Do not accept Changes to be made

Support for this aspect of the plan is welcomed.

The 'future' will not be constrained by the allocations in the plan. Subsequent reviews of the structure plan will provide an opportunity to reconsider allocations for employment and housing land.

Rep. Number

428 2 Subject SS(SGA) Summary Welcome the focusing of development along existing rail corridors (except where they cross the green belt). Specific emphasis should be placed on linking new development along these corridors to improved rail service provision through planning agreements. There is an urgent need to promote Crossrail and provide new stations at Laurencekirk, Newtonhill, Cove & Kintore.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

The Transport Scotland / STPR published in December 2008 highlights the need to investigate a rail station at Kintore and timetable improvements will increase the frequency of the service. Crossrail is an important infrastructure project and is now to be delivered in a number of smaller projects over a period of time instead of together, this will increase the number and frequency of trains between the south and Inverurie and reopen Laurencekirk Station.

Rep. Number

441 15 Subject SS(SGA) Summary 50/50 split between the city and shire is intuitively meaningful - split within the city is more contentious, brownfield sites should be the majority and green belt land requires more careful consideration, should be preserved.

Draft Response: Acceptance: Do not accept Changes to be made

It is acknowledged in the plan that a significant level of housing will have to be accommodated on greenfield sites; However, over the plan period, 10,000 homes (almost 28%) are proposed for brownfield sites in Aberdeen.

The Background Report published goes into this subject in more detail and concludes that, despite Aberdeen not having a legacy of industrial decline, it should be possible for the City to continue to accommodate significant levels of brownfield housing development. The sustainable mixed communities objective acknowledges that monitoring of this will be required through the housing land audit and flexibility will be built into the future strategic development plan as a result. The Urban Capacity Study contained in the Background Paper provides the justification for the brownfield allowances until 2016. The allowances beyond 2016 will be reviewed in future strategic development plans in light of updated urban capacity information.

A review of the green belt is stated in the plan since all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, even with this development, more than 50% of the area within the Aberdeen City Council boundary will remain undeveloped.

Rep. Number

14 January 2009 Page 240 of 244 451 4 Subject SS(SGA) Summary Too much emphasis on the city not enough on rural areas.

Draft Response: Acceptance: Do not accept Changes to be made

The introduction makes it clear that "the plan does not aim to cover all planning issues but only those which can best be dealt with by Aberdeen City and Aberdeenshire Councils working together". This has had an influence on the content of the plan, but does not mean that rural areas are less important.

The City and Shire are dependent on each other and the SGA corridors can seen as bringing the development opportunities that would otherwise be confined to the City out into Aberdeenshire. The plan states that 50% of the future growth will be situated in Aberdeen City, however, the remaining growt will be in Aberdeenshire (25% in the Shire SGAs and 25% in the Local Growth and Diversification areas). The creation of employment sites at Westhill and Portlethen and concept of employment led development in the Blackdog to Peterhead corridor all reduce the 'dominance' of the City.

Rep. Number

452 3 Subject SS(SGA) Summary It states on page 7 under, 'Aberdeen to Peterhead' there will be less growth in this area than the other 2 SGAs this appears to contradict other views on how the area will development following Trump proposals.

If approved, the numbers from Menie estate would need to be included in the plan.

Draft Response: Acceptance: Do not accept Changes to be made

There are 5,400 houses proposed in the Aberdeen to Peterhead corridor which is a substantial allocation, compared to what has been proposed in the past for development in this corridor.

The decision was made on 16 December 2008 by Scottish Ministers to grant outline planning permission subject to conditions and conclusion of a planning agreement for this proposal. The conditions include phasing conditions which preclude new homes until Phase 1 is complete and limits new housing development until the Balmedie to Tipperty dualling is complete.

This means that 500 new homes are now likely to be built in this corridor. These new homes were not accounted for in the effective land supply on the base date of the plan, so will need to be set against the allowance for the first two plan periods. This phasing between the first and second plan period should reflect the progress expected to be made on site and will allow the allocation of other sites through the local development plan.

Rep. Number

457 3 Subject SS(SGA) Summary The strategic Growth Areas: Although providing infrastructure will be expensive it will be a better value for money. Building one school rather than extending lots of others will provide a better quality building and service.

Draft Response: Acceptance: Noted Changes to be made

It is necessary to ensure that there is sufficient concentration of development to facilitate the timeous provision of community services, facilities and necessary infrastructure, which means that development tends to be focused on a particular area during a particular period.

The Action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’.This will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and will be regularly reviewed. 457 4 Subject SS(SGA) Summary Huntly to Laurencekirk - Important to clarify that the statement about additional schools is intended to be the replacement of two existing schools Mearns and Kemnay when funding is identified.

Draft Response: Acceptance: Do not accept Changes to be made

A range of options are still open in this regard. However, any replacement would be for a school of a larger size. These issues will be taken forward through the Action Programme and local development plans.

14 January 2009 Page 241 of 244 457 9 Subject SS(SGA) Summary The population will not grow instead it will be redistributed. A wider view should be taken from a Scottish/EU perspective.

On page 7 it is stated that the area will need two new secondary schools and associated primary schools based on the assumption that the high population scenario will be achieved.

This proposal appears retrospective and it is important to have confidence in such a large proposal

Draft Response: Acceptance: Noted Changes to be made

The population projections carried out by the councils predict an increase in population within the region by approximately 9%.

The population target of 480,000 by 2030 set out in the draft structure plan is higher than both the ‘Principal Projection’ of the GROS and the Probable-case forecast prepared by the two councils. However, the target is within the range established by both publications, and is lower than the GROS high projection (2006 based) of over 500,000.

An action programme will be produced by the Strategic Development Plan Team during 2009, in conjunction with stakeholders, infrastructure providers and the two councils’. Action programming will detail a number of steps required to put the plan into practice (including timescales, masterplanning and funding of required infrastructure improvements) and the figures for growth will be regularly monitored and reviewed. 457 11 Subject SS(SGA) Summary Support the statement that, 'In the strategic growth areas, services and facilities for the community must be part of the development'. Argues that housing should be considered carefully when building a new school. On average when new homes are built the number of school children rises higher than the average value of housing for a period of years and falls back to normal again.

School openings must be managed carefully to avoid overcrowding at schools and pressure on the local housing stock. Secondary schools should only open when they have a year roll of at lease 100-200.

Draft Response: Acceptance: Noted Changes to be made

The importance of services and facilities for new development is recognised, as are the phasing implication for educational provision.

Rep. Number

458 5 Subject SS(SGA) Summary Under the Energietica initiative housing, infrastructure and the economy need to develop in parallel if they are to remain sustainable.

Draft Response: Acceptance: Noted Changes to be made

At the time the draft structure plan was prepared, the Energetica concept was not well developed. However, a ‘strategic framework’ has since been published which sets out more clearly what it might mean. Although the detail of the framework is not something that can be supported through the structure plan, the concept of supporting economic growth in the corridor is. The Action Programme will need to set out how the concept can be further developed and implemented in terms of housing, infrastructure and the economy.

Rep. Number

460 1 Subject SS(SGA) Summary Support SGAs. Emphasis should be given to linking new development to improvements in rail provision. Support Crossrail and believes its implementation should be supported by Aberdeen City & Shire councils.

Draft Response: Acceptance: Noted Changes to be made

Support for this aspect of the plan is welcomed.

Rep. Number

14 January 2009 Page 242 of 244 469 4 Subject SS(SGA) Summary An analysis of the green belt shows that it has only slowed development and that it is gradually being eroded over time. The AWPR will exacerbate this significantly and the wording of the Aberdeen City paragraph on p.7 suggests a further weakening of this role, which should not be allowed to happen.

Draft Response: Acceptance: Noted Changes to be made

The Council's are committed to the future growth of the north-east and to deliver this there will need to be a review of the green belt to identify sites for development, whilst retaining the most important areas. Despite the high numbers, only a small percentage of land will be developed.

The allocation of specific sites will be determined within the local development plan process. This will involve extensive consultation and site selection will be based on a significant number of criteria.

Rep. Number

470 4 Subject SS(SGA) Summary Welcome proposal to develop half of all new growth in the City as some companies within the oil and gas supply chain feel they are being forced out and are relocating elsewhere. Should this continue, it would impact on the area's ability to maintain a strong economy. Half of all growth must be implemented within the City boundary and not allocated elsewhere.

To effect this growth, green belt land within the City boundary will require approval for development, is this achievable within the timescales within the Economic Development Plan?

Retail growth is pivotal to the City growth strategy and reference should be made to the Traverse Report on retail development in Aberdeen City.

Draft Response: Acceptance: Partially accept Changes to be made

Support for this aspect of the plan is welcome.

A significant level of development will have to be accommodated on greenfield sites in the city. This will involve a review of the green belt and as stated in the plan all greenfield land in the City is also identified as green belt. Although a substantial amount of development may be proposed on City greenfield / green belt sites, a significant percentage of the area within the Aberdeen City Council boundary will remain undeveloped.

Development in Aberdeen is critical to the future of the city region as it minimises the need to travel and encourages walking and cycling and public transport in line with the strategy of the plan. 470 5 Subject SS(SGA) Summary Development along the 66 mile corridor (Huntly-Laurencekirk) is only sustainable if it is accompanied by improvements in rail services and opening additional stations to strengthen the existing road services and assumes substantial investment in schools and housing. A rail action plan needs to be in place to assist with the delivery of this development.

Draft Response: Acceptance: Noted Changes to be made

Rail improvements are highlighted in the draft plan and a rail action plan is currently in preparation by Nestrans, the regional transport partnership. 470 6 Subject SS(SGA) Summary Important strategic assets for this area are understated. Reference should be made to the Energetica master plan (now published) when formulating the action programme for the area. Energetica is one of the strategic priorities in the ACSEF action plan and would wish to see the principles of this framework embedded in the plan and regarded as integral when considering land use allocations and assessing developer proposals.

Draft Response: Acceptance: Do not accept Changes to be made

At the time the draft structure plan was prepared, the Energetica concept was not well developed. However, a ‘strategic framework’ has since been published which sets out more clearly what it might mean. Although the detail of the framework is not something that can be supported through the structure plan, the concept of supporting economic growth in the corridor is. The Action Programme will need to set out how the concept can be further developed and implemented.

Rep. Number

14 January 2009 Page 243 of 244 471 1 Subject SS(SGA) Summary The Huntly to Laurencekirk and Peterhead to Aberdeen SGA's are located within the vicinity of National Grid's high pressure gas transmission pipelines. NG is happy to provide advice and guidance concerning their networks and would wish to be consulted further on specific policy and plan issues as outlined in their letter.

Draft Response: Acceptance: Noted Changes to be made

Note that there is high pressure gas transmission pipelines within the vicinity of the SGAs, however this is the case for many of the larger settlements in the north east. No specific sites have been decided by this plan because they are allocated within the Local Development Plan process. A copy of your representation will be forwarded to the relevant Team.

14 January 2009 Page 244 of 244