Proposed Community And Sports Facilities, Football Academy, Stadium, Ancillary Uses, Formation Of Access Roads, Parking And Associated Landscaping And Engineering Works At West Kingsford, Kingswells. Reference 170021/DPP OBJECTIONS FROM KINGSWELLS COMMUNITY COUNCIL (KCC) The Overview lays out KCC’s principal concerns about the plans. The main body of our response details these concerns, with the ‘green boxes’ summarising each section. Appendices 1 and 2 cover some more detailed points about the Traffic Assessment (TA) submitted by AFC, including the use of park-and-ride facilities. 1.0 OVERVIEW The development plans for Kingsford are a serious breach of planning policy and create a legal precedent for other future departures from the agreed SDP and ALDP. The Green Belt land involved is particularly important to the communities of Kingswells and Westhill because it is the last piece of Green Belt that can prevent the coalescence of the two communities and the creation of a development corridor along the A944. The gaudy external appearance of the stadium is completely unsuited to a semi-rural area. The site selection process is flawed and does not adopt an acceptable sequential approach to the evaluation of other sites. The need to have all facilities on one site is not an essential requirement – it has been used to minimize costs and manipulate the selection process. Other sites identified in the SDP and ALDP have been downplayed. The perceived economic and community benefits are not unique to the Kingsford site. They would be the same, or even greater, if the development was located on a more central site nearer to the communities and businesses that would benefit most. Moving the facilities to an out-of-town location goes against the principles of the City Centre Masterplan. The Traffic Assessment provided by AFC makes quite sweeping assumptions intended to favour the development. It describes modes of travel identified by a survey in which the validity and independence of the source are in question. Even then, it can only show that traffic flows will be no worse than at peak times. The success of the traffic plan depends on commandeering most of the park-and-ride facilities in the City and Shire, and a supply of buses that exceeds the capacity that is locally available. The vast majority of fans can only get to Kingsford by car or bus. Transport options are less sustainable than for Pittodrie and the carbon footprint will be higher. The TA underestimates the number of cars and buses involved and their impact on other road users. We would request that Aberdeen City Council roads specialists look in detail at the issues we have raised. KCC accepts that the majority of fans will be well behaved. However, due to the lack of CCTV, it will be much more difficult to monitor crowd behaviour in the Westhill/Kingswells area than it is in the city centre. The safety of fans on the busy A944 is a real issue. The main beneficiary of this development is Aberdeen Football Club, and there is no justification for the detrimental impact it will have on a semi-rural area and the local communities involved. Kingsford is the wrong location for this development, and a suitable alternative should be found using a more rigorous and approved site selection process. For the above reasons, this planning application should be refused. KCC reserve the right to comment on any modifications to this planning application. Kingswells Community Council 1 2.0 RELATIONSHIP TO THE STRATEGIC DEVELOPMENT PLAN AND LOCAL DEVELOPMENT PLAN The Aberdeen City and Shire Strategic Development Plan (2014) includes provision for a potential new community stadium at Loirston or Kings Links. The Aberdeen Local Development Plan (2017) states that “Loirston is considered suitable for a new football stadium and a site has been identified to accommodate this as part of a mixed use area.” Neither the SDP nor the ALDP mentions other alternative sites. Therefore, Kingsford would be a departure from both development plans which were put together after widespread public consultation. It is not entirely clear why Loirston is no longer considered suitable for AFC’s new stadium. The new Cove Rangers stadium at Calder Park and the new secondary school are both in a different development area from AFC’s original stadium site (OP61 and OP59 respectively). AFC’s plans for Kingsford are for a football stadium with some community facilities. This falls short of the requirement in the SDP to provide a “new community stadium”. AFC’s plans for Kingsford are out-of-line with the SDP and the ALDP. 3.0 GREEN BELT AND COALESCENCE OF COMMUNITIES NE2 Policy on Green Belt is unequivocal and is clearly set out in the Aberdeen Local Development Plan (ALDP). “The aim of the Green Belt is to maintain the distinct identity of Aberdeen and the communities within and around the city, by defining their physical boundaries clearly. Safeguarding the Green Belt helps to avoid the coalescence of settlements and sprawling development on the edge of the city, maintaining Aberdeen’s landscape setting and providing access to open space. The Green Belt directs planned growth to the most appropriate locations and supports regeneration.” The area in question at Kingsford is clearly shown in the ALDP as Green Belt and it fulfills the aim stated above. It is highly functional in preventing the coalescence of Kingswells with Westhill, and ribbon development along the A944. It enables Kingswells and Westhill to maintain their individual identities. This area of Green Belt protects the open and attractive landscape setting looking north from the A944 towards Brimmond Hill and Clog Hill. KCC is aware that a previous application in 2005 to build a floodlit golf driving range on the site was rejected by the Scottish Government Reporter because of its adverse impact on the landscape. Clearly the developments now proposed by AFC would have a much greater impact than a golf driving range. Artificial floodlit pitches alongside the A944 cannot be accepted as an appropriate “green” use of Green Belt. Nor can AFC’s future plans for an additional large building on the site (a covered pitch or stand). Police Scotland’s request for security fencing around the site would also have an adverse impact KCC finds it highly objectionable that AFC continually refers to the area as “Green Belt” (in inverted commas) as if the designation is false. The fact is that the area in question will be the last remaining piece of Green Belt between Kingswells and Westhill after Prime Four completes its permitted expansion on to OP29 (retail park or offices). This makes it even more vital that the site at Kingsford is kept as Green Belt. Kingswells Community Council 2 The preservation of the Kingsford site as Green Belt is absolutely vital to protect the distinct identities of Kingswells and Westhill and prevent their coalescence. Removing this piece of Green Belt will also open the door to ribbon development along the A944 corridor. Approving this development will have fundamental consequences for the integrity of Aberdeen City Council’s planning policy. It will set an unwanted planning precedent for other communities around Aberdeen. Creating a new stadium for Aberdeen Football Club does not justify these risks. AFC have not provided sufficient reason, including perceived economic benefit, to justify breaching this policy. Any new stadium and facilities should be located on sites already approved for development in the SDP and ALDP, not on designated Green Belt. 4.0 CHOICE OF SITE AND CO-LOCATION OF FACILITIES AFC have chosen Kingsford from a range of other options due to its proximity to the AWPR and the opportunity to co-locate a stadium and training facilities on a single site. AFC claims that co-located facilities are essential to secure the future of the club. The AWPR was designed to keep traffic moving and minimize delays. The junction of the AWPR with the A944 was planned in 2008 and was never intended to accommodate the additional traffic from a football stadium. The proximity to the AWPR does not solve all traffic issues and this is discussed in Section 7.0 Traffic Assessment. Other more suitable site options would be possible were it not for AFC’s insistence on the co-location of its training facilities. Whilst co-location, given a choice, might be desirable, it is certainly not essential. There is no evidence that locating everything on one site is required to ensure the sporting success of a team. Of the 10 top teams in the Scottish Premiership, the majority (7/10) have stadiums in urban areas and geographically separate training facilities. Of the top 10 teams in the English premiership, all have stadiums in urban areas and almost all (9/10) have geographically separate training areas. There is no link between co-location of facilities or the newness of the stadium and team performance. The current top 3 teams in the Scottish Premiership (Celtic, Aberdeen and Rangers) illustrate these points. The quality of the players and team management are the key drivers of success. AFC point out that the Pittodrie site has planning permission in principle for 350 new homes and that the financial gain from this development would help to fund Kingsford. This financial benefit should not be a planning consideration. Of the 7 site options considered by AFC, the former AECC site at bridge of Don and the new AECC site at Dyce were both rejected partially on the grounds that local roads lacked capacity due to nearby commercial developments. Although there are very significant commercial developments at Westhill and Prime Four, this fact has been ignored to help justify Kingsford.