Katherine Sneeden, Jigsaw Planning - representing No Kingsford Stadium
Thank you. My name is Katherine Sneeden of Jigsaw Planning and I advised the No Kingsford Stadium group on their objection to this application. I am joined by Diane Reid of NKS, who will be able to assist me with answering your questions shortly.
As you will be aware the basis of our planning system in Scotland is that planning decisions should be taken in accordance with the development plan unless there are material considerations of significant weight to indicate otherwise.
In the case of Aberdeen you are fortunate to have a very up to date development plan –it was only adopted in January this year. As set out in the Officer’s report, the proposed development is clearly significantly contrary to this development plan. The debate is therefore whether the justification set out by the applicants is sufficiently material and has sufficient weight to warrant planning policy being set aside.
It is interesting to note that the applicant’s response to policy seems to be that ‘it is not relevant’, ‘that the strict application of policy is not appropriate’ and that policy is not ‘significantly material to the Kingsford application’ – all quotes taken from their documentation. NKS argue that policy is entirely appropriate to this proposal. Yes this proposal is not one which the planning department see every week, but it is the sort of development that has been planned for through the allocation of sites within the Strategic Development Plan. The key themes from SPP, the Scottish Government’s planning policy document, are fed through to the Strategic Development Plan and the Local Development Plan . Such policies are very much intended to help Councils assess proposals such as this.
In the 7 minutes I have to speak it is not possible to address all the detailed points of objection which NKS have. The planning officer’s report sets these out in detail and the objections from NKS are available to Members to read. My role here is to present to you the key principles on which you should be making your decision.
Firstly the site is within the Green Belt. The aim of the Aberdeen Green Belt is clearly set out in your LDP:
- to maintain the distinct identity of Aberdeen and the communities within and around the city, by defining their physical boundaries clearly.
- to avoid coalescence of settlements and sprawling development on the edge of the city,
- to maintain Aberdeen’s landscape setting and provide access to open space.
- The Green Belt directs planned growth to the most appropriate locations and supports regeneration.
The removal of the Green Belt is something which is done through the preparation of a new LDP if the Council feel it is justified and appropriate. NKS believe it is highly unlikely that the Council would be seeking to remove this area of Green Belt via the normal development plan process. This application is seeking to bypass that process and set aside Green Belt policy entirely. Policy NE2 is very clear that no development will be permitted in the Green Belt unless for certain purposes. This proposal is not for any of the purposes listed.
Regardless of whether the site is allocated as Green Belt, policy NC5 requires a sequential assessment of sites to be undertaken when for a use which will attract significant numbers of people and is in an out of centre location. The Government’s policy document, SPP, brought in a bigger emphasis and recognition of the role that town and city centres play in not only retail but other activities which attract people – offices, leisure developments, cultural venues etc. The SPP is clear in widening out the role of the sequential assessment to include these other uses as the Government acknowledges that the loss of such uses away from city and town centres also have a significant impact on their vitality and viability. The sequential approach does not prohibit the development of out of centre sites but it does say they will only be allowed when all the criteria are met. So even if you consider that there are no sequentially preferable sites available then this is not automatic right for planning permission to be granted. You need to be satisfied that all the other criteria are met. These criteria are:
- that there will be no adverse effect on the vitality or viability of any centre
- that there is a proven deficiency in provision of the kind of development proposed
- that the proposed development would be easily and safely accessible by a choice of means of transport
- and that the proposed development would have no significant adverse effect on travel patterns and air pollution.
NKS have set out extensively why these requirements are not all met by the proposal.
The most recent submission from the applicants on the sequential assessment sets out why they consider that they have undertaken an adequate assessment and gives their thoughts on the co-location point.
Their assessment is based on the requirement of AFC to have co-location of their all facilities. It is noted that they have sought comment from other clubs, and have then relied on this to say that all clubs would like to have their facilities in one place. NKS would argue that this is clearly a desire from all clubs, but what the letters highlight is that there are alternative solutions which other clubs have embraced due to a lack of available land. An adaptive response clearly works for other clubs and therefore the strong reliance on co-location of facilities by AFC does not equate to an automatic right to remove land from the Green Belt. It is worth noting that as recently as 2015, AFC were looking to create training facilities at Balgownie in partnership with Aberdeen University suggesting that separate training facilities are a viable option. NKS fully note the desire for AFC to be successful and of course this is to be supported and encouraged, but this is about whether this site is the right location to do that. There is clearly a strong position of the proposal being significantly contrary to policy and there are huge impacts that NKS argue make the proposal inappropriate for this location:
- the loss of the Green belt, the openness of the area
- the impact on the local communities through noise, traffic, ecology
- the impact on the city centre through the loss of footfall and activity, and the associated effect on businesses
NKS urge members to stand firm on the planning policy position of the Council which was only adopted in January and continue to protect Aberdeen through the retention of the Green Belt. As such NKS respectfully request that you refuse the planning application.
Diane Reid, Director, No KIngsford Stadium Limited
LDPs provide the vision for how communities will grow and develop in the future. The intention is that they provide certainty for communities where development should take place and where it should not.
LDP’s are the result of many years of collaboration between the council and the residents of the communities they serve. They set out what both the council and the residents have agreed is the best plan for the area. I am going to an Aberdeenshire LDP engagement meeting later this month, as I feel it is fantastic to have the opportunity to be part of the process that will shape the future of Aberdeenshire.
It is simply not acceptable that a development of this magnitude can ride rough-shod over the work that the communities and the council put into the creation of the LDP, especially when it meets none of the criteria set out for deviation.
If you approve this application, you will be completely devaluing the process of the LDP formation, and it will call into question your ability to listen to the wants and needs of the citizens of Aberdeen.