latest response to Aberdeen Football Club’s most recent update to their planning application. The SDPA have highlighted multiple flaws in the stadium application. We’ve copied the report below and highlighted the key parts.
SDPA 2nd SUPPLEMENTARY CONSULTATION RESPONSE
ContextThe SDPA responded to the initial consultation on 20 February 2017, with a supplementary response submitted on 17 July 2017 following further information submitted by the applicant. This is therefore the second supplementary response, submitted in light of the further tranche of additional information submitted by the applicant on 1 August 2017 – primarily the ‘Statement on Co-Location, Site Selection and Sequential Test’.
Co-locationThe applicant has asserted that there are numerous benefits for the club if all its facilities are located at one site. This has been supplemented by references from other clubs to the effect that co-location would be their preference as well if the option was available. However, this does not demonstrate the need to have co-location but merely that it is preferable for the club.
The applicant has still not adequately addressed the need to co-locate activities on one site.In light of this, the sequential test should be approached on the basis of separating the stadium from the training facilities.
Significant footfall generating uses and the sequential testScottish Planning Policy states that uses which generate significant levels of footfall should use a sequential test to demonstrate that sequentially preferable sites are not available. Rather than address this issue, the applicant has decided to continue to dispute that the proposal is a significant footfall generating use (SFGU) on the basis that its use would be intermittent. It is also argued that there is no definition or LDP policy relating to SFGUs and that as the Council did not initially request a sequential test during the EIA scoping process it is not necessary. The supporting statement refers to supporters numbering 357,500 p.a. without accounting for the use of the stadium for other functions or the use of the training pitches and by the Community Trust. The proposal is therefore clearly an SFGU and Aberdeen City Council has clearly stated this as their position as well. The inclusion in the latest submission of a proposed footbridge across the A944 at the Arnhall junction to cope with the scale of fans seeking to cross the road (from an area of parking in excess of the maximum parking requirements) is an indication of the footfall generated. However, the bridge appears to be narrow, lack disabled access, outwith the red-line boundary of the application and partially in the adjacent council area (Aberdeenshire), with no indication given as to its potential visual impact on this important entrance to Westhill. As previously stated and the reason additional supporting information has been requested is that a sequential approach to site selection and associated policy framework are key to determining the application (the greenbelt being one of a number of issues). The SDPA’s previous responses explicitly didn’t claim that the proposal required a city centre location, but that a sequential approach should be followed to site selection, in line with Scottish Planning Policy.
The applicant’s continued assertion of the benefits of co-locating the stadium and ancillary facilities do not amount to a need and continue to be weak.While additional information has been submitted it seems to be more a repackaging of existing information rather than anything new or substantive.
The applicant has not effectively discounted the availability of alternative and sequentially preferable sites if the different uses proposed were to be provided for separately.
OTHER OBSERVATIONS AND POLICY CONCLUSIONThe applicant has twice provided additional information in support of the application since its original submission. However the most recent revised information does not address in a satisfactory way any of the issues raised in the SDPA’s previous submissions so they remain the SDPA’s position. The latest tranche of additional information in support of the application further complicates the assessment process as mitigation is now being proposed (a new pedestrian bridge) which has not been assessed in terms of its capacity, visual impact or deliverability as part of this application. Improving and modernising the facilities of Aberdeen Football Club are supported by the SDP, as is the provision of community facilities. However, the application is contrary to the Aberdeen City and Shire Strategic Development Plan. The proposal will result in the loss of 25Ha of greenbelt, the coalescence of urban areas (Westhill and Kingswells), is an inappropriately located development giving rise to unsustainable travel patterns (it has a very small catchment in terms of access by walking, cycling and public transport compared to other sequentially preferable sites) and is likely to have a negative impact on the City Centre.
The application clearly comprises a ‘high footfall generating use’ and no justification has been provided for the need to co-locate the stadium with the training / community facilities and as a consequence the basis of the sequential test is unsound.The applicant has not demonstrated that sequentially preferable sites are not available, including sites at Loirston and Kings Links (identified in the SDP as potential stadium sites), particularly if the proposed uses were provided in separate locations.
As a consequence it does not follow the sequential ‘town centre first’ approach of SPP or accord with the aims and objectives of the SDP.]]>