CULTS BIELDSIDE AND MILLTIMBER COMMUNITY COUNCIL

Aberdeen City and Shire Development Plan Team

Archibald Simpson House

27 – 29 King Street

Aberdeen

AB24 5AA

6 January 2012

Dear Sir/Madam,

Aberdeen City and Shire Strategic Development Plan – Main Issues Report

I write on behalf of the Cults, Bieldside and Milltimber Community Council in response to the report above and supporting documents.

In commenting we have followed the report structure addressing the associated questions as appropriate and/or possible.

1.  Introduction

We note under Purpose that the report states that ‘since the current structure plan was only approved in August 2009, we think the number of changes needed is limited’. We note however that the plan was based on the situation in 2007. In the current circumstances we believe the strategic development plan should reflect a great range of economic outcomes and should be expanded to reflect it.

In 2008 the structure plan was recognised already as being highly aspirational based on a very bullish view on the prospects for the North- East economy. It included a high level of inward migration and the perceived need for a huge increase in private house building above historical levels. At the time we felt the scale of new housing development proposed, particularly on green belt land within Aberdeen City, was overstated. In addition we expressed concerns over the provision of the infrastructure to support the development. Since August 2009 we have seen the worst economic crisis in living memory. Indeed most economists, including the Chief Economic Advisor to the Scottish Government, have forecast a period of economic austerity that will last to the end of decade and probably longer.

We believe that the opportunity should be taken to look at an alternative scenario to the highly aspirational plan that exists at the moment. The Strategic Development Plan Team should consider the impact on the strategic development plan of a prolonged period of low economic growth. We feel this should include the following:

·  The scale of maintenance and essential upgrade of the existing infrastructure, notably roads, schools, public utilities and other public buildings where there are limited resources.

·  A prioritisation of capital projects with realistic estimates of start and completion dates through 10 - 15 years of austerity.

·  An assessment of funding of capital projects in this harsh economic environment with much greater transparency on the balance between national and local resourcing.

·  The alignment of housing developments to the provision of the infrastructure with the opportunity to place constraints on the proliferation of sites where economic realities lead to the deferment or cancellation of infrastructure projects.

The above is not an exhaustive list, instead its purpose is to highlight the need for alternative thinking where there is a much greater emphasis on what will be delivered by when and at what cost. The outcome should be a better understanding of relative priorities and the critical milestone dates surrounding the integration of capital projects.

At the very least it would provide a comparison with the aspirational plan to identify the scale of amendment necessary to the plan to respond to a more austere economic future.

2. Major influences on the strategic development plan (Q1)

Two major influences have been identified on the plan in the main issues report. The first is ‘how we support development in challenging economic times’, we believe this is too narrow and should be expressed differently. Instead we would propose:

How do we ensure the integration and delivery of resources (roads, schools etc.) in challenging times that balances maintenance of our historical and cultural heritage, generates sustainable economic development, promotes a high quality of lifestyle and protects the environment in the long-term?

It is not exclusively about supporting economic development

The second influence ’how we respond to the challenges and opportunities of climate change’ we broadly support.

3. Format (Q2)

Under Section 3.3 reference is made to using more illustrative material in the plan. We would welcome this development and would highlight two opportunities.

1.  An integrated 5-year delivery plan aligning housing development to the provision of infrastructure showing the contingency plans where infrastructure gets deferred or cancelled.

2.  A case study on traffic congestion in the south of the city showing how the impact of new housing development in the city and Aberdeenshire will be mitigated including the contribution of a new bridge over the river Dee.

4.  Vision and spatial strategy (Q3)

Our view - already expressed in the consultation on the current structure plan - is that there should be more emphasis placed on the regeneration priority areas and more focus on developing towns in the shire as opposed to corridor links.

We also see the artificial city and shire boundaries leading to too much new housing being forced into the city. We believe that the integration of the Aberdeen City and Aberdeenshire Councils into one authority would bring a better distribution of housing and provide the delivery of more efficient services through economies of scale. We believe that this should form part of the vision.

5. Sustainable economic growth

Housing demand and affordable homes (Q4 and Q5)

We continue to question the scale of housing development. The most common question raised by local residents is ‘who is going to buy all the new housing proposed’? Given the level of deposits required for a mortgage, particularly for first time buyers and wage rates relatively static, it is difficult to see how potential buyers will raise the necessary finance. The plan seems to equate aspiration for new and possibly larger homes with a realistic housing demand. We believe the housing proposed to 2035 is already too high and where through the master planning process some sites have their housing density reduced it should not be replaced by the allocation of additional sites.

In addition to the issues the above creates in respect of the infrastructure, it hides a constructive public debate about the affordable housing crisis. We recognise the crisis is not going to be solved overnight but the main issues report identifies a need for 830 new affordable homes to be provided each year. In the first phase of the plan to 2017 it is unlikely that more than 30% (5000) of the housing allocation of 16,500 will be built. Even if the quota of 25% of homes built is affordable this will only lead to an average of 250 homes being provided per annum. The 580 shortfall (70%) would have to be provided by increased direct government funding or borrowing by the councils. Neither is looking likely in the current economic climate. As a consequence we don’t have a coherent affordable housing strategy.

We agree with the assessment that to raise the quota to 38% is unrealistic. Indeed we are not convinced the 25% quota will be delivered. We believe that the whole strategy is flawed because it is predicated on a large number of private houses being built very quickly which we think is very unlikely to happen. It requires a renewed debate about public provision and funding of social housing, primarily to rent.

Transport (Q6)

The overwhelming concern of local residents in our area and across Aberdeen is the ability of the local authorities to deliver the infrastructure on the right scale, at the right place and at the right time. In this context the limitations of the current transport network is a significant issue for the people of Aberdeen but it is less about economic growth and more about sustaining a high quality of lifestyle.

At the heart of this issue are the current levels of congestion and the future levels arising from the proposed housing developments. In 2005 there was widespread public scepticism over the forecasts about the impact of the AWPR in reducing congestion in Aberdeen City. The fact that almost all the significant transport projects are not on track in accordance with the regional and local transport strategies only reinforces public concerns.

We welcome the work of the FIRS group and the creation of a Strategic Transport Fund. However, the proposals lack transparency. We are most concerned about the proposals in the Draft Guidance document that contributions are only payable when 50% 0f the house building has been completed and when revenue has been generated. In the current economic climate this will undoubtedly lead to partly completed development and hence no contributions. Contributions should be upfront along with public funding.

The statements of good intent that the proposals will smooth the progress of new residential and commercial development, reduce traffic congestion and encourage access to new development by public transport are not sufficient to restore public confidence. Without full design engineering or feasibility studies having been carried out this remains a wish list of possible solutions rather than a strategic plan of any sort.

Using the proposed new bridge over the river Dee as an example: We see a new base line on 2010 traffic volumes, as opposed to 2005, traffic levels to increase by 34% to 2030 and 10 very different feasibility options none of which seem obvious in terms of benefit to cost ratios. This leads to the view that this is another project to add to the wish list.

Realistically traffic congestion associated with commuting around Aberdeen is only going to be resolved by investing in public transport. In the current climate public transport appears to be moving even further down the agenda, as our approach to transport is becoming more roads centric.

We remain of the view, also expressed in our response to the current structure plan, that there should be carbon emission targets for transport included in the plan. We see this as a ‘forcing tool’ to get a better focus on the provision of public transport.

6. Supporting Development (Q10, Q11 and Q13)

As stated above we are most concerned about the proposals in the Draft Guidance document that contributions are only payable when 50% of the house building has been completed and when revenue has been generated. In the current economic climate this will undoubtedly lead to partly completed developments and hence no contributions at all. Contributions should be upfront along with public funding (Q11).

We are of the firm view that economic development should be infrastructure led with schools, roads and utilities in place prior to the completion of house building. We need developer contributions but upfront costs need to be provided or underwritten by the Scottish government. Councillors should be cautious in approving planning application until they are confident about the delivery of the infrastructure and in the case of roads, particularly the AWPR, they will reduce the level of congestion anticipated (Q10, Q13).

7. Managing resources efficiently

Carbon Emissions

As stated in 5 above we remain of the view, expressed in our response to the structure plan, that there should be carbon emission targets for transport included in the plan. We see this as a ‘forcing tool’ to get a better focus on the provision of public transport.

Managing our Waste (Q14, Q16, Q17 and Q19)

We support option 2 that we should seek to be self-sufficient in managing waste across the region. However, it leads to the vexed question about the identification of sites for new waste management facilities (Q14).

The selection of possible sites should be focussed on those that are best for the environment that does not impact on residential properties and sporting/cultural amenities. Ideally new sites should be on land identified for industrial development. As a consequence decisions will need to be made that are driven more by long term environmental considerations than short-term cost ones. It is vital that the local communities are involved in these decisions and this matter should therefore be left to the Local Development Plan (Q16, Q17).

Transportation of waste from source to the management site remains a critical element in the waste management chain. The Strategic Development Plan should stress and strongly support the study and development of waste transport modes other than by road (train, ship, pipeline?) in order to eliminate the “proximity” conflict that stalls many of the more radical waste management projects. A similar effort should be aimed at the useful by-products of the management processes i.e. electric power rather than direct heating of residencies (Q16, Q19).

Additional Comments on the SEA Interim Environmental Report

Conclusions of the SEA report:

This is an extensive report with many evaluations and attachments; however we are not presented with any ‘Conclusions’ or indications of the potential impact of the report on the Main Issues Report. The Non-Technical Summary includes a summary of the assessment of effects but there is no conclusive statement.

The assessment of effects in Table 1 covers eight issues as follows:

SAE ISSUE / IMPACT
Air and Climatic Factors / Mixed
Water / Negative
Soil / Negative
Biodiversity / Very Negative
Population and Health / Positive
Cultural Heritage / Mixed
Landscape / Mixed
Material Assets / Very Good

There is no mention in the report that to achieve a positive impact for the ‘Material Assets’ issue it is essential that the facilities, roads, schools, etc. will be constructed IN TIME, i.e. concurrent with the residential development. SEA seems to have overlooked the effect of additional car use and traffic congestion if infrastructure provision is not keeping up with residential developments.

In absence of any indication in the report we should give equal weight to these issues and hence the conclusion should be that the Plan presented for consultation in The Main Issues Report would have a negative impact on the environment.

There is an attempt to show how this impact can be mitigated in Table 2. The measures mentioned are very general and do not affect the basic plan hence it is not demonstrated if and how the negative impact on the environment could be reduced substantially.

Example:

Under ‘Air and Climatic Factors’: “We will have a mix of houses, jobs, shops and schools close together so that the buildings will not damage our climate and air”. And repeated in table 5.7 – Climatic factors (Chapter 3.4): “The delivery of local services facilities and a mix of housing and employment reduce the need to travel by car and have a positive effect on climate”.