Our Objections
As the proposals put forth by Sandlaw Farming have developed, so have our main objections. The developer has submitted many documents and made many claims which we feel are inaccurate and misleading. We discuss some of these points below.
LDP Process
This development would signify a major break in the statutory process of long term planning in Aberdeenshire. The Local Development Plan (LDP), prepared over a 4 year period with extensive specialist input and public consultation, did not include this land for development. The LDP lays out the road-map for approved development in Aberdeenshire, including Banchory, with an existing plan covering the current term (2012 - 2016) and an emerging plan recently approved to cover the next term (2017-2021). Neither the existing nor emerging LDP includes any basis for development south of the Dee with future development in Banchory having been identified and approved to the north and east which will allow Banchory to grow sustainably.
A 395 home development has already been set in motion, as per the both the current and emerging LDP, for the Hill or Banchory. If approved, the Braehead development would more than double the number of planned new homes for the coming 5 years.
Banchory sits within a “Local Growth and Diversification Area” and as per page 22 of the Strategic Development Plan (SDP) for Aberdeenshire these areas account for just 5.5% of the planned growth for the region. They are clearly not an area for significant growth which should be focussed to the Strategic Growth Areas where 75% of the planned growth is set to take place (SDP page 11).
Planning Justification
The developer uses an argument based on population projections, household projections, effective land supply and a perceived housing shortfall to justify approving sites outwith the LDP in local growth areas such as Banchory. However these arguments have repeatedly been shown to be without basis by both Aberdeenshire Council and the Scottish Government Reporter.
Population projections – the developer argues that the 2008 based projections used in the SDP show a lower population than more recent data (only if you combine the Aberdeen City and Shire figures). However when you look at Aberdeenshire alone the more recent figures actually show a lower projected population. Please see page 36 of the 2008 data and page 46 of the more recent 2012 data for the figures.
Household projections – again the developer argues that the 2008 based projections are lower than the recent data, yet when you look at the Aberdeenshire figures in isolation (2008-based and 2012-based) you can see that the figures are close to identical.
The developer uses both of these projection arguments to argue that the SDP and therefore LDP are not up-to-date nor relevant. However as shown above, the newly released projections for Aberdeenshire are the same, if not lower, than the figures used to create the plan.
New projections are published every two years - three times between reviews of the development plan, therefore the fact that more recent projections have been published does not in any way render plans out-of-date or irrelevant.
In reference to the arguments against land supply, Aberdeenshire has a 7.7 year effective land supply which is one of the most robust in Scotland and sufficient to meet the needs of the area.
The developer also tries to use housing allowances to justify a shortfall in housing completions, however paragraph 4.24 of the SDP specifically warns against making this comparison. The correct comparison is between housing requirements and housing completions as allowances will always include a significant buffer to allow for flexibility. In the period from 2017 – 2020 the number of housing completions vs. requirement is projected to be in significant surplus for Aberdeenshire.
If any new requirement for homes was identified by Aberdeenshire Council then there is a clear mechanism for drawing on preferred sites within the region, focused to the areas set aside for strategic growth. There is no basis for approving a countryside site in a local growth area that is outwith the LDP and contrary to the aims of the SDP.
Suitability of the Site
As can be seen above the site has been put forward as a candidate but not included in the current or emerging local plans. The Council, with the support of the community, has made clear references to why this site is not suitable for development and some of these are outlined in the sections below.
Braehead is a countryside location, across the River Dee to the south of Banchory. It is not within walking distance of the schools, the supermarkets, the business centre or the proposed new sports village.
The location would encourage people to use their cars and force them to travel either through the centre of Banchory High Street or across the single lane Bridge of Feugh.
As the site is not in the current or emerging LDP and is not in a SDP Strategic Growth Area there is not the infrastructure in place to support such large scale development.
As per the 2013 – 2019 Aberdeenshire School Role Forecasts it can be seen that Banchory Academy is currently operating at 105% of its existing capacity and Banchory Primary will be over capacity by 2018.
Due to a lack in sewage infrastructure the development would also require that a large 100m2 Foul Waste pumping station be constructed on the south bank of the Dee, within the Special Area of Conservation.
The developer tries to argue that development here would be “sustainable” but from the summary of reasons above it can be seen to in fact be the opposite.
Site for Medical Centre/School
The developer also proposes a site for “community uses” and goes on to suggest that it could be used for a new medical centre or school. There is already an approved new site within the village for a new Medical Centre and the approved housing expansion of Banchory has been focused around the recently built Hill of Banchory school. The Braehead site does not allow for easy or safe access to or from Banchory for any new major facilities and would lead to car dependency and a deterioration of the SAC.
Traffic Concerns
The developer has commissioned a Transport Assessment (TA) which concludes that the development would present no noticeable effects on Banchory.
However the report has assumed that only 170 additional car journeys per day would be felt on the roads as a result of the 300 new homes. Knowing how reliant people are on their vehicles south of the Dee we would assume this number to be more than double in reality.
The Feugh Bridge would become swamped with new commuter traffic trying to avoid the traffic lights and newly created congestion at Banchory High Street. And as the TA states that an estimated 75% of all traffic would be commuting to Aberdeen (of which 50% would be going through the High Street) we feel there would be a major increase in congestion.
The TA also does not take account of school traffic as a result of parents within the new development driving their children to school and does not take account of the increased risks to pedestrian safety that would come about as a result of the newly created congestion.
Risk to listed buildings
The proposed development comes within touching distance of the Grade B listed Bridge of Feugh and Tollhouse. These structures are an integral part of the heritage south of the Dee and are very sensitive sites given the traffic that is already present.
The major increase in congestion at this site and the overarching presence of 300 homes behind it would result in a detrimental effect on the character, integrity and setting of the category B listed Tollhouse and Bridge of Feugh, contrary to ALDP Policy 13 – SG HE1.
Landscape & Visual Impact
The site character is a major part of the area south of the Dee and is one of open fields and sweeping views. The site makes up the large part of the land between Scolty Hill to the west and the Falls of Feugh to the east. The character of the wider landscape is very strong and is also characterised by Scolty Hill and woodland to the west, the Falls of Feugh to the east and the River Dee SAC to the north, east and south. Due to the scale of these plans in this location, they would have an unavoidable detrimental impact on the existing landscape character and setting of Banchory.
The plans would also have a significant negative impact on the protected views from both Scolty Hill and Sunset Seat (valued view 27). The views from Scolty are expansive and both the hill itself and views from it are integral to the community's identity. The view eastward from Scolty is particularly important as it stretches uninterrupted along South Deeside to the North Sea. This development would seriously affect that view in which a suburban housing development would be built in the immediate foreground.
On June 3rd 2014 the Marr Area Committee agreed to “Designate Scolty as a Valued View and promote it as a Locally Valued Landscape as part of the Local Landscape Designation Process.”. This development would seriously affect the view of and from Scolty.
As per the 2008 Landscape and Visual Impact Assessment carried out by David Wilson Associates, we agree that any development of this scale south of the River Dee would result in a major urban intrusion into the countryside setting the precedent for future development. The existing enjoyment and views of the land south of the Dee would be forever damaged, including the much loved outlook from Scolty Hill and the renowned Grade B listed Feugh Bridge.
Pollution
Due to the increased traffic and congestion as a result of the location of the proposed development, it is envisaged that a significant increase in vehicle related pollution would be felt within the centre of Banchory. The resulting traffic from an initial 300 homes and the required construction traffic to build the development could impact the air quality and therefore health of local residents. The existing and proposed allocations for future development in Banchory lie to the north and east of the town which reduce the stresses on the town centre when compared with these proposals.
The importance of the River Dee SAC (adjacent to Braehead) must also be recognised; it is a Natura 2000 site and has been protected as a "site of international importance for Atlantic salmon, freshwater pearl mussel and otter". The proposals would therefore not adhere to SPP or the SDP in that they would risk the water environment and a SAC/Natura 2000 site.
Braehead is also part of the River Dee Local Nature Conservation Site (LNCS).
The developer’s Environmental Statement states that "potential dust emissions from construction could be large" which raises serious pollution concerns in a countryside site that is bordering the SAC. The Ecological Impact Assessment also does not account for the fact that a tributary to the Dee flows west to east just north of Braehead and the site contributes significant run-off to that burn. Run-off from the development could pose a serious pollution threat to the SAC.
The development would also add to levels of air pollution within Banchory due to the significant increase in traffic that would result, especially through the town centre. And finally the development would contribute to considerable increases in light and noise pollution in an area that is currently countryside. This would be particularly evident from Scolty.
Environment
The River Dee and its tributaries make up the River Dee Special Area of Conservation (SAC). This area, managed by Scottish Natural Heritage is part of a network of internationally important sites for nature conservation, known as Natura 2000 sites. The SAC provides a valuable habitat for important populations of freshwater pearl mussel, Atlantic salmon and otter. The Sandlaw Farming site comes within 15m of the river Feugh at the south eastern boundary and within 75m of the river Dee at the northern boundary.
The construction of 300 homes in such proximity poses a clear and direct risk to the SAC.
Development on such an environmentally sensitive site should not be approved if it is outwith the LDP and without overwhelming national level benefits.
There are many protected species in the area including otter, Atlantic salmon, red squirrel, wildcat and pine marten all of which would be affected by a reduction in green space, removal of habitat (such as the critical boundary features) and increase in pollution. There is also ancient woodland on the site which should be preserved and not endangered by approving a major development on all sides.
The proposal would destroy wildlife corridors and valuable landscape features that encourage wildlife including protected species. Due to these reasons the application is contrary to ALDP Policy 11 – SG NE2, Policy 14 – SG S1 and Policy 14 – SG S3.
Tourism
The proposals would damage tourism by detracting from the appeal of Scolty, the Falls of Feugh and fishing on the Dee. These are the things that attract people to Banchory and they would be negatively impacted by the approval of a major development in such close proximity.
There is no basis to the argument that the development would attract tourists. The development would negatively impact the landscape that is so integral to why people visit the area.
We must protect our important landscapes and cultural sites, not develop them.
The Wrong Place
If you perform a quick internet search of "Aberdeenshire Landmarks" both Scolty Hill and the Falls of Feugh appear near the top of the list. This area forms one of the most loved and well used parts of Aberdeenshire for sport, recreation and by tourists from all over the world. It is an untouched area of important landscape that lies outwith Banchory itself. It is not a natural extension of the town and is of great importance to the community. This importance has been recognised by the Council who in 2015 highlighted how "the importance to the community of the land south of the Dee must be recognised". To quote former Aberdeenshire Provost Councillor Jill Webster, "of all the places we could build in or around Banchory, this is the absolute worst".
LDP Process
This development would signify a major break in the statutory process of long term planning in Aberdeenshire. The Local Development Plan (LDP), prepared over a 4 year period with extensive specialist input and public consultation, did not include this land for development. The LDP lays out the road-map for approved development in Aberdeenshire, including Banchory, with an existing plan covering the current term (2012 - 2016) and an emerging plan recently approved to cover the next term (2017-2021). Neither the existing nor emerging LDP includes any basis for development south of the Dee with future development in Banchory having been identified and approved to the north and east which will allow Banchory to grow sustainably.
A 395 home development has already been set in motion, as per the both the current and emerging LDP, for the Hill or Banchory. If approved, the Braehead development would more than double the number of planned new homes for the coming 5 years.
Banchory sits within a “Local Growth and Diversification Area” and as per page 22 of the Strategic Development Plan (SDP) for Aberdeenshire these areas account for just 5.5% of the planned growth for the region. They are clearly not an area for significant growth which should be focussed to the Strategic Growth Areas where 75% of the planned growth is set to take place (SDP page 11).
Planning Justification
The developer uses an argument based on population projections, household projections, effective land supply and a perceived housing shortfall to justify approving sites outwith the LDP in local growth areas such as Banchory. However these arguments have repeatedly been shown to be without basis by both Aberdeenshire Council and the Scottish Government Reporter.
Population projections – the developer argues that the 2008 based projections used in the SDP show a lower population than more recent data (only if you combine the Aberdeen City and Shire figures). However when you look at Aberdeenshire alone the more recent figures actually show a lower projected population. Please see page 36 of the 2008 data and page 46 of the more recent 2012 data for the figures.
Household projections – again the developer argues that the 2008 based projections are lower than the recent data, yet when you look at the Aberdeenshire figures in isolation (2008-based and 2012-based) you can see that the figures are close to identical.
The developer uses both of these projection arguments to argue that the SDP and therefore LDP are not up-to-date nor relevant. However as shown above, the newly released projections for Aberdeenshire are the same, if not lower, than the figures used to create the plan.
New projections are published every two years - three times between reviews of the development plan, therefore the fact that more recent projections have been published does not in any way render plans out-of-date or irrelevant.
In reference to the arguments against land supply, Aberdeenshire has a 7.7 year effective land supply which is one of the most robust in Scotland and sufficient to meet the needs of the area.
The developer also tries to use housing allowances to justify a shortfall in housing completions, however paragraph 4.24 of the SDP specifically warns against making this comparison. The correct comparison is between housing requirements and housing completions as allowances will always include a significant buffer to allow for flexibility. In the period from 2017 – 2020 the number of housing completions vs. requirement is projected to be in significant surplus for Aberdeenshire.
If any new requirement for homes was identified by Aberdeenshire Council then there is a clear mechanism for drawing on preferred sites within the region, focused to the areas set aside for strategic growth. There is no basis for approving a countryside site in a local growth area that is outwith the LDP and contrary to the aims of the SDP.
Suitability of the Site
As can be seen above the site has been put forward as a candidate but not included in the current or emerging local plans. The Council, with the support of the community, has made clear references to why this site is not suitable for development and some of these are outlined in the sections below.
Braehead is a countryside location, across the River Dee to the south of Banchory. It is not within walking distance of the schools, the supermarkets, the business centre or the proposed new sports village.
The location would encourage people to use their cars and force them to travel either through the centre of Banchory High Street or across the single lane Bridge of Feugh.
As the site is not in the current or emerging LDP and is not in a SDP Strategic Growth Area there is not the infrastructure in place to support such large scale development.
As per the 2013 – 2019 Aberdeenshire School Role Forecasts it can be seen that Banchory Academy is currently operating at 105% of its existing capacity and Banchory Primary will be over capacity by 2018.
Due to a lack in sewage infrastructure the development would also require that a large 100m2 Foul Waste pumping station be constructed on the south bank of the Dee, within the Special Area of Conservation.
The developer tries to argue that development here would be “sustainable” but from the summary of reasons above it can be seen to in fact be the opposite.
Site for Medical Centre/School
The developer also proposes a site for “community uses” and goes on to suggest that it could be used for a new medical centre or school. There is already an approved new site within the village for a new Medical Centre and the approved housing expansion of Banchory has been focused around the recently built Hill of Banchory school. The Braehead site does not allow for easy or safe access to or from Banchory for any new major facilities and would lead to car dependency and a deterioration of the SAC.
Traffic Concerns
The developer has commissioned a Transport Assessment (TA) which concludes that the development would present no noticeable effects on Banchory.
However the report has assumed that only 170 additional car journeys per day would be felt on the roads as a result of the 300 new homes. Knowing how reliant people are on their vehicles south of the Dee we would assume this number to be more than double in reality.
The Feugh Bridge would become swamped with new commuter traffic trying to avoid the traffic lights and newly created congestion at Banchory High Street. And as the TA states that an estimated 75% of all traffic would be commuting to Aberdeen (of which 50% would be going through the High Street) we feel there would be a major increase in congestion.
The TA also does not take account of school traffic as a result of parents within the new development driving their children to school and does not take account of the increased risks to pedestrian safety that would come about as a result of the newly created congestion.
Risk to listed buildings
The proposed development comes within touching distance of the Grade B listed Bridge of Feugh and Tollhouse. These structures are an integral part of the heritage south of the Dee and are very sensitive sites given the traffic that is already present.
The major increase in congestion at this site and the overarching presence of 300 homes behind it would result in a detrimental effect on the character, integrity and setting of the category B listed Tollhouse and Bridge of Feugh, contrary to ALDP Policy 13 – SG HE1.
Landscape & Visual Impact
The site character is a major part of the area south of the Dee and is one of open fields and sweeping views. The site makes up the large part of the land between Scolty Hill to the west and the Falls of Feugh to the east. The character of the wider landscape is very strong and is also characterised by Scolty Hill and woodland to the west, the Falls of Feugh to the east and the River Dee SAC to the north, east and south. Due to the scale of these plans in this location, they would have an unavoidable detrimental impact on the existing landscape character and setting of Banchory.
The plans would also have a significant negative impact on the protected views from both Scolty Hill and Sunset Seat (valued view 27). The views from Scolty are expansive and both the hill itself and views from it are integral to the community's identity. The view eastward from Scolty is particularly important as it stretches uninterrupted along South Deeside to the North Sea. This development would seriously affect that view in which a suburban housing development would be built in the immediate foreground.
On June 3rd 2014 the Marr Area Committee agreed to “Designate Scolty as a Valued View and promote it as a Locally Valued Landscape as part of the Local Landscape Designation Process.”. This development would seriously affect the view of and from Scolty.
As per the 2008 Landscape and Visual Impact Assessment carried out by David Wilson Associates, we agree that any development of this scale south of the River Dee would result in a major urban intrusion into the countryside setting the precedent for future development. The existing enjoyment and views of the land south of the Dee would be forever damaged, including the much loved outlook from Scolty Hill and the renowned Grade B listed Feugh Bridge.
Pollution
Due to the increased traffic and congestion as a result of the location of the proposed development, it is envisaged that a significant increase in vehicle related pollution would be felt within the centre of Banchory. The resulting traffic from an initial 300 homes and the required construction traffic to build the development could impact the air quality and therefore health of local residents. The existing and proposed allocations for future development in Banchory lie to the north and east of the town which reduce the stresses on the town centre when compared with these proposals.
The importance of the River Dee SAC (adjacent to Braehead) must also be recognised; it is a Natura 2000 site and has been protected as a "site of international importance for Atlantic salmon, freshwater pearl mussel and otter". The proposals would therefore not adhere to SPP or the SDP in that they would risk the water environment and a SAC/Natura 2000 site.
Braehead is also part of the River Dee Local Nature Conservation Site (LNCS).
The developer’s Environmental Statement states that "potential dust emissions from construction could be large" which raises serious pollution concerns in a countryside site that is bordering the SAC. The Ecological Impact Assessment also does not account for the fact that a tributary to the Dee flows west to east just north of Braehead and the site contributes significant run-off to that burn. Run-off from the development could pose a serious pollution threat to the SAC.
The development would also add to levels of air pollution within Banchory due to the significant increase in traffic that would result, especially through the town centre. And finally the development would contribute to considerable increases in light and noise pollution in an area that is currently countryside. This would be particularly evident from Scolty.
Environment
The River Dee and its tributaries make up the River Dee Special Area of Conservation (SAC). This area, managed by Scottish Natural Heritage is part of a network of internationally important sites for nature conservation, known as Natura 2000 sites. The SAC provides a valuable habitat for important populations of freshwater pearl mussel, Atlantic salmon and otter. The Sandlaw Farming site comes within 15m of the river Feugh at the south eastern boundary and within 75m of the river Dee at the northern boundary.
The construction of 300 homes in such proximity poses a clear and direct risk to the SAC.
Development on such an environmentally sensitive site should not be approved if it is outwith the LDP and without overwhelming national level benefits.
There are many protected species in the area including otter, Atlantic salmon, red squirrel, wildcat and pine marten all of which would be affected by a reduction in green space, removal of habitat (such as the critical boundary features) and increase in pollution. There is also ancient woodland on the site which should be preserved and not endangered by approving a major development on all sides.
The proposal would destroy wildlife corridors and valuable landscape features that encourage wildlife including protected species. Due to these reasons the application is contrary to ALDP Policy 11 – SG NE2, Policy 14 – SG S1 and Policy 14 – SG S3.
Tourism
The proposals would damage tourism by detracting from the appeal of Scolty, the Falls of Feugh and fishing on the Dee. These are the things that attract people to Banchory and they would be negatively impacted by the approval of a major development in such close proximity.
There is no basis to the argument that the development would attract tourists. The development would negatively impact the landscape that is so integral to why people visit the area.
We must protect our important landscapes and cultural sites, not develop them.
The Wrong Place
If you perform a quick internet search of "Aberdeenshire Landmarks" both Scolty Hill and the Falls of Feugh appear near the top of the list. This area forms one of the most loved and well used parts of Aberdeenshire for sport, recreation and by tourists from all over the world. It is an untouched area of important landscape that lies outwith Banchory itself. It is not a natural extension of the town and is of great importance to the community. This importance has been recognised by the Council who in 2015 highlighted how "the importance to the community of the land south of the Dee must be recognised". To quote former Aberdeenshire Provost Councillor Jill Webster, "of all the places we could build in or around Banchory, this is the absolute worst".
