KDCC objects to park size reduction
Planning Department
Aberdeenshire Council
Gordon House
Blackhall Road
Inverurie
AB51 3WA
Dear ______,
Outline Planning Permission for Enabling Residential Development and the Formation of a Town Park
Thank for your letter dated 17th March 2009 regarding the above. We have considered both the information provided and the history of the site and wish to make the following observations and objections to the current proposal.
Objection: Local Plan
In the draft version of the currently adopted Local Plan, this 11Ha area (identified within site P2) was originally designated as a Town Park. It was however thought during the final consultation stages of the Local Plan that the only realistic prospect of delivering such a town park would be through an associated enabling development which would use a high proportion of income generated towards the appropriation of land, services and facilities.
As an enabling development, it would be natural to assume that the majority of the site would remain as a town park and not require sacrificing over 70% of the total area to housing, to only receive a town park of just 3.3ha in size.
The Local Plan set the population of Kintore in 2004 at 2,821 residents. Since then the housing stock has risen within Kintore by almost a further 650 units and potentially increased Kintore’s population by a further 1,500 residents bringing the total to approx. 4,321. The housing associated with the enabling development has the potential to further increase this figure by a further 600 residents.
The Local Plan public open space standard for new developments is that for each property built, 40m_ needs to be allocated for open space such as a town park and organised sports facilities. In Kintore, the open space has in fact been reduced by the construction of new homes and the new primary school.
Appendix Six of the adopted Local Plan outlines the ideal hierarchy of Open Space for developments. It states that a civic or town park should be provided within 1.5km of housing where the catchment population is above 2,500 residents. The main function of this park is to provide a strategic ‘green lung’ of a town, with semi-formal and informal open space for walking, wildlife, picnics and enjoyment of the scenery for all the family. Its size should range between 1 – 5ha.
It also similarly states that Organised Sports Facilities be provided within 1.5km of housing where the catchment population is also above 2,500 residents. This can be associated with a town park but its size should range between 7.5 – 15ha. It requires flat, well-drained ground and associated changing facilities.
Taking into account the population levels of Kintore and the current provision of formal open space with Kintore, the area proposed by the developers falls far short of meeting the policies contained within Aberdeenshire Local Plan.
With open space recreational area at a premium within Kintore, this proposal in its current form is likely to meet stiff opposition from the community and may further fuel the community’s scepticism that Aberdeenshire Council has the developer’s interest at heart rather than those of the community.
Observation: Development Brief for Gauchhill
Scottish Planning Policy 1 (SPP1) states that Development Briefs can be an effective means of promoting specific development opportunities and can aid the creation of high quality development.
To clarify what was envisaged as an enabling development, Aberdeenshire Council prepared a Development Brief to give clear indication to both developers and the community.
Although Development Briefs are considered as supplementary guidance, applicants whose Planning Application conforms to an approved Development Brief are more likely to receive planning permission.
The Development Brief outlined that a large area of public open space of at least 4.5ha and the woodland area was required within Kintore to provide a valuable community facility that would have the potential to encourage a wide range of recreational facilities that would require the input of the local community to ensure satisfactory development of these.
The area of 4.5 hectares was less than what the community had hoped for but this compromise was regarded to be substantial enough to allow the development of sports pitches, associated parking capable of accommodating coaches, a large play area with play equipment, semiformal areas and a pavilion.
The Development Brief stated that the primary reason for any development at this site was to enable the development of a town scale area of open space suitable for multi use that also includes the protection of the Woodland for the current residents of Kintore as well as for future generations. The Development Brief set that the preferred location for the public open space and recreational areas was to the north of the site, with access from the B994 and a network of green corridors and footpaths connecting the open space directly with existing Kintore.
Although the Development Brief stated that an alternative location within the site boundaries could be considered if it were able to meet the requirements outlined within it, it did not suggest that the requirements could be met with an area of reduced size.
Objection: Capacity Study
The conclusions of the 2008 Capacity Study did not consider that this site should accommodate further housing and shows the layout of the area as per the Development Brief. The Capacity Study also identified that Kintore would need a Secondary School to enable its further development. With Aberdeenshire Council’s initial Secondary School location proposal at Midmill currently in the process of being developed as housing, the only other ideal site that could provide suitable access to other communities and accommodate a Secondary School with associated playing fields would be this site.
Objection: Sense of place
The map provided shows that access to the park/sports area would be through new residential areas both to the north or south. By not having uninterrupted access from the existing community, it is highly likely this would remove its ‘sense of place’ for the whole community, as it will feel instead more part of the new developments rather than part of the community and discourage its use by existing community members.
Being sandwiched between housing developments, it is therefore also likely that this area could not be used by the community until construction work of the housing areas was completed.
Objection: Suitability for use
The amount of area proposed is unlikely to allow the area to be used at the same time for both recreational and sports uses. The proposal suggests that this would be more in keeping with a sports park rather than a town park. Many residents in the community are already unhappy they are unable to use the Castle Road park area for recreational uses with their families at the weekend due to the formal sports events frequently held there. Due to its immediate proximity to both a young children’s play area and homes, the inappropriate language that often comes from players and spectators at such events is of great and ongoing concern to residents.
Objection: NPPG 11
NPPG 11 Sport, Physical Recreation and Open Space gives guidance to Councils on the levels of provision for these facilities and recognises the need and the importance of communities having access to healthier lifestyles through the positive provision of public open spaces and sports facilities. It sets out that residential neighbourhoods should be no more than 400m from a small park of 1.5ha and no more than 1200m from more extensive facilities suitable for organised sports.
NPPG 11 sets out that the national minimum Open Space standard for new developments is 40m² of public open space per house divided between parks and sports areas. Taking into account both the current number of homes within Kintore and the number of further homes in the pipeline, Kintore will require approximately 8ha of public space to meet this minimum requirement.
Formal park areas within Kintore are currently limited to Castle Road Park and are located next to Kintore’s new Primary School. This park was originally much larger but its size has been reduced too just 2.5ha due to expansion of Kintore Primary School and neighbouring housing developments. The town park at Midmill will thus need to accommodate at least 5.5ha to meet both the National minimum open space standard.
Based upon the feelings of the community about the lack of open space areas and open space previously enjoyed being lost, the Community Council cannot support any enabling development proposal that does not meet the requirements within the Development Brief that has been supported by the community and accepted as an acceptable compromise to their aspirations.
We therefore both ask and encourage Aberdeenshire Council not to consider supporting any proposal that does not incorporate a park area as specified in the Development Brief.
Should you require any additional information, clarification of any comments made, or would like to arrange a meeting to discuss our comments further; do not hesitate to contact us.
Yours sincerely,
For Kintore and District Community Council
Kenny Thomson
Chairman