EIA Scoping Opinion Land at West Kingsford (North of the A944 Road) Page EIA Scoping Report page 10 page 13 Section 4.2.3 Cumulative Impacts 5. Proposed Scope AWPR, Prime four and other development areas (OP43 and OP42), specifically addressing the effects of coalescence along the A944 corridor. Aberdeen Landscape strategy identifies key areas (of which this is one) of green spaces and buffers to prevent visual or physical coalescence of urban areas see Landscape Strategy Part 1 (2002) Not clear which section of the EIA will consider connectivity to the Green Space Network across this site. In terms of Core paths and recreation where will this be assessed? Some aspects can be considered in the LVIA (in terms of impacts on path users as receptors). Consideration should be given to the inclusion of waste management in this section. There would be significant impacts associated with construction activity waste especially if land removed as part of the development isn t utilised on site. Should this be captured? Waste team input might be needed. The site is also located on an old landfill. Section 5.7.4 mentions a material management strategy and that operational works to be covered in project description. If a chapter is
page 14 5.2.2 planning Policy description. If a chapter is not included than greater detail is needed within the project description with reference to policy R2 and contaminated land. There is no mention of climate change mitigation and adaptation especially given the large surface area of potentially non-porous surfaces to be installed and the impact this would have on OP34 risk of flooding. Development should not to be permitted if it increases risk of flooding according to NE6. More detail on building climate resilience into this development is needed. Include and be guided by N1 Green Space Network. The site is located on a site which would expect to provide a linkage between the existing GSN to the east and the developed sites to the east and those to the west. The current green space network would expect to be expanded to include provision for green spaces in any new development in this area, particular as it will connect the city to already developed areas to the west. The relationship between corepaths and cycle routes and future GSN should be identified and addressed in the layout and design of the site. NE 6 the Landscape guidelines SG covers landscape design. The document which provides guidance and background relevant to landscape planning is the Landscape Strategy Part 1 (2002).
page 14 Context Strategy Part 1 (2002). NE8 reference is made only to the Buffer Strips SG. Refer also to Natural Heritage TAN. NE9 is also relevant in relation to this area being a strategic corridor, and related to the aspirations for a connected green network for both people and wildlife. Aberdeen LDP (2015) SG is in the process of being updated. Reference should be made to relevant Supplementary Guidance and TANS as part of policies to be considered. In relation to policy D1 and D2 there is no reference to BREEAM and sustainable construction in the project description and also policy R7 also on low and zero carbon developments. Other relevant policy includes NE10.
Page 16 Site selection Alternative sites, relative merits etc, need to be considered in the context of the plan/policy departures needed for this site. The proposed development is located on green belt land, directly against policies NE1 and NE2. More required on justification for this in project description. There needs to be further detail / justification as to what the reason is that this development is classed as a major infrastructure project that would merit the need for green space network erosion. All aspects of the EIA when considering cumulative impact should take cognisance of OP34 (East Arnhall), OP63 and 29, Prime Four continued development and transport.
Page 18-19 5.6 Water resources etc. This site contains habitats sensitive to changes in hydrology. We would expect to see an integrated approach (including the design of multifunctional SUDs) to protecting important habitats and mitigate effects on the water environment, flooding, landscape and natural habitats. The site presents to the opportunity to make improve linear east-west connections across the north and south perimeters of the site, including providing part of a habitat link to the west towards Arnhall LNR.. The compatibility of wetland habitats with high maintenance sports pitches needs to be considered and mitigated. 5.6.4 Last bullet point should refer to the protection of existing important habitats (e.g. wetlands/raised bog). The assessment should consider the impacts of changes in levels, both in the hydrology and on the direct loss of wet grassland/wetlands. The assessment should consider how the development can achieve objectives for reducing traffic, including existing and potential provision for alternative means of transport, facilities to encourage active travel and public transport, buffered from the A944 with green space / tree planting etc. It should consider this in the context of connections to the Green Space Network and existing cycle and path routes in the locality, for
5.8.3Traffic, Transportation and Access routes in the locality, for example Core Path 91. The assessment should also acknowledge that this is an important and busy cycling corridor between Aberdeen and the Kingswells and Prime Four business areas, with the potential for conflict between different forms of travel with additional vehicle crossings. Pedestrian and cyclist movements need to be considered not just on the core path but in general within and around the site as this area will be far more heavily used than at present, especially on matchdays, how these people interact with vehicle movements both caused by the development and in general needs to be properly studied to ensure pedestrian and cyclist safety. 5.8.4 The traffic assessment is considering the year of opening only, which would not take into account future developments in already allocated sites. It should include a cumulative assessment of traffic levels when all identified and planned development in the area has been completed to ascertain what effect the stadium proposal, an unallocated site, would have on LDP planned development.
Page 22 5.9 Air Quality Section 5.9 predominantly discusses dust emissions. There is no mention of methane from old landfill excavation and monitoring thereafter. This needs further consideration and Environmental Health needs to be consulted. We note that your proposed analysis of baseline data covers: Local level likely to include Kingsford, Kingswells, and possibly Westhill; Regional level likely to include Aberdeen City Council/ Aberdeenshire Council areas, and National level Scottish data. A general weakness of the socio-economic impact assessment is its treatment of impacts on the local level / local project zone (LPZ) as being synonymous with impacts on regional level / construction daily commuting zone (CDCZ) and/or the national level / wider impact zone (WIZ). Impacts arising from any project are likely to affect surrounding geographical areas, from the LPZ (Kingsford, Kingswells, and possibly Westhill), through the CDCZ (Aberdeen, Aberdeenshire) to the WIZ (Scotland and UK). The overall benefits of the proposed project to Aberdeen City or the region do not automatically
Page 26 5.1.1 Socioeconomics do not automatically translate into benefits for the communities in the LPZ (Kingsford, Kingswells, and possibly Westhill). This is why we will like to see your assessment covering all of these areas as your methodology indicates. Specifically we would like to see the assessment of impacts covering: Direct economic effects local vs. non-local employment and income characteristics of local vs. non-local employment (e.g. skill group) local vs. non-local labour supply, training and apprenticeship local vs. non-local wage levels 2. Indirect/wider economic/ expenditure wider multiplier effects effects of employees retail expenditure on local economy links between local suppliers and the project local labour market pressures 3. Demographic impact from the construction and operation phases of the project changes in population local size (temporary and permanent) changes in local population
population characteristics (e.g. family size, income levels, socioeconomic groups) changes in local settlement patterns 4. Effects of the project on local housing including: housing tenure and types in the local area public and privatesector housing in the local area house prices and rents in the local area homelessness and other housing problems in the local area 5. Effects of project staff and future users of the development on: local educational services local health services and social services local police, fire, recreation and transport services local finances 6. Socio-cultural effects of project staff and future users of the development on: lifestyle/quality of life including but not limited to potential drink driving issues gender issues; family structures social problems (e.g. crime, illness, divorce) community stress and conflict; integration, cohesion and alienation
and alienation General Comments Brindley Scoping Study Ecological Assessment Consideration should be given to undertaking constraints and opportunity mapping A clear statement of biodiversity objectives for the proposals should be provided. The project should identify opportunities to both mitigate biodiversity impacts and enhance the biodiversity of the site (and in doing so, the surroundings). This will need to include consideration of the habitats on and near the site and their role in the wider habitat network which extends into adjoining areas, notably of wetland/water body habitats, including Arnhall Moss raised bog. Brindley Scoping Study Ecological assessment Although the site and immediately surrounding habitats may be undesignated and of local significance they are important (and have potential for greater importance) in a city context, and potentially provide habitats for protected species. The Phase 1 survey does not look beyond the boundary of the site. Survey work must extend beyond the boundary of the site, and include appropriate buffers for each species and habitat type refer to SNH and IEEM Guidance. Table 4) 1.4.2. Birds survey timing would need to take
Brindley Scoping Study LVIA timing would need to take account of wintering birds. Badgers surveys should be included to establish if the site and surrounding area is part of a badger territory. 1.4.3 Otter unlikely to be affected at this stage it is too early to accept this, as there are no details of the proposals available. It would depend on the design of the proposals and any direct or indirect impacts on otter usage of the site. 1.4.4 The impact of light and noise as a form of disturbance should be included.
Brindley Scoping Study LVIA A clear statement describing the landscape strategy and landscape objectives for the proposals should be provided, in the context of the landscape setting of the site, and the role of this area in providing a setting for Aberdeen. More detailed information on the detail of the proposals is required. A detailed landscape character assessment will need to be undertaken to allow the proposals to be fully assessed, as the existing LCA does not adequately describe the landscape in this area. For example the subtle topography; the pattern of settlement and rural land uses; the contrasting relationships between the rural landscape and its adjoining residential and business land uses; and the variations in scale and type of settlement pattern. The area maintains its largely rural character and is part of a key rural greenbelt band which contributes to the setting of Aberdeen. Retention of the key characteristics of open, unbuilt character in line with the approach in the Aberdeen Landscape Strategy is central to this assessment. The scoping report states
page 8 1.3.5 Assessment of effect upon routes The scoping report states that potential effects that occur in views from main vehicular and marked recreational routes, paths and trails will be assessed primarily from roads and footpaths that face the proposed development. Consideration should also be given to any trails and routes approaching the area, or with potential views of the site. Strategic landscape issues: The importance of the A944 as a gateway to/ from the city should be included in the assessment. This includes how the area functions as a transition between city and rural landscapes, and its importance as a high quality setting/approach to business parks at Westhill and Primefour. The mapping should take
1.3.7.1 ZTV mapping The mapping should take account of the total height of the development including any ground infill. Figure 4, note 7 excludes this. It should be noted that the ZVT refers to day time visibility only and that a greater zone of influence would likely result at night time. The spatial extent and magnitude of night time impacts should be assessed and mitigated to reduce the zone of lighting influence at night/ dusk to a minimum. It should also describe the effects in different weather conditions (for example in clear skies or where cloud presence increases adverse effects.
1.3.7.2 Visualisations ACC advises that it will require at least two copies of full size, high quality printed visualisations are required. Visualisations will show the proposed development and all ancillary structures, for example lighting columns, overhead services/cables, drainage, and security fences. Night time/dusk visualisations and assessment of night time effects (including cumulative effects) will be required. This may mean that additional viewpoints will be required to assess direct lighting impacts and indirect night time glow (which can sometimes be visible from a far wider range of viewpoints). These should include the effects during autumn-winter-spring when deciduous trees are leafless. Assessment of cumulative effects of lighting (for example with the AWPR will be required). In addition to visualisations using standard methodology, accurate illustrations should be prepared to show how the development will be designed to sit within the landscape, how it will enhance the local landscape and A944 gateway experience.
1.3.8Assumptions 1.4.1 Landscape Effects 1.4.2Visual effects Assessment based on design proposals at time of writing : ACC reserves the right to require additional / updated information should it consider that design changes over the period of the assessment would result in a change of significance of the effects, or significantly alter the appearance of the development in visualisations. Strategic landscape issues: Include the wider effects on the setting of the city - refer to the Landscape Strategy. Note the need for a night time assessment. Note the need for a night time assessment.
Table 2 Item 3, page 13 and Figure 5 General Additional view points Viewpoints Table 2 item 9 and 9.1 Plans, maps Referring to the ZTV - figure 05, a comprehensive range of viewpoints is required. Key viewpoints not represented, and required: From open areas to north in close proximity - minor road (Westhill Road) to north to represent views by road users and from private properties. From open, higher areas on two minor roads to the south, and properties, where the site can be seen in the rural context. Viewpoint 5 the exact location could not be worked out from the low resolution map, however it should be chosen to provide an uninterrupted view of the site. A viewpoint lower down the road (closer to the site) is also required. Viewpoints along the AWPR, both near to the site and approaching from the north and south. Closer to the site than VP4 (in addition to VP 4), on the A944 Public places near residential properties at the edge of Westhill and potentially from higher land at Westhill. Additional viewpoints may be required for night lighting/light pollution assessment. Proposed site OP63 should be added. Future plans should show the location of the AWPR and be higher resolution.