OP63 Framework for Prime Four – Response From Kingswells Community Council
Kingswells Community Council (KCC) makes the following comments on the Draft Framework Document for the OP63 site within the Prime Four Business Park.
This response is written before the Local Development Plan (LDP) has been approved and whilst the OP63 site is under review by the Reporter. As such the response is written with the following assumptions:
the Reporter approves the OP63 site for development in the LDP
the Reporter does not ask for any changes to the wording of the LDP.
If any of the above assumptions prove to be invalid then KCC reserves the right to make additional comments.
The official view of Kingswells Community Council is that the OP63 site is not suitable for this type of development and if there is a need for additional office space then a more suitable site should be found within the Aberdeen City strategic growth area.
The need for this expansion is questionable considering the recent request by the Drum Group for the change of use for the original Phase 4 (now referred to as Phase 5) of the Prime Four site to retail, food and drink and other uses other those that identified in the LDP.
KCC considers the timing of the issue of this document before the approval of the LDP and indeed during the review by the Reporter as a manipulation of the planning system. This view is further justified by the request for the change of use described above. The original Phase 4 area is low-lying and more suitable for the tall buildings proposed than the hilltop development proposed for OP63.
For ease of reference the section headings in this document refer to those used in the Framework document.
Communication and Engagement
The document suggests that there has been a lack of community engagement . KCC has been fully engaged throughout the life cycle of the Prime Four Development and has adopted a philosophy to only identify issues that make a real difference to the community and to let ACC planners act as guardians to ensure the other technical issues are handled in an appropriate manner. KCC concentrated on the integration of the development into the rural setting of Kingswells and assumed that Drum Group would deal with the internal workings of the development.
The lack of comment should not be construed as lack of interest. The comments made by KCC on behalf of the community should be given even more credence as we have already removed any minor comments. All our comments are significant concerns and they should not be dismissed.
Protection of Heritage and Features
KCC does not accept that the introduction of the AWPR gives Drum Group the right to destroy the landscape setting of the area. The AWPR will merge into the landscape and will, in time, have less impact. The proposal to have significant buildings and skyline development will change the landscape forever, and this type of development should not be allowed in the Framework. The original agreement with the community to minimise the visual impact of the development from the surrounding area should be respected.
Impact on Landscape
See above comments.
KCC do not agree that the first phases of the development have been located sensitively within the landscape and more effort is required to minimise the impact on the landscape. Despite promises made by Drum Group that “the development would not be seen from anywhere”, the development is highly visible from a significant distance from the site. Tighter control is required going forward and no development should be allowed above the tops of existing trees, including those in West Hatton Woods, and any reference to prominent development should be removed from the Framework document.
Section 5.1 The Site
Note: timings for walking from Kingswells are extremely optimistic, and are likely to be measured from the Kingswells boundary. A further 15 minutes should be added for travel from the village centre and 30 to 45 minutes should be added for travel from the Derbeth / Concraig Area.
Section 5.5 Surrounding Context
The woodland to the north and east of the site can only offer screening if the buildings within the site do not breach the tops of trees and lighting does not penetrate the deciduous tree line in winter.
Section 5.6 Ecology
We accept the summary information about the ecology of the site. We have previously stated our concerns about the encirclement by buildings of the Local Nature Conservation Site at West Hatton Woods. Increased shading by high buildings during daytime and light pollution at night are bound to have an adverse impact on biodiversity in the woods and reduce their value as a corridor for wildlife. Any development on OP63 should include a commitment by Drum Group to manage the woodland sensitively in order to sustain and broaden their biodiversity. Access paths through the woodland should not be part of any plans going forward.
Section 5.7 Heritage and Archaeology
KCC does not accept that the proposed development “will not affect the setting of the consumption dyke in any way”. The only way to ensure this happens is to extend the “no build” zone introduced in the original Masterplan westward into the OP63 site. KCC insists that the “no build” zone that extends for 120m on both sides of the consumption dyke should be extended westwards (see the blue area shown in Figure 1). Within this zone there should be no development above the tree tops, and development should be set back and aligned to eliminate light pollution through the trees in winter when leaf cover will be reduced. The level of the tree tops varies, and ‘no development above tree tops’ should be interpreted literally, an no part of any building should be visible when viewed from the north and east of the development.
Fig 1: Proposed Exclusion Zone
Section 5.11 Landscape
KCC agrees that the landscape has been changed by the Prime Four development and that it will be changed by the AWPR, but neither of these facts give future development the right to destroy the landscape. Every effort needs to be taken to minimise the impact of the development on the local area.
KCC also agree that lighting on the night sky needs to be considered not only as part of future planning applications, but the existing level of lighting permitted needs to be reassessed and reduced.
The Framework document makes claims about how great the development is, and the development when viewed from within the site is a fine example of a business park. However, the impact on the landscape is much more than agreed with the community, and efforts need to be made to redress the situation. (Note: height of trees in ancient woodland quoted as 15-20m.)
Section 6.2 Key Objectives
The following quotes cause KCC some concern.
“The proposed landscape strategy will be informed by existing natural features. Buildings, street patterns, spaces, skylines, building forms and materials are to enhance the sense of identity and carry on the high standard already delivered in Phases 1-3.”
“The proposals will create the opportunity for a landmark development signalling a gateway to the city at the AWPR junction and promote visually stimulating architecture when viewed in passing.”
KCC are concerned that if the landscape strategy adopted in phases 1-3 is continued then the sense of identity of the Kingswells Community will be lost forever. The strategy seems to be to make the buildings in the business park as prominent as possible. This is good for the business park but it destroys the setting of the village which is low profile and is essentially hidden in a low lying area with effective screening.
The Community Council has worked with Drum Group to try to make the development as good as it can be, and to make it acceptable to the community. We made few demands: maintain the setting of the consumption dyke and arrange the buildings to make them as inconspicuous as possible when viewed from the north. We were promised that the buildings would be concealed by the existing mature trees.
The reality of phase 1-3 is that the tree cover was removed along the A944, and the tallest buildings were built on the highest points of the site. The best views of the consumption dyke have been screened by feature landscaping (mounds) and will be further concealed in the future by the new tree planting.
The sense of identity of the village is important to the residents and their wishes appear to be being ignored by the developer and ACC’s Planning Department. We ask that the views from the north and the east are preserved. They do not need to be enhanced by further landscaping or screen planting. They cannot be enhanced by any more views of the buildings within the proposed development.
The setting of the consumption dyke is important to the residents and it should be important to Drum Group and ACC. Some redesign of the eastern boundary of the northern park is required to reinstate the once magnificent views of the consumption dyke. This can be done by some regrading work to reopen the views of the dyke from the C89 travelling north and relocating some newly planted trees. The natural backdrop to the dyke when looking west is the ancient woodland. This should not be destroyed by the introduction of buildings appearing above the tree tops or by light pollution through the trees in winter time when the leaf cover will be removed.
We ask that the height and layout of the buildings closest to the ancient woodland address the concerns outlined above. Any landmark buildings should be viewed from the west / AWPR. Phase 4 (now called Phase 5) has the lowest contours and is most suitable for the tallest buildings. The design of any future phases must ensure the existing tree cover screen the site. Having buildings appear over the tree tops destroys the natural setting. The architectural beauty of the buildings can be best appreciated from within the development site.
The whole site will be a landmark, and there is no need for any especially tall buildings to highlight the development when viewed from a car travelling at 70mph.
KCC request that the wording of the Framework incorporates the views of KCC and the community.
Section 6.3 Response to the Historic Environment
KCC appreciate that Drum Group has stated that there will be no impact on the setting of the consumption dyke from the development, but these statements need to be backed up by also including the mitigating measures required to ensure that this is achieved in practice. The consumption dyke should be included in this section. Mitigation should include height restrictions to ensure plant rooms are below the tree tops, and buildings are well set back to reduce light penetration through the trees.
The height of trees is not quoted consistently in the document. 15-20m is quoted and so to is
20-25m. In reality the height of trees varies across the site, and the actual heights should be used when designing specific buildings.
Friends Burial Ground
KCC would like the following modification:
“Any building within close proximity to the 20m buffer zone will require to take cognisance of its setting through the use of sensitive design and materials.”
should be changed to:
“Any building within close proximity to the 20m buffer zone will require to take cognisance of its setting through material selection and the use of sensitive design including building height and by increasing the effect of the buffer zone using car park layout.”
The image in Fig 47 appears to be satisfactory, but the presence of a dominating building in the immediate vicinity of the photo would change this opinion.
KCC would favour a road layout that passed in low profile to the north of the Friends Burial Ground, but reserve the right to comment on this at the application stage.
KCC is concerned that a 10m buffer may not be sufficient when considering future maintenance that may require felling of some trees 24m high. The design should include a 10m buffer to the car parking area, and this would avoid buildings creating dark spots which cast shadow on the nearby woodland. The buffer zone between any building and the adjacent trees should be at least the height of the adjacent trees.
KCC welcomes the creation of settings similar to that shown in Fig 51.
Section 6.4 Landscape
The content of this section is largely satisfactory, particularly in relation to dyke preservation/creation, native planting and design of the SUDS area. The long-term viability of the “birch grove” planting needs to be checked – birch as a species has variable success in the local area. Any felling/pruning of existing trees should be kept to an absolute minimum, especially with any less common species such as wych elm. As already mentioned, any buildings near to the Friends’ Burial Ground should be low-profile and sensitively positioned. This is not the right location for a high-profile “hub” building.
Section 6.5 Connectivity & Circulation
A landmark building, if sensitively designed to fit the rural setting, could be made prominent when viewed from within the development and possibly when viewed from the AWPR. However, KCC would like views from the AWPR and A944 and any other affected location to be included in this Framework document. We reserve the right to make comment on the additional information. The best location for a landmark building would be the lower part of the site.
KCC requests that any decked areas of parking should incorporate screening using landscaped features. The wording could be changed from:
Where topography allows, decked structures should be investigated to minimise the surface area of parking, if these can be provided without prejudicing the key principles above (fig. 58).
Where topography allows, decked structures incorporating landscaped screening should be investigated to minimise the surface area of parking, if these can be provided without prejudicing the key principles above (fig. 58).
Section 6.6 Buildings
KCC would like clarification on what the intention is for the area to the west and south of the Friends’ Burial Ground. Fig 61 suggests the area will be used for 3-4 storey stepped buildings whereas Figs 39, 58 and 60 do not show any buildings.
KCC is concerned about the impact the prominent building in the Hub will have on the setting of the Friends’ Burial Ground. The location of the Hub on Fig 54 and 56 is different to Fig 53 on P41 (assumed to be Fig 59)
KCC requests that a comprehensive set of sketches of the development from different viewpoints outside the development are prepared. This would be required before any comment on the heights of buildings could be made. We would also like some indication of how the intended heights of buildings on the OP63 site relate to the buildings in Phase 3.
KCC does not accept that there is a need for a focal point. Fig 54 demonstrates that the whole of the western boundary is visible from the AWPR and the whole of the southern boundary is visible from the A944. The whole of the south eastern corner of the site and views from the north are already very prominent. Building on the exposed southern edge of the development will be very prominent and there is no need for any especially tall buildings to highlight the site and make it any more visible than it will be. Effort is required to ensure the buildings fit into the rural landscape. The existence of the AWPR does not relieve Drum Group of any responsibility to ensure the development fits in with the existing setting. The AWPR will mellow with time, whereas this is not the case with over dominating buildings built on high ground.
KCC would like the additional information outlined above to be provided separately to allow KCC an opportunity to make comment. The above concerns made by KCC on behalf of the community must be incorporated in the text of a revised version of the Framework. The revised document should be an agreement by Drum Group, the community and ACC on the form of a suitable development for the site. Further work is required prior to approval by ACC. It is more important to get it right, and agreed than to rush the approval of this version of the Framework for OP63 through the planning system.