APRS Resources

Objection – Development at Potterton Aberdeenshire

This is the Objection that APRS sent to Aberdeenshire Council on plans for houses on Green Belt land near Potterton – May 2024

ePlanning team, Aberdeenshire Council, Viewmount, Arduthie Road, Stonehaven, AB39 2DQ,

2 May 2024

Dear Sarah Graham

Re:APP/2024/0471 | Erection of 194 Dwellinghouses (Including Affordable Housing) and Associated Works | Land North And North West Of Denview Road, Potterton

Following email correspondence earlier, which established it was not possible to extend the period for responses to the above application beyond today, please accept these comments as an objection to the proposed development.

Unfortunately, in addition to the time constraint we have not been able to look at several relevant documents referred to by the applicant as these don’t appear on the public planning portal. These include a ‘Biodiversity net gain feasibility assessment’ and a ‘Biodiversity design stage report and implementation plan’. We also note that the local authority’s natural environment consultation comments have not been published.

We are aware that the site of the proposal was allocated as an opportunity site in the most recent Aberdeenshire LDP, having previously been designated as Green Belt. Since then however, the new National Planning Framework (NPF4) has been adopted and now forms part of the development plan. Our comments below mainly refer to policies in NPF4 and raise enough concerns that we feel that on balance the proposal should be rejected. We note that in many cases there are polices in the LDP that are similar to those in NPF4, but NPF4 is more recent in date

Climate and nature crises

We would highlight NPF4 policy 1 which states that “when considering all development
proposals significant weight will be given to the global climate and nature crises”. We suggest
that this proposed major housing development on a rural, greenfield site, has associated
issues of increasing individual car use, and other concerns including biodiversity impacts,
flooding and infrastructure gaps should be reconsidered and such development directed to a
more suitable site.


As mentioned above, various documents which the applicant relies on in asserting that the
biodiversity of the site will be enhanced overall are not publicly available so it is difficult to
assess the claims made. The Design and Access Statement part 2 says on page 38 that “a
net gain will be achieved across the development, relative to the ecological baseline” and that the baseline was established by the BNG Feasibility Assessment, but this document is not
public. The BNG Feasibility Assessment is also said to make an assessment as to whether the
current design has capacity to provide a BNG and makes recommendations to address the net
biodiversity loss. It also mentions that there will be a “Design Stage Report and
implementation plan with recommendations that will be presented to the Council” but it is not
clear if this has happened.

NPF4 Policy 3 doesn’t refer to BNG but requires major development proposals to conserve,
restore and enhance biodiversity so that they are in a demonstrably better state than without
intervention and there are five criteria that must all be met. We feel that the documents we
have seen – planning statement, design and access statement and the ecological appraisal –
underestimate the hydrological linkage between the site and the adjacent ancient wet
woodland and do not fully assess the potential negative effects of the development. NPF4
requires that any such negative effects should be fully mitigated in line with the mitigation
hierarchy prior to identifying enhancement (policy 3b,iii). The current proposal relies on the
addition of new planting and nesting boxes to show a “gain” but it is not clear if the mitigation
hierarchy has been followed or if management arrangements for their long-term retention and
monitoring of the “enhancements” (policy 3b,iv) are in place.

We note the range of biodiversity that the area currently supports, including legally protected
species and that there appears to be no mention of soil biodiversity, despite the evident
negative effect such a development would have on it, let alone on the carbon stored in it.
There seems no acknowledgment of the value of the dynamic mix of connected habitats:
wetland, meadow, ancient wet woodland and the variety of biodiversity it already supports. We
also note that the applicant’s ecological appraisal recommends seeking advice from
NatureScot regarding nearby Ramsar and SAC sites but it not clear if this has happened?
Furthermore it is noted that the local authority’s natural environment consultation comments
have not been published adding to the uncertainty over how well the site is understood.
We understand that at least some of the site is known to have carbon-rich soils which should
be protected from most types of development under policy 5. Whilst the applicant highlights
the ancient woodland adjacent to the site, we note that NPF4 policy 6 states that there is a
lack of policy support for development which will result in adverse impact on the ecological
condition of ancient woodland.

Climate and sustainability

NPF4 has several policies which promote local living, the direction of development to places
with existing infrastructure and services and sustainable transport – for example policies 9, 13
15, 18, 27 – which this proposal appears to be in conflict with. For instance, it seems highly
likely that this development would create a substantial increase in private car use, both for
commuting and for accessing services (eg one of the consultees indicates that healthcare
provision would be in the city) – see NPF4 policy 13d.

Flooding and hydrology

In addition to the concerns we noted above about the impact on hydrology and the unknown impact on
the adjacent wet woodland systems, we are aware of local concerns over flooding being exacerbated
by the proposed development. We see that these concerns have been acknowledged and highlighted
by the local authority’s flood prevention team’s own response.

The above concerns taken together lead us to feel that the application is not in line with the
development plan and should be rejected.

Yours sincerely,

Kat Jones, Director

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