The Friends of St. Fittick’s Park Group feels compelled to voice its concerns about behind-the-scenes activities related to the proposed Energy Transition Zone which suggest that those pushing the proposal assume that land acquisition in Torry is a done deal. We believe that the democratic process is being undermined and that business interests and pressures are driving local authority decisions; in fact, that the tail is wagging the dog.
Our organisation was formed to protect the Park against future attempts to incorporate it into the ETZ, thereby losing its social and environmental value to industrial use. However, we recognise that this is the early stage of what could be a protracted process, with a likely referral to a Scottish Government Reporter for adjudication, and then, should that side in favour of the zoning changes, a lengthy planning application process requiring to be negotiated by potential developers.
Given that no specific decisions have been made about the necessary zoning changes, nor subsequent planning applications in place, it therefore comes as a surprise to us that business interests in the city are using language, and creating structures and jobs, on the basis that the ETZ as proposed will proceed. The specific details of the actions we find disturbing are chronicled below but we summarise our concerns by asking the following questions:
1 Why has a non-for-profit company (Energy Transition Zone Limited, SC697431) been incorporated (on 30 April, 2021) to facilitate an Implementation Plan for the ETZ?
2. What drives the confidence (for example the general presumption in Press Releases that the developments in St Fittick’s Park will go ahead; that the project is ‘shovel-ready’) of this newly-formed company to fund the position of a Project Coordinator to assist the development and management of the Plan?
3. Which person, company or organisation is funding this post?
4. It appears Opportunity North-East’s Energy Board has been disbanded. Does this company replace it?
5. Why has there not been any announcement about the Implementation Plan, the formation of the new company or the naming of its directors? (see below)?
6. Why are individuals connected to ONE claiming that initiatives are ‘going through the planning process’ when they are not? (see below)
We do not expect that there should be consultation at every stage of a project’s development but it is extraordinary that plans for such a major change to St Fittick’s Park (the disappearance of most of what is the last accessible green space for 10,000 people in Torry), should continue to proceed without any public consultation, information sharing and largely in secret. This is completely contrary to the conclusions in the recently released Scottish Government’s Commission for a Just Transition’s report that communities should be involved at all stages in any project that affects them.
Timeline of Events:
June 2019 Sir Ian Wood first raises the concept of the Zone.
March 2rd 2020 The rezoning of St Fittick’s Park and Doonies Farm from greenspace/greenbelt to opportunity sites in the Proposed Local Development Plan for industrial development is included as part of the proposed Zone agreed by the full Council.
February 3rd 2021 The STAG2 consultation report (Jan 2021) to the City Growth and Resources Committee on 3rdFebruary cites the difficulties the engineers have had in accommodating the late inclusion of the ETZ sites at St Fittick’s Park and Doonies into the assessment because of the lack of any definitive details of proposals. They had to resort to using the Siemens Green Port in Hull which carries out activities similar to those that might be taking place in these two sites
March 3rd 2021 Graham Lennox of Doonies Farm questions the effect lack of any information about ETZ activities there is having on his plans for the future.
April 23 rd 2021 Sir Ian Wood describes the ETZ as ‘shovel-ready’ to a business breakfast of 240 industry leaders without any zoning changes, approved plans or specific company commitments.
June 2021 Despite lack of information in the public domain and to key stakeholders such as Graham Lennox, an Implementation Plan is now far enough advanced for Energy Transition Zone Limited, a not-for-profit company limited by guarantee, to have been incorporated on 30thApril 2021. The company immediately advertised for a Project Manager to assist the CEO and senior staff with the development and management of the Implementation Plan by co-ordinating and reporting projects. Applications closed on 3rd June 2021.
It appears that ONE’s Energy Board has been disbanded and this new company has replaced it. Companies House register shows that three of the directors are board members of ONE, two have held prominent roles with Scottish Enterprise, one is an ex-deputy chief executive of ONE (now CEO of ETZ Ltd), one is the ex-chairman of ONE’s defunct Energy Board, one is Finance Director of Aberdeen Harbour Board.
Whatever the exact timing and details of management and personnel structures, there is nothing in the public domain announcing these changes – we found out about ETZ when investigating the registered interests of members of Aberdeen Harbour Board. Neither is anything known about the Implementation Plan. The only project that has come to light in public is a Hydrogen Campus next to the Harbour which Martin McCormick, ONE’s Energy Transition Director described in his contribution to the public question and answer session following the official launch of the University’s Centre for Energy Transition on 31stMay 2021. The campus will research and test uses for green hydrogen produced by electrolysis of water by energy produced by wind turbines in the Kincardine Field and piped ashore at the South Harbour or just south of it in the Dolphyn project. One worrying aspect of this announcement was that the project was described as “going through the planning process” when what is going through the planning process is the rezoning of the St Fittick’s Park from green space to Opportunity Site 56 in the Proposed Local Development Plan for industrial development as a site in the ETZ. Nothing more. In fact, the Dolphyn project itself is still at the proof-of-concept stage with the pipeline coming ashore 1 – 3 km south of Aberdeen. In fact, there are now serious doubts about the viability of these hydrogen feasibility studies as well as that of other green infrastructure at the new harbour.
It is perfectly legitimate for business interests to work closely with local authorities to develop economic opportunities for the benefit of the community. In this case though, environmental considerations are stated to be at the fore of the proposed ETZ. The process should be about more than the specific interests of business. Collectively the city – Aberdeen City Council, the commercial sector, and the community at large – is committing itself to its part in combatting global warming by striving towards a carbon-neutral economy and lifestyle. To achieve that ambition effectively requires collaboration, consultation and complete openness. What we have instead are opaque dealings, back-room agreements and hidden agendas.
We fear that the stated green aspirations of creating an Energy Transition Zone are a cloak which disguises naked commercial interests that may be of benefit to some but, perversely, would be to the detriment of the local environmental and at the expense of the local community.
A more detailed timeline of the evolution of this proposal can be studied here:
Friends of the Earth Scotland have hightlighted the threat to St. Fittick's Park: https://foe.scot/saint-fitticks/
In detailing the background to the proposal and its implications, author Kate Whitaker highlights the importance of a 'just transition' to a carbon-free economy, not just in Aberdeen but across Scotland, pointing out that 'the phrase emerged from the international labour movement to describe a societal shift away from fossil fuels, led by the workers and communities that are most impacted, to provide them with secure livelihoods and thriving communities. The term ‘just transition’ is increasingly used by the Scottish Government and others to describe their plans, but the limited transition we are currently seeing is far from just'.
The proposal to industrialise St. Fittick's Park and Doonies Farm could not be further removed from the concept of a just transition.' The article observes that 'the ‘transition’ plans being imposed on them [the local residents] are far from just, or even green. They show a blatant disregard and lack of engagement with the communities that should be at the heart of the transition'.
The Friends of St. Fittick's Park welcome the support of Friends of the Earth Scotland. Ishbel Shand of the Friends says 'This isn’t actually about an energy transition zone – that’s just a story that’s
more palatable to the general public. Their ambition is colossal and linking it to energy transition is muddying the waters'.
As the concept of Just Transition gains traction, and as more people in Aberdeen and across Scotland appreciate the utter environmental idiocy of this proposal, the greater the chance we have in preventing this become a reality. and saving this invaluable green space for the health of the local community, as a haven for wildlife and as a contributor to managing climate change.
See: https://saintfittickstorry.com/useful-links for more on Just Transition
On 22 Feb the civil contractor Nicol of Skene issued a press release. Simultaneously, Aberdeen Harbour Board added an item to the News section on its website. Both announced that a contract had been awarded by the Board to Nicol to lay 3 km of new water mains connecting Aberdeen South Harbour to the mains network and extending to Torry Quay in the existing harbour. [http://www.nicolofskene.co.uk/news/aberdeen-harbour-expansion-project/] [http://www.aberdeen-harbour.co.uk/news/contractor-awarded-for-ahep-water-supply-work/]
Details of the project released by both parties stated that the mains water link would run from an existing main in Wellington Road along Girdleness Road, then through St. Fittick’s Park to the new harbour before heading north along Greyhope Road, then Sinclair Road before terminating at Torry Quay.
This seemed relatively straightforward but trying to follow the stated route on a map raised some questions for the Friends of St Fittick’s group. What exactly was meant by the phrase ‘through St. Fittick’s’? If there is to be major works in the park, has any environmental impact assessment been undertaken? (The stated time period for the project – April to November – includes the nesting period for the many bird species in the wetland and wooded areas of the park.) Given the likely proximity to historic St. Fittick’s Church, had consideration been given to potential archaeological disturbance from digging activity?
Some of these and other questions are speculative but with access to precise details of the planned route of the water main, it would be possible to assess the potential impact. Given that a contract has been agreed between the Harbour Board and Nicol of Skene, it was assumed that a detailed scope of the work, including the route, existed. It seemed a simple matter therefore for us to submit a polite request for a map of the proposed route.
This is where the story gets complicated. Requests for additional information from the two main protagonists, HB and Skene, were rebuffed. Despite their enthusiasm about publicising their agreed contract, they both passed the buck to the City Council for further information. Nicol of Skene, in response to a specific request to supply a map of the proposed route, responded in part, ‘Our works shall be carried out in co-operation with Aberdeen City Council, who will carry out the relevant advertisements and signage, notifying of all dates and restrictions.’ Aberdeen Harbour Board responded to the same request in almost identical terms.
Of course, passing the baton to ACC to provide more specific details would be fine if it gave results. We had in any case, at the same time as asking questions of the HB and Nicol, raised the issue with our local councillors. Shortly after the replies pointing to ACC as a source of information were received, one councillor contacted us to point out that they had been informed, in response to an enquiry to officials, that this is ‘totally a Harbour Board project and has nothing to do with Aberdeen City Council’. This seems strange, not least because the Council owns St. Fittick’s Park and might be expected to have an interest if someone was proposing to dig up part of it, and then of course there is a requirement to apply for Road Opening Permit from the local authority if there is a need dig up a road or pavement. That doesn’t sound like it has nothing to do with Aberdeen City Council.
Meanwhile, exactly one month before works are scheduled to begin on this project, the local community has been kept completely in the dark. There has been no local consultation or information dissemination; those of us with the interests of St. Fittick’s Park at heart find out from Construction News that diggers will be on site soon; nobody involved will answer simple questions about matters that must have already been decided; Aberdeen Harbour Board seems to yet gain have forgotten that the local community is a stakeholder in a Trust Port and should be involved and informed of all developments affecting them.
However, after a month of chasing and asking questions we did finally source the map we needed – by searching the Public Contracts Scotland website and locating the Contract Notice issued by the Harbour Board way back in 2019. Why did neither the Harbour Board nor Nicol of Skene point us to this site which is in the public domain when we asked for a map? Are they trying to avoid scrutiny of the project in advance of its commencement? [https://www.publiccontractsscotland.gov.uk/search/show/search_view.aspx?ID=JUN358702]
In response to questioning, a spokesperson for the Harbour Board said that they ‘are not avoiding scrutiny for the route of the water main, nor have we deliberately kept a map from you or other members of the public. The map you have sourced from PCS was created two years ago, and as I’m sure you’ll understand, the final routes for these types of works are often subject to change.
We are still undergoing final arrangements with Aberdeen City Council for the installation of the water main, having carried out several walkabouts and site visits to various places along the 3km route in recent weeks. As I’m sure you are aware, permits and planning notices can take several weeks to be approved, so it is prudent for us not to release a final route until it is completely set in stone.’
It seems strange that just weeks before this work is due to start and with a signed £2.5 million contract, final arrangements about the route are still be made. We wonder how close to the commencement of works before a final route is released and what arrangements are in place to have the route reviewed by NatureScot to ensure that nesting birds will not be disturbed.
Friends of St. Fittick’s Park have been analysing the responses to the recent consultation on the proposed Local Development Plan. Of the 1195 submissions to the LDP as a whole, 199 individuals and 4 statutory bodies [see News 9 February] objected either to the potential industrialisation of St. Fittick’s Park (127 objections), or of Doonies Farm (143). Seventy-one people objected to both.
Some of the objections were just a single line; others were densely-argued and evidenced denunciations of the proposal to include these two areas - OP 56 and OP 61 – in the proposed Energy Transition Zone. But whether brief comments or extended arguments, what comes across when reading the submissions is the strength of feeling which drives the determination to have a say and object to proposals that people found barely credible in their illogicality.
The strength of feeling was shared across the responses but the specific reasons were many and various. The majority of respondents (88%) cited the obvious loss of a green space amenity (176 mentions) but many amplified their concern to express specific concerns: loss of wildlife biodiversity (34%); importance of preserving greenspace for human health and well being (32%); lost opportunities for the younger and future generations denied healthy play and outdoor educational facilities (31%); the perceived lack of consultation (23%); the belief that there are ample brownfield sites available locally for an ETZ; the feeling that ‘enough is enough’ as far as industrialisation of the area is concerned; general dissatisfaction at the process of local authority decision-making, which is felt to be unfair against Torry and its residents. There were no submissions in favour of the proposed changes detailed in the LDP.
To give a flavour of the passion expressed in the submissions, here are selected extracts:
On Loss of Green Space:
“These are some of the last green spaces the Torry Community has access too”
“This is the only green space left in torry and is a well used area by pet walkers and children playng”
“All of this life exists despite the industrial contamination, and as the last green space in Torry – there is simply nowhere left that can replace such an ecologically important area within the city”
“for a council in its wisdom to steal and industrialise one of Torry’s little amount of green spaces must be seen only as an attack against an already deprived people of this area”
“The Torry community has limited areas of green space for enjoyment of wildlife, nature, fresh air and exercise”
“As a lifetime Torry resident I am disgusted that the only green space available to the area is now been earmarked to be built on”
“St Fitticks Community Park is the last accessible green space available to residents of Torry”
“I think it is pretty shocking that you are planning to get rid of all green space available to residents in Torry”;
“This the only park in Torry and the only green space”
“Within the plan is the proposed re-zoning of the last real area of public open space in Torry”
“DO NOT turn Torry's remaining green space into an industrial park”
“What will happen to the plethora of wildlife that call this green space home?”
“lot wildlife live in park and the council want to destroy it”
“Wildlife in the area has been pressured too much as it is”
“This will be severely detrimental to the people and wildlife in our lovely area of Torry”
“This will lead to the culling of all our lovely wildlife and clearing of our entire natural habitat”
“Money will never bring back the wildlife we have already lost”
“The area has a lot of history and wildlife and all of this will be destroyed”
“Development of the site would result in a significant loss and fragmentation of green space, habitat and wildlife”
“It’s beyond despicable that this council wants to destroy our precious wildlife in favour of an industry that has had its day. Once you destroy a native species habitat it’s gone forever – industry can regenerate itself anywhere it has a mind to……..wildlife only dies once!”
“There is no mitigation possible for the habitat and biodiversity losses site development would incur”
“I cannot see any way that such a zoning can take place and not have a negative impact on the greenspace, biodiversity and recreation value of the site”
“In the midst of a global biodiversity crisis, as recognised by the Scottish Government, the destruction of such a biodiverse area seems particularly short sighted”
On Human Health and Well-Being
“We need to retain these local recreational open spaces for the physical and mental health and wellbeing of people living in the confines of the city and particularly for the communities close to OP56”
“This will result in negatively impacting particularly on mental health and wellbeing”
“Bit of an oxymoron to say that our health and wellbeing are a priority then build or propose to build industries that do and will harm our health and wellbeing”
“There is growing evidence of the importance of our green spaces for both physical and mental health and wellbeing and this has been shown to be vital during the pandemic”
“The negative impact on this community would be enormous in social, health and mental health terms, given the various ugly, smelly and unsightly ventures which have already located in the margins of this area”
“I know from personal experience that St. Fitticks Park has supported my mental health, and physical health during this pandemic”
“By building at St Fitticks and Doonies you are making Torry an industrial area rather than residential and this will affect people's mental health and their right to exercise”.
On Intergenerational Equality
“I object to anything being built on this land due to there being no other suitable green areas around Torry for people to exercise and kids to play in”
“why should you deprive kids of the chance to go there?”
“think of the kids and wildlife”
“Our children and future generations are being prevented from having access to the same experiences that we had access to as children and it is not fair”
“Money will never bring back the wildlife we have already lost, nor will it give our children a open healthy space to play and learn in”
“Doonie’s Farm is a unique asset to Aberdeen, both in terms of its conservation work they do and the opportunity they afford to the local children. It was a key part of my childhood and now my son’s childhood and deserves to be protected”
“you are depriving the children the chance to see farm animals up close”
“It is vital therefore that the voice of today’s children have been heard and reflected in this future spatial plan. Does this apply to the children of Torry?”
“Taking away this land from pensioners, the disabled, children and families who do not have the luxury of having their own garden is shockingly heartless”.
On Lack of Consultation
“The lack of transparency about this consultation makes this even worse. I have spoken to numerous residents during my daily exercise at St Fitticks Community Park and, while they know about the planned rezoning, none of them knew about the consultation.”
“The consultation for these plans is currently live on ACC’s website but the link is small and at the bottom of the main page. It is not obvious that there is a consultation ongoing for this development plan and there has been limited coverage in the news regarding the proposals.
“In regard to St Fitticks Park, I have not seen any information at the location, raising awareness of the consultation, or signposting people to further information about how local people can get involved and share their views, in fact it’s almost as if the local authority don’t want to facilitate effective communication and engagement around this work”
“The people of the area were robbed of a chance for meaningful consultation by this grab for St Fitticks coming now”
“Understandably because of Covid 19 there are difficulties with the consultation process for the new Energy Zone. However this website is user unfriendly and difficult to navigate With libraries closed a plan with such consequences for the south of the city should be more widely available. There are also individuals in the community with no internet access”
“There has been a failure to consult with the relevant communities and stakeholders, and a failure to follow processes”
“The wider population has been significantly disadvantaged in knowing about and responding to the Development Plan on-line consultation”
“I strongly object that this.... online only... consultation has excluded many of our friends who are not online and cannot register their objections to some of the proposals regarding an Energy Transition Zone”.
On Environmental Injustice
“I want the lasting impact of the Scottish Parliament to be fewer opportunity gaps between those with the most and those who have the least. But I am also clear that this gap between the haves and the have-nots is not just an economic issue. For quality of life, closing the gap demands environmental justice too”
“All the rubbish is dumped here”
“Firstly I grew up with the smell from the fish meal factory and then we have to put up with the smell from the Sewage plant which believe me is disgusting some days, we are then being given an incinerator to furthermore pollute our air, our beloved Bay of Nigg is taken away from us to build an unnecessary harbour that has been disastrous from the start and now we are being told we are loosing our only green space to an energy transition zone. I am not surprised that nobody wants to live in Torry why would you with all this in your doorstep. It is extremely unfair on the residents”
“We have already suffered from the installation of the sewage plant (the smell is atrocious during the warmer months), the harbour expansion (removal of yet another area heavily used by local residents), and the planned incinerator (being built within stones throw of a primary school no less). It seems like the council couldn't care less about the residents of Torry, and we have come to expect nothing less from the very body that is meant to be looking out for us. I am not alone in feeling this way, this has been the general consensus of everyone I have spoken to in Torry, we are fed up of being treated as if we don't matter”
“The council don't seem to care about Torry at all. In the last few years we had the stinky sewage plant, we had to put up with the stink from that place for years, and still do. Now we have an incinerator being built close to a school, the pollution from that won't help, the new harbour has been an absolute disaster”
“We, the residents of Torry have been bulldozed far too many times, the sewage works fiasco, the incinerator, Victoria Road School and the new harbour are all projects the people of Torry fought against”
“I also feel Torry has been picked on yet again as one of the most deprived areas in Aberdeen and also as one of the areas where there are little or no residents who have the wherewithal to presume they will be listened to as it's only Torry”
“Torry has been the sacrifice zone for Aberdeen for many years now being lumbered with everything no other part of the city wants and receiving no benefit in return. The proposed new incinerator, the new harbour – over 1 year behind in building, the sewage works, not to mention the demolition of Old Torry sacrificed for oil”
“This isn’t a good idea, with the advent of an incinerator so close to Torry, the sewage works and now the destruction of Torry’s green space. I can’t fathom what the good people of Torry have done to deserve so much ill will from the Council”
“ You treat the residents of Torry as second class citizens. There is no way you would have built this in say Cults”
“ Torry seems to get a rough deal with everything, the incinerator etc.”
“Do most of the councillors who voted have for the bizarre and depraved crazy destruction of a wonderful green space have any care for the people of Torry? No, and why, it is not on MY back door just like the Incinerator”
“You also state in the environmental report that ‘We have serious air quality problems in Aberdeen’ and that ‘We will avoid building where there are risks to health like areas of bad air quality or smell.’ developing this area is in direct conflict with those statements. It's unfair to relentlessly punish this area of Aberdeen with industrial destruction and pollution”.
“The Feasibility Study acknowledges that much of East Tullos is owned by the Common Good Fund and administered by ACC and is already zoned for industry. This would be the obvious location for an ETZ project”
“There is much land .....sites and buildings ....available in the Industrial Estates of East Tullos and Altens which are available for this project......without the need for the wholesale decimation of the green belt around Doonies Farm and St Fitticks Park areas”
“Perfectly suitable land at Altens is 1-2 miles away at best. East Tullos and Altens were identified when planning the harbour extension as ones where industrial activity associated with it would take place”
“There are already alternative sites in Altens or East Tullos Industrial Estate and considering low oil price there will be more unused industrial spaces”
“Altens and East Tullos industrial sites are by no means fully leased and there is room there for expansion and access to main roads and rail”.
The words of those objecting to the proposed industrialisation of the green belt clearly demonstrate the strength of feeling within the community. The comments themselves cover 82 pages, so it was only possible here to cover a fraction of what people have said. This is a great pity. The language used is frequently evocative. One respondent talks of “desecration”, another of “pillaging”. The plan is described as “being similar to the Highland Clearances”. Let us make it clear Aberdeen City Council that they must reconsider this ill-conceived and highly speculative bit of nonsense.
The submissions are publicly available at: https://integration.aberdeencity.gov.uk/service/Proposed_Plan_Responses___Search (hint: to display a list of all responses, click on SEARCH without entering any search terms)
Our view that using St Fittick’s Park as part of an Energy Transition Zone is completely inappropriate for a wide variety of reasons is shared by important organisations who were consulted on aspects of the Local Development Plan (2022).
The Scottish Environmental Protection Agency (SEPA), NatureScot (Scotland’s nature agency), Scottish Forestry and Historic Environment Scotland, have all made submissions which are critical of the ETZ proposal.
SEPA’s submission highlights the inadequacies of the assessment of the site’s suitability, saying that ‘the assessment and proposed mitigation currently provided in the Environmental Report is incomplete’ and expressing the opinion that ‘any development of this site would potentially have a direct impact on the water quality and the ecological status and therefore have significant adverse impacts on the water environment’. As the body which has responsibility for flood risk management, SEPA is particularly concerned that the proposal is lacking mitigation measures for the East Tullos Burn which runs through the site, and that without a more detailed Environmental Report the site assessment as detailed in the LDP is inadequate.
NatureScot are similarly unimpressed. In their submission they say that ‘the Environmental Report under-represents the importance of OP56 St Fittick’s Park (in terms its value to people, wildlife and flood management) and also under-represents the likelihood of adverse environmental effects’. They also point out the many benefits that the East Tullos Burn Project has delivered and how these have been ignored in the Environmental report.
Scottish Forestry points out that the environmental analysis does not even acknowledge that part of St. Fittick’s has been designated as woodland since they funded planting on an area of the park in 2010-12 and that any development proposal would need to be separately assessed by COWPR (Control of Woodland Removal Policy). .
Historic Environment Scotland, focusing on its responsibility to protect and manage historic sites and buildings, points to omissions in the Environmental Report which ignore the historic components of the site. Of particular concern is the lack of any consideration of the direct impact on physical structures, most notably St. Fittick’s Church, but also of indirect impacts of setting. These concerns extend beyond OP56 to other aspects of the Plan.
Although each of these consultees focus on their specific areas of concern, what their submissions have in common is that they all identify omissions and weaknesses in the LDP and its associated documentation. Although the language is polite, as befits comments coming from official organisations, they make it abundantly clear that they view the proposal as poorly articulated and seriously deficient in evidence that appropriate mitigation can be taken to protect the environment and the heritage of the park. Such a unanimous negative response to the proposals from Scottish Governments agencies surely sounds the death knell for an idea that should never have made it into print.
The full submissions from the consultees can be downloaded here: