Aylesbury Vale Area

VALP Proposed Submission

Search Representations

Results for AOTRA search

New search New search

Object

VALP Proposed Submission

1.22

Representation ID: 392

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Extent of Primary Shopping Area should be increased to reflect the situation at the end of plan period.

Full text:

Apart from a small extension around George Street, which AOTRA sought, the area defined as the Primary Shopping Area (PSA) remains the same as that defined as the Central Shopping Area in the adopted 2004 Aylesbury Vale District Local Plan. The definition reflects the status quo pre-2004 and, surprisingly, does not include the proposed major shopping development on the Waterside North site. We suggest that the PSA should show the situation at the end of the Plan period rather than as it existed pre-2004. It should therefore include the Waterside North development site. It should also include the site of the Upper Hundreds car park if this can justifiably be proposed for development for shopping (but see comments on D7 in separate objection).

Object

VALP Proposed Submission

D9 Housing in Aylesbury town centre

Representation ID: 395

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Need to protect subdivision of family homes, which are a valuable but scarce asset which adds to the community mix.

Full text:

Over the recent years the number of homes within the Inner Relief Road has more than doubled (from about 300 to 687 in November 2017). The total is likely to reach 900 in the next 2 or 3 years as existing schemes are completed and planning permissions are implemented. In effect office employment in the Town Centre has declined significantly, whilst the resident population has grown by occupying the redundant office space, with more in the pipeline. These new homes are most welcome but the majority have been 1 or 2 bedroom flats. As a result the remaining family homes with gardens, mainly in the Conservation Area, are a very valuable but scarce asset which adds to the community mix. It is important that the limited number of such properties are protected from possible subdivision.

Object

VALP Proposed Submission

1.21

Representation ID: 435

Received: 11/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Redefine Town Centre boundary to comply with NPPF.

Full text:

1 Paragraph 23 of the National Planning Policy Framework requires local planning authorities, in drawing up Local Plans, to define the extent of town centres and primary shopping areas.
2 Annex A of NPPF defines a Town Centre (TC) as :-
"Area defined in the local authority's proposal map, including the primary shopping area and areas predominantly occupied by main town centre uses within or adjacent to the primary shopping area".
3 It defines a Primary Shopping Area (PSA) as:-
"Defined area where retail development is concentrated, generally comprising the primary and those secondary frontage which are adjoining and closely related to the primary shopping frontage",
and main town centre uses as :-
"Retail development (including warehouse clubs and factory outlet centres); leisure, entertainment facilities, the more intensive sport and recreation uses (including cinemas, bars and pubs, night-clubs, casinos, health and fitness centres, indoor bowling centres and bingo halls): offices; and arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities)".
4 It follows from the above that the starting point for defining the TC is the PSA (as defined under 1 above) .
5 To the PSA should be added other adjacent non-retail town centre uses to determine the extent of the TC. For this purpose we have, perhaps generously, interpreted "adjacent" as located within 100 metres of the edge of the PSA which we have proposed under a separate objection. These uses are listed in the attached appendix. Only three of them are located outside the Inner Ring Road. These are the Waterside theatre, the Friars Square (Station Way) multi story car park, and a restaurant in New Street.
6 The area within the Inner Relief Road is widely used to equate to the Town Centre. For example it forms the basis for applying the 'saturation policy' under licensing legislation and comprises the Aylesbury Town 20 mph speed zone. Although a large part of the western half of the area enclosed by the Inner Relief Road is predominantly residential in character, a character which has been reinforced in recent years by new build and changes of use, it does contain a few main town centre uses additional to those listed in the Appendix. It also forms part of the Old Town Conservation Area in common with part of the PSA.
7 It is our view, therefore, that the area bounded by the Inner Relief Road, together with the Waterside Theatre, adjoining open space, and the Friars Square multi-storey car park, forms a well-defined and widely recognised Town Centre in accordance with NPPF. It is however fairly tightly constrained and may not provide enough space for the location of all the new non-retail town centre uses which may need to be accommodated in the period covered by the Vale of Aylesbury Plan. Nevertheless, it is our view that it should be defined as the Town Centre and any demand for town centre uses which cannot be accommodated there should be dealt with in accordance with policy E5.
8 The submitted draft Plan defines a much larger area as the TC. We think that this is unsound for the following reasons:
a). it does not accord with the NPPF, as explained above:
b). it has not been justified by a demonstrated need;
c) it appears to have been drawn so as to include a number of edge-of-centre sites and some town Centre use sites which cannot in any way be described as adjacent to the PSA (e.g. Aquavale Pool complex in Park Street, the Magistrates (soon to be Crown) Courts in Walton Green and Aylesbury College in Oxford Road.
d) It would seem that many edge-of-centre shops would be reclassified as TC shops. In effect they would confusingly become edge-of-centre shops (in terms of being outside the PSA) within the TC.
e) Under Policy D8 applications to build shops anywhere within the extensive TC would all be acceptable in principle. This would undermine the concept of giving priority to sites within the PSA and prejudice the proposed redevelopment covered by Policy D7.
f) Shops which currently occupy out-of-centre locations (e.g. Tesco, Tring Road) would become edge-of-centre, and the scope for other, new edge-of-centre locations would be greatly increased, with further consequences for maintaining the status of the PSA.
9 The Aylesbury Vale Retail Study 2015 (paragraph 4.7) describes the Aylesbury Vale Shopping Park in Cambridge Close as being located "in close proximity to the town centre". It also describes (paragraph 4.10) well-used supermarkets at the edge of the town centre. These supermarkets are Morrisons in Station Way and Waitrose at Exchange Street. Both of them are further described as being "in close proximity to the town centre".
10 Paragraph 4.11 of the Study describes the Lidl supermarket at Aylesbury Shopping Park as being "within walking distance of the town centre although not technically part of the town centre as per the NPPF definition of "in-centre". The Aldi store in Cambridge Street is also described as being "a short walk from the town centre".

It is clear that the consultants who compiled the Retail Study agreed that all of the above locations were not within the town centre but were edge-of-centre sites.

APPENDIX

Main Town Centre Uses (other than retail) outside, but within 100 metres of the Primary Shopping Area (as proposed by AOTRA)
Offices in :-
Church Street (Town Hall and others)
Exchange Street (Ideal House ground floor)
Granville Street (1 converted house)
High Street (former AVDC offices)
Pebble Lane (CAB etc.)
Temple Square (various)
Walton Street (BCC)
` Restaurants in New Street and Walton Street (Greek Taverna)
Pubs/bars in Market Square (Bell), Walton Street (White Swan) and Exchange Street (White Hart)
Courts, etc. in Market Square
Museum in Church Street
Cinema etc. in Exchange Street
Public Car Parks at Coopers Yard, Upper Hundreds Way and Station Way (Friars Square)
Theatre in Exchange Street.

Object

VALP Proposed Submission

D7 Town centre redevelopment

Representation ID: 436

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The redevelopment proposals for middle High Street, the Wilko store, the adjoining fitness gym and Hampden House are unjustified and should be removed. The Post Office sorting office redevelopment allocation is premature and should be changed to a reserve site. References to Primary Frontages and the retention of trees in the Exchange Street car park redevelopment should be added.
Possible redevelopment for mixed uses, based principally on retail, should be considered for both the Hale Street/Railway Street area and for the area between New Street and Buckingham Street (Sloane House, ex-Govt. offices and Sainsbury's car park)

Full text:

1. The first paragraph of Policy D7 deals with the proposed redevelopment site stretching from Exchange Street car park to the Royal Mail sorting office. This area in fact consists of four parts: (a) the Exchange Street car park (also known as Waterside North), (b) the middle High Street,(c) the area between High Street and Upper Hundreds Way and (d) the Royal Mail sorting office.
2. The Waterside North site has been allocated for shopping development for nearly 20 years. Several schemes have come and gone and planning applications have been heralded but not materialised, apart from the block of flats over restaurants currently under construction on part of the site (Phase 1). In the light of the vacant BHS shop in Friars Square, and the announced intention of House of Fraser not to renew the lease after 2018 of their premises, also in Friars Square, it seems that early progress on Phase 2 of the development is unlikely. However, AOTRA agrees that this site should be developed as the next stage in the expansion of Aylesbury's shopping core, but Policy D7 should make it clear that the main frontages here should be Primary Frontages, and that the chestnut trees adjoining Exchange Street should be retained.
3. Middle High Street currently functions well as a secondary shopping area. Whilst some redevelopment of its south side to link with the Waterside North site is essential, its comprehensive redevelopment, even if necessary, is not urgent. In any event it is likely to prove difficult because of the multiplicity of ownerships and the threat of redevelopment is likely to deter owners from making their own investments in improvements, leading to a downward spiral. Earlier attempts to incorporate the Roman Catholic church into the Waterside North site met with strong opposition from the congregation. The development of both sides of middle High Street was considered in HELAA (Reference AYL061 and AYL062). This concluded:-
AYL061 "Unsuitable- Entire site falls within Flood Zone 2/3. The site has very limited scope for a mixed use development although there is no indication the site is currently available for development. The site also has potential access issues to address.
AYL062 "Unsuitable - Site has potential to introduce residential upper layers through conversion (not demolition of 19th Century buildings) of upper units provided that it does not prejudice the operation of the retail units. Site has planning permission (10/01928/APP) for conversion of first floor flat into two flats with additional accommodation in roof space but is below the HELAA threshold. There is no indication the site is being promoted together and is available as a single development site. If there were interest in a comprehensive development as a single site retaining ground floor retail then a proposal could be suitable in principle."
We therefore suggest that middle High Street should be deleted from the redevelopment proposals in policy D7, apart from essential links to the Waterside North development.
4. Assuming that priority in providing new shopping is given to the Waterside North site then further redevelopment will not be required until late in the Plan period. The Hale Street/Railway street area would undoubtedly be the best location for additional shops and other town centre uses, if required. However, the Plan proposes that Hampden House should be converted to flats (upper floors) (Policy D-ATL063) and redeveloped. Clearly this is not possible and so we suggest that the site of Hampden House should be removed from the redevelopment area but retained as a housing allocation (conversion).
5. We see no current case for redeveloping the modern building occupied by Wilko, which appears to be well-used. The Upper Hundreds car park is unlikely to be needed for redevelopment until very late in the Plan period. It is owned by AVDC and can continue to be used for parking until required for other uses. If and when the Royal Mail sorting office site becomes vacant it should be acquired by AVDC for use in the long term as a possible overflow to accommodate town centre uses which cannot be located within the Inner Relief Road. In the mean time it could be used as a surface car park. Whilst residential use may eventually be appropriate on upper floors of any redevelopment here, we suggest it is premature to allocate this site for housing at this stage (Policy D AYL052).

6. The committed development site AYL056 in Cambridge Street/New Street consists of the Churchill Homes site currently under construction, the long empty office blocks at Sloane House and the former |Government Offices, both of which have a permission for conversion to flats which has not yet been implemented, and the Sainsbury's car park. In our view this site (excluding the Churchill development) could be used for a mixed-use redevelopment including retail, parking (beneath or above the shops) and possibly some residential. This would entail the demolition, rather than the conversion, of the empty and semi-derelict office blocks but could be linked very effectively with the Primary Shopping Area via Buckingham Street (and Sainsbury's) and Cambridge Street (with it's entrance to M&S) to form a shopping circuit. Indeed this site could become part of the PSA itself. We think this would be a more practical proposition then redeveloping Wilko, the adjoining fitness gym and Upper Hundreds car park, would be better located in relation to the PSA than the PO sorting office and could also be delivered earlier. It may well be that in the long run all of these sites will be needed to meet Aylesbury's shopping needs.

Object

VALP Proposed Submission

D7 Town centre redevelopment

Representation ID: 437

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The proposed Transport Hub is not justified by the evidence, would make the town centre shops less accessible to bus users, would be difficult to achieve and would require the resiting (to an unspecified site) of Morrisons supermarket.

Full text:

Proposed Transport Hub
1 The only justification given for this proposal is "as part of the overall vision for the town and to ensure the town remains accessible". Whilst the existing bus station needs improvement and a co-location with the railway station would facilitate bus/rail interchange, this would in our view be at the expense of making the primary shopping area and other town centre locations less accessible to bus users, despite the promise of connectivity improvements to the rest of the town. What proportion of bus users begin or continue their journey by rail as opposed to using buses to access the town centre?
2 The 2016 Aylesbury Transport Strategy summary (page 13) says:-
"Upgrade the existing bus station in Aylesbury town - Increase capacity and possible relocation or expansion to a second site in the long term, possible locations need to be considered. Also review accessibility to current site"
and also says that the upgrade is to be carried out in the medium term (2020 - 2025).
The main Strategy document itself (page 86) says:-
"Upgrade the existing bus station in Aylesbury town - It aims to increase the number of bus passengers by increasing the capacity, comfort and accessibility of Aylesbury bus station. The accessibility improvements would create a proper interchange with the railway station (Aylesbury), and improve links with the cycle and the pedestrian networks. There is a longer term ambition to extend or relocate the bus station, and alternative formats such as a series of mini bus hubs around the town centre could also be considered. Providing that any new provision meets the current and future needs of passengers and bus operators. This should be a key driver of a future public transport strategy."
No evidence is cited in the Local Plan to change this. However the Local Plan proposes a major redevelopment (the Transport Hub) to include, inter alia, a new bus station co-located with the railway station, involving the relocation of Morrisons supermarket, and the possible re-routing of Friarage Road. It is unclear whether this proposal also involves the redevelopment of the the Station Way (Friars Square) multi-storey car park and the station surface car park. No details are given as to where the supermarket will be re-located, nor is any given as to how the relocation of the bus station will meet "the current and future needs of passengers and bus operators" as required by the Transport Strategy quoted above.
3 Altogether, the proposed Transport Hub needs much more justification. Without it, it should be deleted from the Plan.

Object

VALP Proposed Submission

D8 Aylesbury town centre

Representation ID: 441

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Lack of policy which differentiates between shopping proposals within the PSA and elsewhere in the TC.

Full text:

This policy should be extended to include the gist of the second paragraph of Policy D7 and become the overall general policy for the town centre, ideally placed before policy D7.
Although the Plan contains a policy (E6) relating to Primary and secondary Frontage within the PSA, it does not contain a policy which differentiates between shopping proposals within the PSA and elsewhere in the TC. This does not accord with the NPPF which requires local plans to make clear which uses will be permitted in PSA's and TC's respectively. An appropriate policy should therefore be added to Policy D8. It should also include reference to pedestrian priority and the protection of the amenities of residents.

Object

VALP Proposed Submission

1.22

Representation ID: 442

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Committed development site AYL058 in Policies Map.
This site includes the Methodist Church, Coopers Yard car park and Elsinore House, all in Buckingham Street, and Cromwell House in New Street. As far as we are aware there are no commitments for the development of any of these, Development is committed only for Heron House. If it is proposed to convert any of these sites for housing they should be allocated for this purpose on the Policies Map.

Full text:

Committed development site AYL058 in Policies Map.
This site includes the Methodist Church, Coopers Yard car park and Elsinore House, all in Buckingham Street, and Cromwell House in New Street. As far as we are aware there are no commitments for the development of any of these, Development is committed only for Heron House. If it is proposed to convert any of these sites for housing they should be allocated for this purpose on the Policies Map.

Object

VALP Proposed Submission

T5 Vehicle Parking

Representation ID: 443

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Parking provision limitations within the Inner Relief Road according to Policy AY21 of the 2004 Local Plan are needed

Full text:

This policy should be amended to incorporate the gist of the first paragraph of Policy AY21 of the 2004 Local Plan (i.e. that within Aylesbury Inner Relief Road on-site parking provision for all new development proposals will be restricted to that required for the operational needs of the business or land use) and make it clear that the provision of public parking (both on and off-street) should give priority to the disabled, residents of homes within the Inner Relief Road and the customers of town centre uses. Employees of town centre uses should generally be encouraged to walk, cycle or use public transport for journeys to and from work whenever possible.

Object

VALP Proposed Submission

NE1 Protected sites

Representation ID: 446

Received: 12/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy NE1 gives protection to 'ancient' trees. 'Ancient' is not defined but the NPPF uses the term 'Veteran' trees, which it defines as a tree which, because of its great age, size or condition is of exceptional value for the wildlife, in the landscape, or culturally. The word 'ancient' should therefore be replaced with 'veteran' in Policy NE1.
Policy NE9 gives protection both to any 'trees' and 'veteran trees'. The reference to 'veteran trees' here is unnecessary duplication and so it should be deleted.

Full text:

Policy NE1 gives protection to 'ancient' trees. 'Ancient' is not defined but the NPPF uses the term 'Veteran' trees, which it defines as a tree which, because of its great age, size or condition is of exceptional value for the wildlife, in the landscape, or culturally. The word 'ancient' should therefore be replaced with 'veteran' in Policy NE1.
Policy NE9 gives protection both to any 'trees' and 'veteran trees'. The reference to 'veteran trees' here is unnecessary duplication and so it should be deleted.

Object

VALP Proposed Submission

D7 Town centre redevelopment

Representation ID: 448

Received: 11/12/2017

Respondent: AOTRA

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

We put forward a package of changes (set out in our separate, detailed representations) which would make the plan sound provided an early review of the Town Centre proposals is carried out.

Full text:

There is an urgent need for an adopted plan but the current proposals are unjustified or silent, and therefore unsound, in respect of leisure and entertainment, parking in the town centre and bus service improvements.
Paragraph 4.229 briefly discusses leisure and entertainment but does not lead to any proposals. Paragraph 4.222 promises a parking strategy which will emerge 'shortly'. The Transport Hub proposal is lacking in justification.
To overcome these problems we have put forward in separate detailed representations a cohesive package of interim proposals for the Town Centre which include:-
a) A revised and expanded Primary Shopping Area;
b) A revised Town Centre boundary;
c) A redevelopment site for retail and other uses at Exchange Street car park;
d) Provision for further redevelopment for retail and other uses on undefined sites in the Hale Street/Railway Street and Cambridge Place/New Street/Cambridge Street areas;
e) A reserve, mixed use redevelopment site on the Post Office sorting office land;
and meanwhile
f) Removal from the plan of the Transport Hub proposal and the redevelopment allocations covering middle High Street and the land to the North.
We believe that the plan would become sound if it were to be amended to incorporate these changes, provided that an early review of the Town Centre is carried out taking account of further studies on leisure and entertainment, parking and bus service requirements and various practicability issues.

If you are having trouble using the system, please try our help guide.