Aylesbury Vale Area

VALP Proposed Submission

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Object

VALP Proposed Submission

1.14

Representation ID: 1104

Received: 14/12/2017

Respondent: Aviva Life & Pensions UK Limited

Agent: GL Hearn

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Paragraph 1.14 is supported in terms of new employment need being met by new
allocations to meet forecast need however Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs, specifically in Gatehouse Industrial Estate. This has been subject to incremental and piecemeal redevelopment, notably Brook Mews and Alton House. The land between these should be released for residential and mixed use. Retaining this as a key employment site is inconsistent with NPPF para 22. The councils evidence is out of date and should take account of residential developments.

Full text:

On behalf of our client, Aviva Life & Pensions UK Limited, please see attached representations duly made towards the Reg. 19 Aylesbury Vale Local Plan

Full text where it has been summarised:

Para 1.14

Paragraph 1.14 is supported in terms of the policy approach of new employment need being met by new allocations to meet forecast need. However, it is apparent that Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs.
The Council is failing to provied an effective planning policy framework by retaining areas of previous employment land at the Gatehouse Industrial Estate which are no longer suitable, viable or deliverable for
employment purposes. The Gatehouse Industrial Estate has already been subject to incremental and
piecemeal redevelopment for alternative land uses, notably for residential at Brook Mews, and residential
being brought forward at Alton House. The character and form of development at the Gatehouse Industrial
Estate has already chaged such that land between Alton House and Brook Mews should be released for
residential and mixed use development.
The Council's approach in retaining the Gatehouse Close Industrial Estate as a key employment site
is inconsistent with the NPPF paragraph 22 which seeks to prevent the long term retention of employment land where there is no reasonable prospect of the land being used for that purpose. In these circumstances Planning Auithorities should review the potential for allocation the land for alternative land uses, including for residential.
The Council's evidence base relating to the Gatehouse Industrial Estate is out-of-date and should be reviewed to take account of existing and permitted residential development locally.

Para 3.78-3.80

Paragraph 3.80 of the VALP emphasises the considerable difficulty of potential large scale allocations being
brought forward speedily to meet immediate and short term (5 year) housing land supply requirements. Whilst
large scale urban extensions or a new settlement would prove a strong solution to medium and longer term
housing delivery, it is clear that a step change is required to increase the short term supply and delivery.
Aviva remain concerned that existing employment sites, such as HELAA site ref. AYL078 - Land at
Gatehouse Close, Aylesbury, have not been adequately assessed to consider the potential for existing
employment land to be releasd in the shorter term to realise and deliver much needed new housing.
Specifically, further consideration must be given to the current and future difficulties associated with HELAA
site ref. AYL078 - Land at Gatehouse Close being successful or viable for employment purposes. HELAA
site AYL078 would be able to deliver approximately 300 dwellings, reducing the need for release of
greenfield land for a similar quantum of housing.

Table 9 and para 6.6:

Aviva object to the HELAA site ref. AYL078 forming part of the key employment site known as the Gatehouse
Industrial Area. Whilst HELAA site ref. AYL0788 is currently in partial use, the only realistic long term use of the
site is for residential development. There is very limited demand for the existing types of units on the site, and the
site's location and poor access for modern commercial vehicles means that the re-use or redevelopment
for employment is not viable. Although the site presently has some very short term tenants the only realistic long
term use of the site would be residential development.
In addition, it is submitted that paragraphs 6.5 and 6.6 are overly protective of employment land, paricularly of
employment land such as that at HELAA site AYL078 which is clearly suitable for alternative more appropriate
land uses. Paragraph 22 of the NPPF states that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no
reasonable prospect of a site being used for that purpose"...and..."land allocations should be regularly reviewed".
The NPPF goes on to say in the same paragraph that "where there is no reasonable prospect of a site being
used for the allocated employment use, applications for alternative uses of land or buildings should be treated on
their merits having regard to market signals and the relative need for different land uses to support sustainable
local communities".
The NPPF also state that: "To help achieve economic growth, local planning authorities should plan proactively
to meet the development needs of business and support an economy fit for the 21st century".
It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that
consists of residential and employment space. The strategic greenfield sites would allow for the employment sites
to be located in areas that are accessible and sustainable and allow the facilitation of the of the growth of the
Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been
located on the edge of settlements as they benefit from better connectivity.
Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is
likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that previously
allocated land for employment that was once 'out of town' (such as land at HELAA site ref. AYL 078 Gatehouse
Industrial Estate) will be situated in an urban hinterland due to settlement expansion, rendering the employment
sites surplus to modern day requirements.
In the case of HELAA site ref. AYL078 it is submitted by Aviva that there is very limited demand for the type of
units on the site, and the site's location and poor access for modern commercial vehicles, means that re-use or
redevelopment is not viable as a continuation of 'B' uses.
In conclusion, it is submitted that either the Gatehouse Industrial Estate should no longer be identified as a key
employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local
Plan proposals map as no longer forming part of the Gatehouse Industrial Estate as a key employment site.

S2 and table 1:

Policy S2 is supported in terms of identifying an approach to delivery of land for housing and employment growth
and development, including to meet some of the needs of adjoining highly constrained districts including
Wycombe and Chiltern/South Bucks Districts.
Nevertheless, the approach of releasing large greenfield sites for residential development to meet the needs of
Aylesbury and adjoining authorities is not justified, effective or consistent with National Policy where there is
significant previously developed land available that can deliver new homes at sustainable locations.
Aylesbury District is seeking to retain historic/ existing employment land for employment purposes where there is
no realistic or viable prospect of the land contributing towards employment development throughout the Plan
period.
Land at the Gatehouse Industrial Estate should be reviewed in light of current and permitted residential
developments at Brook Mews and Alton House and in light of the long term and persistent vacancies and
poor take up of employment land and premises.
Aylesbury Vale has not recently reviewed the ability for the Gatehouse Close Industrial Estate to contrbute
towards employment development, and it is submitted that in accordance with paragraph 22 of the NPPF land
east of the residential scheme at Alton House should be allocated for an alternative and more suitable land use
i.e. a logical and sustainable form of residential linking Alton House, with Brook Mews.

S7:

Poliy S7 is supported by Aviva. Policy S7 appropriately expects efficient and effective use of land and
encourages reuse of previously developed (brownfield) land in sustainable locations. Nevertheless, Policy S7
should be strengthened to confirm that Aylesbury Vale will encourage efficient and effective use of land, in
sustainable locations and subject to specific site considerations, ahead of release of greenfield or Green Belt
land.
Policy S7 should also be strengthened to set out how Aylesbury Vale intends to apply the emerging
requirements from the government for Council's to prepare brownfield land registers.
Paragraph 3.67 only makes reference to the emerging brownfield land register initiative. Aviva submit that
Aylesbury Vale should set out within paragrph 3.81 and policy S7 strong support for the principles of
brownfield land. Indeed, it is recommended that Aylesbury Vale should provide confirmation that a brownfield
land register will be prepared by the Council, to be informed by detailed and fresh assessment of suitable,
available and deliverable previosuly developed land, such as HELAA site ref. AYL078 - Land at Gatehouse
Close, Aylesbury.

Policy maps for Aylesbury:

Aviva object to the potential housing allocations VALP policy map inset for Aylesbury, as the map fails to identify
HELAA site ref. AYL078, land at Gatehouse Close as a potential housing allocation. HELAA site ref. AYL078
is located immediately adjacent to, and shares its eastern boundary with the now completed residential
development at Brook Mews, as well as its western boundary with the permitted residenital development at
Alton House. HELAA site ref. AYL078 also shares the same credentials as a highly sustainable location for
residential development, being within walking distance of Aylesbury town centre and railway station, as well as
the range and mix of commnity facilites and servies within and around the town centre.

Object

VALP Proposed Submission

3.78

Representation ID: 1644

Received: 14/12/2017

Respondent: Aviva Life & Pensions UK Limited

Agent: GL Hearn

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Para 3.78-3.80 emphasises the difficulty of large scale allocations coming forward speedily to meet short term housing requirements. Aviva remains concerned that AYL078 hasn't been adequately assessed for being released in the short term for housing. Further consideration must be given to current and future difficulties with it being viable for employment purposes. AYL078 would deliver approx 300 dwellings, reducing the need for greenfield land.

Full text:

On behalf of our client, Aviva Life & Pensions UK Limited, please see attached representations duly made towards the Reg. 19 Aylesbury Vale Local Plan

Full text where it has been summarised:

Para 1.14

Paragraph 1.14 is supported in terms of the policy approach of new employment need being met by new allocations to meet forecast need. However, it is apparent that Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs.
The Council is failing to provied an effective planning policy framework by retaining areas of previous employment land at the Gatehouse Industrial Estate which are no longer suitable, viable or deliverable for
employment purposes. The Gatehouse Industrial Estate has already been subject to incremental and
piecemeal redevelopment for alternative land uses, notably for residential at Brook Mews, and residential
being brought forward at Alton House. The character and form of development at the Gatehouse Industrial
Estate has already chaged such that land between Alton House and Brook Mews should be released for
residential and mixed use development.
The Council's approach in retaining the Gatehouse Close Industrial Estate as a key employment site
is inconsistent with the NPPF paragraph 22 which seeks to prevent the long term retention of employment land where there is no reasonable prospect of the land being used for that purpose. In these circumstances Planning Auithorities should review the potential for allocation the land for alternative land uses, including for residential.
The Council's evidence base relating to the Gatehouse Industrial Estate is out-of-date and should be reviewed to take account of existing and permitted residential development locally.

Para 3.78-3.80

Paragraph 3.80 of the VALP emphasises the considerable difficulty of potential large scale allocations being
brought forward speedily to meet immediate and short term (5 year) housing land supply requirements. Whilst
large scale urban extensions or a new settlement would prove a strong solution to medium and longer term
housing delivery, it is clear that a step change is required to increase the short term supply and delivery.
Aviva remain concerned that existing employment sites, such as HELAA site ref. AYL078 - Land at
Gatehouse Close, Aylesbury, have not been adequately assessed to consider the potential for existing
employment land to be releasd in the shorter term to realise and deliver much needed new housing.
Specifically, further consideration must be given to the current and future difficulties associated with HELAA
site ref. AYL078 - Land at Gatehouse Close being successful or viable for employment purposes. HELAA
site AYL078 would be able to deliver approximately 300 dwellings, reducing the need for release of
greenfield land for a similar quantum of housing.

Table 9 and para 6.6:

Aviva object to the HELAA site ref. AYL078 forming part of the key employment site known as the Gatehouse
Industrial Area. Whilst HELAA site ref. AYL0788 is currently in partial use, the only realistic long term use of the
site is for residential development. There is very limited demand for the existing types of units on the site, and the
site's location and poor access for modern commercial vehicles means that the re-use or redevelopment
for employment is not viable. Although the site presently has some very short term tenants the only realistic long
term use of the site would be residential development.
In addition, it is submitted that paragraphs 6.5 and 6.6 are overly protective of employment land, paricularly of
employment land such as that at HELAA site AYL078 which is clearly suitable for alternative more appropriate
land uses. Paragraph 22 of the NPPF states that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no
reasonable prospect of a site being used for that purpose"...and..."land allocations should be regularly reviewed".
The NPPF goes on to say in the same paragraph that "where there is no reasonable prospect of a site being
used for the allocated employment use, applications for alternative uses of land or buildings should be treated on
their merits having regard to market signals and the relative need for different land uses to support sustainable
local communities".
The NPPF also state that: "To help achieve economic growth, local planning authorities should plan proactively
to meet the development needs of business and support an economy fit for the 21st century".
It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that
consists of residential and employment space. The strategic greenfield sites would allow for the employment sites
to be located in areas that are accessible and sustainable and allow the facilitation of the of the growth of the
Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been
located on the edge of settlements as they benefit from better connectivity.
Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is
likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that previously
allocated land for employment that was once 'out of town' (such as land at HELAA site ref. AYL 078 Gatehouse
Industrial Estate) will be situated in an urban hinterland due to settlement expansion, rendering the employment
sites surplus to modern day requirements.
In the case of HELAA site ref. AYL078 it is submitted by Aviva that there is very limited demand for the type of
units on the site, and the site's location and poor access for modern commercial vehicles, means that re-use or
redevelopment is not viable as a continuation of 'B' uses.
In conclusion, it is submitted that either the Gatehouse Industrial Estate should no longer be identified as a key
employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local
Plan proposals map as no longer forming part of the Gatehouse Industrial Estate as a key employment site.

S2 and table 1:

Policy S2 is supported in terms of identifying an approach to delivery of land for housing and employment growth
and development, including to meet some of the needs of adjoining highly constrained districts including
Wycombe and Chiltern/South Bucks Districts.
Nevertheless, the approach of releasing large greenfield sites for residential development to meet the needs of
Aylesbury and adjoining authorities is not justified, effective or consistent with National Policy where there is
significant previously developed land available that can deliver new homes at sustainable locations.
Aylesbury District is seeking to retain historic/ existing employment land for employment purposes where there is
no realistic or viable prospect of the land contributing towards employment development throughout the Plan
period.
Land at the Gatehouse Industrial Estate should be reviewed in light of current and permitted residential
developments at Brook Mews and Alton House and in light of the long term and persistent vacancies and
poor take up of employment land and premises.
Aylesbury Vale has not recently reviewed the ability for the Gatehouse Close Industrial Estate to contrbute
towards employment development, and it is submitted that in accordance with paragraph 22 of the NPPF land
east of the residential scheme at Alton House should be allocated for an alternative and more suitable land use
i.e. a logical and sustainable form of residential linking Alton House, with Brook Mews.

S7:

Poliy S7 is supported by Aviva. Policy S7 appropriately expects efficient and effective use of land and
encourages reuse of previously developed (brownfield) land in sustainable locations. Nevertheless, Policy S7
should be strengthened to confirm that Aylesbury Vale will encourage efficient and effective use of land, in
sustainable locations and subject to specific site considerations, ahead of release of greenfield or Green Belt
land.
Policy S7 should also be strengthened to set out how Aylesbury Vale intends to apply the emerging
requirements from the government for Council's to prepare brownfield land registers.
Paragraph 3.67 only makes reference to the emerging brownfield land register initiative. Aviva submit that
Aylesbury Vale should set out within paragrph 3.81 and policy S7 strong support for the principles of
brownfield land. Indeed, it is recommended that Aylesbury Vale should provide confirmation that a brownfield
land register will be prepared by the Council, to be informed by detailed and fresh assessment of suitable,
available and deliverable previosuly developed land, such as HELAA site ref. AYL078 - Land at Gatehouse
Close, Aylesbury.

Policy maps for Aylesbury:

Aviva object to the potential housing allocations VALP policy map inset for Aylesbury, as the map fails to identify
HELAA site ref. AYL078, land at Gatehouse Close as a potential housing allocation. HELAA site ref. AYL078
is located immediately adjacent to, and shares its eastern boundary with the now completed residential
development at Brook Mews, as well as its western boundary with the permitted residenital development at
Alton House. HELAA site ref. AYL078 also shares the same credentials as a highly sustainable location for
residential development, being within walking distance of Aylesbury town centre and railway station, as well as
the range and mix of commnity facilites and servies within and around the town centre.

Object

VALP Proposed Submission

4.169

Representation ID: 1670

Received: 14/12/2017

Respondent: Aviva Life & Pensions UK Limited

Agent: GL Hearn

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Paragraphs 4.169-4.173 indicate that Aylesbury Vale intends to allocate more employment land within the Local Plan than is required for the Plan period. The over-supply of employment land will comprise a mixture of existing retained employment sites as well as new allocated employment sites.

It is submitted that the oversupply of existing/ historic employment land will result in stagnation and high vacancy
rates for employment premises at sites such as the Gatehouse Industrial Estate.

Land at the Gatehouse Industrial Estate between the existing and permitted residential developments at Brook Mews and Alton House remains (as it has for a number of years) partly vacant, underutilised and unviable for future employment purposes. The land should not be retained as an employment allocation, and the failure to carry out an up-to-date review of the site is contrary to NPPF paragrph 22.

Full text:

On behalf of our client, Aviva Life & Pensions UK Limited, please see attached representations duly made towards the Reg. 19 Aylesbury Vale Local Plan

Full text where it has been summarised:

Para 1.14

Paragraph 1.14 is supported in terms of the policy approach of new employment need being met by new allocations to meet forecast need. However, it is apparent that Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs.
The Council is failing to provied an effective planning policy framework by retaining areas of previous employment land at the Gatehouse Industrial Estate which are no longer suitable, viable or deliverable for
employment purposes. The Gatehouse Industrial Estate has already been subject to incremental and
piecemeal redevelopment for alternative land uses, notably for residential at Brook Mews, and residential
being brought forward at Alton House. The character and form of development at the Gatehouse Industrial
Estate has already chaged such that land between Alton House and Brook Mews should be released for
residential and mixed use development.
The Council's approach in retaining the Gatehouse Close Industrial Estate as a key employment site
is inconsistent with the NPPF paragraph 22 which seeks to prevent the long term retention of employment land where there is no reasonable prospect of the land being used for that purpose. In these circumstances Planning Auithorities should review the potential for allocation the land for alternative land uses, including for residential.
The Council's evidence base relating to the Gatehouse Industrial Estate is out-of-date and should be reviewed to take account of existing and permitted residential development locally.

Para 3.78-3.80

Paragraph 3.80 of the VALP emphasises the considerable difficulty of potential large scale allocations being
brought forward speedily to meet immediate and short term (5 year) housing land supply requirements. Whilst
large scale urban extensions or a new settlement would prove a strong solution to medium and longer term
housing delivery, it is clear that a step change is required to increase the short term supply and delivery.
Aviva remain concerned that existing employment sites, such as HELAA site ref. AYL078 - Land at
Gatehouse Close, Aylesbury, have not been adequately assessed to consider the potential for existing
employment land to be releasd in the shorter term to realise and deliver much needed new housing.
Specifically, further consideration must be given to the current and future difficulties associated with HELAA
site ref. AYL078 - Land at Gatehouse Close being successful or viable for employment purposes. HELAA
site AYL078 would be able to deliver approximately 300 dwellings, reducing the need for release of
greenfield land for a similar quantum of housing.

Table 9 and para 6.6:

Aviva object to the HELAA site ref. AYL078 forming part of the key employment site known as the Gatehouse
Industrial Area. Whilst HELAA site ref. AYL0788 is currently in partial use, the only realistic long term use of the
site is for residential development. There is very limited demand for the existing types of units on the site, and the
site's location and poor access for modern commercial vehicles means that the re-use or redevelopment
for employment is not viable. Although the site presently has some very short term tenants the only realistic long
term use of the site would be residential development.
In addition, it is submitted that paragraphs 6.5 and 6.6 are overly protective of employment land, paricularly of
employment land such as that at HELAA site AYL078 which is clearly suitable for alternative more appropriate
land uses. Paragraph 22 of the NPPF states that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no
reasonable prospect of a site being used for that purpose"...and..."land allocations should be regularly reviewed".
The NPPF goes on to say in the same paragraph that "where there is no reasonable prospect of a site being
used for the allocated employment use, applications for alternative uses of land or buildings should be treated on
their merits having regard to market signals and the relative need for different land uses to support sustainable
local communities".
The NPPF also state that: "To help achieve economic growth, local planning authorities should plan proactively
to meet the development needs of business and support an economy fit for the 21st century".
It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that
consists of residential and employment space. The strategic greenfield sites would allow for the employment sites
to be located in areas that are accessible and sustainable and allow the facilitation of the of the growth of the
Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been
located on the edge of settlements as they benefit from better connectivity.
Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is
likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that previously
allocated land for employment that was once 'out of town' (such as land at HELAA site ref. AYL 078 Gatehouse
Industrial Estate) will be situated in an urban hinterland due to settlement expansion, rendering the employment
sites surplus to modern day requirements.
In the case of HELAA site ref. AYL078 it is submitted by Aviva that there is very limited demand for the type of
units on the site, and the site's location and poor access for modern commercial vehicles, means that re-use or
redevelopment is not viable as a continuation of 'B' uses.
In conclusion, it is submitted that either the Gatehouse Industrial Estate should no longer be identified as a key
employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local
Plan proposals map as no longer forming part of the Gatehouse Industrial Estate as a key employment site.

S2 and table 1:

Policy S2 is supported in terms of identifying an approach to delivery of land for housing and employment growth
and development, including to meet some of the needs of adjoining highly constrained districts including
Wycombe and Chiltern/South Bucks Districts.
Nevertheless, the approach of releasing large greenfield sites for residential development to meet the needs of
Aylesbury and adjoining authorities is not justified, effective or consistent with National Policy where there is
significant previously developed land available that can deliver new homes at sustainable locations.
Aylesbury District is seeking to retain historic/ existing employment land for employment purposes where there is
no realistic or viable prospect of the land contributing towards employment development throughout the Plan
period.
Land at the Gatehouse Industrial Estate should be reviewed in light of current and permitted residential
developments at Brook Mews and Alton House and in light of the long term and persistent vacancies and
poor take up of employment land and premises.
Aylesbury Vale has not recently reviewed the ability for the Gatehouse Close Industrial Estate to contrbute
towards employment development, and it is submitted that in accordance with paragraph 22 of the NPPF land
east of the residential scheme at Alton House should be allocated for an alternative and more suitable land use
i.e. a logical and sustainable form of residential linking Alton House, with Brook Mews.

S7:

Poliy S7 is supported by Aviva. Policy S7 appropriately expects efficient and effective use of land and
encourages reuse of previously developed (brownfield) land in sustainable locations. Nevertheless, Policy S7
should be strengthened to confirm that Aylesbury Vale will encourage efficient and effective use of land, in
sustainable locations and subject to specific site considerations, ahead of release of greenfield or Green Belt
land.
Policy S7 should also be strengthened to set out how Aylesbury Vale intends to apply the emerging
requirements from the government for Council's to prepare brownfield land registers.
Paragraph 3.67 only makes reference to the emerging brownfield land register initiative. Aviva submit that
Aylesbury Vale should set out within paragrph 3.81 and policy S7 strong support for the principles of
brownfield land. Indeed, it is recommended that Aylesbury Vale should provide confirmation that a brownfield
land register will be prepared by the Council, to be informed by detailed and fresh assessment of suitable,
available and deliverable previosuly developed land, such as HELAA site ref. AYL078 - Land at Gatehouse
Close, Aylesbury.

Policy maps for Aylesbury:

Aviva object to the potential housing allocations VALP policy map inset for Aylesbury, as the map fails to identify
HELAA site ref. AYL078, land at Gatehouse Close as a potential housing allocation. HELAA site ref. AYL078
is located immediately adjacent to, and shares its eastern boundary with the now completed residential
development at Brook Mews, as well as its western boundary with the permitted residenital development at
Alton House. HELAA site ref. AYL078 also shares the same credentials as a highly sustainable location for
residential development, being within walking distance of Aylesbury town centre and railway station, as well as
the range and mix of commnity facilites and servies within and around the town centre.

Object

VALP Proposed Submission

Table 9 Key employment sites

Representation ID: 1671

Received: 14/12/2017

Respondent: Aviva Life & Pensions UK Limited

Agent: GL Hearn

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Aviva object to the retention of site AYL078 as part of the Gatehouse Industrial Estate key employment site.

Full text:

On behalf of our client, Aviva Life & Pensions UK Limited, please see attached representations duly made towards the Reg. 19 Aylesbury Vale Local Plan

Full text where it has been summarised:

Para 1.14

Paragraph 1.14 is supported in terms of the policy approach of new employment need being met by new allocations to meet forecast need. However, it is apparent that Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs.
The Council is failing to provied an effective planning policy framework by retaining areas of previous employment land at the Gatehouse Industrial Estate which are no longer suitable, viable or deliverable for
employment purposes. The Gatehouse Industrial Estate has already been subject to incremental and
piecemeal redevelopment for alternative land uses, notably for residential at Brook Mews, and residential
being brought forward at Alton House. The character and form of development at the Gatehouse Industrial
Estate has already chaged such that land between Alton House and Brook Mews should be released for
residential and mixed use development.
The Council's approach in retaining the Gatehouse Close Industrial Estate as a key employment site
is inconsistent with the NPPF paragraph 22 which seeks to prevent the long term retention of employment land where there is no reasonable prospect of the land being used for that purpose. In these circumstances Planning Auithorities should review the potential for allocation the land for alternative land uses, including for residential.
The Council's evidence base relating to the Gatehouse Industrial Estate is out-of-date and should be reviewed to take account of existing and permitted residential development locally.

Para 3.78-3.80

Paragraph 3.80 of the VALP emphasises the considerable difficulty of potential large scale allocations being
brought forward speedily to meet immediate and short term (5 year) housing land supply requirements. Whilst
large scale urban extensions or a new settlement would prove a strong solution to medium and longer term
housing delivery, it is clear that a step change is required to increase the short term supply and delivery.
Aviva remain concerned that existing employment sites, such as HELAA site ref. AYL078 - Land at
Gatehouse Close, Aylesbury, have not been adequately assessed to consider the potential for existing
employment land to be releasd in the shorter term to realise and deliver much needed new housing.
Specifically, further consideration must be given to the current and future difficulties associated with HELAA
site ref. AYL078 - Land at Gatehouse Close being successful or viable for employment purposes. HELAA
site AYL078 would be able to deliver approximately 300 dwellings, reducing the need for release of
greenfield land for a similar quantum of housing.

Table 9 and para 6.6:

Aviva object to the HELAA site ref. AYL078 forming part of the key employment site known as the Gatehouse
Industrial Area. Whilst HELAA site ref. AYL0788 is currently in partial use, the only realistic long term use of the
site is for residential development. There is very limited demand for the existing types of units on the site, and the
site's location and poor access for modern commercial vehicles means that the re-use or redevelopment
for employment is not viable. Although the site presently has some very short term tenants the only realistic long
term use of the site would be residential development.
In addition, it is submitted that paragraphs 6.5 and 6.6 are overly protective of employment land, paricularly of
employment land such as that at HELAA site AYL078 which is clearly suitable for alternative more appropriate
land uses. Paragraph 22 of the NPPF states that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no
reasonable prospect of a site being used for that purpose"...and..."land allocations should be regularly reviewed".
The NPPF goes on to say in the same paragraph that "where there is no reasonable prospect of a site being
used for the allocated employment use, applications for alternative uses of land or buildings should be treated on
their merits having regard to market signals and the relative need for different land uses to support sustainable
local communities".
The NPPF also state that: "To help achieve economic growth, local planning authorities should plan proactively
to meet the development needs of business and support an economy fit for the 21st century".
It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that
consists of residential and employment space. The strategic greenfield sites would allow for the employment sites
to be located in areas that are accessible and sustainable and allow the facilitation of the of the growth of the
Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been
located on the edge of settlements as they benefit from better connectivity.
Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is
likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that previously
allocated land for employment that was once 'out of town' (such as land at HELAA site ref. AYL 078 Gatehouse
Industrial Estate) will be situated in an urban hinterland due to settlement expansion, rendering the employment
sites surplus to modern day requirements.
In the case of HELAA site ref. AYL078 it is submitted by Aviva that there is very limited demand for the type of
units on the site, and the site's location and poor access for modern commercial vehicles, means that re-use or
redevelopment is not viable as a continuation of 'B' uses.
In conclusion, it is submitted that either the Gatehouse Industrial Estate should no longer be identified as a key
employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local
Plan proposals map as no longer forming part of the Gatehouse Industrial Estate as a key employment site.

S2 and table 1:

Policy S2 is supported in terms of identifying an approach to delivery of land for housing and employment growth
and development, including to meet some of the needs of adjoining highly constrained districts including
Wycombe and Chiltern/South Bucks Districts.
Nevertheless, the approach of releasing large greenfield sites for residential development to meet the needs of
Aylesbury and adjoining authorities is not justified, effective or consistent with National Policy where there is
significant previously developed land available that can deliver new homes at sustainable locations.
Aylesbury District is seeking to retain historic/ existing employment land for employment purposes where there is
no realistic or viable prospect of the land contributing towards employment development throughout the Plan
period.
Land at the Gatehouse Industrial Estate should be reviewed in light of current and permitted residential
developments at Brook Mews and Alton House and in light of the long term and persistent vacancies and
poor take up of employment land and premises.
Aylesbury Vale has not recently reviewed the ability for the Gatehouse Close Industrial Estate to contrbute
towards employment development, and it is submitted that in accordance with paragraph 22 of the NPPF land
east of the residential scheme at Alton House should be allocated for an alternative and more suitable land use
i.e. a logical and sustainable form of residential linking Alton House, with Brook Mews.

S7:

Poliy S7 is supported by Aviva. Policy S7 appropriately expects efficient and effective use of land and
encourages reuse of previously developed (brownfield) land in sustainable locations. Nevertheless, Policy S7
should be strengthened to confirm that Aylesbury Vale will encourage efficient and effective use of land, in
sustainable locations and subject to specific site considerations, ahead of release of greenfield or Green Belt
land.
Policy S7 should also be strengthened to set out how Aylesbury Vale intends to apply the emerging
requirements from the government for Council's to prepare brownfield land registers.
Paragraph 3.67 only makes reference to the emerging brownfield land register initiative. Aviva submit that
Aylesbury Vale should set out within paragrph 3.81 and policy S7 strong support for the principles of
brownfield land. Indeed, it is recommended that Aylesbury Vale should provide confirmation that a brownfield
land register will be prepared by the Council, to be informed by detailed and fresh assessment of suitable,
available and deliverable previosuly developed land, such as HELAA site ref. AYL078 - Land at Gatehouse
Close, Aylesbury.

Policy maps for Aylesbury:

Aviva object to the potential housing allocations VALP policy map inset for Aylesbury, as the map fails to identify
HELAA site ref. AYL078, land at Gatehouse Close as a potential housing allocation. HELAA site ref. AYL078
is located immediately adjacent to, and shares its eastern boundary with the now completed residential
development at Brook Mews, as well as its western boundary with the permitted residenital development at
Alton House. HELAA site ref. AYL078 also shares the same credentials as a highly sustainable location for
residential development, being within walking distance of Aylesbury town centre and railway station, as well as
the range and mix of commnity facilites and servies within and around the town centre.

Object

VALP Proposed Submission

S2 Spatial Strategy for Growth

Representation ID: 1673

Received: 14/12/2017

Respondent: Aviva Life & Pensions UK Limited

Agent: GL Hearn

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy S2 is overly reliant on release of greenfield land to meet housing needs for Aylesbury Vale and for neighbouring districts. An updated assessment should be carried out to assess existing vacant and previously developed land, particularly historic employment land at the Gatehouse Industrial Estate, for alternative land uses, including residential.

Full text:

On behalf of our client, Aviva Life & Pensions UK Limited, please see attached representations duly made towards the Reg. 19 Aylesbury Vale Local Plan

Full text where it has been summarised:

Para 1.14

Paragraph 1.14 is supported in terms of the policy approach of new employment need being met by new allocations to meet forecast need. However, it is apparent that Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs.
The Council is failing to provied an effective planning policy framework by retaining areas of previous employment land at the Gatehouse Industrial Estate which are no longer suitable, viable or deliverable for
employment purposes. The Gatehouse Industrial Estate has already been subject to incremental and
piecemeal redevelopment for alternative land uses, notably for residential at Brook Mews, and residential
being brought forward at Alton House. The character and form of development at the Gatehouse Industrial
Estate has already chaged such that land between Alton House and Brook Mews should be released for
residential and mixed use development.
The Council's approach in retaining the Gatehouse Close Industrial Estate as a key employment site
is inconsistent with the NPPF paragraph 22 which seeks to prevent the long term retention of employment land where there is no reasonable prospect of the land being used for that purpose. In these circumstances Planning Auithorities should review the potential for allocation the land for alternative land uses, including for residential.
The Council's evidence base relating to the Gatehouse Industrial Estate is out-of-date and should be reviewed to take account of existing and permitted residential development locally.

Para 3.78-3.80

Paragraph 3.80 of the VALP emphasises the considerable difficulty of potential large scale allocations being
brought forward speedily to meet immediate and short term (5 year) housing land supply requirements. Whilst
large scale urban extensions or a new settlement would prove a strong solution to medium and longer term
housing delivery, it is clear that a step change is required to increase the short term supply and delivery.
Aviva remain concerned that existing employment sites, such as HELAA site ref. AYL078 - Land at
Gatehouse Close, Aylesbury, have not been adequately assessed to consider the potential for existing
employment land to be releasd in the shorter term to realise and deliver much needed new housing.
Specifically, further consideration must be given to the current and future difficulties associated with HELAA
site ref. AYL078 - Land at Gatehouse Close being successful or viable for employment purposes. HELAA
site AYL078 would be able to deliver approximately 300 dwellings, reducing the need for release of
greenfield land for a similar quantum of housing.

Table 9 and para 6.6:

Aviva object to the HELAA site ref. AYL078 forming part of the key employment site known as the Gatehouse
Industrial Area. Whilst HELAA site ref. AYL0788 is currently in partial use, the only realistic long term use of the
site is for residential development. There is very limited demand for the existing types of units on the site, and the
site's location and poor access for modern commercial vehicles means that the re-use or redevelopment
for employment is not viable. Although the site presently has some very short term tenants the only realistic long
term use of the site would be residential development.
In addition, it is submitted that paragraphs 6.5 and 6.6 are overly protective of employment land, paricularly of
employment land such as that at HELAA site AYL078 which is clearly suitable for alternative more appropriate
land uses. Paragraph 22 of the NPPF states that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no
reasonable prospect of a site being used for that purpose"...and..."land allocations should be regularly reviewed".
The NPPF goes on to say in the same paragraph that "where there is no reasonable prospect of a site being
used for the allocated employment use, applications for alternative uses of land or buildings should be treated on
their merits having regard to market signals and the relative need for different land uses to support sustainable
local communities".
The NPPF also state that: "To help achieve economic growth, local planning authorities should plan proactively
to meet the development needs of business and support an economy fit for the 21st century".
It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that
consists of residential and employment space. The strategic greenfield sites would allow for the employment sites
to be located in areas that are accessible and sustainable and allow the facilitation of the of the growth of the
Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been
located on the edge of settlements as they benefit from better connectivity.
Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is
likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that previously
allocated land for employment that was once 'out of town' (such as land at HELAA site ref. AYL 078 Gatehouse
Industrial Estate) will be situated in an urban hinterland due to settlement expansion, rendering the employment
sites surplus to modern day requirements.
In the case of HELAA site ref. AYL078 it is submitted by Aviva that there is very limited demand for the type of
units on the site, and the site's location and poor access for modern commercial vehicles, means that re-use or
redevelopment is not viable as a continuation of 'B' uses.
In conclusion, it is submitted that either the Gatehouse Industrial Estate should no longer be identified as a key
employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local
Plan proposals map as no longer forming part of the Gatehouse Industrial Estate as a key employment site.

S2 and table 1:

Policy S2 is supported in terms of identifying an approach to delivery of land for housing and employment growth
and development, including to meet some of the needs of adjoining highly constrained districts including
Wycombe and Chiltern/South Bucks Districts.
Nevertheless, the approach of releasing large greenfield sites for residential development to meet the needs of
Aylesbury and adjoining authorities is not justified, effective or consistent with National Policy where there is
significant previously developed land available that can deliver new homes at sustainable locations.
Aylesbury District is seeking to retain historic/ existing employment land for employment purposes where there is
no realistic or viable prospect of the land contributing towards employment development throughout the Plan
period.
Land at the Gatehouse Industrial Estate should be reviewed in light of current and permitted residential
developments at Brook Mews and Alton House and in light of the long term and persistent vacancies and
poor take up of employment land and premises.
Aylesbury Vale has not recently reviewed the ability for the Gatehouse Close Industrial Estate to contrbute
towards employment development, and it is submitted that in accordance with paragraph 22 of the NPPF land
east of the residential scheme at Alton House should be allocated for an alternative and more suitable land use
i.e. a logical and sustainable form of residential linking Alton House, with Brook Mews.

S7:

Poliy S7 is supported by Aviva. Policy S7 appropriately expects efficient and effective use of land and
encourages reuse of previously developed (brownfield) land in sustainable locations. Nevertheless, Policy S7
should be strengthened to confirm that Aylesbury Vale will encourage efficient and effective use of land, in
sustainable locations and subject to specific site considerations, ahead of release of greenfield or Green Belt
land.
Policy S7 should also be strengthened to set out how Aylesbury Vale intends to apply the emerging
requirements from the government for Council's to prepare brownfield land registers.
Paragraph 3.67 only makes reference to the emerging brownfield land register initiative. Aviva submit that
Aylesbury Vale should set out within paragrph 3.81 and policy S7 strong support for the principles of
brownfield land. Indeed, it is recommended that Aylesbury Vale should provide confirmation that a brownfield
land register will be prepared by the Council, to be informed by detailed and fresh assessment of suitable,
available and deliverable previosuly developed land, such as HELAA site ref. AYL078 - Land at Gatehouse
Close, Aylesbury.

Policy maps for Aylesbury:

Aviva object to the potential housing allocations VALP policy map inset for Aylesbury, as the map fails to identify
HELAA site ref. AYL078, land at Gatehouse Close as a potential housing allocation. HELAA site ref. AYL078
is located immediately adjacent to, and shares its eastern boundary with the now completed residential
development at Brook Mews, as well as its western boundary with the permitted residenital development at
Alton House. HELAA site ref. AYL078 also shares the same credentials as a highly sustainable location for
residential development, being within walking distance of Aylesbury town centre and railway station, as well as
the range and mix of commnity facilites and servies within and around the town centre.

Object

VALP Proposed Submission

S7 Previously developed land

Representation ID: 1676

Received: 14/12/2017

Respondent: Aviva Life & Pensions UK Limited

Agent: GL Hearn

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Aylesbury Vale District should provide commitment to preparation of a brownfield land register, to include appropriate previously developed sites that are suitable, available and deliverable for residential developments.

Full text:

On behalf of our client, Aviva Life & Pensions UK Limited, please see attached representations duly made towards the Reg. 19 Aylesbury Vale Local Plan

Full text where it has been summarised:

Para 1.14

Paragraph 1.14 is supported in terms of the policy approach of new employment need being met by new allocations to meet forecast need. However, it is apparent that Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs.
The Council is failing to provied an effective planning policy framework by retaining areas of previous employment land at the Gatehouse Industrial Estate which are no longer suitable, viable or deliverable for
employment purposes. The Gatehouse Industrial Estate has already been subject to incremental and
piecemeal redevelopment for alternative land uses, notably for residential at Brook Mews, and residential
being brought forward at Alton House. The character and form of development at the Gatehouse Industrial
Estate has already chaged such that land between Alton House and Brook Mews should be released for
residential and mixed use development.
The Council's approach in retaining the Gatehouse Close Industrial Estate as a key employment site
is inconsistent with the NPPF paragraph 22 which seeks to prevent the long term retention of employment land where there is no reasonable prospect of the land being used for that purpose. In these circumstances Planning Auithorities should review the potential for allocation the land for alternative land uses, including for residential.
The Council's evidence base relating to the Gatehouse Industrial Estate is out-of-date and should be reviewed to take account of existing and permitted residential development locally.

Para 3.78-3.80

Paragraph 3.80 of the VALP emphasises the considerable difficulty of potential large scale allocations being
brought forward speedily to meet immediate and short term (5 year) housing land supply requirements. Whilst
large scale urban extensions or a new settlement would prove a strong solution to medium and longer term
housing delivery, it is clear that a step change is required to increase the short term supply and delivery.
Aviva remain concerned that existing employment sites, such as HELAA site ref. AYL078 - Land at
Gatehouse Close, Aylesbury, have not been adequately assessed to consider the potential for existing
employment land to be releasd in the shorter term to realise and deliver much needed new housing.
Specifically, further consideration must be given to the current and future difficulties associated with HELAA
site ref. AYL078 - Land at Gatehouse Close being successful or viable for employment purposes. HELAA
site AYL078 would be able to deliver approximately 300 dwellings, reducing the need for release of
greenfield land for a similar quantum of housing.

Table 9 and para 6.6:

Aviva object to the HELAA site ref. AYL078 forming part of the key employment site known as the Gatehouse
Industrial Area. Whilst HELAA site ref. AYL0788 is currently in partial use, the only realistic long term use of the
site is for residential development. There is very limited demand for the existing types of units on the site, and the
site's location and poor access for modern commercial vehicles means that the re-use or redevelopment
for employment is not viable. Although the site presently has some very short term tenants the only realistic long
term use of the site would be residential development.
In addition, it is submitted that paragraphs 6.5 and 6.6 are overly protective of employment land, paricularly of
employment land such as that at HELAA site AYL078 which is clearly suitable for alternative more appropriate
land uses. Paragraph 22 of the NPPF states that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no
reasonable prospect of a site being used for that purpose"...and..."land allocations should be regularly reviewed".
The NPPF goes on to say in the same paragraph that "where there is no reasonable prospect of a site being
used for the allocated employment use, applications for alternative uses of land or buildings should be treated on
their merits having regard to market signals and the relative need for different land uses to support sustainable
local communities".
The NPPF also state that: "To help achieve economic growth, local planning authorities should plan proactively
to meet the development needs of business and support an economy fit for the 21st century".
It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that
consists of residential and employment space. The strategic greenfield sites would allow for the employment sites
to be located in areas that are accessible and sustainable and allow the facilitation of the of the growth of the
Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been
located on the edge of settlements as they benefit from better connectivity.
Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is
likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that previously
allocated land for employment that was once 'out of town' (such as land at HELAA site ref. AYL 078 Gatehouse
Industrial Estate) will be situated in an urban hinterland due to settlement expansion, rendering the employment
sites surplus to modern day requirements.
In the case of HELAA site ref. AYL078 it is submitted by Aviva that there is very limited demand for the type of
units on the site, and the site's location and poor access for modern commercial vehicles, means that re-use or
redevelopment is not viable as a continuation of 'B' uses.
In conclusion, it is submitted that either the Gatehouse Industrial Estate should no longer be identified as a key
employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local
Plan proposals map as no longer forming part of the Gatehouse Industrial Estate as a key employment site.

S2 and table 1:

Policy S2 is supported in terms of identifying an approach to delivery of land for housing and employment growth
and development, including to meet some of the needs of adjoining highly constrained districts including
Wycombe and Chiltern/South Bucks Districts.
Nevertheless, the approach of releasing large greenfield sites for residential development to meet the needs of
Aylesbury and adjoining authorities is not justified, effective or consistent with National Policy where there is
significant previously developed land available that can deliver new homes at sustainable locations.
Aylesbury District is seeking to retain historic/ existing employment land for employment purposes where there is
no realistic or viable prospect of the land contributing towards employment development throughout the Plan
period.
Land at the Gatehouse Industrial Estate should be reviewed in light of current and permitted residential
developments at Brook Mews and Alton House and in light of the long term and persistent vacancies and
poor take up of employment land and premises.
Aylesbury Vale has not recently reviewed the ability for the Gatehouse Close Industrial Estate to contrbute
towards employment development, and it is submitted that in accordance with paragraph 22 of the NPPF land
east of the residential scheme at Alton House should be allocated for an alternative and more suitable land use
i.e. a logical and sustainable form of residential linking Alton House, with Brook Mews.

S7:

Poliy S7 is supported by Aviva. Policy S7 appropriately expects efficient and effective use of land and
encourages reuse of previously developed (brownfield) land in sustainable locations. Nevertheless, Policy S7
should be strengthened to confirm that Aylesbury Vale will encourage efficient and effective use of land, in
sustainable locations and subject to specific site considerations, ahead of release of greenfield or Green Belt
land.
Policy S7 should also be strengthened to set out how Aylesbury Vale intends to apply the emerging
requirements from the government for Council's to prepare brownfield land registers.
Paragraph 3.67 only makes reference to the emerging brownfield land register initiative. Aviva submit that
Aylesbury Vale should set out within paragrph 3.81 and policy S7 strong support for the principles of
brownfield land. Indeed, it is recommended that Aylesbury Vale should provide confirmation that a brownfield
land register will be prepared by the Council, to be informed by detailed and fresh assessment of suitable,
available and deliverable previosuly developed land, such as HELAA site ref. AYL078 - Land at Gatehouse
Close, Aylesbury.

Policy maps for Aylesbury:

Aviva object to the potential housing allocations VALP policy map inset for Aylesbury, as the map fails to identify
HELAA site ref. AYL078, land at Gatehouse Close as a potential housing allocation. HELAA site ref. AYL078
is located immediately adjacent to, and shares its eastern boundary with the now completed residential
development at Brook Mews, as well as its western boundary with the permitted residenital development at
Alton House. HELAA site ref. AYL078 also shares the same credentials as a highly sustainable location for
residential development, being within walking distance of Aylesbury town centre and railway station, as well as
the range and mix of commnity facilites and servies within and around the town centre.

Object

VALP Proposed Submission

Central Aylesbury

Representation ID: 1678

Received: 14/12/2017

Respondent: Aviva Life & Pensions UK Limited

Agent: GL Hearn

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Local Plan proposals map for Aylesbury should exclude HELAA site ref. AYL078 and the adjacent site known as Alton House from the Gatehouse Industrial Estate key employment site allocation.

Full text:

On behalf of our client, Aviva Life & Pensions UK Limited, please see attached representations duly made towards the Reg. 19 Aylesbury Vale Local Plan

Full text where it has been summarised:

Para 1.14

Paragraph 1.14 is supported in terms of the policy approach of new employment need being met by new allocations to meet forecast need. However, it is apparent that Aylesbury Vale District is retaining historic employment land that is no longer suitable, or viable for current and future employment needs.
The Council is failing to provied an effective planning policy framework by retaining areas of previous employment land at the Gatehouse Industrial Estate which are no longer suitable, viable or deliverable for
employment purposes. The Gatehouse Industrial Estate has already been subject to incremental and
piecemeal redevelopment for alternative land uses, notably for residential at Brook Mews, and residential
being brought forward at Alton House. The character and form of development at the Gatehouse Industrial
Estate has already chaged such that land between Alton House and Brook Mews should be released for
residential and mixed use development.
The Council's approach in retaining the Gatehouse Close Industrial Estate as a key employment site
is inconsistent with the NPPF paragraph 22 which seeks to prevent the long term retention of employment land where there is no reasonable prospect of the land being used for that purpose. In these circumstances Planning Auithorities should review the potential for allocation the land for alternative land uses, including for residential.
The Council's evidence base relating to the Gatehouse Industrial Estate is out-of-date and should be reviewed to take account of existing and permitted residential development locally.

Para 3.78-3.80

Paragraph 3.80 of the VALP emphasises the considerable difficulty of potential large scale allocations being
brought forward speedily to meet immediate and short term (5 year) housing land supply requirements. Whilst
large scale urban extensions or a new settlement would prove a strong solution to medium and longer term
housing delivery, it is clear that a step change is required to increase the short term supply and delivery.
Aviva remain concerned that existing employment sites, such as HELAA site ref. AYL078 - Land at
Gatehouse Close, Aylesbury, have not been adequately assessed to consider the potential for existing
employment land to be releasd in the shorter term to realise and deliver much needed new housing.
Specifically, further consideration must be given to the current and future difficulties associated with HELAA
site ref. AYL078 - Land at Gatehouse Close being successful or viable for employment purposes. HELAA
site AYL078 would be able to deliver approximately 300 dwellings, reducing the need for release of
greenfield land for a similar quantum of housing.

Table 9 and para 6.6:

Aviva object to the HELAA site ref. AYL078 forming part of the key employment site known as the Gatehouse
Industrial Area. Whilst HELAA site ref. AYL0788 is currently in partial use, the only realistic long term use of the
site is for residential development. There is very limited demand for the existing types of units on the site, and the
site's location and poor access for modern commercial vehicles means that the re-use or redevelopment
for employment is not viable. Although the site presently has some very short term tenants the only realistic long
term use of the site would be residential development.
In addition, it is submitted that paragraphs 6.5 and 6.6 are overly protective of employment land, paricularly of
employment land such as that at HELAA site AYL078 which is clearly suitable for alternative more appropriate
land uses. Paragraph 22 of the NPPF states that:
"Planning policies should avoid the long term protection of sites allocated for employment use where there is no
reasonable prospect of a site being used for that purpose"...and..."land allocations should be regularly reviewed".
The NPPF goes on to say in the same paragraph that "where there is no reasonable prospect of a site being
used for the allocated employment use, applications for alternative uses of land or buildings should be treated on
their merits having regard to market signals and the relative need for different land uses to support sustainable
local communities".
The NPPF also state that: "To help achieve economic growth, local planning authorities should plan proactively
to meet the development needs of business and support an economy fit for the 21st century".
It is submitted that AVDC should continue to release some greenfield land sites for mixed use development that
consists of residential and employment space. The strategic greenfield sites would allow for the employment sites
to be located in areas that are accessible and sustainable and allow the facilitation of the of the growth of the
Aylesbury Vale economy. Research and development, manufacturing and distribution have all traditionally been
located on the edge of settlements as they benefit from better connectivity.
Given the committed investment projects of East West Rail and HS2 and the larger strategic housing sites, it is
likely that Aylesbury will benefit from improved connectivity by 2033. This therefore means that previously
allocated land for employment that was once 'out of town' (such as land at HELAA site ref. AYL 078 Gatehouse
Industrial Estate) will be situated in an urban hinterland due to settlement expansion, rendering the employment
sites surplus to modern day requirements.
In the case of HELAA site ref. AYL078 it is submitted by Aviva that there is very limited demand for the type of
units on the site, and the site's location and poor access for modern commercial vehicles, means that re-use or
redevelopment is not viable as a continuation of 'B' uses.
In conclusion, it is submitted that either the Gatehouse Industrial Estate should no longer be identified as a key
employment site, or alternatively the HELAA site ref. AYL078 should be excluded from identification in the Local
Plan proposals map as no longer forming part of the Gatehouse Industrial Estate as a key employment site.

S2 and table 1:

Policy S2 is supported in terms of identifying an approach to delivery of land for housing and employment growth
and development, including to meet some of the needs of adjoining highly constrained districts including
Wycombe and Chiltern/South Bucks Districts.
Nevertheless, the approach of releasing large greenfield sites for residential development to meet the needs of
Aylesbury and adjoining authorities is not justified, effective or consistent with National Policy where there is
significant previously developed land available that can deliver new homes at sustainable locations.
Aylesbury District is seeking to retain historic/ existing employment land for employment purposes where there is
no realistic or viable prospect of the land contributing towards employment development throughout the Plan
period.
Land at the Gatehouse Industrial Estate should be reviewed in light of current and permitted residential
developments at Brook Mews and Alton House and in light of the long term and persistent vacancies and
poor take up of employment land and premises.
Aylesbury Vale has not recently reviewed the ability for the Gatehouse Close Industrial Estate to contrbute
towards employment development, and it is submitted that in accordance with paragraph 22 of the NPPF land
east of the residential scheme at Alton House should be allocated for an alternative and more suitable land use
i.e. a logical and sustainable form of residential linking Alton House, with Brook Mews.

S7:

Poliy S7 is supported by Aviva. Policy S7 appropriately expects efficient and effective use of land and
encourages reuse of previously developed (brownfield) land in sustainable locations. Nevertheless, Policy S7
should be strengthened to confirm that Aylesbury Vale will encourage efficient and effective use of land, in
sustainable locations and subject to specific site considerations, ahead of release of greenfield or Green Belt
land.
Policy S7 should also be strengthened to set out how Aylesbury Vale intends to apply the emerging
requirements from the government for Council's to prepare brownfield land registers.
Paragraph 3.67 only makes reference to the emerging brownfield land register initiative. Aviva submit that
Aylesbury Vale should set out within paragrph 3.81 and policy S7 strong support for the principles of
brownfield land. Indeed, it is recommended that Aylesbury Vale should provide confirmation that a brownfield
land register will be prepared by the Council, to be informed by detailed and fresh assessment of suitable,
available and deliverable previosuly developed land, such as HELAA site ref. AYL078 - Land at Gatehouse
Close, Aylesbury.

Policy maps for Aylesbury:

Aviva object to the potential housing allocations VALP policy map inset for Aylesbury, as the map fails to identify
HELAA site ref. AYL078, land at Gatehouse Close as a potential housing allocation. HELAA site ref. AYL078
is located immediately adjacent to, and shares its eastern boundary with the now completed residential
development at Brook Mews, as well as its western boundary with the permitted residenital development at
Alton House. HELAA site ref. AYL078 also shares the same credentials as a highly sustainable location for
residential development, being within walking distance of Aylesbury town centre and railway station, as well as
the range and mix of commnity facilites and servies within and around the town centre.

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