Aylesbury Vale Area

VALP Further Main Modifications

Search Representations

Results for Coal Pensions Properties Limited search

New search New search

Object

VALP Further Main Modifications

FMM085

Representation ID: 3942

Received: 09/02/2021

Respondent: Coal Pensions Properties Limited

Agent: Lichfields

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

We note, however, that within the Further Main Modifications (ref. MM186) Policy E5 continues to include
the requirement for an impact assessment threshold of 1,500 sq m for schemes that are likely to affect
Aylesbury town centre. Whilst we support the differentiation between Aylesbury and the rest of the District and the increase in the impact threshold for the former, we consider that a threshold of 2,500 sq m would be more appropriate for Aylesbury in line with the NPPF.

Change suggested by respondent:

We consider an increase to 2,500 sq m would be appropriate for the reasons set out above and in our previous Hearing Statement and Main Modification representations.

Full text:

Dear Sir/ Madam

On behalf of our client, Coal Pensions Properties Limited, we attach a representation form and accompanying letter in response to the VALP Further Main Modifications Consultation.

We trust that the attached will be of assistance prior to the adoption of the Local Plan. Please do not hesitate to contact me or my colleague Peter Wilks if you require further information regarding these comments.

Vale of Aylesbury Local Plan – Representations to the VALP Further Main
Modifications Consultation 2020-2021

On behalf of our client, Coal Pensions Properties Limited, we write in relation to the Vale of Aylesbury Local
Plan (VALP) Further Main Modifications consultation.
Coal Pensions Properties Limited is an important stakeholder in Aylesbury. Its interest relates to Broadfields Retail Park, which performs an important shopping role within Aylesbury. Our comments relate to retail uses and other main town centre development in out of centre locations (Policy E5). We previously submitted representations in relation to this draft policy, prepared a Hearing Statement and attended the Examination in Public in July 2018 on our client’s behalf as well as written representations in December 2019 in respect of the VALP Main Modifications consultation.

Policy E5 – Development outside Town Centre

Our previous representations related to the appropriateness of a 400 sq m impact assessment threshold, and the consistency of policy E5 with national planning guidance. The policy has now been significantly
simplified from the previous version, including the removal of Criterion B and we welcome this change.
We note, however, that within the Further Main Modifications (ref. MM186) Policy E5 continues to include
the requirement for an impact assessment threshold of 1,500 sq m for schemes that are likely to affect
Aylesbury town centre. Whilst we support the differentiation between Aylesbury and the rest of the District and the increase in the impact threshold for the former, we consider that a threshold of 2,500 sq m would be more appropriate for Aylesbury in line with the NPPF.
National planning guidance (paragraph 015 Reference ID: 2b-015-20190722) clearly indicates lower locally
set impact thresholds will only be appropriate where:
• the 2,500 sq.m threshold would be significant relative to Aylesbury town centre;
• Aylesbury town centre’s existing viability and vitality is particularly vulnerable;
• there have been cumulative effects of recent developments on Aylesbury town centre; and
• there are likely to be effects on Aylesbury town centre’s strategy or other planned investment.

In our view none of these very specific circumstances exists in Aylesbury, therefore an impact threshold lower than 2,500 sq m is not justified.

Conclusion
In conclusion, there is no evidence to suggest that developments under the NPPF threshold would have a significant adverse impact on Aylesbury town centre. We consider an increase to 2,500 sq m would be appropriate for the reasons set out above and in our previous Hearing Statement and Main Modification representations.
We trust that the above comments will be of assistance prior to the adoption of the Local Plan. Please do not hesitate to contact me or my colleague Peter Wilks if you require further information regarding these comments.

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