Publication Draft

Object

Representation ID: 65704

Received: 03/07/2014

Respondent: David Lock Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst it is acknowledged that visitor accommodation in the town centre helps to support a vibrant economy it is important to ensure that Policy CT3 Protecting Existing Visitor Accommodation in Town Centres is not unduly restrictive for the following reasons:-
*Many existing hotels are in Listed Buildings that cannot meet visitor customer expectations/ are not viable to upgrade - the closure of these facilities would impact the street scene and vitality of the town centre.
*Due to the scale of existing visitor accommodation in the town centres the conversion of them would not be appropriate and would not meet the demands of potential retail operators(Use Class A1)
*In many instances it is not appropriate to convert the upper floors into retail or assembly and leisure uses (with residential being far more appropriate)
*It is considered inappropriate to subdivide the ground floor to create numerous shop frontages due to the numbers of facilities that are listed/ in conservation areas. The sub -division would have an adverse impact on the buildings and on the street scene.
*The policy is unclear and only addresses visitor accommodation in town centres (no policy about out of centre accommodation)
*The supporting text should acknowledge that in some circumstances visitor accommodation occupies the upper floors with retail uses on the ground floors
*Warwick District Tourism Strategy forms part of the Local Plan evidence base. The document does not provide any evidence on need for visitor accommodation, nor does it suggest that there have been unprecedented closures of visitor accommodation over the plan period. How can CT3 therefore be justified?

For the above reasons the policy is deemed to be unsound due to it being unjustified and possibly having the negative impact of leaving vacant buildings in the historic cores of our town centres, 'run-down' historic buildings, a lack of clarity over visitor accommodation outside town centres and a possible reduction of inward investment.