Planning and Town Centre Uses Assessment Premier Inn, Beanacre Road, Melksham

January 2019

Contents

1. Introduction 1

2. Application Site and Context 2

3. Proposed Development 5

4. Planning Policy Context 8

5. Qualitative Assessment 13

6. Sequential Assessment 19

7. Qualitative Impact Assessment 26

8. Planning Analysis 32

9. Conclusions 35

Appendix 1: Town Centre Uses Plan 37

Appendix 2: Schedule of Existing Facilities 38

Client Leekes Our reference LEET3002

January 2019

1. Introduction

1.1 This Planning and Town Centre Uses Assessment (‘PTCUA’) has been prepared by Turley on behalf of Leekes in support of a planning application for a Premier Inn and accompanying Beefeater restaurant at Beanacre Road, Melksham. The assessment addresses all relevant planning policy considerations associated with the proposed development, examines the impact of the proposed hotel and restaurant on Melksham town centre (impact test) and assesses the suitability and availability of alternative, in and edge-of-centre sites (sequential test).

Context

1.2 This assessment is intended to assist Wiltshire Council in its determination of the application and has been prepared in accordance with the requirements of the National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG). It seeks to evaluate the proposed development against national and local planning policies and considers the planning justification for the scheme. The assessment also examines the implications of the proposed development on retailing and other main town centre uses.

1.3 In respect of retail policy, the report assesses the implications of the proposed hotel and restaurant uses on the vitality and viability and future investment potential of Melksham town centre. In view of the site’s out-of-centre location, this assessment addresses the key planning policy tests of impact and the sequential approach to site selection. The assessment also includes a town centre ‘health check’ in order to give an overview of the existing hotel and restaurant provision in the town centre. This has enabled the structure and performance of the town centre to be examined and the potential effects of the proposed development to be properly evaluated.

Report Structure

1.4 The remainder of this report is set out as follows:

• Section 2 – Application Site and Proposal

• Section 3 – Policy Context

• Section 4 – Qualitative Assessment

• Section 5 – Sequential Assessment

• Section 6 – Qualitative Impact Assessment

• Section 7 – Planning Considerations

• Section 8 - Conclusions

2. Application Site and Context

Site Location and Context

2.1 The application site extends to approximately 0.45 ha and is located within the market town of Melksham along Beanacre Road. It is currently in use as part of the existing Leekes department store car park.

2.2 The Leekes store is positioned immediately to the south west of the application site, with the remainder of the store’s car park located directly south. The existing store is of significant scale, and comprises a rectangular two-storey building approximately eight metres in height to eaves level. The building, which is industrial in character, is predominantly clad in green-coloured insulated metal panels. The building entrance is characterised by a pitched-roof feature located in the centre of the building.

2.3 Dunch Lane runs along the site’s northern boundary. A large area of agricultural land is situated further to the north of the site, beyond Dunch Lane.

2.4 The mainline railway line runs from north to south along the western boundary of the Leekes site. A column of agricultural land runs to the west of the railway line, separating the site from the wider residential development further to the west and south west.

2.5 To the south east of the site beyond Beanacre Road, lies another housing estate. The dwellings are typically one to two storeys in height with a mixture of detached and semi-detached house types in a variety of styles and periods.

2.6 Two Grade II Listed buildings, Halfway Farmhouse and the Gazebo in its garden wall, are located directly to the east of the application site. Halfway House is now subdivided into three residential dwellings.

2.7 A BP petrol filling station and associated car sales & service garage and a Subway fast- food restaurant to the north of the listed buildings.

2.8 Immediately south of the site lies a number of two storey red brick industrial style buildings, occupied currently by Plumbstop and Woodpecker Furniture. Residential development, comprising three and four storey terraced dwellings, directly adjoin the industrial buildings to the south. Further south still, towards Melksham Town Centre (along Beanacre Road), are a variety of building types and uses including McDonald’s, ALDI, Bowden House B&B and Spencer Sports and Social Club.

2.9 Two Grade II listed buildings are located directly east of the site on Beanacre Road. The accompanying Historic Building Assessment prepared by Oxford Archaeology provides greater detail regarding the significance of the listed buildings and their setting, in addition to the impact of the proposal on the character of the historical asset.

2.10 The listed farmhouse is situated between modern housing and open countryside. It has been converted and subdivided, with a new house built in the garden. The complex retains its historic garden wall. Within the grounds, there is a Grade II listed building 18th-century Gazebo (on the corner by the roadside).

2.11 The historic farmhouse was built facing east across the Avon Valley, and only the end of its rear wing looks towards the development site. The listed Gazebo in the garden wall is still seen in the context of the listed farmhouse. Both are separated from the development site by a busy road. The buildings are generally viewed in the context of modern housing, the service station and the Leekes store and car park.

2.12 The site’s only vehicular access is via the west arm of the roundabout junction connecting the A350 Beanacre Road and Avon Road. Beanacre Road is a two-way single carriage road connecting to the A365 Bath Road and the A3102 Bradford Road. The network provides convenient access from the site to the centre of Melksham.

2.13 Within the curtilage of the site, the various sections of the Leekes car park are served by way of a mini-roundabout junction.

2.14 A lit, shared footway / cycleway runs along the western side of Beanacre Road. The pedestrian and cycle infrastructure provides access to key destinations including the railway station, the town centre and local bus stops.

2.15 A subway is provided under the A350 Beanacre Road, which facilitates convenient access from the site to Melksham Railway Station. Two bus stops are located within 150 metres of the site along Beanacre Road. These include the ‘Leekes’ bus stop to the south of the site (northbound and southbound) and ‘Nortree Motors’ bus stop to the north (northbound only).

2.16 Melksham Railway Station is located some 900 metres to the south of the site and is accessed by foot from the site via a network of footways and crossing facilities. This station is operated by Great Western Railway and accommodates services between Swindon and Westbury.

Planning History

2.17 The Leekes store with associated parking and roundabout access was originally granted planning permission in February 1992 (reference. W/91/01291/FUL).

2.18 Between 1993 and 2007, three planning applications were submitted on the site. References W/93/00147/FUL and W/94/01403/FUL regard access improvements, the reorganisation of Leekes car park and additional landscaping. Both applications were granted in February 1993 and November 1994, respectively.

2.19 Application reference W/07/00122/FUL was for the removal of condition 2 of original permission W/91/01291/FUL, which stated that the site should only be used for the sale of non-food goods, excluding clothing. The application was refused in February 2007.

Pre-application Advice

2.20 An extensive programme of pre-application discussions has taken place with senior officers from Wiltshire Council. The discussions aim to ensure that the application proposal delivers a successful and attractive gateway into the market town of Melksham. In October 2017, a suite of plans, photographs and elevations were submitted to the Council and are set out below. Input from the Council’s planning, urban design and conservation officers over a number of months has played a significant role in evolving and refining the scheme since initial dialogue began.

2.21 A pre-application meeting with planning and urban design officers was held in June 2018. Further advice was received regarding their views on the scale, massing and use of materials within the development proposals.

2.22 Senior officers acknowledge that the principle of proposed development at the application site is acceptable. Officers recognised that the proposals provide the opportunity to turn an un-special area of car parking into an interesting piece of built form. Detailed comments were received in respect of the design of the proposal and this dialogue with officers has resulted in a significant reassessment and evolution of the design scheme in response to officer concerns. A detailed analysis of design considerations is set out in the accompanying Design and Access Statement.

3. Proposed Development

3.1 The proposal comprises the erection of a 71 bedroom hotel to be occupied by Premier Inn and a 246 cover restaurant which will be occupied by Premier Inn’s Beefeater restaurant chain. 90 car parking spaces and a service yard are also proposed at ground floor level.

3.2 The application proposal extends to a maximum of four storeys in height, with the eastern extent of the building stepping down to three storeys. The ground floor will provide front of house and reception facilities to serve the Premier Inn hotel and will also be occupied by the 246 cover Beefeater restaurant (and associated back of house facilities). Two entrances are proposed to serve both the hotel reception and Beefeater restaurant respectively. This allows the Beefeater restaurant to serve both hotel guests and visiting members of the public. Both entrances are proposed at ground floor level and accessed from the southern elevation. The design and layout of the proposal maximises active frontage to the wider site and encourages natural surveillance.

3.3 The palette of materials chosen is derived from, but does not copy, the local vernacular. This allows the building to blend into its context. The design evolution for the proposed hotel and restaurant in addition to detailed evaluation of the final design is set out within the supporting Design and Access Statement.

3.4 The redevelopment of the application site will bring about significant regeneration benefits by providing new hotel accommodation on a currently underutilised brownfield site. The proposal will create a high quality modern development that will

positively enhance the street scene, whilst respecting the character and appearance of the wider area.

The Premier Inn and Beefeater Offer

3.5 Premier Inn, part of Whitbread Group PLC, is the largest provider of hotel bedrooms in the country with over 700 hotels across the UK and over 65,000 bedrooms. Whitbread employ over 40,000 people worldwide and are committed to sustainable, good design.

3.6 Premier Inn has an excellent reputation for affordability and quality with rooms available from around £55 per night. A typical ‘Premier Inn’ bedroom will provide the following features:

• King size bed

• En-suite bathroom with bath and shower

• WiFi

• Remote control TV with Freeview

• Tea and Coffee

3.7 In short, Premier Inn offers its customers a high quality service at budget prices, and as such they enjoy an excellent reputation in the market place.

3.8 Beefeater is a chain of over 140 pub restaurants in the UK and is also owned by Whitbread. The Beefeater brand has developed over the past 40 years and is positioned upmarket of Whitbread’s Brewers Fayre chain. The proposed restaurant is intended for hotel guests and the general public.

3.9 In addition to this Planning Statement, the application should be read alongside the supporting application drawing and technical reports, including:

• Economic Benefit Statement, prepared by Turley Economics;

• Transport Assessment, prepared by RGP;

• Travel Plan, prepared by RGP;

• Delivery and Service Management Plan, prepared by RGP; and,

• Heritage Assessment prepared by Oxford Archaeology.

4. Planning Policy Context

4.1 The following section provides a summary of key policies in the development plan and national planning guidance relevant to the consideration of main town centre uses proposed in this application.

4.2 The interpretation of the sequential test, based on policy and recent ‘case law’ is considered in further detail in Section 5 below.

Development Plan

4.3 The development plan comprises the Adopted Wiltshire Core Strategy (January 2015) which provides the overarching planning policy framework for Wiltshire for the period up to 2026.

Wiltshire Core Strategy 4.4 CP1 – Settlement Strategy – identifies the settlement hierarchy where sustainable development will take place, including Principal Settlements, Market Towns, Local Service Centres and Large and Small Villages. The policy identifies Melksham as a Market Town which is considered to have the potential for significant development.

4.5 CP2 – Delivery Strategy – seeks to deliver development in Wiltshire in the most suitable manner. Within the limits of development as defined on the proposals map, sustainable development is favoured at the Principal Settlements, Market Towns, Local Service Centres and Large Villages.

4.6 CP3 – Infrastructure Requirements – states that all new development will be required to provide for the necessary on-site and, where appropriate, off-site infrastructure requirements arising from the proposal. Infrastructure requirements will be delivered directly by the developer and/or through an appropriate financial contribution prior to, or in conjunction with, new development.

4.7 CP15 – Spatial Strategy: Melksham Community Area – stipulates that development in the Melksham Community Area should be in accordance with the Settlement Strategy set out in Core Policy 1. Development proposals will need to demonstrate consideration for the specific issues relevant to the Melksham Community Area.

4.8 CP38 – Retail and Leisure – requires all proposals for retail or leisure uses on sites not within a town centre in excess of 200 sq. m gross floorspace to be accompanied by an impact assessment which should assess the implications of the proposal for the viability or viability of any nearby centres. Proposals must also comply with the sequential approach.

4.9 CP39 – Tourism development – is supportive of appropriate tourist development within the Principal Settlements and Market Towns (including tourist accommodation) subject to the sequential test.

4.10 CP40 – Hotels – states that proposals for new hotels will be supported within Principal Settlements and Market Towns. The policy requires proposals to demonstrate that they will not have a detrimental impact on the vitality of town centres.

4.11 CP57 – Ensuring high quality design and place shaping – states that a high standard of design is required in all new developments, including extensions, alterations, and changes of use of existing buildings. Applications for new development must be accompanied by appropriate information to demonstrate how the proposal will make a positive contribution to the character of Wiltshire. This includes having regard for adjoining buildings and uses, and responding positively to the existing townscape and landscape features in terms building layouts, built form, height, mass, scale, building line, plot size, elevational design, materials, streetscape and rooflines.

4.12 CP58 – Ensuring the conversation of the historic environment - Development should protect, conserve and where possible enhance the historic environment.

Wiltshire Local Transport Plan 2011-2026 Car Parking Strategy 4.13 The Strategy outlines strategic objectives for car parking in Wiltshire. These include supporting the vitality, viability and resilience of Wiltshire’s economy and market towns; providing, supporting and promoting sustainable transport, and ensuring that new developments adequately provide for sustainable transport requirements and mitigate traffic impacts.

4.14 PS4 – Private non-residential parking standards – states that the provision of parking associated with new private non-residential development will be limited to maximum parking standards. The actual parking provision for developments will be negotiated between the council and developers taking account of a range of issues including the mix of land uses, ancillary uses, scale of development and approach to design.

4.15 PS5 – Managing publicly available private non-residential parking – states that there will be a presumption that any planning application which includes provision for publicly available private non-residential parking will be required to provide an accompanying car park management plan.

National Planning Policy Framework (NPPF)

4.16 The National Planning Policy Framework (NPPF) and accompanying Planning Practice Guidance (PPG) set out the Government’s planning policies for England. Both are focussed on a policy commitment to sustainable development. In addition to a social and environment objective, the planning system has an economic objective (paragraph 8 (a)):

“an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure.”

4.17 At the heart of the NPPF is a presumption in favour of sustainable development, which requires local authorities to adopt a positive approach in order to seek opportunities to meet the development needs of their area.

Ensuring the Vitality of Town Centres 4.18 National policy applying to proposals involving main town centre uses is set out at paragraphs 85-90 of the NPPF. Hotels and restaurants fall within the definition of ‘tourism’ and ‘retail’ development respectively. Both are defined as ‘main town centre uses’ within Annex 2 of the NPPF. Paragraph 86 confirms that local authorities should apply a ‘sequential test’ to planning applications for main town centre uses that are not in an existing centre and are not in accordance with an up-to-date Local Plan.

4.19 Proposals for main town centre uses are required to be located in town centres, then edge-of-centre locations, and only if suitable sites are not available within a reasonable period should out-of-centre sites be considered. The NPPF advises that in considering edge and out-of-centre sites, preference should be given to sites that are accessible and well connected to the town centre.

4.20 Town centres are defined in the NPPF as city, town, district and local centres, but exclude small parades of shops of purely neighbourhood significance. The relevant area is to be defined on the local authority policies map, including the Primary Shopping Area (‘PSA’) and areas predominantly occupied by main town centre uses within or adjacent to the PSA.

4.21 Paragraph 89 of the NPPF confirms that when assessing retail and leisure proposals outside town centres, local planning authorities should require an impact assessment if the development is over a proportionate, locally set floorspace threshold. If there is no threshold, the NPPF confirms that the default threshold of 2,500 sq. m will apply. No specific reference is made to hotel developments.

4.22 Where impact assessments are required, policy relating to retail impact has been simplified in the NPPF to reference two criteria only: impacts on existing, committed and planned public and private investment in the centres within the catchment area of the proposal; and impacts on town centre vitality and viability, including local consumer choice and trade in the town centre and wider retail catchment (as applicable to the scale and nature of the scheme).

Planning Practice Guidance

4.23 The Planning Practice Guidance (PPG) provides further guidance in support of the NPPF relating to aspects of the impact test, town centre ‘heath checks’ and the application of the sequential test.

4.24 Para 005 identifies the relevant indicators in assessing the health of town centres. These are as follows:

• diversity of uses • proportion of vacant street level property • commercial yields on non-domestic property

• customers’ views and behaviour • retailer representation and intentions to change representation • commercial rents • pedestrian flows • accessibility • perception of safety and occurrence of crime • state of town centre environmental quality

4.25 In relation to tourism development, para 007 makes clear that local authorities should, among a number of criteria:

• Consider the specific needs of the tourist industry, including particular locational or operational requirements;

• Examine the broader social, economic and environmental impacts of tourism; and

• Analyse the opportunities for tourism to support local services, vibrancy and enhance the built environment.

4.26 In terms of the application of the sequential approach, the test should be proportionate and appropriate for a given proposal. Consideration should be given to scope for flexibility in the format and/or scale of the proposal (para 010). Para 011 states that the sequential test should recognise that some town centre uses may have particular market and locational requirements which mean that they may only be accommodated in specific locations. Local authorities also need to be realistic and flexible in terms of their expectations (para 012).

4.27 The impact test does not apply to all main town centre uses, only retail and leisure development (para 013). The impact test should be undertaken in a proportionate and locally appropriate way, drawing on existing information where possible (para 015). As a guiding principle, para 016 states that impact should be assessed on a like-for-like basis in respect of that particular sector. In considering the impact upon planned investment, key considerations include:

• the policy status of the investment (i.e. whether it is outlined in the Development Plan);

• the progress made towards securing the investment (for example if contracts are established); and

• the extent to which an application is likely to undermine planned developments or investments based on the effects on current/ forecast turnovers, operator demand and investor confidence.

4.28 The guidance sets out a checklist for undertaking an impact test, however the methodology provided relates primarily to retail impact assessments rather than leisure or hotel assessments.

Policy Summary

Development Plan Policies 4.29 Core Strategy Policies CP1, CP2 and CP15 outline the position of Melksham in the settlement hierarchy as a market town. Market towns have the potential for significant development to be delivered sustainably.

4.30 Policy CP57 stipulates that high quality design is required for all developments which should have regard to the compatibility with neighbouring uses and the existing townscape.

4.31 The Wiltshire Local Transport Plan 2011-2026 Car Parking Strategy policies PS4 and PS5 outline requirements for the provision and management of private non-residential parking. The policies stipulate that parking provision for developments will be negotiated between the Council and the developers. Provision for publicly available private non-residential parking will be required to provide an accompanying car park management plan.

Hotel and Retail Policies 4.32 Paragraph 89 of the NPPF makes it clear that the impact test only applies to retail and leisure uses. Whilst hotels are defined as main town centre uses, they fall within the definition of ‘tourism development’ (as set out in NPPF Annex 2).

4.33 In addition, the NPPF confirms that when assessing retail and leisure proposals outside town centres, local planning authorities should require an impact assessment if the development is over a proportionate, locally set floorspace threshold. In this instance, the local threshold for retail proposals, as established in Policy CP38 of the Core Strategy, is 200 sq. m gross floorspace.

4.34 Whilst Core Strategy Policies CP39 and CP40 are supportive of tourism development (i.e. hotels) within Market Towns, they require applicants to demonstrate compliance with the sequential and impact tests.

4.35 As a result of the policy review, it is identified that the proposed development should be subject to the following town centre policy requirements:

• Sequential site assessment of the proposed hotel and restaurant elements of the development (CP38 and CP39); and

• Impact assessment of the hotel and restaurant elements of the development (CP38 and CP40).

5. Qualitative Assessment

5.1 This chapter establishes the baseline health, performance and structure of Melksham town centre, and assists in determining the impact of the application proposal on town centre vitality and viability and future investment.

5.2 Information relating to PPG indicators is set out below. This assessment draws on an occupancy survey undertaken by Turley in September 2018, as well as data published by Experian Goad, CoStar and other published resources.

Melksham Town Centre

Overview 5.3 Melksham is a market town, as identified in Core Policy 1 of the Wiltshire Core Strategy, located approximately 7 km north east of Trowbridge, 10 km south of Chippenham and 15 km east of Bath.

5.4 Melksham has a modest-sized town centre. The townscape benefits from traditional building types, generally of between two and three storeys, with larger modern retail stores to the north of the centre. The primary shopping streets include Bath Road, Bank Street, Lowbourne, High Street, Church Street and Market Place.

5.5 Anecdotally Melksham town centre appears to be busy, particularly on High Street where the primary shopping frontage is comprised mostly of comparison, restaurant/café and service uses. Melksham also benefits from a market which takes place every Tuesday, where a selection of comparison and convenience goods stalls are located along Market Place.

5.6 The town centre comprises a good mixture of independent stores, major retailers and nationally recognised brands; such as Boots, Savers, Peacocks and Costa.

Diversity of Uses 5.7 The table below illustrates the diversity of uses represented within Melksham town centre at the time of the survey in September 2018. An updated Goad land use plan of the centre from September 2018 can be found in Appendix 1.

Table 5.1: Melksham Town Centre – Retail Composition (September 2018)

Use Class No. of Units % A1 Retail Convenience 10 6.37 A1 Retail Comparison 53 33.76 A1 Retail Other 15 9.55 Total A1 Retail Units 78 49.68 A2 Financial/Professional 22 14.01 Services A3-5 Food and Drink 31 19.75

Total Non-Retail Units 53 33.76 Sui Generis 9 5.73 Vacant 7 4.46 Other 10 6.37 Total Other 26 16.56 Total 157 100.00

5.8 As Table 4.1 above illustrates, Class A1 comparison goods retailers represent the principle town centre use, accounting for 33.76% of all units. This is higher than the Goad national average (April 2018) for comparison outlets of 30.82%. The majority of these units are independent boutique-style stores and homeware retailers. Key attractors in the comparison goods sector are Boots, Peacocks and Savers. In view of the centre’s limited size and function, higher order or design/fashion retailers are largely absent. These are mostly located in the larger centres such as Chippenham, situated 10 km to the north of Melksham.

5.9 The proportion of convenience goods retailers is 6.37% and is below the national average (April 2018) of 8.92%; however, Melksham benefits from two large supermarkets in the north of the town centre - Sainsbury’s and Waitrose, together with an Iceland store (frozen food) on Avon Place. The town centre also contains a limited range of small, independent convenience retailers, including butchers and bakers, enhancing consumer choice.

5.10 Situated just north of the town centre boundary are a further three supermarkets: Asda, ALDI and Lidl. Melksham therefore benefits from a wider range of convenience retailers and offers consumers a considerable choice in food and grocery shopping opportunities.

5.11 The proportion of other retail uses, including hairdressers/barbers and beauty and health facilities, accounts for 9.55% of Melksham’s town centre units. This is significantly lower than the Goad (April, 2018) average of 14.51%.

5.12 Melksham town centre also includes a number of cafés, takeaways, restaurants and public houses, accounting for 20.38% of town centre units (Table 5.1). This is lower than the national average (April 2018) of 23.98%. The majority of café and restaurant uses are independent brands, with the exception of Costa on High Street.

5.13 Melksham contains a number of independent restaurants which are well dispersed throughout the town centre. The largest, Refa Tandoori, is located to the south of the centre on King Street, and offers a mixture of Indian and Bangladeshi cuisine. A second Indian restaurant, Melksham Tandoori, is also located in the town centre on Church Street. Two Italian restaurants are located on Bath Road and Bank Street: Alba Ristorante Italiano and Casa la Cucina Italiana respectively. Henry’s of Melksham is located on High Street and offers a range of gastro-pub style food. The town centre includes no nationally branded restaurants of the type proposed in this application.

5.14 Melksham town centre is also served by a large number of financial and professional services, including solicitors, estate agents and a major bank, accounting for 14.01% of all town centre units. However, this has decreased over the last 18 months due to the nationwide closure of major bank branches, including HSBC and NatWest.

5.15 The unit vacancy rate across Melksham town centre of 4.46% is significantly lower than the Goad national average of 11.21% (April, 2018). This is considered in further detail below (see Proportion of Vacant Street Level Property).

5.16 Only one hotel is present in Melksham town centre. The ground floor of The King’s Arms is currently in use as a public house, with accommodation located on the upper floors.

5.17 This analysis demonstrates that the main use in Melksham town centre is independent comparison retailing. Some nationally recognisable retailers are present, including Boots, Peacocks and Savers. Melksham is also well represented in professional services, retail service uses and food and drink services. Convenience retailing within the centre is under-represented in comparison with the UK average (April 2018). However, additional major retailers are located immediately north of the town centre, the closest being Lidl approximately 170 m from the centre boundary. Melksham’s convenience shopping needs are therefore well catered for.

Retailer Representation 5.18 Considering Melksham’s modest size and function, the town centre is reasonably well represented by ‘key attractors’ as defined by Experian Goad (April 2018). Of the 31 retailers identified as ‘key attractors’, 3 are currently trading in Melksham town centre: Boots, Sainsbury’s and Waitrose.

5.19 While not identified as key attractors by Experian, other multiple retailers represented, including Savers, Peacocks and Poundstretcher, are recognised as popular ‘retail brands’ that attract customers to the town centre.

5.20 Melksham town centre lacks ‘high-end’ comparison goods retailers and large department stores typically found in regional or metropolitan locations. The centre lacks the critical mass and catchment population necessary to sustain high order retailing, but contains a good mix of retail and service uses commensurate with it scale and function. The nearest locations that provide a selection of ‘key attractors’ as identified by Goad are Bath and Chippenham, located 15 km west and 10 km north of Melksham respectively.

Proportion of Vacant Street Level Property 5.21 There are currently (September 2018) 6 vacant units within the town centre, accounting for 4.46% of all town centre uses. This is significantly below the Goad average of 11.21% (April 2018).

5.22 The vacant units are located predominantly to the north of the town centre along Bank Street and High Street. The two largest vacant uses are 32 and 34 High Street, formerly HSBC and NatWest bank branches. The remainder of the vacant units are relatively small and are unsuitable for operators seeking larger units.

5.23 Vacancies and the ‘natural turnover’ of the stock of floorspace in response to market factors is a feature of all shopping locations. There are rarely circumstances where no vacancies are found within a centre at a given point in time. In this case, the vacancy level is considerably lower than the UK average, an indicator of high occupier demand and robust overall performance. Recent bank branch closures have also artificially increased the vacancy rate, further indicative of good trading performance.

Commercial Yields and Rental Values 5.24 Average retail rents in Melksham town centre are currently £244/sq. m. (£22.67/sq. ft.) based on data from CoStar (October 2018). This compares with an average retail rent of £197/sq. m. (£18.34/sq. ft.) for the Wiltshire County submarket area. The average rental values for the town centre reflect the higher order size and status of the centre in the shopping hierarchy relative to retail destinations in Wiltshire as a whole.

Pedestrian Flows 5.25 From observation, Melksham town centre is relatively busy, with the majority of pedestrian activity on High Street and Bank Street. Vehicular activity is also at its greatest within these areas. The town centre also benefits from multiple well- maintained road crossings and small pedestrianised areas.

Accessibility 5.26 Melksham town centre is compact and easily accessible on foot.

5.27 Across the majority of the town centre, pavements are wide and flat to allow for unhindered pushchair and wheelchair access.

5.28 The town centre benefits from five main car parks:

 Church Street Car Park – 131 spaces;

 King Street Car Park – 84 spaces;

 Bath Road Car Park – 68 spaces;

 Lowbourne East Car Park – 66 spaces; and

 Union Street Car Park – 25 spaces.

5.29 The town centre is relatively well served by car parks. At the time of our September 2018 survey, the car parks appeared to be well used and charge competitive rates for long or short stay parking.

5.30 The town is well serviced by public transport. Numerous bus stops are located within, and adjacent to, the town centre. These include Melksham town centre, Market Place, Lowbourne, The Bear public house and Avonside Enterprise Park. There are regular bus services to the surrounding areas, as well as Chippenham, Trowbridge and Bath.

5.31 Melksham train station is located approximately 640 m north west of the town centre, with a regular bus service available between the centre and the station. The train station provides direct services to destinations such as Swindon and Trowbridge.

Consumer Opinions 5.32 We are not aware of any up-to-date information that provides an insight into customer views and opinions. As noted previously, the town centre appears to be popular and busy, notwithstanding the low to middle market emphasis of the retail offer.

Perceptions of Safety and Occurrence of Crime 5.33 In July 2018, there were 31 reported crimes within Melksham town centre, compared to 38 in July 2017 and 36 in July 2016 (source: Police.uk). The majority of crime relates to anti-social behaviour, violence and sexual offences. The level of reported crime has therefore remained relatively consistent over the last three years.

5.34 Crime and fear of crime do not appear to be a disincentive to people visiting the town centre. There is limited evidence, for example, of graffiti and damage to property. Overall, the shopping environment is concluded to be ‘safe’ on the basis of available evidence.

Environmental Quality 5.35 Melksham’s town centre environmental quality is ‘reasonable’, with only a limited number of shop units exhibiting signs of disrepair. Positive features include traditional buildings, pedestrianised courtyards and well-maintained pavements and pedestrian crossings. The town also benefits from several Listed Buildings, including Melksham Town Hall and The King’s Arms. However, very limited green open space is present within the centre, and the quantity of street furniture would benefit from improvement.

5.36 The majority of shop frontages and their signage are in relatively good condition, although some branding is dated and in need of upgrading.

Conclusion 5.37 The key findings of our assessment of the town centre’s vitality and viability are:

 Comparison retailing represents the main town centre use. The centre contains a reasonable range and mix of low to mid-range comparison sector operators.

 The proportion of convenience goods retailing is lower than the national average, however, three additional national supermarkets are situated adjacent to the town centre. Melksham therefore benefits from a wide range and mix of high to low order, national and independent retailers which are capable of meeting day-to-day shopping needs.

 The town centre also benefits from a number of independent cafés, restaurants and public houses. Accommodation is currently only available in one town centre location (The King’s Arms public house). Melksham market, which takes place every Tuesday, also acts a key attractor to the south of the centre each week.

 The level of vacant properties within the town centre is significantly lower than the Goad national average. The vacant units are relatively well dispersed and range in size, although one concentration of vacancies is evident, namely the former HSBC and NatWest banks.

 The town centre is easily accessible by car, with ample car parking available for shoppers. The centre also benefits from good public transport links. Melksham town centre offers visitors a safe shopping environment.

 The shopping environment is of generally reasonable quality, although a number of shopfronts appear outdated and some secondary areas are lacking in environmental quality. These units would benefit from environmental enhancement and upgrading.

 Overall, we conclude that Melksham town centre primarily acts as a comparison goods retail destination with an ancillary convenience goods and service role. Independent comparison stores and cafés are attractors to the centre, in addition to the pleasant shopping environment provided by pedestrianised courtyards and Listed Buildings.

6. Sequential Assessment

6.1 This section of the report applies the sequential test to the application proposal, as required by the development plan and NPPF.

6.2 The application proposes main town centre uses (hotel and A3 restaurant) in an out-of- centre location. As required by policy, we have assessed the suitability and availability of alternative in and edge-of-centre locations, focussing on sites within and adjacent to Melksham town centre.

6.3 We refer to assessments undertaken in connection with other hotel developments in Melksham (Land at Commerce Road, Melksham and land adjacent to Commerce Way, Melksham), and the consideration of this evidence by the LPA, as part of our sequential analysis below.

Policy

Development Plan

6.4 The application involves main town centre uses as defined in the NPPF (Annex 2). For the purposes of assessment against development plan policy, the relevant policies are those that relate to retail, leisure and tourist development.

6.5 Core Policy 38 (‘Retail and Leisure’) of the adopted Wiltshire Core Strategy (January 2015) requires retail and leisure proposals in excess of 200 sq. m. gross to comply with the sequential approach, as set out in national guidance, ‘to ensure that development is on the most central site available’.

6.6 Core Policy 39 (‘Tourist Development’) indicates that within principal settlements and market towns, proposals for tourist development of an appropriate scale, will be supported (our emphasis), ‘subject to a sequential assessment’.

6.7 Melksham is defined as a ‘market town’ in the Core Strategy (Core Policy 2). The application proposals therefore benefits from in-principle policy support by virtue of its location within a market town, subject to impact and sequential testing. Policy support for hotels proposed within principal settlements and market towns is further emphasised in Core Policy 40 (‘Hotels, bed and breakfasts, guest houses and conference facilities’).

The National Planning Policy Framework (NPPF)

6.8 The NPPF requires local authorities to apply a sequential test to applications for main town centre uses that are neither in an existing centre, nor in accordance with an up- to-date plan.

6.9 The application of the test has two key requirements: the assessment (of alternative sites) must follow a specified locational sequence; and applicants and local planning authorities must demonstrate flexibility on issues such as format and scale. These matters are explained at NPPF paragraphs 86 and 87:

‘Local planning authorities should apply a sequential test to planning applications for main town centre which are neither in an existing centre nor in accordance with an up-to-date plan. Main town centre uses should be located in town centres, then in edge-of-centre locations; and only if suitable sites are not available (or expected to become available within a reasonable period) should out-of-centre sites be considered.

When considering edge of centre and out of centre proposals, preference should be given to accessible sites which are well connected to the town centre. Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale, so that opportunities to utilise suitable town centre or edge of centre sites are fully explored’.

6.10 The accompanying Planning Practice Guidance (PPG) confirms that it is for the applicant to demonstrate compliance with the sequential test (PPG, Paragraph 010 Reference ID: 2b-010-20140306).

6.11 In relation to the key issue of ‘flexibility’, the PPG states that it is not necessary to demonstrate that a potential town centre or edge-of-centre site can accommodate precisely the scale and form of development being proposed (PPG, Paragraph 010 Ref ID: 2b-010-20140306). Disaggregation of the development into its component parts is not a requirement of the sequential test.

Interpreting the Sequential Test

6.12 The application of the sequential test has been considered in a number of key cases, including Supreme and High Court Judgments and planning decisions made by the Secretary of State.

6.13 ‘Flexibility’ has been a central issue in these cases, in particular the extent to which applicants can be reasonably expected to modify or amend proposals when assessing alternative, sequentially preferable sites.

6.14 The principal cases are summarised below.

Legal Judgments

‘Dundee’ (2012) 6.15 In ‘Tesco v. Dundee’, the Supreme Court considered the objective interpretation of a development plan policy. This required an assessment of availability and suitability of sites.

6.16 This case established that the sequential test should be applied in a real world context (the world in which developers wish to operate), and not, ‘some artificial world in which they have no interest in doing so’. The Judgment confirmed that ‘suitable’ in the context of the sequential test means suitable for the development proposed by the applicant, subject to the qualification that flexibility and realism must be shown by developers.

‘Cotswold’ (2016) 6.17 This Judgment of the Court of Appeal – Warners Retail (Moreton) Ltd v. Cotswold District Council – concerned the interpretation of the sequential test in the NPPF (paragraph 24) and in previous practice guidance (PPS4 companion guide – now superseded).

6.18 The Judgment established that whilst applicants are expected to demonstrate flexibility on issues such as ‘format and scale’, the bounds to be set on the applicant’s preferences depend on the facts and circumstances of a particular case. The policy at paragraph 24 of the NPPF is not prescriptive in this respect.

6.19 The Judgment confirmed that sites should not be rejected on the strengths of the self- imposed requirements of a single operator.

‘Mansfield’ (2016) 6.20 This decision of the High Court related to a challenge to the granting of planning permission for an out-of-centre ALDI store by Mansfield District Council.

6.21 In relation to paragraph 24 of the NPPF, the Judgment established that ‘suitable’ and ‘available’ generally mean suitable and available for the broad type of development which is proposed in the application by approximate size, type and range of goods. This incorporates the requirement for flexibility (in the NPPF), and excludes, generally, the identity and personal or corporate attitudes of an individual retailer. The Judgment emphasised that paragraph 24 of the NPPF cannot be interpreted as requiring suitability and availability simply to be judged from the retailer’s or developer’s perspective.

6.22 This case also established that ‘available’ means available for the type of retail use for which permission is sought, not available to a particular retailer.

Secretary of State Planning Decisions

‘Rushden Lakes’ (2014) 6.23 This decision of the Secretary of State related to a major, mixed use proposal which included main town centre uses. The decision reiterated the matters established by ‘Dundee’. The decision confirmed that applicants are not required to disaggregate developments when applying the sequential test.

‘Exeter’ (2016) 6.24 This decision of the Secretary of State concerned an out-of-centre mixed-use proposal, including main town centre uses, at Honiton Road, Exeter. The Inspector accepted the Inspector’s recommendation and dismissed the appeal.

6.25 The existence of a sequentially preferable site – the Exeter Bus and Coach Station (‘BCS’) – was a central factor. This site was considered available and suitable ‘given no more than reasonable flexibility over the arrangement of the units, the use of existing access and parking, and the occupier of the proposed gym….’

6.26 The Secretary of State accepted the Inspector’s reasoning that there is no rationale for concluding that the site must be on the open market to any developer, and that the

new retail floorspace would be marketed to traders who occupy it regardless of who developed or owned the scheme. He further agreed with the conclusion that the requirement for a bus station or leisure outlet on another part of the BCS site did not mean that the area earmarked for retail development was not available.

Key Issues

6.27 On the basis of the policy position and guidance relating to the sequential test as set out above, and the interpretation of policy in these cases, the following matters are material in this case:

• The sequential test applies by virtue of the proposal’s out-of-centre location.

• ‘Suitable’ and ‘available’ generally mean suitable and available for the broad type of development which is proposed in the application by approximate size, type and range of goods. Availability for the type of retail/main town centre uses, not retailer or developer, is key.

• The owner or developer of a scheme is not material; the scheme can be marketed to occupiers irrespective of ownership or control.

• Disaggregation of a development into its component parts is not a requirement of the sequential test, and this has been underlined by the Courts. The sequential approach therefore applies to the totality of the development (with appropriate allowance for flexibility) and not to its individual components on a solus basis.

• The sequential test is intended to operate in a ‘real world’ context (i.e. the world in which developers wish to operate).

Recent Assessments in Melksham

6.28 Planning permission has been granted for out-of-centre hotels and ancillary development in Melksham at Commerce Road and at land adjacent to Commerce Way. These proposals were supported by sequential assessments undertaken by ‘Walsingham Planning’ (proposal by ‘Hall and Woodhouse’) and ‘DPP’ (‘Travelodge’).

6.29 DPP’s analysis (September 2016) drew upon the earlier comprehensive assessment undertaken by Walsingham Planning (October 2012). DPP concluded that that there were no sites available (in 2016), either within or adjacent to the town centre, capable of accommodating all three elements of the proposed development (paragraph 5.14). DPP’s assessment was based on an application site area of 0.45 hectares and a site search parameter (with allowance for flexibility) of 0.4 hectares.

6.30 DPP’s conclusion was supported by the Council in granting planning permission for a Travelodge, retail unit and drive-thru coffee shop at Commerce Way. The conclusions of the Officer Report’s (‘OR’) in relation to sequential test compliance were as follows:

‘The local planning authority considers the assessment that was undertaken to be acceptable. Taking into account the NPPF requirements to demonstrate

flexibility on issues such as format and scale the applicants reduced the size of sites in the search to 0.4ha as opposed to the 0.45ha available at the proposal site. A suitable range of sites were considered within Melksham town centre using both existing research done in 2012 by Hall and Woodhouse and current research done by the applicants……An appropriate assessment as (sic) therefore been conducted’.

6.31 On the basis of our updated assessment, there has been no material change in circumstances that would lead to a different conclusion being drawn in this case. There continue to be no alternative sequentially preferable sites (to the current Premier Inn application site) in Melksham, and none are likely to become available within a ‘reasonable period’.

Sequential Assessment - Parameters

6.32 The application proposal forms the primary basis for an assessment of alternative sites. Planning permission is sought for a 71 bedroom Premier Inn hotel and 246 cover restaurant together with 90 car parking spaces and service yard.

6.33 In common with Travelodge, the application site extends to 0.45ha. Adopting an approach found to be acceptable by the Council in its determination of the Travelodge application and allowing for flexibility in format and scale, we have based our search for alternative sites on an identical site area of 0.4ha.

Alternative Sites’ Assessment

6.34 Walsingham Planning (‘WP’) considered 14 sites in Melksham town centre in 2012. This assessment also related to an application site (Commercial Road) with an area of 0.45ha. These sites were re-assessed by DPP in 2016 and further research undertaken (although the additional sites considered by DPP are not specified in the 2016 report).

6.35 DPP noted that 8 of the 14 sites assessed by WP were in active use either as car parks serving the town centre generally (public car parks at King Street, Lowbourne, Union Street and Church Street) or commercial businesses (Sainsbury’s and Waitrose). In addition to lack of availability, WP dismissed a number of these sites for other reasons, including lack of frontage (King Street) and scale/too small (Union Street).

6.36 DPP considered the (then) availability of these sites in 2016. DPP noted that none of the public car parks had been declared surplus to requirements by the Council and offered to the market for disposal; and that the private car parks serving Sainsbury’s and Waitrose did not represent realistic development opportunities.

6.37 We have re-visited the WP assessment and considered current site availability. From the evidence available there has been no material change in circumstances: the public car parks continue to be in active use and unavailable; and the supermarket car parks are needed to serve private commercial interests and are accordingly unrealistic as alternative locations. These 8 sites can be dismissed as sequentially preferable alternatives.

6.38 Of the remaining 6 sites (Poulsons Yard, Bank Street, the Riverside Community Leisure Club, the Church Walk Telephone Exchange, the Scout and Guide Centre, and the County Glass/Lighting Store), DPP noted that only the latter two were of sufficient size (c. 0.4ha and larger) to accommodate the proposed Travelodge. Other constraints existed, however, as highlighted by WP, which resulted in their dismissal as sequentially preferable alternatives.

6.39 The Scout and Guide Centre was unavailable and its development would lead to the loss of a community facility; the County Glass/Lighting Store was in active commercial use and unavailable. Whilst of sufficient size, neither site was suitable or available. Various other constraints were identified by WP in respect of the other 4 sites (Bank Street, for example, being considered an inappropriate location for a restaurant and therefore unsuitable).

6.40 From our review of this material and more recent evidence, these assessments remain valid. None of the additional 6 sites currently represent sequentially preferable alternatives (to the application site).

Updated Assessment

6.41 We have undertaken an updated assessment based on site visits to Melksham town centre (a ‘walking survey’); an inspection of town centre maps; and a review of current town centre vacant units. The latter and their respective sizes are set out in Table 5.1.

Table 6.1: Vacant Units within Melksham Town Centre (September 2018)

Address Unit Size (sq m gross) 24 Bank Street 80 34 High Street 210 32 High Street 150 16-18 Market Place 90 16 High Street 90 7 Lowbourne Street 190 51 Union Street 60

6.42 From this analysis we are unable to identify any additional, sequentially preferable sites within or adjacent to Melksham town centre. Vacant units are of insufficient size and are therefore unsuitable (the largest – 34 High Street – extending to 210 sq. m. only).

6.43 The conclusions of the earlier WP and DPP assessments therefore continue to be appropriate and robust.

Conclusion

6.44 On the basis of our assessment of alternative sites; assessments by WP and DPP; extant development plan and national policy; and the key issues highlighted above (paragraph 5.27); we conclude that there are no alternative suitable sites within or adjacent to Melksham town centre that are currently available, or likely to become available in a reasonable time. Additionally, Core Strategy policies CP39 and CP40 provide in- principle support for the proposals.

6.45 The application proposal passes the sequential test and is a policy compliant development in respect of its locational characteristics.

7. Qualitative Impact Assessment

7.1 The National Planning Policy Framework (‘NPPF’) is concerned with protecting the overall vitality and viability and future investment prospects of town centres, which may experience impacts from out-of-centre retail and leisure development proposals. As hotels primarily cater for tourism, it is not a formal policy requirement of the NPPF to assess the impact of the Premier Inn proposal on Melksham town centre.

7.2 However, Core Strategy Policies CP38 and CP40 stipulate that an impact assessment is required with the application which demonstrates that the restaurant and hotel elements of the proposal will not harm the vitality and viability of Melksham town centre.

The Premier Inn Offer

7.3 Premier Inn, part of Whitbread Group Plc, is the largest provider of hotel bedrooms in the country with over 700 hotels across the UK and over 65,000 bedrooms. Premier Inn offers a high standard of overnight accommodation at a modest price. Premier Inn guarantees a full refund if any guest is not satisfied with their accommodation.

7.4 All Premier Inn rooms offer:

• King sized beds

• Good quality duvets & pillows

• En-suite bathrooms

• Shower gel

• Remote control TVs

• Tea & Coffee making facilities

• Hairdryer

• Heater Control

• Desk area

• Internet & broadband access

7.5 Premier Inns also offer:

• Family bedrooms

• Restaurant and licensed bar

• Cots (on request)

• 24 hour reception

7.6 Premier Inns are generally busier during Monday-Thursday when many guests are travelling for business. Across the whole estate, 60% of all Premier Inn guests are business travellers. The average guest stay is 1.59 days and the average room occupancy across the estate is 1.75 sleepers (based on the past 12 months).

7.7 In addition to conventional booking arrangements, Premier Inn has a web-based booking system which receives over 1.5 million visitors each month. Potential guests are able to book by searching for hotels by destination and postcode. The website offers immediate and up-to-date information on room availability and prices across the country.

7.8 In summary, Premier Inn accommodation is reasonably priced, easy to book online and ideal for business travellers and tourists who expect a level of consistency between hotels. It also offers a high level of service and guarantee of a full refund if any guest is not satisfied with their accommodation. This level of high quality service and accommodation, and consistency across the brand, acts as a major attractor and a source of repeat custom to Premier Inn.

Beefeater

7.9 Beefeater is a chain of over 140 pub restaurants in the UK owned by Whitbread. The Beefeater brand has developed over the past 40 years and is positioned upmarket of Whitbread’s Brewers Fayre chain.

7.10 Beefeater restaurants have been described as ‘warm, modern and stylish’ and have open plan grill areas so that customers can see meals being prepared. Beefeater restaurants also have bespoke menus for children and a limited selection of dishes which extend beyond grilled meats.

7.11 In the case of the application proposal, the Beefeater will provide 246 covers and will be located at ground floor level beneath the proposed Premier Inn hotel. The restaurant will open for breakfasts to serve both Premier Inn guests and the public, and will provide the food, beverage and lounge facilities for overnight hotel guests.

Trade Overlap with Existing Town Centre

7.12 Impacts only arise where new and existing developments compete directly (the well- established ‘like-for-like’ impact principle contained within the PPG, para 016). Where a proposal caters for or establishes a new segment or sub-sector of the market; or which explicitly excludes services offered by competitors (such as function space); trade diversion and impacts are lower (or zero if there is no ‘trading overlap’).

7.13 In examining the impact of the proposed development on Melksham town centre, it is therefore important to understand the likely ‘trade overlap’ of the proposed Premier Inn hotel and Beefeater restaurant with existing hotel accommodation and restaurants within the town centre; and establish whether direct competition would arise.

7.14 Details of existing accommodation and the food and beverage offer of Melksham town centre are detailed below. This provides a basis on which to assess the qualitative impact of the development proposal. Our analysis and conclusions are set out below.

Hotel Accommodation within Melksham 7.15 There are only two hotels which are centrally located within Melksham. The King’s Arms is located within the town centre and has 13 recently refurbished en-suite bedrooms. It occupies an attractive historic building on the Market Place. The accommodation and rooms within the public house are also available to hire for functions and events. Room prices vary from £75 per night for twin/double en-suite rooms to £95 for a super double en-suite room.

7.16 The Conigre is located to the south of the town centre (outside of the town centre boundary) and has 8 en-suite bedrooms. The Conigre is a small family-run hotel located within a converted 17th Century Grade II listed former farmhouse. Room prices vary from £97 for a double en-suite room to £110 per night for a twin-bedded room.

7.17 In addition to the two centrally located existing hotels, planning permission was granted on 16 December 2016 for a mixed use development comprising a 60-bedroom Travelodge hotel, retail unit and drive-thru coffee shop on land adjacent Commerce Way, Melksham, approximately 1.7 km to the south of the town centre (LPA ref: 16/09559/FUL). This development opened in December 2017 and is the nearest competing hotel operating within the same budget hotel market sector as Premier Inn. The Travelodge and related facilities occupy an out-of-centre location.

Trade Overlap with Accommodation in Melksham Town Centre 7.18 Rather than being categorised as a hotel, the King’s Arms, located within Melksham town centre, more closely resembles a public house with accommodation above in the format of a traditional ‘inn’. The King’s Arms appears to serve a largely tourist trade for those visiting the local area, as well as a small number of business trips. In addition to catering for the general visitor market, the King’s Arms also offers function space for weddings and other events. The proposed Premier Inn has only limited trading overlap with the King’s Arms and is unlikely to impact on its existing trade.

7.19 Recent reviews of the King’s Arms on TripAdvisor suggest that the accommodation is conveniently placed in the central Market Place with free parking and good quality, well equipped and sizeable rooms. However, a number of the reviews highlight that given the central location of the hotel on the street, accommodation can be noisy at night from live bands playing in the pub and from the adjacent nightclub.

7.20 Whilst the food within the pub/restaurant is generally categorised as reasonably priced and of good quality, some reviews suggest that the restaurant can get very busy during peak times.

7.21 There would be a very limited overlap with the Premier Inn proposal and the accommodation offer of the King’s Arms Hotel. Visitors who prefer to stay centrally within the historic environment of the town (close to shops and restaurants) are likely to continue to use this accommodation (rather than a modern budget hotel located outside of the town centre). Visitors who require the use of function space and conference rooms will continue to use facilities within the King’s Arms which will not be available at the Premier Inn. This offer would limit the extent to which impacts would occur on the King’s Arms.

7.22 The Conigre and Travelodge are located outside of Melksham town centre. They do not form a direct part of the town centre’s function as a retail, leisure and service destination although, in common with the application proposal, contribute to the economy of Melksham as a whole. Whilst the Travelodge hotel shares a more directly competing trading profile with the budget hotel offer of Premier Inn and may experience more direct trade impacts as a result, neither of these hotels is afforded protection by planning policy due to their out-of-centre locations.

7.23 The increase in custom the Premier Inn will bring to Melksham as a whole is likely to provide additional trade for other businesses, including retail, food and beverage providers and other attractions within the town centre. The anticipated result will be that the proposed Premier Inn is likely to boost trade from other services across the town centre, resulting in a net economic benefit for the centre.

7.24 The supporting Economic Impact Assessment confirms that business and leisure guests using the Premier Inn could be expected to spend up to £1.1 million annually in the local economy. This figure represents wider spending that will be generated in the local economy on retail and leisure activities, not inclusive of expenditure on accommodation and transport to and from Melksham. The economic spin-off benefits for the local economy are therefore significant.

Additional Trade Attracted to Premier Inn

Tourism 7.25 Growth of the tourism industry is a key policy objective for Wiltshire. According to the Core Strategy, tourism is worth over £779 million a year to Wiltshire’s economy. Wiltshire’s built and natural environment is a key part of its tourism product. The Core Strategy identifies that Wiltshire has a wealth of natural and heritage assets that attract visitors both nationally and internationally, ranging from the world famous Stonehenge monument (28 km from Melksham), to renowned attractions such as Longleat Safari and Adventure Park (21 km from Melksham), country houses, museums and gardens. The rural countryside within the nearby AONBs of the Cotswolds, North Wessex Downs and Cranborne Chase, Wiltshire’s canal network and historic villages such as Lacock (only 5 km to the north of Melksham) also draw visitors to the area.

7.26 With respect to hotel facilities, the Core Strategy notes that as there is currently a shortfall in bed space across Wiltshire, and new hotels and serviced accommodation are supported in market towns and local service centres. The trend for conversion of existing hotels into other uses, such as residential uses, has exacerbated this shortfall. In particular, the Core Strategy notes that there is a lack of budget hotels within parts of Wiltshire, a market which is well-served by Premier Inn.

7.27 The tourism industry has a key part to play in the future of Wiltshire’s economy; improving the range of hotel facilities within the market towns is necessary for economic growth to be realised.

Business Travel 7.28 60% of all Premier Inn customers are business travellers. Whilst the level of business custom to the Premier Inn in Melksham may be lower than the 60% average for the company as a whole due to the attraction of tourism to the town and surrounding

areas, it is anticipated that the hotel will attract significant custom from business travellers in the region.

Brand Identity 7.29 A significant proportion of customers of the proposed Premier Inn in Melksham will be those who have visited other Premier Inns previously. Customers are familiar with the high standard of accommodation and privacy offered, as well as consistent high quality of service across the brand, with a guarantee of a full refund if left unsatisfied with any part of the accommodation provided. This attracts customer loyalty and a level of repeat business.

7.30 The ability to book Premier Inn accommodation via the online system is a standard product across the country, which will make booking easier and simpler for customers seeking to visit Melksham for business or leisure purposes. The construction of a Premier Inn within Melksham will harness the custom of those attracted to the brand who may have otherwise sought ‘branded’ accommodation elsewhere.

Restaurants within Melksham Town Centre

7.31 Restaurants and pubs within Melksham town centre are summarised below:

Table 7.1: Restaurants and pubs within Melksham Town Centre

Floorspace Name Address Description (sq m net) Sultan 5B Bath Road 112 Indian restaurant Alba Ristorante Italiano 6 Bath Road 92 Italian restaurant Best-rated restaurant in Casa la cucina Italiana 6-8 Bank Street 138 Melksham Melksham Tandoori 26 Church Street 107 Indian restaurant The Refa Tandoori 1-5 Market Place 255 Indian restaurant (i) The Bear 3 Bath Road 434 Wetherspoons chain pub (ii) King’s Arms Hotel 20 Market Place 588 High quality pub food (iii) Parson’s Nose 30 High Street 182 Traditional Pub food (iv) The Tavern 18 Market Place 525 Pub food and light bites (v) Source: Appendix 2

Trade Overlap with Restaurants and Pubs within Melksham Town Centre 7.32 As detailed above, Beefeater restaurants specialise in steak and chargrilled meats and fish, with open plan grill areas so that customers can see meals being prepared. Restaurants also serve full English and continental breakfasts, traditional Sunday lunches and offer specialist menus for children.

7.33 A significant number of visitors to the Beefeater will be guests staying at the Premier Inn hotel above the restaurant. The Beefeater will open for breakfast to serve both Premier Inn guests and the public, and will provide the food, beverage and lounge facilities for overnight hotel guests.

7.34 The five restaurants within Melksham town centre predominantly serve specialist Indian and Italian cuisine. As the Beefeater specialises in grilled foods, the proposal will not have an offer which overlaps with these restaurants. Accordingly, the proposal is unlikely to have any negative impact whatsoever on these existing establishments.

7.35 The four pubs within Melksham town centre serve traditional pub food, with cuisine at the King’s Arms being of a higher quality. Whilst there may be a limited overlap with the offer of the Beefeater restaurant with those of the pubs within the town centre, they are not sustained by this offer. The pubs are all centrally located, primarily used as drinking establishments with a secondary food offer. The Beefeater restaurant primarily has a specialist grilled food offer (which largely differs from that of the town centre pubs) and has a role in servicing the dining requirements of the Premier Inn.

7.36 Accordingly, in applying the ‘like for like’ principle, the overlap of the offer of the Beefeater with pubs in the town centre, and associated trade impact, is assessed as being extremely limited.

Overall Impact on Melksham Town Centre

7.37 Based on our knowledge of how budget hotel and restaurant openings have impacted upon other establishments in towns across the country, and the likelihood of new business being generated by a Premier Inn in this location by tourism, business custom and ‘brand awareness’, we draw the following conclusions:

• The impact of the hotel on existing hotel accommodation within Melksham town centre (limited to the King’s Arms) is likely to be negligible.

• The trade overlap of the Beefeater restaurant with existing restaurants and pubs within Melksham town centre will be extremely limited.

• Having regard to the outputs of the health check assessment and the nature and function of the role of Melksham town centre, we do not consider that the application proposal will undermine the vitality or viability of the town centre, or its future investment prospects and performance.

• The development will assist in supporting the growth of the service sector and tourist economy in Melksham and support the range and choice for local tourist and business visitors to improve the hotel offer of the town.

• The development will also act to enhance investment confidence in Melksham, creating 50 FTE jobs during construction and 60 FTE jobs during operation. Business and leisure guests using the Premier Inn accommodation in Melksham could be expected to spend up to £1.1 million annually.

7.38 In conclusion, it is considered that the provision of the new Premier Inn and Beefeater restaurant at the application site will not have a significant impact upon the vitality and/or viability of Melksham town centre. Rather, it will assist in meeting the demand for tourism and business accommodation within Melksham, a principle which is supported by the aims of local policy. Accordingly, the proposal is fully compliant with planning policy.

8. Planning Analysis

Principle of Development

8.1 The application proposal has been informed by a series of detailed pre-application discussions with officers of Wiltshire Council. From the outset, officer’s confirmed that the principle of the site’s redevelopment for the uses proposed was acceptable.

8.2 Hotel development in this location is compliant with adopted policy (Core Strategy Policies CP39 and CP40). The development proposed is located within Melksham’s defined settlement boundary (‘limits of development’) and comprises an underutilised area of brownfield land. The site’s redevelopment is supported by planning policy at all levels. The proposal is of a scale and intensity appropriate to the application site.

8.3 The application is supported by an Economic Impact Assessment, prepared by Turley Economics. The Assessment provides an independent appraisal of the scheme’s economic impacts, proving the following key conclusions:

8.4 The application proposal represents a significant investment by Leekes and will secure the long term beneficial use of the application site.

8.5 The application proposal will deliver a number of direct and indirect economic and social benefits, making a positive contribution to the Melksham (and Wiltshire) economy. The proposed Premier Inn hotel and Beefeater restaurant will create new jobs for local people. These include a mix of full and part-time roles, including managerial, front of house, housekeeping and catering positions. Premier Inn also offers a range of graduate career opportunities for the recruitment and retention of graduates.

8.6 The application is supported by an Economic Impact Assessment, prepared by Turley Economics. The Assessment provides an independent appraisal of the scheme’s economic impacts, proving the following key conclusions:

Construction phase • Employment: The proposed development has the potential to provide 50 net additional full time equivalent (FTE) jobs within the South West market, including 20 in Wiltshire. These jobs will be directly in the construction sector and associated trades.

• Productivity: The proposed development will generate £1.7m GVA at the Wiltshire level and £4.2m GVA across the wider economy.

Operational phase • Employment: The scheme will support 45 FTE jobs on site.

• Taking additional factors into account, 60 net additional jobs (direct, indirect and induced) could be created within the South West economy, of which 30 could be local to Wiltshire.

• Productivity: The proposed development will result in a productivity boost of £1.3m GVA in Wiltshire and £2.4m GVA across the South West region.

Hotel visitor expenditure impacts • The proposed development will provide accommodation for visitors to Melksham, and more generally to Wiltshire. There is the potential for £1.1m in additional visitor expenditure per annum to be generated. This level of expenditure has the potential to create sustained demand for new leisure related jobs in existing and new businesses.

Business rates impacts • The proposed development will create additional business rates revenue every year which will accrue to Wiltshire Council and can help to finance essential services and investments in the County on an ongoing basis. The development could result in a total business rates revenue of £60,000 per annum.

8.7 In light of the above, the application proposal is compliant with sustainable objectives and principles at both national and local levels and has been supported by Officers during pre-application discussions.

Design

8.8 Detailed analysis regarding the application proposal’s layout, scale and design justification is set out within the supporting Design and Access Statement, prepared by Turley. The Design and Access Statement explains the process of site analysis and contextual appraisal undertaken in formulating the development proposal. It illustrates how the design principles of the site’s surroundings, its broader context within the wider townscape and the initial design and accommodation brief provided by Leekes, have all informed the massing and arrangement of the application proposal.

8.9 The final design has been informed by a series of pre-application discussions with Officers and positively responds to the site context. A key consideration in the design evolution has been the appropriate response to the significance of the nearby listed buildings, and achieving a successful relationship between the proposed hotel/restaurant and the wider Leekes site.

8.10 The application proposal will deliver a high quality development that has been sensitively designed to integrate appropriately with its context.

Heritage

8.11 The application is supported by a Heritage Assessment, prepared by Oxford Archaeology. The Assessment focusses on the impact of the development proposed upon the setting of the Grade II Listed Halfway Farmhouse and the Gazebo in its garden wall.

8.12 The Assessment confirms that the farmhouse dates from the early 18th century. The farm stood originally in open country. The historic farmhouse was built facing east

across the Avon Valley, and only the end of its rear wing looks towards the development site.

8.13 The listed Gazebo in the garden wall is still seen in the context of the listed farmhouse, but both are separated from the development site by a busy road with roundabout, and are generally seen in the context of modern housing and a service station on the east side of the road, and the Leekes store and car park on the west.

8.14 The Assessment concludes that the development site does not feature in the current visual envelope and setting of the listed building. There will only be limited views of the new hotel from one end of the listed building, and the change could only represent minimal harm to the character or assessing of the listed building, and certainly not ‘significant harm’ in planning policy terms.

Access

8.15 A Transport Assessment, Travel Plan and Delivery and Servicing Management Plan prepared by Russell Giles Partnership are included as part of the submitted application.

8.16 The Transport Assessment demonstrates that the traffic generating impact of the proposals would not be severe. The proposals would not have a discernible impact upon the operation of the local highway network. This includes on the Beanacre roundabout and the signalised junctions of the A350 / Asda foodstore and the A350 / A365 to the south of the site. Junction modelling demonstrates that the Beanacre roundabout will continue to operate within capacity limits.

Drainage

8.17 The Flood Risk Assessment prepared by Simpson Associates details a strategy for the disposal of surface water and foul water runoff from the development. It responds to comments received from Wiltshire Council’s drainage officer during pre-application dialogue. A summary of the assessment is set out below.

8.18 The FCA establishes that it would be most appropriate to discharge surface water runoff to the site’s existing surface water drainage system. It is assessed to be appropriate to discharge surface water runoff from the development to the private surface water drainage network within the existing car park. This method of disposal will match the existing situation.

8.19 The accompanying FCA establishes that there is limited opportunity to use SUDS to limit flows to match the greenfield run-off rates as closely as possible. Therefore, it is proposed to use a Hydro-brake flow control device to limit flows by at least 20% for all storm events up to and including the 1 in 100 year event plus 40% climate change.

8.20 The accompanying FCA shows that foul water flows from the hotel and restaurant will be discharged via a traditional network of underground gravity pipework. A private pumping station will ensure discharge to the existing private foul water network serving the Leekes store. The network connects to the Wessex Water Sewer within Beanacre Road.

9. Conclusions

9.1 This report has been prepared in support of a full planning application for a 71 bed Premier Inn hotel and accompanying Beefeater restaurant at Beanacre Road, Melksham. The report should be read in conjunction with the supporting Design and Access Statement and other technical documents submitted in support of this application.

9.2 Further to positive pre-application discussions with senior Council officers, the report has demonstrated that the proposal is in accordance with planning policy at all levels.

9.3 It has been demonstrated that the application proposal will deliver a number of major benefits to Melksham, including:

• The regeneration of an underutilised brownfield site at a prominent location;

• The provision of new, high quality and affordable hotel accommodation;

• Major employment/economic benefits in terms of construction and hospitality and leisure jobs; and

• The erection of a high quality, contemporary and well-designed building at a prominent site at the gateway to the town.

9.4 This Report and the wider application demonstrate that the proposed development can be readily accommodated on the application site and is fully acceptable in principle and in terms of all environmental and technical considerations.

9.5 The assessment addresses all relevant planning policy considerations associated with the proposed development, examines the impact of the proposed hotel and restaurant on Melksham town centre and assesses the suitability and availability of alternative, in and edge-of-centre sites.

9.6 Based on our knowledge of how budget hotels and restaurant openings have impacted upon other hotels in towns across the country, and the likelihood of new business being generated by a Premier Inn in this location by tourism, business custom and ‘brand awareness’, we conclude that the impact of the hotel on existing accommodation within Melksham town centre is likely to be negligible. Similarly, the trade overlap of the proposed Beefeater restaurant with existing restaurants and pubs within the town centre will be extremely limited. Impact on the vitality and viability of the town centre as a whole will not be significant.

9.7 Having regard to the outputs of the health check assessment, the nature and function of the role of Melksham town centre, and existing hotel and restaurant occupiers within the centre, we do not consider that the application proposal will undermine the vitality or viability of the town centre, or its future investment prospects and performance.

9.8 On the basis of our assessment of alternative sites; extant development plan and national policy; and the key issues highlighted within the sequential assessment; we conclude that there are no alternative suitable sites within or adjacent to Melksham town centre that are currently available, or likely to become available in a reasonable period.

9.9 The application proposal will assist in supporting the growth of the service sector and tourist economy in Melksham. It will also support the range and choice for local tourist and business visitors and improve the hotel offer of the town, an aim of local planning policy. The economic benefits of the development are a significant material consideration.

9.10 The development will also bring a productive use to part of an underused car park site which has been unable to fulfil its potential to contribute to the local economy. This situation will be reversed by the investment in the hotel, the creation of local employment opportunities and spin-off benefits for the local economy.

9.11 The development will also act to enhance investment confidence in Melksham. The hotel will result in the direct provision of both full and part-time jobs, equivalent to 50 full time equivalent (FTE) positions during the construction phase and 60 FTE positions during the operational phase. Whitbread is also committed to the employment of local people within its hotels and restaurants and is recognised for the quality of its training programmes. In addition, the total capital investment involved in the provision of this hotel is significant, in excess of £4.2 million.

9.12 The accompanying Economic Benefits Statement confirms that business and leisure guests using the Premier Inn accommodation in Melksham could be expected to spend up to £1.1 million annually in the local economy (excluding accommodation and transport costs). The economic spin-off benefits are therefore significant.

9.13 Overall, it is considered that the provision of the new Premier Inn and Beefeater restaurant at the application site will not have a significant impact upon the vitality and/or viability of Melksham town centre. Rather, it will assist in meeting the demand for tourism and business accommodation within Melksham, a principle which is supported by the aims of local policy. Accordingly, the proposal is fully compliant with planning policy, including Core Strategy policies CP39 and CP40 which provide in- principle support for the proposals.

Appendix 1: Town Centre Uses Plan

37 Melksham Land Use Plan (September 2018) - Cafes, Restaurants and Public Houses

Experian Goad Plan Created: 27/09/2018 50 metres Created By: Turley Associates Ltd Copyright and confidentiality Experian, 2017. © Crown copyright and For more information on our products and services: database rights 2017. OS 100019885 www.experian.co.uk/goad | [email protected] | 0845 601 6011

Poweredby TCPDF (www.tcpdf.org)

Appendix 2: Schedule of Existing Facilities

PROPOSED PREMIER INN & BEEFEATER RESTAURANT, MELKSHAM

TABLE 1: FOOD AND DRINK FACILITIES IN MELKSHAM TOWN CENTRE

Floorspace Name Address Cuisine Description (sq m net)

Restaurants (Class A3) Sultan 5B Bath Road, SN12 6LL 112 Indian Standard India n restaurant Alba Ristorante Italiano 6 Bath Road, SN12 6LP 92 Italian Standard Italian restaurant Casa la cucina Italiana 6-8 Bank Street, SN12 6LG 138 Italian Best-rated restaurant in Melksham Melksham Tandoori 26 Church Street, SN12 6LS 107 Indian Standard Indian restaurant The Refa Tandoori 1-5 Market Place, SN12 6ES 255 Indian Standard Indian restaurant

Cafés (Class A3) Buds Bar 1 Lowbourne, SN12 7DZ 182 Café food More of a bar than a food destination Antico Caffe 6c, Littlebrook Centre, SN12 6LP 47 Italian Small, authentic Italian café Costa Coffee 47-49 High Street, SN12 6JY 134 Café food Costa Coffee chain ArtHouse Café 31A Market Place, SN12 6ES 50 Café food Run by the local Rotary Club (closes at 3pm every day) Henry's of Melksham 12 High Street, SN12 6JU 87 Café food Independent café LA Diner 14 Market Place, SN12 6EX 50 Café food Standard café/diner food

Pubs (Class A4) The Bear 3 Bath Road, SN12 6LL 434 Pub food Wetherspoon s chain pub Kings Arms Hotel 20 Market Place, SN12 6EX 588 Pub food Pub and restaurant in a hotel - high quality pub food Parson's Nose 30 High Street, SN12 6LA 182 Pub food Traditional pub food The Tavern 18 Market Place, SN12 6EX 525 Pub food Pub f ood and light bites

Takeaways (Class A5) Dominos 23-25 Bath Road, SN12 6LP 93 Pizza Dominos chai n takeaway Chop Suey House 15 Bath Road, SN12 6LL 61 Chinese Take-away/delivery with little sit-in option Chicken Hut 54 Union Street, SN12 7PR 45 Take-away Take-away/delivery with little sit-in option Kebab House 4 Bank Street, SN12 6LG 65 Take-away Take-away/delivery with little sit-in option Cinnamon 51 High Street, SN12 6JY 24 Indian Take-away/d elivery with little sit-in option Acropolis 21 Church Street, SN12 6LS 33 Greek Take-away/delivery with little sit-in option Golden Falls 3 King Street, SN12 6HB 61 Chinese Take-away/delivery with little sit-in option

Notes: 1. Net floorspace areas derived from Valuation Office Agency (where available) or from Goad Portal

Turley Office 18 Windsor Place, Cardiff

T 02920 344 445