We recommend some amendment of this policy to ensure it adequately protects against unnecessary loss.

We urge deletion of "An alternative community facility (social infrastructure) which meets similar local needs to at least the same extent is already available." This is because the existence of another local facility of similar nature does not mean both are compatible as they may serve very different functions and communities, and moreover even if they were of similar offer there may be sufficient need and demand for both. The proposed second criteria addresses this point, which makes the first point redundant.

We also urge amendment to the fourth criteria as economic viability can be manipulated to falsely evidence a facility could be lost. It may also be the case that where a facility is run on a commercial basis it could be successful under an alternative model such as community or charitable ownership/operation. It has been demonstrated that it is no longer economically viable and cannot be made so, unless sufficient marketing evidence has been supplied.

It would be beneficial for evidence of marketing of a site to be provided over a period of at least 12 months but ideally up to 24 months to demonstrate lack of interest. This must be a genuine exercise undertaken through recognised local and national agents relevant for the type of use. This must be at a rent or asking price appropriate to existing use without development potential and condition.