Policy DEV2 identifies that sites within the Town Centre should provide 20% affordable housing with a split of 50% affordable rent and 50% affordable ownership. However, we have reviewed the Warrington Borough Council Emerging Local Plan Viability Assessment (Main Report and Appendices) [the Viability Assessment] and note that the report demonstrates that residential development in the town centre is subject to significant viability constraints. The Viability Assessment [?8.17] also acknowledges that none of the recent Build to Rent [BTR] development to come forwards in the Town Centre has provided any affordable housing or policy compliant S106 contributions. Whether or not it is BtR, affordable or market accommodation (or a combination thereof) the Councils evidence identifies that the delivery of high-density apartment schemes in the town centre is the subject of viability constraints. As such, Altered Space would query whether or not the 20% affordable housing requirement for the Town Centre is appropriate or justified having regard to the Council?s own evidence. Altered Space also objects to Part 13 of the policy which seeks to provide dwellings that are appropriately sized and arranged to create well designed homes in accordance with Nationally Described Space Standards [NDSS]. Altered Space notes that the Government?s decision to make these standards optional suggests that they do not expect all properties to be built in accordance with them. If the standards are to be applied, the PPG sets out a clear set of criteria local planning authorities should address in order to justify them. With regard these criteria, we firstly note that no need evidence is provided in the SVLP 2021 or the 2021 Local Housing Needs Assessment [LHNA] to justify the policy requirement. With regards to viability, the Viability Assessment [?7.20] states that the NDSS has been applied within the appraisals as the minimum standard. It is clear that residential developments within the Town Centre are subject to significant viability constraints and that imposing requirements such as NDSS (without evidence) worsens the situation. For these reasons, Altered Space considers that Part 13 of the policy should be deleted, or caveated to exclude residential developments within the Town Centre.

Altered Space is highly supportive of the aspirations set out within Policy TC1 and is fully supportive of the Council?s vision. In fact, on the most part, Altered Space does not object to any of the content of Policy TC1. The main issue we have is the references within the policy to the SPD, and now the SPD should interact with the Local Plan. The way Policy TC1 is currently drafted suggests that the SPD sets the overarching policy framework for development in the Town Centre, and that this should be referred to principally when considering development proposals. For example, in Section 5 of the policy, it is stated that minimum densities (130 dwellings per hectare) should be achieved subject to compliance with the SPD, thus attaching greater importance to complying with the SPD than the policy aspiration itself. However, as set out in our previous representations to the SPD consultation, the document does not conform with the adopted Core Strategy. Bearing this in mind, it is unclear how the SPD can be relied upon within the SVLP 2021 without being reviewed in the context of the emerging policies. Furthermore, the SPD sets out onerous requirements for development in the town centre but was not supported by any viability evidence to test whether this could be supported. As set out above, we have reviewed the Viability Assessment and note that it does not include an assessment of the full SPD requirements in relation to Town Centre typologies tested. Notwithstanding this, as set out above, the assessment concludes that in every scenario tested for the Town Centre typologies that development here is subject to significant viability constraints, with a significant deficit in most scenarios. The Council?s own evidence indicates that, even with 0% affordable housing provision, that viability is constrained which raises questions around developments ability to deliver even standard contributions, before even factoring in the additional costs associated with the SPD guidance.

Firstly, it is important to note that Altered Space does not object to Policy INF5 in principle and understands and supports the need to secure planning obligations to deliver infrastructure. Section 5 of the policy lists key matters that the Council will seek to fund through planning contributions. There is also a caveat noting that planning contributions are not limited to the matters listed. Some of the matters listed such as affordable housing, biodiversity enhancements, open space etc, transport improvements, education provision and health infrastructure are typical matters that would be secured through planning obligations where appropriate. However, some of the matters listed, such as improvements to heritage assets would only be applicable in some site-specific instances and could be delivered as part of the development itself as opposed to through planning contributions. Matters like public realm improvements would also typically be delivered as part of the development itself and would be secured by condition. Bearing in mind that the list is already caveated to make it clear that items that could be secured are not limited to the list, it is considered that the list could be refined to relate only to the matters referred to in the Framework [?34]. In addition, the reference to public art should be removed as this is not referenced in the Framework or PPG and it is unclear how this could be required to make the development acceptable in planning terms. In terms of viability, Altered Space welcomes the acknowledgment within Policy INF5 that there are instances where it may not be viable for development to support the full package of contributions sought.

The policy as currently drafted has not had regard to the differences between delivering housing within the Town Centre as opposed to Suburban Warrington and the implications this has on the nature of open space. The Council itself acknowledges that the Town Centre is an emerging residential market which is yet to be fully established. The type of development that will be delivered will generally be high density housing as acknowledged within Policy DEV1 (Housing Delivery). Some sites will be unable to deliver public open space on site as acknowledged within Policy DC5, but others such as Land at Scotland Road will. However, given the nature of sites in the Town Centre, it is unclear why it is appropriate to apply the usual thresholds and standards in the same way that is the case for Suburban Warrington. Table 7 sets out the Council?s proposed open space standards which is based on Fields in Trust [FiT] standards. These would be applied to all residential developments that exceed the threshold which is 40 dwellings. However, Altered Space is of the view that sites in the Town Centre such as Land at Scotland Road should not be treated in this manner, recognising the unique constraints, but also opportunities that they bring. Unlike more constrained Town Centre sites, Land at Scotland Road will be providing a significant quantum of on-site public open space. The development will create an attractive and vibrant central square that generates footfall and encourages pedestrians to dwell in the heart of the town centre. The size of this space is based on the site itself and should not be calculated on the basis of the usual space standards. That being said, the area of on-site public open space that this development will deliver is substantial and Altered Space is of the view that this should be factored in when considering the need to contribute to other open space typologies. For example, we are of the view that the scale and quality of the on-site public open space that will be created by the Land at Scotland Road development should mitigate any requirement to contribute towards other open space typologies as identified within Policy DC5. Essentially we are of the view that the policy should acknowledge the unique circumstances associated with sites in the Town Centre and therefore should not apply the usual standards but state that the open space, sport and recreation provision for such developments should be discussed and agreed on a site by site basis. Furthermore, the Council?s own viability evidence indicates that residential development in the Town Centre is highly constrained and is unlikely to be able to support full financial contributions. We would therefore query whether it is realistic to seek contributions for all of the open space typologies for residential developments in this market area.