Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14683

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15233
It is key to combine the existing approach based on up-to-date evidence alongside market knowledge to deliver the best opportunities for housing mix. Policies for older persons and specialist housing, including the optional technical housing standards, should be based on evidence of need and tested for viability and the LPA should not attempt to force the market in terms of private dwelling mix where it is not required or evidenced. Opportunities for sites for older persons and specialist housing could be identified in masterplans for strategic sites. However, there must be a mechanism to allow for alternative development where demand is not expressed. Site allocations should satisfy criteria, such as proximity of sites to public transport, local services and facilities (e.g., healthcare), and town centres.

Comment

Representation ID: 14684

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15234
Miller Homes agree that a percentage approach should be given to provide guidance to what is expected and needed in the borough. However, this should be a flexible approach given changing needs throughout the plan period and allow for evidence to be provided at the time of submission of an application should there be any deviations from mix, type or if specialist housing is required. At most, a percentage approach would need to enable a range (e.g. 5-10%) to account for individual site needs and constraints. A flexible approach that also requires consideration against the Housing Needs Assessment (or any such later document) would enable sites to more accurately meet local market demands and respond to updated assessments in real time.

Comment

Representation ID: 14685

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15235
The policy as written suggest the intention to reflect the government’s requirement for housing sites in the Green Belt to provide at least 50% affordable housing. The amount of affordable housing a scheme can provide depends on the overall viability of a project and a flexible approach is needed to take account the circumstances of individual schemes. The approach should be justified by up-to-date evidence of need and viability tested, as deliverability should not be compromised by over ambitious requirements. Therefore, the most effective approach would be to identify areas with the greatest need for affordable housing and apply lower thresholds in those locations, allowing for a more flexible and responsive delivery strategy.

Comment

Representation ID: 14686

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15236
Miller Homes agree that housing developments should take every reasonable opportunity to promote and positively contribute to the health outcomes for the borough. The supporting PPG, healthy and safe communities, suggests the use of a health impact assessment (HIA) can be beneficial “where there are expected to be significant impacts”. Planning policies SPDs can include specific triggers requiring a HIA to be submitted with a planning application, particularly where evidence shows that the development could significantly affect sensitive receptors. However, for this approach to be effective, CWAC must first establish clear health priorities and needs across the borough and throughout the plan period. This would then allow the Council to define appropriate local triggers, e.g., the size or type of development, or its location that would determine when an HIA is required.

Comment

Representation ID: 14687

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15237
Miller Homes do not consider there a need to include a specific policy in relation to separation distances. This can be included within a supporting SPD which can go into further details regarding contextual changes around the borough that may result in instances where distances may require shortening or lengthening.

Comment

Representation ID: 14688

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15238
Miller Homes agree that private outdoor amenity space is essential in new developments and should be provided. As with Policy HW 3, this could be further detailed in a dedicated SPD on outdoor amenity and open space. This SPD could establish clear thresholds, requirements, and exceptions, covering aspects like garden sizes, public open space standards, and play provision.

Comment

Representation ID: 14689

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15239
Miller Homes supports the overall intent of this policy to promote healthy and sustainable communities. However, this must be balanced against the need to meet housing requirements. The release of carefully selected Green Belt land at Lostock Gralam presents an opportunity to deliver a comprehensive development that includes new and enhanced open space and recreational facilities. Policy DM35 sets out a clear framework for delivering open space provision and allows for off-site contributions where on-site delivery is not practical. Carrying this approach forward into the emerging Local Plan would support a comprehensive strategy. However, it must be underpinned by up-to-date evidence to provide developers with a clear and consistent baseline. Policy DM35 should be reviewed, as it sets open space provision standards based on an open space study that now requires updating. Revised evidence may lead to changes in the required provision for each typology, reflecting evolving local needs and priorities.

Comment

Representation ID: 14690

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15240
Miller Homes consider that the thresholds set out in adopted Policy DM35 could be considered suitable, however, these need to be tested through a strategic viability assessment.

Comment

Representation ID: 14691

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15241
Miller Homes recommends that CWAC update the Open Space Study, as the current assessment covers the period 2016–2030 and does not align with the extended timeframe of the emerging Local Plan. Open space provision and quality can change significantly over time, so an updated study is essential to ensure that both on-site and off-site contributions are proportionate and targeted to areas where need is greatest. This approach aligns with Paragraph 103 of the NPPF, which states that planning policies should be based on robust and up-to-date assessments of the need for open space, sport, and recreation facilities (including any quantitative or qualitative deficits or surpluses) and opportunities for new provision, The findings from these assessments should then inform what provision is required, which the Local Plan should seek to accommodate. The Playing Pitch Strategy was updated in February 2025 and as such is considered appropriate to inform the emerging Local Plan.