Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9098

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9591
Northstone 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 if any deviations from mix, type or specialist housing is required. At most, a percentage approach would need to enable a range of percentages (e.g. 5-10%) to account for individual site needs and constraints. A flexible approach also requiring 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: 9099

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9592
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 of 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. Identify the areas where affordable housing is most needed and take a flexible approach driven by lower thresholds where need is greatest.

Comment

Representation ID: 9100

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9593
Northstone 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 HIA can be beneficial “where there are expected to be significant impacts”. Planning policies and SPDs can introduce triggers that require an HIA to be submitted as part of a planning application where evidence demonstrates the development impacts can be expected to be significant on sensitive receptors. However, CWAC need to establish clear health needs and priorities on a borough wide basis and across the plan period to then then set out what defined local trigger may be required, whether that be on size of scheme, use of scheme or within certain locations.

Comment

Representation ID: 9101

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9594
Northstone do not consider there a need to include a specific policy in relation to separation distances. This can be included within a supporting Supplementary Planning Document 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: 9102

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9595
Northstone agree that private outdoor amenity space is essential within new developments and should be provided. As with HW 3, this is something that could be progressed in detail within an outdoor amenity and open space SPD, establishing thresholds, requirements and exceptions for outdoor amenity and open space within new developments. This may include garden sizes, POS thresholds and play requirements.

Comment

Representation ID: 9103

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9596
Northstone support the overall thrust of this policy to ensure provision is made to sustain healthy and sustainable communities. However, protection must be balanced with meeting housing needs. Releasing carefully chosen Green Belt land at Lostock Gralam provides an opportunity to secure new and enhanced open space and recreation provision as part of a comprehensive development. Policy DM35 provides a clear approach to the delivery of open space provision and allows for instances where it is not practicable to deliver on site. Following this approach through the emerging plan would provide a comprehensive approach however this needs to be supported by up-to-date evidence to ensure that a clear base position is provided to developers. Policy DM35 should be reviewed however given it provides quanta for open space provision on the basis of the open space study that now needs to be updated. This may change the level of requirement for each typology depending on changed needs.

Comment

Representation ID: 9104

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9597
Northstone 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: 9105

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9598
Northstone would suggest that CWAC should update the Open Space Study given the previous assessment covers the period of 2016-2030. As the emerging plan extends beyond this period it should be critical to update. The quality and provision of open space studies can change significantly over time and therefore an update to this is key to ensure any onsite or offsite contributions are proportionally provided where need is greatest. This approach is set out under NPPF Paragraph 103 whereby it is clearly set out that Planning policies should be based on robust and up to date (NJL Emphasis) assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from these assessments should then be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate. The Playing Pitch Strategy was updated in February 2025 and as such is considered appropriate to inform the emerging Local Plan.

Comment

Representation ID: 9106

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9599
Northstone support the overall aim of biodiversity net gain and across their development sites seek to deliver 10% where feasible. However, any increase on 10% through local policy needs to be robustly evidenced and ensure it does not impact upon the viability of schemes that in turn may not be able to be delivered to support housing growth.