Dear Head of Planning,
RE: FUL/356274/26 – 121 Long Lane, Chadderton, Oldham OL9 8AY Change of use of hot food takeaway and first floor residential unit above to create a 7bedroom House in Multiple Occupation (HMO) (sui generis).
As the local Member of Parliament, I do not ordinarily intervene in individual planning applications. However, this proposal raises wider concerns that residents have consistently brought to my attention regarding the cumulative impact of poorly located HMOs on neighbourhood character, residential amenity and the quality of the built environment.
The recent focus on HMOs through the Article 4 Direction is a welcome move. It shows the rapid rise of HMOs in the borough, totalling 384 as of November 2025, and directs more stringent control.
I welcome the publication of the Housing Delivery Interim Planning Position Paper (June 2025), which states that “Houses in multiple occupancy shall not be permitted unless it can be demonstrated that the proposal does not adversely affect: the local character of the area; the residential and workplace amenity of current, future and neighbouring occupants; and traffic levels and the safety of road users.” (June 2025, p10). This remains current and is consistent with the adopted Places for Everyone Plan (PfE) (March 2024), particularly policies JP-S1 (Sustainable Development), JP-D1 (Design) and JP-P1 (Sustainable Places), which reinforce the need for development to respect local character and ensure high-quality living conditions.
This application fails to demonstrate compliance with the Housing Delivery Interim Planning Position Paper (June 2025) key tests, as well as planning considerations directed by the National Planning Policy Framework (NPPF Dec 2024)and the Places for Everyone Joint Development Plan adopted by Oldham Council. It should therefore be refused planning permission.
1. Over-intensive development causing harm to the character of the area
The proposal represents an over-intensive form of residential occupation that is materially out of keeping with the scale, character and function of the surrounding area. The introduction of a seven-bedroom House in Multiple Occupation into a former takeaway would result in a significantly greater intensity of occupation and activity than the existing lawful use or the surrounding residential properties. The applicant has failed to demonstrate that this level of intensification can be accommodated without causing harm to the character of the locality as required in Places for Everyone JP-P1 (suitable places).
Whilst there have been two previous planning permissions within the parade for residential conversion, those schemes largely retained the established form and appearance of the buildings. In particular, the later approval adopted a front elevation that closely reflected the architectural proportions and appearance of the adjoining property, preserving the visual continuity of the terrace and in line with PfE JP-P1 (suitable places).
By contrast, the proposed front elevation bears little relationship to the established design of the parade. Rather than respecting the proportions, fenestration and architectural cohesion of the neighbouring buildings, it adopts a layout which appears to be driven primarily by the internal room configuration. The result is a frontage that neither reflects the character of the original purpose-built parade nor contributes positively to the local streetscape.
When considered alongside the incremental loss of commercial frontages elsewhere within the parade, the proposal would further erode its architectural coherence and reinforce the piecemeal pattern of unsympathetic alterations that has gradually diminished the quality and identity of this part of Long Lane.
Policy 11 of the Oldham Joint Core Strategy requires HMOs to avoid adverse impacts on the character of the area, neighbouring land uses and residential amenity, the above would suggest that this application does not adhere to Policy 11.
The National Planning Policy Framework (Chapter 12 – Achieving Well-Designed Places) requires development to be sympathetic to local character, to reinforce the positive qualities of an area and to function well whilst adding to the overall quality of the built environment. Key design tests now sit at NPPF paragraphs 135-141.
Places for Everyone Plan Policy JP-P1 (Sustainable Places) requires distinctive places with a clear identity that respects and acknowledges the character and identity in terms of design, sitting, size, scale and materials used (JP-P1-1C). This is not achieved with this application.
2. Unacceptable impact on neighbouring amenity
The proposal would introduce a seven-bedroom House in Multiple Occupation immediately adjacent to existing residential properties and a long-established children’s nursery. By its nature, a seven-bedroom HMO is likely to generate substantially greater levels of activity, comings and goings, noise, refuse generation and general disturbance than either the existing mixed commercial and residential use or a conventional dwelling. The application provides no evidence to demonstrate that neighbouring occupiers, or neighbouring community facilities, would not experience an unacceptable loss of amenity. Similarly, the application does not demonstrate that the building would be functional and convenient, enabling people and uses to act efficiently with minimal effort (JP-P1, PfE, Sustainable Places).
The relationship with the adjoining children’s nursery is of particular concern. The nursery benefits from an established outdoor play area immediately to the rear of the site, which is used throughout the day as part of its normal operation. The proposed HMO introduces multiple new bedroom windows overlooking this space, creating a materially different relationship between the two users than currently exists which is entirely foreseeable.
The application contains no assessment of the impact that this intensified residential use may have upon the continued operation of the nursery, including the potential for overlooking the children’s outdoor play area, noise sensitivity arising from multiple residential occupiers overlooking an established community facility, or the potential for future conflicts between the normal operation of the nursery and the expectations of HMO residents. Planning decisions should seek to avoid introducing incompatible neighbouring uses where foreseeable conflicts could prejudice the continued operation of an established community facility.
Similarly, the application provides no assessment of refuse storage, servicing arrangements or the cumulative impact of increased activity associated with seven separate households on neighbouring amenity.
Policy 11 of the Oldham Joint Core Strategy requires HMOs to avoid adverse impacts on the character of the area, neighbouring land uses and residential amenity.
The National Planning Policy Framework, particularly Chapter 8 (Promoting Health and Safe Communities) and Chapter 12 (Achieving Well-Designed Places), requires planning decisions to create healthy, safe and inclusive places and to secure a high standard of amenity for both existing and future users (NPPF, paragraph 97).
Places for Everyone Policy JP-D1 reinforces the need to avoid unacceptable impacts on neighbouring uses, including community facilities.
3. Highway safety and parking impacts
The proposal would intensify occupation without adequately demonstrating that existing parking provision and highway capacity can safely accommodate the additional demand. A seven-bedroom HMO, together with visitors, servicing and deliveries is capable of generating significantly greater parking demand than the existing lawful use. The application proposes no off-street parking provision and provides no evidence to demonstrate that this absence of parking would not adversely affect the surrounding highway network.
The application contains no Parking Survey, Transport Assessment or assessment of existing parking demand to demonstrate that the proposal would not adversely affect highway safety or traffic conditions, as required by Policy 11 of the Oldham Joint Core Strategy. Furthermore, the applicant has failed to demonstrate, as required by paragraph 115(b) of the National Planning Policy Framework that safe and suitable access can be achieved for all users. Paragraph 116 requires decision makers to ensure development does not result in unacceptable impacts on highway safety.
The application appears to assume that future occupants will rely primarily on walking, cycling and public transport. However, no evidence has been submitted regarding anticipated levels of car ownership, the availability of on-street parking or the cumulative impact on surrounding highway conditions. This is of particular concern given the existing demand for parking associated with the adjoining children’s nursery, neighbouring commercial premises and existing residential properties, all of which rely upon the same limited on-street parking bays. In the absence of such evidence, the Local Planning Authority cannot reasonably conclude that the proposal complies with Policy 11 of the Joint Core Strategy or with paragraphs 115(b) and 116 of the National Planning Policy Framework.
Places for Everyone Policy JP-T1 (Sustainable and Integrated Transport Network) reinforces the requirement for development to demonstrate safe access, appropriate parking and no adverse impact on the transport network.
4. Failure to provide satisfactory living conditions for future occupiers
Oldham Council’s report Update on Proposed Planning Policy for Houses in Multiple Occupation (November 2025) recognises the importance of ensuring that HMOs provide a decent standard of accommodation and do not contribute to overcrowding. The objective is particularly relevant to larger sui generis HMOs, where the intensity of occupation has the potential to place significant pressure on shared facilities and communal living space.
The application identifies seven letting rooms together with some details on room sizes, but it provides limited information regarding the anticipated occupancy levels or whether the proposed communal facilities have been designed to accommodate the likely intensity of occupation. The adequacy of the communal living space and kitchen facilities in particular comes into question when reviewing the proposed floorplan, with the kitchen being a similar measured size to all four of the first-floor bedrooms, with Bedroom 5 exceeding the size of the kitchen. Similarly, no robust assessment has been made of the proposed refuse storage, cycle storage, external amenity space or other shared facilities necessary to support a development of this scale.
Whilst planning permission is sought for a seven-bedroom HMO, it is increasingly common for HMOs within the Borough to accommodate couples and, in some cases, households placed in temporary accommodation, resulting in occupation levels that exceed the simple number of bedrooms. This is reflected in the proposed floorplan of the application, whereby three of the first-floor bedrooms exceed the minimum room size prescribed for two-person occupancy under the Licensing of Houses in Multiple Occupation (Mandatory Conditions of Licences) (England) Regulations 2018. The applicant has provided no evidence to demonstrate that the proposed accommodation would continue to provide an acceptable standard of living should rooms be occupied by more than one person, or that the communal facilities can support that level of occupation without creating overcrowded or substandard living conditions.
In addition, Places for Everyone Policy JP-H1 (Housing) seeks to ensure that new housing contributes positively to meeting identified housing needs by delivering high-quality homes in sustainable locations that support balanced and inclusive communities. Whilst the policy supports increasing housing supply, it does not do so at the expense of housing quality or the creation of sustainable neighbourhoods. The applicant has not demonstrated that this form of large-scale shared accommodation would provide a high-quality residential environment or contribute positively to the creation of a balanced and sustainable community in this location.
In the absence of this information, the Local Planning Authority cannot be satisfied that the proposal would provide a high-quality living environment for future occupiers or comply with the Council’s objective of ensuring HMOs contribute positively to the Borough’s housing stock rather than creating poor-quality accommodation. This is not an unfounded concern, given the localised experience of this type of accommodation in the Borough.
The National Planning Policy Framework requires planning decisions to create healthy, safe and inclusive places and to secure a high standard of amenity for existing and future users (paragraph 97 and Chapter 12).
Emerging Draft Policy H6 (Houses in Multiple Occupation) of the Update on Proposed Planning Policy for Houses in Multiple Occupation (November 2025) seeks to ensure that HMOs provide an appropriate standard of accommodation, sufficient communal facilities and do not contribute to overcrowding. Whilst not yet adopted, it is a material consideration and reflects the Council’s current policy direction.
Places for Everyone Policies JP-H1 and JP-D1 also require new housing to provide a high-quality living environment, including appropriate internal space, communal facilities, waste storage and amenity provision.
5. Failure to demonstrate that the proposal would not contribute to harmful concentrations of HMOs
The application provides no robust assessment of the cumulative impacts of the proposed development of the existing concentration of Houses in Multiple Occupation within the surrounding area. In the absence of such evidence, the Local Planning Authority cannot reasonably conclude that the proposal would maintain a balanced and sustainable community or avoid cumulative harm to the character and amenity of the locality.
Oldham Council has recently introduced a Borough-wide Article 4 Direction in recognition of the cumulative planning impacts arising from the growth of HMOs across the Borough. Whilst the Direction does not apply directly to this proposal, as it relates to a sui generis HMO rather than a Class 4 HMO, it nevertheless reflects the Council’s evidence-based conclusion that HMO development requires careful scrutiny because of its potential cumulative effects on neighbourhood character, residential amenity and balanced communities. The accompanying Council report identified 384 HMOs across the Borough and acknowledged the need for greater planning control in response to their increasing number.
The application contains no assessment of the number, location or distribution of existing HMOs within the locality and no evidence to demonstrate that the proposal would not contribute to an over-concentration of HMOs or undermine the Council’s objective of maintaining balanced and sustainable communities. In the absence of such evidence, the Local Planning Authority cannot be satisfied that the proposal accords with the direction of emerging Draft Policy H6, or with the broader objectives of the National Planning Policy Framework in promoting well-designed, health and sustainable communities.
Places for Everyone Policy JP-S1 emphasises the need for balanced and sustainable communities.
6. Insufficient justification for the loss of an active commercial use
The proposal would permanently remove a purpose-built commercial premises within an established neighbourhood shopping parade that continues to provide important local services, without providing sufficient evidence that the existing commercial use is no longer viable or that its loss would not undermine the vitality and function of the local area.
Whilst the application refers to a marketing report, no such report has been published as part of the application documents. In the absence of that evidence, the Local Planning Authority cannot conclude that the existing commercial use is no longer viable or that reasonable efforts have been made to market the premises either as a going concern for an alternative commercial use. The applicant has therefore failed to demonstrate that the permanent loss of this commercial unit is justified.
The continued occupation of almost every unit within the parade demonstrates that there remains demand for commercial premises in this location. The parade accommodates a range of established local businesses and services, including a hair salon, children’s nursery and launderette, with only one other recent change of use. Planning permission FUL/355441/25 approved the conversion of a former sunbed shop to a launderette whilst retaining an active commercial frontage and providing residential accommodation above.
That permission demonstrates that mixed use development is both achievable and acceptable in this location. The applicant has not demonstrated why a similar approach, retaining a commercial use at ground floor level with residential accommodation above, could not be adopted in this case.
The significance of this application lies not simply in the loss of one takeaway, but in the continued piecemeal erosion of a purposebuilt neighbourhood shopping parade. The parade was designed as four matching semidetached blocks with active commercial frontages serving the surrounding residential community. Whilst individual changes of use have previously been permitted, their cumulative effect has been to fragment the architectural coherence of the parade, break the continuous active commercial frontages, reduce the concentration of local services and weaken its original planning function. The Local Planning Authority should therefore consider not only the acceptability of this proposal in isolation but also the cumulative effect of successive losses of commercial frontage on the vitality and viability of this local centre.
Previous permissions have already resulted in one pair of units (Nos. 125 and 127 Long Lane) being converted to residential use, reducing the continuity of the parade. This proposal would further diminish its commercial role and is also likely to increase pressure on the limited onstreet parking originally intended to serve the parade. Those parking bays are already heavily used by customers of neighbouring businesses, residents and parents using the adjoining children’s nursery during peak dropoff and collection periods. The proposal provides no evidence that these cumulative impacts have been properly assessed. Furthermore, the proposed residential frontage would contribute to the growing patchwork of unrelated conversion styles, further eroding the coherent architectural character of the parade and undermining the quality of the local built environment.
The National Planning Policy Framework requires planning decisions to support the vitality and viability of town and local centres and to promote sustainable communities (Chapter 7). Although this parade is modest in scale, it performs an important neighbourhood function by providing a concentration of local services within walking distance of surrounding residential areas.
The Oldham Joint Core Strategy similarly seeks to support sustainable communities and maintain the function of local centres.
Places for Everyone Plan Policy JPP1: Sustainable Places requires that development is distinctive, with a clear identity that respects and acknowledges the character and identity of the locality in terms of design, siting, size, scale and materials used (JPP11C); that it is socially inclusive in promoting a sense of community (JPP13D); and is wellserved by local shops, services and amenities (JPP117). The loss of a neighbourhood chippy which has served the local community for decades, on an established purposebuilt commercial precinct, fails to demonstrate this test has been adequately met.
Finally, in reaching its decision, the Local Planning Authority is required under section 38(6) of the Planning and Compulsory Purchase Act 2004 to determine applications in accordance with the Development Plan unless material considerations indicate otherwise. The applicant has not demonstrated compliance with Policy 11 of the Joint Core Strategy, nor has sufficient evidence been provided to satisfy the requirements of the National Planning Policy Framework in respect of design quality, residential amenity, transport impacts or the creation of highquality living environments. In these circumstances, planning permission should be refused.
Given the scale of public interest in this application and its wider implications for the future of neighbourhood shopping parades and HMO development within the Borough, I would request that the application be determined by the Planning Committee rather than under delegated powers.
I trust the points above will be taken into consideration.
Jim McMahon OBE MP 