Evidence to The Housing, Communities and Local Government Committee on Permitted Development Rights


Introduction

We have had a variety of discussions with our members on permitted development in respect of large-scale development, commercial-to-residential conversions and changes of use between different types of commercial and retail premises. We have also discussed the matter with colleagues in a wide range of organisations with an interest in this matter.

Our response is thus collected from the comments of both our members and colleagues, and they are given here very much in the manner in which we have collected them.

Responses from members

Bb members, local communities and their representatives are concerned to discover that almost any shop, restaurant, nursery or other community facility now comes with an automatic right to convert to residential.

We believe that new residential development can play a vital role in town centre recovery, but poorly planned homes will do more harm than good. We believe that it will result in a piecemeal approach, without taking into consideration that which the entire high street requires to successfully serve the community.

One of our colleagues has put it succinctly: “If we are to build back better, we need responsible development and an holistic approach to a high street’s future, which means new homes are planned for, to ensure the right balance is achieved between residential and the other offers – whether that be shops, gyms, restaurants, nurseries, soft play for kids and sports halls – so that every business and new home support one another, to create coherent and thriving neighbourhoods. This new PDR will take control away from local authorities at a time when our high street’s future depends more than ever on strong local leadership and vision.”

Bb members believe that this is a major concern for our high streets and for the future of decent housing. The government appears to have ignored much evidence of the poor outcomes that existing permitted development has delivered and has made local authority plans for the comprehensive redevelopment of towns and city centres irrelevant.  These new laws mean that democratic planning in England is heavily constrained.

It is well-recognised that the best town centres require active co- ordination at a local level. The National Planning Policy Framework support this approach, as do the objectives of the High Streets Task Force and the guidance for both the Towns Fund and the Future High Streets Fund. Blanket permitted development rights for E Use Class to residential would damage these objectives for relatively minimal returns on additional housing stock.

Our members fully understand that our town centres must change, but an all-embracing permitted development right that allows most commercial buildings to be converted to housing risks putting the long-term health of our town centres at risk for the sake of a short-term stimulus.

Putting ground floor housing in a random and uncontrolled manner within high streets does not draw footfall, does not support new businesses, reduces the potential for business growth and will undermine the viability of existing retail, cultural and commercial activities on the high street and remove convenience stores from local neighbourhoods. This will create a vicious circle whereby the reduced viability of the remaining commercial uses in turn threatens their existence and incentivises their conversion to residential.

At the neighbourhood level, we consider that local centres would be particularly at risk. The loss of local shops and services could precipitate their decline at a time when we are putting greater emphasis on the need for walkable neighbourhoods which provide a range of day-to-day needs in local centres.

The policy puts the premises of small businesses at risk of redevelopment, will impact the real diversification of the high street and could threaten the existence of E Use classes uses such as financial and legal services, health centres, GP surgeries, Post Offices, community centres and hubs, gyms, leisure facilities, education, co-working spaces, and life sciences and deter other innovations coming into town centres.

We have major concerns from our Industrial and commercial park members that Light industrial premises and the jobs and services they provide could be converted to residential, even though the locations could be far from the facilities and public transport residents need.

Financially, the proposed permitted development right reduces local authorities’ ability to raise funds to mitigate the impact of conversions due to loss of planning gain, yet increases the pressure on local services, such as schools and other social infrastructure. In a relatively short time, it could also make a significant dent in local authority finances as council tax generally results in a lower contribution to local authority finances than business rates for the same size property.

Conclusion

We therefore ask you to work with government to re-evaluate this policy. Our members and much of the business community believe more support should be given to local authorities to develop their own renewal plans, under clear direction in national policy. There is certainly the will and enthusiasm at a local level. What is often lacking is resource. 

Read the full evidence document here.

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