CONSULTATION ON SUPPORTING HOUSING DELIVERY AND PUBLIC SERVICE INFRASTRUCTURE
Response by Greenwich Planning Alliance*
Part 1: Supporting housing delivery through a new national permitted development right for the change of use from the Commercial, Business and Service use class to residential
There is a lack of clarity at the heart of the consultation paper. The text refers repeatedly to the proposal being aimed at high streets and town centres but in paragraph 16 it is stated that, “The Commercial, Business and Service use class applies everywhere in all cases, not just on the high street or in town centres”. If the proposed PDR is to apply everywhere it will post a threat not only to the viability of town centres and high streets but to corner shops, village shops and other sole retailers who may be the only shop in an area.
We do not agree with the proposed new PDR. Allowing class E uses to be converted to class C3 residential use without planning consent would lead to random conversions scattered across the country. This pockmark effect would reduce the attractiveness and drawing power of high streets and town centres because of dead frontages and reduced footfall.
Such a PDR would be likely to accelerate the hollowing out of high streets and town centres. Conversion of premises to residential use would offer the prospect of a quick capital gain which would tempt landlords of commercial premises and independent, owner-occupier retailers whose profitability was marginal to sell up.
We recognise that high streets and town centres are facing serious economic problems, primarily relating to retailing. Central and local government have taken a number of measures to help diversify and rejuvenate them. Reducing the extent of high streets and town centres is one of the measures to be considered but this needs to be done in a planned way, eg by reducing retail floor space in secondary shopping areas, not randomly.
A better approach, if the government is intent on introducing this PDR, would be confine it within areas of oversupply of retail and commercial space which local authorities would designate. This would enable local authorities to integrate such action with their local plan, with Neighbourhood Plans and any other actions to revitalise high street and town centres.
Q1 Size of the buildings to which the right might apply
We oppose the proposed change of use regardless of size. Any conversion of premises to housing should be thoroughly vetted through the normal process of development control. The complex issues associated with residential development cannot be subsumed in a check list for prior approval.
In the case of the conversion of larger buildings a wider range of issues about access, parking, availability of services, amenity and recreation space should come under review.
The PDR allowing offices to be converted to housing has created a significant number of dwellings with inadequate space and daylighting standards. The government has acknowledged this and added new prior approval requirements. But other relevant planning considerations remain excluded.
In the case of larger conversions requiring investment in infrastructure and services would local authorities be able to secure a financial contribution from developers via S106 agreements? We understand that they cannot in the case of the office-to-residential PDRs.
Q2.1 Do you agree that the right should not apply in areas of outstanding natural beauty, the Broads, National Parks, areas specified by the Secretary of State for the purposes of section 41(3) of the Wildlife and Countryside Act 1981, and World Heritage Sites?
Q2.3 Do you agree that, in conservation areas only, the right should allow for prior approval of the impact of the loss of ground floor use to residential?
No. Conservation areas should not be covered by the proposed PDR. They are selected by local people and their local authorities for protection and enhancement because of their special architectural and street scape qualities and historic interest. Central government should not sweep aside these arrangements but work with local authorities to find ways of repurposing those parts of conservation areas suffering from an oversupply of retail and commercial floorspace in a properly planned way.
Matters for local consideration through prior approval
Q3.1 Do you agree that in managing the impact of the proposal, the matters set out in paragraph 21 of the consultation document should be considered in a prior approval?
No. Ensuring that new housing is fit for purpose, now and for the foreseeable future, cannot be a tick-box exercise. The list of factors in paragraph 21 omits some important planning considerations such as thermal insulation, heat and power sources and the level of emissions, amount of amenity space and access to play and recreation space. There are many other issues which arise on particular cases. For example heavy industry and waste management nearby are not the only matters that should be assessed. Even light industry in the vicinity or logistics and storage facilities may generate frequent movements of lorries and other vehicles. Many of these factors cannot be covered in a definitive list because circumstances vary but they are nonetheless important. Identifying them is what planners and urban designers are trained to do. The quality of housing created under PDR is likely to be worse without this skilled input.
Q3.2 Are there any other planning matters that should be considered?
Paragraph 17 of the consultation document permits the right to change of use to part of a building but the prior approval criteria do not deal well with consideration of the other uses in that building
Q4.1-4.2. Applications for prior approval and fees
Q5. Do you have any other comments on the proposed right for the change of use from Commercial, Business and Service use class to residential?
Part 2: Supporting public service infrastructure through the planning system
Providing further flexibilities for public service infrastructure through permitted development rights
We are not in favour of extending the existing PDRs for extensions to schools and colleges, universities and hospitals and extending them to prisons and MOD buildings on the defence estate. Such building extensions can have a significant impact on the local built environment and on local communities. They can arouse strong feelings. They are best handled through the development control process.
Any extension of the existing PDR should not apply in designated areas such a SSSIs, conservation areas, World Heritage Sites or apply to any listed buildings including buildings within their curtilage.
A faster planning application process for public service developments
We do not support the proposal to shorten the public notification and consultation period for certain major public sector service infrastructure projects from 21 days to 14 days. We do not believe this would make a significant difference to the overall timetable of projects but it would seriously prejudice the position of the public. The argument that this is justified by the practice of pre-application consultation ignores the fact that such consultation is not universally satisfactory and its reach is often limited. Furthermore with a period of only 14 days to comment people away on business, on holiday or ill may miss out.
We do not agree that the period for local authority determination of this category of applications should be reduced from 14 to 10 weeks. This risks rushed and inadequate assessment and poorer decisions. Moreover a requirement to prioritise these projects over private sector development proposals, such as large housing schemes, is undesirable and at odds with the government’s housing objectives.
Part 3: Consolidation and Simplification of PDRs
No comments on this part
- 27 January 2021
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*member organisations of the Greenwich Planning Alliance
Howard Shields – Blackheath Society
Roden Richardson – Charlton Society
Sheila Keeble - East Greenwich Residents’ Association
Laurie Baker – Eltham Society
Richard Butt – Greenwich Society
Stewart Christie – Positive Plumstead Project
Deborah Boyle – Plumstead to Peninsula
Judy Smith – South Greenwich Forum
Kevin Veness – Speak Out Woolwich
Anne Robbins – Westcombe Society
Richard Buchanan – Woolwich Antiquarian Society
Elizabeth Pearcey – Greenwich Industrial History Society