Creating spaces: Rethinking office conversions and raising standards of permitted development schemes
Chair: Paul Hackett, Director, Smith Institute
Dr Ben Clifford, UCL Bartlett School of Planning
Stephanie Pollitt, Programme Director for Housing, London First
Eloise Shepherd, Strategic Lead, Housing and Planning, London Councils
Permitted development schemes often fall short of a sustainable solution to housing shortages. But despite the bad press, can permitted development conversions can be successfully used to meet the need for affordable, good quality homes?
Ben Clifford draws on his extensive research on permitted development, while Stephanie Pollitt looks at the build-to-rent market’s response to affordability in London and Eloise Shepherd defends the role of local authority planners.
Ben Clifford highlights concerns about the quality of housing conversion through permitted development but asks if there is a role for local authorities to raise standards
To avoid clogging up the planning system with minor matters, we’ve always had categories of development that are permitted without planning permission based on a proportionality principle.
Traditionally, it was small and temporary structures. In 2013 the government expanded this to include the ability to create new housing, first, through office-to-residential conversion. This was made permanent in 2015, followed by further expansions of light industrial units to residential and retail to residential.
Government figures show that nearly 19,000 new dwellings were created under permitted development rights across Greater London. There have long been concerns about the consequences of this.
Quality is the major concerns
In 2020, the Secretary of State commissioned us to do an independent review of permitted development housing. Our main concern was quality.
The main issue about design without proper planning was that residential quality varied enormously. Some high-quality developments have come through permitted development, but a majority have not been of high quality.
About 30% of permitted development units would meet the nationally described space standards compared to 94% that came through planning permission. Only 14% had access to private or communal amenity space.
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Following our report, the government changed the requirement so that permitted developments must have adequate natural light and habitable rooms. In September 2020, the government announced that all permitted development conversions would have to comply with nationally described space standards.
About 80% of non-residential buildings could be converted to residential under permitted development. So permitted development continues. I think it has potential as part of the housing supply.
PD is not planning
By no means do I think permitted development is good. It’s not the result of a spatial vision. It’s not planning.
However, in the interests of provoking a discussion, we should note that the government has addressed the most pressing issues of space standards and natural light.
Buildings are also a significant source of global carbon emissions, and embodied carbon is becoming a much greater concern. Conversion can be more environmentally friendly than demolishing and rebuilding. This will become increasingly important, as we have seen from the debate about the M&S building on Oxford Street.
The latest figures show that 19% of commercial premises in some boroughs like Richmond or Hammersmith and Fulham are vacant. Office vacancies have grown, and that doesn’t appear to be going away with changes in how we work.
Conversion opportunities
So with these vacancies, with these environmental concerns, can we afford to totally ignore conversion opportunities?
We need to think creatively about the use of surplus commercial space in future. Given housing demand in London, that’s got to be part of it. Less reputable developers have been responsible for some poor schemes, but could more socially focused providers make positive use of PD in future?
Could local authorities themselves convert office buildings of high quality? The governance isn’t quite right, but we should not overlook the ability for conversion to form part of a housing supply.
Stephanie Pollitt warns about jumping to conclusions about office over-supply and argues that build-to-rent is a better way to ensure community-focused development
Permitted development had a bad rap in terms of providing poor-quality accommodation. But governance is changing and legislation is changing with that. So there could be the opportunity to think more creatively about how we convert disused or redundant commercial space.
But we need to be quite careful. Yes, working from home now appears to be the norm and we’re seeing vacancies in commercial office space.
However, we are still a little bit too early post-pandemic to understand how that shift will work its way through. So we need to be quite careful that we don’t get rid of our commercial space in favour of trying to convert to homes.
High street vacancies
The second point is around pepper potting. We know that there are lots of high streets that are no longer fit for purpose. We’re seeing huge vacancy rates across the board in town centres.
Theoretically, there was a good argument that you should convert some of those empty retail spaces into homes. However, you risk doing is not allowing that high street, not allowing that town centre to recover and renew itself.
You can’t bring affordable homes forward with PD, so how do we provide that affordability? I want to argue for more build to rent, which has a huge part to play in helping to solve the housing crisis. It offers a wide variety of flexibility with longer leases and everything that’s coming through on rent reform.
The build-to-rent is not solely about putting up development and putting up buildings. It’s also about community and sustainability. It’s about creating communities and the public realm. And we see the regenerative effects built around developments in their local area.
Elly Shepherd remains opposed to creating housing through permitted development but sees opportunities for conversions to address supply
A lot of the PD we saw pre-pandemic was happening on outer London high streets. Those outer London boroughs that wanted to grow their high streets and do economic development didn’t want to end up like dormitories. So it was important to retain that office space, as well as the concerns about quality.
We do have that screaming need for supply but not at any cost. We shouldn’t be introducing housing supply that is degrading people’s health and not a good environment to live in. And specifically not an environment to raise children.
So while the government has addressed space and natural light standards, the developments that could be brought forward in future may have no regard for amenity. When you’re talking about development on industrial land, how are the children going to play, what transport options are available, what shopping options are available?
Life experience, not units
It’s important not just to think in terms of units, but to think about life experience. On the social housing side, we’ve had a big push towards decent homes and improving conditions because of the travesties we’ve seen on ITV and we can’t just be allowing that kind of supply to come through.
So while things have improved, we still have concerns at London Councils. But having said that, we are in a very different context to where we were pre-pandemic. The ultimate need for office space isn’t yet established, but I’m now seeing proposals and thoughts about PDR in central London.
That may be more appealing for some local authorities, as long as these essential quality issues can be answered. Central London has school spaces. You’re talking about potentially well-connected developments as opposed to industrial land or a tower block.
If it’s done correctly, with appropriate regard for affordability and family-sized accommodation, we are not against conversion. But we are still against it through permitted development.
People always talk about planning being the blocker to development. But planning has to consider all the different needs of communities of public space and balance that up in the decisions that councils have to make.
Ben's presentation slides
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