How Can Planning Be More Proactive in Providing Homes?
Hope McGee
In 2013, the UK government amended a planning process – called permitted development rights (PDRs) – to allow certain types of development to be carried out without the need for a full planning application.
These rights only apply to England, as house building policies for Wales, Scotland and Northern Ireland are designed by the devolved governments.
The theory was that PDRs would speed up the house building process in England, with the hope of lightening the burden on under-resourced and staffed planning authorities while tackling an ever-growing housing crisis.
PDRs, and their ongoing annual amendments, have continued to cause widespread debate. The focus of IPPO’s research has been on how PDRs allow the conversion of office and commercial space to residential use.
While countless reports have shown that supply needs to increase to tackle the pressing housing crisis, our discussions with experts across the field have shown that, in their current form, PDRs are likely not the answer.
With restrictions to properties under 1500 sqm (until March this year when the limit was lifted), most current uses of PDRs have been for the provision of 10 houses or less. In the year 21-22, only 10,000 units of net additional housing were provided in England – about 4% of total net additional units delivered that year.
In 2019, the London Assembly published a report lobbying the government to halt PDRs for office-to-housing conversions.
A spokesperson for Sadiq Khan, the two-term Mayor of London, was quoted as saying that PDRs can lead to ‘poor quality overcrowded accommodation, with serious impacts on the health and safety of residents’.
Many of the issues that occur in such forms of development are about quality control.
Commercial and office spaces are often not a suitable architecture for conversions into housing, with central areas of large floorplans not having access to enough natural light.
Significant evidence shows that housing created under PDRs, as opposed to through traditional planning routes, are lower quality in terms of size, amenity, space and location; with Ben Clifford recently leading a study uncovering the health impacts on tenants of such quality issues. When housing is created outside the usual planning routes, it also evades local authority oversight and incorporation into strategic plans, meaning necessary infrastructure, such as schools, transport or social spaces, may not be in place.
Additionally, the output often doesn’t meet demand for family homes in undersupplied areas. While demand has risen significantly for one-bedroom apartments, this is driven by an affordability crisis, forcing families into smaller and smaller apartments.
Additionally, affordable housing and community infrastructure obligations and contributions, normally negotiated through the planning process, are circumvented.
A private sector analyst told IPPO that lower standards are likely a direct result of the incentive that’s been created for individuals to work on projects with lower documentation demands. Developers drawn to these conversion projects are likely to be those focused on maximising profitability and lacking resources or design expertise.
From our research and initial conversations with experts from the associations, businesses, local authorities and academia across the UK, we have developed several key policy areas which need addressing to increase the provision of housing and quality under the current regime.
- Tackle Tax Incentives: Currently, incentives for private developers to carry out such conversions are low – with retrofit and conversions not benefitting from the VAT-free status of new developments. With the embodied carbon in existing buildings meaning that renovation and re-use are fundamental to tackling the climate impacts of the built environment, this issue is also an environmental one. There is an opportunity for greater Green Finance and the provision of carbon credits like Glasgow City Blended Finance and the Neighbourhood Homes Tax Credit to provide better incentives for rejuvenating existing properties.
- Raise Design Standards: Ideas to raise existing design standards include the certification of developers who can show a track record of good quality builds – although this does pose the risk of excluding small builders not driven by the same shareholder pressures. TCPA has also suggested basic minimum standards for all housing to overcome current gaps in building regulations. Finally, there is space for something between PDRs and full planning which incorporates the previous suggestions or more, limiting the lengthy process of planning approvals while focusing on the most important aspects of creating healthy homes.
- Strengthen Use of Planning Levies: In order to be incorporated into local strategic plans, authorities need the powers to collect S106 and Community Infrastructure Levies through all housing development, allowing provisions of infrastructure and affordable housing within neighbourhoods. For speeding up planning and facilitating better strategic planning, authority capacity needs to expand – calling for greater devolution and the funding that’s needed to accompany that. Local authorities also have the opportunity to exercise site allocations in their local plans, anticipating the use of such PDRs in certain areas; this facilitates planning for the infrastructure needed in these neighbourhoods.
- Supportive Governance Models Creating and supporting more vehicles for non-private actors and partnerships to operate within the field could see a shift in priorities. This could include joint ventures, community-led housing, Urban Development Corporations or innovative regeneration vehicles.
- Underpin Policy with Values Insight from experts outside of England has underlined how the faults within the current planning systems are rooted in an insufficient framework. Within Scottish Planning Policy, there is a strong focus on reducing health inequalities which helps to inform decisions. Whereas the Well-being of Future Generations Act 2015 and a recent White Paper outlining a plan to enshrine the Right to Adequate Housing in Wales creates a clear values-based system for public decision-making. There is a need for the big picture; a planning system which is less reactive and backed by a set of guiding principles.
Within these areas, we are continuing to look for evidence-based initiatives which can provide the most effective changes to the current policy landscape. We’re grateful for those who have taken part in the discussions so far and contributed to the research. Our aim is to provide impactful policy recommendations and therefore we welcome everyone’s continued engagement, suggestions and feedback on these initial ideas.