Response to CLG consultation on change from commercial to residential use of property

The key points of London Councils’ response to the CLG’s consultation on the relaxation of planning rules for the change of use from commercial (B use classes) to residential (C3 use class) are:-

• London Councils supports the aim of increasing housing supply in London, however the failure to adequately address under-supply of housing in the city is not due to the lack of sites or delays in the planning process as there are approximately 170,000 un-built homes that currently have planning permission in London.
• Other planning tools already in existence (such as PPS4) are available to remedy London’s housing undersupply problem, and are available to boroughs to achieve exactly the purpose the Government is suggesting can be achieved by this measure
• New homes created under this policy change may well be of low quality, without conforming to lifetime homes, living space or environmental standards
• There are very real and potentially expensive costs relating to use conversion that may not be accounted for without the planning process, including compliance with safety requirements, introducing supporting infrastructure, premise design and the appropriateness of converting commercial premises to housing use
• There will be a loss of Section 106 and CIL income to boroughs which is a valuable resource used to provide homes and infrastructure, as well as possible loss of business rates income in the future
• The proposal potentially undermines boroughs' abilities to effectively plan for longer term community infrastructure for issues such as school place demands
• There is a significant threat that the higher land values for business sites converted to housing could have the effect of undermining business within an area as well as constraining business development within a locality
• Boroughs in preparing their local development frameworks have already identified land that is or is not suitable for housing, which means that a proposal of this nature at this time is not necessary and will be of extremely limited use
• The proposal runs contrary to the Government’s stated localist intent.

For the full response, please download above.