22 Sep 2023

CIH submits response to open consultation on additional flexibilities to support housing delivery

CIH have submitted their response to the latest government consultation on extending permitted development rights (PDR). 

The consultation (closing date 25 September) proposes substantial expansions of the PDR system to enable the delivery of housing. Proposals include significant changes to the commercial to residential PDRs including expanding or potentially removing the floorspace caps and removing vacancy requirements, changes to allow conversions from hotel and guest house to residential use, and changes around Article 23 and protected landscapes.

At CIH we believe that converting redundant buildings for housing could be an important part of the solution to the current housing emergency but that we must ensure that these conversions are contributing high-quality homes, well-connected to local places, facilities and services, that support people’s health, wellbeing and engagement in communities in the long-term.

In consultation with our planning for housing network, our development community of practice, and others in the housing and homelessness sectors, we have drafted our response to reflect this belief. 

Summary of CIH’s position

The summary of CIH’s position reflected in our response submitted is as follows:

  • There is a pressing need for more homes that are decent, safe, accessible and affordable.
  • The rising level of homelessness and evidence of the impact of the cost-of-living crisis reinforces the need for more truly affordable homes for social rent.
  • With increasing costs of materials and labour, CIH calls for greater investment in affordable housing and higher grant levels to deliver this provision.
  • CIH supports the conversion of buildings to homes where this is done to the right standard and in the right location.
  • PDR may be one route to help deliver homes at scale and speed, if local authorities can exercise more control over the quality, tenure and size mix and location as part of a plan-led approach.
  • There are some basic requirements that all homes should meet, including those provided through conversions. TCPA’s Healthy Homes principles provide a starting point for this.
  • We agree with the recommendations of the joint inquiry into rethinking commercial to residential conversions that three key areas must be addressed if PDR conversions are to play a role in addressing the housing emergency. These are that:
    • PDR standards need to be strengthened to ensure developments are of high quality,
    • local authorities need to be able to give greater direction over where conversions take place,
    • conversions should be required to contribute to affordable housing and social infrastructure.
  • Without these three areas being adequately addressed, PDR conversions risk adding to the housing emergency; creating more poor-quality accommodation with disproportionate impact on those in greatest housing need and with the least housing choice. Therefore, CIH do not agree with the further expansion of PDR flexibilities proposed until the safeguards and standards framework has been fully addressed and strengthened.

Read our full submission here