pdr conversions research study · 2020. 8. 27. · final report – pdr conversions research study...

PDR Conversions Research Study

London Borough of Enfield

July 2020

Final Report – PDR Conversions Research Study – L.B. Enfield

Prepared for: London Borough of Enfield

AECOM

Quality information

Prepared by Checked by Verified by Approved by

Paul Avery Senior Housing Research Consultant

Kerry Parr

Associate Director

Stephanie Brewer Associate Director

Stephanie Brewer

Associate Director

Guillaume Rey Graduate Urban Planner and Social Consultant

Karlene Stubbs

Graduate Consultant

Akwesi Osei

Graduate Consultant

Revision History

Revision Revision date Details Authorized Name Position

1 13 November 2019 Interim findings SB Stephanie Brewer

Associate Planner

2 11 December 2019 Draft report SB Stephanie Brewer

Associate Planner

3 2 March 2020 Second Draft with additional analysis, updated data, and justification section

SB Stephanie Brewer

Associate Planner

4 5 May 2020 Final report following client comment

SB Stephanie Brewer

Associate Planner

5 21 July 2020 Additional analysis

SB Stephanie Brewer

Associate Planner



AECOM

Prepared for:

London Borough of Enfield

Prepared by:

Paul Avery

Housing Research Consultant

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M: +44 (0)779 963 5065

E: [email protected]

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Table of Contents

List of abbreviations ................................................................................................................................................ 7

Executive summary .................................................................................................... 8

Introduction ............................................................................................................................................................. 8

Conversions data .................................................................................................................................................... 8

Heritage assets ....................................................................................................................................................... 9

Employment need ................................................................................................................................................. 10

Housing need ........................................................................................................................................................ 11

Housing quality...................................................................................................................................................... 12

Council revenues .................................................................................................................................................. 12

Potential for intervention ....................................................................................................................................... 12

1. Literature review ............................................................................................ 14

Permitted Development Rights.............................................................................................................................. 14

Enfield policy context - offices ............................................................................................................................... 16

Enfield policy context - retail ................................................................................................................................. 17

2. Conversions data ........................................................................................... 19

Introduction ........................................................................................................................................................... 19

Completed office to residential conversions .......................................................................................................... 19

Location of completed O2R conversions ............................................................................................................... 21

O2R Conversion pipeline ...................................................................................................................................... 26

Location of O2R conversion pipeline ..................................................................................................................... 26

Reasons for refusal ............................................................................................................................................... 27

Retail to residential PDR conversions ................................................................................................................... 28

Non-PDR retail conversions data .......................................................................................................................... 28

Location of retail conversions ................................................................................................................................ 29

Non-PDR conversions affecting other employment uses ...................................................................................... 31

Retail PDR conversions - conclusion .................................................................................................................... 31

3. Heritage assets .............................................................................................. 32

Introduction ........................................................................................................................................................... 32

Listed buildings ..................................................................................................................................................... 32

Conservation area impacts ................................................................................................................................... 32

4. Employment need .......................................................................................... 35

Introduction ........................................................................................................................................................... 35

The Enfield office market....................................................................................................................................... 35

Office demand ....................................................................................................................................................... 35

Retail demand ....................................................................................................................................................... 36

Loss of office space through PDR ......................................................................................................................... 36

Office vacancy ....................................................................................................................................................... 36

Retail vacancy ....................................................................................................................................................... 38

Office rental values ............................................................................................................................................... 38

Retail rental values ................................................................................................................................................ 39

Office size considerations ..................................................................................................................................... 39

Office location ....................................................................................................................................................... 41

Forecast office need .............................................................................................................................................. 41

Future office supply ............................................................................................................................................... 41

5. Housing need ................................................................................................ 43

Introduction ........................................................................................................................................................... 43

Conversions in the context of past delivery ........................................................................................................... 43

Conversions in the context of housing targets ...................................................................................................... 43

Size and type ........................................................................................................................................................ 44



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Affordable housing ................................................................................................................................................ 45

6. Housing quality .............................................................................................. 48

Introduction ........................................................................................................................................................... 48

Quality appraisal ................................................................................................................................................... 48

Agent interviews .................................................................................................................................................... 49

Other evidence ...................................................................................................................................................... 50

7. Council revenues ........................................................................................... 51

Introduction ........................................................................................................................................................... 51

Section 106 ........................................................................................................................................................... 51

CIL contributions ................................................................................................................................................... 52

Business rates and council tax .............................................................................................................................. 52

8. Potential for intervention ................................................................................ 55

Introduction ........................................................................................................................................................... 55

Emerging Local Plan policy ................................................................................................................................... 55

A4D policy context ................................................................................................................................................ 55

Summary of evidence justifying intervention in Enfield ......................................................................................... 56

London A4D case studies ..................................................................................................................................... 60

Appendix A : Enfield completed scheme locations ................................................... 63

Appendix B : CIL calculations ................................................................................... 66

Appendix C : Detailed London A4D Case Studies .................................................... 67

Camden ................................................................................................................................................................ 67

Croydon ................................................................................................................................................................ 68

Old Oak and Park Royal Development Corporation (OPDC) ................................................................................ 68

Richmond upon Thames ....................................................................................................................................... 69



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Figures

Figure 2-1: Completed O2R PDR conversions (FY2014-2018) – Number of schemes to known office floorspace

lost ........................................................................................................................................................................ 20 Figure 2-2: Completed O2R PDR conversions (FY2014-2018) – Number of schemes to residential units gained 20 Figure 2-3: O2R PDR schemes location within Enfield ......................................................................................... 22 Figure 2-4: O2R PDR schemes location in vicinity of Enfield Town Centre ........................................................... 23 Figure 2-5: O2R PDR schemes location in vicinity of Southgate........................................................................... 24 Figure 2-6: O2R PDR schemes location in vicinity of Palmers Green ................................................................... 25 Figure 2-7: Trend in applications for prior approvals for O2R conversion in Enfield .............................................. 27 Figure 2-8: Location of (completed and pipeline) retail to residential schemes in Enfield, PDR and full planning

permission ............................................................................................................................................................. 30 Figure 4-1: Total Enfield office space and vacancy rate (2010-2019) .................................................................... 37 Figure 4-2: Average rental value per sqm evolution in Enfield .............................................................................. 39 Figure 4-3: Office development forecast ............................................................................................................... 42 Figure 5-1: Proportion of overall residential delivery through PDR (annual) ......................................................... 43 Figure 5-2: Proportion of Enfield’s housing target met by PDR conversions ......................................................... 44

Tables

Table 2-1: Number of O2R PDR schemes completed, B1 office floorspace lost to residential through PDR (sqm)

and sum of residential units gained from offices to residential PDR ...................................................................... 19 Table 2-2: Number of completed schemes per ward ............................................................................................. 21 Table 2-3: Total floorspace loss (sqm) per ward .................................................................................................... 21 Table 2-4: Number of O2R PDR schemes in the pipeline (class O prior approval applications made 2014-2018

but not yet built out in 2019), B1 office floorspace expected to be lost to residential through PDR (sqm) and sum

of residential units to be gained, by permission year............................................................................................. 26 Table 2-5: Number of pipeline schemes and known floorspace lost per ward ....................................................... 27 Table 2-6: Number of completed schemes per ward ............................................................................................. 29 Table 2-7: Non-PDR change of use schemes, Enfield 2013-2019 ........................................................................ 31 Table 4-1: Office space loss .................................................................................................................................. 38 Table 4-2: Stock and vacancy by unit size in Enfield, 2019 ................................................................................... 40 Table 4-3: Size of office units lost to residential conversion (completed schemes) ............................................... 40 Table 4-4: Stock and vacancy by size: comparison between existing and converted floorspace .......................... 40 Table 5-1: Proportion of overall residential delivery through PDR (annual) ........................................................... 43 Table 5-2: Size of completed O2R PDR new units ................................................................................................ 45 Table 5-3: Type of completed O2R PDR new units ............................................................................................... 45 Table 5-4: Affordable housing and PDR delivery rates .......................................................................................... 47 Table 6-1: Quality analysis table............................................................................................................................ 49 Table 8-1 : Summary of evidence justifying an intervention .................................................................................. 56



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List of abbreviations

A4D – Article 4 Direction

CAZ – Central Activities Zone

CIL – Community Infrastructure Levy

DCLG – Department for Communities and Local Government (now MHCLG)

DMD – Enfield Development Management Document 2014

DNLP – Draft New London Plan (various versions cited)

ELR – Enfield Employment Land Review 2018

FEMA – Functional Economic Market Area

FY – Financial Year

GDPO – General Permitted Development (England) Order

GLA – Greater London Authority

LDD – London Development Database

LOPR – London Office Policy Review 2017

LPA – Local Planning Authority

LSIS – Locally Significant Industrial Sites

MHCLG - Ministry for Communities, Housing and Local Government (formerly DCLG)

NPPF – National Planning Policy Framework

O2R - Office to Residential

PDR – Permitted Development Rights

PPG – Planning Practice Guidance

PTAL – Public Transport Accessibility Level

RICS – Royal Institution of Chartered Surveyors

S106 – Section 106

SHMA – Strategic Housing Market Assessment

SME – Small and Medium Enterprise

SQM – Square Metres

UCL – University College London

VOA – Valuation Office Agency

Final Report – Permitted Development Rights Research Study – L.B. Enfield

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Executive summary

Introduction

1. This report details the effects of Permitted Development Rights (PDR) in Enfield.

2. It explores the scale, nature and location of office to residential (O2R) PDR conversions in Enfield, their role

in meeting future housing needs versus demand for employment space, and the appropriate way forward

for Enfield’s emerging Local Plan and other potential responses as regards this matter.

3. It also explores PDR conversions affecting other employment uses (namely retail) and their potential

implications, although these are far fewer in number and significance than O2R conversions and are

accordingly the lesser focus in this analysis.

4. The findings of the study aim to help Enfield in developing relevant policies for the Regulation 19 Draft Local

Plan and/or other appropriate interventions, such as a potential Article 4 Direction (A4D). Where justified

and allowed by the Secretary of State, an A4D can enable a Local Planning Authority (LPA) to remove PDR

within a given area, thereby bringing formerly PDR-applicable schemes back within the normal planning

system. It is understood that the Council is considering this measure.

5. The report consists of findings in relation to PDR on:

• Conversions data – the number, location and size of PDR conversions;

• Heritage assets – the scale and nature of the risks to listed buildings and conservation areas;

• Employment need – the relative impact of PDR conversions on the stock of (and demand for)

employment space;

• Housing need – the contribution of PDR conversions to Enfield’s housing delivery in terms of the

quantity and type of housing needed;

• Housing quality – an appraisal of the quality of residential delivery through PDR;

• Council revenues – the estimated impact of PDR conversion on various streams of Council revenue;

and

• Potential for intervention – the options for intervention, the planning policy context, and comparable

Greater London examples.

6. The key findings on each of the above areas of study are presented below, followed by the potential way

forward as regards the Council’s intervention.

Conversions data

Office to residential PDR

7. Office to Residential Permitted Development Rights (O2R PDR) conversions peaked in 2015 (17 schemes)

and 2016 (12 schemes), likely reflecting a rush to convert following the introduction of PDR in 2013 with a

delay for construction lead times. This has since stabilised to a lower level of 5-7 schemes per year, which a

review of the pipeline suggests will be sustained.

8. Total office floorspace lost to PDR conversions in the period 2014-2018 stands at 20,050 sqm, counting only

the 30 schemes for which floorspace data was available. On that basis the average scheme size was 668

sqm. The average floorspace lost per residential unit gained, taking into account both completions and

pipeline data, is 51.4 sqm. This provides an estimate of 25,396 sqm of total office space lost to completed

PDR conversions in 2014-2018.

9. A total of 429 residential units were delivered during the period through O2R PDR.

10. The three wards with the highest amount of office floorspace converted through O2R PDR (Southbury,

Grange and Town) effectively constitute the functional extent of Enfield Town Centre. Not every scheme

counted in these wards falls within the actual town centre boundary but aside from one exception they are in

the immediate vicinity. Together, the three wards include more than half of converted O2R PDR schemes


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(25) and 74% of floorspace lost. Southgate is the next most affected area with 7 schemes and 12.6% of

total Borough floorspace lost there.

11. There are 24 O2R PDR schemes in the pipeline at the time of writing. They are expected to deliver 309

residential units and are estimated to result in a loss of 12,552 sqm of office floorspace.

12. Overall, pipeline O2R PDR schemes are more evenly spread across Enfield, with less of a concentration in

key centres. However, Enfield Town and Southgate are still the locations which are predicted to have the

highest percentage of expected office floorspace loss and which contain many of the biggest schemes. The

two town centre areas together represent 13 of the 24 pipeline schemes, and 61.6% of expected office

floorspace loss.

13. The majority of O2R PDR schemes in Enfield did not require prior approval (63.8% of all applications). Most

of the applications where prior approval was required were refused (74%).

Retail to residential PDR

14. All of the PDR conversions in Enfield that were not office to residential were retail to residential conversions.

The few other change of use schemes that could in theory be subject to PDR have been taken forward with

full planning permission.

15. There have been 5 PDR retail to residential conversions since 2013 and there are 5 currently in the

pipeline. This equates to 12.3% of all PDR schemes, with the remaining 87.7% being O2R schemes.

16. Although the total residential gain from completed and pipeline schemes is 15 dwellings, the vast majority of

retail to residential conversions through PDR delivered only one dwelling.

17. The location of retail to residential PDR conversions has not been limited to one particular area of the

borough, although 40% of completed and pipeline schemes fall within the functional extent of Enfield Town

Centre, which is identified as the retail area most worthy of protection in Enfield planning policy. There are

no known conversion schemes in Southgate.

18. There have been 15 retail to residential conversion schemes completed with full planning permission since

PDR were introduced, and a further 18 granted for development in future. This is more than double the

number of schemes taken forward through PDR in the same period. 31% of retail to residential conversions

made use of PDR, compared with 83% of O2R conversions that did so.

19. Furthermore, the rate of planning permissions for retail conversions has increased in recent years in line

with Enfield’s intended relaxation of restrictions on such schemes in the emerging new Local Plan.

20. While the Council’s emerging policy position weakens the justification to restrict or control retail to

residential PDR through an intervention,1 it also seeks to determine each retail loss in light of the role it

plays in meeting local needs and maintaining town centre vitality. As such, restrictions on PDR, if pursued,

could better enable the Council to achieve this aim, and may be particularly valuable in affording greater

scrutiny over the potential loss of retail in the key location of Enfield Town Centre. Beyond this, the

justification to intervene on the evidence gathered here is relatively weak.

Heritage assets

21. It is clear that while listed buildings have not suffered direct, measurable harm from PDR conversions, such

schemes pose potentially significant ongoing cumulative harm to the appearance of conservation areas and

the market town character of Enfield.

22. 10 past PDR conversions and 4 pipeline schemes sit within designated conservation areas, representing

12% of all known PDR schemes. Such schemes are not subject to the various measures that have been put

in place to protect the borough’s considerable heritage merit.

23. The risks to heritage arising from retail to residential PDR conversions would appear to be greater because

shopping parades are a key element of the special interest of Enfield’s Conservation Areas, upon which

inappropriate redevelopment can exert significant visual impacts as well as erode heritage land uses.

However, retail to residential PDR conversions are relatively few in number within such areas. O2R

1 The intention in Enfield’s emerging new Local Plan to 2036 is to maintain but soften protection for the loss of retail floorspace. Change of use from retail is not to be refused outright, but to be considered on a case-by-case basis in light of each unit’s role in maintaining town centre viability and vitality. It is acknowledged in the Regulation 18 Issues and Options Local Plan publication that housing should be part of the balance in town centres. The Enfield Town Centre Framework Masterplan states that there are locations and sizes of retail unit that may be in surplus or not suitable to modern needs.


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conversions are far more prevalent, but their risks are primarily limited to the erosion of the appearance and

character of Conservation Areas through changes to building fabric.

24. A further intervention on the part of the Council to remove PDR for change of use conversions within

Conservation Areas, or the town centres of which they form a part, would help to further safeguard these

areas from the further erosion of their character and patterns of use.

Employment need

The office sector

25. Enfield is not a strategic office location for Greater London, with companies and office space tending to

largely serve the local economy. However, office work is an important source of local employment, with

17,300 office-based jobs in 2016.

26. Demand for office space in Enfield is currently stable rather than rising. However, it is expected to grow in

line with economic forecasts, the borough’s increasing focus on high-value jobs, and the potential of

Crossrail 2.

27. Total completed and pipeline O2R PDR conversions as discussed above represent 16.3% of the total

available Borough office floorspace existing at the time of the introduction of PDR in 2013.

28. Total office floorspace in Enfield is currently 224,474 sqm, of which 220,677 sqm is occupied and 3,797 sqm

is vacant. The vacancy rate of 1.7% is extremely low compared to other locations and to previous years,

and has decreased over time. This is due less to an increase in demand and more to a reduction in supply

resulting from PDR.

29. The London Office Policy Review (LOPR) 2017 assumes that the equilibrium or ‘frictional’ vacancy rate

below which additional supply is needed to bring an office market back to a normal operating state is 8%.

Enfield’s vacancy rate has fallen far below this level.

30. This is because an average of 2% of Enfield’s existing office stock has been lost to PDR conversion every

year since its introduction. The expected rate of conversion for 2019-20 is 3.48%.

31. The average office rent per sqm in Enfield at the time of writing is £258.33, following average annual growth

of 6% over the past 5 years and a 42% increase on 2010 rents. However, the correlation between rents,

supply and vacancy levels is not clear-cut.

32. There are 307 office units in Enfield with an average size of 731 sqm. The average size is increasing as a

result of PDR, which has been focused on the more numerous small units. Vacancy is generally lower for

smaller units, with demand remaining resilient as the stock is reduced through PDR.

33. Since the introduction of PDR, the office unit size bands that have been disproportionately affected by

conversions now display the lowest vacancy levels. The 250-500 sqm size category currently has a vacancy

rate of 0% and has experienced a significant amount of conversion. Particularly given the potential shortage

of grow-on space required for SMEs identified in the 2018 Enfield Employment Land Review (ELR), this

size category is the most at-risk segment of Enfield’s stock.

34. The prospects for future supply to replenish office stock lost to conversion are poor, with an expected net

loss of office space after pipeline conversions are deducted from supply.

35. In terms of location within the borough, conversion is happening within the key office markets where the

stock of available units to convert is greatest, namely Enfield Town Centre and, to a lesser extent,

Southgate.

The retail sector

36. Enfield’s retail sector is relatively healthy, with growing expenditure and employment, although the market is

evolving in line with national and technological shifts. Vacancy is low (1.2%) and rents are increasing (2.8%

from 2018 to 2019), but neither indicator represents a departure from historic trends. Since the introduction

of PDR, there has been a net gain of retail floorspace. There is little evidence that change of use from retail

to residential (through PDR or otherwise) has had a significant impact on the economic strength of the

sector.

37. In terms of benefit to the local community, the median gain of one dwelling per retail PDR scheme is likely to

be insufficient compensation for the loss of a retail business and its associated jobs. However, whether the

affected retail units were occupied, fit for use, or important to local amenity is not known for the schemes in

question.


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38. In terms of the loss of retail stock, the small number of retail to residential PDR conversions has little impact

on the total available retail floorspace, with new retail space delivery projected to continue, and the majority

of single dwelling conversions assumed to primarily affect the small retail units that the ELR suggests are in

surplus.

39. The relative harm brought about through PDR conversion of retail to residential is considered to be minimal

and not sufficient to justify intervention on the part of the Council.

Housing need

40. PDR conversion has made a relatively significant contribution to residential delivery in Enfield since it was

introduced. The annual average is 16% of all housing supply during a period of delivery stress. There has

been significant annual variation: excluding the peak years 2015 and 2016, the annual average is 7%.

41. The average annual delivery rate through PDR conversion of 87 units would meet only 7% of Enfield’s

housing target of 1,246 in the Intend to Publish version of the Draft New London Plan (DNLP)2. However,

Enfield’s average residential delivery over 2014-2018 of 529 units is just 42.4% of that anticipated target, so

there is a compelling need for all types of new housing in general in the borough.

42. For context, even if all the 224,474 remaining sqm of office floorspace in the borough in 2019 was to be

converted to residential accommodation, this would only be capable of delivering approximately 4,367

dwellings. This equates to three and a half years’ worth of Enfield’s DNLP target of 1,246 units per year.

43. Dwellings brought about through PDR conversions are overwhelmingly small in terms of bedrooms (98% of

O2R conversions have fewer than 3 bedrooms), and almost exclusively flats (99.1% of O2R conversions

are flats or maisonettes).

44. The Enfield Strategic Housing Market Assessment (SHMA) (2015) finds that 50% of market housing and

affordable rented housing should consist of three and four bedroom dwellings, a conclusion that is also

supported by evidence that 47.3% of need on Enfield’s Local Housing Register is for larger family-sized

homes (i.e. those with three or more bedrooms).

45. It is therefore the case that 98% of all O2R PDR housing supply can therefore be said to fall into a typology

that represents only 50% of need as identified in the SHMA. Outside of the planning system, O2R

conversions cannot be expected to deliver towards the borough’s identified need to supply larger homes (of

more than 3 bedrooms) and a more diverse mix of units in terms of type, size and tenure.

46. The Enfield SHMA (2015) identified an annual net shortfall of 456 affordable rented dwellings over the

period to 2032 in Enfield. Recognising the magnitude of the borough’s affordable housing need, Enfield’s

draft Local Plan (Issues and Options publication 2018) proposes a strategic target that 50% of new housing

in the period to 2036 should be affordable. This is in line with the level of affordable housing need and the

strategic target put forward in the DNLP, and also reflects the first of Enfield’s five priorities set out in the

Enfield Housing and Growth Strategy 2020-3030.

47. PDR conversions are not required to provide affordable housing and no schemes completed so far have

done so. Applying Enfield’s current Core Strategy policy requirements to the completed and pipeline O2R

PDR schemes suggests that the maximum quantity of affordable housing that would have been provided

were those schemes subject to policy is 266 units, subject to viability. This estimate is reduced to 263 units

if Enfield has ceased to collect contributions from sites delivering fewer than 10 dwellings and will continue

with this approach going forward.

48. The number of affordable housing units delivered in Enfield between 2014 and 2017 was 546, so this lost

supply is significant.

49. However, it should be emphasised that the office conversion rate in Enfield prior to the introduction of PDR

was extremely low, and it is likely that the additional requirements that accompany a full planning application

would make many conversion schemes unviable or undesirable in comparison with continued receipt of

office rents. Therefore, the likely outcome of the removal of PDR would be the retention of office stock

rather than the continuation of a high rate of residential delivery through conversions subject to normal

planning requirements such as affordable housing provision.

2 At the time of finalising this report in February 2020, the Draft new London Plan (DNLP) was undergoing Examination in Public and the latest version of it which was publicly available was the ‘Intend to Publish’ version dated December 2019. This followed the GLA’s receipt of the Inspectors’ Panel report. The DNLP will not be fully finalised and adopted until after the GLA receive the Secretary of State’s response, anticipated on 16 March 2020.


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Housing quality

50. The sample of O2R PDR schemes reviewed does not appear to raise any major issues of substandard

quality housing being provided. However, space standards are only met in around half of cases and the

proportion of wheelchair accessible units is low among the vast majority of schemes surveyed.

51. Additional anecdotal evidence supplied by the Council does, however, suggest that a small number of PDR

schemes that are deficient in terms of space standards continue to come forward. Cases have also been

observed in which the residential units become smaller as an application proceeds from pre-application to

application stage.

52. Property agent awareness of O2R PDR conversion is generally low, but among those who expressed an

opinion there were few known or shared concerns. The specification of residential units brought forward

through O2R PDR and their suitability to agents’ perceptions of market demand was expressed to be high.

Council revenues

53. The foregone Section 106 (S106) contributions (excluding affordable housing) for completed O2R PDR

conversions to date is estimated to be £1,287,000. The equivalent estimate for pipeline schemes is

£927,000. The total estimated revenue that would have been received were O2R conversions not subject to

PDR is therefore £2,214,000.

54. It is important to note that PDR schemes are considered to be acceptable in planning terms, implying that

foregone S106 revenue alone should not be used as a justification to remove PDR. Recouping some of this

revenue for future schemes would be a by-product of an A4D, but it is the view of this study that it should

not be cited as a primary justification.

55. Placing planning obligations on schemes formerly subject to PDR may also render them unviable or require

changes to the number of units or other aspects to maintain viability. It is unlikely that the full estimate of

foregone S106 revenue would have been received were PDR removed because it is highly likely that fewer

schemes would have come forward without PDR. This is a reasonable assumption based on past low rates

of O2R conversions before PDR was introduced.

56. PDR conversions are exempt from making Community Infrastructure Levy (CIL) contributions, but this is

because they fall under the category of change of use schemes, rather than because they are subject to

PDR. As such, there are no CIL revenues that were foregone due to PDR. That said, bringing future

conversions within the normal planning process would (as a side-effect rather than a stated purpose)

potentially make CIL collection easier and help to reduce the rate of non-compliance.

57. The estimated annual council tax received for new residential dwellings provided through O2R PDR is

slightly higher than the estimated annual business rates revenue lost as a result of removing office space

from the stock. The net impact is an annual gain of £106,222. O2R PDR conversion is therefore understood

to be relatively tax-neutral and not a strong basis upon which a decision to intervene against PDR should be

made.

Potential for intervention

58. Enfield’s existing and draft policies, supported by the objectives of the emerging Local Plan, make provision

for O2R conversion. These should be retained so that if an A4D is pursued at any time within the Plan

period, there is adequate policy guidance. Minor changes to planning policy that would strengthen existing

requirements are recommended, such as expanding protected office unit size categories.

59. Planning Practice Guidance (PPG) states that A4Ds ‘should be limited to situations where this is necessary

to protect local amenity or the wellbeing of the area’ and ‘the potential harm that the direction is intended to

address will need to be clearly identified’.

60. On the basis of the evidence considered, it is the view of this study that an intervention to restrict and

control O2R PDR in Enfield through an A4D would be advantageous. There is little to justify a similar

restriction to retail to residential PDR.

61. A successful O2R A4D would allow the Council to stem the tide of future conversions if the declining

availability of office space impacts the local economy. It would also bring the conversion of office

accommodation to residential uses within the jurisdiction of the normal planning system. Applications would

therefore be subject to a more detailed process of scrutiny and negotiation by the Council, with schemes

subject to policy requirements including those preventing the conversion of office units of a particular size


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and those relating to housing mix and tenure. They would also be subject to planning application fees and

S106 contributions.

62. Restricting PDR through an A4D is, however, not a unilateral decision but one that is scrutinised by the

Secretary of State and liable to be amended or cancelled at their discretion. This study does not take a view

on the probability that an A4D put into place by the Council will survive that scrutiny. It is therefore important

that if Enfield decides to pursue this course of action its justification is considered carefully.


14

1. Literature review

Permitted Development Rights

63. In an effort to boost housing supply, central government introduced temporary policy in 2013 allowing for the

conversion of buildings of certain use classes to residential use without the need for full planning

permission, resulting in the Permitted Development Rights (PDR), granted by Class O of Part 3 in the

Second Schedule to the General Permitted Development (England) Order (GPDO).3

64. Opposed by several London boroughs and other Local Authorities, there has been much discussion

regarding the benefits and costs associated with O2R PDR in particular.

65. The relevant provision of the legislation permits “Development consisting of a change of use of a building

and any land within its curtilage from a use falling within Class B1(a) (offices) of the Schedule to the Use

Classes Order, to a use falling within Class C3 (dwelling houses) of that Schedule.”4 Prior approval for the

conversion is not obligatory, but the developer must apply to the Local Planning Authority (LPA) for a

determination as to whether the prior approval is required as to transport and highways impacts of the

development, contamination and flooding risks on the site. The LPA can decide that prior approval will not

be required for a given scheme, or that it is required and subsequently grant or refuse such approval.

66. Originally applying for a temporary period of three years, PDR was made permanent in April 2016. The

legislation was amended to consider noise issues in the prior approval process and to require applicants to

specify the number of dwellings proposed. However, the immediate spike in conversions (with almost 4,000

given the go-ahead between April 2014 and June 20155) and the potential impact of lost office space raised

by concerned authorities were not addressed at the time the legislation was made permanent.

67. The government believed that “the changes would encourage developers to bring underused offices back

into effective use as houses for local residents … They will provide badly needed homes … they will also

help create jobs in the construction and service industries, and help regenerate our town centres.”6 While

this may be true, lost office space in strategic areas has been shown to negatively impact economic activity

and prevent SMEs from remaining in certain areas,7 while the residential accommodation delivered is

perceived to frequently be sub-standard and lacking in affordable housing provision.

68. In the case of PDR, a planning obligation can in principle be agreed by the Local Authority and developer,

but only as a means of dealing with technical matters such as flood risks, cycle parking or securing funding

for the management of traffic. It is unlikely that a S106 agreement can be negotiated to fund local

infrastructure or affordable housing under PDR. Furthermore, if the building has been in lawful use as an

office during a continuous period of at least six months in the three years ending on the day prior approval

was first sought (and does not create any new build floorspace), then the permitted development is not

liable for Community Infrastructure Levy (CIL) contributions.8

69. Questions have therefore been raised about the extent of PDR’s benefit to the wider community and the

diminishing ability of the Local Authority to both promote long-term economic development and control

residential standards.9

70. The 2018 Raynsford Review of Planning attributes some of the problems associated with PDR to flaws in

the current planning system in England, describing an ineffective system plagued by conflicting policy

objectives and significant deregulation.10 The cost of this ‘non-planning’ include the loss of 1,000 new

affordable homes or equivalent Section 106 (S106) developer contributions from schemes granted prior

approval by London boroughs in 2015, and a decline of office stock in England of 9 million square feet.11

The Review believes that PDR threatens the viability of local office markets and economic centres,

3 http://www.legislation.gov.uk/uksi/2015/596/contents/made. 4 Ibid. 5 DCLG (2015). Thousands more homes to be developed in planning shake up. Available at: https://www.gov.uk/government/news/thousands-more-homes-tobe-developed-in-planning-shake-up. 6 UK Parliament (2013) Change of use: promoting regeneration. At: https://www.gov.uk/government/speeches/change-of-use-promotingregeneration. 7 GLA (2017) London Office Policy Review 2017, with Radimus Consulting. Greater London Authority, London. 8 Bibby, P., Brindley, P., Dunning, R., Henneberry, J., McClean, A. and Tubridy, D. (2018) The Exercise of Permitted Development Rights in England Since 2010, Report to the RICS Research Trust, RICS, London. 9 Goodall, M. (2016) A practical guide to permitted changes of use. Second Edition. Bath Publishing, Bath. 10 Planning 2020 – Final Report of the Raynsford Review of Planning in England. Town and Country Planning Association. Nov, 2018. https://www.tcpa.org.uk/Handlers/Download.ashx?IDMF=30864427-d8dc-4b0b-88ed-c6e0f08c0edd. 11 Permitted Development Rights: One Year on from Permanence. British Council for Offices, Sept. 2017. Available at: http://www.bco.org.uk/Research/Publications/Permitted_Development_Rights.aspx.


15

endangering small and medium-sized enterprises and the voluntary sector who depend on low-rent office

spaces – causing an overall displacement of jobs.12 It states that among the most urgently needed reforms

to the planning system is the restoration of “basic controls over the conversion of office and commercial

buildings to housing units.”

71. Research undertaken for the Royal Institution of Chartered Surveyors (RICS) published in 2018 argues that

“overall, office-to-residential PD has been a fiscal giveaway from the state to private sector real estate

interests, while leaving a legacy of a higher quantum of poor-quality housing than is seen with schemes

governed through full planning permission.”13

72. In contrast, supporters of O2R PDR believe that technology and innovative working patterns are reducing

the demand for office space, a trend expected to accelerate. They see policies that seek to resist

redevelopment of industrial land and office premises as serving to protect empty and derelict sites which

should be making a positive economic contribution if redeveloped for other purposes.14

73. The speed and efficiency of PDR are also welcomed in an era of growing concern over London’s housing

crisis. The government has highlighted various benefits of PDR, including the lack of monetised costs from

the policy change, efficiencies for business stemming from the reduced regulatory requirement for change

of use, the assertion that external impacts of residential development are likely to be equal to or less than

those for office use and thus unlikely to have any potential costs in terms of additional infrastructure

requirements. The government also cited benefits to Local Authorities from the reduced planning burden

and resultant administrative cost savings.15

74. At the London level, monitoring by the Greater London Authority (GLA) and the London Development

Database (LDD) suggest that O2R conversions through PDR have had a modest effect on housing

delivery.16 There is also an issue of a large gap between consents and implementations,17 which could be

explained by the fact that “securing a prior approval could provide a negotiating tool for a developer who

would really prefer a more flexible planning consent.”18

75. In terms of future trends, research suggests that O2R conversions will continue to be motivated by the

benefit to developers in terms of the difference between office and residential land values.19 However, a

growing number of A4Ds sought by Local Authorities could have the effect of slowing the rate of

conversions in key areas.

76. A4Ds exist as an optional direction though which individual Local Planning Authorities may seek to

reimpose the requirement for planning permission in specific areas or premises. Originally widely used in

relation to heritage and conservation issues, an A4D can be pursued when the local planning authority

considers PDR development to be “prejudicial to the proper planning of their area or constitute a threat to

the amenities of their area.”20 The local planning authority must submit the direction the Secretary of State,

who can then modify the direction as they see fit.

77. The government issues guidance on submitting an A4D that local authorities should consider making them

only in exceptional circumstances where the exercise of PDR would harm local amenity or the proper

planning of the area.21 The government retains the right to modify the direction if they are considered to be

‘inappropriate’ or ‘disproportionate’, as seen in the London Boroughs of Islington and Richmond.22

12 Planning 2020 – Final Report of the Raynsford Review of Planning in England. Town and Country Planning Association. Nov, 2018. Available at: https://www.tcpa.org.uk/Handlers/Download.ashx?IDMF=30864427-d8dc-4b0b-88ed-c6e0f08c0edd. Ibid. 13 B Clifford, J Ferm, N Livingstone and P Canelas: Assessing the Impacts of Extending Permitted Development Rights to Office-to-Residential Change of Use in England. Royal Institution of Chartered Surveyors, May 2018. Available at: https://www.rics.org/globalassets/ricswebsite/media/knowledge/research/research-reports/assessing-the-impacts-of-extending-permitted-development-rights-to-office-toresidential-change-of-use-in-england-rics.pdf. 14 https://planninglawblog.blogspot.com/2016/06/residential-conversion-of-offices-in.html. 15 DCLG (2013) Relaxation of planning rules for change of use from offices to residential: Impact assessment. At: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/207922/Relaxation_of_planning_rules. 16 RCIS (2018) Assessing the impacts of extending permitted development rights to office-to-residential change of use in England. Royal Institution of Chartered Surveyors, London. 17 Johnson, A. (2015) What contribution has the newly created Class J B1(a)-C3 permitted development made towards housing supply in London and to what extent has this contribution met housing need. Bartlett School of Planning, UCL, Unpublished Master’s Dissertation. 18 BCO (2015) Office-to-Residential Conversion—Establishing the Impacts of the Prior Approval Regime. British Council for Offices, London. 19 BCO (2017) Permitted Development Rights—One year on from permanence. British Council for Offices, London 20 http://www.legislation.gov.uk/uksi/2015/596/schedule/3/made. 21 PPG Paragraph: 045 Reference ID: 13-045-20140306. 22 https://www.londoncouncils.gov.uk/our-key-themes/housing-and-planning/permitted-development-rights-offices/article-4-directions.

https://www.tcpa.org.uk/Handlers/Download.ashx?IDMF=30864427-d8dc-4b0b-88ed-c6e0f08c0edd


16

78. Certain areas of London, including the Central Activities Zone (CAZ), the Canary Wharf area and Tech City

have been exempted from PDR on the basis of economic importance, but A4D remains the main method by

which other London boroughs can resist O2R conversion.

79. Case studies on other London boroughs’ A4Ds are provided in Appendix C, and a thematic comparison is

given in section 7 of this report on ‘Potential for intervention’.

Enfield policy context - offices

80. Enfield’s new Local Plan Issues and Options publication, as well as earlier Consultation documents for the

emerging Enfield Local Plan highlight a number of objectives that either explicitly seek the retention of office

space-based employment or would be indirectly advanced by greater control over O2R PDR.23

• Protect employment land that is needed;

• Target service-based sectors;

• Nurture the SME base;

• Focus on high jobs density land uses;

• Enable local businesses to grow;

• Provide higher wage jobs;

• Promote town centre and high street vitality and viability; and

• Jobs closer to home so Enfield residents can live and work in the borough.

81. Existing policies in Enfield’s Core Strategy and Development Management Document (DMD) also include a

number of stipulations that are relevant to office floorspace, and which would have been applied when

considering planning applications for O2R conversion prior to the introduction of PDR. They also represent

the planning strategy for relevant land uses, the frustration of which may form part of the argument for an

intervention to restrict O2R PDR. Relevant adopted policies include the following directions:

• “The Major Centre of Enfield Town will continue to be supported as the main destination for . . . office

uses”; residential uses are not listed as a key or supported use in the Town;24

• Enfield Town will be protected and enhanced as “the main location in the borough for new office

development”, with “renewal and modernisation of existing offices”; office uses will be protected in

Southgate town centre subject to “evidence of demand”; surplus offices in other locations will be

supported for conversion where evidence of no demand is demonstrated;25

• Loss of office floorspace will be resisted in key locations “unless it can be demonstrated the site is no

longer suitable and viable for continued office use”, and only permitted if there is “appropriate

mitigation for the loss of employment”;26

• The loss of units under 50 sqm suitable for SMEs will be refused;27 and

• The re-use of upper floors of commercial and retail space is encouraged, including for residential.28

82. Draft policies for the emerging Local Plan contained in the 2018 Issues and Options document also make a

number of stipulations that represent Enfield’s emerging planning strategy for relevant land uses. They also

form the policy baseline that, if adopted, will govern the consideration of O2R conversion planning

applications if an intervention to restrict PDR is successful:

• Support is given for the provision of additional office floorspace;29

23 2015 Consultation document 2.2.10; 2018 Issues and Options document 2.8.7 and p. 106 24 Core Policy 17. 25 Core Policy 19. 26 DMD Policy 22. 27 DMD Policy 24. 28 DMD Policy 30. 29 Policies E1d, E2e, E3.


17

• Change of use proposals must “demonstrate the premises have been vacant for over 12-18 months,

following active marketing” and include compatible employment uses;30

• Proposals involving loss of employment floorspace are expected to deal with relocation requirements

for affected businesses;31 and

• Housing will be promoted in centres where existing functions are not prejudiced.32

Enfield policy context - retail

83. Enfield’s adopted Local Plan documents (Core Strategy 2010 and Development Management Document

2014) emphasise that the borough’s retail offering is important for meeting local people’s needs, achieving

the borough’s economic vision, and delivering its sustainable communities agenda.33 As such, various

policies seek to protect and promote retail uses:

• Core Policy 18 states that ‘the Council will protect existing retail uses’ as well as promote new

development;

• Core Policy 17 supports Enfield Town as the main shopping destination with a borough-wide

catchment area, seeks to strengthen and reinvigorate district shopping centres, and supports the

provision of core local shopping facilities in other local centres;

• DMD 26 states that in Enfield Town ‘proposals involving the change of use to non-A class uses will be

refused within the primary shopping frontage’, with any change of use on the ground floor subject to a

number of conditions; and

• Similar conditions are placed on changes of use in district centres (DMD 27) and local centres (DMD

28).

84. Enfield’s draft Local Plan Issues and Options publication (2018) generally relaxes the attitude to retail

provision compared to the adopted Local Plan, proposing to remove guidelines for the proportion of A1 retail

units in the main centres.34

85. Enfield Town Centre is still promoted as the main centre for retail activities.35 However, it is acknowledged

that new homes will also be a part of the balance sought in key centres, and other locations may in fact

need to prepare for a decline in retail space.36

86. Retail is considered primarily through the lens of town centre vitality and viability rather than employment

(unlike the case for the office market).

87. Draft Policy TC2 states that ‘in order to protect the retail and town centre uses the Council will only permit

conversion of retail and other town centre uses to residential use where it does not harm the role and

character of the centre, including maintaining the supply of shop premises in centres across the borough.’ It

also states that for conversions outside of town centres the Council will take into consideration whether the

loss of the existing shop would leave the area under-served by convenience retailing.

88. The direction of travel in the draft Local Plan is to acknowledge the nationwide changes to physical retail

provision, and to afford protections to retail space only where they play a key role in the viability and

character of local centres. There is lower resistance to conversion from retail to other uses as an end in

itself.

89. The Enfield Town Centre Framework Masterplan (2018) is aligned with this approach – which sees retail

as one component of a well-functioning town centre – and is more candid in its acceptance that a loss of

retail space (in certain areas) may be appropriate.

90. It acknowledges that areas of higher vacancy exist in lower footfall locations where rents are not

correspondingly low, that small and irregular floorplates may be ill-suited to modern requirements, and that

many units need refurbishment.37

30 Policy E2l. 31 Ibid. 32 Policy TC2. 33 Core Strategy 6.56 34 Draft Local Plan 7.2.10. 35 Ibid. 7.1.2. 36 Ibid. 7.2.5, 7.2.10. 37 Enfield Town Centre Framework Masterplan pg. 16.


18

91. It is also noted that a 2017 Town Centre Health Check found that ‘Enfield’s retail stock has too many small

units (<100 sqm) and not enough bigger units suitable for quality mid-market multiples or mini anchors (250-

500 sqm).’38

38 Ibid. pg 9.


19

2. Conversions data

Introduction

92. This section presents key findings from Enfield-held completions and permissions data, covering the

quantity of office and retail to residential conversions through Permitted Development Rights (PDR) since its

introduction, as well as the employment space consequently lost, residential units gained, and location of

schemes. Completed schemes are considered first, followed by pipeline conversions, a section considering

the reasons for prior approval refusal, and a brief analysis of the impact of PDR on heritage assets.

Completed office to residential conversions

Table 2-1: Number of O2R PDR schemes completed, B1 office floorspace lost to residential through PDR

(sqm) and sum of residential units gained from offices to residential PDR39

Financial year FY2014 FY2015 FY2016 FY2017 FY2018 Total

Number of

completions 6 17 12 7 5 47

Office

floorspace

lost(sqm)40

113 3,140 12,808 3,140 849 20,050

Residential

units gained 34 112 240 36 7 429

93. Considering the data summarised in Table 2-1 above, a number of conclusions emerge.

94. A total of 47 office to residential (O2R) conversion schemes were completed in Enfield between FY2014

and FY2018. The 29 schemes completed in financial years 2015 and 2016 are primarily a result of a high

number of schemes brought forward soon after the announcement of PDR that then took more than a year

to be built out.

95. The total known floorspace lost during the period was 20,050 sqm. This figure only includes 30 schemes, as

floorspace data is not available for 17 of the schemes. The average floorspace lost per scheme is 668 sqm,

and the median is 270 sqm. The trend in known office floorspace lost over time is presented in Figure 2-1

overleaf.

96. The 47 O2R PDR schemes completed between FY2014 and FY2018 delivered a total of 429 new

residential units. This is an average (mean) of 11 units per scheme and a median of 2.5 units. Note that the

mean differs substantially from the median because the mean is skewed by a small number of large

schemes. The trend in residential units delivered over time is presented in Figure 2-2 overleaf.

97. The average quantity of office space loss required to deliver one PDR residential unit is 62 sqm (20,050

sqm of known lost floorspace divided by the 325 residential units delivered by those schemes). This does

not equate to the average residential unit size because it also includes non-habitable, structural and

communal space.

98. To estimate the total floorspace lost to all completed conversions, including the schemes without floorspace

data, the following approach is taken:

• The average quantity of office floorspace loss required to produce one residential unit (61.7 sqm) is

multiplied by the 104 completed units in schemes for which floorspace data is unknown, to produce an

estimate of 6,417 sqm. This is added to the floorspace lost in the schemes for which that data is

known (20,050 sqm across 325 units) to produce an estimated total office floorspace loss of 26,467

sqm.41

• Bringing in data from pipeline conversions as well as completed schemes allows for a more realistic

estimate of the total floorspace lost. Total known floorspace lost is 30,340, across 590 residential units.

The average floorspace lost per residential unit across all (completed and pipeline) schemes with

39 Enfield Council (2019): LDD - Housing Completions 01-04-2013 to 31-03-2019. 40 Does not include schemes for which floorspace data was not provided. 41 As a cross-check, if the average floorspace per scheme (rather than per unit) of 668.3 sqm is multiplied by 47 (total number of PDR schemes completed) instead of 30 (PDR schemes with known floorspace data), this results in an estimated total office floorspace loss of 31,410 sqm. This is deemed less accurate as the majority of schemes are small, so the result would be skewed by the larger schemes.


20

known floorspace data is therefore 51.4 sqm. Multiplying this by the 104 completed units in schemes

for which floorspace data is unknown produces an estimate of 5,346 sqm. This is added to the

floorspace lost in the schemes for which that data is known (20,050 sqm) to produce a more realistic

estimated total office floorspace loss of 25,396 sqm.

99. The number of units gained from O2R PDR conversions represents 41.2% of all change of use completions

over the 2014-2018 period.

100. The average site area for completed O2R PDR schemes is 0.049 hectares, compared with 0.087 hectares

across all types of development. This is explained by the fact that PDR conversions almost exclusively

deliver flats, generally across multiple storeys, with little communal or outdoor space.

Figure 2-1: Completed O2R PDR conversions (FY2014-2018) – Number of schemes to known office

floorspace lost42

Figure 2-2: Completed O2R PDR conversions (FY2014-2018) – Number of schemes to residential units

gained43

42 Ibid. 43 Ibid.

0

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21

Location of completed O2R conversions

101. Table 2-2 and Table 2-3 below show that the three wards with the highest amount of office floorspace

converted through PDR (Southbury, Grange and Town) are those which effectively constitute the functional

extent of Enfield Town Centre. Not every scheme counted falls within the actual town centre boundary but

aside from one exception they are in the immediate vicinity. Together the three wards include more than half

of converted O2R PDR schemes (25) and 74% of floorspace lost.

102. Southgate is the next most affected area with 7 schemes and 12.6% of floorspace lost.

103. On the basis of the high rate of conversion in Enfield Town Centre and Southgate, together with the

economic importance of these locations (explored in greater detail in the ‘Employment need’ section), it is

advisable that any intervention on the part of the Council, such as an A4D, be limited to those areas that are

most likely to be affected by future conversions.

104. The maps overleaf show the precise locations of the completed PDR conversions to date. A key detailing

the address and permission status of each numbered scheme is provided in Appendix A.

Table 2-2: Number of completed schemes per ward44

Ward name Number % of total number of schemes

Town 16 34.0%

Grange 7 14.9%

Southgate 7 14.9%

Palmers Green 5 10.6%

Winchmore Hill 3 6.4%

Bowes 2 4.3%

Southbury 2 4.3%

Upper Edmonton 2 4.3%

Bush Hill Park 1 2.1%

Cockfosters 1 2.1%

Southgate Green 1 2.1%

Total 47 100.0%

Table 2-3: Total floorspace loss (sqm) per ward45

Ward name Known floorspace loss % of floorspace lost Number of schemes

Southbury 6,270 31.3% 2

Grange 5,328 26.6% 7

Town 3,232 16.1% 16

Southgate 2,520 12.6% 7

Cockfosters 1,200 6.0% 1

Palmers Green 825 4.1% 5

Upper Edmonton 530 2.6% 2

Bush Hill Park 109 0.5% 1

Bowes 36 0.2% 2

Southgate Green - 0.0% 1

Winchmore Hill - 0.0% 3

Total 20,050 100.0% 47

44 Enfield Council (2019): LDD - Housing Completions 01-04-2013 to 31-03-2019. 45 Ibid.


22

Figure 2-3: O2R PDR schemes location within Enfield


23

Figure 2-4: O2R PDR schemes location in vicinity of Enfield Town Centre


24

Figure 2-5: O2R PDR schemes location in vicinity of Southgate


25

Figure 2-6: O2R PDR schemes location in vicinity of Palmers Green



AECOM 26

O2R Conversion pipeline

Table 2-4: Number of O2R PDR schemes in the pipeline (class O prior approval applications made 2014-

2018 but not yet built out in 2019), B1 office floorspace expected to be lost to residential through PDR

(sqm) and sum of residential units to be gained, by permission year46

Financial year FY2014 FY2015 FY2016 FY2017 FY2018 FY2019 Total

Number of

approvals 1 1 6 7 8 1 24

Floorspace (sqm) - - 306 7,689 150 2,145 10,290

Residential units 3 6 13 167 28 92 309

105. Looking forward to the expected pipeline of future O2R PDR schemes as expressed in prior approval

applications made and not refused since 2014 but not yet under construction in 2019, presented in Table

2-4 above, a number of conclusions emerge.

106. In all, 24 schemes are currently expected to come forward.

107. Floor space data is only available for 12 of the 24 schemes. The total office floorspace expected to be lost

for these 12 schemes is 10,290 sqm.

108. The average (mean) known office floorspace lost per scheme is 858 sqm and the median is 140 sqm.

Again, the mean is far higher than the median due to a small number of large schemes skewing the results.

109. The 24 O2R PDR conversion schemes in the pipeline at the time of writing are expected to deliver a total of

309 new residential units. This is an average (mean) of 13 units per scheme and a median of 3 units.

110. Based on the pipeline, the average quantity of lost office space required to deliver one residential unit

through PDR is 38.8 sqm (10,290 sqm of floorspace across 265 residential units in schemes for which

floorspace data is known). This does not equate to the average residential unit size because it also includes

non-habitable, structural and communal space.

111. To estimate the total office floorspace lost including from the schemes without data, the following approach

is taken:

• The average quantity of office floorspace loss required to produce one residential unit (38.8 sqm) is

multiplied by the 44 pipeline units in schemes for which floorspace data is unknown (it is known for

schemes totalling 265 units). The result is 1,707 sqm, which is added to the 10,290 sqm of known

office space lost to produce an estimated total office floorspace loss for pipeline schemes of 11,997

sqm.47

• The average office floorspace lost per residential unit gained across both completed and pipeline

schemes with known floorspace data is 51.4 sqm. Multiplying this by the 44 pipeline units in schemes

for which floorspace data is unknown results in 2,262 sqm. This is added to the 10,290 sqm of known

office space lost to produce a more realistic estimate of total pipeline office floorspace loss of 12,552

sqm.

112. The average site area for pipeline O2R PDR schemes is 0.060 hectares.

Location of O2R conversion pipeline

113. Table 2-5 below shows the number of pipeline O2R PDR conversions by ward. Grange and Southgate

continue to be two of the three wards with the highest number of conversions. However, Enfield Town – the

ward with the highest number of completions – only has two conversion schemes in the pipeline (a decline

from 34% of all completed schemes to just 9% of pipeline schemes). Overall, pipeline schemes are more

evenly spread across Enfield, with less of a concentration in key centres. However, this is in terms of the

number of schemes only.

46 Enfield Council (2019): LDD - Housing Approvals 01-04-2013 to 31-03-2019. To this pipeline data has been added one scheme (19/04354/PRJ), with expected delivery of 92 residential units and an approximate 2,145 sqm of lost office floorspace. 47 As a cross-check, if the average floorspace per scheme (rather than per unit) of 885 sqm is multiplied by 24 (total number of PDR schemes completed) instead of 11 (PDR schemes with known floorspace data), this results in an estimated total office floorspace loss of 21,240 sqm. This is significantly higher but deemed less accurate as the majority of schemes are small, so the result would be skewed by the larger schemes.



AECOM 27

114. When looking at the quantity of floorspace that is projected to be lost (only for those schemes for which data

is known), Southgate and Enfield Town will remain the most impacted, along with Bush Hill Park (due to one

particularly large scheme). The two town centres of Enfield Town Centre and Southgate together represent

13 of the 24 pipeline schemes, and 61.6% of expected office floorspace loss. The predominance of office

uses in Enfield Town and Southgate suggests that these locations will continue to be most affected by O2R

PDR in future.

Table 2-5: Number of pipeline schemes and known floorspace lost per ward48

Ward Name Number % of total schemes % of known floorspace lost

Grange 4 16.7% 1.7%

Southgate 4 16.7% 37.3%

Enfield Highway 3 12.5% 1.3%

Palmers Green 3 12.5% 1.6%

Southbury 3 12.5% 1.8%

Ponders End 2 8.3% 0.0%

Town 2 8.3% 20.8%

Bush Hill Park 1 4.2% 34.9%

Enfield Lock 1 4.2% 0.6%

Bowes 1 4.2% 0.0%

Total 24 100.0%

Reasons for refusal

115. Looking at data provided by the Ministry for Communities, Housing and Local Government (MHCLG) on

applications for prior approval for O2R PDR conversions and the outcomes of these applications in Enfield,

it is apparent that the majority of applications had no prior approval required (74 or 63.8% of all 116

recorded applications).49 When prior approval was required, most of these applications were refused (31

refused compared with 11 approved).50

116. Figure 2-7 below presents Enfield’s prior approval and refusal rate over time in further detail. In addition to

the declining number of O2R PDR conversions overall, the proportion of prior approvals required and

granted has also fallen over time.

Figure 2-7: Trend in applications for prior approvals for O2R conversion in Enfield51

48 Enfield Council (2019): LDD - Housing Approvals 01-04-2013 to 31-03-2019. 49 MHCLG (no date): Table PDR 1: District planning authorities - applications for prior approvals for permitted developments, by local planning authority, [online] available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/833722/Table_PDR1__Final_.xlsx. 50 Ibid. 51 Ibid.

0

5

10

15

20

25

30

2014 2015 2016 2017 2018 2019

Prior approval not required Granted Refused



AECOM 28

117. The Council provided a detailed list of all O2R PDR applications registered between 10/06/2013 and

09/07/2019. The list records 44 prior approvals required (without specifying whether they were granted or

refused), compared with 42 in the MHCLG data referenced above. A search within the Enfield online

planning register reveals that all 44 approvals were refused, again in contrast to the MHCLG data. However,

the primary purpose of this exercise was to develop an understanding of the most common reasons for

refusal.

118. The most common reason for refusal in Enfield is that insufficient information was provided to demonstrate

that the building was used for a use falling within Class B1(a) (offices) of the Schedule to the Use Classes

Order on 29th May 2013. This reason was cited in 17 refusals (39%), although it was not always the sole

reason that a change of use application was refused. Unpermitted change of use was another common

reason for refusal (14% or 6 applications). In these cases, buildings were either mixed use (for example

B1(c) with ancillary A1 use) or simply the wrong use class.

Retail to residential PDR conversions

119. Excluding O2R conversions, there were 5 completed PDR change of use schemes in Enfield that led to a

net gain of residential units between 2013 and 2019. At the time of writing, there are a further 5 schemes in

the development pipeline.52

120. All 10 schemes are classified as change of use from retail (Class A1/2) to residential (Class C3). There are

no known incidences of PDR change of use affecting other employment uses than office or retail. In

comparison to the 71 completed and pipeline O2R PDR conversions, the 10 retail to residential conversions

represent a small proportion of PDR schemes in Enfield (12.3%).

121. Of the completed schemes, 1 scheme was completed in 2015, 3 were completed in 2018, and 1 was

completed in 2019. All of the pipeline schemes received permission (through prior approval) in 2017.

122. The 5 completed retail to residential PDR conversions resulted in 8 additional residential units. The 5

pipeline schemes are expected to deliver 7 residential units. Only two schemes have or are expected to

deliver more than 1 dwelling, so while the mean residential gain per scheme is 1.5, the median is 1.

123. This is significant for two reasons. First, because the Enfield Town Centre Framework Masterplan notes that

Enfield has a surplus of smaller units. It appears that such units predominate in those converted to

residential in PDR schemes. Second, because, in comparison to O2R conversions, the benefit to housing

delivery from retail conversions is minimal. Referring to the median rate of residential delivery, it can be

understood that the addition of a single dwelling is equivalent to the loss of one whole retail business or

franchise.

Non-PDR retail conversions data

124. It is worth comparing the above data on conversion schemes from employment uses other than office

through PDR with data on the same types of conversions given full planning permission.

125. Starting with retail to residential conversions with planning permission, there were 15 schemes completed

over the same period (2013 to 2019). There are also 18 schemes currently holding full planning permission

but not yet completed. The completed schemes delivered 26 residential units, and the pipeline schemes are

expected to deliver 23 residential units. The mean residential gain per scheme is 1.5 and the median 1,

meaning that there is no difference in scheme size between PDR and full permission conversions.

126. The key conclusion from a comparison of non-PDR data is that the majority of retail to residential

conversion schemes are taking place through the normal planning system. Only 31% of schemes are being

brought forward through PDR.

127. The fact that a comparatively high number of retail to residential schemes have been permitted following a

full planning application, and that the rate of granted permissions is increasing with time (27 approvals in

2016-2018 compared with just 6 in 2013-2015), appears to reflect Enfield’s evolving policy position that

retail uses do not automatically merit protection from conversion.

52 This and all further data referenced in this section (unless otherwise stated) is derived from Enfield Council (2019): LDD - Housing Approvals 01-04-2013 to 31-03-2019.



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128. For comparison with the 31% of retail conversions coming forward through PDR, among O2R conversions

71 (completed and pipeline) schemes made use of PDR, compared with 15 which did not. That equates to

82.6% of O2R schemes, which have or will come forward through PDR.

129. The impact associated with the introduction of PDR is therefore much greater for Enfield’s office stock than

its retail stock. Should the Council wish to reduce or control the conversion of retail units to residential, it

appears that the most appropriate response would be a change of policy or the way that full planning

applications are reviewed rather than the revocation of PDR for such conversions.

130. What this conclusion cannot at this point in time take into account, however, is the possibility that the retail

to residential schemes converted through PDR may be affecting higher-value retail stock or resulting in

lower quality residential units. This question is beyond the scope of the present analysis.

Location of retail conversions

131. Table 2-6 below shows that the distribution of completed and pipeline retail PDR schemes is concentrated in

the functional extent of Enfield Town Centre (with 4 schemes in total in the wards of Enfield Town and

Southbury), with the remainder spread relatively evenly across the rest of the borough.

132. Although this concentration is not as high as that for O2R conversions (74% of floorspace was lost in

Enfield town Centre), it remains the position of the Council that the retail offering in Enfield Town centre is

particularly deserving of protection. The ability to offer such protection, even on a case-by-case basis in line

with emerging Local Plan policy, is effectively waived by the existence of PDR.

Table 2-6: Number of completed schemes per ward53

Ward name Number % of total number of schemes

Chase 2 20%

Cockfosters 1 10%

Enfield Lock 1 10%

Southbury 2 20%

Town 2 20%

Turkey Street 1 10%

Winchmore Hill 1 10%

Total 10 100%

133. Looking at the location of retail to residential schemes with full planning permission, 9 are located in Enfield

Town Centre (6 in Town and 3 in Southbury), with no schemes in Southgate, 5 in Enfield Highway, and the

rest evenly distributed across the borough. The concentration in Enfield Town Centre, at 27%, is lower than

for PDR schemes (40%).

134. The map in Figure 2-8 below plots the location of all completed and pipeline retail to residential conversions

in Enfield since 2013, with blue marketers representing PDR schemes and pink markets representing

schemes with full planning permission. The schemes with full planning permission are more evenly spread

throughout the borough, but the number of PDR schemes is too small to indicate a significant clustering of

schemes in Enfield Town Centre.

53 Ibid.



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Figure 2-8: Location of (completed and pipeline) retail to residential schemes in Enfield, PDR and full planning permission



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Non-PDR conversions affecting other employment uses

135. As stated above, no PDR change of use schemes in Enfield between 2013 and 2019 affected any

employment uses other than office or retail.

136. However, these are not the only employment uses vulnerable to PDR conversion. It is worth noting that

there are 2 pipeline schemes for change of use from B1(a) light industrial uses to C3 residential, and 2

pipeline schemes for B8 storage or distribution uses to C3 residential. All of these change of use schemes

would in theory be possible to progress through PDR. However, all of the known examples in Enfield are

being taken forward through full planning applications.

137. On the basis of this evidence, there is no justification to restrict or control PDR through an intervention on

the part of the Council for these other employment uses.

138. For reference, Table 2-7 below includes all of the non-PDR change of use schemes (both completed and

pipeline) in Enfield over the same period. The categories given in purple are those that are in theory

possible to undertake through PDR.

Table 2-7: Non-PDR change of use schemes, Enfield 2013-201954

Change of use category Number of schemes

A1 (Shops) to C355 31

A2 (Financial and professional services) to C356 2

A3 (Restaurants and Cafes) to C3 2

B1 (a) (Offices) to C3 15

B1 (c) (Light industry appropriate in a residential area) to C357 2

B8 (Storage or distribution) to C358 2

C1 (Hotels) to C3 2

C3 (b) (Care homes) to C3 (a) 2

D1 (Non-residential institutions) to C3 6

Sui Generis to C3 (non-permitted forms) 2

Unclear 1

Retail PDR conversions - conclusion

139. In the context of the policy extracts presented in the ‘Literature review’ section and retail market indicators

discussed in the ‘Employment need’ section, it is considered that Enfield’s retail sector is sufficiently resilient

and the scale of conversions insufficiently great that an intervention on the part of the Council to restrict

PDR is not warranted. This position is corroborated by the direction of travel in Enfield’s planning policy, and

the fact that the majority of retail conversions are already take place through the normal planning system.

That said, a limited intervention could be considered simply to apply greater scrutiny to the loss of retail in

the key location of Enfield Town Centre.

54 Ibid. 55 Subject to Prior Approval Class M or Class G http://www.legislation.gov.uk/uksi/2015/596/schedule/2/part/3/crossheading/class-m-retail-or-betting-office-or-pay-day-loan-shop-to-dwellinghouses/made; Class G – retail or betting office or pay day loan shop to mixed use: http://www.legislation.gov.uk/uksi/2015/596/schedule/2/part/3/crossheading/class-g-retail-or-betting-office-or-pay-day-loan-shop-to-mixed-use/made 56 Subject to Prior Approval Class M or Class G http://www.legislation.gov.uk/uksi/2015/596/schedule/2/part/3/crossheading/class-m-retail-or-betting-office-or-pay-day-loan-shop-to-dwellinghouses/made 57 Subject to Prior Approval (made between 1 October 2017 - 30 September 2020). 58 Subject to Prior Approval Class P storage or distribution centre to dwelling houses (until 15 April 2018).

http://www.legislation.gov.uk/uksi/2015/596/schedule/2/part/3/crossheading/class-m-retail-or-betting-office-or-pay-day-loan-shop-to-dwellinghouses/made


http://www.legislation.gov.uk/uksi/2015/596/schedule/2/part/3/crossheading/class-g-retail-or-betting-office-or-pay-day-loan-shop-to-mixed-use/made

http://www.legislation.gov.uk/uksi/2015/596/schedule/2/part/3/crossheading/class-g-retail-or-betting-office-or-pay-day-loan-shop-to-mixed-use/made





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3. Heritage assets

Introduction

140. This section discusses conversion data in terms of its intersection with listed buildings and relative

concentration in conservation areas. It then considers the direct and indirect risks to the heritage and

character of Conservation Areas from PDR conversion.

Listed buildings

141. Enfield has 22 conservation areas, approximately 480 statutorily listed buildings, and 263 entries on the

Local Heritage List.59 These are protected to various degrees in planning policy from development that may

cause harm or not conserve the character of the asset or location.60 A number of A4Ds are currently already

in place to enable more effective management of residential properties within the Enfield Town Conservation

Area.61 Because PDR conversions can proceed with limited oversight from the Council, they have the

potential to impact heritage assets without suitable mitigation measures being agreed.

142. To gauge the potential scale of this risk, the locations of office and retail PDR conversions have been cross

referenced with a database of Enfield’s listed buildings, and the boundary of its conservation areas.62

143. 32 instances were counted where schemes / planning approvals between 2013 and 2018 in Enfield

intersected with listed buildings or listed assets. However, a single planning application or permitted scheme

can affect multiple listed building elements (such as individual statues). When these duplicates are

removed, there are 14 unique planning applications that affect one or more listed building or listed asset.

However, none of these schemes were PDR conversions from office or retail to residential uses. As such,

PDR conversion has had no known direct impact on Enfield’s listed assets to date.

Conservation area impacts

144. In terms of PDR conversions taking place within Enfield’s conservation areas, there have been 10

completions to date and there remain 4 in the pipeline which are located within conservation areas. This is

approximately 12% of all PDR conversions. PDR conversions show clusters in conservation areas, and

particularly those of Enfield Town and Southgate Circus (as can be seen in Figures 2-4, 2-5 and 2-8). The

risks of this are considered below following a brief review of protections afforded to the conservation areas.

145. Enfield Town Conservation Area was first designated in 1968 and subsequently enlarged in 1972, 1983 and

1984. Southgate Circus Conservation Area was designated in 2008. Conservation Area Management

Proposals were put in place for both Conservation Areas alongside updates to their Character Appraisals in

2014 (Enfield Town) and 2015 (Southgate Circus).63 As noted above, a number of A4Ds were also made in

2017, which withdraw PDR for alterations to dwelling curtilages fronting relevant locations in the Enfield

Town Conservation Area.64

146. These steps, alongside Enfield’s Heritage Strategy (2019) and adopted planning policies, primarily Core

Policy 31 and DMD 44, provide a framework for the protection and enhancement of heritage assets and the

character of the borough’s Conservation Areas. Draft Local Plan policies, notably HE2 and HE3, take this

further, including provision for the ‘uses associated with some buildings’ in addition to their physical fabric.

59 Regulation 18 Issues and Options Local Plan publication, 3.2.2. 60 See Core Strategy Policy 31, DMD Policy 44, Regulation 18 Issues and Options Local Plan publication Policies HE1, HE2 and HE3. 61 Enfield Town Framework Masterplan, pg. 28. 62 Council data on listed buildings were provided in the form of map layers. These layers identify listed assets as specific geographical points. The same is true of the LDD approvals data used to plot the location of PDR conversions. As such, there is the potential for two points (one for a listed building and one for a PDR conversion site) to refer to the same address but not to register as an intersection. To overcome this, each set of geographical points were first cross-referenced with polygon mapping layers for all planning applications in Enfield (polygons cover the exact area of a building, not simply one point within it). Intersections were then identified to count how many listed buildings were converted through PDR. 63 In all, there are currently 22 Conservation Areas in the borough, with Character Appraisals and Management Proposals in place as appropriate. Due to the concentration of PDR conversions in the two main centres, however, they are the focus in this discussion. 64 An earlier A4D with less relevance here was made in 2004 to remove PDR for the painting of the principal elevation of commercial properties.



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147. The ‘considerable heritage merit’ of Enfield’s Conservation Areas and the importance of protecting it from

the pressures associated with development are clearly established.65 However, change of use conversions

through PDR are able to evade many of the protections that have been found to be warranted:

• Conservation area designations generally do not control forms of development permitted under PDR;66

• Management proposals can use proactive measures to protect and enhance Conservation Areas

outside of the planning system, or seek the introduction of planning controls, but do not themselves

represent a form of planning control that impacts PDR schemes;

• The A4Ds in effect in Enfield Town only remove PDR from types of development affecting either

buildings already classified as residential dwellings or external features such as gates. They therefore

do not apply to PDR for the conversion of commercial to residential uses;

• Planning polices governing the determination of planning applications with relevance to heritage, as

with those covering other aspects of development, are not able to control PDR schemes, which do not

require planning permission. Prior approval, which may be required, is not determined with reference

to such aspects; and

• The Council uses Section 106 (S106) Agreements (which cannot be levied for PDR conversion

schemes) to mitigate the impacts of developments on a conservation area by ‘assist(ing) in conserving

and enhancing’ it, with receipts available to be used to help deliver other management proposals

supporting the conservation area.67

148. It has been demonstrated above that change of use PDR in Enfield has not, so far, had a significant direct

impact on particular listed assets. However, in light of the fact that such schemes are not subject to the

various measures put in place to protect heritage and character, the high volume of conversions in the

Conservation Areas of Enfield Town and Southgate Circus is a potential contributor to the ‘cumulative minor

changes’ that are acknowledged to present a risk to the character and appearance of these areas.68

149. The potential cumulative impacts from unchecked PDR conversions could include changes to the external

appearance of a street arising from works to the external fabric, windows and other materials used in PDR

conversion. It could also include indirect effects such as increases to street clutter (such as the placement

of bins) and car parking arising from higher proportions of residential use in town centres. The corollary

reduction in traditional work and leisure practices such as retail in shopping parades that have special

heritage interest may also dilute the intangible heritage value of such areas.

150. Among the key characteristics listed as giving special interest to the Enfield Town Conservation Area are its

shopping parades and its visual unity through the use of materials.69 The greatest potential issues going

forward have been identified as risks to non-listed buildings with less stringent protections and the poor

quality alterations arising from development, especially to shopping street frontages and the upper floors of

shops.70 PDR conversion from retail to residential use has a direct impact on the appearance of shopping

streets (although such schemes are few in number). Therefore, the more widespread O2R conversions

carry the threat of cumulative impacts on the appearance of the Conservation Area through the replacement

of windows, roof materials and other external features.

151. The special interest of Southgate Circus resides primarily in the modernist style of the Underground station

and its environs.71 The key risks to heritagae include building condition, use and alteration, particularly of

shopfronts. It is also noted that mass produced modern materials, which may be used without oversight in

PDR conversions, will not normally be appropriate within conservation areas.72

152. However, it should also be acknowledged that there is a degree of opportunity in Southgate Circus arising

from change of use conversions, in addition to the threats identified. The Conservation Area Management

Proposals document states that ‘most of the problems that still affect the area stem from the relatively low

value commercial uses around the station’ and ‘new uses for vacant uses should be encouraged, both at

ground (shop) level and above’.73 Conversion to residential use, when done well, could add value to the

65 Enfield Town Conservation Area Character Appraisal, 2014, 4.1.1. 66 Ibid., 1.1.2. 67 Enfield Town Conservation Area Management Proposals, 2015, pg. 5; Making Enfield: Enfield Heritage Strategy 2019-2024, 2019, 1.5.6. 68 Enfield Town Conservation Area Management Proposals, 2014, pg. 3. 69 Enfield Town Conservation Area Character Appraisal, 2014, 3.1.1. 70 Ibid., 4.1.7. 71 Southgate Circus Conservation Area Character Appraisal, 2015, pg. 22. 72 Southgate Circus Conservation Area Management Proposals, 2015, pg. 9 73 Pg. 8, pg. 10.



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Conservation Area, although it is noted that development should be appropriate to the architectural interest

of the building. In this sense, while change of use could be supported, there is also strong justification for

the oversight from the Council that would be facilitated by the removal of PDR.

153. Bringing this evidence together, it is clear that while listed buildings have not suffered direct harm from PDR

conversions to date, there is potential for cumulative harm to the appearance of conservation areas and

Enfield’s market town character. That is because this form of development is not subject to the various

forms of protection and planning oversight that have been proven to be warranted.

154. The risks to heritage arising from retail to residential PDR conversions would appear to be greater because

shopping parades have been found to be a key element of the special interest of Enfield’s Conservation

Areas, upon which inappropriate redevelopment can exert significant visual impacts as well as erode

heritage land uses. However, retail to residential PDR conversions are relatively few in number within such

areas. O2R conversions are far more prevalent, but their risks are primarily limited to the erosion of the

appearance and character of Conservation Areas through changes to building fabric.

155. A further intervention on the part of the Council to remove PDR for change of use conversions within

Conservation Areas, or the town centres of which they form a part, would help to further safeguard these

areas from the further erosion of their character and patterns of use.



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4. Employment need

Introduction

156. This section reflects on the conversion data presented above within the context of demand for office and

retail employment space in Enfield. As O2R conversions are far more common in the borough and are

understood to exert a greater impact on employment need, the focus in this section is primarily on the office

market. Background information is drawn primarily from the 2018 Enfield Employment Land Review (ELR),

while current floorspace, vacancy and rental information is drawn from Costar for the year to November

2019 and all previous whole calendar years.74

The Enfield office market

157. Enfield is among the 15 smallest office markets in Greater London but one of the largest in the outer

northern area, according to Costar analysis. Enfield’s stock of office accommodation is the fourth largest of

the London boroughs included in its Functional Economic Market Area (FEMA), and the borough is home to

the third highest number of office employees across the FEMA overall.75

158. However, the number of office jobs in Enfield declined between 2001 and 2015 despite rising across the

FEMA, and the borough’s loss of office stock through PDR conversion comes at a time when supply is

increasing in nearby markets outside of Greater London, such as Welwyn-Hatfield.76

159. As central London and non-London office markets grow in prominence, Enfield’s office floorspace serves

primarily to meet local needs, with 66% of surveyed office-based businesses saying that a majority of their

employees are Enfield based.77 However, the market continues to demonstrate vacancy rates and rental

growth that outperform the wider FEMA (see below).

160. It is recognised by the Council that major occupier demand across the borough is low and competing

centres such as Stratford are rising,78 while Town Centre stock is relatively dated and the potential for a

strong office cluster is low.79

161. Enfield’s office market therefore cannot be considered strategically important for Greater London as a

whole, or to have significant reach beyond the FEMA, but it is a segment of Enfield’s economy that the

Council wishes to enhance and protect,80 as well as one that provides important diversity and sustainability

to local employment.

162. Enfield’s office stock is characterised as being mostly small and of average quality in terms of offer,

although relatively low rental values constitute part of the market’s appeal and suitability to the small and

medium sizes enterprises (SMEs) that make up the vast majority of local employers.81 This stock is primarily

located within or close to the town centre areas of Enfield and Southgate with limited stock in other town

centres and in local centres.

163. Enfield moved from having the third highest vacancy rates in the FEMA in 2007 (lower than only Welwyn

Hatfield and Hertsmere) to the third lowest in 2016.82

Office demand

164. Overall demand for office space from businesses in the borough is said to be small, though a significant

segment of demand comes from public bodies and non-business organisations such as charities.83

74 Available at https://www.costar.com. Paid login required. 75 The FEMA includes the following areas: Barnet, Broxbourne, Enfield, Epping Forest, Haringey, Hertsmere, Waltham Forest, and Welwyn and Hatfield; ELR 6.2.5; Table 6-2. 76 ELR 6.2.5; Table 6-2; Table 5-5. 77 ELR 3.11.3. 78 Enfield Core Strategy 6.71. 79 Enfield Town Centre Framework Masterplan pg. 15. 80 Enfield Issues and Options (2018) 2.8.7. 81 ELR 8.2.23; 3.9.1. 82 ELR 5.3.19. 83 ELR 5.3.10.

https://www.costar.com/



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165. The number of office-based employees working in Enfield stood at 17,300 in 2016. This was up on 16,100

in 2015 but down on 18,000 in 2001. It is projected to increase to 22,200 in 2036.84 This projection is the

main basis for the need for supply to increase in the medium to long term.

166. The rate at which the number of office employees has declined since 2001 is twice as large as the

equivalent decline in floorspace. This suggests that employment densities are declining in Enfield, despite a

decrease in office vacancies in the borough and at a time when employment densities have been increasing

across London as a whole.85

167. However, applying future employment projections to the historic relationship between employment growth

and floorspace requirements, Enfield is projected to need a compound annual growth rate in available office

space of 0.6%, above the 0.5% projected for the FEMA as a whole.86

168. Demand could sharply increase following the continued development of Meridian Water and the wider

Edmonton Leeside, as well as the completion of rail improvements to the STAR line scheduled for 2024 and

if Four Tracking and Crossrail 2 go ahead.87 However, it is understood that Meridian Water will also increase

the supply of office floorspace, potentially absorbing much of the potential increase in demand (detailed

under Future office supply below).

Retail demand

169. Enfield’s Retail and Town Centre Study (2014) found that projected consumer expenditure could support an

additional gross 14,414 sqm of convenience goods floorspace and 38,194 sqm of comparison goods

floorspace in Enfield by 2029.88

170. In line with this positive forecast for the industry, employment growth in Enfield’s retail sector between 2010

and 2015 was 20.9%.89 Retail employment in the borough stood at approximately 12,800 in 2015, which is

12.7% of total employment.90

Loss of office space through PDR

171. The 20,050 sqm of office space known to be converted through PDR since FY2014 is equivalent to 8.6% of

all the office floorspace existing in 2013, when PDR was introduced,91 and the higher estimate of 25,396

sqm, (which includes an estimate of the floorspace likely to be lost in the schemes for which floorspace data

is unknown) is equivalent to 10.9%.

172. If the pipeline estimate of 12,552 sqm is included, this percentage rises to 16.3%: nearly one sixth of all the

office accommodation available prior to the introduction of PDR will have been lost to completed and current

pipeline schemes.

Office vacancy

173. Following losses resulting from PDR conversion, total office floorspace in Enfield currently stands at

224,474 sqm, of which 220,677 sqm is occupied and 3,797 sqm is vacant.92

174. The current vacancy rate is therefore 1.7%, which is well below the current London and national average,

and half the rate of the FEMA average in 2016 of 3.3%.93 It is also significantly below the assumed

equilibrium or ‘frictional’ vacancy rate of 8% put forward in the London Office Policy Review 2017, below

which additional supply is needed to bring an office market back to a normal operating state.94

84 ELR Tables 6-2 and 6-4. 85 ELR Table 6-3, London Office Policy Review 2017 (LOPR) 3.1.22. Note that this does not align with the figures produced from this analysis. However, this is understood to be due to a time lag in reporting and the different points in the year at which totals have been taken. 86 ELR 6.5.3. 87 ELR 8.2.26. 88 Quoted in ELR 2.4.12. 89 ELR Table 3-8. 90 ELR Table 3-7. 91 232,574 sqm (Costar, 2019). 92 CoStar, 2019. 93 Costar, 2019; ELR Table 5-8. 94 LOPR 9.2.2-5.



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175. Vacancy in Enfield has only been lower than its present rate in one year since 2003, when it was 1.2% in

2016.95 A slight increase in 2017 was primarily due to ongoing refurbishments at the 5,000 sqm Ross House

unit.96

176. Figure 4-1 below shows that the decline in total stock through PDR conversion has created pressure in the

market that is steadily reducing vacancy levels.

177. The actual quantum of occupied space has not varied significantly over the period, sitting within a range of

218,441 to 226,729 sqm and averaging at 221,946 (as shown by the orange line in Figure 4-1 below). This

indicates that demand is relatively stable.

178. However, O2R PDR conversions to date have eliminated more stock than the amount that was vacant in the

years 2012, 2015 and 2016. Total stock at 224,474 now stands at just 2,528 sqm above the average

occupied stock level for the period of 221,946 (Figure 4-1 below). It therefore appears likely that the loss of

further office space would create a net undersupply, with potential knock-on effects for employment.

Figure 4-1: Total Enfield office space and vacancy rate (2010-2019)97

179. Table 4-1 below shows that on average in any given year 2% of Enfield’s existing office stock is lost to PDR

conversion. Were the 7,819 sqm of known office space for which approval for PDR conversion was obtained

or not required in 2016 and 2017 to complete in 2019, this would represent 3.48% of the stock available at

the end of 2018.

180. Note that this data does not include schemes for which the floorspace lost was not known. The total

floorspace available each year is per calendar year while the floorspace lost in each year is per financial

year.

181. In relation to the link between PDR conversion and office vacancy it is also worth noting that 28% of Enfield

O2R conversions were either partially or fully occupied before the conversion started.98 However, it is

unclear whether the remaining 72% were genuinely vacant or whether a decision to convert meant that the

lease was allowed to lapse where it otherwise would not, leaving the unit deliberately vacant at the time that

this metric was captured. Without comparator geographies it is also difficult to judge if a 28% occupancy

rate (despite its limitations) is relatively low or high for a Greater London office market.

95 CoStar, 2019. 96 Ibid. 97 Costar 2019 98 Dr Ben Clifford et al., Research into the quality standard of homes delivered through change of use permitted development rights, December 2019 (draft). Note that this finding is from a sample of schemes between 2015-2018.

0%

1%

2%

3%

4%

5%

6%

7%

210000

215000

220000

225000

230000

235000

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Occupied floorspace Vacant floorspace Average occupied stock Vacancy %



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Table 4-1: Office space loss99

Total floorspace at end of previous year Floorspace lost in year % of floorspace lost

2014 232,574 113 0.05%

2015 231,247 3,140 1.36%

2016 231,941 12,808 5.52%

2017 227,059 3,140 1.38%

2018 225,995 849 0.38%

2019 estimate 224,474 7,819 3.48%

Average % loss per year (2014-2018) 2%

Retail vacancy

182. The vacancy rate across all of Enfield’s retail in 2019 was 1.6%.100 It was slightly lower at 1.2% for the high

street and general retail under consideration here, while it was 0.1% for shopping centres and 5.4% for

retail parks.101 The overall vacancy rate in Greater London is 1.4%, which is lower than Enfield’s overall

vacancy rate, but higher than Enfield’s general (high street) vacancy rate.102 It is also worth noting the

national context: across all UK town centre retail, the vacancy rate was 10.3% in July 2019, which is

significantly higher than Enfield and London as a whole.103

183. The general retail (not including shopping centres and retail parks) vacancy rate has fluctuated between

0.6% and 1.3% over the past ten years, meaning that there has not been a sharp decline in vacancy since

the introduction of PDR as was seen for Enfield’s office stock.104

Office rental values

184. The average rental value per sqm in Enfield is currently £258.33.105 This represents a slight decrease on

2018 but average annualised growth of 6% over the past 5 years and a substantial 42% increase on 2010

rents.106

185. Interestingly, increases in average rents over time do not correlate with the introduction of PDR in 2013. In

fact, rental growth in the six years since 2013 was 1.8%, below the 2.7% increase in the six years to 2009,

the year in which price growth began to accelerate. The curve of the market since 2012 shown in Figure 4-2

below is broadly similar to that seen across London as a whole.107 Between 2007 and 2016, Enfield’s office

market rental growth exceeded that of the FEMA in percentage and nominal terms.108

99 Ibid. 100 Costar 2020. 101 Ibid. 102 Costar 202. 103 British Retail Consortium, August 2019. https://brc.org.uk/news/2019/2019-aug-12-footfall-monitor-july. 104 Ibid. 105 Costar 2019. 106 Ibid. 107 Ibid. 108 ELR 5.3.14.



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Figure 4-2: Average rental value per sqm evolution in Enfield109

Retail rental values

186. The general retail market rent in Enfield in 2019 was £29.48 per square foot per month, having grown by

2.8% on 2018 rents.110 Average rental growth per year over the last ten years has been 1.96%.111 Again,

while rents are increasing, such growth rates are close to inflation and do not suggest that pressure is

increasing in this market.

187. There are currently an estimated 463,897 sqm of general retail floorspace in the borough, with inventory

growth relatively flat over the past decade (0.5% growth between 2010 and 2019).112 While only two years

since PDR were introduced have coincided a contraction in available space (6 sqm lost in 2016 and 322

sqm in 2017), 1,426 sqm of new space has been delivered during that period, leading to a net gain in

available stock.113

Office size considerations

188. There are currently 307 office units in Enfield, with an average unit size of 731.2 sqm, and a median of just

195.6 sqm.114 These averages align with the composition of Enfield’s businesses, 93% of which have fewer

than 9 employees, while there are 125 medium scale enterprises with 50 to 249 employees and 25 larger

ones with more than 250 employees.115 The average number of employees in Enfield businesses is 11.116

189. The current average (mean) office unit size represents an increase of 1.3 sqm on the average size of 729.9

sqm recorded in 2016, as a result of the conversion of a higher share of small units.117 The average size of

unit converted since 2014 was 668.3 sqm, which is below the average size of all available units.

190. Vacancy is generally lower for smaller unit sizes, indicating high demand, but also reflecting a high volume

of PDR conversion. This is shown in Table 4-2 below.

191. The majority of stock by floorspace comes from units 2,000-10,000 sqm in size, but the vast majority in

terms of the number of units comes from those under 250 sqm. These small units cater to Enfield’s large

number of SMEs.

192. There are comparatively few medium to large units in Enfield. The low availability of grow-on space is

identified in the ELR as a potential constraint on the growth of Enfield’s small businesses.118

109 CoStar, 2019. 110 Ibid. 111 Ibid. 112 Ibid. 113 Ibid. 114 Ibid. 115 ELR 3.9.1. 116 Enfield Business Survey, quoted in ELR 3.11.2. 117 Costar, 2019. 118 ELR 5.3.10.

£100

£120

£140

£160

£180

£200

£220

£240

£260

£280



AECOM 40

Table 4-2: Stock and vacancy by unit size in Enfield, 2019119

Unit size

(sqm) Units

% of total

units stock

Floorspace

(sqm)

% of total

floorspace

stock

Vacancy (%)

FEMA

vacancy

2016 (%)

Under 250 182 59.3% 22,990 10.2% 1.0% 1.1%

250 to 500 36 11.7% 12,685 5.7% 0.0% 1.3%

500 to 1,000 30 9.8% 21,428 9.5% 1.1% 1.6%

1,000 to

2,000 35 11.4% 50,218 22.4% 1.9% 3.0%

2,000 to

10,000 22 7.2% 88,277 39.3% 2.4% 3.9%

Over 10,000 2 0.7% 28,876 12.9% 0.0% 4.4%

Total 307 100% 224,474 100% 1.70% 3.5%

Table 4-3: Size of office units lost to residential conversion (completed schemes)120

Units % of total

completed units Floorspace (sqm)

% of total

completed

floorspace

Under 250 15 50.0% 1,128 5.6%

250 to 500 7 23.3% 2,350 11.7%

500 to 1,000 2 6.7% 1,210 6.0%

1,000 to 2,000 4 13.3% 6,432 32.1%

2,000 to 10,000 2 6.7% 8,930 44.5%

Total 30 20,050

193. Comparing Table 4-2 and Table 4-3, the size spread of converted units aligns closely with the size spread of

existing units. However, the size spread of total floorspace lost (presented in Table 4-4 below) deserves

further consideration.

Table 4-4: Stock and vacancy by size: comparison between existing and converted floorspace121

% of floorspace stock % of converted floorspace Variance Vacancy

Under 250 10.2% 5.6% -4.6 1.0%

250 to 500 5.7% 11.7% +6 0.0%

500 to 1,000 9.5% 6.0% -3.5 1.1%

1,000 to 2,000 22.4% 32.1% +9.7 1.9%

2,000 to 10,000 39.3% 44.5% +5.2 2.4%

194. Table 2-4 above compares available and converted floorspace by unit size. All other things being equal, it

could be expected that conversions would occur in the same proportion as the stock of floorspace. A

notable observation is that the smallest units (under 250 sqm floorspace) only supplied 5.6% of conversions

despite accounting for over 10% of the stock. Conversely, 250-500 sqm units provided a disproportionate

supply of conversations compared to the number of these units in the stock. There was also a greater loss

of 1,000-10,000 units by floorspace than their availability in the stock would suggest.

195. Comparing this with vacancy rates shows that the two biggest contributors to converted floorspace, in

absolute terms, are the size categories with the highest vacancy. In these examples, conversions are

aligned with market demand. Units of under 250 sqm and 500-1,000 sqm are converted at a lower rate than

their availability would suggest, which aligns with their comparatively lower vacancy. However, the 250-500

sqm category has the lowest vacancy (0%) and experienced a high rate of conversion relative to the stock.

119 CoStar, 2019. 120 Enfield Council (2019): LDD - Housing Completions 01-04-2013 to 31-03-2019. 121 Enfield Council (2019): LDD - Housing Completions 01-04-2013 to 31-03-2019, Costar 2019.



AECOM 41

196. This is an example of the disproportionate loss of potential grow-on space for SMEs that was identified as

important in the ELR.122 If the Council seeks to intervene to limit PDR conversions, this evidence suggests

that greater protection should be afforded to the office unit size categories with the lowest vacancy and

highest value for local business, namely those with between 250 and 500 sqm of floorspace.

197. Note that this analysis does not include an appraisal of the quality of the stock lost. It also can only include

schemes for which floorspace data is available.

Office location

198. Enfield Town Centre contains some medium sized offices, either located above retail units or in dedicated

blocks in the east and west parts of the cluster. The buildings and environment are considered in the ELR to

be in good condition.123 Southgate Town Centre has a number of very good quality small to medium scale

offices in dedicated blocks (e.g. the Grange and Southgate Office Village) and above retail units. The

environment is considered to be in very good condition.124

199. Outside of the town centres, some office floorspace can be found in Strategic Industrial Locations (SIL), for

example at Innova Park, and at Locally Significant Industrial Sites (LSIS) such as at Claverings Industrial

Estate and Queensway, although not of significant quantum. Further ancillary offices can be found attached

to other premises such as warehouses and manufacturing plants in the SIL and LSIS areas.125

200. The quality of stock varies between good and functional in the town centres to mostly poorer quality units in

the SIL and LSISs where stock is present. Affordable units / floorspace are mostly in demand and the

existing stock serves these needs well.126

201. A positive net change in office floorspace was observed at only four of the 21 wards in LB Enfield between

2000 and 2016 (Edmonton Green, Enfield Lock, Jubilee and Winchmore Hill). The largest positive

contribution to the office stock is at Enfield Lock, where a net additional 23,100sqm of additional floorspace

was provided. This is over five times larger than the next largest ward, Jubilee (4,300sqm), and without

which the net loss across LB Enfield would be almost three times larger.127

202. 74% of floorspace lost through PDR conversions in the period 2014-2018 was lost in Enfield Town Centre

and its environs, with 12.6% lost in Southgate. These are recognised in the ELR and in Enfield’s Issues and

Options Consultation document as the most suitable locations for office space and can therefore be

considered the locations where the loss of office space should be resisted. However, they are also the

locations where office accommodation is most plentiful.

Forecast office need 203. The forecast gross requirement for office floorspace to 2036 provided in the ELR is 249,700 sqm.128

204. With total stock decreasing, the forecast space requirement is becoming harder to meet over time. The current deficit against that target is 25,226 sqm.129

Future office supply

205. Office development in Enfield has been almost non-existent in recent years: less than 1,400 sqm have been

built over the past decade, compared with an estimated loss through PDR conversion of 32,263 sqm since

2014 alone.130

206. This is likely due to stable (i.e. not increasing) demand from local and incoming businesses, combined with

Public Transport Accessibility Level (PTAL) ratings below that typically required to attract large-scale office

development.

207. No new speculative office developments were observed during the site survey at the time of the 2018

ELR.131 One 5,000 sqm building (Ross House) is underway. It was forward-funded by LBE and has been

122 ELR 5.3.10. 123 ELR 4.3.38. 124 ELR 4.3.39. 125 ELR 5.3.1. 126 ELR 8.3.21. 127 ELR 7.3.9. 128 ELR Table 7-2. 129 CoStar, 2019. 130 Ibid. 131 ELR 5.3.4.



AECOM 42

entirely pre-let by Metaswitch which will consolidate 3 other Enfield offices (Figure 4-3 below). It has not

been determined whether the three vacated offices will be released into the office market or converted to

residential.

208. Enfield officers indicate that the Meridian Water development is expected to deliver 38,000 sqm of office

space based on indicative use class ratios (29% of all development floorspace as office and 17% as service

office), and a further 16,575 sqm as small studios, a proportion of which will be small office format (with the

remainder market space studios) targeting SME demand in the borough.

209. All expected office floorspace loss through conversion (10,407 sqm) minus all outstanding permissions for

office development (9,020 sqm –not including the Meridian Water estimated supply, which is not yet

confirmed and is beyond the timescale measured in Costar data) results in a net expected loss of 1,387

sqm over the short to medium term.

210. The development of Meridian Water can be expected help to address the persistent net loss of office

floorspace over the longer term. However, it will provide a high volume of stock in one small area of the

borough that may not be suitable to all the businesses impacted by the loss of space in other areas, and

may arrive too late for businesses impacted by near-term PDR conversions to relocate.

Figure 4-3: Office development forecast132

132 Costar 2019.



AECOM 43

5. Housing need

Introduction

211. This section sets PDR conversion data in the context of housing need as evidenced in the Strategic

Housing Market Assessment (SHMA) (2015), as well as with reference to Enfield’s Core Strategy housing

policies and the borough’s evolving housing targets over recent years.

Conversions in the context of past delivery

212. Table 5-1 and Figure 5-1 below show the scale of the contribution PDR conversion has made to housing

delivery in Enfield since 2014. Over the period as a whole, 16.5% of all housing delivery has been brought

about through PDR conversion. This represents a valuable source of housing supply during a period of

delivery stress.

213. However, and as noted above, there is a high degree of annual variation in the data. The majority of PDR

delivery took place in the financial years 2015 and 2016. Excluding these peak years following the

introduction of PDR, conversions have contributed approximately 7% of all housing completions.

Table 5-1: Proportion of overall residential delivery through PDR (annual)133

FY2014 FY2015 FY2016 FY2017 FY2018 Grand

Total

O2R PDR completed units 34 112 240 36 7 429

Retail PDR completed units - 1 - - 6 7

Total completed units 402 676 884 386 298 2,646

% of PDR units to total

completed 8.5% 16.6% 27.1% 9.3% 4.3% 16.5%

Figure 5-1: Proportion of overall residential delivery through PDR (annual)134

Conversions in the context of housing targets

214. Enfield’s annual housing targets as set out in various recent planning documents are as follows:

• Core Strategy (2010) / London Plan (2008): 395

• London Plan (2011): 560

• London Plan Alterations (2016): 798

• Draft New London Plan (DNLP, 2019) previous target: 1,876

133 Enfield Council (2019): LDD - Housing Completions 01-04-2013 to 31-03-2019. 134 Ibid.

0%

5%

10%

15%

20%

25%

30%

0

200

400

600

800

1000

1200

FY2014 FY2015 FY2016 FY2017 FY2018

PDR completed units Total completed units % of PDR units to total completed



AECOM 44

• Intend to Publish DNLP (taking into account a reduction of the small sites target from 9,830 to 3,530):

1,246

• Standard Method calculation (2019): 3,750

215. While the contribution of PDR conversion to past delivery rates is significant, the average annual delivery

rate of 87 units becomes less significant in the context of Enfield’s evolving housing targets. The proportion

of each target that would be met by this average annual rate is shown in Figure 5-2 below.

Figure 5-2: Proportion of Enfield’s housing target met by PDR conversions135

216. PDR conversion at 87 units per year represents 7% of Enfield’s annual housing target of 1,246 in the Intend

to Publish DNLP. This contribution comes at an approximate cost of 1.3% of all existing office space in the

borough and a small amount of retail space loss.136 On this basis (7% of annual need compared with 1.3%

of total office supply), the cost to employment need appears to be greater than the benefit to residential

delivery.

217. However, the borough’s land supply bears consideration. Enfield’s five-year land supply (2018/19 to

2022/23) identifies land for 4,808 dwellings over the period, which represents a 20% buffer on the London

Plan (2016) annual target of 798 and would also address the previous three-year shortfall of 439 units.137

However, Enfield’s housing target is set to nearly double with the adoption of the DNLP. The borough’s

average annual residential delivery rate of 529 units (2014-2018) does not come close to meeting the

currently expected 1,246 target. Enfield’s five-year land supply may be less secure in the context of a new

higher target, bolstering the argument that any positive source of housing delivery – including O2R

conversion – should be promoted.

218. Yet the supply of units through office conversions is effectively finite. The average loss of office floorspace

per residential unit gained through O2R PDR over the period 2014-2018 (including pipeline schemes) was

51.4 sqm. On that basis, the 224,474 remaining sqm of office floorspace in the borough in 2019 has the

capacity to deliver approximately 4,367 residential units. This is roughly three and a half years’ worth of

Enfield’s housing target of 1,246 as recommended by the Intend to Publish DNLP.

219. While PDR conversion has made a relatively significant contribution to housing delivery in recent years, it

has limited potential to meet Enfield’s housing requirement going forward – both on the basis of past

average annual delivery rates and the maximum contribution converting all remaining office stock could

make.

Size and type

220. Arguably as important as the overall quantity of housing delivery through conversions is the question of

whether the type of housing that is brought about through PDR meets the borough’s needs.

221. The Enfield SHMA notes that ‘the one and two bedroom stock in the borough is higher than both in outer

London and the national level’, accounting for 42.2% of the housing mix.138 In terms of future need, the

135 Enfield Council (2019): LDD - Housing Completions 01-04-2013 to 31-03-2019; targets set out in each plan. 136 At an average floorspace loss of 51.4 sqm per residential unit, 86 units would be expected to result in a loss of 2,981 sqm, which is 1.3% of the 224,474 sqm currently existing in the borough. 137 https://new.enfield.gov.uk/services/planning/annual-monitoring-report-and-housing-trajectory-2019-planning.pdf. 138 SHMA 3.4.3; 3.4.5.

100% 100%

2018 NPPF OAN

DNLP (Intend to Publish Target)

DNLP (Previous Target)

London Plan (2016)

London Plan (2011)

Core Strategy (2010) / London Plan (2008)

Target % of target met by average annual PDR delivery 2014-2018



AECOM 45

SHMA finds that 50% of market housing and affordable rented housing should consist of three and four

bedroom dwellings, with only intermediate housing of all tenures found suitable for one and two bedroom

homes at a proportion greater than 50%.139 This conclusion is also supported by evidence that 47.3% of

need on Enfield’s Local Housing Register is for larger family-sized homes (i.e. those with three or more

bedrooms).140

222. It is in this context of existing stock and future need that the size and type mix of converted dwellings should

be understood. Table 5-2 and Table 5-3 below show that dwellings brought about through O2R PDR

conversions are overwhelmingly small in terms of bedrooms (98% have fewer than 2 bedrooms), and

almost exclusively flats (99.1% are flats or maisonettes).

Table 5-2: Size of completed O2R PDR new units141

Number of bedrooms % Sum of new units

Studio 32.6% 140

1 bed 46.2% 198

2 bed 19.6% 84

3 bed 2.1% 9

Total 100% 429

Table 5-3: Type of completed O2R PDR new units142

Unit type % Sum of new units

Flat Apartment or Maisonette 66.4% 285

House or Bungalow 0.9% 4

Studio or S/C Bedsit 32.6% 140

Total 100% 429

223. 98% of all O2R PDR housing supply can therefore be said to fall into a typology that represents only 50% of

need as identified in the SHMA. Outside of the planning system, O2R conversions cannot be expected to

deliver towards the borough’s identified need to supply larger homes (of more than 3 bedrooms) and a more

diverse mix of units in terms of type, size and tenure.

224. Due to the constraints of existing building sizes and layouts, it is not reasonable to expect that a far higher

proportion of converted flats should have 3 or more bedrooms. However, were Enfield to successfully

intervene to remove PDR, policy-compliant O2R conversions could make a meaningful contribution to the

need for family-sized homes.

Affordable housing

225. Core Policy 3 in the Enfield Core Strategy, updated in the Enfield S106 SPD (2016), requires that 40% of

dwellings in applicable schemes of 11 or more units be affordable homes, and 20% of dwellings in schemes

of 1-10 units with combined floorspace over 1,000 sqm be affordable homes.143

226. The Enfield SHMA (2015) identified an annual net shortfall of 456 affordable rented dwellings over the

period to 2032 in Enfield.144 Recognising the magnitude of the borough’s affordable housing need, Enfield’s

draft Local Plan (Issues and Options publication 2018) proposes a strategic target that 50% of new housing

in the period to 2036 should be affordable.145 This is in line with the level of affordable housing need and

139 SHMA pg. 132 140 Enfield Local Plan Issues and Options publication 2018, 5.5.2 141 Enfield Council (2019): LDD - Housing Approvals 01-04-2013 to 31-03-2019. Data for the type of each dwelling allows the studios (given only in data on type, not size) to be split out from the 1 bed dwellings, on the assumption that no studios would have been counted as 2 or 3 bed dwellings. 142 LDD (2019): Housing Approvals (unit level) on the London Development Database (LDD), [online] available at: https://data.london.gov.uk/download/planning-permissions-on-the-london-development-database--ldd-/4d65e64c-f8d8-4ca8-90cf-97921830cec2/LDD%20-%20Housing%20Approvals%20unit%20level.xlsx. 143 Paragraph 7.4 of the SPD states: In light of changes to the Government's National Planning Practice Guidance (NPPG) following the Court of Appeal decision on 11 May 2016 (referred to in paragraphs 1.2-1.4), Affordable Housing contributions will be sought from schemes of 11+ units (irrespective of the floorspace of the site). Contributions will also be sought from proposals for 1-10 units where the maximum gross combined floorspace of the site is over 1000 square metres. 144 Enfield SHMA 2015, 13.12.8. 145 Policy H2.

https://data.london.gov.uk/download/planning-permissions-on-the-london-development-database--ldd-/4d65e64c-f8d8-4ca8-90cf-97921830cec2/LDD%20-%20Housing%20Approvals%20unit%20level.xlsx

https://data.london.gov.uk/download/planning-permissions-on-the-london-development-database--ldd-/4d65e64c-f8d8-4ca8-90cf-97921830cec2/LDD%20-%20Housing%20Approvals%20unit%20level.xlsx



AECOM 46

the strategic target put forward in the DNLP,146 and also reflects the first of Enfield’s five priorities set out in

the Enfield Housing and Growth Strategy 2020-3030.147

227. It should be emphasised here that PDR conversions do not require any affordable housing to be provided,

and no affordable dwellings have been delivered through conversions in Enfield to date.

228. On the basis of Enfield’s affordable housing policy target in the Core Strategy, it is possible to estimate the

quantity of affordable housing that would have been delivered were O2R PDR conversions required to

provide affordable housing at target levels.

229. Of the 47 O2R PDR schemes completed to date, which supplied 429 residential units, the potential quantity

of affordable housing that would have been provided is 138 whole units, with commuted sums equivalent to

provide 16.2 units off-site.

230. Of the 24 O2R PDR schemes currently in the pipeline, which are anticipated to deliver 309 units, the

potential quantity of affordable housing that would have be provided is 103 whole units, with commuted

sums equivalent to provide 8.6 units off-site.

231. In total this amounts to 241 affordable housing units and commuted sums to provide 25 units (rounded), or

a grand total equivalent to 266 affordable housing units that were not delivered due to PDR.

232. However, it is worth pointing out that the office conversion rate in Enfield prior to the introduction of PDR

was extremely low. So the likely outcome of the removal of PDR would be the retention of office stock rather

than the continuation of a high rate of conversions subject to normal planning requirements such as

affordable housing provision.

233. In calculating these figures, a number of assumptions were made:

• It is assumed that schemes will meet affordable housing requirements in full, which has been

demonstrated to not be realistic in practice (see below). The results therefore represent the maximum

potential quantity of delivery.

• Only the unit totals of schemes have been considered, because the gross floorspace of schemes

delivering fewer than 11 dwellings is rarely (nor exactly) known.

• It is assumed that where multiplying the total number of units per each scheme by the relevant

affordable housing policy target results in a number greater than one, any whole units will be provided

on site and commuted sums will be paid at the equivalent of the remainder. For example, a 6-unit site

at a policy rate of 20% should deliver 1.2 affordable housing units, so it is assumed that 1 unit will be

delivered on site and a commuted sum paid at the equivalent of 0.2 units to fund affordable housing

off-site.

• It is assumed that Enfield would have or may in future continue to collect affordable housing

contributions from sites delivering fewer than 10 dwellings despite national planning policy guidance

more recent than the Enfield Core Strategy that restricts this. Alternative calculations assuming the

reverse (that no affordable housing contributions will have been or in future be collected for sites

delivering fewer than 10 dwellings), produce the following results:

• 132 whole units and commuted sums equivalent to 4.8 units from completed schemes;

• 125 whole units and commuted sums equivalent to 1.6 units from pipeline schemes;

• A grand total of 257 whole units and commuted sums equivalent to 6.4 units, or 263 units

(rounded) in total.

234. These estimates of foregone affordable housing should be viewed in the context of past affordable housing

delivery rates in Enfield. This data is presented in Table 5-4 below.

146 Policies GG4, H4 and H5. 147 The priority is, in full: ‘More genuinely affordable homes for local people: building more homes that are the right kind of homes, in the right locations and for local people. This means homes that are well-designed and are the right size, tenure and price that local people can afford.’ pg. 6.



AECOM 47

Table 5-4: Affordable housing and PDR delivery rates148

FY2014 FY2015 FY2016 FY2017

Total housing delivery 399 674 884 397

Market units 314 552 582 360

PDR units (all market) 34 112 240 36

Affordable units 85 122 302 37

% affordable housing 21.3% 18.1% 34.2% 9.3%

% PDR 8.5% 16.6% 27.1% 9%

235. The data shows that there is no strong statistical correlation between high PDR delivery in a given year and

the percentage of affordable housing delivered in that year. However, it also shows a relatively volatile and

consistently below-target affordable housing delivery rate.

236. The elimination of PDR could only be assumed to aid in the necessary effort to increase affordable housing

supply, since policy compliant conversions would need to meet affordable housing requirements. However,

the extent to which a Council intervention would genuinely increase affordable housing delivery is not clear.

148 Enfield Council (2019): LDD - Housing Completions 01-04-2013 to 31-03-2019; Enfield Annual Monitoring Report and updated Housing Trajectory 2019, Enfield draft Local Plan Issues and Options publication 2018 Table 5.1.



AECOM 48

6. Housing quality

Introduction

238. This section comprises two forms of analysis: a desk-based review of a representative sample of residential

schemes delivered through O2R PDR, and a series of interviews with local estate agents. The intention of

including both approaches is to identify any common issues or concerns with the quality of the housing that

has been provided through PDR conversion in Enfield.

Quality appraisal

239. Nine different O2R PDR conversion schemes in Enfield were selected and assessed against a set of

metrics derived from space standards set out in Draft New London Plan Policy D4 (housing and quality

standards) and Enfield Core Strategy Policy DMD 8 (general standards for new residential development).

The result of the quality analysis is presented in the table overleaf.

240. The chosen schemes constitute a representative sample of O2R conversions in Enfield since 2014. Six of

them are located in the wards of Enfield Town and Southgate, because this is where most schemes were

concentrated. A further three are located in other wards. Within each main area of search, at least one large

scheme (>10 units), one mid-sized scheme (3-10 units) and one small scheme (<3 units) were included.

Finally, the chosen schemes represent a range in terms of their year of completion, from 2014 to 2018.

241. This quality appraisal is a desktop exercise, using a range of publicly available sources such as Google

Maps, floor plans and officer reports included in the planning application, as well as rental websites such as

zoopla.co.uk.

242. Notably, the information available varies considerably between the schemes. For example, some of the

applications did not contain any architectural drawings, highlighting the lack of scrutiny around the quality of

the schemes when determining applications.

243. It was found that the overall quality of residential schemes brought about through O2R PDR has tended to

be sufficient, with most of the surveyed schemes scoring well on the metrics employed. This is shown in

Table 6-1 below. A majority of schemes provide satisfactory access, daylight and facilities, with minimal

evident cause for concern regarding daylight, aspect or internal layouts.

244. However, the schemes scored moderately or poorly on four interconnected metrics. These were space

standards (including those for individual rooms and entire units), where around of half of schemes did not

meet nationally described guidelines. However, it should be noted that where schemes fell below expected

space standards, they generally did not fall below by much. Another area of moderate concern is the

provision of amenity space and communal areas that just under half of schemes fail to provide.

245. The metric on which the schemes surveyed performed worst was wheelchair accessibility, with only 2 of 9

schemes appearing to provide at least 10% wheelchair-accessible dwellings. This is the standard that is

required of all new residential development by Policy DMD 8 in Enfield’s Development Management

Document (2014), with which PDR conversions are exempt from complying.

246. Note that the DNLP sets a similar target of 10% M4(3) wheelchair accessible standard homes and 90%

M4(2) accessible standard homes.

247. Although flats are among the typologies that most frequently meet accessibility standards,149 there is no

policy requirement or incentive for PDR conversions (9.1% of which are flats) to achieve this. Bringing future

conversions within the normal planning system would help to deliver this.

248. Note that Ben Clifford of University College London (UCL)’s emerging work for MHCLG includes a similar

but more detailed assessment of the quality of PDR residential units than was possible here.150 This

emerging work looks at a larger sample of 25 examples and includes site visits. The conclusions of that

exercise, when complete, should be referenced by the Council in addition to the results of this AECOM

study, when making relevant policy decisions.

149 English Housing Survey 2014/15: Adaptations and Accessibility. 20% of flats meet full visit-ability standards, compared with 5% among all dwelling types. 150 Dr Ben Clifford et al., Research into the quality standard of homes delivered through change of use permitted development rights, December 2019 (draft).



AECOM 49

Table 6-1: Quality analysis table151

FACTOR

P14-

01766

PRJ

14-

03249

-PRJ

16-

05074

-PRJ

P14-

00401

PRJ

P13-

02348

PRJ

17-

00979

-PRJ

P14-

01696

PRJ

P13-

03468

PRJ

P13-

02831

PRJ

Tally

Location Town Town Town South

gate

South

gate

South

gate

Grang

e

South

gate

Green

Winch

more

Hill

Date 2016 2015 2018 2015 2016 2017 2017 2016 2014

Number of units 27 6 1 40 5 2 21 5 1

Appropriate

location and

access to local

amenities

Yes Yes Yes Yes Yes Yes Yes Yes Yes 9

Acceptable levels

of daylight,

privacy, noise,

outlook

Yes Yes Yes Yes Yes Yes Yes Yes Yes 9

Single / dual

aspect Dual Dual Dual Dual Single Single Dual Dual Dual 7

Meet or exceed

space standards Yes Yes No No No

No

data Yes Yes

No

data 4

Well-designed

functional layout Yes Yes Yes Yes Yes

No

data Yes Yes

No

data 7

Adequately sized

rooms (per space

standards)

Yes Yes Yes N/A Yes No

data Yes

No

data

No

data 5

10% of units

wheelchair

accessible

No

date Yes No Yes No

No

data

No

data

No

data

No

data 2

High quality

amenity space Yes Yes Yes Yes No No No Yes No 5

Adequate access,

parking and refuse

storage, with no

adverse effects to

street scene

Yes Yes Yes Yes Yes No Yes Yes No 7

Agent interviews

249. To complement the above analysis, Enfield estate agents were also interviewed about the quality, demand

and tenure of O2R PDR conversions, revealing the following observations:

• The converted apartments are mostly offered for rent. Although in the western more affluent parts of

Enfield there are higher proportions of apartments for sale to occupiers.

• Conversions in recent years tend to be to a high specification in terms of design and furnishings.

However, some conversions can include fairly small rooms throughout the house. There are, however,

notable exceptions.

• There is a general consensus that the apartments are meeting local requirements, especially in terms

of size. The vast majority of O2R apartments tend to be 1-2 bedroom homes, which are currently

perceived to be in high demand.

• Many estate agents seem unaware of O2R conversions and state that not many of these homes come

onto the market in Enfield, but more so in neighbouring districts. However, while sales of these homes

have been low, they have been increasing over the past 3-4 years.

151 Enfield Planning Register https://planningandbuildingcontrol.enfield.gov.uk/online-applications/?_ga=2.199052399.1566051786.1573048919-1561078477.1569406032



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Other evidence 250. The Council has raised concerns about the quality of residential schemes brought forward through O2R

PDR conversion in particular. It has been noted that in some instances, developers have reduced unit sizes

or removed amenities (such as parking spaces) as the scheme proceeds through successive applications.

251. In one particular example it is understood that when the number of residential units in the scheme was

increased from 76 to 92 units, the average unit size was consequently reduced from 23 sqm to 17 sqm

(both being below nationally described space standards).

252. This pipeline scheme was not included in the quality appraisal above as it was brought to the Council’s

attention after the analysis was undertaken, but it demonstrates that a representative sample cannot give a

complete picture. It also contributes to the conclusion that O2R PDR conversion schemes in Enfield are in

general at or above expected standards, but a small number of exceptions may still justify concern on the

part of the Council and create a negative perception about PDR more widely.



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7. Council revenues

Introduction

253. This section estimates the financial impact to the Council from O2R PDR conversions in three areas: the

lost revenue from Section 106 (S106) contributions that would have been paid were conversions treated as

normal planning applications; the implications for the Community Infrastructure Levy (CIL); and the net

impact of O2R conversions on lost business rates and gained council tax receipts.

Section 106

254. Unlike non-negotiable CIL contributions, which are levied at fixed rates to finance the cost of additional

infrastructure required to support new development, the purpose of Section 106 (S106) agreements is to

make specific developments acceptable in planning terms by mitigating any undesirable impacts.152

255. This is undertaken as part of the normal planning process, and applies only to development that requires

planning permission. PDR conversions are thus exempt. This is confirmed in PPG:

• ‘By its nature permitted development should already be generally acceptable in planning terms and

therefore planning obligations would ordinarily not be necessary. Any planning obligations entered into

should be limited only to matters requiring prior approval and should not, for instance, seek

contributions for affordable housing.’153

256. It is therefore helpful to understand the scale of the S106 contributions that would have been received, had

O2R PDR conversions been subject to the normal planning system. This may inform a decision as to

whether the Council should intervene to restrict PDR in Enfield.

257. However, for the purpose of this exercise it is assumed that placing planning obligations on such schemes

would not render them unviable or require changes to the number of units or other aspects in order to

maintain viability. This assumption is unlikely to be true in practice, so the total potential revenue estimated

here should be understood in that context.

258. Generally, the most important element of a Section 106 (S106) agreement is a contribution made by the

developer in the form of affordable housing delivery or a commuted sum for off-site affordable housing

delivery. An estimate of the foregone affordable housing contributions from PDR O2R conversions is

considered separately in the ‘Housing need’ section of this report.

259. Here, the financial contributions (separate from affordable housing) made through S106 received from

residential development are considered. This is estimated with reference to the flat sum of £3,000 per

dwelling for schemes delivering up to 250 dwellings and £7,500 per dwelling for schemes delivering more

than 250 dwellings. These sums were determined in a Viability Assessment of CIL and the Proposed

Submission DMD, published in 2013, and are understood to have applied in Enfield since 2013 (the

introduction of PDR), up to the present.

260. None of the 47 schemes completed to date and 24 schemes currently in the pipeline are expected to deliver

more than 250 units.

261. To determine the foregone residual (non-affordable housing) S106 contributions for completed conversions

to date, the 429 units delivered is multiplied by £3,000 to give a result of £1,287,000.

262. To determine the foregone residual (non-affordable housing) S106 contributions for pipeline conversions,

the 309 units delivered is multiplied by £3,000 to give a result of £927,000.

263. In total, therefore, the estimated S106 revenue foregone from all (completed and pipeline) O2R conversions

that are exempt due to PDR is £2,214,000.

264. In addition to the caveat that schemes subjected to S106 obligations may become unviable and therefore

generate less or no revenue, it is important to note that the fact that PDR schemes are considered to be

acceptable in planning terms suggests that foregone S106 revenue alone should not be used as a

justification to remove PDR. This would be a by-product of an A4D, but it is the view of this study that it

should not be cited as a primary justification.

152 Enfield Council Section 106 SPD, November 2016, p.g 7. 153 Paragraph: 009 Reference ID: 23b-009-20190315, Revision date: 15 03 2019.



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CIL contributions

265. The Enfield Section 106 SPD (November 2016) states the Council’s application of nationwide CIL

regulations as follows:

• ‘CIL is levied in pounds per square metre of the net additional increase in floorspace for development

which either a) creates 100 square metres of gross floor space or more, or b) creates a new dwelling,

irrespective of its size. The levy is not charged on changes of use where there is no increase in

floorspace and the building (or part of the building) has been in continuous lawful use for 6 months

within the 3 year period prior to receiving planning permission.’ (Emphasis added.)

266. CIL regulations apply to ‘general consents’ (the category into which permitted development rights fall) as

well as normal planning applications.154 PDR schemes are therefore liable for CIL contributions.

267. However, the majority of PDR conversion schemes will be not be liable for CIL. This is not because PDR is

in any way exempt but because (as above) ‘the levy is not charged on changes of use’. All PDR

conversions are by definition changes of use, and such schemes very infrequently add to the total

floorspace.

268. It is worth reflecting further on the other exemption, however. It is distinctly possible that some of the

conversion schemes had not been in continuous use for six months at any time in the three years preceding

the prior approval application.

269. Given the low vacancy rate of office space in Enfield throughout the last decade, however, it is reasonable

to assume that only a minority of all office units fulfilled the necessary condition of vacancy to be CIL-liable.

Though it is likely that vacant units will have been overrepresented among those units subjected to PDR

conversion (due to a lack of resistance from occupiers or a willingness for owners to sell), it is equally

possible that some other factor – such as the location or condition of the building – would have made such

units as unappealing to residential developers as to office occupiers. Furthermore, the additional cost

associated with the condition of CIL-liability is itself a deterrent to the conversion of long-term vacant stock.

270. In any case, those schemes that were CIL-liable would have been obliged to make CIL contributions.

271. The necessity to maximise CIL receipts cannot therefore form part of any justification to intervene to restrict

PDR: the majority of conversions would remain exempt even were an A4D to be successful, and non-

exempt schemes would be obliged to pay.

272. However, CIL Liability Notices are issued to developments alongside Planning Decision Notices in Enfield,

as elsewhere.155 The lever for charging CIL therefore sits within the normal planning process from which

PDR is divorced. Enfield planning officers attest to the fact that PDR cases are more difficult to monitor for

this reason, and because the occupancy test (‘continuous lawful use…’ as above) is harder to prove or

disprove.

273. It is therefore understood that the removal of PDR, bringing future conversions within the normal planning

process, would (as a side-effect rather than a stated purpose) potentially help to reduce the rate of non-

compliance.

274. For general interest, an estimate of the CIL revenue that would have been gained were O2R PDR change of

use schemes in Enfield not exempt from CIL is provided in Appendix B.

Business rates and council tax

275. Estimating the loss of revenue to Enfield Council from business rates no longer paid at converted offices

and the additional council tax revenue arising from new residential properties provides an understanding of

the net tax impact of O2R PDR conversions. However, the analysis also comes with a number of limitations.

276. The main limitation is the inadequacy of data, in terms of both availability and reliability. Data from the

Valuation Office Agency (VOA)156 for the addresses of converted properties are necessarily incomplete:

where they have been converted, no business rates valuation is published; where they have not yet been

converted council tax banding has not been determined. Very few cases allow the past business rate and

current council tax rate to be viewed, and many allow neither. However, the Council have been able to

154 The Community Infrastructure Levy Regulations 2010 5.3. 155 https://new.enfield.gov.uk/services/planning/community-infrastructure-levy/. 156 Data available from the Valuation Office Agency at https://www.gov.uk/correct-your-business-rates.



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provide business rates valuations for Enfield offices existing as such in 2017-2019, which greatly improves

data gathering for this aspect.157

277. The VoA data is of low quality: it is frequently not possible to specify the precise unit in question at a given

address, or to distinguish which part of an address will undergo or has undergone conversion. The Enfield

data improves on this but addresses are not all able to be precisely matched to conversion schemes. As a

result, additional steps to estimate and extrapolate the data are introduced.

278. Taking business rates first, the first step is to determine the rateable value of each office premises that has

been or will be converted.

279. Yet as noted above, conversions which took place prior to 2017 do not have their rateable value published

(and more recent conversions do not all reliably appear in the data available). For pipeline conversions,

however, data is more readily available. Therefore, the rateable values of pipeline conversion addresses

were captured (19 of 23 addresses had a valuation).158

280. The next step, ideally, would be to divide these valuations by the existing floorspace of their addresses to

produce an average valuation per sqm, but this data is not known for the majority of pipeline schemes.

Instead, each valuation is divided by the number of residential units expected to be delivered. Taking an

average of these results produces a mean rateable value per residential unit gained of £5776.23.159 As most

units are 1 or 2 bedroom flats that are unlikely to differ dramatically in size, this is considered to be a fair

assumption. This average is then multiplied by the number of units expected for every pipeline scheme that

did not have a valuation, and for every completed scheme (since little, older, and less reliable valuation data

was available for past conversions).

281. The next step is to apply a multiplier to determine the actual rate of tax owed. The national 2019/20

multiplier is 0.491 for small businesses occupying space with a rateable value of less than £51,000, and

0.504 for all other businesses.160 Note that only 5 of 23 pipeline schemes and 10 of 47 completed schemes

exceeded the threshold to be eligible for the large business multiplier.

282. As a general rule, businesses occupying properties with a rateable value of under £12,000 get full relief

from business rates.161 Properties with a rateable value of £12,000 to £15,000 get an unspecified degree of

relief, up to 100%. For the purpose of this calculation, in which there were only two pipeline properties with

a rateable value in this range (with values of £13,525 and £14,250), it is assumed that 50% relief was

received.

283. This step significantly reduces the number of offices that would be expected to generate business rates

revenue: 12 of 23 pipeline schemes and 23 of 47 completed schemes would be expected to receive full

business rates relief. Note that no deduction is made to account for the 3-month relief to which vacant

properties are eligible because the vacancy rate in Enfield is negligible.

284. Local Authorities retain 50% of revenue generated through business rates, so the business rates for the

remaining schemes not eligible for relief are divided by 2.162

285. On this basis, the total estimated annual business rates revenue due to Enfield for pipeline schemes is

£316,258. The total estimated annual business rates revenue lost to completed PDR conversions since

2014 is £580,066. The grand total is therefore £896,324.

286. Turning now to council tax, the first step is to determine which council tax bands the apartments resulting

from O2R PDR conversions fall into.163

287. As noted above, pipeline conversions have not yet been completed and the council tax bands of the

resulting dwellings have not been determined. Therefore the council tax banding of completed schemes is

gathered. Again, the data is of low quality, with a low proportion of bandings disclosed and a high degree of

157 For pipeline conversion schemes almost all 2019 business rate valuations are known (and 2017 data was used in two cases where 2019 data was not available). For completed schemes, 2017 data (the oldest available) was used to capture the greatest number of units prior to their conversion, but the majority were still unavailable. 158 Note that there are 24 conversion addresses. However, one address (55-57 Chase Side) is subject to two conversion applications, but only has one (total) business rates valuation. It’s business rates valuation is therefore counted as though it were one scheme, and the total number of schemes in this section of the report is given as 23. 159 Note that this calculation was made using the less reliable and less plentiful VOA data before the Enfield data became available. The result of the previous calculation was £5,884.23, suggesting that the VOA data is in fact relatively reliable for this purpose and the average-based approach taken is sufficiently accurate. 160 Available at https://www.gov.uk/government/publications/12019-business-rates-2019-to-2020-multipliers. 161 This and other methodological guidance is expressed in Enfield’s 2019/20 Explanatory Notes, available at https://new.enfield.gov.uk/services/business-and-licensing/business-rates-explanatory-notes-19-20-business-and-licensing.pdf. 162 https://www.local.gov.uk/topics/finance-and-business-rates/local-taxation-council-tax-and-business-rates. 163 This data is searchable at http://www.mycounciltax.org.uk/content/index.



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uncertainty around which apartments listed at an address result from the conversion (as opposed to existing

previously).

288. Contrary to expectations, for the data that was available, there was a high degree of variation in the council

tax banding of apartments gained through O2R PDR conversion. Of the 18 completed schemes for which

council tax banding data was available, every band from A through G is represented. Of the 68 units

counted, 3% were band A, 15% band B, 15% band C, 31% band D, 32% band E, 3% band F, and 1% band

G.

289. These proportions are therefore taken as a representative proxy for all residential dwellings gained through

O2R PDR conversion. The total number of units delivered from completed schemes (429) and expected

from pipeline schemes (309) are then multiplied by the banding percentages above and manually rounded

(so that all units are counted as whole numbers) to produce an estimated dwelling mix by council tax

banding.

290. The total number of dwellings falling into each band is then multiplied by the amount of council tax charged

for that band, resulting in an estimate of total annual council tax revenue from converted dwellings.164

291. For completed dwellings this is £582,147 and for pipeline conversions it is £420,399. The grand total is

therefore £1,002,546.

292. In conclusion, the estimated annual revenue received by the council for new residential dwellings is slightly

higher than the estimated revenue lost from businesses occupying converted offices. The net impact is an

annual gain of £106,222. O2R PDR conversion is therefore understood to be relatively tax-neutral and not a

basis upon which a decision to intervene against PDR should be made.

293. Note that this estimate is not a full cost benefit analysis. Rather, it is a comparison of the tax revenues

generated by the two uses. The benefits of retaining businesses in offices might outweigh the benefits of

converting to residential in other ways, such as spend by employees in the local economy, the costs of

providing services to residents, and so forth. Such additional matters are beyond the scope of this study and

for the Council to consider.

164 This is provided online at https://new.enfield.gov.uk/services/council-tax/guide-to-your-council-tax-2019-20/#3.



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8. Potential for intervention

Introduction

294. This section considers the primary avenue for intervention to control or restrict PDR, namely a combination

of Local Plan policy with an A4D. This section deals specifically with O2R PDR, which due to its scale and

nature is determined to exert by far the greatest potential risk to employment and planning objectives in

Enfield. A table summarising the key evidence gathered in this study in terms of whether it supports or

would not support an intervention on the part of the Council is presented. The section also reviews relevant

Planning Practice Guidance and examples of A4Ds to restrict O2R PDR in other London boroughs, to

provide an appropriate context.

Emerging Local Plan policy

295. Whether or not an A4D or alternative response is taken, this study recommends a number of minor changes

to planning policy that may be advantageous with regard to O2R conversion.

296. The policy baseline of the Core Strategy and Development Management Document in relation to O2R

conversions (namely Core Policy 19, DMD 22, DMD 24) has been superseded by the expansion of PDR in

2013. Where PDR applies, the policies in question are redundant. If an A4D is not pursued or is pursued but

not successful, such policies will continue to be redundant. If an Article 4 is successfully implemented, even

if covering only part of the borough, such policies will once again be of great importance.

297. To cover all eventualities, it is recommended that all retained policy wording be updated to state: “Planning

applications for change of use (where planning permission is required)…” This would cover applications for

conversions in Article 4 areas, and anything that goes beyond PDR (i.e. involving demolition, recladding,

additional storeys, etc.).

298. The next question is how the relevant policies should be amended in the emerging Local Plan, and how

permissive or restrictive they should be. Analysis based on the data presented above suggests that the

following stipulations should be retained or appended:

• Continued protections for the strategic employment areas of Enfield Town and Southgate as in Core

Policy 19.

• The similar provisions in Policy DMD 22 and Draft Policy E2l should be retained in some form to

ensure that conversions do not create an undersupply of office accommodation. It may be useful to

include provision for demonstrating prolonged vacancy following sufficient, appropriate advertising.

• Small office accommodation (<50 sqm), being more strategically important to SMEs, more likely to

deliver poor-quality studios, less likely to deliver meaningful affordable housing contributions, and less

effective in delivering Enfield’s housing targets, should continue to be protected as proposed in DMD

policies.

• Adding similar protections to office accommodation up to 500 sqm units (which have the lowest

vacancy and are being converted in disproportionate numbers compared to their share of the stock)

would also be appropriate.

A4D policy context

299. A successful A4D would bring the conversion of office accommodation to residential uses within the

jurisdiction of the normal planning system. Applications would therefore be subject to a more detailed

process of scrutiny and negotiation by the Council, with schemes subject to policy requirements including

those preventing the conversion of office units of a particular size and those relating to housing mix and

tenure, as well as subject to planning application fees, CIL and S106 contributions.

300. An A4D is therefore clearly preferable to PDR where a Council wishes to control and fully scrutinise new

development. However, PDR was introduced to streamline the planning system and boost housing delivery.

Restricting PDR through an A4D is therefore not a unilateral decision but one that is itself scrutinised by the

Secretary of State and liable to be amended or cancelled at their discretion.

301. It is therefore important that Local Planning Authorities pursuing such a course of action prepare the

wording of their A4D and consider its justification carefully.



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302. PPG states that:

• The use of article 4 directions to remove national permitted development rights should be limited to

situations where this is necessary to protect local amenity or the wellbeing of the area. The potential

harm that the direction is intended to address will need to be clearly identified, and there will need to

be a particularly strong justification for the withdrawal of permitted development rights relating to:

a) a wide area (e.g. those covering the entire area of a local planning authority, National Park or

Area of Outstanding National Beauty).

b) cases where prior approval powers are available to control permitted development.165

• Provided that there is justification for both its purpose and extent, an article 4 direction can:

a) cover an area of any geographic size, from a specific site to a local authority-wide area.

b) remove specified permitted development rights related to operational development or change of

use.

c) remove permitted development rights with temporary or permanent effect.166

303. While this study looks at the wider question of the overall costs and benefits of PDR in Enfield, PPG implies

that the chief question when it comes to justifying an Article 4 is the narrower issue of what harm is done by

PDR. The scale of the contribution to housing need from PDR, the need to deliver affordable housing, or the

desire to scrutinise proposals for size mix arguably represent opportunity costs but are otherwise not in

theory under consideration by the Secretary of State. Although previous A4Ds in other London boroughs

have developed cases that cover such aspects, the key justifying factor should be the harm to employment

uses.

304. The second important lesson to be drawn from PPG is the higher burden of justification for A4Ds that apply

to a wide area. Previous A4Ds in other London boroughs have faltered on this aspect in particular and it is

now widely understood that a successful Article 4 will generally be limited to a specific geographical area.

305. The cancellation of Article 4 by the Secretary of State provides a mixed precedent due to the fast-changing

political environment and the evolution of wider opinion on what is an increasingly heated subject. Two

examples of a shift in support of Article 4 include the DNLP, which supports A4Ds to protect “existing viable

office floorspace” in geographically-defined local office locations but not “surplus office space,”167 and a

recent RICS report that categorically states that “Article 4 directions should be used, where resources

allow.”168

Summary of evidence justifying intervention in Enfield

306. Table 8-1 below compiles key pieces of evidence analysed in this report by topic area, presenting each

either as justification for or against an intervention on the part of the Council.

Table 8-1 : Summary of evidence justifying an intervention

Factor and conclusion

Justification for intervention Justification against intervention

Demand for office stock. Strong justification for intervention.

Enfield office-based employees are expected to increase from 17,300 in 2016 to 22,200 in 2036. Forecast demand for office floorspace in 2036 is 249,700 sqm, which exceeds current supply by 11.2%. Vacancy rates have consistently declined over the past decade to currently stand at the historically low level of 1.7%. This is low for the FEMA and far below the required frictional rate of 8%.

There is a general need for additional supply of new office stock to improve quality and meet a wider range of needs. However, the existing stock that the ELR found to be generally affordable and therefore particularly beneficial to SMEs may not be likely to be replicated in newly developed supply.

165 Paragraph: 038 Reference ID: 13-038-20190722; revision date: 22 07 2019. 166 Paragraph: 037 Reference ID: 13-037-20140306; revision date: 06 03 2014. 167 DNLP Policy E1 criteria E and I; para 6.1.6. 168 RICS, Assessing the impacts of extending permitted development rights to office-to-residential change of use in England, May 2018, pg. 11.



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Rents have increased by an average annual rate of 6% (a total of 42% since 2010). Although the correlation with conversions is not clear, rising rents have a significant impact on the viability of SMEs and other local businesses.

Loss of office stock. Strong justification for intervention.

The scale and speed of office space loss since the introduction of PDR is significant. 47 schemes were completed in FY2014-2018, resulting in an estimated loss of 25,396 sqm of office space. Total estimated floorspace lost to completed and pipeline conversions is equivalent to 16.3% of the total floorspace existing at the time of the introduction of PDR in 2013. Office development in Enfield has been almost non-existent in recent years: less than 1,400 sqm have been built over the past decade, compared with an estimated loss through PDR conversion of 25,396 sqm since 2014. Lack of replenishing pipeline supply means stock is effectively finite. Deducting outstanding permissions for new offices from pipeline conversions leaves a near-future net loss of 1,387 sqm.

The pace of conversion has slowed since the initial 2015-2016 peak, with only 849 sqm of known floorspace converted in 2018 and 10,290 sqm of known floorspace currently earmarked for conversion in future years (compared with 12,808 sqm of known floorspace lost in FY2016 alone). This suggests demand to convert may have plateaued and pose less risk in future.

Threat to economy from lost space. Strong justification for intervention. Justification for focusing PDR restrictions on office units under 500 sqm in size.

Enfield office space largely serves the local market and its availability has a direct impact on the local economy. Total available stock is approaching the average quantity of occupied stock in previous years, below which an undersupply would force businesses to relocate or start elsewhere. SMEs are the lynchpin of the Enfield economy (93% of firms have fewer than 9 employees). The unit sizes they occupy are under particular threat from conversion (the median size of completed conversions 2014-2018 was 270 sqm, and 59.3% of conversions were of units under 250 sqm in size). The ELR noted that SMEs in Enfield lack the grow-on space needed for expansion. The next largest size category, 250-500 sqm, has a vacancy rate of 0% and represented 11.7% of conversions by floorspace despite being only 5.7% of the stock by floorspace.

The number of office jobs in Enfield declined between 2001 and 2015 despite rising across the FEMA. The borough is not a major office location in the FEMA nor seen as strategic for Greater London.

Residential delivery. Justification against intervention.

429 residential units were delivered through PDR since 2014, with a further 217 in the current pipeline. The potential benefit of PDR conversion to residential delivery is low in the context of new targets: the past annual average of 87 units is equivalent to 7% of the Intend to Publish DNLP target.

PDR has since its introduction made a meaningful contribution of 16% of all housing supply during a time of delivery stress. Residential delivery in Enfield has underperformed targets in most recent years, and targets are set to nearly double. All sources of supply should therefore be promoted, including PDR conversion.



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The potential housing supply to be gained from all remaining office stock is around three and a half years’ worth of that target. Enfield’s five-year land supply is robust at present, although this may change as new targets are introduced.

Enfield does not have a strong track record of residential delivery to justify additional restrictions that impact upon it.

Housing mix. Justification for intervention.

The residential size mix brought forward by PDR conversions is dominated by small flats: 99.1% flats and 98% units with 2 bedrooms or fewer. Both Core Strategy policy and future need identified in the SHMA contrast strongly with this mix. Only 50% of future housing need is for 1-2 bed units, which are supplied by 98% of PDR units. The absence of affordable housing delivery through PDR conflicts with strategic objectives and impedes the delivery of the annual housing need of 456 identified in the SHMA. Foregone affordable housing through PDR amounts to a maximum of 266 units, over a period in which a total of only 546 affordable units were delivered. This estimate is reduced to 263 units if Enfield has ceased to collect contributions from sites delivering fewer than 10 dwellings and will continue with this approach going forward.

It is not evident that restricting PDR would produce residential conversions with affordable housing. Rather, the rate of conversions will likely slow altogether, affordable housing obligations may impinge on viability, and any conversions that do proceed may not supply enough units to meet the policy threshold.

Residential quality. Neutral evidence.

The accessibility of PDR housing is particularly poor, with only 2 of the 9 sample schemes assessed providing 10% wheelchair accessible housing. Anecdotal evidence suggests that a small number of schemes are far below nationally described space standard.

Residential conversions to date do not appear to raise any major issues in terms of quality. Though space standards are less frequently met in PDR schemes, the representative sample surveyed indicates that they are not missed by a wide margin.

Location of conversions. Justification for intervention. Strong justification for limiting Article 4 to key locations.

PDR has been non-uniform in its impact across the borough, with knock-on effects for particular areas that are important to the local economy. Completed schemes have been highly concentrated in the Enfield Town area (74%) and Southgate ward (13%). While pipeline schemes are more evenly spread in terms of incidences, they are still most concentrated in Enfield Town and Southgate in terms of floorspace lost. The condition of offices in Enfield Town and Southgate, as appraised in the ELR, was deemed to be good to very good overall. These two locations are also recognised in the ELR and in Enfield’s Issues and Options Consultation document as the most suitable locations for office space and can therefore be considered the locations where the loss of office space should be promoted or protected in the interests of the local economy.

The worst affected Boroughs are also those where the stock of office accommodation is most plentiful. the borough Limiting PDR in key locations such as Town, Southgate, SIL and LSIS leaves other isolated units vulnerable at a time when conversions are becoming more evenly spread across the borough.



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SIL and LSIS locations are less appropriate for residential use, and further conversions there could reduce the integrity of key reservoirs of employment land. A4Ds have generally only succeeded where limited to a geographical area.

Proper planning of the area. Justification for intervention.

The Council’s strategic objectives of protecting and densifying high-value employment and of delivering affordable housing are impeded by PDR conversions. The volume of conversions in recent years raises the stakes in terms of PDR’s impact on wider planning strategy.

The office sector is not sufficiently strategic to the FEMA economy nor to that of Greater London that this represents a major justifying factor.

Council revenues. Neutral evidence.

The total revenue from S106 payments that would have been due from PDR O2R schemes (both completed and pipeline) is estimated to be in the region of £2,214,000. However it is likely, given the low rate of O2R conversions prior to PDR, that most schemes would not have gone ahead if subject to S106 obligations. This estimate of foregone revenue is therefore likely to be overstated.

PDR schemes are considered to be acceptable in planning terms, implying that foregone S106 revenue is not an appropriate basis upon which to remove PDR. PDR schemes are not liable for CIL because they involve a change of use. Were PDR to be removed, they would remain not liable. The estimated impact of conversions on business rates and council tax is within the margin of error of the calculation, with a £106,222 gain from conversion to residential of all completed and pipeline schemes.

Heritage assets. Justification for intervention.

There are 14 completed and pipeline PDR schemes located within Enfield’s conservation areas. Conservation Areas and intangible heritage assets are not protected from development undertaken through PDR, which is liable to contribute to cumulative impacts on the appearance and character, as well as the use patterns, of such areas.

No PDR schemes completed or approved to date are known to affect any listed buildings or other listed assets.

Future developments. Justification for intervention.

Demand for office space and from developers to convert to residential uses could sharply increase following the development of Edmonton Leeside and if Four Tracking and Crossrail 2 go ahead, though supply could increase as well. This would justify more stringent protections in key areas, but the prospect also justifies pre-emptive intervention. Mechanisms to control PDR would need to be in place in advance of such decisions being made in order to respond to the probable immediate spike in conversions being brought forward.

Loss of retail stock. Intervention not justified.

Vacancy of retail space in Enfield is low. Because most conversions result in a single residential unit, the cost of lost employment space is relatively high per dwelling delivered.

5 completed and 5 pipeline retail to residential PDR schemes represent only 31% of all retail to residential schemes, with the majority being taken forward with full planning permission. Enfield planning policy in this area is moving toward greater flexibility and the recognition that the loss of some retail space is not harmful.



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Retail sector market indicators do not demonstrate growing pressure since the introduction of PDR, and new retail delivery continues in excess of space lost to conversion.

London A4D case studies

307. This section reviews A4Ds limiting O2R conversion in other London boroughs. Key findings to be drawn

from these examples with relevance to Enfield’s situation include the following:

• All successful A4Ds apply only to selected strategic locations, on the basis of their importance to the

local economy;

• Impacts on SMEs, in addition to the wider effects of a loss of employment space, are frequently cited

as justification in successful examples;

• Addressing an imbalance in the type and size mix of dwellings delivered through PDR, and the desire

to increase affordable housing provision, are frequently cited as secondary justifications;

• Accessibility and space standards in the housing delivered have been cited as justifications;

• Buildings with historical significance may be targeted in A4Ds;

• The effect of an A4D is primarily to reduce the flow of O2R conversions rather than to meaningfully

increase the provision of affordable and more appropriate residential units.

308. More detailed descriptive case studies are also provided in Appendix C.

Barnet: successful

309. Justification: Barnet’s economy is driven by SMEs, both office and industrial, which serve the local area

rather than London or the South East. It is therefore important for Barnet to manage any change of use and

potential loss of employment space: the sustainability of Barnet’s economy relies on the continued

functioning of small businesses that supply jobs and services to local people. Article 4 would allow for this

management and closer consideration.

310. In justifying its Article 4, Barnet relied predominantly on the ELR’s identification of the vulnerability of the

borough’s employment land. The ELR concluded that the reduction of stock through PDR had led to

increases in rent. This, along with a lack of investment in new stock and other constraints in the commercial

market, threatened a loss of businesses and jobs. This situation is also compounded by the competition

between the residential and commercial property markets.169

311. The Council also highlights that housing delivered through permitted development is not managed through

Local Plan policy requirements, particularly on dwelling mix, size and affordability. This undermined Barnet’s

ability to manage the delivery of the right homes in the right locations, and to maintain quality and

accessibility.

312. Location: The A4D is limited to nine town centres, employment sites designated in the Local Plan and other

selected sites across the borough where it was particularly necessary to protect an economic niche,

vulnerable employment, or the wellbeing of the area. Proportionally only a small area of Barnet is

affected.170

313. Particular building types affected: Offices, buildings within town centres that support SMEs.

314. Result: From 1 October 2019 planning permission is required to change the use of buildings from B1a

(office) or B1c (light industrial) to C3 (residential dwelling house) within specific areas across the London

Borough of Barnet. The making of these non-immediate A4Ds were reported to Planning Committee on 25

June 2018 and were confirmed at Planning Committee on 24 July 2019.

315. Planning applications for a conversion of employment uses to residential will now be considered against

policies in Barnet’s Local Plan.

Camden: successful

169 https://www.barnet.gov.uk/sites/default/files/employment_article_4_justification.pdf. 170 https://www.barnet.gov.uk/sites/default/files/employment_article_4_maps_0.pdf.



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316. Justification: In 2014 Camden Council commissioned a report to examine the impact of PDR which found

that in the 12 months since the change to permitted development rights in 2013, the borough lost

approximately 24,000 sqm of office space, equivalent to some 2,570 jobs, and experienced a deficit of

affordable housing. On this basis, the report recommended the Council seek a borough-wide A4D to protect

an estimated 5,000 businesses occupying office premises outside London’s PDR-exempt Central Activities

Zone (CAZ).171

317. Location: Specific clusters of commercial buildings. PDR conversions of small units outside of these clusters

will still be permitted.

318. Particular building types affected: Commercial units, offices, and spaces potentially used by the creative

economy.172

319. Result: Approval for the direction was based on DCLG’s requirement for Camden to restrict coverage to

smaller geographical areas, largely clusters of commercial buildings. In August 2015 the Article 4 came into

effect, leaving small and standalone offices vulnerable to conversion.

320. The introduction of the A4D has led to a palpable slowing of prior approval applications submitted to the

Council. However, there are still concerns that the impact is ultimately marginal, and the Council cannot

recoup costs for full planning application fees for PDR conversions.173 The significant costs accrued by the

Council in putting the Article 4 in place might be prohibitive for local authorities that do not receive a similar

number of prior approvals.

321. Alternative actions: As a reaction to the loss of planning control, Camden has implemented a variety of

requirements outside of the Article 4’s jurisdiction. Camden is able to secure S106 agreements on PDR for

a construction management plan, cycle parking, car-free development and highways contributions. PDR is

Community Infrastructure Levy (CIL) liable, as long as the building has been occupied for more than 6

months within the last 3 years. The Council also requires that PDR applicants inform building control upon

implementation of the scheme, allowing Camden to monitor implementation rates.

Croydon: successful

322. Justification: Croydon was experiencing among the highest rates of PDR conversion in London, due to a

large amount of vacant office stock and high housing demand. After monitoring the impacts of PDR when

first introduced, the Council raised concerns about PDR undermining sustainable place-making practices

and the low quality of housing being delivered, eventually voting in favour of pursuing an A4D.

323. Concerns were also raised about the accessibility and quality standards of units being built, as over half of

PDR residential units reviewed did not meet minimum space standards, with one property in Croydon

measuring just 10 square metres.174

324. Location: Croydon Opportunity Area.

325. Result: Recently built office buildings and those with historical significance.

326. For the Croydon Opportunity Area (COA) alone, the Council has successfully adopted an A4D. The Council

made a non-immediate A4D on 5 September 2014, followed by a consultation period, after which the

council's planning committee endorsed and confirmed the A4D on the 6 November 2014.

327. Concerns remain over the quality of homes being provided under PDR which are not within the COA.

328. Alternative actions: The Council attaches conditions to PDR and have entered S106 agreements with

developers over parking issues. A CIL charging schedule has been in place since 2013.

Hounslow: partly successful

329. Justification: Hounslow has seen significant impacts from PDR, including the loss of office space and

planning control, and wished to protect the borough’s remaining office stock from conversion.

330. Location: 32 Town Centres, industrial areas, business parks and yards.175

171 Camden Council (2015a) Cabinet Report: Confirmation of Article 4 Directions for the Change of Use from Office To Residential (CENV/2015/13). Camden Council, Camden; Camden Council (2014); Camden Council (2014) Cabinet Report: Article 4 Direction for the change of use from office to residential (CENV/2014/11). 172 https://www.springerprofessional.de/the-camden-story-threatening-the-creative-economy/16644142. 173 Understanding the Impacts of Deregulation in Planning (2019). Ben Clifford, Jessica Ferm, Nicola Livingstone, Patricia Canelas. Springer International Publishing. 174 https://www.london.gov.uk/sites/default/files/slums-of-the-future-permitted-development-conversions-in-london-by-tom-copley-am.pdf. 175 https://hounslow.app.box.com/s/d3uuci2mzxwweh14afe7o98cqzsued9j.



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331. Particular building types affected: Industrial and office buildings.

332. Result: On 10 January 2018, Hounslow Council confirmed the non-immediate A4D to remove PDR for

change of use from B1(a) offices to (C3) residential. This A4D came into effect on 11 January 2018. The

Council had intended to introduce a Direction that removed O2R PDR from all buildings except those which

had obtained prior approval and were still capable of being built out.

333. However, the wording employed appeared to exclude all sites or buildings in respect of which permitted

development rights had been granted: it used the words ‘building and land’ rather than ‘development’. A

claimant then entered into a judicial review for sites that had been refused on the basis of the A4D.176 The

court subsequently quashed refusals for up to 271 units of accommodation.177

334. The High Court, despite being sympathetic to the Council's situation, especially given they were using the

Secretary of State’s wording from previous A4Ds, applied a plain meaning interpretation to the wording.

Islington: Initially cancelled but subsequently successful

335. Justification: In the first 18 months following the introduction of PDR, 75 applications for prior approval were

granted by the London Borough of Islington for a total of just over 700 residential units. Over two thirds of

residential units to be created were studio and one-bedroom flats, with no ability for the borough to secure

affordable housing.

336. Location: Borough-wide, which is the primary reason why the application was unsuccessful.

337. Particular building types affected: None specified.

338. Result: The planning minister announced his intention to cancel the Article 4 direction shortly before it was

due to be implemented, on the grounds that it was disproportionate to remove PDR across the entire

Borough, stating that “this revocation should send a strong message.”178 This gave the borough little time to

consider the impact of the cancellation before it was announced or to submit revised proposals, though an

alternative agreement was subsequently reached with government to reduce the scope of the direction.

Old Oak and Park Royal Development Corporation (OPDC): Successful

339. Justification: OPDC is the Local Planning Authority for the UK’s largest regeneration project, developing a

new centre and community for west London. There were indications that the Old Oak and Park Royal

regeneration area was coming under increasing pressure for change of use from office and industrial uses

to residential via PDR.

340. Article 4 was approached as a way to give OPDC greater control over inappropriate use changes that could

compromise Park Royal’s role as an important industrial area and undermine the comprehensive

regeneration of Old Oak.

341. Location: The Strategic Industrial Location (SIL) designated by OPDC.

342. Particular building types affected: Light industrial, office and commercial buildings.

343. Result: On 12 September 2016, OPDC gave notice of the making of a non-immediate Article 4 to remove

PDR and to reintroduce the need for planning permission for the conversion of offices, storage or

distribution centres to houses or flats within areas designated as Strategic Industrial Location in OPDC's

boundary. The direction was approved on 22 September 2017, applying only to the area designated as a

Strategic Industrial Location.

176 https://imbusiness.passle.net/post/102f5g1/the-road-to-permitted-development-is-paved-with-good-intentions-high-court-tel. 177 https://www.landmarkchambers.co.uk/high-court-decides-meaning-of-hounslow-article-4-direction. 178 As set out in the National Planning Policy Framework (DCLG, 2012b) and its specific guidance on Article 4 directions (DCLG, 2012c); UK Parliament (2014) Written Statement to Parliament. Available at: https://publications.parliament.uk/pa/cm201415/cmhansrd/cm140710/wmstext/140710m0001.htm.



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Appendix A : Enfield completed scheme locations Table A-1: Key for schemes identified on maps

Number Permission

Status

Site Name/Number Street Ward Postcode

1 Completed 18-24 Chase Side SOUTHGATE N14 5PB

2 Completed 8a Ladysmith Road TOWN EN1 3AA

3 Completed 267 Green Lanes PALMERS GREEN N13 4XE

4 Completed 10 Ladysmith Road TOWN EN1 3DT

5 Completed 221 Whittington Road BOWES N22 8YW

6 Completed 39 Church Street TOWN EN2 6AJ

7 Completed 221 Whittington Road BOWES EN1 3PE

8 Completed 10 Little Park Gardens TOWN EN2 6PQ

9 Completed 487 Green Lanes WINCHMORE HILL N13 4BS

10 Completed 92-94 Fore Street UPPER EDMONTON N18 2XA

11 Completed 22 Bull Lane UPPER EDMONTON N18 1RA

12 Completed 26 Burleigh Road SOUTHBURY EN1 1NY

13 Completed 7 Aldermans Hill PALMERS GREEN N13 4YD

14 Completed 80 Chase Side TOWN EN2 6NX

15 Completed 171 Chase Side TOWN EN2 0PT

16 Completed 3 Chase Side SOUTHGATE N14 5BP

17 Completed 6 Lodge Drive PALMERS GREEN N13 5LB

18 Completed 826 Green Lanes BUSH HILL PARK N21 2RT

19 Completed 36-37 The Town GRANGE EN2 6LA

20 Completed 43-45 Church Street TOWN EN2 6AJ

21 Completed 8 Genotin Terrace GRANGE EN1 2AF

22 Completed 14 Ladysmith Road TOWN EN1 3AA

23 Completed 157 - 159 High Street SOUTHGATE N14 6BP

24 Completed Adrian Nicholas

Court, 41

Silver Street TOWN EN1 3TD

25 Completed Dumayne House, 1 Fox Lane WINCHMORE HILL N13 4AB


27 Completed 725 Green Lanes WINCHMORE HILL N21 3RX



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28 Completed 32 Little Park Gardens TOWN EN2 6PF

29 Completed South Point House,

321

Chase Road SOUTHGATE N14 6JT



32 Completed Everlast House, 1 Cranbrook Lane SOUTHGATE

GREEN

N11 1PF

33 Completed Cecil Court, 1 London Road GRANGE EN2 6DE

34 Completed 39 Church Street TOWN EN2 6AJ

35 Completed 46 London Road GRANGE EN2 6EF

36 Completed Newby House, 309 Chase Road SOUTHGATE N14 6JS

37 Completed 275 Green Lanes PALMERS GREEN N13 4XE

38 Completed Hobart House The Bourne SOUTHGATE N14 6RT

39 Completed Urban House, 43 Chase Side SOUTHGATE N14 5BP

40 Completed Winchester Court,

237

Green Lanes PALMERS GREEN N13 4UH


42 Completed 280-286 Southbury Road SOUTHBURY EN1 1TR

43 Completed Northside House Mount Pleasant COCKFOSTERS EN4 9EE



46 Completed 33 London Road GRANGE EN2 6DR

47 Completed Lawrence House, 5 River Front TOWN EN1 3SY

48 Started 55-57 Chase Side SOUTHGATE N14 5BU

49 Submitted Lincoln House Lincoln Road PONDERS END N18 3HF

50 Submitted 25 Hertford Road ENFIELD HIGHWAY EN3 5JD

51 Submitted 421 Hertford Road ENFIELD HIGHWAY EN3 5PT

52 Submitted 52 Alexandra Road PONDERS END EN3 7EH

53 Submitted 33 Burleigh Road SOUTHBURY EN1 1NY

54 Submitted

London Road GRANGE EN2 6JG

55 Submitted 2 Green Lanes BOWES N13 6JR

56 Submitted Solar House, 282 Chase Road SOUTHGATE N14 6NZ

57 Submitted 794 Green Lanes BUSH HILL PARK N21 2AW

58 Submitted 273 Green Lanes PALMERS GREEN N13 4XE



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59 Submitted 341 Ordnance Road ENFIELD LOCK EN3 6HE

60 Submitted Brickfield House,

284

Southbury Road SOUTHBURY EN1 1GG

61 Submitted Chase House, 305 Chase Road SOUTHGATE N14 6JS

62 Submitted 46 Church Street GRANGE EN2 6AZ

63 Submitted 10 Genotin Terrace GRANGE EN1 2AF

64 Submitted 55-57 Chase Side SOUTHGATE N14 5BU

65 Submitted 33 Stockingswater Lane ENFIELD HIGHWAY EN3 7JX

66 Submitted 283 Green Lanes PALMERS GREEN N13 4XS

67 Submitted 23-25 Aldermans Hill PALMERS GREEN N13 4YD

68 Submitted 2-6 Silver Street TOWN EN1 3EE

69 Submitted 7-7a Southbury Road SOUTHBURY EN1 1RT

70 Submitted 6 Gladbeck Way GRANGE EN2 7HT



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Appendix B : CIL calculations 344. Below is estimated the potential CIL revenue from all completed and pipeline PDR O2R conversions that

would have been gained were such schemes not exempt from CIL owing to their change of use nature. It

should be emphasised that there is no expectation for that exemption to be removed in future, and that the

existence or removal of PDR would have no effect in either case.

345. The approach taken is to treat all past and pipeline conversions as though they would have been subject to

CIL, even though Enfield’s Charging Schedule only came into effect in 2016. This increases the size of the

data sample, making any forward projections more robust.

346. Before the results of this exercise are discussed, it is worth briefly describing the steps in the calculation

and the assumptions that have been applied.

347. The starting point for the calculation is the Enfield Council Community Infrastructure Levy: Charging

Schedule, April 2019. This document divides the borough into four CIL rate charging zones (Meridian Water

receiving a nil rate, the eastern corridor a lower rate of £40 per sqm, Enfield Town and the area south of the

A406 and A110 an intermediate rate of £60 per sqm, and the remainder of the borough a higher rate of

£120 per sqm).179 It then provides the relevant extract of the Community Infrastructure Levy Regulations

2010, which explains how the chargeable amount is calculated.

348. In short, the rate for the zone in question (as above) is multiplied by the net chargeable area and then by

the index figure for the year in which permission was granted (this refers to the all-in tender price index

published by the Royal Institution of Chartered Surveyors (RICS)). The result is then divided by the index

figure for the year in which the charging schedule took effect.

349. Each completed and pipeline conversion scheme is therefore accorded a rate band according to the zone in

which it was located. Where a ward is bisected by two or more CIL rate zones, it is assumed that any

scheme within that ward is subject to the rate for the zone covering the largest part of that ward.

350. The net chargeable area is assumed to be equivalent to the existing floorspace area of the office unit in

question. Where no floorspace data is known, the number of residential units delivered or expected is

multiplied by the average floorspace per residential unit for schemes with known floorspace data (51.4

sqm).

351. The all-in tender price index figures for the year in which permission was granted is, in accordance with the

Charging Schedule, the figure for the 1st of November in the preceding year. This data is known for all

years from 2014 to 2019, so the 2014 figure is used for schemes given permission (or prior approval) in

2013.

352. The index figure for the year in which the charging schedule took effect is that for 1st November 2015.

Although this means that schemes given permission before April 2016 will be calculated using a future index

figure, it is considered the most appropriate and consistent reference point for schemes which would not in

reality have been charged CIL at all.

353. The result of the calculation is an estimated foregone CIL revenue of £3,068,469 for all completed and

pipeline schemes. This can be split into £2,083,281 for completed schemes and £985,188 for pipeline

schemes.

354. If all schemes for which permission was granted before 2016 (the introduction of CIL in Enfield) are

excluded, the potential revenue that would have been received if all completed conversions since CIL was

introduced were liable is £189,855, with an additional £968,606 due from pipeline conversions. The total is

£1,158,461.

355. Returning to the maximum figure of £2,083,281, this can be divided by the total estimated office floorspace

lost from completed and pipeline schemes of 35,803 sqm to give a rough estimate of the potential CIL

revenue that could be generated per sqm of office floorspace where conversions are CIL liable of £58.19.

179 AECOM is aware that the CIL charging rates and zones are currently in the process of being revised as part of the Whole Plan Viability Assessment supporting the emerging Local Plan and parallel CIL review.



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Appendix C : Detailed London A4D Case Studies

Camden

356. Camden contains concentrations of commerce inside and outside of the London Central Actives Zone

(CAZ), where PDR is exempt. Concentrations outside of the CAZ have faced pressure to convert office

floorspace to housing before the introduction of PDR due to the extremely high residential land values (up to

4.5 times the value of offices).180 Opposition to PDR has been building from the borough’s creative

industries and businesses, as well as difficulties the borough has faced in securing affordable housing.

357. The borough commissioned a report to examine the impact of PDR which found that in the 12 months since

the change to permitted development rights in 2013, Camden lost approximately 24,000 sqm of further

office space, equating to some 2,570 jobs.

358. In August 2015 an A4D came into effect, but following a change by DCLG, only clusters of commercial

buildings rather than the whole Borough were applicable. This left small and standalone offices vulnerable

to conversion.

359. In the Council’s cabinet reports on the proposed A4D, it was emphasised that it could cost £20,000 per

annum in officer time in processing the applications without payment and that preparing and consulting on

the Article 4 had cost nearly £35,000.181

360. Camden enters into S106 agreements on prior approvals if relevant to the limited issues they can take into

account. Usually these are non-financial, for example over restricting parking, but in one case there was a

payment for highways improvements. Camden Council adopted a CIL charging schedule in 2015, in

addition to the Mayoral CIL, which had applied since 2012.

361. The view from stakeholders is that PDR schemes are not redeveloping vacant office buildings but instead

fuelling the conversion of occupied offices. Some have voiced concerns over the increasing of rents due to

the limited supply of office space and low vacancy rates (estimated at 2.7% in April 2014) and the negative

impacts this will have on small and creative businesses.

362. There is anecdotal evidence from the Camden Business Improvement District that occupiers have been

approached by property owners to leave early for payment. Other stakeholders are concerned that the

housing being delivered is not affordable, of poor quality, or not suitable for the needs of the borough’s

residents. Frustration with PDR was also seen as being antithetical to the spirit of localism and public

engagement.

363. Of the 832 new units created through PDR conversions in Camden, 72% met national space standards but

just 1% had access to amenity space. 80% of the units were studios or 1 bedroom apartments, suggesting

some issues over residential quality and mix. For the 75 units being created through conversions governed

through full planning permission, 100% met national space standards and the majority had access to

amenity space. 44% of the units were studios or 1 bedroom apartments.

364. Financially, Camden is calculated to have lost £665,853 in planning application fees from all prior approvals

received over the first four years of PDR. There has been a potential loss of 333 affordable housing units

from the PDR schemes, and at least £9,012,825 lost from S106 contributions. Based on the low figure of

£4,600 per new dwelling for infrastructure costs, the additional cost to local services from the 832 PDR units

is £3.827m, and £7.783m for the 605 units under construction.

365. Overall, PDR has resulted in a considerable negative public and community impact in Camden. However,

the quality of the average conversion has generally been high.

180 B Clifford, J Ferm, N Livingstone and P Canelas: Assessing the Impacts of Extending Permitted Development Rights to Office-to-Residential Change of Use in England. Royal Institution of Chartered Surveyors, May 2018; https://www.rics.org/globalassets/ricswebsite/media/knowledge/research/research-reports/assessing-the-impacts-of-extending-permitted-development-rights-to-office-toresidential-change-of-use-in-england-rics.pdf. 181 Camden Council (2015a) Cabinet Report: Confirmation of Article 4 Directions for the Change of Use from Office To Residential (CENV/2015/13). Camden Council, Camden; Camden Council (2014) Cabinet Report: Article 4 Direction for the change of use from office to residential (CENV/2014/11). Croydon Council, Croydon.



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Croydon

366. Croydon has a high rate of office vacancy due to a large supply of outdated stock. As Croydon is deemed

an Opportunity Area, the GLA and Croydon Council worked together to produce an “Opportunity Area

Planning Framework” which proposes rejuvenating at least 25% of existing office stock through

conversions, refurbishment and redevelopment. The Framework calls on for this to be done in a way that

promotes good design quality. The Council’s Local Plan also calls for the refurbishment of office blocks into

residences to be taken with a flexible approach not to undermine the opportunity for economic growth.182

367. The Council’s approach to PDR has changed over time. At first, they were unsure if they could permit prior

approvals with conditions attached. They now do attach conditions to PDR and have also entered S016

agreements with developers over parking issues.

368. For the Croydon Opportunity Area, the Council has adopted an A4D. This came after spending time

monitoring the impacts of PDR from its first introduction, and producing reports183 to the cabinet and

planning committee184 voicing concerns about PDR undermining sustainable place-making and justifying

the A4D.185 The council made a non-immediate A4D on 5 September 2014.

369. In accordance with Article 5(4)(d) the Council sought representations during a 6-week period from 10

September 2014 to 22 October 2014. A schedule of the representations received and responses has been

compiled and is available to view. The Council's planning committee endorsed and confirmed the A4D on

the 6 November 2014. The confirmed Article 4 direction starting from 10 September 2015 required

owners/occupiers within the Croydon Opportunity Area to be made aware of the confirmed Direction by

letter and both site and public notices. The Secretary of State was also notified. In accordance with Article 5

paragraphs (9), (10), (13) and (18), the A4D came into force on 10 September 2015.

370. Stakeholders have acknowledged as positives that PDR has delivered much needed housing in the town

centre, the relative affordability smaller units and the reusing of older buildings. Quality concerns have

however been present, as some developments have been of such poor quality there were health and safety

issues. The size of units delivered has also come into question, as examples of studio flats which were 12

sqm are feared to be occupied by families who cannot afford more space. The majority of PDR schemes

approved in Croydon do not meet the floorspace requirements set out in the London Plan, and almost none

have provision for private or communal amenity space

371. The results of a small survey of residents of office-to-residential conversions are not representative, but are

at least indicative of residents’ experience. 60% of the residents who completed the survey rent their

apartment; 75% are 18-40 and 14% have children living with them; 80% are full-time employed, 9% are

students. The most common household size was 2 people, and most people intended to only live in their

apartments for a shorter-term period. The survey respondents generally valued location as the most

important factor in deciding where to live.

372. Using the low figure of £4,600 per unit, the 2,708 units completed or under construction at the time of the

study total £12.456m in additional local infrastructure costs. For all 3,300 units with prior approval in

Croydon the cost for is estimated at £15.18m.

373. Croydon Council looks for 50% affordable housing on schemes over 10 units. This means that schemes

with prior approval in Croydon should deliver 795 affordable housing units (477 affordable rent and 318

intermediate rent). Looking at recent planning application cases, this would have been unlikely to have

completely survived viability testing, but it is believed that 30% might have been achieved overall, or 477

units. Finally, had all the prior approvals been full planning applications, the fee income to the Council would

have been £1,701,810 higher.

Old Oak and Park Royal Development Corporation (OPDC)

374. A successful A4D by OPDC was confirmed in September 2017, requiring planning permission for changes

of use from offices, storage and distribution uses to residential. OPDC is the Local Planning Authority for

one of the UK’s largest regeneration projects, developing a new centre and community for west London.

182 Croydon Council (2013) Croydon Local Plan: Strategic Policies. Croydon Council, Croydon. 183 Croydon Council (2014b) Office to Residential conversions in the Croydon Opportunity Area (COA): Cabinet Report. Croydon Council, Croydon. 184 Croydon Council (2014c) Planning Committee Report. At: https://www. croydon.gov.uk/sites/default/files/articles/planning-committee-report.pdf (last accessed 20/10/2017) 185 Remøy H., and Street E. (2017) ‘The Dynamics of “post-Crisis” Spatial Planning: A Comparative Study of Office Conversion Policies in England and The Netherlands’. Land Use Policy, In Press.



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375. In September 2016, OPDC made an A4D without immediate effect to remove PDR for changes of use from

offices (use class B1) and storage and distribution uses (use class B8) to residential (use class C3), in the

Old Oak and Park Royal Strategic Industrial Location. Consultation on the A4D took place in September and

October 2016. OPDC Board decided to confirm the A4D on 12 September 2017 and it came into effect on

22 September 2017. From this date, changes of use from offices and storage and distribution uses to

residential in the affected area require planning permission.186

376. The A4D applies within the area designated as a Strategic Industrial Location in OPDC’s boundary. It is

designed to give OPDC more control over inappropriate changes of use that could compromise Park

Royal’s role as an important industrial area and undermine the comprehensive regeneration of Old Oak.

Richmond upon Thames

377. Richmond-upon-Thames has received the highest number of prior approval applications of any London

borough, with 360 applications having been received by March 2015. The borough estimates a loss of

around 20% of the office space in its area through the policy, the equivalent of around 57,000 sqm of office

space to be converted to 693 residential units. It is estimated that these conversions will displace around

3,150 local jobs.

378. PDR has also made it more difficult for the local voluntary sector to secure suitable accommodation in the

area, as the borough estimates the policy has reduced opportunities for business development, particularly

for small IT firms which the borough has been seeking to promote. One such company was required to

place its office equipment into storage and to make three members of staff redundant while it sought new

accommodation, owing to the landlord’s desire to convert its long-standing premises into one-bedroom flats.

379. A significant proportion of the prior approval applications received are for office spaces of 1,000 and 2,500

sqm, for conversion to residential schemes of between 10 and 25 dwellings, which overlap with the spaces

the borough had been using to promote itself as a location for smaller firms in the IT sector. Now having

been significantly diminished by O2R conversions, this has had countervailing impacts on rents (which have

increased as accommodation has become scarcer) and on the viability of the office market as small

businesses begin to look elsewhere for more widespread and affordable accommodation.187

186 https://www.london.gov.uk/about-us/organisations-we-work/old-oak-and-park-royal-development-corporation-opdc/planning-old-o-12. 187 London Councils (2015). The impact of permitted development rights for office to residential conversions. London Councils, London.

pdr conversions research study · 2020. 8. 27. · final report – pdr conversions research study...

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