Written evidence submitted by Reading Borough Council [PDR 022]
This response on behalf of Reading Borough Council (RBC), based on its significant experience of permitted development rights (PDR) within its own area, raises the following concerns about the current use of PDR:
This response suggests that many of the new PDR introduced since 2012 should be removed and replaced by consideration through a full planning application process.
1.1 This response is made on behalf of Reading Borough Council. Reading is a unitary authority covering a primarily urban area with a population of around 162,000. Reading has a fast-moving economy with particular strengths in business services, ICT and pharmaceuticals, but also a strong industrial heritage and an increasing role in logistics. In general terms, Reading has a highly qualified population, but there are also significant numbers who have few or no qualifications. The overall affluence of the area masks some concentrated areas of deprivation.
1.2 There is a significant need for new housing in the local area, in particular affordable housing. Local housing need calculations that informed our Local Plan indicate that the overall need for housing is 699 per annum, but that affordable housing need is 406 per annum, over 60% of the total need.
1.3 There has been significant uptake of the permitted development rights for changes of use to residential in particular in Reading. Between 2013 and 2020, we have seen 1,040 homes being delivered through the permitted development route and loss of almost 54,000 sq m of commercial floorspace. Table 1 breaks this down between the different forms of permitted development. As such, Reading Borough Council is well-placed to understand the way in which PDR have been rolled out across our area.
Table 1: Dwellings completed and floorspace lost as a result of PDR in Reading, 2013-2020
Office prior approval
Retail prior approval
Light industrial prior approval
Storage and distribution prior approval
Floorspace lost (sq m)
1.4 RBC strongly objected to the initial proposals to introduce office to residential permitted development rights in 2011. RBC also applied to be one of the authorities to benefit from an exemption from the new permitted development rights in 2013, but was not successful. We have subsequently raised concerns through the consultation process on every occasion that the government has sought to expand these permitted development rights. RBC was also involved with a report on office to residential PDR prepared on behalf of RICS that took Reading as a case study, so is well-placed to understand the quality of accommodation that has been delivered within our area.
2.1 PDR should continue to play a role in the planning system, but should be used to continue to allow small-scale development such as for some householder developments and for matters such as allowing infrastructure providers such as statutory undertakers to carry out their work within reasonable parameters. This was approximately the approach taken to PDR prior to 2012.
2.2 PDR should be tested against a basic principle that the developments permitted should be unlikely to cause harm that may outweigh its benefits. This should be rigorously tested by the government when PDR is proposed.
2.3 PDR should not be used by the government to achieve policy ambitions such as boosting housing delivery. If this is considered necessary, this should instead be addressed by changes to national planning policy that place particular weight on the benefits of a certain form of development, which nonetheless allows for the merits of a particular proposal to be considered through the planning application process.
3.1 Reading was one of seven case study authorities which were examined as part of ‘Assessing the impacts of extending permitted development rights to office-to-residential change of use in England’, a study conducted on behalf of RICS which reported in May 2018. Among its conclusions for Reading were that there had been a “marked loss of planning gain, particularly for affordable housing” (p79). The report also noted concerns about “whether they are really directly servicing the housing needs of the local population. Some schemes are now explicitly providing student housing, and others are heavily pushed towards the investor and PRS markets” (p79).
3.2 In terms of the quality of accommodation provided, the authors of the report were able to access a number of buildings in the town. Their conclusions were that none of the units appeared to meet national space standards, and some units had no natural light in the bedroom, with light instead being provided through interior windows. Over 60% of the units the report looked at had no outdoor private or communal amenity space. The overall recommendations of the report were that these forms of development should be brought back within full planning control, but, failing that, that additional safeguards should be added to the prior approval process, fees should be increased, and development creating new dwellings should contribute to the Community Infrastructure Levy (CIL) regardless of previous vacancy.
3.3 In terms of quality and quantity of housing provided, our evidence below covers the following issues:
3.4 Since the PDR for office to residential was introduced in 2013, a total of 1,040 new homes have been delivered through all forms of PDR in Reading. This represents almost a quarter (22.6%) of all completed dwellings in Reading. Therefore, on the face of it, it might appear that PDR has made a major contribution to new housing supply.
3.5 However, it is not necessarily as straightforward as that. Conversions or redevelopment of redundant offices or other commercial space to dwellings had been taking place in Reading for many years prior to the introduction of PDR, so there can be no certainty that many of these offices may not have come forward for residential in any case through the planning application route. Equally, developers may have been focused on relatively easy wins through office conversions with no requirement for developer contributions rather than bringing forward other sites, particularly given that the temporary nature of the office to residential PDR when originally introduced may have incentivised this.
3.6 In the ten years before the office to residential PDR was introduced in Reading (2003-203), on average 665 new dwellings were delivered each year from all sources. In the seven years since its introduction (2013-2020), on average 656 new dwellings were delivered each year, a very similar figure. Whilst this latter figure may have been lower without PDR, it is not possible to know this for certain, and it does therefore cast some doubt as to whether PDR has actually boosted overall housing supply, in Reading at least.
3.7 As was noted in the RICS report, homes delivered by the PDR route in Reading generally do not meet the nationally described space standards. Some units fall considerably below, with dwelling sizes for 1-bed flats of 16-20 sq m not uncommon compared to 37 sq m as the minimum for a one person one storey dwelling in the space standards. We do not provide any further points on that issue, as we are aware that national changes to PDR mean that compliance with space standards is now necessary, other than to point out that this safeguard can easily be removed by government at any point, in the same way it was introduced. However, it is worth noting that it demonstrates that poorly thought-out PDR can leave a legacy of poor-quality homes.
3.8 Homes delivered under PDR are also overwhelmingly small in terms of the number of rooms. Of the homes delivered in Reading between 2013 and 2020, 83% are either studio or 1-bed dwellings, with almost all of the remainder being 2-bed. This compares unfavourably with the needs identified for Reading in the Berkshire Strategic Housing Market Assessment (SHMA), where 58.5% of the market homes needed in Reading up to 2036 are for three-bed or more, with the need for 1-bed market home being only 10.3%. Due to the types of site available, generally brownfield and high density, delivery of family housing in Reading is already difficult, but this is significantly exacerbated by the dominance of small units in PDR development.
Figure 1: Size of dwellings delivered under PDR in Reading 2013-2020
3.9 Reading has a very significant need for affordable housing. According to our SHMA, of an overall need for 699 homes per year in Reading, 406 of these (almost 60%) need to be affordable. Whilst the Council has its own Local Authority New Build (LANB) programme which is already delivering new affordable homes, to even fulfil a meaningful proportion of that identified need requires significant delivery through contributions made by private developments. The LANB programme is also partly funded through off-site developer contributions.
3.10 However, PDR has meant that one of the major sources of new homes, conversions of existing buildings, does not make any contribution to meeting this need, because there is no ability to secure this through a legal agreement. This means that affordable housing provision has to be secured from a shrinking proportion of the overall housing delivery. In the seven years before office to residential PDR were introduced (2006-2013), 8.6% dwellings completed in Reading were from an application route where a legal agreement cannot be applied (usually certificates of lawfulness). In the seven years afterwards (2013-2020), 24.7% of dwellings completed were from a source where a legal agreement cannot be applied. Whilst the PDR therefore does not necessarily appear to have boosted overall delivery (as seen previously in this section), it certainly has reduced the proportion of delivery that can contribute to affordable housing.
3.11 There are challenges in estimating what the affordable housing contributions would have been had these proposals been subject to Section 106, as they are subject to negotiation that are heavily influenced by assessments of viability that would have to take account of relatively high existing use values for the former office premises. However, based on local policy, we consider that, had the schemes that have received prior approval since 2013 instead of planning permission been subject to full policy compliant Section 106 agreements, they might have been expected to lead to the following levels of affordable housing contributions:
3.12 The effects in terms of overall affordable housing delivery can be seen in Figure 2, which shows an overall decrease in affordable housing delivery over the last decade, albeit with some fluctuation. PDR is not wholly to blame for this decrease, with issues such as developers able to exploit previous national policy on viability also playing a role, but PDR must represent part of the background as it reduces the overall proportion of developments that can make contribution.
Figure 2 – Annual affordable housing completions in Reading 2010-2020
3.13 In terms of location, the main concerns are around proposals which would introduce residents to locations which are subject to noise, disturbance, pollution or poor air quality.
3.14 When the office to residential PDR was originally introduced, in Reading it was mostly implemented in secondary office locations around the fringe of the town centre such as Kings Road and London Street. These were the types of locations where the Council had previously permitted conversions to residential by the planning permission route, so were potentially suitable for residential. However, an important distinction, particularly since conversions tend to be on busy roads, is that, unlike planning permission, PDR does not offer a means of mitigating the effects on residents of noise and poor air quality related to traffic.
3.15 More recently, office to residential PDR has increasingly spread to the commercial core of the centre and to outlying employment areas, which gives greater grounds for concern. Parts of the commercial core have a significant night-time economy, and residents could be subject to noise and disturbance at unsociable hours as a result. Of greatest concern perhaps, however, is the introduction of residents into our employment areas, which are wholly unsuitable as a place to live.
3.16 It is worth illustrating that point with a real world example. Prior approval was granted in June 2018 for the change of use of 14 Arkwright Road, Reading from office to 37 dwellings (reference 180654). This has not yet been implemented. This building, currently known as The Quad, and formerly the Duran Centre, was constructed in 2000 and forms part of a defined Core Employment Area (‘North of Basingstoke Road’) under policy EM2 of the Reading Borough Local Plan.
3.17 Figure 3 shows the location of the site. It sits at the end of an entirely commercial cul-de-sac and is surrounded on all sides by commercial uses. These uses comprise the types of uses that one would expect to find in a mixed commercial location such as this – factories, trade counters, vehicle workshops and warehouses. All of these uses will generate some level of noise and disturbance to residents, potentially at unsociable hours, and this may well be an essential part of their operation. Some of these uses are in very close proximity. The rear wall of the PDR building, which comtains what would become residential windows, is only 6-7 metres away from the nearest industrial unit in Hyperion Way. Due to level changes, the surface car parking and surfacing uses for Hyperion Way and the Toyota site to the south are raised and are directly adjacent to first floor windows of the PDR building. As is often the case with this type of mixed employment location, there is very little vegetation within the locality to help soften the impacts of the surroundings. There are two trees at the entrance to the PDR site and some other very small areas of planting, but otherwise the surroundings are entirely buildings or hard surfacing. All of this makes the site an entirely inappropriate place to live, that would not be considered appropriate for residential through a normal planning application route.
Figure 3: Location of PDR approval at 14 Arkwright Road
3.18 As identified in the report for RICS, of the units that the authors visited in Reading, over 60% had no private or communal outdoor amenity space. In our experience of the operation of PDR, dwellings are rarely served by outdoor amenity space, even in the form of balconies, and where they are it is only because that space already existed to serve the office occupiers and not because it has been provided in addition by the developer.
3.19 Our Local Plan expects that, even within the town centre, new dwellings should be provided with functional private or communal outdoor space. This is in recognition of the important contribution such space makes to a good quality of life. This has been underlined throughout the Covid-19 pandemic where many households have been confined to their private spaces. Outdoor space is even more essential where, as is the case for many developments that came from PDR, indoor space is insufficient. It is also necessary where access to public recreational open space is limited, as is particularly the case in parts of the town centre and outlying business areas where PDR tend to be located.
4.1 The most immediate, measurable impacts on these matters is through income to local authorities from planning application fees, business rates or Council tax and infrastructure contributions through Section 106 agreements. RBC regularly reports to Councillors on implications from planning fees and Section 106 as a result of office to residential prior approval, and can therefore readily share this information, but does not have any information immediately to hand on the differences between business rates and Council tax income.
4.2 In terms of planning application fees, had those proposals submitted as office to residential prior approvals between 1st April 2013 and 31st March 2021 been instead submitted as planning applications, the additional fee income received over that timescale would have been £1,532,648. It is of course likely that many proposals would not have come forward at all without PDR, particularly those which are applied for in order to establish a value for the site and never actually implemented, so this is a purely theoretical figure, but office to residential conversions have long taken place in Reading before the introduction of PDR, so the Council has certainly lost out on significant planning fee income.
4.3 Fees for prior approvals for conversions to residential are due to increase, to £100 per dwelling. This is welcome, but it is still insufficient to cover the cost to authorities of considering these applications, particularly where there is a long list of conditions that mirror some of those that would need to be considered for a planning application, including matters such as noise and contamination where specialist input will be needed.
4.4 In terms of developer contributions, undoubtedly the biggest loss has been affordable housing. The estimated loss of 586 affordable housing units and £3,639,000 towards off-site affordable housing has been noted in section 3 of this response.
4.5 In terms of developer contributions towards other forms of infrastructure such as transport, education and open space, in Reading these have mainly been covered by CIL since 2015, and therefore development proposed under PDR is subject to the same charges as development subject to planning permission. However, had the schemes approved before April 2015 that have received Prior Approval instead of planning permission been subject to full policy compliant Section 106 agreements, they might have been expected to lead to the following levels of contributions:
4.6 It should also be noted that, even after the introduction of CIL, some office to residential proposals might have been expected to make an additional site-specific contribution to open space in particular by Section 106 had they come in as a planning application, particularly if, as was usually the case, there was no on-site private amenity space.
4.7 To summarise, the potential Section 106 contributions, including affordable housing, lost since 2013 total £5.8 million, in addition to the 586 affordable housing units.
4.8 We note that the Planning White Paper includes proposals for infrastructure funding which might mean that some developments under PDR are required to make contributions to affordable housing through a consolidated infrastructure levy. This is yet to be fleshed out, and we do not wish to detail our concerns about these proposals here, but in summary we do not believe that the White Paper proposals for infrastructure funding are appropriate or will lead to an overall increase in the infrastructure funds available, and will not therefore mitigate our concerns set out in this evidence.
Loss of services
4.9 It is worth considering the loss of services more widely, in particular where loss of commercial space to residential results in the loss of essential retail or community services. Until recently, there have been some safeguards within the PDR themselves that have meant that this PDR can have relatively limited impacts. For changes from A1 retail or A2 financial and professional to retail, a size limit of 150 sq m applied, and proposals were subject to a prior approval process that involved consideration of the level of provision of those services locally and on the wider sustainability of the shopping area. Those considerations are missing from the new replacement PDR for changes from use class E to residential (other than some limited consideration within conservation areas and for medical services and nurseries), whilst the size limit increases tenfold to 1,500 sq m.
4.10 This means that there is very significant potential to undermine the very existence of many of our smaller centres and shopping parades, where almost all shops and services will be below the threshold and there will be no consideration of wider impacts. These centres survive because they form a convenient location where a single trip can fulfil many functions. Allowing some of these uses to be lost, particularly in the most important frontages, can have a domino effect that can undermine the vitality and viability of the entire centre. These centres are often the core of their communities, and are particularly important for those without access to a car and to people with limited mobility.
5.1 The approach to PDR is not consistent with the vision of the Planning White Paper.
5.2 Part of the reason for this is that the Planning White Paper is in itself inconsistent. Aims such as achieving ‘beautiful’ development and more meaningful community engagement at an early stage will not be secured by the deregulatory approach set out in the White Paper.
5.3 Within the vision section of the White Paper, the government lists some specific statements about what it wishes to achieve. Many of these cannot be reconciled with the way that permitted development continues to be operated, and this includes the following quoted parts of this section:
We explore the ways in which permitted development causes real harm elsewhere in this evidence, but it includes the quality of accommodation provided and the impacts on existing uses. Much permitted development therefore fails even the ‘no net harm’ test, and the notion that it would pass a ‘net gain’ test is fanciful, unless ‘net gain’ is simply interpreted as meaning achieving as many dwellings as possible, in whatever way necessary.
The introduction of permitted development rights frequently undermines local plan policies for an area that have sound local justification and have been tested through and supported during community involvement. An obvious example is policies which seek to retain employment land in employment use. RBC’s own Local Plan defines Core Employment Areas, based on a rigorous analysis of which areas are essential to the local economy and have genuine prospects of continued employment use through the plan period. Permitted development rights have ridden roughshod over these policies by opening them up to residential uses. Another example is policies that seek to retain essential local facilities in small centres to ensure that they are accessible for all, but the most recent set of new permitted development rights could lead to their wholesale loss. Communities therefore lose an input into decision making at both plan making and application stages.
It would be difficult for anyone reading through the General Permitted Development Order, which continues to be expanded, to come to the conclusion that information on how the planning system works is easy to find and understand. Each permitted development right is accompanied by a long list of criteria and exclusions, and many now have a prior approval route which requires many of the same considerations that would have been necessary through a planning application. It is very difficult for professional planners to keep up with, let alone members of the public who do not regularly engage with the system.
A great deal of permitted development comes forward without any private outdoor amenity space at all. There is currently no mitigation of impacts in local infrastructure through the Section 106 route, and only through the CIL route if vacancy criteria are fulfilled, which is virtually never the case in our area, so this means that no contribution is made to new or improved parks and open spaces, or to any other forms of infrastructure. No contribution is made to affordable housing, so dwellings will not be ‘affordable’ in the planning sense, and are only ‘affordable’ in a more general sense by virtue of the fact that they often offer much poorer quality accommodation than what is available elsewhere. Finally, because developments are not subject to local planning policies, they do not have to fulfil local sustainability and energy efficiency requirements, and may well be far from ‘green’.
We explore the impacts on business and economic growth in other sections, but the effect of PDR has been to directly and significantly reduce available commercial space. This space is often the cheaper space needed by small and growing businesses. In addition, the introduction of residents into areas which are otherwise entirely commercial in nature can impact on existing businesses by restricting their ability to continue or intensify activities that can cause noise and disturbance but which are nonetheless an important part of the local economy.
Dwellings delivered by PDR overwhelmingly offer small flatted units, as previously demonstrated. This will only be exacerbated by the continued roll-out of further PDR.
Expanded PDR makes it more difficult to protect features important for biodiversity that already exist on site. For instance, the recent PDR for expansion of the footprint of sites for public service, which could include schools, colleges and universities, could mean loss of significant trees or undeveloped areas that often exist on these sites, without any consideration through the planning process.
5.4 These contradictions within the government’s approach become even clearer as the detail starts to emerge. The first element of the White Paper to be rolled out is the proposal for design codes, which was recently subject to consultation, and there are examples within the National Model Design Code that suggest that the government is not aware of the implications of its own approach.
5.5 For instance, paragraph 52 vii of the draft National Model Design Code ensures that the height of buildings will be a key element of design codes. However, permitted development rights have been introduced for upward extensions of homes and blocks of flats that mean that the control that local authorities can exercise over height has been weakened.
5.6 As a further example, paragraph 55 iii recognises the importance of active frontages, i.e. ground floor uses that create activity and interest, and that requirements for these may be higher in town and local centres. However, at the same time, the most recent PDR for changes from use class E to residential would allow such vital active uses to change to residential without requiring planning permission, and proposed changes to the National Planning Policy Framework would make it more difficult to put in place Article 4 directions to control these changes. This important element of designing high-quality and sustainable places is therefore being removed from local control.
6.1 The way that PDR have been, and continue to be, introduced significantly restricts the ability of local authorities to plan development and shape local communities.
6.2 For example, the Reading Borough Local Plan was adopted in November 2019, so is less than 18 months old. This went through several iterations of community involvement, and was examined in public and found to be sound and legally compliant. However, the government has introduced PDR that already means that some of those policies cannot be applied in full. This includes policies protecting employment land (policy EM3), retaining key uses within high streets (RL3, RL6 and CR7) and ensuring that the impacts of expansion of uses such as the university are considered (OU1).
6.3 It is worth considering the latter in more detail, since the effects of PDR conversions to residential are explored elsewhere in this response. The background is that there is already significant competition for land between general residential (including affordable housing) and speculative student accommodation in Reading, particularly in the town centre, and this could be exacerbated by the significant expansion ambitions of the University of Reading (UoR). RBC wishes to support the UoR, a key contributor to the town’s success, but wants to also ensure that growth of the university is supported by adequate provision of student accommodation, preferably on site to prevent displacing other residential provision elsewhere. This is set out in policy OU1, and this matter was subject to much discussion at the Local Plan examination and eventually this approach was endorsed by the Inspector. However, PDR has recently been introduced that would allow expansion of up to 25% of the university’s footprint, which could not only mean a considerable expansion of academic facilities without supporting student accommodation, but could also reduce the on-site opportunities for providing that accommodation through loss of the developable sites. This could have very serious implications for the town as a whole.
6.4 The above are only examples of how PDR restricts the ability to plan and shape communities. It is likely that further implications will become clear as the various forms of PDR are taken up in larger numbers.
7.1 The more traditional use of PDR, which includes allowing businesses to expand on site within certain size limits and other parameters, can indeed support those businesses. The more recent uses of PDR can also benefit a few businesses, most notably those developers that have taken up the PDR. However, in more general terms it is hard to argue that PDR now supports business and economic growth overall.
7.2 As set out in section 1, Reading has lost almost 54,000 sq m of commercial floorspace since 2013 under PDR. Whilst, when the PDR for office to residential was initially introduced the communications focused on vacant or surplus office, the reality is that much of this floorspace was occupied. CIL is not payable where a building was at least partly occupied for six months of the last three years, and in Reading virtually all office to residential PDR proposals have managed to demonstrate sufficient recent occupancy to avoid paying CIL, meaning that almost none of the buildings converted have been wholly long-term vacancies. This loss of floorspace most affects those businesses in need of cheaper, lower grade floorspace, which can include small and growing businesses.
7.3 It is worth referring once again to the example of 14 Arkwright Road, granted prior approval in 2018, and highlighted in section 3. As previously noted, this is part of a defined Core Employment Area in the Reading Borough Local Plan, within which land is generally protected for employment use. This proposal would result in the loss of 1,900 sq m of office space, built in 2000, which still has some occupiers, in an entirely commercial location.
7.4 RBC took this policy stance after carrying out an Employment Area Analysis, which considered all of our existing employment areas in terms of whether they needed to be protected or could be brought forward for other uses. This location was considered important for a continued employment role and inappropriate for alternative uses. A number of other sites were considered to have potential for residential use, and these have been actively brought forward in a planned manner through the Local Plan, as is appropriate.
7.5 Loss of this site reduces the amount of modern office floorspace available within mixed commercial areas, with most modern office floorspace in Reading being located either in the town centre or out of centre business parks, without any analysis necessary of the degree to which this floorspace is required for local businesses.
7.6 However, the impacts on businesses are not necessarily restricted to existing or potential occupiers of the site itself. As previously illustrated, the site is surrounded on all sides by industrial or warehouse uses, the operations of which are in very close proximity to the building and potential residents within it. The occupiers of these buildings should be able to use their premises to operate their businesses without the potential for complaints about noise and disturbance from residents that should never have been there in the first place. In addition, those occupiers should potentially be able to extend or intensify their operations on their premises, subject to other planning considerations, but, should the prior approval be implemented, any planning application will now need to be considered in terms of the impact on those residents. This is therefore likely to restrict the operations of local businesses, and limit their contribution to economic growth.
8.1 The impact of PDR on local community involvement can only be to reduce opportunities for the community to engage. Opportunities are effectively lost in three ways.
8.2 Firstly, the community is engaged in setting policies through the Local Plan that define appropriate residential locations, set development management policies on the quality of that residential accommodation, including matters such as environmental standards, and protect key uses in important employment areas or high streets. The government frequently introduces PDR which makes it difficult or impossible to apply those policies, meaning that the quality and form of development cannot meet the expectations that the community helped to set. As previously stated, this has already happened within 18 months of the adoption of the Reading Borough Local Plan.
8.3 Secondly, the opportunities for community engagement at application stage are much reduced or eliminated through the prior approval process, and this can apply to developments which would in some cases deliver over 100 homes, or thousands of additional square metres of floorspace. The community should be able to comment on the merits of such proposals.
8.4 Finally, the sheer complexity of the system that has emerged may well serve to deter engagement in the planning system. The list of matters that are considered permitted development has expanded significantly, subject to many conditions and caveats, and many now require an application process through the prior approval route through which only a limited number of matters can be considered. The complexity of the resulting system and the frequency of changes is something which professional planners find very difficult to remain abreast of, and which is even more confusing to those who do not regularly engage in the planning system.
9.1 RBC considers that reforms to PDR are urgently required. The government should return to the way PDR was used prior to 2012, which is to allow small scale development, development which is unlikely to have significant impacts, or for certain types of important infrastructure or operations.
9.2 This would involve removing a number of types of PDR and ensuring that these are covered instead by a full planning application process. This includes, but is not limited to:
9.3 RBC considers that, in particular, a development that results in a new dwelling should always be subject to the need to apply for planning permission.
9.4 If the government wishes to achieve specific policy objectives with regard to those forms of development, this should be dealt with through changes to national policy.
9.5 RBC recognises that the government have sought to apply conditions to the PDR which mean that some matters can be considered through the prior approval process. These only cover some of the matters identified in this response, and where a matter is covered it is often partial. For instance, the process allows consideration of the impact of loss of medical facilities or nurseries on the provision of local services, but not any other forms of commercial use such as essential shops. On-site expansion of public service uses need to take account of heritage and archaeology, but not biodiversity. Change of use of commercial to residential now needs the building to have been vacant, but only for three months, which not likely to put off a landowner who wishes to convert a building that could otherwise be occupied for commercial.
9.6 However, even if the conditions for prior approval were to cover all matters of concern, the overall approach of addressing this through prior approval is misguided. These matters need to be covered by a full planning permission process. A planning application carries a full public consultation, without limiting the planning matters that can be raised. It is accompanied by a fee that can cover the resources needed to determine the application, not only by the Planning section, but also by essential consultees dealing with matters such as noise, transport impacts and the natural environment, many of which remain necessary as a result of the conditions attached to PDR. And finally, it allows for the impacts of the development on local infrastructure to be mitigated, and for affordable housing to be provided, through a Section 106 agreement.
9.7 In the longer term, if England is to move towards a zoning-based system as envisaged under the Planning White Paper, the need for PDR should be considered afresh, as it is likely to cover many of the types of development that zoning might allow for, thus resulting in substantial duplication of regimes.
 ‘Assessing the impacts of extending permitted development rights to office-to-residential change of use in England
 See Table 107 of the Berkshire (including South Bucks) SHMA
 National Model Design Code