Below is the TD & WG Residents' Association response, opposing the Housing Consultation proposal which would allow developers a free hand to convert High Street shops and offices to housing.  It was also copied to our MP, Dominic Raab.

Subject:   Supporting housing delivery and public service infrastructure
Date:   26/01/2021, 14:58
To:   PublicServiceInfrastructure&PermittedDevelopmentConsultation@communities.gov.uk

I write as Chairman of the Thames Dltton & Weston Green Residents' Association which has a paid-up membership of 1200 households representing over 2,400 residents.  Founded in 1934 our Association is a non-party-political organisation with 4 councillors on Elmbridge Council and a Surrey County Councillor. We have worked with, and participated with both Surrey and Elmbridge councils in the past 40 years in drawing up strategic and local plans, based on national and local planning policies.

Planning proposals are an attack on local democracy

It is clear that a key aspect of the proposed new system would remove the rights of residents and local councils to have a say on developments, eg. the change of use of High Street shops to residential, effectively greatly reducing democratic input in the planning process. At present elected councillors draw up local plans that are debated in public and then managed by  the local council. Council meetings are open and transparent and councillors are elected and accountable to residents who feel ownership of local plans.  The local council is also responsible for compliance/enforcement of local plan policies.

The Consultation Paper’s proposals for  new permitted development rights for change of use from Commercial, Business and Service use class to residential without planning permission, with no further involvement from the local community or council, removes the rights of the local people who pay their council tax for planning services.

Permitted development Class E to residential (C3)

We question claims that these proposals will breathe new life into high streets and town centres.  It will simply enable change of use to more profitable uses, ie. residential.  For over 30 years we have fought to retain shops in Thames Ditton High Street from change to residential in order to retain the vitality and viability of the local centre in accordance with Local Plan and NPPF policies.

Taking away planning powers from local councils and communities will deprive them of the ability to define the area they live in and risks giving developers the ability to ride roughshod over local areas.

Extending Permitted Development Rights to Conservation Areas

We oppose the proposed change to allow properties within conservation areas, falling under Class E to change use to housing without the need for planning permission or consultation with the  local Conservation Area Advisory Committees.  Many of these buildings, often located within historic high streets, town and city centres, contribute to the character of some of our most treasured and locally loved historic areas. Conservation areas have been designated locally because they are "areas of special architectural or historic interest, the character and appearance of which it is desirable to preserve or enhance “   (s69 Planning (Listed Buildings and Conservation Areas) Act 1990).

The danger with deregulation is that it will lead to unscrupulous developers / landowners exploiting loopholes, as has been seen with previous widening of Permitted Development Rights, which the Government's own commissioned report concluded that permitted development rights create "worse quality residential environments".  A limited list of prior approval matters may not necessarily secure a high quality residential environment or vibrant, diverse and planned centres.

Conclusion

These proposals would threaten the vitality and viability of local High Streets and centres including village conservation areas. We urge in the strongest terms that the Government abandons the present proposals, which are an attack on local democracy and instead, supports local decision making by local councils.

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Graham Cooke
Chair, Thames Ditton & Weston Green Residents' Association