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BetterHomesEnfield logo2A campaign group called BetterHomes Enfield has launched an online petition calling on Enfield Council to follow the example of many other London boroughs and take steps to prevent developers using a planning loophole called "permitted rights" to convert office blocks into "human warehouses" - turning former offices into flats which are not fit for purpose. They are often far too small, have rooms without windows, are poorly ventilated and don't meet environmental standards. Developers are also able to avoid making contributions towards affordable homes and community payments.


Refuge House, Enfield Town, is being converted into 52 flats (Photo: Google)

Another issue highlighted by BetterHomes Enfield is that in some cases the converted office blocks are still occupied by businesses, which are forced to move, often out of the borough. For example, they estimate that the conversion of Refuge House in Enfield Town into 52 "studio flats" involves the displacement of between 80 and 100 jobs.

The campaigners say that there is an "easy solution": Enfield should issue an "Article 4" directive, as used by most other London boroughs, to block this type of permitted development.

Writing in Enfield Dispatch, Al Sims from BetterHomes concludes:

By signing our petition, you’ll be helping to reduce misery, increase affordable housing, save jobs, improve the borough’s finances and help the environment. It’s not often that a single petition can have so many positive outcomes for our borough!

Petition text

We the undersigned petition the Council to enact an Article 4 Directive to remove permitted development rights for office to residential conversions across the borough.

Please sign our petition to stop “human warehouses” being developed in Enfield.

We are a group of Enfield residents who are concerned about the large quantity of poor quality homes being developed in our borough under a planning loophole (called permitted development rights). This impacts all of us, please read why.

The problems with the loophole are that:

  • Property developers can change offices into residential units without any planning permission.
  • Property developers can create very cramped and overcrowded homes that are significantly smaller than the minimum usually allowed.
  • Enfield is losing a lot of money as property developers can avoid paying their share of infrastructure contributions.
  • Enfield is losing affordable homes as property developers can avoided contributions towards affordable homes in the borough.
  • Neither Enfield Council nor residents have any control over these office conversions.
  • Enfield residents are picking up the costs for this!

We have discovered residential units that are very small, overcrowded, have no outdoor space and do not meet basic environmental standards. Some studio flats are as small as a car parking space (9 square metres) and many are the size of a budget hotel room.
Some flats are being created with no external windows. There has been a lot of coverage in the press calling these developments the “slums of the future” and “human warehouses”. Major housing charities (e.g. Shelter and Crisis) are against permitted development rights.

This affects everyone in Enfield, not just those living in or near these developments, as property developers are able to avoid paying their share of infrastructure contributions. Based on the information provided to us from the council, we estimate that the council has lost at least £1.2 million pounds over the last few years. These are funds that are desperately needed for our borough and if developers don’t pay them then Enfield’s residents will need to make up the short fall.

Furthermore, developers avoid contributing towards affordable homes in the borough. We estimate that Enfield has lost around 200 affordable homes as a result of the loopholes these permitted development rights have created.

There is a solution. If the council put an Article 4 Directive in place, it would close the loophole and force property developers go through normal planning processes (instead of bypassing them). That means that residential units would need to be of a decent size, have proper windows and meet environmental standards. Furthermore, property developers would need to pay their fair share. An Article 4 Directive does not stop homes from being built, it simply makes sure that they are of a decent quality.

Nearly all the councils in London have put an Article 4 Directive in place EXCEPT ENFIELD!

Please sign our petition and follow us on Twitter BetterHomesEnfield @BetterEnfield

This Petition runs from 21/07/2019 to 10/09/2019


Petition on Enfield Council website

BetterEnfieldHomes on Twitter

BetterHomesEnfield on Facebook

We need better homes (Enfield Dispatch August 2019)

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PGC Webmaster's Avatar
PGC Webmaster posted a reply #4865 06 Nov 2019 20:19

A message from Matt Burn of Better Homes Enfield

I wanted to let you know that a new permitted development application has been submitted for Refuge House in Enfield Town, this time to convert the office into 76 studio units.

Almost all the units are more than a third smaller than the minimum normally allowed. Many of the units will be poorly ventilated, with limited natural daylight and there is no outdoor space. It seems likely that the building will be used to house vulnerable people requiring temporary accommodation.

The units proposed for Refuge House are substantially smaller than the single room units at Brickfield House, another large-scale office conversion. Residents living at Brickfield House complain about noise, not being able to sleep, drug taking, cramped conditions, poor ventilation, overcrowding and cockroaches. There are police notices warning residents about anti-social behaviour and drug use.

Apart from the serious consequences for health and wellbeing, these developments also put pressure on local resources.

We are asking that people object to these plans via the online portal on the Council’s website and to email their Councillors to express their objection.

The portal is at and the reference is 19/03612/PRJ.
PGC Webmaster's Avatar
PGC Webmaster posted a reply #4866 06 Nov 2019 23:12
Some more information from Matt Burn:

A few people have asked for a link to the plans and asked whether it is worth objecting as it is a permitted development application - so I have pasted my response below in case it is of interest.

We are hoping to get as many objections as possible as this will help us to get it decided in an open forum at the Planning Committee, rather than it being decided solely by a Council Officer.

If we can get it to the Planning Committee, we will try to persuade them to enact an emergency/immediate Article 4 direction, which the Council has the power to do and would stop this application.

Previously the planning officer discouraged objections from residents by saying there is no point in objecting as the application is decided on material fact not planning policy – there is some truth to this. However, when the planning officer was asked why he did not call in the decision last time as he was requested to, one of the reasons he gave was that he had not received many objections!
David Eden's Avatar
David Eden posted a reply #4868 07 Nov 2019 11:06
PDR is not a "loophole".

Is there any evidence to support this statement: "It seems likely that the building will be used to house vulnerable people requiring temporary accommodation."; or is it just fear-mongering hyperbole?

Also, I would be grateful of an explanation as to what Brickfield House has to do with Refuge House? Is it the same developer or in any other way linked?

Developers can't just force businesses to move willy-nilly for PDR, any more than they can if going through the full development application process. There is no interaction between PDR legislation and statutory landlord & tenant rights.
Matt Burn's Avatar
Matt Burn posted a reply #4872 08 Nov 2019 10:50
Hi David,

PDR has created numerous loopholes (i.e. an ambiguity or omission in the text through which the intent of a statute, contract, or obligation may be evaded). For example, the aim of the legislation was to speed up the conversion of empty or under used office buildings to be converted into homes. However, this is not what is happening, as many of the offices are not empty. It also enables developers to avoid making affordable home contributions, CIL payments, S106 payments and, avoid meeting planning regulations (e.g. minimum room sizes). Conservative MP Robert Halfon described it as, “… a policy that is possibly the most ill-thought-out, ill-conceived and subject to the law of unintended consequences, than almost any other policy … over the past few years”.

In terms of it being likely to be used as temporary accommodation - this is based on the evidence of other similar office conversions in and around Enfield (i.e. office conversions of a similar scale, room sizes, etc. are often used as temporary accommodation). There have been previous applications for Refuge House (e.g. for 31-units) and we did not claim that these were likely to be used as temporary accommodation, as they did not so clearly match the characteristics - this latest application for 76 units does more clearly match the characteristics of a block that will be used for temporary accommodation. Brickfield House is given as an example of a nearby conversion as it is in Enfield and has similar characteristics in terms of scale, room sizes, amenity space etc. and it shows what can happen if such developments are allowed to proceed unchallenged.

Over the last few months we have spoken to quite a few of the businesses and people working in Refuge House, who now need to pay the cost and upheaval of moving office location. They say their tenancies are either not being renewed or they are being offered short tenancies, which they feel make managing their business and business planning very hard - so they feel they are having to move out.
David Eden's Avatar
David Eden posted a reply #4873 08 Nov 2019 15:03
PDR is not a loophole. It is an piece of legislation. That it circumvents elements of previous planning control (legally) does not mean it is a "loophole".

Do you have evidence that PDR is not being applied to offices? Ask Croydon, huge amount of low quality office stock has been converted to resi there. Or are you saying there are examples where office blocks have resi conversions on one floor and continuing office uses on another? I would be interested to hear which examples they are (i.e. your "many of the offices are not empty").

I do not disagree that PDR means no CILs or s106s etc, that's why local authorities all hate it - but they simply can't/won't hit housing delivery targets without it therefore their responses are hamstrung.

Thank you for confirming there is no link to Brickfield house nor any actual evidence of an intended purpose of temporary accommodation, just postulation.

The impact of those business tenants at Refuge House is no different from if the Landlord wish to redevelop for any other reason or use.