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Heroes & Villains

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The UK’s PM Boris Johnson recently stated that it’s time for everyone to get “back to the office” and that they’ve had enough “days off”. He’s not keen on having people continue working from home probably because they might learn to like it. It also means office buildings may be under-occupied yet, over the past ten years, his government has done everything it can to force people (but mainly the homeless and vulnerable) to live in them. This is what went down

2011: UK government ministers had the bright idea of removing planning permissions for office-to-residential conversions ostensibly because the private sector can “better” provide social housing once regulations are removed. There was to be no planning scrutiny if an office or industrial building built before 1990 had been vacant for six months, and was to be either demolished or replaced with a house or apartment block. I can understand the logic to an extent since the typical western apartment building is basically an office building anyway.

Mies van der Rohe’s Lake Shore Drive apartments with extra internal walls and plumbing.

2013: A three-year trial period began. The relaxation led to an immediate and substantial rise in “permitted development” applications. Developers know a money tree when they see one.

2015: Levitt Bernstein architects began presenting the government with examples of the policy not working, only to be told those particular projects were not representative.

2016: The change in policy was made permanent.

2018: The Royal Institution of Chartered Surveyors sounded the first public alarm with a report that stated

“Overall, office to residential PDR has been a fiscal giveaway from the state to the private real estate interests, while leaving a legacy of a high quantum of poor quality housing than is seen with schemes governed through full planning permission”.

2019, January 10: Levitt-Bernstein made public a report of their own findings and recommendations.

“We acknowledge that when Ministers first came up with the idea in 2011, it might have been difficult to foresee that run-down office buildings on the edge of dual carriageways, or within industrial estates, would be converted to ‘homes’ as small as 13m2, or that some would lack a window. But alarm bells began to ring long before the three-year trial period, which begun in 2013, was made permanent.”

This is their report. It’s grim reading.

Here’s some examples of developments that were permitted.

Parkview Office Campus, Bristol
This was the largest permitted development project in the UK, with 467 flats created in a former supermarket headquarters. If you follow through a particular set of layout design priorities then this is what you get.

Here’s a full pdf explaining the project.

A failed business park may have empty building stock that, even if repurposed as accommodation, won’t magick up the local amenities and public transport to serve it. It’s worrying, but not surprising, that housing separated from local amenities and public transport can even be thought of.

A floorplate suitable for office space isn’t that different from a floorplate divided into rooms either side of a corridor and used as apartments or a hotel but this doesn’t mean that single aspect apartments the size of hotel rooms are a good thing. This also indicates that housing is thought of as nothing more than a place to sleep. The elevator and stair positions aren’t going to be changed and, as a result, those inside corner apartments are going to be particularly miserable.

Newbury House, Redbridge

This development is famous for being sited on the edge of a six-lane, dual carriageway with a 70mph speed limit. It’s also an example of how the permitted development legislation affected minimum spatial standards.

This next image is from the Levitt Bernstein report and shows what happens when a 50 m2 apartment is compressed into a 14 m2 one. Once again, it shows that housing is thought of as no more than a place to sleep.

Terminus House, Harlow, Essex
This is often used as an example of everything that wrong with this kind of permitted development. Levels of crime and other ills caused by poverty and unemployment were an issue back in 2018 and, after a one-year UK lockdown, people in accommodation far larger and pleasant than this are displaying mental health issues.

Here’s two photographs of the apartment in the bottom left corner. The left one looks professionally taken but for what purpose I can’t imagine.

Edinburgh House, Harlow
This development is remarkable for having bedrooms with high-level fixed glazing providing bedrooms with borrowed light from corridors. Once again, it shows that what might have been acceptable in an office building is not so clever for residential.

1 Wellstones, Watford
This proposal was refused permission but then that decision was overturned on appeal. Seven of the apartments have no windows and those that do have only high-level ones. The upper floor apartments don’t have standing room across their floor area.

106 Shirley Road, Southampton
It’s not even necessary to write anything about this one.

I used to think the 2014 conversion of Providence Arcade [the US’s oldest shopping mall] was grim but those two bedroom windows and that one internal swing door make it humane by comparison. [c.f. The Vertical City]

While all that was going on…

Jan. A report compiled for the government by persons from University College London and the University of Liverpool was damning of the policy. That same day, the policy was extended.
Mar.12 It was reported that the RIBA had condemned government proposals to expand permitted development rights, labelling plans to allow the demolition and replacement of industrial and commercial property with housing a “fundamental contradiction”.
Apr. A BBC report highlighted the problems with Terminus House.
Jul.21 The government report submitted in January was made public and, on the same day, the policy it was critical of was extended.
Jul.24 Three days later, the horrors of these permitted development projects found a wider audience with a July 24 article in The Guardian.
Sep.30 The UK government Housing Secretary announced that new homes delivered through Permitted Development Rights will have to meet space standards. This is the announcement as reported on

The RIBA was quick to respond to the government’s change of policy seven years after it was implemented and nine years after the policy was first floated.

When the respective statements of the Housing Secretary and RIBA president are seen side by side, it’s odd the Housing Secretary claimed that “Permitted development homes make an important contribution to delivering the housing the country needs by making effective use of existing buildings, allowing them to be changed into homes without the need to go through a full planning application.” This is unsubstantiated. “The homes are instead consented through a lighter-touch ‘prior approval’ process, speeding up the delivery of these new homes – with over 60,000 homes provided over the last 4 years. The truth of this depends on what your definition of a home is. Also, the use of the term “lighter touch” suggests the preexisting planning process was heavy-handed and the truth of this depends upon what you expected a planning system to do. Dismissing this as “neoliberals being neoliberals” is to normalize it.

On the other hand, the RIBA president is overexcited by a government having done one right thing. Requiring Permitted Development developments to meet National Described Space Standards will probably be sufficient to make such exploitative developments (at a minimum three times the area) unattractive to the more cavalier developers. However, the Housing Secretary’s statement said nothing about location, daylighting or ventilation. If buildings with habitable rooms having nothing but borrowed light from an access corridor have been acceptable in the past then I expect them to continue to be so in the future unless specifically singled out. This is still a major loophole as office buildings usually have deeper floor plates than apartment buildings. Providing accommodation in which all habitable rooms have openable windows is at odds with making the “best use” (a.k.a. most exploitative) use of that floor plate. If you think about it, the very idea of converting office space into residential space suggests daylighting will be a problem. Hopefully, fire safety is still controlled by building control but that thought’s not as reassuring as it should be.

The sorriest thing about this whole story is that the government tried it on, was rumbled, and backtracked while claiming success and without apology. Having private enterprise provide housing for society’s most vulnerable indicates failure of the entire system of building design and provision. It’s damning there was no way to stop these developments being built, and more damning that the only way to stop them being occupied was to launch a legal challenge under the 2018 Homes (Fitness for Human Habitation) Act. We can say that architecture as any kind of social endeavour is for all practical purposes dead in the UK.

Charles Jencks is no longer around to dispute this but Pruitt Igoe failed not because of a lack of postmodernism but because of shitty seventies circumstances coupled with the lack of a maintenance and management plan. Few people care to know or remember that its initial residents were very happy to be living there. This important short film still available on VIMEO. The convenient but false binaries of Modernism and Post Modernism served to vilify the public provision of housing.

The greater disgrace of these British permitted development projects is that government, developers, councils nor tenants had any expectations of them to begin with. This absence of concern along the entire chain of provision is a new low. It’s never a good time to be disenfranchised but so far the 21st century is no high point. Heroes and villains are another convenient yet false binary. On a 0–10 scale of concern, the UK government gets zero for beginning this shitshow and the Royal Institute of Chartered Surveyors gets a 10 for flagging it and calling it for what it is. Levitt Bernstein is up there too for making those concerns more public. With its statement of “looking forward to engaging with the policy makers,” the RIBA has lived down to its domain name of and is a 3 at best.



  • Interesting stuff. An efficiency, studio unit in CA used to be 220 SF. Now, by way of ADU laws and the tiny living movement, it’s 150. That’s living, but can include the kitchenette area. Bathroom and closet required, is beyond the 150. Figure about 210 SF all in. More of our peeps need to be in political office and positions of policy making. Lim did wonders for Singapore and Lerner in Curitiba. When Obama was asked “what’s next?”, he said he’s always had in interest in architecture (i.e., I like building things). That Thomas Jefferson guy was pretty good too. At least in the end, UK set a minimum dwelling size.