On 8th August 2019 Julia Park wrote:

An open letter to the Prime Minister to end office-to-resi PDR

Dear Prime Minister,

As Mayor of London, you did a great deal to improve the quality of London’s new housing. Through the London Housing Design Guide, you brought in a total of 75 housing standards. Despite some early resistance the guide soon proved universally popular, even with developers. Forward looking, but achievable in practice, it has been emulated by many local authorities here, and elsewhere in the world.

Arguably, your greatest legacy was the introduction of internal space standards. Dubbed the ‘Parker Boris Standards’ (after the famous Parker Morris of the 1960s), your version was not just better; it was the first space standard to apply to all tenures. Your pledge to ‘end hobbit homes’ soon became legendary, though you may remember that you took some convincing to reduce the minimum size for a single-person home from 50m2 to 37m2. Give (or more accurately, take) that 13m2 climb-down, in 2015, your standard was adopted across the country as the Nationally Described Space Standard (NDSS). Regrettably, Ministers lacked your confidence. Rather than make it mandatory, it was left to local authorities to justify adoption, creating what your predecessor recently referred to as ‘a postcode lottery’.

You also set ambitious targets for carbon reduction, (remember ‘lean, clean and green’?), brought in the Lifetime Homes Standard (helping hundreds of thousands of older and disabled people remain more independent) and introduced a simple standard for daylight (requiring every habitable room to have a window equivalent to at least 20% of its floor area). You even required dedicated play space in every development for ten or more children, insisted that every new home should have some private open space (at least a balcony of 5m2) and much more besides. There was almost no stopping you.

It was all going swimmingly until 2013, when Permitted Development Rights (PDR), allowing office buildings to be converted to housing without requiring normal planning permission, were introduced. It meant that none of your 75 standards could be applied to these developments, even in London. If there were any lingering doubts about the need to protect basic attributes, they soon evaporated.

Six years and at least 42,000 homes later (experts believe the real number is nearer to 70,000), we have thousands of tiny, inaccessible new homes with no outdoor space. Single room ‘studios’ of 13m2 are not uncommon and one of just 8.3m2 has also come to light. If you deduct 2.5m2 for a small shower/toilet cubicle, the ‘13m2 home’ reduces to 10.5m2 (considerably smaller than the 12m2 you required for a double bedroom) and the ‘8.3m2 home’, to 5.8m2 (well below the 8m2 you required for a child’s bedroom).

These rooms are not just used for sleeping though. They are also where their hapless occupants (including families) sit, cook, eat, study, play, exercise, socialise, bathe and store everything they possess. As our report shows, some of these homes have no windows either. A shed on an industrial estate in Watford, has ‘Prior Approval’ to become 15 flats. Seven of them (including six in the roof with crawling height only at the edges) will have no daylight at all. At the bottom of this page is the building, viewed from the front.

We imagine that you are as concerned about this as we are. It must be very distressing to see your standards tossed aside as though they no longer matter. The homes created under PDR may just about be fit for hobbits but they are certainly not fit for human habitation – as defined under the new ‘Homes (Fitness for Human Habitation) Act 2018’. As Prime Minister, this must be of grave concern to you.

We would therefore like to invite you to be among the first to sign our petition to end this form of PDR.

Yours sincerely,

Julia Park
Levitt Bernstein
August 2019