Change of use
Converting a commercial, office, or other non-residential building to residential use is one of the most common and most policy-complex types of planning application. The supporting statement must navigate permitted development rights, housing policy, employment land protection, design standards, and — in London — the Mayor's specific requirements. Getting it right from the start saves weeks of back-and-forth with the planning officer.
The first question for any commercial-to-residential conversion is whether the change of use can be achieved through permitted development via prior approval, or whether a full planning application is required.
Class MA of the General Permitted Development Order allows the change of use of a building in Class E (commercial, business, and service use) to Class C3 (dwelling houses) without a full planning application, subject to prior approval. The key conditions are:
For Class MA prior approval, the LPA assesses a defined list of matters: transport and highways, contamination, flooding, noise, natural light, and the impact on the character or sustainability of the area. A supporting statement addressing each of these matters is required with the prior approval application.
Note: Many London boroughs have used Article 4 Directions to remove Class MA permitted development rights in specific areas — particularly town centres and employment zones. If the site is in London, check whether an Article 4 Direction applies before assuming prior approval is available.
A full planning application is required where:
Establish that the development plan supports residential use at this location. Most development plans zone land for specific uses — employment zones, primary shopping frontages, mixed-use areas. If the site is in an employment protection zone, the statement must address the policy and explain either compliance or why material considerations justify a departure.
The loss of employment land is a frequently cited reason for refusal of commercial-to-residential conversions. Your statement should address whether the existing commercial use is viable — whether the building has been marketed, whether there is demand for commercial floorspace in the area — and argue that the loss of employment is not significant or is outweighed by the housing benefit.
A change of use to residential contributes to housing supply. NPPF paragraphs 60–62 give significant weight to boosting housing delivery, and this is a positive material consideration in your favour. Reference the LPA's housing land supply position — if they cannot demonstrate a five-year supply, the tilted balance under NPPF para 11 applies and gives additional weight to housing delivery.
The quality of the residential accommodation proposed is a key consideration — particularly internal space standards, daylight, outlook, and amenity space. Many LPAs require compliance with the Nationally Described Space Standard. In London, Policy D6 of the London Plan sets space and quality requirements for all new dwellings.
Address each room's dimensions, ceiling heights, window areas, and outlook. For basement or ground floor conversions, natural light is often the critical issue — explain how adequate daylight reaches habitable rooms and consider whether lightwells or larger window openings address any shortfall.
Introducing residential use in a commercial or mixed-use area raises noise amenity questions. The new residents will be living alongside commercial activity — deliveries, late-night uses, mechanical plant. Your statement should address whether a noise assessment is required and how the proposed development protects future occupants from noise.
Residential uses typically generate different parking and transport patterns than commercial uses. Address parking provision against the development plan's standards, cycle storage, and any transport assessment requirements.
Where the conversion creates new dwellings above the threshold in the development plan (often 10 units for major applications), affordable housing contributions may be required. Address this in the statement — either confirming compliance with the policy threshold or setting out the viability position.
Planabl generates a policy-referenced first draft for change of use applications in under 60 seconds. First draft free — no account needed.
Try Planabl free →