The TCPA is still working up its full response to this consultation and we recognise there are other issues that many will want to raise.   

If you are considering raising other issues, we would ask you to consider raising the following in response to proposed changes to chapter 4: decision making. 

Proposed changes to this chapter would make it even harder for local authorities to take steps to prevent permitted development rights being used to circumvent the planning system to deliver potentially poor-quality new homes. As the rights enable the conversation of other buildings to residential use, it also poses risks to the viability of town centres and presents a range of other challenges we wrote about in our report, No place for place-making 

In response to question 3, therefore, relating to chapter 4, we ask people to consider selecting ‘no’ and stating: 

In light of the concerns set out in the Government commissioned report on the quality of homes delivered through permitted development rights [published 2020] and the wider concerns about the impact of these rights on place-making I object to all of the proposed changes set out for paragraph 53. Article 4 directions are one of the few tools available to local authorities to shape places and their use should not be limited any more than they already are.  

If the Government is serious about seeking to ensure the vitality of villages, towns and cities, and the achievement of health communities, the proposed changes cannot be taken forward into the updated NPPF.