CENF have submitted a letter of support for Haringey’s move to apply an ‘Article 4 Direction’, covering Crouch End town centre, designed to restrict permitted development rights which currently allow for the change of use from offices to residential without full planning permission. Some recent conversions elsewhere in London have produced shockingly poor accommodation.
Article 4 Directions remove certain permitted development rights. This means that within those areas subject to an Article 4 Direction, developers may have to apply for planning permission for works which normally would be permitted development.
As it goes we had a slight problem – the area the Direction covered doesn’t actually contain Crouch End’s surviving office buildings. It just covered the retail area. Meanwhile, retail to residential PD rights aren’t part of this Article 4 Direction. So it’s the right idea with the wrong map. Ah well, hopefully things can be tweaked.
Read here for Haringey’s intentions. It isn’t limited to Crouch End.
Images: google maps. Alexandra House above was lately the hugely controversial subject of an application to convert to flats.
Representation by the Crouch End Neighbourhood Forum
Re. Notification of Making of a New Article 4 Direction for the Change of Use from Office (B1a) to Residential (C3)
The Forum strongly supports the Council’s intention to designate an Article 4 Direction (A4D) for Crouch End. We would also like to propose some revisions to the area covered.
We note the emerging intentions of the government to move to a zonal approach to town planning, that resulting ‘protected’ zones would have to be agreed, that a new Local Plan is approaching, and that the shape of town centre boundaries will be in flux (equally, we are also aware that the reclassification of land uses is due in a few weeks). We also note that Crouch End District Centre is mostly within a conservation area, but not all of it, and that our conservation area is due to be reviewed shortly. These are all forthcoming exercises we are likely to be a part of, which ought to inform the area included within the Article 4 Direction.
There are well documented examples of poor residential housing as an unintended consequence of the policy to extend Permitted Development (PD) rights to the conversion of commercial property and we support the Council’s intention to avoid such development. In addition, there is acute local concern regarding the detrimental effect of PD rights on the integrity of the town centre and the consequent performance of the local economy.
We understand that the proposed A4D covers Class O PD rights, however we would like to express our support for an additional A4D to cover Class M PD rights. This is set out below. Furthermore, we note that Class O PD rights apply to development in conservation areas. This strengthens the case for inclusion of the employment sites detailed below.
As all this may change as the transitional period for the reform of land use classes plays out, it would seem prudent to assume that little is assured. Nevertheless, this may increase the value of an A4D made at this time.
Protecting town centre retail and leisure use
Although Crouch End’s town centre is long established it is far from immune to widespread contemporary retail pressures. It is, in our view, of key importance to develop programmes of investment here, projects that seek to support, enhance, and diversify the local economy. This work is perfectly possible, but would be significantly harmed if the integrity, completeness and character of shopping parades and the cohesion of town centre uses were suddenly lost to ill-designed piecemeal conversions of shop units to residential flats. A sense of place, aesthetics and economic performance are aligned. Already planning applications are being submitted to effect such changes along Tottenham Lane. Consequently, we would support an A4D to limit PD rights under Class M in the District Centre.
Protecting liminal town centre office sites
The proposed A4D covers much of the retail area in Crouch End, but does not include the main, surviving, office and light industrial accommodation – which is found at the edge of the town centre.
Residential developments are continuing at pace in the area and it seems entirely unnecessary to add to the mix poor examples of converted office space.
Furthermore, our consultations with local traders and residents have identified key weaknesses in the local economy. These include particularly a lack of office space and marked retail under-trading during weekdays. Such things are linked, and the loss, over the years, of local employment is an issue for the town centre.
We are therefore keen to ensure the continued use of the sites described below for local employment. In addition to the local value of B1 and A2 land use, this is in line with Haringey Local Plan employment policies, and in accord with the overriding principle of governmental policies for high streets – ie. maintaining viability through diversification. The importance of retaining employment space in suburban locations in the light of changing patterns of working and commuting produced by the current pandemic, would also appear wise. Obviously, this does not remove the possibility of redevelopment – of residential or mixed nature – merely seeks to assure it through the planning application process.
In conclusion we believe the following sites should be considered for inclusion in the Article 4 Direction area:
- To the SW: Include the whole of the Crouch End Telephone Exchange (B1 use, it currently sits astride the District Centre boundary). This aids protection of the site for mixed town centre/employment use. Also add, if it is not already, no. 71 Crouch End Hill (Marks and Spencers).
- To the SE: Include Park Chapel, currently sub-divided to a variety of B1 uses
- To the W: Include Coleridge Lane, Frederick Place (part) and the Crouch Hall Road car park. This area comprises a collection of B1 workshop and office units behind the Broadway.
- To the NW: Include the Lynton Road and Courtyard commercial estate. We note that this site is already designated a Site Allocation within the current Local Plan, however, at a time of change for planning designations, and as our own Neighbourhood Plan develops, we feel it important to future proof the area to retain the possibility of locally determined development policies.
Questionable PD conversions are not limited to office blocks. There’s a current application to convert the shop unit at no.47 Tottenham Lane (the solicitors next to George’s Fish Bar) to residential. At the moment the parade is complete, but PD rights suggest it may not be so for long. Some of the units up there have been vacant for some time. The new flat behind the frontage would be a tiny 28.7 m2 (there are flats already at the back and on the first/second floors).