England (United Kingdom): Permitted Development Rights + Street Votes

England never did what New Zealand and British Columbia later did. It did not pass a single law that re-zoned every house lot in the country for three or four homes overnight. Instead, England has a plan-led system: under the Town and Country Planning Act 1990, almost any building work that counts as "development" needs planning permission from the local council, and councils weigh each application against a local plan. That makes the system slow and case-by-case. To add homes faster without rewriting that whole framework, England reached for a workaround it had used for decades: permitted development rights, which let certain kinds of building work happen automatically, without a full planning application.

The result is a useful warning for British Columbia and anywhere else following the multiplex path. England chased speed by removing the planning check on a set of conversions, then discovered that when you remove the check, you also remove the quality floor. The homes got built, but a government-commissioned study found many of them were small, dark, and worse to live in than homes that went through the normal process. England's experience is the cautionary counter-case: it shows what blanket up-zoning looks like when it is done without minimum standards attached. This page sets out what England actually did, what got built, the quality backlash, and what it means for British Columbia's own multiplex rules.

Permitted development rights are grants of automatic planning permission written into law. The main rules are consolidated in the Town and Country Planning (General Permitted Development) (England) Order 2015 (Statutory Instrument 2015/596). When a project fits a listed class, the developer does not have to ask the council whether the principle of the development is acceptable. At most, they go through a lighter check called prior approval, where the council can only consider a short, fixed list of issues such as flooding, contamination, highways impact, and noise rather than the full merits of the scheme.

Three of these rights matter most for adding homes. The first is office-to-residential conversion, known as Class O. It lets a developer turn an existing office building into flats without a normal planning application. The right was made permanent by the Town and Country Planning (General Permitted Development) (England) (Amendment) Order 2016 (SI 2016/332), which came into force on 6 April 2016. The second is upward extension, called Class AA, which lets owners add new storeys on top of an existing home. It was introduced by the General Permitted Development (Amendment) (No. 2) Order 2020 (SI 2020/755), in force from 31 August 2020. The third is demolish-and-rebuild, called Class ZA, which lets a developer knock down a single vacant office, light-industrial, or block-of-flats building and replace it with new homes. It was added by the General Permitted Development (Amendment) (No. 3) Order 2020 (SI 2020/756), also from 31 August 2020. Together these rights created a route to new housing that bypassed the usual planning judgment about whether the homes would be good places to live.

Office-to-residential conversion delivered real numbers of homes, and that is exactly why the quality problem matters. When the government removed the planning check, it also removed the rules that normally guarantee a home is big enough and gets enough daylight. The clearest evidence comes from a study led by Dr Ben Clifford at University College London's Bartlett School of Planning, commissioned by the Ministry of Housing, Communities and Local Government and published in July 2020. The researchers visited 639 buildings across 240 housing schemes in 11 local authority areas, comparing homes created through permitted development against homes created through the full planning process.

The findings were stark. Only 22.1% of the permitted-development homes met the government's own Nationally Described Space Standard for minimum floor area, compared with 73.4% of homes built under full planning permission, according to the UCL study. On natural light, 72% of permitted-development homes were single-aspect, meaning all their windows faced one direction, compared with 29% of the planning-permission homes, the same research found. Single-aspect homes get less daylight and ventilation and are harder to keep at a comfortable temperature. The study reported some converted office units smaller than a typical hotel room and others with no windows at all in habitable spaces. The conclusion was that the permitted-development route was producing a class of homes systematically worse than the ones the planning system would have allowed.

The quality findings forced a partial reversal. On 30 September 2020, the government announced that new homes created through permitted development would have to meet the Nationally Described Space Standard, according to the official announcement. The minimum floor area for a one-bedroom flat with a shower room was set at 37 square metres, the same announcement confirmed. This built on an earlier change that required permitted-development homes to provide adequate natural light, as the government noted.

This is the heart of the cautionary lesson. England got the sequence backwards. It removed the planning check first, let homes get built for several years, and only added a minimum-size and minimum-light requirement after a commissioned study documented the harm. By the government's own admission the reform was aimed at developers "abusing the system" to deliver inappropriately small units. Had those standards been attached to the permitted-development right from the start, the worst outcomes the UCL study measured would not have happened. Speed was delivered, but the quality floor arrived years late and only after the evidence was undeniable.

England's second tool for adding homes was design quality rather than raw permission. On 20 July 2021, the government published a revised National Planning Policy Framework alongside the National Model Design Code. The framework added a stronger emphasis on well-designed and "beautiful" places and made it the expectation that councils produce local design codes, with the National Model Design Code acting as the template, according to the ministerial statement to Parliament.

The idea behind this approach is often called "gentle density": adding homes within existing neighbourhoods through well-designed extensions, infill, and modest apartment buildings that fit the character of the street, rather than through large towers or sprawl. It is the opposite philosophy to the permitted-development route. Where permitted development removes the design judgment entirely, design codes try to pre-agree what good development looks like so that more of it can be approved quickly and with confidence. England, in other words, ran both experiments at once: stripping the quality check in one part of the system while trying to formalise it in another. For British Columbia, the contrast is the point. Pre-agreed design standards are how you get speed and quality together; removing standards to get speed is how you get the office-conversion problem.

England's most direct answer to a blanket up-zone was a tool called street votes. The idea is that the residents of a single street could collectively propose and then vote on rules that would allow them to extend or redevelop their own homes, with planning permission granted automatically if the proposal passed and met set requirements. It is a bottom-up version of up-zoning: instead of the national government re-zoning every lot, each street opts itself in. The legal power to create street votes was put in place by the Levelling-up and Regeneration Act 2023, which received Royal Assent on 26 October 2023.

But putting the power in the Act was not the same as making the tool work. Street votes can only operate once the government writes the detailed secondary regulations, called street vote development orders, that set out exactly how a vote is run and what it can approve. The government ran a consultation on those rules from 22 December 2023 to 2 February 2024, intending to have the regulations in place during 2024, according to the consultation document. As of mid-2026 those regulations have still not been laid before Parliament, so street votes are not yet operational. One policy briefing reported that the ministry had completed about 90% of the required legal drafting but that the statutory instruments still needed a final push to be finished and laid, according to British Progress. The tool is real and on the books, but it has not delivered a single home, because the last step was never completed.

The contrast with New Zealand and British Columbia sharpens the lesson. New Zealand did the thing England avoided: it passed national legislation requiring its largest cities to allow up to three homes of up to three storeys on most residential sites, a genuine blanket up-zone applied through the Resource Management (Enabling Housing Supply and Other Matters) Amendment Act 2021. England never enacted an equivalent. Its permitted-development rights changed the rules for converting and extending existing buildings, not a wholesale re-zoning of residential land for new multiplexes.

British Columbia sits closer to New Zealand than to England. Its small-scale multi-unit housing rules, brought in by Bill 44, require local governments with a population over 5,000 to allow at least three units on lots of 280 square metres or smaller, at least four units on larger lots, and up to six units on larger lots near frequent transit, according to the Province of British Columbia. That is a true up-zone of single-family land, the move England chose not to make. The crucial difference from England's permitted-development experiment is that British Columbia's framework still runs new homes through the building code and local site standards, so the units have to meet baseline rules on size, light, and safety.

The single most important takeaway from England is that speed without quality standards backfires. England removed the planning check to get homes built faster, and it worked in volume terms, but a government-commissioned study then found that only 22.1% of those homes met the basic space standard, against 73.4% for homes that went through full planning, according to the UCL research. The political and human cost of building thousands of substandard homes outweighed the speed gain, and the government had to bolt the standards back on afterward.

For British Columbia, the practical guidance follows directly. First, keep the quality floor attached to the up-zone from day one. Bill 44 allows more homes by right, but those homes still answer to the building code and to local site standards, and that combination is what England lacked at the start. Second, treat minimum size and daylight as non-negotiable rather than as something to add after the fact; England's reversal shows how hard and slow it is to fix quality retroactively. Third, do not over-rely on opt-in tools that look good on paper but stall in implementation. England's street votes have sat unused for years because the final regulations were never finished, as British Progress documented. A multiplex policy delivers homes only when every step of it is finished and operational. England got the build-out but not the quality; the lesson for British Columbia is to insist on both.