The Pub to C3 Change of use is a very common task we are asked to do. If you are looking to convert a pub to a C3 property – that’s a flat or a normal house – this page provides some helpful planning advice. 

Do I need planning permission to convert my pub (Sui Generis) to a house or flat (C3)?

In 2020, public houses (or “pubs”) were stripped of their former use class (C4) and became “Sui Generis”.

“Sui Generis” is not technically a use class. It’s latin for “in a class of its own” and applies to any use of a property that does not fall within one specific use class. Other types of property that don’t fall into a use class and are therefore considered “Sui Generis” include cinemas, casinos, betting offices and Hot Food Takeaways. You can find out more about the different use classes here.

If you would like to change the existing use of any property to, from or within “Sui Generis”, you must always submit a full planning application. 

This means that you must always submit a planning application for any of the following changes of use:

  • Pub (Sui Generis) to house (C3);
  • House (C3) to pub (Sui Generis);
  • Pub (Sui Generis) to any other use class (e.g. a retail shop in use class E); and
  • Pub (Sui Generis) to any other Sui Generis use (e.g. a Hot Food Takeaway). 

The planning application should be submitted to your Local Planning Authority (this is normally your local council). Your Local Planning Authority (LPA) will then assess your planning application and either approve or refuse it. 

In assessing your planning application, the LPA will take account of their local planning policies and any other “material planning considerations” – find out more about these here

Although the content of local planning policies will vary, there are certain key planning issues that almost always apply when considering the change of use of a pub (Sui Generis) to a house or flat (C3) anywhere in England. These are discussed below. 

What are the key planning issues? 

Local planning policies will vary and it is important that your planning application is designed to meet the policies in force in your local area. There are, however, a number of key planning issues that will almost always apply to the proposed change of use of a residential property (C3) to a HMO (C4 or Sui Generis), no matter where the site is located. 

These are:

Effect on local community facilities

Pubs are considered to be a type of community facility. At the national level, planning policies seek to retain and enhance existing community facilities wherever possible. 

Furthermore, since the year 2000, around a quarter of all the UK’s pubs have permanently closed, with unfortunate social and economic consequences. There is broad agreement that efforts should be made to halt or at least slow this trend. 

To this end, lots of LPAs have adopted local policies to resist the change of pubs to other uses, unless certain criteria are met. These criteria will vary from place to place. However, the following local policy requirements are fairly common:

  • The property has been actively marketed as a pub for a reasonable period of time without any serious interest or offers (some LPAs set specific marketing time periods, often 18 months or 2 years);
  • There is no longer a demand for the pub;
  • The pub is not financially viable (and could not be made so under new ownership);
  • There are enough similar facilities (like pubs and social clubs) in the area. 

You may need to meet just some or all of the above requirements. Exceptions are often made to local policy requirements, although the onus is on the applicant to justify this. For example, your change of use may be supported if you have failed to meet a minimum marketing period BUT your planning application is accompanied by compelling evidence that the business is not – and could not be made – financially viable.

When it comes to a change of use from a pub to a house, the effect on local community facilities  is the most critical planning issue and the most difficult hurdle to overcome. If your planning application is refused, it is highly likely to be for this reason alone. 

Effect on character and appearance

“Character and appearance” is the way a place looks, functions and “feels”. 

This includes its buildings (size, height, architecture etc.), its layout (e.g. are buildings close together or far apart?), its uses and activities (e.g. is it a busy town centre or a quiet residential street?).

When it comes to a change of use of a pub (Sui Generis) to a residential property (C3), the LPA will mainly be concerned with the:

  • Effects of physical development, mainly external changes (such as new windows or re-landscaping). Is it designed and constructed to a high quality? Is it “in keeping” with the building and surrounding area’s established character and appearance? For example, do any new windows follow the style, position and materials of the building’s existing windows? Many public houses will have large car parks, meaning there is often opportunity to enhance character and appearance with a well-designed landscaping scheme. You can find out more about our landscaping services here
  • Effects of the loss of the public house. For example, does the public house contribute positively to the character of the place? Would its loss cause the local community to become less vibrant or sociable? The loss of a public house is far more likely to be acceptable in areas that already have a good range of public houses, cafes, restaurants etc. The loss of “the last village pub” is more likely to be resisted, although this can still be overcome with good marketing and/or financial viability evidence. 

Sustainability

The general principle when it comes to the creation of new homes (C3) is that they should be located in “sustainable” locations. These are broadly understood to be sub/urban locations where services and facilities (such as shops, schools and workplaces) can be accessed from the home using sustainable transport modes. Sustainable transport modes include walking, cycling and public transport. 

Sometimes, LPAs assess all “new” homes in the same way, no matter whether they are new builds or conversions of existing buildings such as pubs. 

If the pub is located in an area where new housing is generally resisted – normally “open countryside” locations without access to services/facilities using sustainable transport modes – the LPA may object to its residential conversion on this basis. 

However, Planning Direct frequently succeeds in rebutting objections of this nature. This is because in the vast majority of cases, the residential conversion of a pub will cause a notable reduction in “unsustainable” journeys (that’s using a private car or taxi) made to and from the site. It would not seem reasonable to object to a reduction in unsustainable vehicle movements to and from an existing building on the grounds of “sustainability”. 

Standard of accommodation

The LPA will need to be satisfied that the property would provide an acceptable standard of accommodation to its residents. Given that public houses tend to be large properties set in spacious grounds, it is rarely difficult to achieve this. However, if you are looking to convert the pub to multiple flats, more care will be needed. 

The LPA will likely have local design policies concerning (for example) the form, layout, size etc. of residential gardens, parking facilities, bedrooms etc.. These apply to residential properties converted from other uses as much as to new builds. 

Effect on heritage assets 

If the building is listed (including locally listed), in or adjacent to a Conservation Area OR close to a listed building (including locally listed), the LPA is obliged to consider the effect of the change of use on the affected assets’ heritage value/s. Permission for the change of use will normally only be provided if the effect on heritage assets is beneficial or neutral. 

In these circumstances, your planning application should include a proportionate assessment of the affected heritage assets’ significance, including an assessment of the likely impact of the proposed change of use.

What do I need to submit with my change of use planning application?

Your planning application for a change of use of a pub (Sui Generis) to a house or flat (C3) should normally include:

  1. Application form;
  2. Planning, design & access statement/s; and
  3. Suite of relevant planning drawings:
  • Site location plan
  • Block plan
  • Existing and proposed floorplans
  • Existing and proposed elevations.

Other requirements will vary depending on the LPA and its local policies, the site/location and the physical changes required (if any). For example:

  • If a relevant local policy requires evidence that the property has been marketed for a specified period without success, Evidence of Marketing should be submitted with the application. This should normally contain the following information as a minimum:
  1. Date the property was first placed on the market (and date removed, if relevant);
  2. Copy of sales particulars (etc.);
  3. Asking price and any reductions;
  4. Number of enquiries, viewings and offers;
  5. Reason for turning down offers (if relevant);
  6. Letter from the Property Agent providing their professional insight into the unsuccessful marketing exercise (e.g. location is undesirable, property is unsuited to pub use etc.).
  • If a relevant local policy requires evidence that the pub is not financially viable OR you are seeking to rely on this as a “material planning consideration” (find out more about these here), you should submit a Financial Viability Assessment with your planning application. This should assess the business’s financial accounts over previous years. Ideally, it should also apply CAMRA’s “Public House Viability Test” which seeks to establish the trade potential of the premises. 

How can Planning Direct assist with my change of use application?

Planning Direct can assist you with all aspects of your change of use planning application, from start to finish. Our “comprehensive package” includes the following services:

  • design guidance
  • planning drawings
  • planning, design & access statement; and 
  • case management*. 

*this means we will submit the planning application on your behalf and then act as your agent throughout the process, liaising with the LPA until a decision is reached. 

You can find more information about these services here.

If you don’t require a comprehensive package (for example, because you are providing your own drawings), we can provide a bespoke selection of the above services at a reduced cost.

In the event that any supplementary reports are required (such as a Financial Viability Assessment, Evidence of Marketing etc.), we can either produce these in-house or commission them from an external provider on your behalf. We will always agree this with you beforehand. 

Planning Direct will ensure that your planning, design & access statement is carefully crafted to address all relevant local planning policies and all relevant planning issues (such as those described above). 

How much will it cost?

There are two main expenses that you need to take into account:

  1. Preparation and submission of the planning application (including drawings, written statement, case management etc.); and
  2. Application fee payable to the LPA.

Currently, the application fee for a change of use from a pub (Sui Generis) to a single house or flat (C3) in England is £462. If you are looking to convert the pub to multiple flats or houses, each flat/house will attract a fee of £462*.

*please be aware that although we make every effort to keep our website up-to-date, application fees do change occasionally and you should always check the fees in place at the time of making your application. 

At Planning Direct, fees for a comprehensive change of use planning application start from £1195.

Please be aware that in certain circumstances the LPA may request supplementary reports (such as Evidence of Marketing, Heritage Impact Assessment etc.) which will attract additional fees. 

Broadly speaking, the fewer physical alterations you need to make to the building in order to change its use to a house or flat, the less the cost of the planning application overall. 

Although you are entitled to prepare and submit your own planning application, employing a good planning consultant can save you money in the long run. This is partly because there are various technical requirements that your application must meet in order to even be considered by the LPA. For example, planning drawings must be drawn to particular scales and show specific site/locational features. If it takes you multiple attempts to get this right, you could spend more money overall. 

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