Can residential conversions count against self-build housing supply? - Public forum - Planning Advisory Service (PAS)

Hi I am a Policy monitoring officer at a District Council. I (try to) monitor annual self-build plot approvals and have traditionally taken the view that conversions don't count. This is based on the wording of definitions in the SaCBHA 2015 and HaPA 2016 which seem to define self-build in terms of construction, access to utilities etc. I also note the HaPA Section(3)(6A) now seems to specify that "completion" of plots only means in relation to building operations and nothing else. So am I right in thinking this excludes changes of use, so conversions can't count?

Many thanks