Some thoughts on the Proposed Class E to Resi High Street PD Right

• The requirement for natural light means it will be hard to apply to zone A deep fronted vacant high street stores – there development will require PP to form light wells
• The right is more likely to be applied to small shops on fringes of town centres and in local areas
• The lack of any shopping need test – unlike the current A1 to C3 right – means it will most likely be applied to much needed shops in high value areas (Like Belgravia and well heeled villages) with disastrous consequences to local services.
• We have too many shops for modern needs, especially in linear traditional high streets, and especially in more distressed towns.
• There are often calls for such linear centres to be compressed, taking away shops at the edges.
• However the most depressed areas of many centres are not at the outer edges, which are often nearest railways stations and car parks, but at the centre where the big stores like BHS, Marks and Spencers etc. used to be – examples Northampton and Southend.
• The peripheral areas often have more mixed uses such as cafes and residential which add to footfall.
• This questions the ‘planning dogma’ of primary frontages. Much of the evidence for them is discredited. I think of the old Unit for Retail Planning Information 35% rule – which suffered from spatial autocorrelation – i.e. poorly performing areas were more likely to be in depressed areas with low footfall.
• Primary frontages are unlikely to be relevant unless in the very busiest regional centres e.g. Nottingham and Cambridge and no longer relevant in 95% of areas.
• Permitted development is likely to hinder land assembly for comprehensive redevelopment at higher densities – we already see this with office PD rights in London.
• I have blogged here many times about the latest research on vibrant centres suggesting the key to survival is introduction of mixed uses which bring footfall – cafes etc. The town centres most dependent on retail are thiose most struggling. We have to abandon 1970s ‘primary frontage’ thinking.
• Dead frontages more more walking and is the enemy of vitality – it would make more sense for pd rights to apply to upper floors and rear storage areas than frontages.
• There is big suppressed savings from the lockdown in more wealthy areas, expect a big recovery in spending in 2021.
• Large centres anchored on department stores are dinosaurs.
• Emerging clothing retailers, especially from Europe and Asia, still struggle to find space in the UK locked out by long leases – just compare the names say from a mall in Dubai. I’m sure there would be a market for splitting large footprints into concessions and administrators need to be more imaginative.
• Town centres biggest assets are their open car parks, now wasted providing spaces for stores that are no longer there. Develop them for housing. Charge a premium for the remaining structured parking, parking and shopping floorspace find a new equilibrium.
• Rebuilding town centres and assembling mixed use sites requires intervention and good planning. Crude PD rights wont help here. Much better there ws NPPF revisions and a PPG based on the latest research and best practice.