IPM submits robust rejection of proposals to extend permitted development
The Institute of Place Management has today submitted its response to the Government consultation on ‘Supporting housing delivery and public service infrastructure’.
The consultation is seeking views on a proposed new permitted development right for the change of use from Commercial, Business and Service use to residential to create new homes, on the approach to simplifying and consolidating existing permitted development rights following changes to the Use Classes Order, as well as measures to support public service infrastructure through the planning system.
Supporting town centres?
The introduction to the consultation re-echoes that the government wants “to support our town centres and high streets in adapting to these changes to become thriving, vibrant hubs where people live, shop, use services, and spend their leisure time.” It notes that changes to Use Classes in September have been introduced so that a new ‘E Use class’ includes uses generally found on the high street such as shops, banks and restaurants, but broadens it to encompass a wider range of uses such as gyms, creches and offices. The introduction says “This provides greater flexibility to move between such uses, and to provide for a mix of such uses, without the need for a planning application.”.
Although the Institute is a keen supporter of residential in town centres, we believe that this should be part of the plans communities make and not imposed.
The consultation suggests that residential development would “make effective use of existing commercial buildings, bring additional footfall from new residents, and assist in the wider regeneration of town centre and other locations”. We don’t agree with this supposition.
The consultation proposes permitted development should take place in conservation areas.
Along with many other organisations with whom we work, we have submitted a response saying this is wrong approach, that will have serious adverse implications for town centres. It is directly contrary to the work of Task Force that is encouraging community engagement and ownership in planning the future direction of their towns. It is hierarchical in approach that will take control from partnerships. It runs counter to the existing funding streams for town centres, most notably the High Street Action Zones, which are bringing investment into supporting the historic identity of places, and other government funds such as the Future High Streets Fund, Towns Fund, recovery and levelling up funds.
It is an extensive consultation but in response the question “Do you have any other comments on the proposed right for the change of use from Commercial, Business and Service use class to residential?”, a short summary of our response says:
Although our high streets are challenged at the moment this is not the right approach. It will do harm to the vitality and viability of our high streets. After decades when investment and development of our high streets has been determined in a hierarchical manner to the exclusion of community engagement, it is no surprise that we have high streets with unsuitable and unsustainable offers.
We now have a chance to change. Because of COVID, broad range partnerships are now being formed to support recovery and embark on transformation of high streets. A new sense of localism is emerging; people want to be engaged.
We lead the High Streets Task Force, which is funded by Government to support the development of place leadership at a local level, and to support the capacity of places to develop effective visions for the future. In addition the funds provided by the Future High Streets Fund, Towns Fund, Levelling Up programme and recovery funds will provide the capacity to make change happen. Housing will be a key part of the future high street but it must be part of the overall community-led plan. Government is doing it all it can to encourage communities to take control of their futures and this proposal does exactly the opposite.
Putting ground floor housing in high streets does not draw footfall, does not support new businesses, reduces the potential for business growth and will undermine the viability of commercial activities on the high street. We also have major concerns about the impact this is likely to have on the real diversification of the high street, which would see healthcare, medical facilities, civic services, gyms, leisure facilities, education, co-working spaces, community hubs, life sciences and other innovations coming into town centres. All of which would support economic growth and centre vitality. Because of the E Use Class, all of these would be undermined by permitted development.
Applying permitted development in conservation areas will undermine their historic character at a time Government is funding 69 Historic Action Zones with £96 million of funding. These areas provide the towns with a distinct identity and offer. Permitted development risks making such places clone towns again.
Response on change of use
One of the other questions we have responded to was “Do you think that the proposed right for the change of use from the Commercial, Business and Service use class to residential could impact on businesses, communities, or local planning authorities? Our response is:
This would undoubtedly have a negative impact on business, communities and local planning authorities. The fragmentation of the high street would make high streets less of a destination and reduced footfall. This will affect trade resulting in job losses, lack of investment and may lead to further vacancies and hence a less attractive and viable town centre or local shopping parade. This is not just about retail. This will impact the health and wellbeing of local communities who could suffer through loss of valuable local health, nurseries, GP services, indoor sports and leisure facilities and community centres.
The local planning authority and its partners would lose its ability to plan positively and creatively for facilitating change and adaptation of town centres and high streets to respond to changing shopping and leisure habits. Changes to residential use would be irreversible, so any flexibility offered is only one way, leading to loss of potentially valuable mixed uses. The only people who will benefit would be property owners who are seeking the highest value for their property.
Government has long been very supportive of Business Improvement Districts, providing core funding of £6 million during lockdown. The conversion of commercial premises to residential will have a significant impact on the amount of levy available to BIDs. This could make many of them unviable further undermining the viability of town centres.
We hope that Government will consider all responses carefully and that this will be rejected.