We have just under two weeks until MHCLG's consultation on Class E to Resi PD Rights closes.* Given the impact those proposals could have on English High Streets, yesterday's launch of KPMG's Report "The future of towns and cities post Covid-19" feels very timely. 

The Report states that the pandemic has accelerated underlying trends in our economy, which are unlikely to recede entirely after the pandemic subsides. In particular, the growth of online shopping and the increased prevalence of home-working are likely to stay, even after the vaccination programme has reached a point where the current restrictions have been lifted. 

As a result, the Report predicts the possible loss of up to 400,000 retail jobs in England; concluding that:

"As we leave the pandemic behind, hopefully sometime in 2021, towns and cities across the UK will need help and space to rethink the purpose of their centres. High streets will need to be reimagined as cultural and recreational hubs that will act as magnets for businesses and jobs able to transform less prosperous areas."

The introduction of Class E, last summer, is likely to help high streets and commercial areas adapt to the changes imposed by the pandemic - as planning permission is no longer required to move between any of the following uses:

  • shops, 
  • financial & professional services, 
  • restaurants & cafes, 
  • offices and light industrial uses;
  • indoor fitness and recreation;
  • medical or health services; and
  • day nurseries.

That said, the help that this flexibility and ease of movement between Class E Uses can provide to high streets, and commercial areas, is likely to be significantly undercut if the proposed PD Right to Residential is introduced in its current form. 

As currently envisaged the proposed right is not limited to high streets or former shopping areas and lacks size restrictions, or even a requirement that the relevant unit has been vacant for any period of time before the PD Right is invoked. It also has a very light touch prior approval regime, which would not allow Councils to take into account the impact of the change to residential on the viability or vitality of the wider area (which is currently the case for the existing PD rights from retail to residential use).  

Whilst nobody denies that residential uses have a key role to play in reinvigorating our high streets and city centres, the mix of residential, retail, cultural and leisure uses needs to be carefully managed if we are to achieve the kind of transformation that the KPMG report calls for. Too much of any one type of use would leave our town centres vulnerable to falling footfall and an over-reliance on specific sectors of the economy. A mix which the current pandemic has clearly demonstrated to be unsustainable.  

If you haven't already responded to the Class E consultation, I recommend you do so. The consultation closes on 28 January

* A deadline that I am keenly aware of; as I am half way through our own consultation response.