Written evidence submitted by Institute of Place Management [PDR 043]
1 The Institute of Place Management (IPM) at Manchester Metropolitan University is the professional body and learned society for people who serve places. We represent professional place managers and leaders in local authorities, Business Improvement Districts, and other place partnerships, as well as consultants, academics and policymakers. We publish the Journal of Place Management and Development, an international, peer-reviewed journal and deliver post-graduate training programmes (including the MSc Place Management and Leadership). The IPM is the lead partner of the government-funded High Streets Task Force.
2 Material within this written submission has been contributed by IPM staff and Members. We are not a professional body for planners but rather draw perspectives from a range of professional place managers and leaders, and from academics in the field. We work closely with the Royal Town Planning Institute, through the High Streets Task Force, and anticipate contributing a complementary place-based view to other responses the inquiry receives from planning, development and property sectors.
3 With growing evidence that multifunctional centres have proven to be more resilient than other centres, it is important that plans for high street revitalisation embed non-retail functions, to consider leisure, commercial and residential uses, but also the development of non-retail attractions (health, education, public services), together with quality public realm and open-space. It is vital that councils are enabled to provide a co-ordinating function, to engage with local networks and partnerships and develop a shared understanding and vision for this place transformation. PDR reform could undermine local interests and make it more difficult for local, distinctive visions to be advanced with coordinated and place-appropriate development.
4 IPM was co-signatory of a letter to the Secretary of State on February 9 2021 setting out, along with a range of representatives from economic and place-based groups, our concerns about PDR and the contradictions with other, existing government policy and funding schemes (see, 5 & 6)
5 It is well-recognised by (Ministry of Housing, Communities and Local Government) that the best town centres do not just happen but require active coordination at a local level. The NPPF policies support this approach, as do the objectives of the High Streets Task Force and the guidance for both the Towns Fund and the Future High Streets Fund. Blanket permitted development rights for E Use Class to residential would damage these objectives for relatively minimal returns on additional housing stock.
6 We welcome Government recognition that our town centres must change, but an all-embracing permitted development right that allows most commercial buildings to be converted to housing risks puts the long-term health of our town centres at risk for the sake of a short-term stimulus.
What is the impact of PDR on the ability of local authorities to plan development and shape their local communities?
7 According to High Streets Task Force research, 8% more towns in England are now classified as ‘multifunctional’, compared to 2018. Multifunctional towns offer a wide range of functions and services; leisure, culture, education, health, retail, greenspace, and residential etc, and as a result are more resilient urban centres. This has been evident through the COVID-19 crisis as multifunctional places have retained more footfall and activity than other town types. The government high street inquiry (2019) identified that this transformation to multifunctionality was needed and should be “led by the local authority, using all its powers and backed by cross-sector collaboration”. PDR in its current form runs counter to this imperative for collaboration, allowing people and organisations to act unilaterally. Town centres remain an important part of British life, and high streets should be supported through policy to transition from shopping areas to multifunctional centres which contribute to social inclusion, education, leisure, culture and work. PDR puts this coordination and oversight at risk.
8 The consensus of IPM and its membership is that local authority oversight and coordination is required where conversion from commercial to residential in town centres is proposed. Retail uses in town centres are likely to contract in the years to come and conversion from retail to other commercial or community uses will be a feature of the times. However, conversion to residential uses at ground level can fragment town centres, reducing walkability which is a fundamental component of town centre vitality and viability (https://www.highstreetstaskforce.org.uk/frameworks/25-vital-and-viable-priorities/). It is very important that towns can concentrate their attractions (agglomeration) into a core so that they are pleasant and convenient to users. PDR puts the definition and maintenance of a town centre ‘core’ at risk.
9 It was very evident that existing Use Classes in town centres were becoming increasingly irrelevant and so we welcome much about the new Class E. However, we are concerned about some of the implications of this change for town centres. The breadth of Class E gives the potential to repurpose larger footprint gyms, offices and so on to retail uses outside of town centres without any consideration of the consequential impacts. In some circumstances, retail will continue to provide a greater return on existing uses and the revision has the potential to take more retailers (and other uses) away from the high street unless conditions can be placed on out of centre development to restrict the use to that applied for.
10 Putting ground floor housing in a random and uncontrolled manner within high streets does not draw footfall, does not support new businesses, reduces the potential for business growth and will undermine the viability of existing retail, cultural and commercial activities on the high street and remove convenience stores from local neighbourhoods. This will create a vicious circle whereby the reduced viability of the remaining commercial uses in turn threatens their existence and incentivises their conversion to residential.
11 Cultural venues are an important part of the multifunctional mix which towns and cities are encouraged to develop. PDR reforms provide no protection for cultural venues (beyond a temporary limit on change of use in response to COVID-19, until 2022). In the past 20 years, many venues been lost to residential conversion. In addition, the development of residential units alongside noisy activity, from clubs to bakeries to light industry, too often results in the permanent loss of such uses from our towns and cities due to resident complaints. We believe an entirely market-led system will have unintended consequences for town centre economies, with landowners dictating uses according to the greatest rental values. The Asset of Community Value scheme is not referenced in the recent Planning for the Future white paper and does not provide the scale of protection and oversight needed should change of use become widespread, driven by short- and medium-term commercial interest. There is also concern among those that work in the licenced trade that expanding residential will threaten late night licensing with no opportunity for the risks to businesses to be articulated through a planning process.
12 The conversion of commercial floorspace to residential will have an impact on local income generation necessary to fund the ongoing management and future regeneration of town centres. Local authorities rely on income from business rates and, in many areas, this is augmented by additional levy funding that is collected within a Business Improvement District and spent on local improvement and maintenance projects.
13 Our Members report a negative impact as control over the location, scale and phasing of new development is lost. Local Planning authorities are expected to manage such proposals without being resourced to do so via the normal process and fee generation from planning applications.
Is the government right to argue that PDR supports business and economic growth?
14 The Planning for the Future White Paper targeted a reduction the layers of bureaucracy which hamper development, and we welcome the policies which aim to modernise the system, including through digital transformation. However, while there are undoubtedly hold-ups in the planning system, no evidence has been presented in the paper or otherwise which illustrates the degree to which this is among the most significant barriers to development. In places up and down the country, land remains undeveloped, commercial space is left empty and absentee landlords allow buildings to deteriorate.
15 The new PDR regulations, without further oversight or protections, could lead to successful businesses being managed out of premises to enable developers to claim that a property, having been empty for 3 months, is now no longer viable as an E-class use. A requirement to prove that premises have been legitimately vacant for 3 months is needed, which includes aspects such as marketing the property and making reasonable efforts to secure a tenant.
16 At the neighbourhood level, we consider that local centres would be particularly at risk. The loss of local shops and services could precipitate their decline at a time when we are putting greater emphasis on the need for walkable neighbourhoods which provide a range of day-to-day needs in local centres.
17 In the white paper proposals, there is a conflation between the benefits of PDR to individual businesses and the overall business impact and effect on the long-term viability of town and city centres. Businesses need strong and effective planning which manages development in the overall public interest and provides necessary certainty for investment. This is not provided by PDRs.
What is the impact of PDR on the involvement of local communities in the planning process?
18 PDR, when taken with other planning reform proposal within the Planning for the Future white paper, means that there will be much less input at a local level over what happens when new development proposals come forward. There will be no planning applications where development is consented through the Local Plan. This will put significant pressure on communities and their place-based partnerships to influence new style Local Plans which will be statutorily required to be prepared in a very short time period. Many commentators believe the time period is unrealistic and that the intention to move engagement upstream of planning applications and allow no input at the delivery stage is unworkable. For any large development sites, this would entail trying to work out the conception and detailed delivery of a whole masterplan and all the associated planning applications in around 12 months with likely a single formal opportunity for engagement in a draft plan. This approach fails to acknowledge the rapid pace of change in many places.
Should the government reform PDR? If so, how?
19 It is our belief that PDR in its current form and the previous white paper’s stated aim to “help businesses to expand with readier access to the commercial space they need in the places they want and supporting a more physically flexible labour market” provide insufficient consideration of commercial centres. The planning system must be designed to recognise the important interconnections between housing and commercial land use, particularly as the way people live, work, shop and spend their leisure time is so rapidly changing. Town centres are currently facing a significant, perhaps existential, economic challenge. This challenge requires considered, evidence-based intervention at a local level to ensure our high streets meet the needs of the 21st century. Without the tools provided through the planning system to do this, town centres will continue to decline, leading to job losses, hollowed out high streets and unsustainable places.
20 We believe that PDR will lead to the dilution of commercial centres. There should therefore be a requirement for local planning authorities to assess the requirement for employment land as well as housing needs assessment, and to ensure that this is delivered.
21 A Register of Beneficial Interests (rather than the proposed register of ownership), as proposed by the 2019 MHCLG Select Committee, would enable places to track down absentee landlords and engage them in dialogue.
22 Local Planning Authorities’ CPO powers should be strengthened to provide recourse where buildings are dilapidated, and to tackle land banking, where it occurs.
23 As mentioned in paragraph 15, a requirement to prove that premises have been legitimately vacant for 3 months is needed, which includes aspects such as marketing the property and making reasonable efforts to secure a tenant.
24 As we recognise in the preface, we are not planners by profession – we represent place managers and leaders, from local government, the business and wider community. However, we see that a specific focus on town centres and how they can be supported, to develop rather than atrophy, is required through PDR and the wider planning system. As we have previously proposed, we would welcome the opportunity to contribute to this broader discussion, perhaps via a working group including The Institute for Place Management, Royal Town Planning Institute and Royal Institution of Chartered Surveyors.