Recommendation 92

We heard concerns, including from Lords Minister for Housing and Local Government, that the introduction of such a broad Use Class has made it more difficult for local authorities to apply frontage policies to their high streets and has “resulted in lots of the same types of occupants in small areas”. 169 One student told us that the replacement of empty units with offices in their home town meant that “it doesn’t have a high street anymore”. 170 In Epsom, the introduction of Use Class E undermined its town centre planning policy which was protecting retail frontages and had been credited with helping to regenerate the town centre. 171 The council had been maintaining a specific mix of uses on the high street to ensure retail vibrancy, but it concluded this was not possible following the introduction of the new Use Class. 172 Furthermore, RICS and Brighton and Hove City Council noted that the introduction of a single Use Class could inadvertently lead to out-of-town commercial centres such as offices being converted into retail outlets, which compete with the high streets and are not subject to the sequential tests required for new out-of-town retail development. 173