Recommendation 97

This inability to control the loss of retail frontages altogether could result in ‘gap-toothed’ high streets. . 183 Interspersing town centres with “dead” retail frontages “may actually reduce the attractiveness and retail footfall rather than enliven it.” 184 The then Government was aware of these risks when expanding PDRs in February 2024. In July 2021, the then Secretary of State for Housing, Communities and Local Government announced a higher threshold for converting commercial units to residential use, describing the “loss of the essential core of a primary shopping area which would seriously undermine its vitality and viability” as “unacceptable”. 185