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The High Street isn’t dead, long live the high street #5 - the Post-COVID “new norm”?
The Government’s latest retail sales figures show encouraging signs of recovery since lockdown, but what do the figures tell us about the future and the most likely “new norm”?
In the past consumer expenditure has grown consistently in real terms (over and above inflation) over the long term. This growth has fuelled the demand for new retail floorspace. Average retail expenditure per person in the UK grew by about 16% between 2009 to 2018 (Experian), despite the impact of the last recession i.e. 1.8% decline between 2009 and 2012. However, beyond this headline growth, home shopping accounts for much of this growth rather than in-store shopping. Expenditure growth per person attracted to traditional bricks and mortar retail was only 5% between 2009 to 2018, as a result demand for new retail floorspace has been sluggish during the last decade.
The short-term impact of the COVID-19 crisis is becoming clearer but the longer term structural implications are harder to predict. In the short term, operators have faced cash flow issues and increased costs arising from a slump in consumer demand and disruption to supply chains. Non-essential products, hospitality and leisure services have been hardest hit. Some retailers able to fulfil on-line orders/home delivery are benefiting at least in the short term from enforced changes in habits. There is likely to be a longer term structural shift to on-line shopping, reducing the demand for physical space within town centres. Following the COVID-19 furlough arrangements there is likely to be a spike in vacancies and some centres may struggle to fully recover. Some centres will need to explore opportunities beyond retail.
Office of National Statistic (ONS) monthly sales volume information for Great Britain indicates total retail sales volumes had recovered to previous levels of growth but the proportion of retail sales spent on-line is likely to represent a higher proportion of total sales, which will have an impact of traditional bricks and mortar retailing.
Retail sales volume fell by 22% in April 2020 during the start of lockdown. However, post lockdown sales during July and August recovered to pre-lockdown levels, with the August figure now 4% higher than the February figure. During lockdown on-line retail sales peaked in June at over 62% higher than pre-lockdown levels. On-line sales remain high at about 50% above normal levels.
Excluding on-line sales, the latest sales figures suggest bricks and mortar retail trade is still 6% down on pre-lockdown levels. This 6% reduction may not fully reflect the implications of the expected economic downturn, particularly after the furlough period ends in October. A challenging period for town centres and some operators over the next 3 to 5 years now seems likely, but these effects will not be evenly distributed.
The comparison goods (non-food) sector has been particularly affected with a 50% drop in sales from February to April, whilst the food sector experienced 10% growth in sales during March, in part due to panic buying at the start of the crisis. Food sales volumes have been consistently higher since February, benefiting from reduced trade in restaurants, cafés, pubs and bars.
The year to date sales figures (January to August) are down by -4.8%. Food stores achieved +4.4% growth compared with -18.2% reduction for non-food retail, with clothing and footwear the hardest hit at -30.1%. The continuation of these trends suggest higher order fashion shopping destinations could suffer most from the surge in on-line shopping. Lower order centres focusing on day-to-day essential items and services have, and should continue to recover more quickly.  
This trend is evident from the Centres for the Cities’ high street recovery tracker which monitors footfall and spend across cities and large towns. Large city centres have been slow to recover with many centres still 30% or more down on footfall and spend during the last week of August compared with pre-lockdown levels. The worst affected city centres in terms of footfall include: London (-69%), Manchester (-51%), Birmingham (-48%), Leeds (-43%) and Nottingham (-41%). These large centres have been the hardest hit due to increased home working and loss of international tourism. As a consequence of increased working from home, these headline figures for larger cities mask increased footfall within many local, district and town centres: which have seen a resurgence in footfall as people work and spend locally. Many satellite towns and seaside resorts have benefitted from home working, staycations and more customers shopping locally. The best performing towns include: Blackpool (+41%), Bournemouth (+33%), Birkenhead (+24%), Southend (+16%) and Chatham (+15%). This is likely due to the differing roles that high streets have in smaller towns. Where footfall has previously been driven by destination retail (for example the Bull ring in Birmingham or Oxford Street in London) or by office generated footfall, for example Leeds or the City of London, high streets have lost their customers during lockdown and the shift to working from home. In smaller towns, and local centres however there is evidence of customers returning, following the eat out to help out scheme and the benefits of being able to shop locally.

Source: Centres for Cities footfall data for 13 February – 1 September 2020

Some rebalancing from large to smaller centres will be welcomed in many areas, following the extended period of polarisation towards the most successful regional shopping destinations. This rebalancing could be sustained if, for example, increased home working continues. Town centres ability to retain market share and compete with on-line sales will be critical for the vitality and viability of town centres in the post-COVIDnorm. Town centres will need a coherent recovery strategy to have the best prospects of flourishing. Continued repurposing of retail space is inevitable due to the likely spike in vacancy rates and recent changes to the Use Class Order allowing more flexibility for changes of use.
Other blogs in this series:


The Local Plan Transition – From the NPPF (2019) and the Standard Method to a new White Paper Planning System

The preparation of local plans in England has become a ‘little’ more complicated in recent weeks (if it ever needed more complexity?). A new planning system is on the horizon, following the publication of the planning White Paper ‘Planning for the Future’. Shorter term changes are also proposed to the Standard Method for calculating local housing need, which has received much publicity recently[1] and Lichfields has already crunched the numbers and considered the different figures at a local level. While some of the output figures are on the high side (i.e. Westminster), other figures are surprisingly low (i.e. Liverpool).

For plan-making though, the combination of proposed introduction of a new Standard Method and a wholly new planning system really has thrown the cat amongst the pigeons. Each LPA will need to take stock and work out its next move. Will it be decided to have a ‘White Paper’ Local Plan, to try and rush through a NPPF (2019) Plan or even try to game the system?

This blog maps out the ‘plan-making’ road ahead: considering both the transition to a new planning system in the long term and a new standard method in the short term. Inevitably, this is a complex topic and just the transition itself will be complicated. We look to cut through the complexity here and to consider how LPAs might react in response to their different circumstances. There is some background to the different transitional arrangements, but if you already have some knowledge then you might want to skip ahead:





The Road Ahead: White Paper Plans and the Standard Method 2

A new ‘White Paper’ planning system

We know that a new planning system is coming, underpinned by new legislation. We have looked at the proposals in-depth here. For this blog, the key thing to know is that the Government wants to give each LPA a binding housing requirement to plan for. This will take into account both housing need in an area (i.e. what the Standard Method currently provides) and relative constraints (or lack of) – i.e. a ‘policy on’ requirement[2]. Crucially, there is also an expectation that at least some ‘White Paper’ Local Plans will be adopted before the end of this Parliament and the next election in May 2024[3].
There are proposed transitional arrangements in terms of moving from the current system to the new ‘White Paper’ planning system[4]. Under the proposals, each LPA would have a statutory duty to prepare a new ‘White Paper’ Plan:
  • 30 months from new legislation coming into force for any LPA without a local plan adopted in the previous three years;

  • 42 months from new legislation coming into force for any LPA with a local plan adopted in the previous three years; or

  • 42 months from adoption of a current local plan that was submitted for examination prior to the new legislation becoming in force.
Working backwards, the new planning legislation will need to be in force by the end of September 2021 at the very latest, to enable a ‘White Paper’ Local Plan to be adopted before the end of Parliament. This takes account of a 30-month statutory deadline for LPAs without a Local Plan adopted in the previous three years and pre-election Purdah (following the dissolution of Parliament on 28th March 2024).

Standard Method 2

The proposed changes to the standard method are independent of the White Paper proposals and are described as ‘short term’. Looking back at previous changes to the NPPF (2018), a consultation commenced at the end of October 2018 and changes were published in mid-February 2019 – c. 4 months. On this basis, we could be looking at ‘Standard Method 2’ being in place before Christmas. However, to simplify our road map, we have assumed that the PPG is updated with the new ‘Standard Method 2’ on 1st January 2021 (a new year’s treat).
Transitional arrangements are proposed in the plan-making context (key to note that similar arrangements are proposed for five-year housing supply) to move us from the current ‘Standard method 1’ to the ‘Standard Method 2’. These are:
  • If an LPA has already undertaken a Reg.19 consultation, it has six months from the adoption of ‘Standard Method 2’ to submit its new plan for examination – by our timescales this would be the end of June 2021.

  • If an LPA hasn’t undertaken a Reg.19 consultation by the adoption of Standard Method 2, the LPA has three months to do so (i.e. by the end of March 2021) and then has a further six months to submit the plan for examination – i.e. the end of September 2021.

The ‘plan-making’ road map: the transition from the NPPF (2019) to a new planning system

The roadmap identifies a rough timetable for the adoption of ‘Standard Method 2’ and the new White Paper planning system. Obviously, this is based on a number of assumptions, including that the proposed transitional arrangements are implemented as proposed.

How might LPAs react

The circumstances for each LPA will be unique with politics likely to play a large role. However, there are some clear groupings in terms of potential outcomes.

Group 1: Those with a plan adopted within three years of legislation coming in to force

Taking a White Paper legislation ‘in force’ date of September 2021, for LPAs who have adopted a Plan since September 2018 (or will likely go on to adopt a plan from now up until that date) we can assume that its next Local Plan will be in accordance with the new White Paper legislation. Some with Plans on the boundary of September 2018 may be a little nervous as they could just fall through the cracks. 
In any case, these authorities will then have 42 months to adopt said ‘White Paper Plan’: c. March/April 2025. Currently, there are only 59 LPAs that fall into this category. A list of these is included at the end of the blog.

Group 2: Those LPAs without a plan adopted within three years of legislation coming into force

The vast majority of LPAs currently fall into this group. The LPAs with Local Plans not already at Examination will be under a pressure to progress with plan-making under the current system and may well already be deep into plan-preparation. These LPAs have an incentive to adopt an NPPF (2019) compliant plan ahead of the new legislation. The incentive being an additional 12 months to prepare and adopt a future ‘White Paper’ Local Plan following the ‘in force’ date.
How each LPA will react in plan-making terms will most likely hinge on its proposed ‘Standard Method 2’ figure:


LPAs with a Standard Method 2 figure above the current standard method

Similar to previous transitional arrangements from the 2012 to the then 2018 NPPF, the new standard method might be the nudge to get on with plan-making for LPAs in this situation. You may recall a flurry of LPAs submitting local plans just before the transitional deadline to the 2018 NPPF. Missing this deadline would have meant that these LPAs Plans would have to be assessed against the then new Standard Method 1 (subject to constraints) instead of their own assessed housing needs.
These LPAs may, therefore, attempt to ramp up plan-making to adhere to transitional arrangements in order to submit a ‘Standard Method 1’ plan; thereby banking a lower housing requirement in the short term and buying more time to make a ‘White Paper’ Local Plan in the longer term. Many LPAs will already have spent many years investing in a new Local Plan with residents and businesses inputting throughout – so it only seems fair that they may take this route. Therefore, expect a flurry of Reg.19 consultations either side of the new year, with Plan Submissions to the Secretary of State following in the summer.
It may take a year or so from Submission of a Local Plan to its adoption: c. Summer 2022. From that point on, each of these LPA would have a further 42 months to prepare a ‘White Paper’ Local Plan – likely to be some time towards the back end of 2025 or 2026. This would give plenty of time to work out how to tackle whatever requirement figure the Government will mandate and gives time for the new system to bed in.
Of course, it is also worth noting that missing the ‘Standard Method 2’ transitional arrangements for these LPAs could have major plan-making implications. There is unlikely to be time to account and plan for a higher Standard Method 2 target, so many of these LPAs may have to wait for the White Paper system to come in to force and prepare a new Plan within the 30-month deadline.

LPAs with a lower Standard Method 2 figure

As a starting point, there will be many – most likely northern – LPAs with, what would appear to be rather low Standard Method 2 figures, when judged against said LPAs ambitions for housing and the ‘Standard Method 1’ outputs. These LPAs may simply ignore the ‘Standard Method 2’ figure even if they miss transitional deadlines and plan for a higher target; akin to the ‘Standard Method 1’ or even go further above that to meet housing/economic ambitions.
A cynic, though, could see a situation arise where an LPA is struggling to meet the Standard Method 1 figure, or is doing so begrudgingly (against local opposition) and, in such cases, these authorities may deliberately wait for the ‘Standard Method 2’ transitional arrangements to pass. That LPA could then subsequently submit a Local Plan for examination – using the ‘Standard Method 2’ as its basis of local housing need – just prior to the White Paper legislation ‘in force’ date. With examination of the Submitted Plan, plus a 42-month timescale to prepare a ‘White Paper’ Local Plan, these LPAs would buy themselves some breathing time to prepare for whatever the Government mandated requirement is further down the line. For these LPAs, they might adopt ‘White Paper’ Plans at the back end of 2025 or early 2026.

And for those LPAs willing to wait it out?

The above has assumed that LPAs will mainly want to have an NPPF (2019) Plan adopted ahead of the new White Paper legislation. This is chiefly to buy themselves time in the transitional measures to adopt a new ‘White Paper’ Local Plan: i.e. having 42-months (the carrot) instead of 30-months (the stick). But what about those who, by design or circumstance, become the early adopters of the new planning system?
For LPAs who are already struggling to plan for the ‘Standard Method 1’ figure, or where they are highly constrained, or where the Standard Method 2’ is also higher - waiting could, arguably, be in their favour. This would depend on the politics of the area, but it’s not hard to imagine an authority with Green Belt/AONB and vocal residents, where holding off plan-making under the current system would be a significantly less controversial option. Given that the White Paper proposes that LPAs will have a housing requirement dictated to them which specifically accounts for constraints, these LPA may decide to hold fire and chance a lower figure later down the line for its ‘White Paper’ Local Plan.
There will also be some LPAs who are in early plan-preparation stage, with less time and money invested, who might just wait. Why spend lots of local authority money on a Plan now, when there will be a statutory duty to prepare one within 30-months - potentially starting from Summer next year?
However, waiting for the new White Paper legislation also brings with it considerable risks and unknowns. A constrained LPAs housing number could well go up, as well as down. There could be delay in the legislation coming forward with legal challenges – leaving LPAs without an up-to-date local plan. This is also a new system after all, that is highly likely to have teething problems.
Finally, there is also the December 2023 deadline for all LPAs to have an ‘up-to-date’ local plan to consider. There was nothing in the White Paper regarding this deadline, nor any recent comments regarding it by Ministers. Assuming it is still in place, waiting to prepare a ‘White Paper’ Plan would mean missing this deadline. We don’t know what measures the Secretary of State would take in these circumstances.


There are many unknowns and permutations in our roadmap set out above. The introduction of the ‘Standard Method 2’ arguably makes the transition to a new planning system more complicated but may also result in some LPAs working quicker to bring about emerging plans. For those LPAs who end up waiting for the White Paper legislation to make their next Local Plan, there are significant risks and unknowns and so the question is whether local politicians will be willing to take the risk of the unknowns?
The only thing that is clear is that the transition from the current to the new plan-making system will complex. We will need to wait and see what comes out of the consultation process but in the run up to Christmas and over the next few years in general local plan life will be complicated. We will all need to be monitoring local circumstances carefully and consider how these interact with changes to national policy.
Of course, who could be better placed than Lichfields to help in this regard. Follow our blog for upcoming updates on what the various consultations means for local regions across the country. Also, contact one of our local offices if you have a more detailed query.
LPAs with a plan/review/DPD adopted since September 2018. LPAs that have adopted joint plans are individually listed below.

Housebuilding algorithm will lead to more developments in Tory areas, Johnson warned
[2] Lichfields: Grow, Renew, Protect: The White Paper - ‘Top Down’ Housing Requirements
[3] Paragraph 6.3 of the White Paper[4] As detailed at Paragraphs 2.50 & 2.51 of the White Paper.