Change of use with no building work: what to submit

A change of use application with no building work still needs drawings, and the usual change of use application drawings are an existing floor plan, a proposed floor plan and a site location plan with the application boundary edged in red. Councils reject applications without them every week, and the reason is structural rather than bureaucratic: the permission that gets granted is a permission for a defined use within a defined planning unit, and only drawings can define either of those things.

Why the council still wants drawings when nothing is being built

A planning permission has to be capable of being enforced. If a permission says only change of use from Class E to a children's day nursery, nobody can later say whether the nursery that has spread into the rear store room is operating lawfully.

Drawings answer three questions the decision notice cannot answer on its own. What land and buildings does the permission cover. What use is proposed in each part of that space. What is the relationship between the primary use and anything ancillary to it.

The approved plans condition then ties the permission to those drawings, which is why the drawing numbers and revision letters matter as much as the lines on them.

Existing and proposed floor plans

Two plans, drawn to the same scale and oriented the same way, at 1:50 or 1:100 for most commercial units.

The existing plan shows the lawful use as it stands, room by room, with areas annotated. Label the ground floor sales area, the back of house, the staff WC, the store and any first floor space, and give each a figure in square metres. If part of the building is currently in a different use, show the boundary between them.

The proposed plan shows the same space with the new arrangement and the new labels. Mark which areas serve the primary use and which are ancillary, because that distinction is what a future enforcement officer will rely on. Where the proposal introduces a mezzanine, additional floorspace appears even though no external building work does, and that can change the fee and sometimes the use class position.

Keep the two plans honest about what stays. An existing plan redrawn optimistically to show a tidy rectangular unit that is not what is there will be compared with the officer's site visit photographs.

The site plan and the planning unit

The site location plan is normally at 1:1250 in an urban area or 1:2500 in a rural one, with a north point, a scale bar and at least two named roads visible.

The red line is the substantive part. It should enclose exactly the land to which the application relates, which is the planning unit as you propose it will be. Two errors recur. The first is drawing the red line around the whole building when only one unit within it is changing use, which overstates what you are applying for. The second is leaving out land that the new use will actually rely on, such as a yard used for storage, a bin area or an external seating area, which produces a permission that does not authorise part of what you intend to do.

Land you own or control nearby, but which is not part of the application, goes in a blue line. Where a single unit is being divided, the boundaries need more thought than a change of use within existing walls, and our note on splitting a commercial unit into two sets out how the planning units are then defined.

Supporting statements that change the outcome

For a straightforward change of use within a town centre, a short statement covering the proposal, the policy position and the operational detail is enough. A Planning Statement earns its place where there is a policy obstacle to deal with, and there usually is.

The common ones, in rough order of how often they bite:

• A main town centre use proposed outside a defined centre, which triggers the sequential test and, above the threshold in national policy or a lower local threshold, an impact assessment
• The loss of a protected use, such as employment floorspace in a designated employment area, a community facility in Class F2 or a ground floor retail frontage in a primary shopping area
• Residential amenity, where the new use operates in the evening or generates servicing movements next to housing
• Highway safety and parking, where the new use has a different trip profile from the old one

Each of those is answered with evidence rather than argument. The sequential test needs a documented search of alternative sites with reasons for discounting each. Amenity needs measurements. Parking needs a count or a credible trip comparison.

Operational detail, and why to volunteer it

The conditions on your permission will be drafted from whatever operational detail is in front of the officer. Supply none and you get a restrictive condition written defensively.

Set out the hours you want to open, the number of staff, the expected customer numbers, delivery frequency and vehicle sizes, the waste storage and collection arrangements, whether plant is proposed and where, and whether anything happens outside the building. If the use involves cooking, extraction becomes part of the application even with no building work, because the duct, its termination point and its abatement all have to be specified, and a Ventilation and Extraction Statement is what environmental health officers read.

Ask for the hours you need, not the hours you think will be granted. Varying an hours condition afterwards means a fresh application and a fresh consultation, as our piece on varying an opening hours condition explains.

The validation items that catch people out

The lawful use point deserves emphasis. Your application describes a change from an existing use, and if the existing use was never authorised, the application is built on sand. Check the planning history on the authority's register before you describe the current use, and if it is unclear, consider a certificate of lawfulness of existing use or development under section 191 of the Town and Country Planning Act 1990 first. A Lawful Development Certificate is the only formal way to confirm that an existing use is lawful.

Where the local list differs from the national one

The national information requirements come from article 7 of the Development Management Procedure Order 2015 and apply everywhere. Each authority then publishes a local list of additional requirements, and those lists are where the surprises live.

Local lists commonly add a parking and servicing statement for any town centre change of use, a noise assessment for any evening use near housing, an odour and extraction statement for any food use, a waste and recycling statement, and a statement addressing the loss of the previous use where a protection policy applies. Some authorities add a flood risk sequential test for a change to a more vulnerable use even on a small site.

Download the list for your authority and work through it line by line before submitting. It takes twenty minutes and it is the difference between validation in three days and validation in three weeks. If you want to see which supporting documents your particular site and use are likely to need, enter the postcode on PlanScope and work through the constraints first.

This is general guidance, not legal advice, so check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.