Class Q prior approval: assembling the submission

A Class Q prior approval submission is refused more often for missing evidence than for bad design. The council has 56 days, it can only consider the matters the Order lists, and if the structural position or the agricultural history is not proven on the papers, the answer is no. Assembling a Class Q prior approval submission is therefore a document exercise as much as a design one, and the order in which you build the file matters.

Confirming the building qualifies

Class Q sits in Part 3 of Schedule 2 to the Town and Country Planning (General Permitted Development) (England) Order 2015, and it permits the change of use of an agricultural building and land within its curtilage to dwellinghouses, together with the building operations reasonably necessary to convert it.

The gateway tests come first, and any one of them ends the matter.

• The building must not be listed, and must not be a scheduled monument.
• The site must not be on article 2(3) land, which takes out conservation areas, National Parks, National Landscapes and World Heritage Sites.
• The building must have been in agricultural use as part of the relevant qualifying period set by the Order.
• The scheme must sit within the numerical limits on dwellings and floorspace.

Class Q was amended with effect from 21 May 2024, and the current limits allow a larger number of dwellings and a higher total floorspace than the original version, with a cap on the size of each individual dwelling. Read the consolidated Order on legislation.gov.uk before you rely on any figure, including one quoted in an older article or a planning consultant's template, because the thresholds and the qualifying date have both moved.

Evidence of the agricultural use history

This is the part landowners underestimate. An assertion that the building "has always been agricultural" carries no weight. What works is a bundle:

1. Rural payments or subsidy records naming the holding and the relevant years.
2. Invoices for feed, fertiliser, seed, livestock or contracting work referable to the building.
3. Veterinary records or movement records where livestock were housed.
4. Dated photographs showing agricultural use, ideally with machinery or stock visible.
5. Aerial imagery from the relevant years.
6. A statutory declaration from the owner or a former farm manager, setting out the history in dates.

Where the building was let, the tenancy agreement and rent records do useful work. Where the use ceased some years ago, say so plainly and address the qualifying date directly rather than hoping the officer does not check.

The structural report and what it must show

Class Q allows conversion. It does not allow rebuilding dressed as conversion, and that distinction has been the subject of appeal and High Court consideration. The practical consequence is that the building must be capable of taking the conversion works without substantial reconstruction.

A structural appraisal should state the existing construction, frame type and condition, the foundations as far as they can be established, whether the frame can carry the loads of the proposed roof, floors and openings, what remedial work is needed, and a clear statement that the building is capable of conversion. Where a new frame, new foundations and new walls are needed, the honest conclusion is that Class Q does not apply and a full application for a replacement building is the route.

Keep the engineer's drawings consistent with the architect's. A Structural Survey that describes a steel portal frame while the proposed sections show new blockwork carrying the roof is the inconsistency officers notice first.

Drawings of existing and proposed

The drawing pack should leave nothing to inference. Include a site location plan with the red line and the curtilage identified, a block plan showing the building, access, parking and any residential curtilage proposed, existing plans and elevations measured on site, proposed plans and elevations at the same scale, and a demolition drawing showing exactly which elements of the existing fabric are removed.

That last drawing is the one that decides borderline cases. Shade what stays, shade what goes, and give the percentages of external wall and roof being retained. An officer who can see that 85 per cent of the frame and envelope is retained has an easy decision to make.

Design and external appearance

Design is one of the matters for prior approval, so it is assessable, but the test is narrower than in a full application. Officers are looking at whether the external appearance is acceptable in its rural context rather than applying the whole of a design guide.

What tends to work on a former agricultural building is restraint. Keep the large openings where the doors were, use recessed glazing rather than flush, keep materials simple and agricultural in character, avoid domestic detailing such as fake shutters and porches, and keep the curtilage small and undemonstrative with a simple gravel yard rather than a suburban garden with fencing and ornamental planting.

A short statement explaining those choices helps. It does not need to be a full Design and Access Statement, which is not required for prior approval, but two or three pages setting out the approach to the elevations, materials and curtilage is worth writing.

Transport, flooding, noise and contamination information

The Order lists the matters the council may consider, and each needs a proportionate answer in the file.

Two of those are the usual killers on working farms. Noise and odour from the adjoining agricultural operation can make residential use unsuitable, and a grain drier 20 m from a proposed bedroom window is a genuine problem rather than a drafting one. And a site in Flood Zone 3 will usually need a Flood Risk Assessment and may still fail.

Where the visibility splay cannot be achieved from the existing farm access, a Transport Statement showing what can be achieved, with the land available to deliver it, is better than silence. Where fuel tanks, a workshop or asbestos sheeting are present, a desk study referencing a Land Contamination Phase 1 approach is proportionate, and land contamination work requires a suitably qualified and experienced person under the standards councils apply.

Fee, forms and the determination period

The application is a prior approval application submitted with the prescribed fee, which is indexed, so check the current fee schedule rather than an old figure. The determination period is 56 days from the day after a valid application is received, and if the council fails to determine within it, the development may proceed subject to the Order's conditions.

Three procedural points worth knowing. The council will consult neighbours and the parish council. It can request further information, and the 56 days does not restart, so a file with gaps is a file that runs out of time. And a refusal can be appealed, with the appeal considering only the matters the Order permits.

Build the bundle in this order: gateway checks, agricultural history evidence, structural appraisal, measured survey, drawings including the demolition drawing, then the technical notes on transport, noise, contamination and flooding, then the short design statement. A Planning Statement pulling those threads together in six or seven pages makes the officer's report easy to write, which is the outcome you want.

This is general guidance, not legal advice; permitted development rights change, and the position should be checked against the current Order and with your local planning authority or a qualified professional. A lawful development certificate is the only formal way to confirm that works or a use are lawful. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.