Employment Land Assessment outline for a loss of use
Applications to lose employment floorspace are decided on marketing and demand evidence. This outline sets out each section and what has to sit behind it.
An employment land assessment outline supporting the loss of employment floorspace has one job: to show that the site is no longer needed, or no longer suitable, for the use the development plan protects. Councils refuse these applications on evidence, not on principle, and the evidence that carries the argument is marketing and demand. Everything else in the document supports those two sections.
Most adopted local plans contain a criteria-based policy for the loss of employment land. Read it first and structure the report to answer each criterion in the order the policy states them. Officers write their reports against policy wording, and a document that mirrors it is easier to agree with.
The policy that protects the use
Open by identifying the designation precisely. A site inside an allocated employment area is a different proposition from an unallocated industrial building in a residential street, and the policy hook differs accordingly.
Set out the relevant development plan policies with their numbers, the supporting text, and any employment land review or economic development needs assessment that sits behind them. Where the evidence base is old, say so with its publication date. A plan adopted on the back of a needs study from a previous decade is a legitimate point to make, provided you make it factually rather than dismissively.
National policy expects planning to help create the conditions for business to invest and adapt, and it also expects planning policies to avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. That second limb is the sentence the whole report is aimed at. Cite the current edition of the Framework by its policy reference and check the wording at the time of writing, because it has been re-issued more than once.
Describing the site and testing its suitability
A suitability appraisal is a factual description plus an honest judgement. Cover the building fabric and its condition, eaves height, column spacing, floor loading, service yard depth, turning provision for articulated vehicles, power supply, access geometry and the width of the approach roads.
Then set that against what the market actually occupies. A 1960s two-storey factory with four metre eaves and no yard is not competing for modern logistics demand, and it is fair to say so with measurements rather than adjectives.
Photographs help here more than prose. Cover the approach, the access, the yard, the internal volume, the roof structure and any obvious defects, and reference them to a location plan.
Where the constraint is a neighbouring sensitive use, deal with it directly. An industrial unit hemmed in by housing with hours conditions restricting it to weekdays has a limited occupier pool, and environmental health complaint history, if the council will release it, is sourced evidence rather than assertion.
Marketing evidence and how long is long enough
Most policies specify a marketing period. Twelve months is common and twenty-four appears in tighter authorities, so check the policy and the supplementary planning document before the agent starts rather than after.
What a council looks for in the marketing evidence:
- Instruction of a commercial agent with genuine coverage of the relevant market, with the instruction letter and its date.
- Particulars published and dated, with the quoting rent or price and the terms offered.
- Evidence of the channels used: the agent's own site, the main commercial property portals, boards on site with photographs and dates, and direct approaches to known occupier requirements.
- A schedule of enquiries with dates, the nature of each enquiry, and the reason it did not proceed.
- Any offers received, with the terms and the reason they were not accepted.
The two failures that sink otherwise sound cases are a quoting price set above the market, and marketing for the wrong use. Price the unit at a level a surveyor would defend, keep the evidence of how that level was set, and market it for the range of uses the policy protects rather than only the current one.
A period that spans a market disruption invites the response that the test was run at the wrong time. Acknowledge that and extend, rather than leaving the officer to make the point.
Demand evidence for the locality
Marketing shows what happened to this unit. Demand evidence shows the wider context, and the two together are what make the argument.
Draw on the authority's own employment land review, the local economic strategy, published vacancy and availability figures for the relevant use class in the district, and the agent's commentary on comparable stock and its absorption. Where a neighbouring allocated site is being delivered with modern floorspace, that is directly relevant to whether this building is needed.
Name the source and the date of every figure. Unattributed market commentary carries no weight at appeal, and an officer cannot reasonably rely on it in a committee report.
Testing alternative employment uses
A policy test for the loss of employment land usually requires the applicant to show that no other use within the protected class is viable, not merely that the current use has ceased.
Work through the realistic alternatives in turn: light industrial, storage and distribution, trade counter, self-storage, flexible workspace, and where the policy permits it, other main town centre uses. For each, say what the building would need, what that would cost, and what the resulting rent would have to be. Where the cost of conversion exceeds the value it creates, an appraisal makes the point in a way prose cannot, and the discipline is the same as the one set out for a viability appraisal inputs schedule.
Refurbishment for continued employment use deserves a fair hearing in the report. If you dismiss it in one sentence, the officer will commission their own view of it.
Weighing the benefits of the proposed use
Set out what the proposal delivers, with numbers where they are real: units by size and tenure, affordable housing provision, construction employment, any employment floorspace retained or reprovided, and the removal of a source of amenity conflict.
Where jobs are being lost, quantify them honestly and compare like with like. An Economic Impact Assessment can do this properly on a larger scheme, with construction and operational effects separated and the net position stated.
Do not overclaim. A report that treats the loss of twenty jobs as a benefit because the new use generates spending has told the officer how to read the rest of it.
Landing the policy test
The closing section should restate each criterion of the policy and answer it in a sentence or two with a cross-reference to the section of the report that supports the answer. That is the part an officer can lift into a committee report, and making it easy to lift is the point.
Keep the structure tight. A typical Employment Land Assessment for a loss of use runs to perhaps thirty pages with the marketing schedule and photographs in appendices, and the argument should be legible without them.
One honest caveat. Marketing evidence is the part of this report that cannot be drafted in advance of the work being done, and no amount of structure compensates for a twelve-month campaign that was never really run. Start the marketing, then write the report, then submit. The order matters more than the wording.
A Planning Statement then carries the wider planning balance, with the employment land assessment sitting behind it as the technical evidence.
Browse the 66 PlanScope report types to see how an employment land assessment fits alongside the rest of the submission. This is general guidance, not legal advice; 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.
Frequently asked questions
How long does the marketing period need to be?
Check the adopted policy and any supplementary planning document, because the period is set locally. Twelve months is common and twenty-four months appears in authorities with tight employment land supply. Start the marketing before you write the report, since a campaign run retrospectively or for too short a period is the most frequent reason these applications fail.
What makes marketing evidence unacceptable to a council?
A quoting price above the market level, marketing for only one narrow use when the policy protects a wider range, an agent without coverage of the relevant market, and an incomplete enquiry schedule. Keep instruction letters, dated particulars, photographs of boards on site and a record of every enquiry with the reason it did not proceed.
Do I have to show that other employment uses would not work?
Usually yes. Most criteria-based policies require the applicant to show that no use within the protected class is realistically viable, rather than that the current occupier has left. Work through light industrial, storage and distribution, trade counter, self-storage and flexible workspace, with conversion costs and the rent each would need to support.
Can an appraisal be used instead of marketing evidence?
No. They answer different questions. An appraisal shows whether refurbishment for continued employment use stacks up financially. Marketing shows whether there is occupier demand at a sensible price. Councils generally want both, and an appraisal offered in place of a marketing campaign is treated as an admission that the campaign was not run.
Does losing jobs count against the application?
It does, and the report should quantify the loss rather than avoid it. Compare the existing employment on site with any floorspace reprovided, separate construction employment from operational employment, and let the planning balance be struck openly. Overstating the economic benefit of a residential scheme damages the credibility of the whole document.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.