Employment land supply tables in an employment land assessment

An employment land supply assessment stands or falls on two tables: the schedule of sites making up the supply, and the marketing record for the site you want to release. Everything else in the document supports those two. Where the argument is that employment land should be given up for another use, national policy allows for it where there is no reasonable prospect of an application coming forward for the allocated use, and the whole evidential exercise is about demonstrating that prospect does not exist.

Councils resist these applications hard, because releasing employment land is irreversible and the plan's jobs figures depend on it. Expect the supply table to be checked site by site.

What the supply side has to show

The purpose of the supply analysis is to answer one question: if this site goes, does the authority still have enough of the right kind of employment land in the right places.

That means recording, for the plan area or a defined market area within it, every site contributing to supply, its area, its planning status, its physical condition, whether it is available in practice and whether it is deliverable. Those last two tests matter. A site allocated for twenty years with no access, no services, a ransom strip and an owner who will not sell is not supply in any practical sense, and saying so with evidence is the strongest move available to an applicant.

Work to the national guidance on housing and economic land availability assessment, which sets out the approach councils themselves are expected to follow. Using the same method as the authority removes an easy line of attack.

An Employment Land Assessment also needs to state its market area explicitly. A borough boundary is rarely the market for industrial space, and an occupier looking for 2,000 m² of warehousing will search a travel area rather than an administrative one. Define the area, justify it, and use it consistently.

Allocated, committed and windfall supply

Split the supply into categories and keep them separate, because they behave differently.

Allocated sites are those identified in the development plan for employment use. Record the plan reference, the area in hectares, the use classes specified, the current planning status and any constraint that has held the site back.

Committed supply is land with an unimplemented planning permission for employment use. Record the reference, the date, the floorspace, whether the permission has been implemented in part, and when it expires. A permission granted seven years ago and never begun tells you something about demand.

Windfall supply is land coming forward without allocation, which is best evidenced from past completions rather than assumed. Establish a rate from monitoring data over a reasonable period and apply it with caution.

Then record losses. Employment floorspace lost to residential and other uses over the monitoring period, including losses through permitted development rights where those applied, gives the council's own trend. Our note on the supply chapter of an employment land assessment goes further into how each category is compiled.

One discipline throughout: cite the source and date for every figure. The council's authority monitoring report, its published completions data and its own land availability assessment are the sources with the least room for argument, precisely because they are the council's own.

Take-up and vacancy evidence

Demand evidence is where applications most often thin out into assertion.

Take-up is the amount of floorspace or land brought into use over a period, and it is meaningful only as an annual average across enough years to smooth the cycle. Five years is thin. Ten is better. Break it down by use type, because office take-up and industrial take-up tell opposite stories in many areas, and by size band, because demand for small units and demand for large distribution sheds are different markets.

Vacancy needs two figures rather than one. The headline vacancy rate across the stock, and the vacancy rate within each quality band. A market with five per cent overall vacancy that is entirely concentrated in poor quality older stock is a market with no supply of good space and a surplus of bad space, which is an argument for releasing bad space and protecting good.

The supporting data worth using: the council's own monitoring, national non-domestic rating statistics on the stock of business properties, official business register employment data by sector, and commercial agents' market reports for the area. Where you use agents' data, say whose it is and what period it covers.

Avoid vague attribution entirely. A sentence beginning with the words the market suggests is worth nothing in an appeal.

Marketing evidence and the period expected

This is the table the case officer reads first, and most refusals turn on it.

Local plan policies commonly specify a marketing period, often somewhere between twelve and twenty-four months, and the policy wording may also specify the terms. Read the policy before you start marketing, because a period that falls short by two months is a period wasted.

What a defensible marketing record contains:

1. The agent instructed, their relevant market experience, and the date of instruction.
2. The terms offered, including asking rent or price, lease length, break options and any incentives, with evidence that these reflect market levels for comparable space.
3. Physical marketing, meaning a board on the site, with photographs and dates.
4. Digital and particulars-based marketing, with copies of the particulars and the listing dates.
5. A log of every enquiry received, with the date, the party's requirement, the outcome and the reason it did not proceed.
6. A log of viewings, again with outcomes.
7. Any offers received and why they were not accepted, which is the entry councils scrutinise most closely.
8. Evidence of any refurbishment, subdivision or re-specification attempted to widen the market.

The failure modes are predictable. An asking price reflecting residential development value rather than employment value. Marketing through an agent with no commercial presence in the area. A board that went up eight months into a twelve month period. Offers declined without a stated reason. Marketing of the whole site only, where subdivision would have found occupiers.

Where an offer was refused, explain it properly. An offer at a level that made the continued employment use unviable can be a legitimate refusal, and that is a point a Viability Assessment prepared to recognised valuation standards can support. Councils expect a suitably qualified author for that work and professional review is strongly advised.

Qualitative fit against occupier requirements

Numbers alone rarely persuade. The qualitative case explains why this particular site cannot meet modern requirements, and it is the part of the assessment that benefits most from specifics.

The attributes occupiers actually ask about: clear internal height to the eaves and under any haunch, floor loading capacity, door sizes and dock provision, yard depth for articulated vehicle manoeuvring, separate service and staff access, available electrical capacity in kilovolt-amperes, three phase supply, fibre connectivity, sprinkler provision, parking ratio, and access to the strategic road network without passing through residential streets.

Test the site against each and record the result. A 1960s multi-storey industrial building with 3.5 metres of headroom, no yard, a single loading door onto a residential street and a 100 amp supply is not a functioning industrial site, and describing it in those terms is far more effective than asserting that it is outdated.

Photographs help here more than anywhere else in the document. Include images of the constrained access, the inadequate yard, the condition of the fabric and the relationship to neighbouring housing.

Arguing the loss of employment land

Sequence the argument so each step depends on the last.

Start with the policy position: whether the site is allocated or protected, which policy applies, and what test that policy sets. Then the site-specific case: the physical and locational unsuitability, evidenced as above. Then the marketing record, showing no reasonable prospect of the allocated use coming forward. Then the supply position, showing the authority retains sufficient land of the right type. Then the economic effects, where an Economic Impact Assessment can quantify the jobs lost and any jobs created by the alternative use. Then the benefits of the proposed use, and any employment retained on site through a mixed-use scheme.

Two additional points worth raising. Where national policy supports alternative uses on sites with no reasonable prospect of the allocated use coming forward, quote it accurately and check the current edition, because the Framework published on 17 August 2026 uses policy codes rather than paragraph numbers. And where the plan is old and its employment requirement was based on forecasts now superseded, say so and evidence the change rather than implying it.

Consider offering a partial retention. A scheme that keeps a proportion of employment floorspace, in a form that modern occupiers will actually take, is easier to permit than one that removes all of it, and it undercuts the objection that the loss is absolute.

Table formats that survive scrutiny

Three tables carry the document, and they need to be legible in a committee report.

Keep the units consistent, state whether floorspace is gross external or gross internal, and put the data cut-off date in the table heading rather than in a footnote. Where a figure is estimated, mark it and explain the estimate in a note beneath the table.

Then carry the conclusions into the Planning Statement in the same words. An assessment that concludes one thing and a planning statement that claims something slightly stronger is the kind of inconsistency that gets quoted back at an inquiry.

PlanScope can draft the assessment structure and the policy analysis around your supply and marketing data, flagging figures that still need a source rather than filling them in. This is general guidance rather than 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.