Section outline: planning statement for a change of use
A change of use statement has to establish the lawful existing use before it argues anything else. Seven sections in the order a case officer reads them.
A planning statement change of use outline has one job that distinguishes it from the statement supporting a new building: it has to establish what the lawful existing use is before it argues about the proposed one. Get that wrong and every policy argument downstream rests on a false premise. The structure below follows the order a case officer reads in, and it works for a shop to restaurant, an office to residential, a barn to holiday let or a warehouse to gym.
Seven sections, roughly 2,500 to 4,000 words for a straightforward change, with the technical detail pushed into separate documents.
Site and existing lawful use
Open with the address, the site area, the building's age and construction, the floor areas by level, and the designations that apply. Conservation area, listed building and its grade, flood zone, Article 4 direction, town centre boundary, Air Quality Management Area. Each one with its source.
Then the planning history, as a table of application references, descriptions, decisions and dates. Officers check this against their own records, so a complete history buys credibility and an incomplete one costs it.
The lawful use statement comes next and it is the part most statements skimp. Say what the lawful use is, say what evidence establishes it, and say when it began. Where the use has changed over time without permission, address the immunity position explicitly rather than letting the officer discover it. Where the record is unclear, say so and explain what you are asking the authority to accept.
One formatting point. Give the existing and proposed floor areas in a single table by use and by level, so the officer can see the change at a glance rather than deriving it.
The proposed use and its characteristics
Describe the operation, not the label. "Class E(b) restaurant" tells an officer very little. The number of covers, the hours of opening, the number of staff on the busiest shift, whether there is table service, whether hot food is taken away, whether alcohol is sold, how deliveries arrive and how often: those are the facts the whole assessment turns on.
Include the use class and the sub-class, and state whether the change is within a class or between classes. Where the proposed use is sui generis, say so and say why.
This section should also name what is not proposed. No external alterations, no change to the shopfront, no new plant, no extension of the existing hours: each negative is a point the officer does not have to assess and a condition they do not have to impose.
Policy framework and relevant development plan policies
Start from section 38(6) of the Planning and Compulsory Purchase Act 2004 and the adopted development plan, then the National Planning Policy Framework in its current edition, stating the edition date. Then any supplementary planning documents, the neighbourhood plan where one is in force, and any relevant town centre or employment land policy.
List each policy with its number and the test it sets, not a summary of its aspiration. A policy that protects employment land will have a sequence of criteria for release, and the statement should answer each criterion in turn. A town centre policy will have a frontage classification and a proportion-of-frontage rule, and the statement should give the actual figures.
Where the loss of the existing use is the policy issue, the marketing evidence belongs here or in an appendix. Length of marketing, agent appointed, asking rent, enquiries received and why they did not convert. Vague marketing evidence is the most common reason an employment land release fails.
Our outline for an economic impact assessment on a rural employment scheme sets out how to build the economic side of that argument where jobs are part of the case.
Amenity, noise, odour and hours
The core of most change of use decisions. Deal with each impact as a separate sub-section, and in each one state the sensitive receptor, the mechanism of effect, the mitigation and the condition you offer.
Noise covers plant, customer activity, deliveries and departing patrons, and where residential windows are within earshot a noise impact assessment to BS 4142:2014+A1:2019 gives the rating level against background. Odour covers cooking and process extraction, with the duct route and termination height shown on an elevation. Hours cover opening, deliveries, plant operation and waste collection, which are four different things and should be offered as four separate conditions.
Then say what the existing use was permitted to do. A change from a use with unrestricted hours to one with conditioned hours is a reduction in impact, and that comparison is frequently the strongest point available.
Highways, servicing and parking
State the Public Transport Accessibility Level or equivalent, the parking provision existing and proposed, the local parking standard and whether the site is in a controlled parking zone.
Then trip generation. A transport statement is the proportionate document for most changes of use, with a full assessment reserved for larger proposals. The comparison that matters is between the trips generated by the lawful existing use at its permitted intensity and the trips generated by the proposed use, which is a different and usually more favourable comparison than one against the current, often vacant, activity level.
Servicing needs a swept path drawing where anything larger than a transit van delivers, a statement of where it stops, and the times. Refuse storage needs a capacity calculation, a store location within the demise and a collection arrangement, and our waste management strategy outline for a mixed-use block sets out how that is built.
Conditions the applicant offers
A short numbered list of the conditions you invite. This section repays more effort than it usually gets, because a statement that offers precise conditions tends to receive those conditions rather than the officer's standard wording.
- Hours of opening to the public, stated separately for weekdays, Saturdays and Sundays and bank holidays.
- Hours of deliveries and servicing, and hours of waste collection.
- Plant noise limited by reference to a rating level relative to background at a named assessment position.
- Extraction installed in accordance with an approved scheme and maintained thereafter.
- Refuse and recycling stored in accordance with an approved scheme.
- Where relevant, a restriction on the use so that it does not change to another use within the same class without further permission.
That last one is worth understanding before you offer it. A condition removing the ability to move freely within a use class can be lawful where it is necessary and justified, and it is sometimes the price of permission. It also has to pass the same six tests as every other condition, so ask the officer to justify it rather than accepting it as standard.
Planning balance and the case for permission
Close with the balance rather than a restatement. Set out the harms identified, the mitigation offered, the benefits, and why the development plan as a whole supports permission.
Three habits make this section work. Name the harms you accept rather than denying all of them, because a statement that concedes a minor harm and explains why it is outweighed reads as an assessment rather than an advertisement. Address the objections actually likely to be made, which on a change of use means noise, parking and the loss of the previous use. And finish on the development plan, since section 38(6) requires the determination to be made in accordance with it unless material considerations indicate otherwise.
Keep the statement to the argument and put the detail in appendices: the planning history schedule, marketing evidence, the floor area schedule, the swept path drawing and the technical assessments. Officers read appendices when the statement tells them which appendix answers which question.
PlanScope can draft this structure to policy, cite the relevant national and local policy and flag the facts it needs from you, including the lawful use evidence it cannot know. Browse all 66 PlanScope report types to see which supporting documents a change of use usually needs alongside the statement.
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 should a change of use planning statement be?
Roughly 2,500 to 4,000 words for a straightforward change, with technical detail in separate documents and appendices. Length is less important than order. Officers read for the lawful existing use, the proposed operation, the policy tests, the amenity and highways impacts and the conditions offered, so structure it that way.
Why does the lawful existing use matter so much?
Because every policy argument compares the proposal against it. If the lawful use is wrongly stated, the trip generation comparison, the amenity comparison and the policy test all rest on a false premise. Where the record is unclear, say so and explain what you are asking the authority to accept rather than glossing over it.
Should the statement describe the use or the use class?
Both, but the operation matters more. Covers, opening hours, staff numbers, service model, delivery frequency and whether hot food is taken away are the facts the assessment turns on. Give the class and sub-class too, and say whether the change is within a class or between classes.
What should the trip generation comparison be against?
The lawful existing use operating at its permitted intensity, not the current activity level of a vacant or underused unit. That comparison is both the correct one in planning terms and usually the more favourable one. A transport statement is proportionate for most changes of use.
Should the applicant offer conditions?
Yes, as a short numbered list. A statement offering precise conditions tends to receive those conditions rather than the officer's standard wording. Separate opening hours from delivery hours, plant operating hours and waste collection hours, because they are four different things and councils often conflate them.
Should the statement admit any harm?
Conceding a minor harm and explaining why it is outweighed reads as an assessment rather than an advertisement, and officers weigh it accordingly. Name the objections likely to be made, which on a change of use usually means noise, parking and the loss of the previous use, and answer them directly.
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.