Self storage: Class B8 or something else

Self storage sits within Class B8 of the Use Classes Order in almost every case, because the primary activity is the storage of goods. The self storage use class B8 analysis only comes under pressure where the customer-facing elements grow beyond what is ancillary: a shop selling packaging, a van hire desk, a trade counter, or an access pattern closer to a retail park than a warehouse.

That matters commercially, because B8 brings two things with it. A limited set of permitted development routes in and out of the class, and a set of employment land policies that treat storage very differently from industry.

What Class B8 covers

Class B8 is defined as use for storage or as a distribution centre. It is deliberately broad, and it covers cold stores, bonded warehouses, container yards, parcel hubs and self storage facilities alike.

Two features of the class are worth holding onto. There is no requirement that the storage be wholesale or trade only, so storage for members of the public is still storage. And the class says nothing about employment density, which is why a policy objection to self storage is a policy point rather than a classification point.

Movement into B8 from general industrial use is available under Part 3 of the General Permitted Development Order subject to a floorspace cap, and the considerations that go with that change are set out in the note on general industrial to storage and distribution. There is also a narrow prior approval route in Part 3 allowing small B8 buildings to become dwellings, subject to a floorspace limit and a qualifying date test. Read the current text of the Order rather than a summary, because both routes have been amended.

Where a proposal mixes storage with data processing or similar, the classification questions described in the note on data centres, storage and where new uses land in the Order apply instead, and the answer can be different.

Public access and the character of the use

The argument that self storage falls outside B8 rests on customer access. A distribution warehouse receives and dispatches goods through a loading bay. A self storage facility has members of the public arriving in cars and vans throughout the day, parking, using trolleys and lifts, and leaving.

On a plain reading of the class that does not change the use. Storage is still what the building is for, and the visits are incidental to it. Where the position does change is when a separate commercial activity becomes more than ancillary.

Three elements to watch:

• Retail sale of boxes, tape, bubble wrap and padlocks. Ancillary at a small scale, and capable of becoming a retail use if it occupies real floorspace and is advertised to passing trade.
• Van and trailer hire. The hire of motor vehicles is a sui generis use, so offering it creates a mixed use rather than a pure B8 use.
• Office and meeting room letting, which has appeared in some operators' models and belongs in Class E.

Describe each of these honestly in the application and the classification problem usually disappears, because the authority can impose a condition capping the ancillary floorspace rather than arguing about the class.

Trip generation compared with warehousing

Highways officers will ask about trips, and the honest answer is that self storage generates more vehicle movements than a distribution warehouse of the same floorspace but far fewer than retail or leisure.

The pattern also differs. Peaks fall at weekends and in the early evening rather than at the highway peak hour, and a proportion of trips are in vans rather than cars. Where an assessment is needed, draw trip rates from the recognised trip rate database using comparable sites, and state the sites used and why they are comparable. A Transport Statement is usually proportionate for a single facility, with a full transport assessment reserved for larger schemes or constrained accesses.

One practical point that carries weight with officers: unloading happens at the building, not at a remote bay, so the layout needs short, covered loading positions next to the entrance. A scheme that forces customers to carry boxes 40 metres across a yard will see them park on the access road instead.

Employment land policy and the loss of industrial space

This is the real battleground on allocated employment sites. Local plans commonly protect industrial and employment land, and authorities assess proposals against the jobs and the floorspace that would be lost.

Self storage employs few people per square metre, which makes a straight substitution for a B2 or light industrial use hard to justify where the plan protects that land for employment. The arguments that succeed are evidence-based rather than rhetorical.

1. Demonstrate the marketing history of the unit, with the agent's record, the asking terms, the enquiries received and why they did not proceed.
2. Show the condition and configuration of the building, including eaves height, floor loading, yard depth and power supply, and why it does not suit modern industrial occupiers.
3. Set out the demand evidence for storage in the catchment, including the facilities within a reasonable drive time and their occupancy where that information is published.
4. Quantify the jobs created, including on-site staff, and any ancillary office space.
5. Address the plan's own tests in order, rather than asserting that the site is unviable.

An Employment Land Assessment that addresses the adopted policy wording directly is more useful than a general market commentary, and on a site where the plan is explicit about protecting employment use, the honest advice to a client is that the application is finely balanced.

Hours of access, lighting and amenity

Twenty-four hour customer access is attractive commercially and it is the element most likely to attract a condition.

Where the site adjoins housing, expect the authority to look at vehicle movements late at night, roller shutter noise, lighting spill from the yard, and the gate or barrier operation. The measures that tend to resolve it are a staffed-hours model with electronic access confined to daytime, internal corridors so that unit doors are not on the external elevation, lighting designed to the recognised obtrusive light limits for the environmental zone, and a slow-acting barrier rather than a shutter facing the nearest dwellings.

Where unit doors do face a boundary, the noise case needs real numbers rather than assurances, and an acoustic author should prepare it.

Describing the use accurately in the application

The description of development determines what the permission allows, and a vague description causes problems later.

A workable form is to describe the use as storage and distribution within Class B8 in the form of self storage, together with any ancillary elements named individually: ancillary sale of packaging materials, ancillary office, and vehicle hire if it is part of the model. Then offer conditions capping the ancillary retail floorspace and fixing the hours of customer access.

That approach has two benefits. It removes the authority's reason to argue the use is sui generis, and it gives the operator a permission that survives a change of management without an argument about whether the current activity matches the consent. A Planning Statement that sets out the operating model in plain terms, with floor areas for each element, is what makes that possible.

Where the use has been running for years under an unclear permission, consider a certificate of lawfulness of existing use under section 191 of the Town and Country Planning Act 1990 to fix the position before a sale or a refinancing.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.

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