Self storage on employment land: an illustrative case

A self storage building on land allocated for employment use is not a straightforward application, even though storage and distribution is itself an employment use. The objection is almost always job density: a few thousand square metres of self storage supports a handful of staff, where the allocation was made on the assumption of light industrial or distribution occupiers employing many more. That is the argument in one sentence, and the evidence base has to answer it.

What follows is an illustrative walkthrough, not a real case. The site, the figures and the decision are composites used to show how the pack fits together.

The site, its allocation and the proposal

The illustrative site is a 0.4 hectare former builders' merchant yard on the edge of an industrial estate in a Midlands town, vacant for three years, with a single access onto a distributor road and a railway embankment along one boundary. The adopted local plan allocates the estate for employment use and carries a policy resisting the loss of allocated employment land to other uses.

The proposal is a three-storey self storage building of about 4,000 m² gross internal area, with a small reception, a loading canopy, nine customer parking spaces and a van-sized service bay. Hours proposed were 8am to 8pm for customers, with staffed reception during the day only.

On the face of it there is no change of use at all: a builders' merchant yard with storage and trade sales, replaced by storage. The dispute was never about the class. It was about whether this particular storage use made efficient use of an allocated site.

The use class and the policy conflict

Self storage sits within Class B8 of the Town and Country Planning (Use Classes) Order 1987 as amended, which covers storage or distribution. The previous use had a trade counter element, which pushed part of it outside B8, so a change of use application was needed in any event.

The local plan policy allowed the loss of allocated employment land where the applicant could show there was no reasonable prospect of the site being used for the allocated purpose. The council's position was narrower: self storage is B8 and therefore within the allocation, but the policy on efficient use of employment land meant the scheme had to justify the low employment generated.

So the case ran on two tracks at once. One answering the marketing question, the other answering the density question.

Job density evidence and the economic case

The employment density guidance used in English plan-making gives floorspace per job figures by use, and storage sits at the sparse end of the range, with self storage sparser still. Quoting the guide against yourself looks reckless, and it is the right approach anyway, because the council's officers will find the figures regardless.

The Economic Impact Assessment therefore argued on something other than headcount:

• Construction employment and local supply chain spend during the build period
• Business rates payable on a developed site against an empty yard
• Customer businesses served, with an account of how small traders and online sellers use storage units as operational space
• Removal of a derelict frontage and the effect on the estate's lettability

The last point did more work than any of the others, because it answered a concern officers held about the estate's general decline.

An Employment Land Assessment ran alongside, setting the site against the authority's own employment land supply figures from its most recent published study, and showing that the loss of theoretical job capacity on this plot was small against the supply as a whole.

Marketing evidence for the allocated use

The marketing evidence is where these applications are won or lost. A letter from an agent saying the site is hard to let carries little weight. What the officer wanted was a record.

The submitted evidence covered an unbroken 24 month marketing period, the asking terms, the agents instructed, the particulars issued, where the site was advertised, a dated log of enquiries with the reason each fell away, and two offers that failed on access constraints for articulated vehicles. The access was the recurring theme, and it was verifiable from the site layout.

Access, servicing and vehicle movements

Self storage generates a different movement pattern from distribution. Customer cars and hire vans rather than articulated lorries, peaking at weekends, with long dwell times and no shift changeover. The Transport Statement used trip rates from the national trip rate database for comparable self storage sites, and compared them with the rates for the previous builders' merchant use.

The comparison favoured the proposal on peak hour movements, which neutralised the highway authority's initial concern. A swept path drawing showed the largest expected vehicle, a long wheelbase van with a trailer, turning within the site without reversing onto the distributor road. A condition was offered restricting deliveries by vehicles above a stated length.

Design, massing and the boundary treatment

Three storeys of storage is a large blank box, and the first submission looked like one. Revisions broke the mass with a recessed entrance bay, moved plant off the roof line visible from the road, and set a planted strip along the frontage wide enough to hold trees that would actually survive.

The railway boundary needed a response too: no windows facing the line, acoustic fencing, and a maintenance strip inside the boundary so the operator never needs access over railway land. Network Rail's standing asset protection requirements drove that detail more than any planning policy.

The pack submitted and the committee decision

The illustrative submission comprised a Planning Statement, a Design and Access Statement, the Economic Impact Assessment, the Employment Land Assessment, the marketing report, a Transport Statement, a drainage strategy, a biodiversity net gain assessment with the statutory metric completed by an ecologist, a preliminary ecological appraisal, a noise assessment addressing plant and the railway, a lighting assessment and a construction management plan.

The application went to committee because of the employment land policy, and was approved with conditions in this illustrative account:

1. Use restricted to self storage within Class B8, removing the general flexibility the class would otherwise allow
2. Ancillary sales limited to packaging materials, with a stated floorspace cap
3. Customer hours limited, with no HGV deliveries outside stated weekday hours
4. Vehicle length restriction, with a swept path drawing approved as part of the permission
5. Landscaping with a five year replacement obligation
6. Plant noise limited by reference to a measured background level

The first condition is the one to watch. A B8 permission conditioned down to self storage only has less value than it looks, because any later change to general storage or distribution needs a fresh application.

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