Commercial Occupiers

Self storage: which class and where it fits policy

7 min readBy PlanScope Editorial Team

The classification is the easy part. The argument is about job density on allocated employment land, and transport is usually the applicant's strongest ground.

Self storage planning use class questions have a short answer and a long argument. The short answer is that self storage is normally treated as Class B8 storage or distribution under the Use Classes Order 1987. The long argument is about employment policy, because a B8 classification puts the proposal squarely inside allocated employment land while generating a fraction of the jobs that the allocation was made for.

That is the objection you will face on almost every site. Prepare for it before you buy.

How self storage is classified

Class B8 covers use for storage or as a distribution centre. Self storage fits the description, and most authorities assess it on that basis.

Two complications arise. The first is the customer-facing element. A self storage facility has a reception, sells boxes and packaging, and often offers van hire, which makes it more visitor-intensive than a distribution shed. Where those elements are modest they are ancillary to the B8 use and need no separate consent. Where they become substantial, an authority can argue for a mixed use or a sui generis characterisation, and van hire in particular is a separate use rather than part of B8.

The second is trade counter operation. A facility where businesses take deliveries in and distribute out, with a counter open to the public, starts to look like something other than storage, and the description on the application should reflect what will actually happen.

Describe the use precisely on the application form and in the planning statement: floor area given to storage units, floor area to reception and ancillary sales, whether vans will be hired, whether goods will be sold to the public, and expected customer numbers. An imprecise description is the seed of an enforcement dispute later. The same characterisation exercise applies to other uses that do not fit tidily, as our note on experience venues in retail units shows.

Employment land policy and job density

Here is the argument that decides these applications. Employment allocations exist to deliver jobs, and self storage delivers very few of them per square metre compared with light industrial, general industrial or distribution operations of the same floor area. A large facility can be run by a handful of staff.

Officers reach for that point immediately, and a planning statement that does not address it head on will be treated as avoiding the issue.

Three lines of response tend to carry weight, and they work best together.

The first is the market evidence. Where the site has been marketed for conventional employment uses without success, the marketing history, with particulars, asking terms, period and a schedule of enquiries, does more than any policy argument. Weak marketing evidence is worse than none, because it invites scrutiny of whether the price reflected employment use value.

The second is the service argument. Self storage serves households in the surrounding area and, increasingly, small businesses that use units as stock-holding and fulfilment space, which is economic activity even where it does not appear in the operator's own headcount. Evidence it with the operator's own customer profile rather than asserting it.

The third is the site argument. Constraints that make a site poor for employment use, such as inadequate access for articulated vehicles, awkward shape, residential neighbours close enough to preclude a noisy use, or a low eaves height, are more persuasive than general assertions about demand.

An Employment Land Assessment is the document where this evidence belongs, and it should engage with the authority's own employment land review rather than ignoring it.

Traffic generation and servicing

Transport is usually the applicant's strongest ground, and it is worth developing rather than treating as a formality.

Self storage generates low trip rates for its floor area, and its peak is different in shape from most employment uses: busier at weekends and in the late afternoon than in the weekday morning peak. Heavy goods vehicle movements are few, since most customers arrive in cars and vans.

Consideration Self storage Typical distribution use
Trip rate per unit floor area Low Higher
Peak period Weekends and late afternoon Weekday morning and evening peaks
Heavy goods vehicles Occasional Frequent
Parking demand Short stay, customer vans and cars Staff plus vehicle marshalling

Use recognised trip rate data for the specific land use rather than a generic warehouse category, and present the survey sites you drew from so the highway authority can check the comparison. Set out loading bay arrangements, the swept path for the largest vehicle expected, and how vehicles turn within the site.

A Transport Statement suffices for most schemes below the thresholds at which a full assessment is expected, and councils usually expect a suitably qualified author with professional review for transport work.

Ancillary retail and trade counter elements

Keep the ancillary element strictly ancillary and say so in the description.

Sales of boxes and packaging to storage customers are part of the operation. A shop selling to passing trade is not, and where the retail floorspace becomes material the authority may apply town centre policy to it. National policy sets a default floorspace threshold for retail impact assessment outside town centres, which local plans can lower, so check the local threshold before assuming a small ancillary shop escapes it. A Retail Impact Assessment rarely arises on a facility of this kind, but the threshold is worth checking rather than assuming.

Van hire needs separate consent where it is offered, and it brings its own parking and vehicle storage requirements. Include the vehicles on the parking layout rather than discovering later that the hire fleet occupies the customer spaces.

Security, hours and lighting

Operators want long access hours, and authorities worry about what that means for neighbours.

Noise is the first issue. Roller shutter doors, trolleys on hard surfaces, vehicle movements and car doors at night carry further than operators expect on a quiet residential edge. A Noise Impact Assessment addressing plant to BS 4142:2014+A1:2019 and setting out the effect of vehicle and customer activity is the evidence that supports extended hours. Councils usually expect a suitably qualified author and professional review here as well.

Lighting is the second. Security lighting across a large yard is exactly the kind of installation that produces obtrusive light complaints, and a Lighting Assessment prepared against the relevant obtrusive light guidance, with an isolux plot at the boundary and a curfew regime, answers the question. Specify luminaire types, mounting heights, aiming and controls rather than leaving them to a supplier.

Expect conditions on hours of customer access, on external loudspeakers and tannoys, on lighting levels and curfews, and on the hours during which the yard may be used for loading. Offer a management plan rather than waiting to be asked for one.

Design and frontage expectations

A self storage building is a large box, and its elevations are the part that produces most of the objection letters.

What authorities look for is massing broken down rather than a single unrelieved mass, offices and reception addressing the street with real windows, a material palette that is not simply corporate colours across the whole elevation, and landscaping with enough depth and soil volume to grow. Corporate branding is separately controlled by advertisement consent, and a design that depends on a full-height corporate colour block will meet resistance on both fronts.

Roof area is the other design consequence. A large single roof generates a lot of surface water, so a drainage strategy with attenuation and a restricted discharge rate should be designed in rather than bolted on, and photovoltaics on that roof area are an easy win on the energy policy tests.

Evidence to submit

For a typical facility on an employment allocation, the pack that works is:

  1. A planning statement that addresses the employment policy objection in its own section, not in a footnote.
  2. Employment land evidence, with marketing history and site constraint analysis.
  3. A transport statement using land-use-specific trip rates, with servicing and swept paths.
  4. Noise evidence covering plant and activity, aligned to the hours applied for.
  5. Lighting evidence with boundary isolux plots and a curfew.
  6. A design and access statement dealing with massing, frontage and materials.
  7. Drainage, biodiversity net gain and energy evidence as the scheme scale requires.

Sequence it so the employment argument is settled first. Everything else is negotiable detail, and the employment point is the one that gets these applications refused.

This is general guidance rather than legal advice. Use classification and employment land policy vary by authority, so check the position with your local planning authority or a qualified professional before relying on it.

Scoping the evidence for a self storage application? Enter your postcode on PlanScope to see the likely report list. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

What use class is self storage?

Normally Class B8, storage or distribution, under the Use Classes Order 1987. Where the customer-facing element becomes substantial, an authority may argue for a mixed use or a sui generis characterisation, and van hire is a separate use rather than part of B8. Describe the floor areas and activities precisely on the application.

Why do councils object to self storage on employment land?

Because employment allocations exist to deliver jobs, and self storage generates very few per square metre compared with light industrial, general industrial or distribution uses of the same floor area. A large facility can be run by a handful of staff. Address the point directly, with marketing evidence and site constraint analysis.

Does self storage generate much traffic?

Less than most employment uses of the same floor area, and with a different peak shape, busier at weekends and in the late afternoon than in the weekday morning peak. Heavy goods vehicle movements are few. Use land-use-specific trip rate data rather than a generic warehouse category, and show the survey sites relied on.

Do I need separate permission for van hire at a self storage site?

Usually yes, because vehicle hire is a separate use rather than part of Class B8. Apply for it expressly if it is part of the business model, and show the hire fleet on the parking layout, otherwise the vehicles end up occupying the customer spaces and the parking provision fails in use.

What conditions should I expect on hours and lighting?

Conditions on hours of customer access, on external loudspeakers, on external lighting levels and curfews, and on loading hours in the yard. Support extended hours with noise evidence covering plant and customer activity, and support the lighting scheme with boundary isolux plots, luminaire specifications and a curfew regime.

Sources and further reading

self storageclass b8employment landchange of usecommercial development

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.

More in Commercial Occupiers

View all →
Commercial Occupiers7 min read

Hours of opening conditions and how to negotiate them

An hours condition is easier to shape before it is imposed than to vary afterwards. Here is the evidence that supports longer hours, how to split customer and delivery restrictions, and what varying an existing condition involves.

Read article →
Commercial Occupiers7 min read

Planning a pharmacy alongside a medical practice

Retail and health services both sit inside Class E, so a pharmacy opening in a shop unit or alongside a surgery usually needs no change of use permission. The consents that do bite are parking, hours, extraction and signage.

Read article →
Commercial Occupiers7 min read

Change of use to a light industrial unit near homes

Light industry sits inside Class E only where the process could be carried out in a residential area without detriment to amenity. That wording, not the machinery, decides whether your unit needs permission.

Read article →
Commercial Occupiers6 min read

Change of use to an amusement arcade or betting shop

Amusement arcades and betting offices sit outside every use class, so a change of use always needs planning permission. The decision usually turns on frontage policy, clustering and noise rather than on the gambling itself.

Read article →
Commercial Occupiers7 min read

Planning a barber, nail bar or beauty salon

Most personal care uses now sit inside Class E, so the use rarely needs permission. Extraction, waste and registration are where the work is.

Read article →
Commercial Occupiers7 min read

Mobile catering on private land and the 28-day rule

Part 4 Class B allows temporary use of land for 28 days a year. It does not apply inside the curtilage of a building, which rules out most car parks.

Read article →