The phenomenological approach introduced by Benisty et al. [Appl. Phys. Lett. 76, 532 (2000)] to model out-of-plane radiation losses in planar photonic crystals with a low vertical refractive index contrast is extended to the case of in-plane disorder. The model is experimentally validated by means of optical measurements on GaAs-based structures. For the present fabrication techniques the disorder-induced contribution is found to be negligible compared with the other loss mechanisms