Town centre health checks and the indicators used

A town centre health check is the evidence base that tells a decision maker whether a centre is vital and viable, and it is the document that decides whether an argument about a centre's decline is accepted or dismissed. Town centre health check indicators are not a fixed statutory list. They are a conventional set that national guidance and local retail studies have used for years, and the ones that carry weight are the ones you can show were measured consistently.

Get the survey method right and the conclusions follow. Get it wrong and the whole analysis is unusable.

What a health check is for

Three different arguments rely on it. An applicant proposing a main town centre use outside a centre uses it to show whether harm to vitality and viability would arise. An applicant proposing to take a unit out of retail use uses it to show the centre is already oversupplied. A council defending a frontage policy uses it to show the centre is functioning and worth protecting.

Because all three use the same evidence, the survey has to be neutral. A health check written to a conclusion reads that way, and an inspector who notices will discount it.

National policy expects authorities to define a network and hierarchy of centres and to take a positive approach to their growth and adaptation. The impact test applies to main town centre uses outside a centre above the locally set floorspace threshold, or above the default national threshold where no local figure is set. The health check supplies the baseline against which that impact is judged.

Indicators councils commonly measure

The conventional indicator set covers a mix of occupancy, commercial and perception measures:

• Diversity of uses, by unit count and by floorspace
• Proportion of vacant street level units, and the length of time they have been vacant
• Retailer and operator representation, including anchor occupiers
• Evidence of operator demand, including letting activity and requirements
• Commercial rents and yields on non-domestic property
• Pedestrian flows at fixed count points
• Accessibility by public transport, cycle, on foot and by car, with parking availability
• Perception of safety and recorded crime
• The quality of the physical environment, including street, pavement and shopfront condition
• Customer views and behaviour, where a survey has been done

No single indicator decides anything. A centre with a high vacancy rate but strong operator demand and rising rents is in a different position from one with the same vacancy rate, no enquiries and falling rents, and the analysis has to say which it is.

Vacancy, diversity of uses and occupier mix

Vacancy is the indicator most often quoted and most often measured badly. Count ground floor units on a defined frontage, state the boundary you used, count by unit and by floorspace, and distinguish empty units from those under fit-out or in temporary use. A unit with a charity shop in it is occupied. A unit with vinyl on the windows and a letting board is not.

The 2020 amendment to the Use Classes Order complicates any comparison over time. Movements within Class E are not development, so a unit recorded as A1 retail in a 2018 survey may now be a clinic, an office or a gym without any planning record of the change. That means a health check cannot build a trend from planning permissions. It has to survey actual occupiers on the ground and classify them by what they do, with the use class noted separately.

Diversity is best presented as a table of occupier categories against unit counts for each survey year, with the classification rules stated. Convenience, comparison, service, food and drink, leisure, health, office and vacant is a workable set. Say what you did with upper floors, because a centre with residential above shops has a different footfall profile from one with offices.

Footfall and survey methodology

Pedestrian counts are only comparable if the method is repeated exactly. Fix the count points and record their locations on a plan. Count in the same weeks of the year, avoiding August and the weeks around Christmas, and avoid school holidays and days with unusual weather or events. Count the same days of the week, typically a midweek day and a Saturday, in defined time bands across the trading day.

Record the counts in short blocks and scale them with a stated factor rather than counting continuously and hoping. Note the weather, any street works and anything else that would explain an outlier. Where automated counters are in place, say who owns them, what technology they use and what the error characteristics are.

A count taken once, at one point, on one afternoon, tells a decision maker almost nothing. Two matched surveys a year apart at six points tell them a great deal.

Using the authority's own monitoring data

Start with what the council has already published. The authority monitoring report, the retail and leisure study that underpins the local plan, the town centre strategy and any business improvement district monitoring are all public, and using them puts you on the same evidence base as the officer.

That has a tactical benefit. An applicant whose figures contradict the council's own published study has to explain the difference, and an applicant whose figures update the council's study on the same method is simply more current. Where you depart from the council's classification, say so and give both versions.

Where the evidence supports an argument that obligations agreed in different market conditions no longer work, our note on discharging a section 106 obligation that no longer serves sets out the route.

Where the evidence is out of date

Retail evidence ages quickly, and three specific cut-offs matter. Anything collected before the 2020 use class changes cannot be compared on planning categories. Anything collected before 2020 reflects a different pattern of town centre trading. And anything in a local plan evidence base more than a few years old will be met with the argument that circumstances have changed.

The answer is not to discard it. The answer is to use the older study for structure and hierarchy, carry out a fresh survey on the same method for the current position, and present both so the trend is visible. State the limitations of the older dataset plainly rather than quietly adjusting it.

An out of date retail study also weakens a council's resistance to a proposal, which is why a Retail Impact Assessment should always identify the age and method of the evidence it is arguing against. The same point arises on viability, as our note on when an inspector reopens viability at appeal describes.

Presenting the analysis in an application

Lead with the method, not the conclusion. State the centre boundary, the survey dates, who carried out the survey, the count points, the classification rules and the limitations. Put the raw survey schedule in an appendix so it can be checked.

Then present the indicators in a table with the current figure, the previous figure where one exists, and the source for each. Draw the conclusion in a short section that connects the indicators to the specific policy test you are addressing, whether that is the impact test, a frontage policy or a change of use. A Sequential Test is a separate exercise about site availability and should not be merged into the health check.

Finally, be honest about what the evidence does not show. A health check cannot tell you why a particular operator left, and inferring motive from a vacancy is the error that inspectors pick up most often.

Browse all 66 report types on PlanScope to see which town centre documents your proposal needs, then send the retail evidence for professional review.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.