Yes - I submitted the following objection based on conversations with a number of residents -
Objection to a new premises licence for a Betting Shop at 89 Sydenham Road, SE26 5UA in the name of Paddy Power
1. Impact on Sydenham high street
A survey by the Local Government Association (14th April 2012) concluded in their report that the toxic economy of betting shops, pawnbrokers and payday loan companies was deterring investment and stifling economic growth.
The Portas Review, published in December 2011, had originally proposed to change the use class of betting shops from “A2” to sui generis (a category all of its own). This would mean every prospective betting shop would have to apply for planning permission, thus giving the local council and local residents the chance to consider the cumulative impact of the clustering of betting shops.
However, the Department for Communities and Local Government replied that the government is cutting red tape to make it easier to get redundant buildings in our town centres back into productive use and help increase footfall on local high streets. The alternative is boarded up, empty buildings which create a cycle of decline. Councils already have the ability to tackle the cumulative impact of development through an Article 4 Direction.
Councils have a range of planning powers to protect a local amenity if there are localised issues; for example, the London borough of Barking and Dagenham has been consulting on an Article 4 Direction and associated supplementary planning guidance to address the proliferation of betting shops in the local area.
This part of Sydenham Road is governed by the Thorpes Conservation Area, where the residential streets benefit from an Article 4 Direction. We believe that an Article 4 direction should be put in place at 89 Sydenham Road in order to require Paddy Power to apply for planning permission rather than have automatic rights to change from the currently use of A3 (Wimpy Bar) to A2 financial services.
This would enable some discussion on the impact of the neighbouring business in this part of the parade. The premises in question are within a group of five shops which contain two other betting shops - namely Ladbrokes at 85 Sydenham Road and William Hill at 93 Sydenham Road. There is a Cash & Cheque Express at 79 next to Barclays Bank at 81 with a Cheque Centre at 105 so already a number of A2 uses in this stretch of prime retail units in the designated Core Shopping area.
We have been working hard to improve the quality of the retail offer in the high street with four pop up shops offering a diversity as they include modern jewellery and vintage, designer T shirts, organic hair and beauty products as well as hand made leather goods. An excess of one type of use has a damaging effect on the economic and commercial life of the high street. I believe that this damaging economic effect has a direct relationship with the licensing objectives. The increase in the number of betting shops will hinder the improvement of the public place and impact on vulnerable people.
2. Licensing
Background
Local authorities might be able to exercise greater control on the location of betting shops if gambling legislation were to be reviewed. The Rt. Hon. Harriet Harman QC MP published a report on the Problem of Betting Shops Blighting High Streets and Communities in Low-Income Areas in 2011. The report highlighted that a snapshot of local authority areas has shown that an unintended consequence of the Gambling Act 2005 has been a dramatic proliferation of betting shops in deprived areas and a clear clustering of these shops in high streets in these areas.
The Licensing Committee can refuse a license if they can be convinced that the prospective shop will impact adversely on vulnerable people or will generate crime and disorder.
Objection under each of the Gambling Act’s three licensing objectives:
1. To prevent gambling from being a source of crime and disorder
Sydenham high street is a problem area with street drinkers who act as a magnet for anti-social behaviour. This has led to an ASBO on one of the offenders but residents still have concerns with crime and disorder. There are incidents of armed robbery – notably at the 66 Sydenham Road which is opposite this stretch of the retail parade in question (the numbers on each side of the high street are not in parallel). The Cash & Cheque Express at 79 Sydenham Road has been ram-raided a couple of times and had asked for a bollard on the new pavement. In their planning application for 42 Sydenham Road Tesco set out several bollards on their forecourt to ram-raiding. This is not the type of high street local residents want for Sydenham and regularly ask questions as to the effectiveness of the four CCTV cameras we have positioned on the corners of Mayow and Queensthorpe Road. Whilst the cameras are monitored they cannot always pick up a good image in the centre of the parade.
Residents have advised me that all kinds of anti social behaviour arise inside and just outside the betting shops. When people who are already in difficult financial circumstances lose money, which is inevitable, they can become aggressive to others inside and outside the shop, and at times violent towards the machines in the shop.
This adds to the need to keep betting shops to a minimum in places where children and other vulnerable people have easy access, like Sydenham town centre. The first hand reports from the betting shop worker is that children visit the shops to watch who wins and frequently then follow them out of the shop to aggressively seek some of the winnings. All this is very anti social leading to disorder and raising the risk and probability of criminal behaviour, in addition to such a damaging environment for children to grow up in.
The increasing numbers and clustering of the betting shops, which if granted would mean a betting shop at 85, 89 and 93 Sydenham Road, is significantly increasing the likelihood of these damaging effects as set out under the Licensing objectives.
As the Cabinet Member for Community Services and Older People which includes Public Health I have grave concerns about the impact on mental health on gambling and have set out my concern below as I believe that the Fixed Odds Betting Terminals (FOBTs) are addictive.
2. To ensure that gambling is conducted in a fair and open way
Primary Use The definition of a betting shop is a “Licensed Betting Office”. Gaming is distinctly different to betting. The Primary Gambling Activity within a betting shop should be betting and not gaming.
Figures available from bookmakers’ annual accounts or Gambling Commission Industry Statistics show that the primary use of betting shops is now gaming via Fixed Odds Betting Terminals (FOBTs) and not traditional betting. FOBTs now account for over 50% of the profits of betting shops and 80% of the turnover.
We believe that the proliferation of betting shops is driven by what are called B2 gaming machines, otherwise known as FOBTs. As a single betting shop is limited to four FOBTs, it is apparent that bookmakers are opening multiple outlets to maximise the revenue these gaming machines generate. FOBTs have been described in the media as the “crack cocaine of gambling” due to their addictive gaming characteristics, in particular roulette which accounts for 90% of all turnover and profits that are derived from these machines.
We find it unacceptable that so many betting shops are being allowed to operate within our community when driven by a product that is known to be addictive and it is apparent that the bookmakers are targeting the less affluent areas with these machines and preying on the most vulnerable. According to research carried out by Geofutures, there are more than twice as many betting shops in areas of high unemployment than there are in areas of low unemployment.
The clustering of betting shops also results in problem gamblers moving from shop to shop, from FOBT to FOBT to satisfy their addiction. A Department of Culture Media and Sport (DCMS) Scoping Study for the UK Gambling Act 2005, published in 2007, concluded: “The international research evidence demonstrates that FOBTs possess the characteristics of those forms of gambling most associated with gambling problems, namely high event frequency and opportunities for rapid reinvestment.”
There has been no research in Great Britain specifically designed to estimate the costs of gambling related harm to society and the economy. However GamCare (a problem gambling charity funded by bookmakers) has estimated the costs of problem gambling at around £3.6 billion per year, based on an estimated average cost per problem gambler of over £8,000 per year (Grinois & Mustard, 2001) and using the 2010 British Gambling Prevalence Survey figure of 450,000 problem gamblers.
Accepting wagers from under-age gamblers is common on FOBTs. This was highlighted by Test Purchasing carried out by the Gambling Commission in 2009 where there was a 98% failure rate in the first wave of tests and 35% in the second later that year.
Bookmakers will argue that they want to cater for demand. But the accessibility, marketing and addictive nature of FOBTs creates the demand. Extended opening hour’s means minimal staff providing minimal oversight of increased FOBT gambling and increased consequential addiction, harm and crime.
3. To protect children and other vulnerable persons being harmed or exploited by gambling
This is creating an excess of one kind of use which is exactly what the Council is aiming to discourage, because of the damaging effect to the economic and commercial life of the town centre. These damaging economic effects have a direct relationship with the licensing objectives for this reason. Sydenham has a lot of vulnerable people – a day centre for People with Learning Difficulties at 44 Sydenham Road, children, people in difficult financial circumstances whether because of unemployment, low incomes, or debt, and people with mental health problems. It is in the interests of all these children and vulnerable people, for the town centre to be improved as a public place.
The SEE3 Portas pilot has, for the past year, been working on a number of initiatives to improve the offer in Sydenham Town Centre as well as Forest Hill and Kirkdale. We know street drinkers are a problem outside Paddy Power in Forest Hill and there are reports from the local SNT on the SE23.com web site – please see the thread - Street drinkers outside Paddy Power
http://www.se23.com/forum/showthread.php?tid=8483 .
Forest Hill SNT are very much aware of the street drinkers outside Paddy Power on Dartmouth Road and you can be assured that they are stopped and dealt with every time they are seen to be acting in an anti social manner or drinking alcohol in a public place. The PCSO's deal with them on a regular basis and the area is patrolled every time the team are on duty. The team have received no phone calls or e-mails regarding photographs members of the public have, but if anyone would like to send photos or speak to us the team would be more than happy to speak to anyone. We can be contacted on:
Tel: 0208 721 2723
Email: ForestHill.SNT@met.police.uk
However, street drinkers are also vulnerable adults and the Council tries to give appropriate support but for many they are hardened drinkers and it is a way of life. They can have dual needs with drug addiction and being on the street all day drift into the betting shops for warmth as well as to place a bet.
Allowing the increase in numbers of betting shops will seriously hinder any support the Council can offer, and also more directly interfere with the licensing objectives of protecting vulnerable people.
The town centre is used every day by many school children from the local schools. The betting shops’ slot machines will attract children as has been shown in other such premises. Children being present where there is adult gambling in public commercial premises is bound to cause harm to the vulnerable children.
There are also a significant number of unemployed people and others with very low incomes close to the town centre. There is much evidence that people in difficult economic circumstances are prone to gambling to attempt to ease their financial difficulties. Such people are very vulnerable to a proliferation of betting shops appearing in the town centre, which is now happening with these new applications.
Sydenham Road is a route travelled by parents and children to and from the local schools. People congregating at times outside the shop, which is likely, will block the pavement and make it risky for everyone, including especially vulnerable people, to have to go into the road into the traffic.
We want Sydenham to flourish with a diverse range of retailers, making it more attractive as a shopping destination and leisure area. We strongly feel that the increasing prevalence of betting shops is jeopardising this and leading to an increase in gambling addiction and crime and disorder.
In conclusion I am requesting that the Licensing Committee reject the application for a betting shop at 89 Sydenham Road.
Further, I am requesting that the Planning Officers consider an Article 4 direction on the premises of 89 Sydenham Road to prevent the use as a betting shop.
