We promised a template that you may adapt for your own use. Please visit the next post to read an objection to Betfred which relates to the planning requirements of Lewisham's own Unitary Development Plan with special reference to Shopping, as advised by the Planning Officer.
We shall also be posting as much detail as we can find regarding all the social and community reasons for opposing a new betting shop asap (as if you didn't know what they were).
Since Lewisham's full website still appears as a temporary site despite a still stated promise that it would be back to normal at 8am Monday morning, here also is a direct link to Betfred's Planning Application Ref 11/76362.
Meanwhile, here is a synopsis of that application that may inform the template letter that follows in the next post...
Financial Service or Retail Outlet – make up your minds!
If you click on the Planning Support Statement you can read that Betfred think they are "one of the UK's biggest privately owned retail outlets" and that "licensed betting shops are regarded as being key town centre uses and are seen to maintain the vitality and viablity of town and city centres. "
Betfred recite the National Planning Policy and pick out a number of salient points from it. For instance, planning should:
• Contribute to sustainable economic development
• Protect and enhance the natural and historic environment, the quality and character of the countryside and existing communities
• Ensure development supports existing communities and contributes to the creation of safe, sustainable, liveable and mixed communities with good access to jobs and key services for all members of the community
• Promote personal wellbeing, social cohesion and inclusion and create equal opportunity for all citizens
Etc. All good stuff. Betfred's only claim is that the proposed occupation of 93-95 Deptford High Street "will contribute to the local economy and create jobs", in accordance with the aims of National Planning Policy to promote strong, stable and productive economies that aim to bring jobs and prosperity to all.
Hurrah! Any shop on this site is going to employ people so BIG DEAL! It is such a good site, it could not stay empty for long. For those who fear yet another grocer-meat-phone shop, may you save your complaints for another time—a much worse fate awaits.
Betfred then quote national policy regarding economic growth and note that the government requires:
• New economic growth...with the aim of offering a wide range of services to communities in an attractive and safe environment and remedying deficiencies in provision in areas with poor access to facilities
• Competition between retailers and enhanced consumer choice...which allow genuine choice to meet the needs of the entire community (particularly socially excuded groups)
• The historic, archaeological and architectural heritage of centres to be conserved and, where appropriate enhanced, to provide a sense of place and a focus for the community and for civic activity.
Betfred's only claim here is that that the change of use from Building Society to Betting Shop will promote a diversity of uses and choice for consumers. There is a contradiction in the policy to be exploited by them here in that while there is no way Betfred will remedy deficiencies in provision by becoming the 6th betting shop within 150 metres, they may still yet offer enhanced consumer choice.
However, this so-called consumer choice is exclusive within the competitive trade of other gambling establishments. They indeed may offer much better or worse odds than the betting shop opposite, and two doors down, whilst the best odds may come from 150 metres away in BetterBet. Much like the inside track on Epsom Downs, but not much to do with racing, since the main earner for all these betting shops are the slot machines, the Fixed Odd Betting Terminals from which they earn over 70% of their takings, and which are designed for punters to lose. A bit different from which shop sells the cheapest bananas.
Then Betfred looks at Lewisham's Unitary Development Plan (UDP), developed in 2004 (see here) which identifies the old Halifax site as falling within the Core Shopping Area. The plan states that the council will strongly resist any change of use involving the loss at ground floor of Class A1 shops (Retail).
• Betfred contend that since the site had been exceptionally allowed to be A2 (with the condition that this was only as a Building Society), if the A2 use was expanded to include betting shops (which A2 use inexplicably usually does), there will be no loss of an A1 unit since it hasn't been a retail shop there for ages (they later go on to add that their service is more akin to retail anyway).
• Since its neighbours are A1 retail (Greggs the bakers and the wig/cosmetics/phone shop), there will not be three non-retail uses together, so not contrary to policy.
• They promise that like other A2 uses (like banks and building societies), the betting shop will attract footfall throughout the day as well as evenings and weekends. Residents in the high street will surely have something to say about that.
• Not only that, but it's a positive thing that the building is not to be left boarded up for a long time since Betfred have jumped in and bought the place up (in reality, no one else had a chance since they were gagging to get hold of it).
• On the other hand, they also state that they will operate like other A1 retailers and will not harm the adjoining occupiers as there will be no noise and disturbance, smell, litter or incompatible opening hours. So there will be no punters hanging about outside smoking and drinking and blocking the pavement for the children, young people, mothers, high street workers, locals and visitors who come to get their bread, lunch and pastries from the bakery next door?
• They say their window displays would not be dissimilar to the window displays of the Halifax. So shall they be completely see-through, unlike other betting shops, so that we can see the Betfred punters staring glassy-eyed at the TV monitors, where we used to see the Halifax customers queuing up to safely deposit or withdraw their earnings or benefits?
• Their premises will have disabled access (not difficult on the ground floor)
In conclusion they reckon that if the condition of only allowing A2 use to a Building Society were removed, Deptford High Street would benefit from an A2 (Financial Services etc) use that is also masquerading as a A1 (Retail) use, should Lewisham Planners wish to revert planning use from A2 back to A1 in deference to their own Unitary Development Plan.
Betfred really isn't sure if it is a Financial Service (which it isn't, since it's not regulated by the FSA) or a Retail Outlet. That is because IT IS NEITHER. Surely the latter is when it is almost certain that if you pay for something on that premises, you will leave it with SOMETHING—usually to eat, wear or use. That has never been a guarantee in a betting shop—not even a promise—merely and simply a possibility.
Betfred's claim to be one of the UK's biggest retail outlets is an insult to retailing and consumers alike.