Harp of Erin – next betting shop?

The Harp of Erin has seen better times. Full of history, it is now a pub that beer snobs Fancy A Pint and Beer in the Evening wistfully regard as one of the last pubs in Deptford High Street not worth going in (there is only one other, The Swan, whose Vietnamese owners don't have real ale on their agenda). The Deptford Dame, in her post Deptford pubs added to local listing shows "The Harp" appearing as one of many pubs the Council has identified to be added to a list of heritage assets to be protected.

It recently appeared on the market as a lease worth £24,000 pa with estate agents Cannon Kallar, but has been removed. It may be sold, under offer or temporarily withdrawn. A notice seen in a window of the pub suggests the game is on privately.

Since there would be no need to change the planning class of this premises to turn it into a BETTING SHOP, we think Lewisham Council and EVERYONE should keep a careful eye on this. Betfred is still waiting for an 'in' to the Deptford High St gambling enclave, and Paddy Power's recent takeover of McDonnell Racing is hardly making an impact (they can't be much pleased with looking like a likkle sweet shop opposite the church).

We'd like to point Lewisham towards the progress of Newham Council's present battle with Paddy Power. Newham refused Paddy Paddle'o'Shite a license on the grounds that the operator was making more money out of gaming machines than ordinary betting (which they are). But as usual, the £multi-billion gambling operator has appealed, so Newham is now facing a test case in the high court, the sort of case that Lewisham have hitherto avoided.

This article explains Newham's case well enough:  www.thisismoney.co.uk/money/markets/article-2283376/Bookies-Paddy-Power-lose-licences-gaming-machines-dispute.html
 

Crosswhatfields campaigned tirelessly against Betfred being the 8th bookies to enter Deptford High Street all through from Jan 2011 till June 2012, but the only thing that saved us was someone clever (but rather slow-acting) in Lewisham Council who came up with an old planning clause about the use of the premises. Let's hope The Harp is now equally protected.

Please read this timely article in The Independent by Mathew Norman which neatly sums up all we have fought over and written about over the last two years...(search 'Betfred' on this blog).

Also see the Deptford Betting Map (please email any inaccuracies).

Deptford High Street mentioned in Dispatches

The Channel 4 Dispatches investigative team visited Deptford High Street back in May to take a look at the plethora of betting shops and interview some locals on their feelings about the situation. The team also visited other high streets to get the national picture.

The resulting programme, Britiain's High Street Gamble will be aired this coming Monday 6 August at 8pm on Channel 4.

"Britain's high streets are struggling to survive, but one business is booming; betting shops. On average one new bookie opens every week. In one London high street there are now 10 within yards and the locals are fed up. What's driving this gambling boom and what's the impact on our communities? Michael Crick investigates the rise of High Street gambling. He hears from an apologetic politician who now admits they got the gambling laws wrong, and from those most affected by the spread of the betting shops."

Watch the trailer here.

Meanwhile, thanks to a clause in the original planning permission for the ex-Halifax site at 93-95 Deptford High Street, Lewisham Planning and the government inspectorate have managed to fight off Betfred's exhaustive attempt to become the eighth betting shop in the high street. Betfred seem to have given up for now, if this To Let sign is anything to go by.

However, the problem has not gone away, especially since the recent Select Committee's Review of the 2005 Gambling Act ("A bet worth taking?" published on 24 July) has seen fit to recommend an increase in the allowance of Fixed Odd Betting Terminals (FOBTs) from 4 to as many as 20 – per shop!

See Daily Mail report based on the programme.

Betfred appeal dismissed!

Good news just in! The Government Inspectorate has dismissed Betfred's appeal against the previous Inspector's decision to decline permission for betting office use at the old Halifax premises.

Overall, I conclude that the balance of likelihood is that the use enabled by the removal of the condition in dispute would give rise to anti-social behaviour and disturbance to local residents and other users of Deptford District Centre; that the fear of crime would be enhanced by an additional betting office in close proximity to 5 others; and that there is a risk of an increase in actual crime. Such outcomes would broadly conflict with the intentions of criterion (d) of UDP policy STC4. There would also be material conflict with the social component of sustainable development, as set out in the NPPF. However, I have not identified conflict with any part of Policy 6 in the Lewisham local development framework Core Strategy (June 2011), also cited on the Council’s decision notice.

Sorry, this writer had to go back to work and miss the fanfares and celebrations...

UPDATE 15-06-2012: Details...and Peckham continues the struggle...

The Deptford Dame has since gone into some detail about the Inspector's decision, which may have ramifications for any betting company who has to go through planning, with an interesting speculation on Betfred's next move – the High Court? (If only!). Dept Misc has also published the Inspector's decision in his post Deptford 4 - Betfred 0.

Deptfordians have been fighting Betfred since January 1st 2011 when we first spotted the notice on the old Halifax building of Done Brothers applying for their Gambling License. We soon discovered the Licensing Committee were powerless to turn them down, and, as Dept Misc sums up, it's only through a quirk (or foresight) of planning that we have held them at bay.

However, in Peckham, campaigners have just on Thursday (ironically the day after Deptford's good news) suffered the same disappointment as we did in January 2011, as Betfred swanned through Southwark Licensing Committee to get their Gambling License. Campaigner Rowenna Davis wrote the disappointing news on Thursday evening to fellow petitioners who had attended the license hearing at Southwark council that morning:

Despite a brilliant set of presentations from representatives of Peckham church groups, police, residents and business leaders, I'm afraid we lost the case today. BetFred is set to open.

However, we did manage to win a stronger set of conditions - I believe extra staff and security measures - which I believe the council will publish shortly. I also think the fact we tried and failed tells a very important story about how local people don't have enough power. I think the licensing committee would have liked to have sided with us, but didn't feel they had the legal authority to do so. I plan to write about this and keep fighting the next application for a betting shop, which is at the Bun House.

In this case, Peckham folk do not seem to have ahead of them the opportunity of seeing Betfred "go through planning" – though neither did Deptford campaigners see any hope back in January 2011.  If anyone wants to contact Rowenna to help her in Peckham, please email us for her details.

Linking crime to bookmakers – no problem!

Those who have been objecting to Betfred opening shop at the old Halifax site have been waiting to hear the decision of the Bristol Planning Inspectorate after Betfred appealed for the second time (see our January post).

Yesterday, anyone who had written an objection should have received an email from the Inspectorate notifying them of a new statement submitted by the appellant. In this 18-page document Betfred argue that the decision made by the Inspector against their last appeal on the grounds that betting shops in the area attract crime and antisocial behaviour was based on rather flimsy evidence.

However, as if on cue, the NewsShopper reports today that three men have been arrested over alleged drug dealing at Paddy Power.

On May 2, New Cross Safer Neighbourhoods Team arrested the men on suspicion of supplying Class B drugs from Paddy Power, Deptford High Street.

One man was searched in New Cross Road after leaving the betting shop and five wraps of Class A drugs were found on him. Officers then returned to the bookies, detaining and searching the punters inside. A further man was found in possession of Class A drugs and arrested, while another was given a cannabis warning.

At a linked address, police found scales, cling film and cutting implements believed to be used for preparing Class A drugs, along with three bags of cannabis and a can of CS gas.

Two men in their 20s have both been bailed pending further enquiries. 

This news will come as no surprise to some locals, one or two of whom have been following the manager's Twitter feed. So, it appears, have the police.

Meanwhile, Betfred whine on and on: 

"...no information is given as to the number of reportable crimes relating to Deptford High Street in general or in relation to other identified occupiers within the town centre to identify how the reportable crimes associated with betting shops compare with other shops on the High Street."

We suggest the Inspector has a chat with the staff at Greggs (who, coincidentally, recently saw fit to bring in some male staff) and to other shopkeepers such as Housewives Cash n' Carry about the massive level of blatant shoplifting – along with aggressive behaviour – committed by some betting shop regulars. The frequency of this petty crime means it is not worth reporting, since doing so is disruptive to trade. Nor are there local police resources to keep up with it. But Betfred go on:

"Having reviewed the list of reported crimes provided by the Licensing Officer, only one of these relates to a public order offence which could constitute antisocial behaviour, the majority of the other offences listed do not relate to crimes which would impact on neighbouring residents, only to the owners of the individual betting offices. Furthermore, no information is given as to the exact nature of the crimes, particularly in relation to the incidents of criminal damage to be able to adequately assess whether any of these incidents would have impacted on neighbouring residents.

No evidence has been put forward by the Council to support their case that a higher number of betting shops automatically results in more crime...Should an individual engage in criminal activity they are not more likely to do so because there are more betting shops. There is a case to be made that in fact it is more likely that with a higher number of betting shops it is less likely that large congregations of customers will result in a single shop and therefore crime and disturbance could decrease."

This last statement beggars belief. How little these people understand their customers! Punters will congregate where they find the best deals, and Betfred will no doubt aim to offer better deals than their rivals (if and when they get stake in our high street). In Paddy Power's case, the best deals have also included Class A drugs!

Betfred will argue that they'll run a cleaner shop than their (potential) next door neighbours – the very same promise made by those other identical corporate billion pound businesses when they moved into this 150 meter stretch. Paddy Power, meanwhile, continues to break local planning laws with their unauthorised building alterations, as well as breaching the terms of their gambling license by allowing crime to be conducted on their premises.

One of the Licensing Objectives is: "preventing gambling from being a source of crime or disorder, being associated with crime or disorder, or being used to support crime." This, as we have learned previously, is interpreted in law as crime = "serious organised crime" and disorder = "riots". So it will be business as usual at Paddy Power, who can now claim to be "creating a new job in a vibrant town centre".

Of course all this is not to say that all betting shop punters are criminals, or that all the blokes who hang outside for a tinny and a smoke are up to no good. Indeed the Safer Neighbourhood Teams know exactly who the regular offenders are. But it should be noted that Lewisham Met's Licensing Officer has failed to supply updated crime statistics to back up in law what everyone who lives or works on the high street knows to be the case. Betfred state: "It is also relevant that the Witness Statement prepared by the Licensing Officer is unchanged from the response provided in relation to the previous application submitted in February 2011." Such laziness may well lose the case on a technicality for the good people of Deptford.

Dung Brothers at it again (Betfred update)

Fred Done aka Done Brothers aka Betfred (who last year bought the Tote for £7b) invites you to take a punt

We regret to inform you that the Betfred saga is far from over. Having been turned down a second time by Lewisham Planning, they are now appealing again to the Government Planning Inspectorate in Bristol.

Comments previously submitted to the Council as objections have been forwarded to the Planning Inspectorate and will automatically be considered by the Inspector.

Any further observations you wish to make should be emailed by 17 February 2012 to: teamp6@pins.gsi.gov.uk.  Address your email to Ms Vicky Williams, and quote reference APP/C5690/A/11/2168006/NWF.

The usual jolly scene outside Ladbrokes and Paddy Power today.

Here's the Deptford Betting Map – updated since Better at no.14 became Jennings very recently. (Hales Gallery at no.70 was originally bought by Jennings who quickly sold out to Coral).


View D=f(m,b,c) Deptford High Street in a larger map

Also see 853's post about Coral taking over the Nationwide in Lewisham High Street. 

If you're unfamiliar with the history of Betfred's attempts to grab a share of the profits being made by their rivals already operating on Deptford High Street, you can read all our posts about last year's campaign against them here. Alternatively, for a brief summary, pop over to the Deptford Dame.

Betfred refused again!

Good tidings! On 16th December, Lewisham Planning again turned down Betfred's application – this time for a "Variation of Condition...to allow all A2 uses, including a betting office".

Reasons for the refusal were given as: "The proposed variation of Condition (1) to allow use of the premises for unrestricted A2: Financial and Professional Services including the use as a betting shop, would be likely to give rise to anti-social behaviour and disturbance including a risk of an increase in crime detrimental to the maintenance of a safe and accessible environment for local residents and users of the town centre where crime and disorder or fear of crime does not undermine quality of life or community cohesion..." See the application here.

Thanks to everyone who took the trouble to object.

Meanwhile, betting shops were mentioned in The Portas Review – An independent review into the future of our high streets published on 13th December (see p.29):

13. Put betting shops into a separate ‘Use Class’ of their own

I also believe that the influx of betting shops, often in more deprived areas, is blighting our high streets. Circumventing legislation which prohibits the number of betting machines in a single bookmakers, I understand many are now simply opening another unit just doors down. This has led to a proliferation of betting shops often in low-income areas. 

Currently, betting shops are oddly and inappropriately in my opinion classed as financial and professional services. Having betting shops in their own class would mean that we can more easily keep check on the number of betting shops on our high streets.

Hopefully the government will take note – and do the same with Pawnbrokers while they're at it.

Betfred objection deadline 6 December

As we reported in October, Betfred have reapplied to Lewisham Planning for the site at 93 Deptford High Street after having their appeal to the Government Inspectorate turned down.

This has meant a campaign-weary community having to repeat their previous objections. Presently there are 23 objections filed on the planning portal for application DC/11/78506/X. Last time there were 84.

Hopefully the smaller number of objections will still be enough to support Lewisham should they be minded to turn the application down again, but if you can spare some time in the next week and don't want to see an eighth betting shop opening on our high street, please write in to object. The target date for receiving objections is 6th December.

If you don't have time to write an objection, there is a petition you can sign at Come The Revolution Cafe on New Cross Road. But a petition only counts as one objection...

Our Deptford High Street

A project such as mydeptfordhighstreet.com (see previous post) may help draw attention to a less desirable aspect of our main shopping mall – the over population of betting shops.

The Deptford Dame has recently posted about the Mayor's call for planning controls over betting shops. Boris has finally joined the cross party campaign spearheaded by his rival Ken Livingstone (and Livingstone's campaign manager, David Lammy MP), and other Labour MPs such as our own Ms Ruddock, to change the national planning law to help control the proliferation and clustering of betting shops.

According to the BBC, the Green Party's Darren Johnson says Boris had dodged taking action when he replied to a question from the Greens in a May 2010 London Assembly meeting, preferring to offer the same excuse for inaction that the government and the betting industry has long been giving (that the issue can be dealt with by a local authority's own planning powers).

Boris told Communities Secretary, Eric Pickles, that having so many bookies so close together could negatively affect the vitality and viability of town centres and the quality of life of those living nearby. "There is a balance to be struck between having betting shops as part of the high street retail mix and the negative impact they can have on shoppers and visitors when they start to dominate."

The bookies are reported to have reacted angrily to the news. A statement issued by the Association of British Bookmakers said that it was a myth that there had been a sharp rise in the number of betting shops in London. Meanwhile, the ABB, along with William Hill and Ladbrokes are lobbying the Culture Media and Sport Select Committee to remove the limit on the number of Fixed Odd Betting Terminals allowed in their shops. In July 2011 they presented written evidence to the Committee's review of the Gambling Act, saying that betting shops "support the vibrancy and footfall of the high street and pay a higher level of tax" and urging them to "mitigate against the heavy tax and regulatory burden that Licensed Betting Offices face". Despite evidence to the contrary, the ABB did not accept there was any widespread problem with minors gambling in their members' premises, nor that problem gambling was an issue. They also requested a liberalisation in the maximum permitted number of gaming machines since "there is no evidence to link them to problem gambling." (www.parliament.uk)

The ABB boast that the industry voluntarily donates £5m a year towards helping fund the education, research and treatment of problem gambling. Small fry when Betfred, to name but one corporate tax dodger in this industry, turn over £3.5bn and recently paid £265m for the Tote (and their online gambling business, growing at a rate of 80%, is based in Gibraltar to avoid tax).

Whilst the industry was lying and whining to the Select Committee in July, Joan Ruddock presented a bill to the House of Commons proposing to change the planning class of betting shops and allow councils to place a cap on the number of them in any area. Ideally they would be taken out of the A2 Financial Services and put into a class of their own. Joan told the Commons that "a turf war is now under way, as bookmakers, including new entrants, seek to seize a market share." (See our post in July, Joan speaks for Deptford). The ABB said in response, "Extra regulation on our industry would be wholly disproportionate. Local authorities are already able to have their say on betting shops through the licensing process. Under the Gambling Act, councils have the power to decline licensing applications where there is hard evidence that a bookmaker would have a negative impact in a community."

All lies, damn lies. As we have already seen with Betfred, Paddy Power et al, the Licensing Law as enshrined in the 2005 Gambling Act was written by bookies for bookies, and no local authority dares to turn them down. It is only at the planning stage that councils can wield any power – but only if a Change of Use is being applied for. If the premises was already classed as A2 (be it a pub or a bank), planning can do very little except request modifications to shopfronts and signage. The industry is prepared to bankrupt local authorities in constant appeals whenever a decision goes against them.

In the unusual case of Betfred in Deptford High Street (where there was already a condition placed on its A2 useage), the planners could turn them down; they then appealed to the government inspector and lost, and are now trying again, no doubt in the hope that when they are turned down and appeal again, they will get a different inspector – who may let them through. They have enough resources to try and try again, wasting vast sums of public money in the process.

Please write an objection. See the application DC/11/78506/X and Betfred's covering letter here.

Betting shops and pawnbrokers again

(The vile) BETFRED

We regret to inform you that Betfred are back for a battle over 93-95 Deptford High Street. They have reapplied to Lewisham planning for permission to enable the premises to be occupied by any Class A2 use, including a betting office. See the application DC/11/78506/X and Betfred's covering letter here.

At the end of March, Lewisham Planning turned down their application to alter the then current planning class (A2 Financial) to lift the condition on it that said it was only to be used as a Building Society. Betfred then appealed to the government Planning Inspectorate.

On August 16, the government Inspector decided to lift the special conditions on the A2 Financial use – since there had not been a Building Society there for some time anyway (the Halifax had been a bank since 1997). However, he decided to allow all A2 uses but then applied a new condition to preclude its use as a betting office. 

This conclusion was based on the objections provided by local people and the police and their reporting of the high level of antisocial behaviour created by already existing betting shops (see extracts from the inspector's report at the bottom of this post). Although the inspector agreed the proposed betting office would occupy an empty unit and create jobs in line with national planning policy for sustainable economic growth (PPS4), he stated "there is no indication that this is the only viable use of the premises or of the employment that would be generated. Since the main aims of PPS4 also encompass safe environments, these factors do not outweigh the harm identified."

Betfred are now whining on about how the antisocial behaviour going on at other betting shops is not a good enough reason to disallow their own presence, arguing that the imposition of the new condition by the government inspector is unreasonable.

Objections need to be put in again. If you objected last time round this new objection can be an updated version of your old objection (with the date and application number altered), or a new letter that refers to your previous objection. Address it to planning@lewisham.gov.uk – the planning officer in charge is Russell Penn. We have up until the beginning of December to get in objections but don't delay!

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ALBEMARLE & BOND Pawnbrokers

Deptford Nightlife: the view from 37 Deptford High Street: three betting shops and another pawnbroker within spitting distance.

Three objections went into planning to oppose the pawnbroker Albemarle & Bond setting up shop at no.37 Deptford High Street (directly opposite another pawnbroker and two betting shops, and only a few doors down from two other pawnbrokers and three other betting shops). This many objections should have resulted in the application having to go before the Planning Committee, but it appears the planning department asked the applicant to withdraw part of their application, which was in essence a request for change of use but included drawings for a new shopfront. The planning team requested these to be submitted in a separate application. They were then obliged to allow the change of use from "sui generis" (no particular class) to "A1 Retail" as befits the council's own core retail strategy, and because pawnbrokers fall under the "Retail" classification.

Although the applicant may now set up shop, they may have difficulty getting permission for their modern branded shopfront. (See our previous post on Abermarle & Bond).

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Extracts from the Planning Inspectorate's Appeal Decision on Betfred in August 2011:

21. Just because there may be problems in connection with other betting offices does not necessarily mean that these would be repeated in conjunction with Nos 93-95. The appellant company suggests that this could lead to a greater dispersal. However, this is a large unit and presumably it would not open unless the operator was satisfied that it would generate sufficient custom to make it profitable. If the appeal were dismissed then the current state of affairs would remain but, to my mind, an additional premises would simply add to problems and should not be supported.


22. Consequently the proposal would be likely to increase anti-social behaviour and 
disturbance although the implications for crime are less certain. The appellant company is critical of the Council for referring to the potential for harm to be caused in this respect rather than expressing certainty. It seems to me that it is not possible to be categorical but that the weight of well-informed evidence suggests that this outcome is likely to materialise. Put another way, it would be foolish to ignore the convincing accounts given or to assume that they would not be repeated in association with the proposed betting office.


23. As a consequence the proposal would make the High Street a less safe place 
for residents and other users of the town centre. In this way there would be a broad conflict with the intentions of criterion (d) of Policy STC4 of the Unitary Development Plan and also with the aims of PPS1. The same would not necessarily be true of every betting office but it is the conclusion in this case based on the evidence about existing operations in Deptford High Street.

See also Deptford Misc for more of the report, and, for a simple digest go to Deptford Dame.

Betfred lose their appeal! Yippee!

Fantastic news! The Deptford Dame has just informed me that Bill Ellson at Deptford Miscellaneous has posted about the the Planning Inspectorate's decision to REFUSE Betfred's appeal. 

Suffice to say, the Inspector found the evidence from local residents "compelling" and is allowing the premises to be used for any Class A2 Financial Use EXCEPT as a Betting Shop!

Well done everyone who helped to keep Betfred at bay.

The Dame has now posted the news with some detail.
You can also see the report on Deptford Misc, or go to the Planning Portal and click on 'decision' to download the relevant document.

Update: We sent an email out with the news to petitioners and got some happy responses:

Cool. Well done, great job! Nick • Excellent news! Cllr Bell • Brilliant, well done for alerting everyone. Sue • Really great news thanks! Richard • Fantastic news! Lea • Why don't we stage a finger nosing parade outside? Marianne • Great news! A step in the right direction. Thanks! Caroline • Well done! Alison • Thanks so much for the good news! Susan • Yippee. The system works :-) Gus • That's fantastic, this is what happens when people unite for a worthy cause. Nathan • Great campaign and good news! A little rejoicing here too! Father Paul • That's fantastic news. John • Well done. Emma • Great! Billy • Fantastic! :-D Anton • Yes Yes Yes!!! Thank you. Sybar • Blimey! Someone in the planning inspectorate with common sense, perception and decency…Until the maggots at Betfred find a loophole. But meanwhile I agree, Yippee, toot toot! Julian • That is indeed excellent news. RH Joan Ruddock MP • Yahoo even! Good news! Cheryl • Yes yippee! Fantastic news! Well done for seeing this one through Anne • That's amazing – people have the power! If only we had more. Thanks for letting me know, that's great news and really inspiring. Keep on keeping on! Anita • Thanks you for this heartening news! And also thank you for all your hard work in bringing about this great result Nuala • Yeepeeee. All your efforts pay off. Well done. Raj • That's brilliant news Hazel • Great stuff! Mike

Joan speaks for Deptford

Yesterday, Joan Ruddock MP spoke to a rather empty house (no guesses as to why it was less than full apart from it's holiday time) to propose legislation to tighten planning permission restrictions for high street betting shops. Worth ten minutes of your time – check it out at the Beeb's Democracy Live.

As pointed out by recent Crossfields commenter Charlz, she was opposed by some Tory called Laurence Robertson (Tewkesbury) who said the betting industry contributes greatly to the racing industry, seemingly forgetting that the racing levy only just survived an onslaught from the betting industry to ditch it, and continues to suffer less funding from said industry because most of the betting companies' increasing online activities are based offshore – which is why the levy was increased in February by .75% to 10.75% and the threshold reduced, which the betting industry was not pleased about at all.

Everything else Robertson said can be completely disproved with convincing statistics from highly credible sources and studies, including the government's own Gambling Prevalence Surveys. The man is an ass. Fortunately the 'ayes' went in Joan's favour, which means we may hear more again of this in the autumn.

Congratulations, Joan, and thanks.


Meanwhile, the Deptford Dame has posted about a campaign called Living Streets: the local joke. This is worth looking at, but misses the point a bit, seemingly misunderstanding how planning regarding betting shops works, despite a great cartoon. However, as the Dame says, use it to make your views known.

Betting Shops: Joan's 10 Minute Rule Bill tomorrow

This blogger received news last week from Joan Ruddock's office that she will be presenting a new bill in the Commons tomorrow, as part of the ongoing campaign against betting shops. I was on holiday at the time, so here is the belated news:

-------------------------------------------------------------------------------------------------

Tuesday 19 July

Ten-minute Rule Motion

BETTING SHOPS

Joan Ruddock

That leave be given to bring in a Bill to require the Secretary of State to create a new planning use class for betting shops which would require the granting of planning permission; to provide that local planning authorities assess demand for betting shops when considering applications for premises in that planning use class and place a cap on the number of betting shops for which planning permission may be granted in any area; and for connected purposes.

-------------------------------------------------------------------------------------------------

Glad to hear Joan's contributing to the cause, but not entirely sure what a Ten Minute Rule Bill/Motion is, so went to the oracle...

The Ten Minute Rule, also known as Standing Order No. 23, is a procedure in the British Parliament for the introduction of Private Member's Bills in addition to the 20 per session normally permissible. It is one of the ways in which a bill may receive its first reading.

Any MP may introduce a bill under the Ten Minute Rule, although in practice it is only used by backbenchers. To qualify to introduce a bill under the Rule, the MP in question must be the first through the door to the Public Bill Office on the Tuesday or Wednesday morning fifteen working days (three weeks) prior to the date they wish to introduce their bill. Due to the popularity of the Rule and the difficulty in launching a Private Member's Bill by other means, MPs have been known to sleep outside the Public Bill Office in order to guarantee a slot.

Ten Minute Rule motions are held in the main Commons Chamber after question time, at around 12:30pm on most Tuesdays and Wednesdays. Whichever MP has reserved the slot presents their bill and is entitled to speak for 10 minutes to convince the house of its merit. After the 10 minutes have passed, another MP may speak for a further 10 minutes to oppose the bill. The Speaker then calls a voice vote to decide whether the bill should be allowed a second reading, which is when the bill is debated at a later date. The Speaker will divide the house for a recorded count of votes if there is some opposition. However, the majority of Ten Minute Rule motions are not objected to, and are allowed to proceed without any debate at this stage. This is because MPs have not yet had time to review the bill's content.

When a Ten Minute Rule motion passes, the bill is added to the register of parliamentary business. It is scheduled for debate along with the other Private Member's Bills, but at a lower priority. The MP presenting the bill must tell the Speaker the date for this second reading debate. The bill is generally printed and published shortly before the second reading.

Bills introduced under the Ten Minute Rule rarely progress much further, since the Government usually opposes Private Member's Bills in the later stages and, given their low priority in the schedule, there is often insufficient time for the debate to be completed. Most Ten Minute Rule introductions are instead used to stimulate publicity for a cause, especially as the debate follows the media-popular question time and is usually broadcast live on BBC Parliament, or to gauge the opinion of the house on an issue which may later be introduced in another bill.
http://en.wikipedia.org/wiki/Ten_Minute_Rule

New inquiry into the Gambling Act 2005

We have just heard that on 17 May the Culture, Media & Sport Committee launched a new inquiry into gambling, looking in particular at the implementation and operation of the Gambling Act 2005.

The deadline for written submissions is Thursday 30th June and the Committee is requesting views on the following issues:

•    How effective the Act has been in its core objectives to: 


- ensure that gambling is maintained crime-free and conducted in an open and fair manner,

- protect children and vulnerable people from the adverse effects of gambling,

- update the legislative framework with regards to online gambling;


•    the financial impact of the Act on the UK gambling industry;


•    the effectiveness of the Gambling Commission since its establishment, and whether it represents good value for money;


•    the impact of the proliferation of off-shore online gambling operators on the UK gambling sector and what effect the Act has had on this;


•    why the Act has not resulted in any new licences for casinos or “super” casinos;


•    the effectiveness of the classification and regulation of gaming machines under the Act;


•    what impact the Act has had on levels of problem gambling.

How to respond

The Committee is inviting written submissions on the above and other matters relevant to the inquiry. A copy of the submission should be sent by e-mail to cmsev@parliament.uk and should have ‘Gambling’ in the subject line. Submissions should be received by Thursday 30 June 2011.

There are quite strict rules on submitting written evidence to Select Committees, so please do follow the guidelines. For instance, make sure you include all necessary information about yourself in your email, then make your submission a single attachment which should be a Word document of UP TO 3000 words or run to no more than 6 sides of A4, begin with a short summary and have numbered paragraphs.

See also the above information on www.parliament.uk (link updated)

This information came from a campaigner in Harringey. Strangely it was not information supplied to us by our parliamentary representative.

Ironically, the June 30th deadline co-incides with the day the Planning Inspectorate announces its response to Betfred's appeal. (We now know the appeal won't be decided until October or possibly as early as end of August)

Reminder: Object to Betfred Appeal before it's too late!

The deadline for objecting to Betfred's appeal to the Planning Inspectorate is tomorrow, June 9th.
If you wanted to but forgot, there is just time!

Email: teamp6@pins.gsi.gov.uk quoting reference  
APP/C5690/A/11/2151228/NWF
and address it to Mrs Ruth Howell, The Planning Inspectorate.

See our last post about this.

And to get you in the mood, here are some comments from local people that have been left on the No to Betfred petition:

It's killing our high streets, our local high streets have enough problems without betting shops adding to the problem, they are also magnets for antisocial behaviour and crime, surely more than one betting shop within half a mile of each other should be sufficient for most people and areas! Sascha

Deptford already has enough betting shops without another opening up within metres of two other competitors. Gemma

Betting shops are already in the area and do not serve a useful contribution to the community. An additional betting shop can be seen to be encouraging people to gamble which can lead to unmanageable debts. Surely this is not good. Wai-Joe

Enough is enough...Call that REGENERATION? I call it DEGENERATION! This is one of the only streets around left with small shops, the type where you know the shop keeper on first name terms, these places are important for the community. Love deptford, not debtford! Cecile

The number of betting shops on deptford highstreet is beyond depressing, it is as if it is now an area past hope and has been abandoned to the parasites who feed on desperation and serve only the god mamon. These parasites also include the 3 pawnshops, almost in a row (broken only by the bookies) and the tesco metro that is sucking the life blood from the already struggling small grocers on the high street. This kind of planning is immoral; a daming indictment of our so called civilised society. Nuala

I have service users who live in the New Cross and Deptford areas: they suffer from the silent addiction of gambling, this area needs jobs and a Jobcentre plus so they can access the jobs. Stop targeting the poor and jobless – this really isn't fair!!!! Joan

I am working with vulnerable adults, specifically people addicted to drug, alcohol and gambling. Consequently, we see the devastation that betting can produce. It is criminal to allow such establishments to invade and ruin a local community, exploiting the most vulnerable. Our next generation has no role models other than the need to chase a dream that never becomes reality; dependent on benefit that will never suffice their needs and drives them to crime. Please, hear us, stop this. Brigitte

It is inhuman and, I'm sure history will see, a form of madness to allow gambling premises to exist in such proliferation in one urban neighbourhood, where children grow up. Build a Las Vegas in Chelsea for everyone to play but keep it away from being a Tax on the poorer people of the more neglected areas on London, nay any city. Simon

It's so sad to see Deptford high street turning into a poor man's casino, with the attendant junkies and beggars. I have experienced aggressive anti-social behaviour on the high street and I'm sure the betting shops contribute to it. There are far too many betting shops already. Nicholas

Enough is enough! Supercasinos were defeated but these ubiquitous dives slipped through. The gambling fraternity is laughing all the way to their banks! Mike

Councils & government should be working to prevent this. This should go hand in hand with supporting useful small retail businesses. Clusters of betting shops attract gangs, petty criminals, drug dealers and alcoholics and do nothing but harm to local communities. They are often sited in poor communities who can't afford to gamble in the first place. Douglas

Betfred appeal against Lewisham Planning decision

On 30 March 2011, Lewisham refused Betfred's planning application (see our post here). It was inevitable that Betfred would appeal against this decision to the government's Planning Inspectorate and now they have.

Those who objected to Betfred opening a new betting shop at 93-95 Deptford High Street are now being given the opportunity again to make their views known to the Planning Inspectorate.

The objections already made at application stage have been forwarded on to the Planning Inspectorate for consideration, but any further observations you may wish to make should be sent directly to:

Mrs Ruth Howell
The Planning Inspectorate
3/14 Eagle Wing
Temple Quay House
2 The Square
Temple Quay
Bristol BS1 6PN

by THURSDAY 9 JUNE 2011.
Comments must be sent in triplicate quoting reference APP/C5690/A/11/2151228/NWF.

Or you can email teamp6@pins.gsi.gov.uk.

Any comments you write on this appeal will be copied by the Planning Inspectorate and forwarded to all parties to the appeal including the appellant.
Those who own a property nearby should make sure they tell the Planning Inspectorate if they want the Inspector to view their objections from their property. He may make a site visit to determine the relevant facts and features.

Anyone is welcome to send in their objections – not just those who have already objected. So please get writing! 

In their appeal, Betfred state:

"...the use of the unit as a licensed betting office rather than a bank/buiding society would not adversely affect the diversity of uses or the vitality and viability of the area. The proposed use will create a level of footfall similar to that of an A1 retail unit."

Except most retail units are not open in the evening encouraging drinking and begging outside on the pavement.

"...there is nothing to suggest the use of the premises as a betting shop would cause harm in terms of anti-social behaviour, crime or disturbance to neighbouring residents and other users of the town centre. This reason for refusal is based on a subjective view of the type of people that use betting shops. There is no evidence that customers visiting betting shops are any more likely to cause harm in terms of anti­social behaviour, crime or disturbance than any other use present along Deptford High Street."

Funny, then, that street drinking is only taking place outside betting shops and not other retail outlets...

The Blackheath Bugle has posted the letter from planning here, and suggests his/her readers use the Bugle's comments section to gather case studies, examples and evidence that illustrate why yet another betting shop in Deptford High Street is a bad idea. Feel free to do that on this blog too.

And the bigger picture...

We have been contacted by Joan Ruddock's office to let us know that David Lammy MP is tabling an Amendment to the Localism Bill as it relates to Planning Consent for Betting Offices, and this bill in back in the Commons on Tuesday/Wednesday this coming week and could be called anytime.

The idea of the amendment is to give more powers to local authorities to refuse planning permission to betting shops (as one way of combating the loopholes in the present Gambling Act). There is absolutely no guarantee that the amendment will be called for debate, but if it is, Ms Ruddock would like to speak about the experience on Deptford High Street.

So if you're able to find time to write an objection this week, please copy it to Joan Ruddock's assistant, Jessica.

The petition again...

Meanwhile, the online petition No to Betfred in Deptford High Street is still available for you to add your signature to, if you haven't already. It was addressed to Lewisham Planning, but after 181 signatures we may readdress it to the Planning Inspectorate. People have left some extremely pertinent comments on the petition which makes it worthwhile to continue. Any further signatures and comments may be submitted to the Inspectorate.

Some of these comments were incorporated into my March Planning Objection. This was a pretty long objection but contains a lot of information from surveys and reports about gambling and its effects on vulnerable people and poor communities. Download it here.

Betfred Refused Planning Permission!

Lewisham has refused Betfred's Planning Application!

We called the Planning Officer today to find out when the Planning Committee hearing might take place and were told that only just yesterday the Chief Planning Officer, as the delegated authority, had turned them down, based on Lewisham's Planning Policy. Such a decision negates the need to go to committee.

The reasons are posted on the website page detailing the Planning Application and are:

1) The proposed variation of Condition (2) to allow use of the premises for unrestricted A2: Financial and Professional Services, for use as a betting shop would continue the proliferation of an over concentration of betting office uses in the vicinity within a designated core shopping frontage, beyond an acceptable level, detracting from the range of retail services available within the defined District Town Centre, adversely affecting the diversity of uses and the vitality and viability of the area, contrary to Policy STC 4 Major and District Centres - Core Shopping Areas of the adopted Unitary Development Plan and Policy CSP6 of the Submission Core Strategy.

2) The proposed variation of Condition (2) to allow use of the premises for unrestricted A2: Financial and Professional Services, for use as a betting shop, would have the potential to cause harm in terms of anti-social behaviour, crime and disturbance to neighbouring residents and other users of the town centre, contrary to the requirements of Policy STC 4 Major and District Centres - Core Shopping Areas in the adopted Unitary Development Plan (2004) and Policy CSP6 of the Submission Core Strategy.

Betfred will now have to appeal to the government Planning Inspectorate in Bristol.

We would like to think Lewisham's decision was reinforced by the sheer volume of objections from the community and the petitions signed, which totalled over 1100 signatures overall (320 of which went to planning - see earlier post).

Yesterday we got a call from BBC London who wanted to come down to Deptford to do a story on the high street betting shops with reference to the campaign against Betfred. A reporter had arranged to come tomorrow morning (Friday), but with the latest news, has now been pulled off the story. Perhaps we shouldn't have let him know the news, since although the battle has been won, the war goes on...

Meanwhile, Betfred's application to make modifications to the back of the building was granted, so the building work that we've witnessed over the past few weeks will probably continue.

Like Paddy Power at the Deptford Arms, who went ahead with their new shop front despite planning permission being turned down, Betfred are likely to continue refitting the ground floor premises at 93-95. Paddy Power will now be subject to planning enforcement that may involve a retrospective planning application, a long drawn out process that would hopefully result in them having to rectify what they've done and remove unapproved structures at their own cost.

-o-

A note on Betfred and Paddy Power profits...
Betfred announced sales of £3.5bn in January 2011, up 30% on last year. 'Pre-exeptional' operating profits were £12.37m. £10.2m of 'exceptional costs' relating to 'provisions against property-related loans' mean that their pre-tax profits were only £360K...Despite some closures, Befred opened 41 new shops in the 12 months to the end of March 2010, taking the total number of outlets to 832. They have since increased their portfolio to beyond 850, with the intention of expanding to 1000 over the next year. The business had continued to benefit from the operation of fixed-odds betting terminals, while a tight rein had been kept on overheads. Staff numbers had increased to 2,951. Betfred is a leading contender to buy the Tote, which was officially put up for sale by the coalition government in June 2010 and estimated to be worth up to £200m with 3,300 staff and 500 shops in the UK.
      Meanwhile, Paddy Power announced in March 2011 that profits rose by 56% as it capitalised on World Cup misery. The draws against America and Algeria in the group stages of last summer's world cup were preceded by a wall of money being placed by patriotic fans on England winning. The company also benefited from its acquisition of Australian company Sportsbet. Pre-tax profits rose to £89.6m in 2010, £6.4m of which were UK operating profits. Almost two-thirds of its profits last year were generated outside the Republic of Ireland, and most of their revenue is now internet related, with many punters using smart phones to place bets. (It is expected that there will be a billion smart phones in use by 2013, as many as there are now computers).

Betford Bulletin

The deadline for objecting to Betfred's Planning Application for 93-95 Deptford High Street passed ten days ago. There were 74 79 objections submitted, plus one petition. You can view the list of objectors here.

The petition was made up of both the paper petition signed by 161 people and the online petition, which at the point of submission on March 1st, had 160 signatures (and presently stands at 173). This second paper petition was gathered in less than 10 days. The first paper petition against Betfred's Gambling License Application ran for much longer (beyond the Gambling License hearing deadline) and garnered over 800 signatures, and serves as an indication of local opinion.

Many, many thanks to those who signed the latest petition against Planning Permission being granted, and to the shops and venues who hosted it. The online petition has space for signatories to leave comments and these views were incorporated into the submitted petition to Planning.

All those who wrote individually to Planning to object have been sent a letter of acknowledgement. Planning have requested that petitioners also be advised of their letter. At this stage, the letter simply sets out the process, and as soon as a date is set for the hearing we shall notify you. See the letter below (click to enlarge).

Meanwhile, please tell all your friends and associates to sign the National Petition Stop Betting Shops Taking Over Our High Streets which aims to lobby government to amend the 2005 Gambling Act.

Objection to Betfred Planning Application (3) Children & vulnerable persons

Only 6 days to go. Objections to Betfred's Planning Application must be in by 2nd March (planning@lewisham.gov.uk).

Here is some more ammo for your objection. This time it's about Deprivation, Child Poverty and Vulnerable People...

Good information is hard to find and a lot of the following information isn't up-to-date, even though it's obvious to most of us that things have only got worse. If anyone can update and expand on the information below, please contact us.

Postscript: Since posting, Save the Children Fund have hit the news with some frightening statistics. As the Londonist reports: "the proposed changes to benefits and continued high rate of unemployment will tip more families into poverty". According to the statistics, 20% of Lewisham's kids are living in poverty. The Guardian has mapped the data.

..............
 

The betting industry seems to keep targeting deprived and poor areas. Why? 

• End Child Poverty reported in 2008 that Lewisham has one of the highest rates of child poverty in London and is the 11th most deprived borough out of the 32 boroughs in the capital. 

• Particular issues that Lewisham faces include high levels of unemployment, disadvantage in income, health and crime, low levels of educational attainment and a poor natural environment. 

(The State of the Borough, An Economic Social and Environmental Profile, 2007, The local futures group)

• 55% of Lewisham’s children are from low income families, and 35% of adults in those families are out of work.  Source: HM Revenue and Customs (2006: please update). Provided by the Child Poverty Toolkit

• The problem affecting local children living in poverty because of gambling addiction:  
- when their father or mother spends uncontrollably,
- spends significant amounts of time not at home, conceals or lies about their gambling behaviour
- has no interest in spending time with them
- doesn't attend parent evenings or help with school work
- cannot keep a job, cannot pay the bills and cannot feed them.

• The site at 93-95 is extremely close to Tidemill Primary School. Even when the school moves to its new site, it will still be extremely close. Older children from Addey & Stanhope and St Joseph's also use the high street at lunch time and at the end of the school day around 3.30-4pm. Greggs the bakers at no. 91 (next door to the proposed premises) is a particular favourite for these kids. It is also a favourite with everyone, old and young, including mums with toddlers.

• The staff at Greggs have been told by their Head Office to ignore the shop lifting drug addicts who occasionally barge in to steal a sandwich. This is possibly to avoid the disruption caused by calling the police, so that the store may continue to run happily and productively without interruption.  Staff at Greggs were horrified to hear there is likely to be another betting office right next door, when there is already a problematic betting shop right opposite.

• Operators like to think they are successfully operating a "Think 21" policy. But last year, a gambling commission investigation uncovered that 98% of bookmakers allowed under-age gambling. It is estimated that 127,000 young people in the UK aged under 24 have a gambling addiction.

• Gamcare reports that 2% of their calls in 2009/10 were from under 18s, with an increase of 22% from those aged 18-25. Most of the ‘under 18s’ who called the confidential helpline reported gambling in ‘arcades’ and ‘betting shops’.

• The rate of problem gambling is over three times higher in young people as it is in adults according to the Journal of Child Adolescent Substance Abuse, 8, 55-68 (or see page 7 of Gambling Addiction and its treatment within the NHS download here).

• If a young person under 18 or 21 is to understand that a betting premises, like a pub, is an establishment they are not permitted to enter,  it may be observed that with the clustering of betting establishments currently in the high street, an entire stretch of the road has become out of bounds to young people and children.

• It has been suggested that first generation migrants may not be sufficiently socially, culturally or even financially adapted to their new environment to protect them from the potential risks of excessive gambling. Many are therefore vulnerable to the development of problems. This highlights the need for healthcare professionals to be aware of specific groups — increasingly, women and new migrants, as well as young males and adolescents — who may present with gambling problems... BMA Board of Science

• The types of games played also impacted on the development of gambling problems, the BMA report found. Problem games have a high event frequency (fast and allow for continual staking), played mostly by single unemployed males under 30, followed by older males over 40 often of Chinese ethnicity, and adolescent males. BMA Board of Science

• One of the most recent and prominent beggars on Deptford High Street is now a young Chinese man (at least that is how he is perceived and is described by the Safer Neighbourhood Team) which goes against the findings of a 2010 report How Fair Is Britain (by the Equality and Human Rights Commission) in which young Chinese were perceived to be above black and other racial groups in educational achievement. He was such a nuisance that the SNT tried to get him on an ASBO but it didn't stick, he's out there begging right next to BetterBet.

• Shockingly, the same report said "While disabilities often mean lower income levels and life expectancy, the commission found that being black and male appears to have a greater impact on levels of numeracy than being learning disabled". Oddly enough, there are black males in bettting shops who must surely be numerate, just not very lucky.

Next topic: Gambling Addiction and Anti-social behaviour

Meanwhile see the Deptford Dame's post on objecting to Betfred.

Objection to Betfred Planning Application (2) - Template

Only 6 days to go. Objections to Betfred's Planning Application must be in by 2nd March (planning@lewisham.gov.uk).

Here is a template letter written by a fellow objector that you may adapt for your own use, relating to the planning requirements of Lewisham's own Unitary Development Plan with special reference to Shopping (see previous post and Deptford Dame for more info).

Please adapt to your own use regarding your relationship to the high street and don't forget your name and address. If you duplicate the letter exactly it will be recognised as one objection with the original, so please be a little bit creative.

We'll also be posting more shortly with other clues for objections...

.............

Dear Sir or Madam,

Reference planning application DC/11/76362/X

I wish to register my objection to the above planning application, relating to the proposed change of use of 93-95 Deptford High Street.

I am a local resident and regular user of the high street, and I am objecting to the application as I believe it is contrary to a number of policies contained in the council’s Unitary Development Plan relating to shopping areas.

I strongly reject the applicant’s contention that granting the change of use, in order to allow another betting shop to be established on this premises, will ‘enhance the vitality and viability’ of the existing shopping area, and likewise that it will ‘promote a diversity of uses’. 

Within the UDP, Deptford High Street is classified as a District Town Centre, and the unit in question, 93-95 Deptford High Street, falls within the core area of this classification.

I draw your attention in particular to policies STC1 and STC4 in the UDP:

STC1
The council will seek to maintain, and where necessary improve, the function, character, vitality and viability of the established shopping hierarchy … by sustaining and encouraging through a balance of development, regeneration and conservation a diversity of uses appropriate to their function and location and retaining and enhancing each centre as a focus for retail activity.

STC 4 major and district centres - core shopping areas
Within the core shopping areas….the council will strongly resist any change of use involving the loss at ground floor level of Class A1 shops. The following factors will be taken into account when considering exceptions:
(a) whether the proposal harms the overwhelming retail appearance of the shopping frontage, with an over-concentration of non-retail uses (normally 3 non A1 uses together and 70% maintained in A1 use);
(b) whether the proposal will generate a significant number of pedestrian visits; and
(c) whether the proposal uses vacant units (having regard both to their number within the shopping centre as a whole and the core area and the length of time they have been vacant).

The basis for these policies includes the following reasoning:

The major and district shopping centres are the largest established concentrations of retail activity in the borough. Although a wide range of town centre uses are located in them shopping is considered to be their primary function. Hence a change of use to another function, even another service use, must be carefully monitored and controlled. The preservation of the primary retail function within core areas is a major planning objective as this is considered the best way to protect the character and role of the centres.

The core area of Deptford Town Centre, as defined in the UDP, already has five betting shops – if this application was granted, the total would be six. Moreover, the non-core area of Deptford Town Centre contains a further two betting shops, and the Evelyn Triangle shopping area, which is classified as a local shopping parade and is within half a mile of the core area, contains an additional three betting shops.

Any claim that another betting shop would promote diversity, given the existing number of similar businesses in the area, is clearly nonsense.

What’s more, the unit in question has only been empty for a short time since the previous occupier vacated the premises, and there is no evidence to suggest that it would remain vacant for a long time should this change of use be refused.

Yours sincerely

XXX

Objections to Betfred's Planning Application (1)

Objections to Betfred's Planning Application must be in by 2nd March (planning@lewisham.gov.uk).

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.