Wednesday, February 23, 2011

Objection to Betfred Planning Application (2) - Template

Only 6 days to go. Objections to Betfred's Planning Application must be in by 2nd March (

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:

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



  1. part of my penny's worth :....
    Deptford High Street is unique in its character, vitality, viability and function in several ways that have been recognised by media coverage both in this country and in the United States. Its status as one of London's 2 original high streets is internationally recognised and its buildings listed by English Heritage. The diversity of its multicultural and artistic uses has won praise London wide. Large amounts of regeneration money has been awarded towards its improvement and the large scale of residential new builds recently in the area increased its potential for local shopping customers.

    The impact of the 10 betting shops already permitted to operate in the High Street is in fact greater than would be the case in a more modern High Street. Deptford High Street is closed to buses - being too narrow. The retail experience is mainly therefore pedestrianised, the pavements are narrow and close to shop fronts. The South section of the High Street is also very short. The experience of shopping on the High Street nowadays is one of dodging one ugly betting shop front after another at uncomfortably close quarters. They are not buildings you would want to stop outside and chat to your friends and neighbours as was the case before the betting shops occupation.

    People hanging outside betting shops, the smells of alcohol and cannabis frequently lingering with them have to be more closely and frequently negotiated by shoppers and pedestrians using Deptford High Street - making the experience a closer encounter than would be the case in a High Street with wider pavements and where shops fronts are separated from each other at greater distance - for example as in Catford or Lewisham Town Centres.

    The shopping hierarchy, well established prior to the invasion of the betting shops , made shopping in Deptford not only a retail but an experience in community cohesion The street's scale and geographic intimacy is reflected in the interactions a local user has with neighbours, friends and shop keepers - all of which made the High Street an attractive place to shop, be seen and catch up on local news.

    The invasion of betting shops is seriously undermining this. New residents to the area are being put off from shopping there as are older ones such as myself. Their overloaded presence amongst us is loosing regular and local retail business to nearby Greenwich Town Centre and Surrey Quays on easy main bus routes from SE8 and both outside of the borough.

    The permission given in 1974 to Halifax to use the premises as A2 was conditional on it being occupied by a building society. It is vital that permission is NOT given to Betfred to use it as a betting shop

    People are outraged that the numbers of betting shops have reached such a high number already. And I would additionally urge Lewisham council to participate in the campaign to have the 2005 Gambling Act amended to be less so very favourable to the betting barons.

    There has been no evidence that the recently vacated building would remain empty if not turned to a betting shop. In fact there has been in recent years a marked increase in the occupation and variety of retail outlets on Deptford High Street and this looks likely to continue.

    Allowing the 11th betting shop on the High Street would work against all the hand won improvements that local people and the council itself have committedly pursued in Deptford. I believe the conversion of another iconic building within the community will contribute to a retail collapse of the High Street not the rebirth envisioned.

    I strongly object to the council agreeing to the change in variation of contract and urge it to turn the application down.


  2. What do you say when (if you read Betfred's application you would know) Betfred say they are "one of the Uk's biggest privately owned retaile outlets".

    Don't assume they have an answer for everything. They can't answer any of the arguments about child proverty, problem gambling and antisocial behaviour.

  3. I've sent my objection in - thank you for the comprehensive info. I'm sick of the continual violation of our poor high street. What on earth are the council thinking? bastards.

  4. Anon, the betting industry is so powerful that they can overcome any objection in court. The law needs to change.

    We heard the other night that Lewisham Planning had turned down Paddy Power's request for their new frontage, but PP went ahead anyway...Not sure what the council will do about it...there would probably be court costs equivalent to another part time job or two.

    Great that you objected, Planning needs more people like you. The more Objections the better for if and when it ends up in appeal. Am still writing mine, it's a bit long. Apologies for not putting more of an argument up on these pages.
    MT's got it quite succinct though!