Forum topic: Proposed gambling arcade on the high street
PG resident launches petition against new Green Lanes adult gaming centre
PGC Webmaster
05 Jul 2023 22:55 6891
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A Palmers Green resident has launched an online petition calling on Enfield Council to refuse a licence for a new adult gaming centre in the heart of PG's main shopping area.
The petition on the Change.Org website, headlined Oh No, Not Another Betting Shop in Palmers Green, was started by Georgia Scaturro on Sunday 2nd July and by Wednesday afternoon had amassed more than 460 signatures. It asks the council to reject an application for a Palace Amusements adult gaming centre in the premises at 369-371 Green Lanes that were formerly a branch of Lloyds Bank.
Palace Amusements is a trading name used by East Kent Leasing Ltd, based in Folkestone (and also known as the Godden Gaming Organisation), who operate eight adult gaming centres in various parts of the country, including one in Enfield Lock.
The details of the petition and a model objection letter are reproduced below.
Two years ago a campaign along similar lines was fought unsuccessfully to try to block the issuing of a licence to another gambling venue, Merkur Slots, whose premises are on the opposite side of Green Lanes. The campaign was supported by councillors, including the council leader herself, but a planned review of the licence was cancelled after legal advisors to the council suggested that the grounds were weak and that there might be financial consequences for the council. The same considerations will presumably apply to this new case, since the laws that generally favour operators of gambling premises remain unchanged, despite calls for reform.
However, there is a precedent for a council blocking a similar application. At around the same time as the campaign against Merkur Slots was approaching its end, Waltham Forest Council refused an application to open a new gambling arcade in Leyton on the grounds that it would “pose clear harm to vulnerable adults”. One perhaps relevant difference between the proposed "Little Vegas" in Leyton and Merkur Slots in Palmers Green was that Merkur were moving into premises that had previously been used for gambling - a betting shop - while the Leyton premises had been a homewares store. In the case of 369-371 Green Lanes, it would also be a case of conversion between two very different uses, turning a former bank into a gambling venue. Plus, in 2023 the problems of widespread poverty are even worse than they were two years ago, meaning that more people are likely to be vulnerable because of sheer desperation.
Petition details
Oh No, Not Another Betting Shop in Palmers Green
Started by Giorgia Scaturro
We Say NO to more gambling and betting activities in Palmers Green
We the residents of Palmers Green, North London, wholly object to the application for an Adult Gaming Centre by East Kent Leasing Limitedon on 369-371 Green Lanes, N13 4JH
We ask ENFIELD council to REJECT the proposed applicationfor yet another betting shop in the premises previously occupied by Lloyd's bank. We already have a dense concentration of betting shops on our high street: two Ladbrokes, Merkur Slots, Bet Fred and Paddy Power - we don’t need any more!
Our high street is at the heart of our community, where local people should come to shop, relax and socialise. We do not want another gambling establishment in our area.
More betting shops can only mean:
- no regeneration of the area. Less retail space, less amenities and cultural services needed in our local community,
- More normalisation of our children to gambling
- Researches* show that for one unit increase in betting shops, shoplifting counts increased by approximately 16%, theft from person by 10%, anti-social behaviour by 7%, public disorder by 7%, and bike thefts by 6%.
- There is a well-known risk that these venues attract money laundering, and criminality. These venues encourage behaviour that has a negative effect on individuals, families and communities.
- 1.44 million adults addicted to gambling in Great Britain. And 105,000 UK children addicted to gambling or at risk of addiction. Up to 496 gambling-related suicides in England every year, 1 in 4 gamblers are at substantially higher risk of suffering serious harm**
- Palmers Green ward is one of the top 40% of most deprived wards in the country. We witness homelessness and begging. Town centres should not be places where people are encouraged to waste money, get into debt, cause damage to their lives and to their families. There are many more people now struggling financially, making them more vulnerable to such a venue.
We have a number of schools and social/elderly care centres in close proximity to the proposed new gambling venue and we want to protect our children and vulnerable persons in our community from being further exposed to gambling while en route to school, to the nearby park, playgrounds and local shops.
The site for the application is just 80 metres from Devonshire Square, a recently created pedestrianised community space where markets and events are regularly held and children are invited to play on the bespoke street furniture. This project has been funded by Enfield Council.
We implore Enfield to listen to residents and take a holistic look at our high street, with all the efforts being made by volunteer groups to improve the high street with art, planting and new businesses, there is no place for another adult gaming centre.
SEND YOUR OBJECTIONS TO BOTH: , on the grounds of the prevention of crime and disorder, public safety and the protection of children from harm.
*Analysing the effect of betting shops on crime in England- Nottingham Trent University and Bournemouth University
**2023 Office for Health Improvement and Disparities report
Model objection text
To stop the opening of this new gambling venue in our high street we, residents in Palmers Green, can:
- Write our objections
- By 23 July 2023!
- Indicate our name and address
- Base our objections on:
- prevention of crime and disorder
- public safety
- the prevention of public nuisance
- the protection of children from harm
- Email our objection to both and
- SUBJECT: Review Application for adult Gaming Centre Premises Licence to 369-371 Green Lane Palmers Green, N13 4JH
TIPS ON WHAT TO WRITE YOUR PERSONALISED OBJECTION
I _ _, resident in Palmers Green at n.X, XXX road N13XX
Object to the license for an adult gaming centre in 369-371 GREEN LANES, N13 4JH
Because:
1) Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime:There is already a concentration of four betting shops in close proximity to the proposed new gambling premises. There is a well-known risk that these venues attract money laundering, and criminality. These venues encourage behaviour that has a negative effect on individuals, families and communities. Researches show that for one unit increase in betting shops, shoplifting counts increased by approximately 16%, theft from person by 10%, anti-social behaviour by 7%, public disorder by 7%, and bike thefts by 6%.
2) protecting children and other vulnerable persons from being harmed or exploited by gambling: This type of venue is totally unsuitable in this area with a large number of growing families and elderly. Children risk becoming normalised to gambling, will be exposed to betting shops and gamblers while en route to school, to the nearby park, playgrounds and local shops. There are 1.44 million adults addicted to gambling in Great Britain and 105,000 UK children addicted to gambling or at risk of addiction
3) Public safety: Palmers Green ward is one of the top 40% of most deprived wards in the country. We witness homelessness and begging. Town centres should not be places where people are encouraged to waste money and get into debt, causing damage to their lives and to their families. There are many more people now struggling financially, making them more vulnerable to such a venue.
4) Public health dangers: Gambling is related to serious mental health issues with a sharp increase in the number of NHS gambling clinics for 13-25-year-olds who are suffering from addiction. Gambling addiction can result in homelessness, suicide, domestic violence and family breakups. Up to 496 gambling-related suicides in England every year, 1 in 4 gamblers are at substantially higher risk of suffering serious harmLocal residents in Palmers Green have worked with businesses to improve and support the high street, making it a more pleasant environment for the community at a time when local high streets are facing huge challenges. The local community are keen to see the local day and night-time economy thrive, and the opening of another Adult Gaming Centre in a prime spot in the high street would be highly detrimental to those efforts.
The site for the application is just 80 metres from Devonshire Square, a recently created pedestrianised community space where markets and events are regularly held and children are invited to play on the bespoke street furniture. This project has been funded by Enfield Council.
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More grounds for objecting to new Green Lanes adult gaming centre
PGC Webmaster
10 Jul 2023 15:30 6892
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The petition opposing granting of a gaming licence for the premises formerly occupied by Lloyds Bank has so far been signed by 837 people.
The updated deadline for objecting is 30th July and the campaigners have provided the following expanded grounds to quote when writing to the council:
We OBJECT to Palace Amusement, and OPPOSE more gambling in Palmers Green because
- The new proposed Palace Amusement shop (on 369-371 Green Lanes) will open just one shop apart from the existing Ladbrokes! ( 363-365 Green Lanes) and 24 metres away from Paddy Power. The Development Management Document (DMD 33) states that "There should be a minimum of five non-betting shop units between the proposed site and the next betting shop premises, or at least 25m, between them, whichever is greater." In addition it will be 78 metres away from G&S Jewellers which also operates as a pawn shop.
- BETTING SHOPS DETRACT FROM VITAL SERVICES: What we need in our high street are amenities and shops that serve our family-friendly community. Losing the current commercial business [to have a betting shop instead] would “detract from the function of the primary retail frontage” and “have a detrimental impact on the vitality and viability of the town centre. Betting shops in the area discourage the opening of other more needed businesses that could benefit the community: retail, books, cinemas, fashion, shoes, art clubs… Local residents in Palmers Green have worked with businesses to improve and support the high street. They are keen to see the local day and night-time economy thrive, and the opening of another Adult Gaming Centre in a prime spot in the high street would be highly detrimental to those efforts.
- THE COUNCIL MUST COMMIT TO THE REGENERATION OF THE AREA: Approving a licence for another adult gaming arcade on the high street is counter to the ambitions and visions of Enfield Councils Palmers Green Town Centre Action Plan published in 2022 . Enfield Council is particularly concerned that significantly higher risks are associated with gaming machines. As outlined in their Gambling Act Statement of Principles 6th edition January and there is already an adult gaming centre (Merkur), multiple betting shops as well as several pubs that house gaming machines.
- RISK TO CHILDREN: This type of venue is totally unsuitable in this area with a large number of growing families and elderly.
Children account for 20% of the demographic
in Palmers Green. Our children risk becoming normalised to gambling, and will be exposed to yet more betting shops and gamblers while en route to school, to the nearby park, playgrounds and local shops, or at bus stops. The site for the gambling application is just 80 metres from Devonshire Square, a recently created pedestrianised community space where markets and events are regularly held and children are invited to play on the bespoke street furniture. This project has been funded by Enfield Council.
FROM THEIR RISK ASSESSMENT, Palace Amusement state that they are 'aware of student learning facilities (schools & colleges) in the local area'. But It is difficult to understand how their mitigation measures - such as for instance “Frontage of venue will be designed so as not to be attractive to children. No line of sight into premises from the exterior” - could be effective and credible when THIS IS AN EXAMPLE of one of their arcades where although you can’t see in - passers by including children are enticed by bright lights and promises of £500 jackpot machines - We have a visible number of VULNERABLE PEOPLE including elderly, homeless, beggars, drug addicts and alcoholics using that segment of Green Lanes. They need to be protected from being harmed and exploited by gambling. Palmers Green ward is one of the top 40% of most deprived wards in the country. Town centres should not be places where people are encouraged to waste money, get into debt, cause damage to their lives and to their families. There are many more people now struggling financially, making them more vulnerable to such a venue. The gaming centre is in close proximity to vulnerable groups - including schools, care homes and addiction support services (*) - and would have a “harmful effect on the health and wellbeing of residents and the local area”
- LOCAL CRIME IS ON THE RISE. We must prevent the threat posed by all sources of crime and disorder, starting from gambling. *East Kent Leasing (Palace Amusements) themselves have noted that the potential of risk posed from gambling related harm in this area might be higher than normal due to the levels of social deprivation. An element of street drinking and homelessness was noted during the Risk Assessment. They also note ‘Awareness of heightened local crime in the local area’.
Data from the police already confirm an upward crime curve in Palmers Green while researches* show that for one unit increase in betting shops, shoplifting counts increased by approximately 16%, theft from person by 10%, anti-social behaviour by 7%, public disorder by 7%, and bike thefts by 6%. There is a well-known risk that these venues attract money laundering, and criminality. These venues encourage behaviour that has a negative effect on individuals, families and communities.
We implore Enfield to listen to residents and take a holistic look at our high street, with all the efforts being made by volunteer groups to improve the high street with art, planting and new businesses, there is no place for another adult gaming centre.
Thank you all who will sign the petition and, crucially will email their objections directly to the council.
(*) References:
Devonshire Square community space
Broomfield Park
UK Community Centre, 26 Oakthorpe Road, N13 5JL
Medstar UK, 200 Green Lanes, N13 5UE ADDICTION/VULNERABLE SUPPORT SERVICES
Woodlands Residential Care Home, 33-35 Fox Lane, N13 4AB
Abbeydale Care Home, 51-53 Fox Lane, N13 4AJ
Roland Residential Care Home, 231 North Circular Road, N13 5JF
Priory Adult care - 43 Devonshire road
https://www.prioryadultcare.co.uk/find-a-location/devonshire-road/
Hazelwood House, 9 Hazelwood Lane, London N13 5EZ
https://www.shinepartnerships.co.uk/hazelwood-house/
Forensic (inc 37/41) & Non Forensic Mental Health & Complex Needs inc. LD
Millennium Care 10, 1 Old Park Road, London N13 4RG Tel: 020 8447 8897
Millennium Care 7, 89 Fox Lane, London, N13 4AP Tel: 020 8882 8171
www.millenniumcareservices.com
Queen Ann Care, 38-42 Old Park Road, Palmers Green, London, N13 4RE
http://queenanncare.com/
Hazel House, 57 Fox Lane Palmers Green N13 4AJ
https://www.conniferscare.co.uk/homes/hazel-house/
Grovelands House, 64 – 66 Grovelands Road, London N13 4RH
https://www.shinepartnerships.co.uk/hazelwood-house/
Forensic (inc 37/41) & Non Forensic Mental Health & Complex Needs inc. LD
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More grounds for objecting to new Green Lanes adult gaming centre
Karl Brown
11 Jul 2023 16:02 6893
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One (large) operator will have the opportunity to install 80 gaming machines per venue, four times the current limit.
For the bingo sector – I recall this was the Merker Slots sector - the changes will remove the 20% restriction of B3 category machines (minimum £2 stake, maximum £500 prize).
A City estimate sees one operator going from £20m operating profit to a forecast £55m pa as a result.
That reads like a risk of more applications to me.
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More grounds for objecting to new Green Lanes adult gaming centre
PGC Webmaster
12 Jul 2023 00:02 6894
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Mati Valdivieso from Palmers Green Action Team has sent me some more arguments to use when writing to the council objecting to licensing of an adult gaming centre in the former Lloyds Bank premises:
QUOTE
It has been brought to our attention that Enfield's Development Management Document (DMD) adopted on November 2014 states under paragraph DMD33:
Betting Shops Proposals for betting shops will only be permitted if all of the following criteria are met:
a. The proposed development is located within a local or district centre, or within the secondary shopping frontage of Enfield Town;
b. There should be a minimum of five non-betting shop units between the proposed site and the next betting shop premises, or at least 25m, between them, whichever is greater; and
c. The proposal should be designed such as to provide an active frontage during the daytime and evening, and to have a positive visual impact on the street.
The former Lloyds premises at 369-371 Green Lanes are within close proximity to the other 5 betting establishment in Palmers Green high street as follows:
Ladbrokes | 363 - 365 Green Lanes | 19 meters |
Paddy Power | 314 Green Lanes | 24 meters |
Merkur Slots | 292 Green Lanes | 71 meters |
Betfred | 319 Green Lanes | 133 meters |
Ladbrokes | 402 Green Lanes | 322 meters |
In addition it will be 78 meters away from G&S Jewellers which also operates as a pawn shop. But more importantly, there is only one non-betting shop at 367 Green Lanes between Ladbrokes and the new proposed Adult Gambling Centre.
Will this not contravene the guidance in DMD33?
UNQUOTE
The Licensing team however cannot take this into consideration: extract below from the Gambling Commission guidance ( full guidance found here ) which highlights how it deals with planning:
7.65. When dealing with a premises licence application for finished buildings, the licensing authority should not take into account whether those buildings have to comply with the necessary planning or building consents. Nor should fire or health and safety risks be taken into account. Those matters should be dealt with under relevant planning control, building and other regulations, and must not form part of the consideration for the premises licence. S.210 of the Act prevents licensing authorities taking into account the likelihood of the proposal by the applicant obtaining planning or building consent when considering a premises licence application. Equally, the grant of a gambling premises licence does not prejudice or prevent any action that may be appropriate under the law relating to planning or building.
To summarise, a licence cannot be refused if planning permission has not yet been granted. However, to trade lawfully, both a licence and the appropriate planning permission are required - one does not override the other.
The Council's Planning Team are aware of this licence application and the concerns raised, and we expect it will be considered once a planning application is submitted.
So the residents should submit their objections to those points but ideally we need to continue developing our answers for the following points:
- Devonshire Square being a public space design for families and children, e.g. dot-to-dot floor drawings, climbing structures
- There are at least four houses where vulnerable adults live in close proximity to the high street. The details can be found at https://www.healthwatchenfield.co.uk/sites/healthwatchenfield.co.uk/files/Enfield%20Care%20Directory-2019.pdf and the council should be aware of the locations.
- Crime figures for from the MET Monthly Crime Data for Enfield Palmers Green: https://public.tableau.com/app/profile/metropolitan.police.service/viz/MonthlyCrimeDataNewCats/Coversheet show an increase in the past two years.
From May 2021 to May 2022: Offence count: 1306 - Offences per 1,000 pop. 120.5 : +5.3 % compared to previous 12 months
From May 2022 to May 2023: Offence count: 1516 - Offences per 1,000 pop. 139.9 : +16.3 % compared to previous 12 months
And we will enquire (including Cllr Chris James) with on whether the premises need to apply for a change of use from Class E to Sui generis.
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Proposed gambling arcade on the high street
Cara McD
16 Jul 2023 12:26 6906
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People have also taken to creating their own protest posters and adding them to the windows of the vacant shop, so feel free to create your own so we can highlight the campaign and show the strength of feeling in the community.
If we are unsuccessful in stopping the licence the next step is to object to a planning application that Palace Amusements will need to submit. We will object on the grounds that it is next door but one to a Ladbrookes which goes against the The Development Management Document (DMD 33) which states that "There should be a minimum of five non-betting shop units between the proposed site and the next betting shop premises, or at least 25m, between them, whichever is greater."
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