Written evidence submitted by the Ladder Community Safety Partnership (LCSP) (GA 08)

Submission endorsed and fully supported by:

The Gardens Residents Association (GRA)

The Harringay Green Lanes Traders’ Association


• As representative residents’ and traders’ organisations, we are concerned at the negative impact of the ever-increasing number of gambling outlets in our local high street (Green Lanes, Harringay, in the London Borough of Haringey)

• We are particularly concerned that the recent legislation has facilitated the clustering of 8 betting shops (and 1 AGC) in a very small area of Green Lanes

• This clustering has in turn led to the provision of 32 FOBTs within this very small area

• We are worried about both the likely impact on vulnerable adults and on the economic viability of our local high street

• Current legislation makes it impossible for residents successfully to oppose new gambling outlets in our high streets

1. About the LCSP, the GRA and the Harringay Traders’ Association


1.1 The LCSP is an umbrella organisation representing Neighbourhood Watches and Residents’ Associations in the so-called ‘Ladder’ roads of Harringay Ward on the west side of Green Lanes, in the London Borough of Haringey. The LCSP has been in existence for some 13 years, meets every month, is an award-winning organisation and aims to improve the quality of life for all who live in the Harringay area.

1.2.1 This submission is fully supported by the Gardens Residents Association (GRA) which works closely with the LCSP on planning and licensing matters. Founded in 1999, the GRA represents the roads known as the Gardens in the St Ann’s Ward of Haringey, which are on the eastern side of Green Lanes. The GRA has received numerous awards, in particular for its community garden and recycling activities.

1.2.2 Finally, the submission is also fully endorsed by the Harringay Green Lanes Traders’ Association. This is a very active, long-standing and award-winning Association which represents the interests of some 200 local businesses. It is highly significant that local traders are in complete agreement with local residents in their joint concern about the proliferation and clustering of gambling outlets in Harringay Green Lanes, our high street.

2. Residents, traders and gambling in our local high street

2.1 We have represented the growing concerns of residents and traders since all of the provisions of the Gambling Act 2005 became law in September 2007.

2.2 In particular, we have opposed the consequent increase (from 5 to 9) in the number of gambling outlets clustered in a small area of Green Lanes; Harringay and St Ann’s Wards (the west and east side of Green Lanes respectively). This small area now has 8 betting shops and 1 AGC (slot machines).

2.3 Despite opposition from a wide variety of local stakeholders (LCSP, GRA, traders, Councillors, MP) we have failed to prevent the opening of four new gambling outlets in Green Lanes.

2.4 Haringey Council, as the local Licensing Authority, initially refused permission in the light of the special problems in our local area (see below), but the decisions were overturned on appeal by the Magistrates’ Court.

2.5 Since then, all further applications for a gambling licence within the Borough have – obviously – been granted by the Council

3. Clustering of Betting Shops


3.1 Since the Gambling Act removed the requirement for an applicant to show the need for another outlet in a given area, there has been a very clear development of the clustering of betting shops within key areas of the borough of Haringey.

3.2 Betting shops are located in very specific areas of the borough, especially in he Green Lanes corridor (Harringay - Wood Green), Tottenham High Road, and West Green Road. By contrast, few are to be found in the more wealthy areas: Highgate, Muswell Hill, Fortis Green and Crouch End.

3.3 The East – west divide in the 66 betting shops in the borough is 85%-15%

3.4 This is because betting shops are located in key geographical areas: poorer areas of the borough and those with a known demographic which is more likely to gamble (evidence shows that punters are more likely to be male, aged 18-35, often from minority ethnic backgrounds, and living in poor accommodation and suffering from poor health) [GamCare Annual Reports; Gambling Prevalence Surveys]

3.5 This east-west divide in Haringey is a reflection of the situation in London as a whole (eg 80 outlets in Newham but only 29 in Richmond)

3.6 We believe that the clustering of betting shops matters a great deal because it can have an adverse effect on an entire local community.

4. Problem Gambling


4.1 GamCare (funded by the gaming industry) is the leading agency offering help and support to problem gamblers. Their Annual Reports reveal the steadily increasing numbers of people seeking help each year.

4.2 GamCare=s Annual Reports reveal that their callers seeking help were largely male, and that the key age-group was 18-35 years old - the very group which are above-average in numbers in the two wards either side of Green Lanes, often single, living in poor or sub-standard accommodation such as HMOs (see below).

4.3 These large figures are only the tip of the iceberg: the Gambling Commission estimates that there are a quarter of a million problem gamblers in Britain, but Gamblers Anonymous thinks it is well over half a million. It=s certainly a significant and growing problem.

5. Vulnerable Adults


5.1 There is a very high number of vulnerable adults in and around the Harringay - St Ann’s area, adjacent to Green Lanes, where so many betting shops are clustered.

5.2 Indeed, so well known are the numbers and problems of vulnerable people in the area that the Drug and Alcohol advisory services for Haringey Council launched a special outreach scheme in December 2007, specifically for the local community around Green Lanes.

5.3 There are extensive mental health care facilities at St Ann=s Hospital, which draws in vulnerable adults from a broad area of North London.

5.4 There is also an exceptional number of vulnerable adults living in >care in the community= in the two wards adjacent to Green Lanes.

5.5 There is also an unusually high number of vulnerable adults in the area because of the huge number of HMOs (Houses in Multiple Occupation). Harringay ward has the largest number of any ward in the Borough, with St Ann=s not too far behind. This has been recognised by the creation of a new Additional Licensing Scheme for all HMOs in Harringay Ward, with effect from October 2011.

5.6 Too often, family houses have fallen victim to excessive sub-division (quite often illegally) into large numbers of poor quality small units, which are often found to be homes of young single men - many of them vulnerable adults: recent migrants, asylum seekers, refugees, those who lack the means to live anywhere else.

5.7 Such adults may be all too willing to take a gamble, believing that they have nothing more to lose. Academic studies in a number of countries, including Australia, Sweden and the United States, have shown the rate of problem gambling to be several times higher among minority or immigrant groups than the rest of the population.

5.8 Despite all these factors, which were respected by the Council’s Licensing Committee in their initial decisions, the concerns of the local community were overridden by the Magistrates’ Court on appeal, and, as noted above, licences have accordingly been granted for 3 more betting shops and 1 AGC in Green Lanes.

6. Vulnerable Adults and Problem Gambling: FOBTs

6.1 The lives of vulnerable adults are clearly harmed by addiction of any kind.

6.2 FOBTs (Fixed Odds Betting Terminals) are recognised as highly addictive. As early as 2003, the government expressed its concerns about the growing number of FOBTs as an undesirable development. Tessa Jowell MP, then Secretary of State at the DCMS, in a written statement to Parliament (8 Jan) said:

>The Government has noted with concern the increasing installation in licensed betting offices of machines , described as fixed odds betting machines, which enable customers to play virtual casino games.... We take the view that the uncoordinated proliferation of high-prize machine-gaming on the high street risks seriously increasing problem gambling=

6.3 This led to the limitation of 4 high-value FOBTs in a betting shop and a code of practice for FOBTs in Nov 2003.

6.4 However, as betting shops proliferate and cluster in a small area, tiny sections of high streets in Haringey are saturated with 30 or 40 FOBTs. In Harringay Green Lanes, for example, the betting shops contain 32 FOBTs, with yet more lower value machines in the AGC (Adult Gaming Centre).

6.5 This clustering makes the limitation of 4 FOBTs in a single betting shop a largely pointless exercise.

6.6 4 FOBTs in a single betting shop have been estimated (The Guardian: 12/01/08) to produce a profit of ,2000 - ,2500 per week - a huge financial drain on the well-being of a local community with a cluster of betting shops

6.7 Research evidence overwhelmingly suggests that FOBTs are clearly associated with the highest levels of problem gambling (eg Gambling Prevalence Survey 2007)

6.8 Much of the crime/ASB associated with betting shops is also the result of frustration from young male customers who have lost large sums of money playing on FOBTs (as shown in the crime figures noted below).

6.9 We are seriously concerned that more gambling outlets and more FOBTs in small stretches of our high streets will simply provide more temptation, through increased availability, for vulnerable local adults. There is plenty of academic research which supports this stance, ie that increased availability leads to more gambling and more problem gambling for the vulnerable.

6.10 One recent study (supported by Gamcare - Gambling and Debt Pathfinder Study 2009, produced jointly by Manchester Metropolitan University, Gamcare, the Money Advice Trust and the Salvation Army) noted how >the more marginalised and deprived are often the most susceptible= (to problem gambling and debt). Moreover, >gamblers who had self-excluded [in a bid to control their addiction] from one or two venues in a locality tended to move between different gambling operators as a strategy to avoid detection...= (p122). In other words, more gambling outlets in an area make life more tempting for problem gamblers.

7. Conclusion

In conclusion, our members are concerned that betting shops (with FOBTs), when clustered together in small areas of our high streets, tend to:

• upset the diversity and vibrancy of the high street

• change the character of the area

• target a specific clientele and are therefore not inclusive

• are obviously not like ordinary shops, because they need special licensing rules and regulations to control their activities, to reduce the harm they may cause

• are not community-friendly: no children or youths (obviously) and very few women customers

• discourage shoppers from the high street as there are fewer shops to use

• can also discourage shoppers (especially women) because of men gathering outside, sometimes blocking the pavement and/or leaving cigarette associated litter, all of which makes the street look unattractive and potentially even threatening (smoking and gambling, especially problem gambling, are significantly associated: Gambling Commission March 2009)

• tend to attract more crime to the area where they are located (hold-ups, robberies on cash in transit, damage to FOBTs, customers rage/ASB on losing money etc). No ordinary shop would cause all of these issues (Figures for Green Lanes supplied by the Met Police for consideration of a licence for a new betting shop at 513 Green Lanes - Licensing Cttee hearing 25/01/10 showed 46 recorded crimes in the financial year 2008/09 and 37 for the period April-December 2009. Therefore 83 reported criminal acts took place in Green Lanes between April 2008 and December 2009 which are directly attributable to betting shops)

• tend to lead to problem gambling especially in the case of FOBTs; academic research has also shown that increased availability of opportunities to gamble is often associated with more gambling and more problem gambling (eg Prof Jim Orford: Problem Gambling and other Behavioural Addictions, 2003)

8. Recommendations



8.1 At present, A2 outlets include banks, building societies, estate agents - and betting shops. We believe that there should be a special and separate planning use class for betting shops (eg sui generis) so that planning permission would have to be obtained for a change of use.

8.2 We are aware that the government has recommended the use of Article 4 Directions to restrict the clustering/proliferation of betting shops. However, this is a slow, cumbersome and expensive procedure, and Councils may be subject to legal and financial challenges if they proceed along this route. In the current economic climate this is not a realistic way forward.

Betting Shop Premises

8.3 Where a large number of gambling outlets are already in existence in a finite area, a local authority should be able to require an applicant to show why existing demand has not already been met. The applicant should have to present a case for a new outlet rather than automatically (>aim to permit=) be granted a licence. A simple change in the 2005 Act would facilitate greater powers for local authorities/residents regarding the number and location of gambling outlets. At present, in the opinion of at least one leading Legal Counsel, no new applications can, in effect, be refused. That cannot be right or fair.


8.4 Given the available research, especially on problem gambling, much tighter regulations should be placed on FOBTs. Serious consideration should be given to reducing the permitted number, and imposing tighter controls regarding location and use, which already occurs in some other countries.

June 2011

Prepared 29th July 2011