Betfred update

'Oh no, not more betting shop stuff' I hear you groan.'Haven't you flogged that particular horse to death with no hope of success in the light of the current licensing laws?'

Well you're right on one count - the licensing laws are of little use to communities trying to protect the viability and diversity of local shopping streets.

Despite vocal opposition, a massive petition and a dozen individual letters of objection, Betfred's application for a gambling licence for the former Halifax building was passed by Lewisham Council's licensing committee. Objectors are offered the right to appeal but in truth there is little point.

'So why are you harping on about it?' I hear you say. 'Put it behind you and get back to moaning about the architectural quality of local developments!'

All in good time my friends. Meanwhile, gather round and listen carefully.

Back in 1974 when the Halifax first moved into 93-95 Deptford High Street, planning permission was granted for the premises to be classified as A2 (bank/building society) use. However this was conditional upon the unit being occupied by a building society. In order for Betfred to be able to occupy the premises, Lewisham's planning department must grant a variation to the classification.

In considering whether to grant this application, the planning department must take note of national and local planning policy. In particular this means Lewisham Council's Unitary Development Plan as well as various national planning policies relating to sustainable development, for one thing.

Chapter 8 of Lewisham's Unitary Development Plan, which basically sets out the guidelines for planning officers to follow when deciding planning applications, classifies Deptford High Street as a 'district town centre' - just one step down from the importance of Catford and Lewisham as major town centres. The south end of it, including the former Halifax building, numbers 93-95, forms the 'core shopping area'.

According to 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."

The UDP explains the council's reasoning for wanting to restrict non-retail use; "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 national planning guidelines, which Betfred's planning supporting statement helpfully refers to in great detail, are similarly clear on the question of sustainable development, but also require 'that the impact of development on the social fabric of communities is considered and taken into account'; and direct planning authorities to remember that 'a diversity of uses in centres makes an important contribution to their vitality and viability' and to 'take measures to conserve, and where appropriate, enhance, the established character and diversity of their town centres'.

Betfred's argument in favour of its application is almost entirely based on the fact that it will create employment, and 'contribute to the local economy' which is questionnable. It's not unreasonable to surmise that what it contributes to the local economy in salaries will be far less than what it takes back out in the course of its business.

Almost laughably, Betfred also suggests that its application meets the requirement for a diversity of uses. Being rather lost for words here, I'm not even going to attempt to rebuff that one.

Anyway, that's where you lot come in.

Assuming you agree that maintaining diversity (of uses, not just a range of betting shops) and a strong retail function is vital to the continuation of Deptford as a shopping centre, please consider objecting to this application.

The deadline for objections is Wednesday 2 March.

If you do not want to write your own objection letter, there are new petitions being passed around and held at local shops that you can sign. But it's worth remembering that however many people sign a petition - whether 2 or 2,000 - it will be counted as a single objection.

If you really want your objection to count, send a letter.

It's best to write it in your own words, or again, if duplicates are received, the committee may count them as a single objection. However, a group of local campaigners have drafted a sample letter which you can use as the basis for your own objection, which notes some of the salient points you should highlight.

1. include your name and address to prove that you are an 'interested party' - you don't have to live or work on the High Street, if you live locally and shop there your views are still relevant. The planning department will need your contact details to advise you of any hearings or committee meetings where decisions will be taken.

2. include the application reference number DC/11/76362/X

3. say that you live on/have a business on/shop on the high street, and you object strongly to this application

4. tell them why;

- it will undermine the retail function of the shopping area and is contrary to the policies of the council's Unitary Development Plan which relate to Deptford, which is classified as a district shopping centre

- another betting shop will not add to the diversity of businesses on the High Street - in fact it will reduce it by duplicating the type of business that already exists at five other premises in the core shopping area

- there is no evidence to suggest that the premises would be left empty for very long, should the variation not be granted

5. if you want to refer to the specific policies, there is further detail below. But it's not necessary to make your objection valid.

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.

Send your objection by email to planning@lewisham.gov.uk or by mail to the planning officer Russell Penn, at the Planning Department, Town Hall, Catford, London SE6 4RU. You can also comment online here.

As a footnote, it's worth remembering that Haringey Council recently won a case against Paddy Power on a similar basis - although they were applying for a change of use, rather than a variation. The case went to appeal and was dismissed by the inspector. Paddy Power's application for costs was also rejected.

And if you needed a further word of encouragement, Paddy Power's applications to make changes to the outside of the former Deptford Arms and to put up new signs have also been refused, both by the council's planning officers, and dismissed at appeal. The changes have already been made of course, so we await with interest to see what happens next.