A Fair Deal: Betting Shops, Adult Gaming Centres and Pawnbrokers in Brent. Policy Evidence Base. 1.0 Introduction

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1 A Fair Deal: Betting Shops, Adult Gaming Centres and Pawnbrokers in Brent Policy Evidence Base 1.0 Introduction The purpose of this report is to provide an evidence base for town centre policies in the emerging Development Management Development Plan Document (DMDPD). This report summarises the policy context and evidence base that has informed the council s decision to seek to prevent an over-concentration of the following uses through the planning system:- Pawnbrokers and Payday Lenders Betting Shops Adult Gaming Centres (AGCs) 2.0 Background Definitions A pawnbroker is a store that offers loans in exchange for personal property as equivalent collateral. If the loan is repaid in the contractually agreed timeframe, the collateral may be repurchased at its initial price plus interest. If the loan cannot be repaid on time, the collateral may be liquidated by the pawnshop through a pawnbroker or second hand dealer through sales to customers. A payday lender is a company that lends customers small amounts of money at high interest rates, on the agreement that the loan will be repaid when the borrower receives their next wages. Increasingly many pawnbrokers also function as payday lenders. Brent s town centre health check data indicates many pawnbrokers in the borough are also operating as payday lenders and the two can rarely be distinguished, therefore for the purposes of this report pawnbrokers and payday lenders are included in one category. The definition of a betting shop is that the primary activity on the premises must be betting services. Each premises is permitted to have up to four gaming machines, known as fixed odds betting terminals. Gaming machines now account for a higher proportion of betting shop revenue than over the counter betting. 1 It has been suggested in order to get round limits on the number of machines per shop, bookmakers are simply opening multiple shops in close proximity. An AGCs is a place of gambling where access is restricted to persons over 18. An AGCs may have a limited number of category B3 or B4 gaming machines (not exceeding 20% of the total number of gaming machines which are available for use on the premises), and any number of category C or D machines. Gaming machines are categorised by their maximum stake and prize, B3 or B4 machines have a higher 1 Industry Statistics, April 2009 to September Available from: 1

2 maximum stake and prize than category C or D machines. A table of gaming machine categories is included in appendix A. Planning Controls AGCs are use class sui generis, whilst betting shops and pawnbrokers/payday lenders fall within the A2 use class. This means these businesses can open in units previously used by financial and professional services (A2), restaurants and cafés (A3), drinking establishments (A4) and hot food takeaways (A5) without planning permission being required. Local authorities do have the power to overrule these permitted changes of use through an Article 4 Direction under the Town and Country Planning Act. The National Planning Policy Framework (2012) advises that the use of Article 4 Directions to remove national permitted development rights should be limited to situations where this is necessary to protect local amenity or the wellbeing of the area. Licensing Controls The Gambling Act 2005 ( the Act ), which received Royal Assent on the 7 April 2005, replaced most existing gambling law and created a new system involving tri-partite regulation by the Independent Gambling Commission, Licensing Authorities (local councils) and Central Government. The council s Licensing Committee is responsible for determining premises licenses and a range of permits in the borough to authorise the provision of gambling facilities, including AGCs and betting premises licenses. In exercising most of their functions under the Act the Licensing Authority must have regard to the licensing objectives, which are:- preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime; ensuring that gambling is carried out in a fair and open way; and protecting children and other vulnerable persons from being harmed or exploited by gambling. While the Gambling Commission does not attempt to define vulnerable persons, it does offer a working category, which includes people who gamble more than they want to, beyond their means; and people who may not be able to make informed or balanced decisions about gambling due to a mental impairment, alcohol or drugs. The Act removed the demand test meaning it is no longer necessary to prove there is demand for further premises in an area. No regard can be given to the likelihood of the applicant obtaining planning permission or building regulations approval for their proposal. Therefore, the wider issues that may be covered under a planning consent, such as public nuisance and developing local high streets to meet local needs, cannot be taken on board. 2

3 3.0 Policy Context The National Planning Policy Framework (NPPF) (2012) emphasises that the purpose of the planning system is to contribute towards sustainable development. One of the three dimensions in achieving sustainable development is for the planning system to perform a social role by supporting strong, vibrant and healthy communities. Consequently one of the core planning principles is to take account of and support local strategies to improve health, social and cultural wellbeing for all and deliver sufficient community and cultural facilities and services to meet local needs. In relation to plan making, local authorities should have an up to date and relevant evidence base for the Local Plan. To develop this evidence base local planning authorities are to work with public health organisations to understand and take account of the health status and needs of the local population and information about relevant barriers to improving health and wellbeing. Town centres are recognised as being integral to meeting local need and supporting wellbeing. The NPPF states that Local Planning Authorities (LPAs) should recognise town centres as the heart of their communities and pursue policies to support their viability and vitality. LPAs should set out policies that make clear which uses will be permitted in such locations, and promote competitive town centres that provide a diverse retail offer which reflects the individuality of a town centre. National guidance also requires planning policies and decisions to guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community s ability to meet its day-to-day needs. Similarly, London Plan Policy 4.8 states that boroughs should support a successful, competitive and diverse retail sector which promotes sustainable access to the goods and services that Londoners need. Local Plans should enhance the vitality and viability of town centres and develop policies to prevent the loss of retail and related facilities that provide essential convenience and specialist shopping. Furthermore, paragraph 157 of the NPPF requires Local Plans to identify areas where it may be necessary to limit freedom to change the uses of buildings, and support such restrictions with clear explanation. The Draft Further Alterations to the London Plan (January 2014), acknowledges the particular concern over-concentrations of uses, such as betting shops, can give rise to. Accordingly, policy 4.8 states Local Plans should manage clusters of uses having regard to their negative impacts on broader vitality and viability, competitiveness, quality and diversity of offer, local identity, and community safety. The Mayor s draft Town Centre Supplementary Planning Guidance (SPG) (2013) provides guidance on the implementation of London Plan town centre policies. The SPG highlights it is important that the planning system is used to help manage clusters of uses in the interests of having diverse and therefore more vital and viable town centres. There may, therefore, be occasion for regulation through the planning system, if a concentration of a particular use has a significant negative impact on the objectives, policies or priorities of the London Plan. The SPG goes on to state there is an urgent need to enable LPAs to control the proliferation of betting shops which can lead to a narrowing of a centre s offer, and raise concerns about crime and antisocial behaviour. 3

4 In summary, the policy context supports limiting the freedom to change use where this is necessary to ensure town centres provide a diverse offer, which meets community needs, and are therefore more viable. Local Plan policies should also seek to improve health, social and cultural wellbeing. 4.0 Impact on Vitality and Viability of Town Centres There is increasing evidence that town centres are becoming overly dominated by particular uses. A joint study by consultancy the Local Data Company (LDC) and Oxford University s Saïd Business School, examining 1,300 UK high streets between 2011 and 2013, shows pawnbrokers/payday lenders and betting shops have increased their town centre presence by 17%. Furthermore, there has been a 94.8% increase in pawnbrokers across London since January 2010 along with a rise in betting shops. 2 Table 1: Increase in selected uses in London s town centres Type Number, 01/01/2010 Number, 01/12/2012 % Change Betting Shops % Pawnbrokers % Charity shops % Supermarkets % Discount stores % Source: Local Data Company, January 2013 Brent has also seen a significant increase in these uses. As figure 1 indicates between 2007 and 2013 the number of betting shops in Brent s town centres increased by 41% from 43 to 61. During this period the number of pawnbrokers/payday lenders in Brent s town centres increased by 171% from 7 to 19. In comparison the number of AGCs has increased by 1 unit, reflecting the fact the council has been able to prevent an over-concentration of AGCs through its planning policies. Based on Local Data Company and Brent s health check figures 7% of London s betting shops and 7% of London s pawnbrokers/payday lenders are located in Brent s town centres. 2 Open For Business: Economy Committee investigation into empty shops on London high streets, London Assembly, March

5 Number Increase in selected uses in Brent's town centres Figure Year Bookmakers Pawnbrokers and Payday Lenders Adult Gaming Centres The diversity of a number of Brent s town centres are being impacted on by an overconcentration of these uses, as illustrated by figure 2. Town centre health checks indicate that 7.6% of Wembley Park centre frontage and 5.5% of Colindale centre frontage now comprises of betting shops. Sudbury, Wembley, Harlesden, Kilburn and Neasden also have a high proportion of frontage in use as AGCs, pawnbrokers/payday lenders and betting shops. Furthermore, a study by Geofutures for the Department for Communities and Local Government found Kilburn, Cricklewood and Harlesden town centres had amongst the highest number of bookmakers per hectare alongside Walworth, Camberwell, Newham, Barking, Haringey and Acton. 3 3 Betting Shops on the high street: An overview, Geofutures,

6 Burnt Oak Colindale Cricklewood Ealing Road Harlesden Kensal Rise Kenton Kilburn Kingsbury Neasden Preston Road Queen's Park Sudbury Wembley Wembley Park Willesden Green 8.0 Proportion of frontage in selected uses in Brent's town centres (%) Adult Gaming Centres Pawnbrokers/ Payday Lenders Betting Shops Total Figure 2 Major District Local 6

7 There is evidence of clustering in a number of Brent s town centres. As the map below indicates, in Wembley Town Centre these uses are clustered in the frontage adjacent Central Square. Map 1 7

8 Similarly, in Harlesden Town Centre uses cluster in the primary frontage on High Street Harlesden. Map 2 This is of concern as an over-concentration of such uses reduces the diversity of town centres, which not only impacts on a centre s ability to meet local need but also on vitality and viability. The London Assembly report Open for Business: Empty shops on London s high streets (March 2013), provides evidence low quality units, such as betting shops, pawnbrokers and payday lenders, reduce the overall value of the high street. The study found strong evidence that reduced diversity impacts on the attractiveness of a centre, and therefore footfall. 4 This reflects the findings of footfall surveys undertaken in Wembley and Kilburn. The council commissioned independent consultants to undertake pedestrian counts on a Friday and Saturday in October Count points were located at various points throughout the town centres including adjacent bookmakers, pawnbrokers and payday lenders. Figure 3 and 4 compare the footfall adjacent to particular town centre uses. The highest footfall in each survey was recorded adjacent retailers. The footfall was significantly lower adjacent betting shops, pawnbrokers and payday lenders. 4 Dan Morgan, British Retail Consortium, Transcript of Economy Committee meeting, 19 September 2012, page 40; Written submission from LB Lewisham, September 2012, page 2 8

9 Pedestrian Count Pedestrian Count Kilburn Footfall Friday Saturday Figure Wembley Footfall Friday Saturday Figure 4 9

10 Inflow However, the difference in footfall could be impacted on by other factors, such as whether the frontage was primary or secondary. Therefore, the council also undertook pedestrian count surveys of different uses within the same length of frontage. The counts took place during 2009 and The method followed was counts for four 15 minute periods between 11am and 5pm. This was considered the optimum period for the operation of the majority of town centre uses, and would therefore give a fair comparison. The graph below shows the results of pedestrian counts undertaken by the council in 34 surveys across the borough, measuring footfall in betting shops, payday lenders/pawnbrokers and AGCs against adjacent units with varying uses. The results, provided in full in appendix B, show that on average adjacent units attracted significantly higher inflow than betting shops, payday lenders/pawnbrokers and AGCs. As all adjacent units fall in the same frontage bracket as the relevant surveyed unit, we can conclude that the patterns demonstrated in the 2012 footfall surveys in Wembley and Kilburn, as well as the more recent data shown below, cannot be simply a result of lower footfall being recorded in secondary frontage. 120 Average Inflow by Use Adult Gaming Centres Pawnbrokers Betting Shops Comparison Retail All Adjacent Uses Convenience Retail Banks Use A breakdown of results by use indicates that retail and banking functions continue to attract the highest footfall across the borough, which is again consistent with the 2012 footfall surveys, which recorded highest footfall figures outside retailers. The consistency of retail uses performing well across the borough highlights the need to promote and protect these functions in Brent s high streets from over-concentration of uses which act to their detriment. 10

11 In addition to the detrimental impact on footfall, there is also concern betting shops can have the effect of increasing rents in an area, therefore pricing out smaller independent chains. 85% of all betting shops operating in Great Britain are owned by four operators William Hill, Ladbrokes, Gala Coral Group and Betfred. 5 National chains such as these can afford to pay higher prices than independent businesses. This national trend is reflected in Brent where 88% of betting shops are operated by national chains William Hill, Ladbrokes, Gala Coral Group and Paddy Power. An analysis of health check data indicates that nearly 50% of the premises converted to betting shops, AGCs and pawnbrokers/payday lenders since 2009 were previously occupied by independent businesses. Table 2: Ownership of betting shops in Brent Betting Shop Owner Proportion of betting shops William Hill 37.2% Ladbrokes 27.9% Gala Coral Group 13.9% Paddy Power 8.14% Other 12.94% Source: Gambling premises licence register (September 2013) 4.0 Impact on Wellbeing In addition to reducing the viability and vitality of town centres, there is increasing evidence uses such as betting shops, pawnbrokers/payday lenders and AGCs can negatively impact on wellbeing. Gambling Problem gambling is classed as a health disorder and has been identified as gambling that compromises, disrupts or damages family, employment, personal or recreational pursuits. 6 The NHS estimates there may be as many as 450,000 problem gamblers in Great Britain. There is a link between gambling, alcohol abuse and mental health problems. Rates of depression and attempted suicide among gambling addicts are double the national average. Gambling addicts are also more likely to go to prison as a result of criminal activity, mainly theft and fraud. 7 There is evidence to suggest that the growth of gambling establishments, such as AGCs and betting shops, is particularly prominent in areas with high levels of social and economic deprivation. A paper published in the Journal of Gambling Studies by social research institute NatCen in December 2012 showed that the greatest concentration of gambling machines could be found in Britain's most deprived areas, with the highest density of machines mirroring the profile of those most at risk of experiencing harm from gambling. 8 5 Industry Statistics, April 2009 to September Available from: 6 Griffiths, M. Gambling addiction and its treatment within the NHS: A guide for healthcare professionals British Medical Association, London (2007) 7 NHS Gambling addiction, September Heather Wardle, Research Director, Health and Wellbeing, NatCen, Betting shops blighting the high street? How, why and where and why?, August

12 This is supported by an analysis by Geofutures which reveals that betting shops cluster in those town centres across Great Britain where residents are on the lowest incomes and in areas where those who can least afford to spend money on an activity which is loss making. The study found on average across England and Wales (and some regional variation was evident), for every percentage point increase in unemployment claimant counts in a local authority, the number of betting shops in that local authority increased by 20%. 9 Furthermore, the 2010 British Gambling Prevalence Survey undertaken by the Gambling Commission found the profile of high-time only gamblers consisted disproportionately of those with the poorest socio-economic indicators. This group showed a relative preference for betting on horse races, fixed odds betting terminals and playing casino games. The study also found an association between problem gambling and being Asian/Asian British, unemployed and being in bad/very bad health. This of particular concern as the profile of Brent residents indicates they are more likely to be at risk from problem gambling. Brent is characterised by high levels of unemployment, particularly long-term unemployed, low household incomes and dependence on benefits. In 2010 Brent was ranked as the 24th most deprived borough in England. 10 According to Census data in % of all residents were unemployed. This is an increase of 0.81% since The number of individuals who are unemployed and have never worked doubled to 1.4% of the borough s population in 2011, greater than the Outer London average (1%). Long-term unemployed increased by 65% to 2.2% of the borough s population, greater than the outer London average of 1.9%. In terms of ethnicity 33.01% of Brent s population is Asian or Asian British, also indicating the population is more at risk from problem gambling. A study undertaken for Fairer Gambling and reproduced in the Guardian on January shows that Brent Central comes 8 th in the country in unemployment ratings and has correspondingly high numbers of betting shops and FOBTs. 11 The map below compares levels of deprivation, as measured by the Indices of Multiple Deprivation, to the concentration of betting shops in town centres. The general trend is that centres in wards with higher levels of deprivation have a greater concentration of betting shop, pawnbrokers/payday lenders and AGCs. 9 Geofutures, Analysis of high street book makers across Britain, August Indices of Multiple Deprivation (2010) 11 Gambling and Unemployment, the Guardian, 4 January 2013: =1 12

13 Map 3 Furthermore, research has shown that increasing the availability of particular forms of gambling can have a significant impact on the prevalence of problem gambling within a community. 12 Allowing opportunities to gamble to continue to increase could negatively impact on the wellbeing of Brent s community. Money Lending Studies highlight a significant growth in payday loan debts. Between January and June 2013, StepChange Debt Charity helped 30,762 people with payday loan debts. For the whole of 2012, this figure stood at 36, Between 2011 and 2012, the average payday loan debt of the charity s clients in London rose by 563. People using high-cost credit such as payday loans, home credit, store cards and catalogues are more likely to be behind on essential household bills. In % of all StepChange Debt Charity clients had Council Tax arrears, this rose to 17.1% among people with a least one high-cost debt, and 21.8% among those with payday loans. 6.3% of all clients had arrears on gas payments. For those with at least one high-cost credit debt this figure rose to 7.6% and 8.2% among those with payday loan debts. 8.9% of all clients were behind on electricity payments. For those with at least one high-cost credit debt, this figure increased to 10.4 percent and 10.9% among those with payday loan debts. 12 Problem gambling. The Psychologist: Bulletin of the British Psychological Society 16:582-84, Griffiths.M.D, StepChange Debt Chairty, 13

14 Furthermore, a study by Citizens Advice found 3 out of 4 people struggle to repay payday loans (1,539 cases). There is also evidence that payday loans can lead to a cycle of borrowing which is difficult to break. This is because many borrowers are unable to pay off their loan plus lenders fees in full when they are due and still have enough money left to cover their expenses until their next payday. Research in America by the Centre for Responsible Lending estimated in a 2007 report that more than 60% of payday loans are taken out by borrowers who have at least 12 payday loan transactions annually and nearly one-quarter are withdrawn by customers who have at least 21 payday loan transactions annually. 14 Given the high levels of unemployment in Brent and low household incomes the potential social impacts of high concentrations of betting shops, AGCs and pawnbrokers/payday loan companies is of particular concern. 5.0 Conclusion For town and neighbourhood centres to be successful it is imperative that there are a range of uses providing a breadth of products and services to encourage a diverse customer base, increased footfall and to sustain the life of the borough s high streets. The national and local evidence summarised in this report indicates that the numbers of betting shops, pawnbrokers and payday lenders are increasing significantly, and in some cases this has already led to an over-concentration of these uses in Brent s centres. Research by London Assembly and the council indicates that an overconcentration of these uses can impact on footfall, and therefore the vitality and viability of Brent s town centres. In addition, the prevalence of these uses can have negative impacts on the wellbeing of communities. The demographics of Brent s residents indicate they are particularly at risk from social impact, such as problem gambling. There is therefore a strong social and economic case to prevent an over-concentration of these uses. Since the introduction of the 2005 Gambling Act the council s Licensing Committee have limited powers to prevent an over-concentration of betting shops and AGCs, as decisions can no longer take account of need. It is therefore necessary to use the planning system to control these uses. To ensure that shopping areas are diverse and balanced Development Management policy will set a limit on the proportion of town or neighbourhood centre frontage in use as a betting shop, AGCs, or pawnbrokers/payday lenders. Based on existing levels it is proposed that 4% is a reasonable cap on the proportion of frontage in use as betting shops and 3% for AGCs and payday loan companies, which allows for provision of these uses without them becoming dominant. This will allow a slight increase in all centres with the exception of Burnt Oak, Colindale, Wembley Park and Sudbury where an over-concentration of betting shops already exists. For the purposes of the policy the proportion will be based on designated primary and secondary frontage within town centres. Non-designated frontage outside of town centres will be classed as a neighbourhood centre. 14 Who borrowers from payday lenders? An analysis of newly available data, Amanda Logan and Christian E. Weller, March

15 In addition, to prevent clustering and ensure these uses do not dominate any single length of frontage a limit will be set on the proximity of these uses to each other. Planning permission will not be granted where it will result in less than four units in a different use between each betting shop, AGCs, or pawnbrokers/payday lenders. As previously stated pawnbrokers/payday lenders and betting shops are use class A2, meaning that in many cases premises could be converted without the need for planning permission. The Government expressed its intention in the report Gambling Protections and Controls (April 2014), to create a smaller planning use class containing betting shops. This will mean that in future, where it is proposed to convert a bank, building society or estate agent into a betting shop, a planning application will be required. In addition, the Government proposes to remove the ability for other premises such as restaurants and pubs to change use to a betting shop without planning permission. All changes of use to a betting shop would therefore require planning permission in future. The Department for Communities and Local Government will consult on the detail of these proposals as part of a wider consultation on change of use in summer There are currently no proposals to place pawnbrokers and payday loan shops in a separate use class. Given the rapid increase in the number of pawnbrokers and payday loan shops, consideration should be given to introducing an Article 4 Direction alongside the Development Management policy. The council would not be able to single out pawnbrokers/payday lenders within the A2 use class. The Direction would need to apply to all uses within the A2 use class, so a change of use to a bank or solicitors for example would also require permission. It should be noted that while an Article 4 Direction would require changes from A3, A4 and A5 use classes to an A2 use class to obtain planning permission, it would not affect changes within the A2 use class. A bank, building society or an estate agent could be converted into a pawnbrokers/ payday lender without needing planning permission. Once planning permission is granted for A2 use, the Article 4 Direction would also not be able to control changes of use to another A2 use such as a betting shop. However, the council would be able to condition planning permissions for new A2 use to prevent this where it can be justified. This may include the imposition of a restriction of use condition which could specifically exclude certain A2 uses within the A2 use class. However, as such a condition would be restricting future change of use which the Use Classes Order would otherwise allow, it should be used in exceptional circumstances and requires robust evidence to support its use to avoid being construed as unreasonable. Introducing an Article 4 Direction has financial implications such as loss of fees and potential compensation claims. To avoid potential compensation claims the council could use a non-immediate direction which provides 12 months notice in advance of an Article 4 Direction taking affect. Where an Article 4 Direction has been made, the planning application fees should be waived as the application for planning permission is only required by virtue of an Article 4 Direction removing permitted development rights. 15

16 Appendix A: Summary of Gaming Machine Categories Category of Machine Maximum Stake Maximum Prize A Unlimited Unlimited B1 2 4,000 B2 100 (in multiples of 10) 500 B B3A B C 1 70 D non-money prize 30p 8 (other than a crane grab machine) D non-money prize (crane grab machine) 1 50 D (money prize) 10p 5 D - combined money and non-money prize (other than a coin pusher or penny falls machine) 10p D - combined money and non-money prize (coin pusher or penny falls machine) 10p 8 (of which no more than 5 may be a money prize) 15 (of which no more than 8 may be a money prize) 16

17 Appendix B: Inflow Data AGCs Name Date of Survey Town Centre Frontage Inflow All Cash Kilburn Secondary 2 City Slots Kilburn Primary 6 Silvertime Harlesden Primary 7 Agora Amusements Kilburn (Camden) N/A 7 Cash City Amusements Wembley Primary 1 Cash City Amusements Wembley Primary 6 Silvertime Wembley Primary 1 AVERAGE INFLOW

18 Pawnbrokers Name Date of Survey Town Centre Frontage Inflow The Money Shop Wembley Primary 8 H&T Pawnbrokers Wembley Secondary 10 Albermarle Bond Wembley Primary 11 H&T Pawnbrokers Kilburn Primary 5 Cash Converters Kilburn Secondary 23 H&T Pawnbrokers Willesden Green Primary 9 Cash Generator Willesden Green Primary 25 Cash for Gold Harlesden Primary 57 Albermarle Bond Harlesden Primary 7 Cash Wembley Secondary 4 The Money Shop Wembley Secondary 3 AVERAGE INFLOW

19 Betting Shops Name Date of Survey Town Centre Frontage Inflow William Hill Wembley Secondary 26 Ladbrokes Kensal Rise Secondary 14 Paddy Power Wembley Secondary 33 William Hill Sudbury Primary 9 Ladbrokes Kensal Rise Primary 27 William Hill Ealing Road Primary 40 William Hill Kilburn Primary 19 William Hill Kilburn Secondary 18 William Hill Kingsbury Primary 14 Coral Racing Ltd Kingsbury Primary 15 Betfred Sudbury Primary 9 Paddy Power Sudbury Primary 23 William Hill Wembley Secondary 27 Gr8 Odds Wembley Secondary 25 Paddy Power Wembley Secondary 59 Paddy Power Wembley Park Primary 5 AVERAGE INFLOW

20 Adjacent Units Name Use Date of Survey Town Centre Frontage Inflow Small & Beautiful Café (A3) Kilburn Secondary 6 Home Solutions Comparison Retail (A1) Kilburn Primary 28 Peacocks Comparison Retail (A1) Harlesden Primary 111 Pound Land Kilburn (A1) (Camden) N/A 630 Specsavers Opticians (D1) Wembley Primary 32 Specsavers Opticians (D1) Wembley Primary 22 Outlet Clothes Comparison Retail (A1) Wembley Primary 35 Kilburn Phone House Comparison Retail (A1) Kilburn Secondary 6 Entertainment Centre (A1) Kilburn Primary 76 Best Deals Comparison Retail (A1) Harlesden Primary 65 Norwest Trading Kilburn (A1) (Camden) N/A 113 Atlantic Ladieswear Comparison Retail (A1) Wembley Primary 133 Atlantic Ladieswear Comparison Retail (A1) Wembley Primary 50 Sam 99p Store (A1) Wembley Primary 55 Carter's Pharmacy Chemist (A1) Wembley Primary Wembley Secondary Wembley Food and Wine (A1) Wembley Primary Champion Mall (A1) 73 Kilburn Eye Centre Opticians (D1) Kilburn Primary 6 Evening Use Evening Use Kilburn Secondary Evening Use Buy Wise Grocers Willesden Primary 35 20

21 (A1) Green Willesden Primary Closed Closed Green Closed Game Arena Comparison Retail (A1) Harlesden Primary Harlesden Primary Shoe Zone (A1) 29 Betting Shop Betting Shop Wembley Secondary Betting Shop St Luke's Hospice Comparison Retail (A1) Wembley Secondary 16 Natwest Bank (A2) Wembley Primary 100 Educational Wembley Secondary Educational Use Educational Use Use Wembley Plaza Internet Café Internet Café (A1) Wembley Primary 48 Bag Heaven Comparison Retail (A1) Kilburn Primary 28 Pipes N Pouches Kilburn Secondary Newsagents (A1) 45 Willesden Primary Everything Etc. (A1) Green 10 Willesden Primary Barclays Bank Bank (A2) Green 98 Subway Sandwich Shop (A1) Harlesden Primary Harlesden Primary Iceland (A1) 115 Pamir Hairdresser (A1) Wembley Secondary 16 SDA Express Off licence (A1) Wembley Secondary 38 Evening Use Evening Use Wembley Secondary Evening Use Dominos Takeaway (A5) Kensal Rise Secondary 6 Catwalk Nail Bar (SG) Wembley Secondary 16 Evening Use Evening Use Sudbury Primary Evening Use Warwick Estate Agents (A2) Kensal Rise Primary 10 21

22 She Collects Comparison Retail (A1) Ealing Road Primary 59 Kilburn Eye Centre Opticians (D1) Kilburn Primary 6 Pipes n Pouches Newsagents (A1) Kilburn Secondary 45 Rose Vegetarian Cafe (A3) Kingsbury Primary 24 Evening Use Evening Use Kingsbury Primary Evening Use Wakil Hairdressers (A1) Sudbury Primary 5 Self Service Grocers (A1) Sudbury Primary 46 Evening Use Evening Use Wembley Secondary Evening Use Pawnbrokers Pawnbrokers Wembley Secondary Pawnbrokers Walli's Chicken Takeaway (A5) Wembley Secondary 28 Shop N Save (A1) Wembley Park Primary 37 Evening Use Evening Use Wembley Secondary Evening Use Closed Closed Kensal Rise Secondary Closed Dahabshill Travel Agent (A1) Wembley Secondary 14 Circus Clothes Comparison Retail (A1) Sudbury Primary 3 Clothes Comparison Retail (A1) Kensal Rise Primary 5 Post Office Post Office (A1) Ealing Road Primary 95 Bag Heaven Comparison Retail (A1) Kilburn Primary 28 Evening Use Evening Use Kilburn Secondary Evening Use London Quality Fisheries (A1) Kingsbury Primary 14 Evening Use Evening Use Kingsbury Primary Evening Use Sudbury Tearooms Café (A3) Sudbury Primary 12 Newsagents (A1) Sudbury Primary 39 Closed Closed Wembley Secondary Closed Barbershop Hairdressers (A1) Wembley Secondary 16 22

23 Tailor Wear (A1) Wembley Secondary 6 Subway Sandwich Shop (A1) Wembley Park Primary 17 AVERAGE INFLOW 49.5 N.B Adjacent units were omitted where they contained evening uses, educational uses, betting shops, AGCSs, pawnbrokers or were closed. 23

24 Summary Use Average Inflow AGCs 4.3 Pawnbrokers 14.7 Betting Shops 22.7 Comparison Retail 41.4 All Adjacent Uses Banks 99 24