The main railway station in Birmingham, where I live and work, is undergoing major renovation. Its new main entrance was opened earlier this year. Directly opposite is a multi-fronted betting shop run by one of the big betting chains. Turn to the right and you will find within just a few yards another two betting shops run by competitor chains. Quite apart from what this indicates to rail travellers about the image of Britain’s second city, it nicely illustrates the problems that have been taxing local councillors and officials and MPs for some time now, particularly those in poorer areas. What is concerning them is the apparent proliferation, more prominent location, and clustering of betting shops in high street areas, plus of course the accumulating evidence – both from personal accounts and observations and from scientific studies – that the controversial FOBTs (fixed odds betting terminals) have altered the nature of betting shops, making them increasingly dangerous places. They are worried about the risks they pose to local people in the form of heavy gambling losses, increasing debt, encouragement to gamble for young people (including those under age) and those who are unemployed, as well as the possibility of associated public disorder (for example, loitering of street drinkers around betting shops, disorder amongst disgruntled punters, and vandalising of gambling machines). But they are also concerned, more generally, about the future sustainability of their high streets, threatened as they are by declining retail mix.

One of the most important changes introduced by the 2005 Gambling Act – little publicised and appreciated by the public – was the abolition of the ‘demand test’ which had previously required that a gambling operator applying for a new licence had to establish that there was a demand for a new venue which was not being met by existing outlets. There now seems to be relatively little that a local authority can do to stop the kind of proliferation of betting shops which greets me now when I enter and leave Birmingham New Street station. The position of local authorities is made that much more difficult due to the rather extraordinary situation regarding the classification of the uses of high street premises. Betting shops are in use class A2 along with banks, building societies, bureaux de change, estate agents and employment agencies, so that no change of use is required if a betting shop takes over premises that had been used by another business within that same class. To make it worse planning permission is not required for a change of use from certain other types of premise such as cafes, restaurants and drinking establishments! Local authorities are starting to fight back however. A good example is a consultation document produced by the London Borough of Barking and Dagenham, entitled ‘Evening the Odds: Curbing the Proliferation of Betting Offices in the Borough’, which includes the proposal that there should be a 400 metre ‘exclusion zone’ around existing premises.

A highly relevant document appeared in June this year (2013) from the London Health Inequalities Network (prepared by Shannon Hanrahan of The Outcomes Group). LHIN is a consortium of chief public health and health inequalities officers in the 11 most deprived London Boroughs. What this report does is to offer local areas a method that they can use to help them restore their ability to control their high streets in the interests of their residents’ health and safety and the future well-being of their communities. The idea is that of a Cumulative Impact Policy Statement (CIPS) which has been used for some time in relation to alcohol outlets, where it has been shown that the density of outlets in an area is related to harm. CIPS have not yet been used with regard to gambling, but they could be. If the case can be made that the cumulative effect of a number of betting shops in the same geographical area (a CI zone) is harmful, then this could be legal grounds for rejecting a new licence application. The report provides a great deal of background information which local authorities should find helpful in preparing such a case, plus practical advice about gathering relevant local data, the likely value of multi--agency partnerships, and the role of the local public health department. The report finishes by making the good point that the use of a CIPS should be seen as just part of a move towards looking more broadly at gambling as an activity which can have harmful health and social consequences and which therefore constitutes a public health issue.