PALACE AMUSEMENTS APPEAL AGAINST COUNCIL DECSISION REFUSING PLANNING PERMISSION
Palace Amusements (East Kent Leasing Limited) were denied planning permission for an Adult Gaming Centre in the former Lloyds bank on Green Lanes back in September 2024.
East Kent Leasing are now appealing to the Planning Inspectorate to overturn the decision and grant them planning permission. We have until Tuesday 15 January to submit representation to the Planning Inspectorate as ‘interested parties’ to oppose the appeal. This has to be based on the Council’s original decision to deny planning permission and the arguments from East Kent Leasing to appeal.
Why planning permission was denied
Over-Concentration and Clustering:
The proposed development would lead to a clustering and intensification of gambling-related uses in the area, detrimental to the vitality, viability, and character of the town center.
It risks exacerbating existing issues, including crime, anti-social behavior, and social disadvantage, harming the health, wellbeing, and cohesion of the community.
Loss of Class E Floorspace:
The change of use would result in the loss of valuable Class E floorspace in a district centre, undermining the street's shopping role.
The proposal does not meet a demonstrated local need, fails to provide a public service, and introduces adverse impacts such as increased crime and anti-social behavior.
Night-Time Use Concerns:
Introducing a sole, isolated night-time use in an area without other night-time activities would increase the potential for crime and anti-social behavior.
The proposal compromises safety and the perception of safety, contrary to planning policies.
Impact on Heritage Asset:
The proposal fails to preserve the special interest of the non-designated heritage asset, conflicting with both local and national heritage policies.
Inadequate Cycle and Refuse Storage:
The application does not include adequate provision for cycle parking and refuse storage, failing to meet relevant standards and policies.
Read the planning permission refusal in full
Why East Kent Amusements are appealing
East Kent Amusements have submitted an appeal based on the following points
Nature of the Use: The appellants argue that Adult Gaming Centres (AGCs) are distinct from betting shops and should not be conflated with them in terms of clustering or intensification policies. They emphasise that AGCs focus on low-stakes gaming and cater to a different demographic.
Economic and Social Benefits: The appeal highlights the importance of bringing a vacant unit back into use, generating employment, and contributing to the vitality of the Palmers. They argue that AGCs can attract footfall and linked trips, which benefit other businesses.
Compliance with Policies: The appellants assert that the proposed development aligns with national and local policies, including promoting diverse uses in town centers, improving vitality, and making efficient use of vacant units.
Crime and Anti-Social Behavior: The appellants argue that there is no evidence that AGCs increase crime or anti-social behavior. They propose measures like implementing "Secured by Design" standards, CCTV, and access control to mitigate concerns.
Night-Time Economy: The appeal states that the AGC would diversify the night-time economy in the area without significant negative impacts, especially since existing AGCs have not led to increased crime.
Heritage Concerns: While the site is a non-designated heritage asset, the appellants argue that their design improvements would not negatively impact the site's historical value. They are open to planning conditions to align the design with local guidelines.
Refuse and Cycle Parking: The appellants dispute claims about inadequate refuse and cycle parking provisions, stating that their plans meet relevant standards and are willing to adjust designs if needed.
Read their Statement of Case in full
How you can make representation
Palmers Green Action Team has submitted a detailed objection highlighting several critical points and facts that can be used as the basis for opposing an appeal. This must be made to the Planning Inspectorate by 15 January 2025. Use this link to submit an appeal and select ‘interested party’. https://acp.planninginspectorate.gov.uk/ViewCase.aspx?Caseid=3356297&CoID=1053832
Below are some key points from our argument which you might want to consider, include and expand on in your response:
AGCs and Enfield’s Development Management Document (DMD33)
While AGCs are not explicitly classified as betting shops, their core purpose is identical: monetising gambling. This results in similar social, economic, and community impacts, such as crime, anti-social behavior, and problem gambling.
The lack of mention of AGCs in Policy DMD33 reflects the policy's creation in 2014 before their proliferation, not an intent to exclude them from regulation.
Over-Concentration and Cumulative Impacts
Palmers Green already hosts one AGC and four betting shops. Adding another gambling venue risks creating a "gambling hub," stifling diversity and discouraging families and other demographics from visiting the high street.
Enfield’s Development Management Document (DMD33) requires a minimum of five non-betting shop units or 25 meters between gambling establishments. This proposal does not align with these principles.
Palmers Green has been designated a Cumulative Impact Zone (CIZ), emphasising the need to limit licenced businesses due to their documented negative effects.
Impact on High Street Vitality and Economy
The AGC’s target demographic does not encourage linked trips or additional economic activity, unlike retail, hospitality, or service-oriented businesses. Money spent at AGCs typically does not circulate back into the local economy.
Marketing data provided by the appellant is self-reported and lacks independent verification of claimed footfall benefits.
Palmers Green’s low vacancy rate (7% vs. the national average of 13.9%) and alternative tenant interest in the site—22 enquiries—demonstrate that viable, community-serving options were available.
Crime, Anti-Social Behavior, and Social Harm
Recent efforts to encourage crime reporting have revealed a significant increase in reported incidents in Palmers Green, with 150 reported crimes in October 2024 alone. Green Lanes is now the top police priority across five wards.
Illegal gambling activities and raids in the area suggest that introducing a legal AGC could exacerbate existing crime issues.
Gambling venues, especially in proximity to vulnerable populations, have been linked to social harm, including addiction and financial hardship.
Inappropriate Shopfront Design
Evidence from other "Palace Amusements" locations indicates harsh, unappealing designs (black facades and gaudy gold stars) that detract from the visual quality of the high street.
The proposed design fails to meet DMD40's requirement for active and engaging frontages that positively contribute to the street scene. Exposed interiors of gambling venues also normalize gambling for children passing by, increasing societal risks.
Conclusion
The proposed AGC conflicts with Enfield’s Town Centre Action Plan, which prioritises vibrant, inclusive, and family-friendly high streets. It fails to provide public benefit, exacerbates over-concentration of gambling uses, and harms the economic and social fabric of Palmers Green. Upholding the Council’s refusal will protect Palmers Green’s unique identity and prevent it from following other borough wards that have become gambling vulnerability areas.
Next steps
The Planning Inspectorate will review all the submissions and there will be a public hearing at Enfield Council on 25 February 2025.