[Case Study] Southwark Council: A 'whole council' approach

Southwark is one of the most densely populated boroughs in the country with a population of around 313,000. Southwark is also the 40th most deprived local authority in England and the ninth most deprived out of 33 London local authorities.

Southwark is also one of the most ethnically diverse areas in the UK, with just over a half of residents coming from a White ethnic background. Around a third of all residents are from a Black ethnic background and the remaining fifth of the residents come from mixed, Asian and multiple other ethnic groups.

In this context, the proliferation of betting shops has become an increasing concern since 2011. Unlike some other boroughs in London, there has been a consistent “churn” of betting shops – with some closing, while others open – meaning that the number has been relatively consistent, only increasing by 6.5 per cent since 2007.

Even so, the concentration of gambling premises in the most deprived areas has spurred the council to implement a “whole council” approach to control their number. Under this banner, the Council Plan 2014/15 – 2017/18 included a commitment to stop the stop the spread of pawnbrokers, betting shops, gambling machines and pay day, and a specific policy to limit the spread of betting shop has been included in the emerging New Southwark Plan, now in its submission version. This “whole council” process led to a number of planning and licensing initiatives.


In 2014 Southwark became the first council in the UK to utilise Article 4 Direction to limit the proliferation of
betting shops.

An Article 4 Direction can be used to remove specific permitted development rights in all or parts of the local authority. As it is put in place to ensure that certain development requires planning permission, it does not restrict development altogether. The government’s own NPPG states that an Article 4 Direction 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. In particular, in deciding whether an Article 4 Direction would be appropriate, local planning authorities need to clearly identify the potential harm that the Direction is intended to address.

In 2015 the government changed the General Permitted Development Order and betting shops and payday loan shops were reclassified to sui generis use. This meant that permitted development rights no longer applied to change use to a betting shop without planning permission. It is still possible to change use from a betting shop to another use under permitted development.

Property and Asset management

The council’s commercial property estate is comprised of a wide variety of shops, offices, industrial buildings, community centres and more. However, payday lenders and betting shops are excluded from the Council’s own Asset Management Plan for the Commercial Property Estate.

The council is also able to grant rate reliefs to encourage thriving and diverse town centres by supporting retailers as they look to adapt to changing consumer preferences and provide support to the construction industry. To qualify for retail relief, a property must be occupied, have a rateable value of £50,000 or less and be wholly or mainly used as a shop, restaurant, cafe or drinking establishment.

The council’s discretionary rate relief policy explicitly excludes betting shops, payday lenders and hot food takeaways from any type of rate relief.

Local Area Risk Profiles

The Council’s Public Health team plays a significant role in gambling policy. Not only is Public Health notified and involved in any application for a new betting shop, the team has also provided significant input into Southwark’s Statement of Gambling Policy. Southwark’s Public Health supports their licensing team in this work through the production of local area risk profiles for gambling. The risk profiles are based on a number of location indicators, including proximity to schools, places where vulnerable people are housed, and other betting shops. Area-based vulnerability considerations are also included in the model, such as demographics, deprivation and those affected by substance misuse, gambling addiction and poorer mental health.

The involvement of the Public Health team in Southwark’s “Whole Council” approach is significant, allowing for the borough’s Planning and Licensing Committee to make decisions that are fully informed and cognisant of the potential risks and impacts.

The risk profiles are already in development to be incorporated into the next iteration of the Statement of Gambling Policy Public Health has also facilitated buy- in from the Health and Wellbeing Board and partners. In fact, stopping the spread of betting shops and gambling machines and promoting financial well-being and independence among residents is one of the “big asks” of the Health and Wellbeing Strategy 2015-2020.