We are formally objecting to the proposed
Adult Gaming Centre (AGC) at 82 Kilburn High Road. This application is
unsuitable for the area and fails to meet the requirements of the Brent Local
Plan (Policy BE5 and DMP1) regarding the safety and vitality of our high
streets.
Our objection is based on the following material planning grounds:
1. Risk to Sensitive Educational Uses
The site is a primary thoroughfare for families and children attending the high
density of educational facilities in the immediate vicinity, including:
- Primary Schools: Kilburn Grange School, St Mary's C of E Primary, and St
Eugene de Mazenod Primary.
- Nurseries: Busy Bees Nursery and Learning Tree Nursery.
- Community Amenities: Kilburn Grange Park.
The introduction of an AGC here would lead to the unacceptable normalization of
gambling for hundreds of local children. Permitting a high-stakes gaming
environment in such close proximity to five early-years and primary providers
is a significant safeguarding risk that contradicts the NPPF goal of promoting
healthy and safe communities.
2. Over-concentration of Gambling Establishments
Kilburn High Road is already saturated with adult gaming venues. There are
already two Game Nation outlets in the immediate vicinity (89 and 108 Kilburn
High Road), as well as Merkur Slots (130 Kilburn High Road).
- Policy BE5 Breach: Adding another unit at number 82 would lead to a
clustering of gambling uses that exceeds the 3% frontage limit set by Brent
Council.
- Harm to Retail: This over-concentration undermines retail diversity and
discourages the family-oriented businesses that the local community actually
needs.
3. Failure to Support High Street Vitality
The proposal does not contribute to the "vibrancy" of the High Road:
- Dead Frontage: AGCs rely on obscured windows and heavy branding, creating a
"dead zone" on the street that reduces natural surveillance and
active footfall.
- Precedent for Refusal: we draw the council's attention to the recent refusal
of a near-identical application by the applicant, Sunni-Ed Limited, at Staines
High Street (Spelthorne Council, Nov 2025). In that case, the committee
determined that such uses provide no community value and fail to enhance the
daytime economy of major town centres.
4. Public Safety and Anti-Social Behaviour (ASB)
Kilburn High Road already faces significant challenges with loitering and
street-based ASB. Adding a late-night gaming use at this specific location will
exacerbate these issues, creating an intimidating atmosphere for parents and
residents during the school run. The "fear of crime" is a material
planning consideration that warrants the refusal of this application.
This proposal offers no benefit to the community and poses a clear risk to the
welfare of local children. We strongly urge the Council to refuse this
application.
………………..
I am the Co-chair of the One
Kilburn coordinating group and am writing on behalf of One Kilburn to challenge
the planning application for an adult gaming centre in Kilburn on multiple
grounds, with particular emphasis on breaching the Local Plan and on the
serious public health consequences of introducing additional gambling
facilities in an already vulnerable community. Founded in 2022, One Kilburn is
a community-led initiative which provides a space where Kilburn people can
meet, connect and make common ground. It seeks to foster a community, place and
belonging in Kilburn, across the municipal boundaries which have historically
split Kilburn across three London boroughs. We therefore have a strong interest
in issues affecting the vitality of the High Road.
Breaching the Local Plan
Policy BE5 of the Brent Local Plan 2019-2041 specifically aims to prevent an
over-concentration of betting shops and adult gaming centres and to protect the
vitality and retail function of town centres. Crucially, one of its provisions
states that adult gaming centres will only be permitted where they would not
result in more than 3% of the town centre frontage consisting of adult gaming
centres or pawnbrokers, or payday loan shops. By our rough estimate, the town
centre frontage on the Brent side of the High Road is around 1,400m; it follows
that 3% of that amounts to 42m. The site plans for this proposal suggest that
the frontage of the establishment would be nearly 40m (on both the High Road
and Victoria Road, since the premises are located on a corner). Given the
current existence of other adult gaming centres on the Brent side of the High
Road, we believe that this proposal would breach the 3% threshold and should be
rejected on those grounds, in addition to what we argue below. Furthermore, as
a high-profile corner site, it should anchor the high street. Instead, an adult
gaming centre creates a dead frontage which doesn't support Kilburn's recovery.
It offers no active engagement with the streetscape, directly undermining
Policy BE5's objective to protect the retail function of town centres.
Public Health Crisis in Brent
The evidence of gambling-related harm in Brent is stark and unequivocal.
According to the Brent Joint Strategic Needs Assessment on Gambling, the
borough has one of the highest concentrations of gambling premises in London,
with 81 licensed venues already operating. Most alarmingly, 6.2 percent of
Brent residents are classified as high-risk gamblers-more than double the
national average of 2.9 percent. This represents a public health crisis that
would only be exacerbated by permitting additional gambling facilities.
The economic burden of this gambling epidemic is substantial and growing. The
estimated cost of gambling-related harm in Brent has increased sevenfold to
£14.3 million annually, placing immense pressure on public services including
health care, social services, and community support systems. These costs are
ultimately borne by taxpayers and divert resources from other essential
services. Under the Equality Act, Brent Council must also consider its Public
Sector Equality Duty (PSED). With 6.2 percent of Brent residents who are
classified as high-risk gamblers-is more than double the national average.
These vulnerable protected groups in a gambling density area are impacted
disproportionately and are already at a heightened risk of financial exclusion
and mental health crisis.
Targeting Vulnerable Communities
National and local evidence demonstrates that adult gaming centres
systematically target areas of socioeconomic disadvantage. The High Streets at
Stake report reveals that 33% of adult gaming centres are located in the most
deprived 10%t of neighbourhoods nationally, with over half serving the most
deprived 20%. Kilburn fits this vulnerable profile precisely, with high levels
of private renting, overcrowding, and a younger working-age population that
research consistently identifies as being more exposed to gambling harms.
The physical availability and visibility of gambling venues is a proven driver
of harm. By introducing an additional adult gaming centre in Kilburn, this
proposal would increase exposure to gambling, normalise harmful behaviours, and
elevate risk levels in a community already experiencing rates of problem
gambling at twice the national average. While the applicant may claim to
contribute to the local economy, these venues offer little or minimal
employment with no community benefit. This targeting is a form of corporate
extraction where significant public health costs (estimated at £14.3 million
annually in Brent), wil have to be managed by local authorities and health
services.
Exacerbating Existing Problems
Kilburn High Road already contains a dense concentration of betting shops,
gambling-adjacent uses, and late-night premises. The proposed site sits
opposite a 24-hour McDonald's, creating conditions that would intensify
late-night congregation, loitering, and associated anti-social behaviour. The
cumulative impact of this proposal cannot be ignored. It will create an
environment that residents have consistently reported as being associated with
crime, exploitation of vulnerable people, and general deterioration of
community wellbeing. By placing another gambling venue directly opposite a
fast-food outlet (McDonald's), the application creates a hotspot for loitering.
This creates a perceived lack of safety that discourages other residents and
families from using the High Road, thus damaging the evening economy and
undermining the diverse and resilient vision set out in the Kilburn
Neighbourhood Plan.
Adult gaming centres offer minimal local employment, no genuine community
benefit, and actively undermine the pride and vitality of high streets that
residents desperately want to see improved. They are inward-facing and
represent single-purpose uses that do not provide an active frontage or support
browsing and linked trips. Moreover, a further gaming centre on the High Road
would go against the spirit of the Kilburn Neighbourhood Plan, recently
approved through a referendum of local residents.
Conclusion
The planning and health evidence is clear. This speculative proposal clearly
breaches Policy BE5 of the Brent Local Plan and should be refused. At a time
when local authorities are campaigning to tackle gambling harms, this
application moves Kilburn in the opposite direction. It breaches frontage
thresholds, threatens public health, and contradicts the community-led vision
for a healthier, more vibrant Kilburn High Road. We urge the Council to protect
Kilburn community's physical, mental, and economic well-being by rejecting this
application.
……........
Proposal: Change of use of basement and
ground floor from vacant bank to Adult Gaming Centre
This proposal represents the antithesis of the kind of development and
meaningful progress that residents in both Brent and Camden want to see. At a
time when both Brent and Camden Council are actively campaigning to tackle
gambling harms, rebuild pride in our high streets and support healthier town
centres, this application would take Kilburn in precisely the opposite
direction. It would introduce a use that extracts value from the community,
generates well evidenced public health and anti-social behaviour impacts, and
gives little back in return.
I primarily object to this application on planning grounds. In doing so, I also
make clear that the proposal raises material considerations relating to public
health and the effective operation of the council's licensing regime, all of
which are supported by adopted policy and robust local evidence and should
therefore be afforded significant weight.
1. Planning impacts in Kilburn and conflict with the Brent Local Plan
The site sits within a designated town centre frontage on Kilburn High Road, a
corridor already under intense pressure from deprivation, high footfall, late
night activity and a concentration of nonretail uses. Kilburn experiences high
levels of private renting, overcrowding, and a younger working age population
that Brent Council's own evidence identifies as being more exposed to gambling
related harm.
Against that context, Policy BE5 of the Brent Local Plan 2019-2041 is directly
engaged. Policy BE5 exists specifically to prevent over concentration of betting
shops and adult gaming centres and to protect the vitality and retail function
of town centres. It states that betting shops and adult gaming centres will
only be permitted where they would not result in:
- more than 3 percent of the town centre frontage consisting of adult gaming
centres or pawnbrokers or payday loan shops
- more than 1 unit or 10 percent of a neighbourhood parade frontage, whichever
is greater, consisting of betting shops, adult gaming centres or pawnbrokers or
payday loan shops
- a dominance of single use, low diversity frontages that undermine the retail
role of town centres
The justification to Policy BE5 is explicit that these controls are necessary
to protect health, social and cultural wellbeing, and to prevent harmful
clustering in areas already experiencing disadvantage.
Kilburn High Road already contains a dense mix of betting, gambling adjacent
uses, money transfer outlets and late-night food premises. This proposal would
sit directly opposite a 24-hour McDonald's, intensifying late night footfall,
congregation and loitering, and compounding cumulative impacts associated with
noise, disturbance and anti-social behaviour. These are not hypothetical
concerns but well understood dynamics in this location.
Adult gaming centres are inherently inward facing uses. They do not support
linked trips, they do not meaningfully activate the street during the day, and
they do not contribute to a diverse or resilient retail offer. Replacing a
former bank with an adult gaming centre would therefore further erode the
balance of uses on Kilburn High Road, contrary to both the wording and intent
of Policy BE5 and the wider town centre objectives of the Local Plan.
2. Public health impacts
Public health is a material planning consideration where supported by local
evidence, and in Brent that evidence is unequivocal.
The Brent Joint Strategic Needs Assessment on Gambling identifies Brent as
having one of the highest concentrations of gambling premises in London, with
81 licensed premises, and rates of high-risk gambling more than double the
national average. In Brent, 6.2 percent of residents are classified as
high-risk gamblers, compared with 2.9 percent nationally. Low risk gambling is
also significantly higher, meaning a far larger group exposed to harm.
The JSNA shows that gambling premises are disproportionately clustered in wards
such as Kilburn, and that the physical availability and visibility of gambling
venues is a key driver of harm. The estimated economic cost of gambling related
harm in Brent has risen sevenfold to £14.3 million per year, placing further
pressure on public services.
Kilburn's demographic profile makes it particularly vulnerable. The ward has
high levels of private renting, overcrowding, younger working age residents,
and communities that national and local evidence consistently show are more
exposed to gambling harms. Introducing an additional adult gaming centre in
this location would increase exposure, normalisation and risk, directly
undermining the council's preventative public health objectives.
3. Undermining the council's licensing framework
Although licensing is determined separately, planning decisions must not
undermine the effective operation of the council's adopted regulatory
framework.
Brent's Statement of Licensing Policy 2025-2030 makes clear that the council
seeks 'alignment between planning and licensing', particularly where proposals
risk increasing crime, disorder and harm to vulnerable people. Granting
planning permission here would materially frustrate that objective by enabling
further clustering of gambling uses in a location already identified as
sensitive and high risk.
Once planning permission is granted, the council's ability to manage impacts
through licensing is significantly constrained by the permissive national
regime. That is precisely why planning judgement at this stage is so important.
4. High streets, cumulative harm and the wider evidence base
The High Streets at Stake report by the Social Market Foundation and sponsored
by Brent Council provides a compelling national and local evidence base on
adult gaming centres. It finds that:
- the number of adult gaming centres increased by 7 percent between 2022 and
2024
- 33 percent of adult gaming centres are located in the most deprived 10
percent of neighbourhoods, and over half serve the most deprived 20 percent
- gross gambling yield from higher risk machines has almost doubled since 2022
- residents consistently report associations with crime, anti social behaviour
and exploitation of vulnerable people
The report identifies locations in Brent as being systematically targeted
because of high footfall, transport connectivity and socio economic
vulnerability. This application fits that pattern precisely.
Adult gaming centres are the textbook definition of corporate extraction. They
generate private profit while exporting public health costs to councils, health
services and communities. They offer little local employment, no community
value, and actively remove pride from high streets that residents want to see
improved, not hollowed out.
Summary
This application should be seen for what it is: a speculative proposal in a
vulnerable location, relying on a permissive national regime, offering no
meaningful contribution to Kilburn's future, and running directly counter to
adopted planning policy, public health evidence and the council's wider
campaign to tackle gambling harms.
It is also notable that the applicant, SUNNI ED LIMITED, is part of a pattern
of serial applications around the country, often supported by the same agent,
testing the limits of local resistance. The same applicant has recently had a
planning application refused in Spelthorne, which raises further concerns about
the approach being taken and the absence of any genuine local commitment.
At present, there is no clarity about who the eventual operator would be,
reinforcing the concern that this is a faceless, footloose proposal with no
accountability to the community it would affect.
Taken together, the planning harm, the public health impacts, the risk of
increased anti-social behaviour, and the undermining of local policy are clear.
This proposal fails to meet the test of good planning and should be refused
before it puts residents in Brent at avoidable risks of harm.
……........
I and my neighbours in the BRAT Residents'
Association catchment area strongly oppose this planning application which is
at odds with every aspiration set out in the newly endorsed Kilburn
Neighbourhood plan. The arrival of another Adult Gaming Centre in these large
and prominent premises will overshadow all the good work underway to try to
improve Kilburn High Road and make it a vibrant and appealing retail town
centre and community hub. Its presence will also overshadow improvements at
Kilburn Sq retail and undoubtedly deter more quality appropriate retailers too.
Also no account terms to have been taken of the proliferation of gambling and
gaming on Kilburn High Rd. For example there are several Betting shops and a
Mercure Slots very nearby already on the same High Road and the concentration
will become totally inappropriate with another such large centre. This may be
partly to do with Kilburn High Road being under the jurisdiction of both LB
Camden and Brent so it appears that gaming premises are in different Boroughs
when in fact they are in close proximity on the same street. The local
population is strongly against Kilburn becoming a gaming and gambling dominated
centre - our population is already under pressure and working hard to improve.
Why then insert a large enterprise designed to exploit poverty and deprivation
through gaming?. This is totally at odds with the democratically endorsed local
Plan. Please re-think the approach and work with the local population to find a
more appropriate use for this important and prominent site. The local Town
Centre Manager is working hard to create an improved environment and offer on
Kilburn High Riad. Last week I was part of a local group welcoming the planting
of x6 new trees to the street and many elements are scheduled for or have
already benefited from improvement. A large Gaming Centre will undermine this
investment and dilute this good work. Please do not neglect z Kilburn and its
population further by enabling such exploitative and inappropriate businesses
to proliferate on our High Road.
