Former Santander Bank 131-135 Kilburn High Road, corner of Victoria Road, opposite McDonalds
At the time of publication there have been 194 objections to the conversion of the basement and ground floor of the former Santander Bank at 131-135 Kilburn High Road to an Adult Gaming Centre.
Although the above notice gives tomorrow as the expiration date for Neighbourhood Consultation, in practice comments can be submitted up to the day before the Committee Date. This has not yet been fixed.
Details of the application and comment portal can be found HERE.
A selection of the objections that include One Kilburn and BRATS can be found below:
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.
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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.
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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.
