Local Plan Topic Paper

Retail, Leisure and Services, Culture and Visitor Accommodation

February 2020

1 Introduction ...... 1 2 Policy framework ...... 2 National ...... 2 London ...... 3 Local adopted policy ...... 5 3 Background ...... 6 4 Policy R2: Primary Shopping Areas ...... 8 PSA boundaries ...... 8 PSA A1 percentages ...... 11 5 Policy R3: ’s Town Centres ...... 14 Town Centre boundaries ...... 14 Sequential test ...... 16 Impact assessment...... 17 Residential use ...... 17 Office use ...... 18 6 Policy R4: Local Shopping Areas ...... 19 Land use ...... 19 LSA designation changes ...... 20 7 Policy R5: Dispersed Retail and Leisure Uses ...... 24 A1 use ...... 24 A3 use ...... 25 8 Policy R7: Markets and specialist shopping areas ...... 26 9 Policy R8: Location and concentration of uses ...... 28 Hot food takeaways ...... 29 Betting shops and adult gaming centres ...... 32 10 Policy R10: Culture and the Night-Time Economy ...... 36 Agent of change ...... 36 Cultural quarters ...... 37 11 Policy R11: Public houses ...... 41 12 Policy R12: Visitor accommodation ...... 43 13 Appendix 1: 2019 Retail Survey analysis…………………………………………………46 14 Appendix 2: Fast Food Takeaways and Health in Islington – health impacts……….56 15 Appendix 3: Betting Shops and Subprime Lenders in Islington – health…………….93

Tables

Topic paper Table 1: changes in PSA A1 percentages between 2017 and 2019 surveys………. pg.11 Table 2: Reasons for LSA deletions and additions……………………………………. pg. 21 Table 3: Cultural organisations in Archway……………………………………….…….. pg.39 Appendix 1 – Retail Survey analysis Table A1.1: Primary Shopping Areas……………………………………………………. pg. 47 Table A1.2: Vacant units within Primary Shopping Areas…………………….………. pg. 47 Table A1.3: Specialist Shopping Area A1 mix……………………………………….…. pg. 47 Table A1.4: Specialist Shopping Area vacancy rates…………………….……………. pg.47 Table A1.5: Town Centre betting shop/adult gaming centres………………………… pg.48 Table A1.6: Local Shopping Area betting shop/AGC 4% threshold limits for LSAs with 26 units or more…………………………………………………..… pg.48 Table A1.7: Local Shopping Area betting shop/AGC two or more threshold limits for LSAs with 25 units or less………………………………………..….. pg.49 Table A1.8: Local Shopping Area A5 hot food takeaway 4% threshold limits for LSAs with 26 units or more……………………………………………….... pg.50 Table A1.9: Local Shopping Area A5 hot food takeaway two or more threshold limits for LSAs with 25 units or less……………………………………….…... pg.51 Table A1.10: Town Centre A4 uses……………………………………………..…….… pg.52 Table A1.11: Local Shopping Areas A4 uses…………………..………………….…… pg.53 Appendix 2 – Fast Food Takeaways and Health in Islington – health impacts Table A2.1: Schools in Islington…………………………………..……………….…….. pg.77 Table A2.2: Frequency of A5 HFTs within 200m of a school…………..………………pg.78 Table A2.3: Frequency of all HFTs within 200m of a school……………..…………... pg.78 Appendix 3 - Betting Shops and Subprime Lenders in Islington – health Table A3.1: Crime recorded at Islington betting shops, 2015, 2016 and 2017…..… pg.105

1 Introduction

This topic paper provides justification for the policies in Islington’s Local Plan relating to retail and service uses; cultural and night time economy uses; and visitor accommodation.

It sets out the relevant existing local policy, and the London and national policy framework which guides the production of housing policies; and the key evidence base which supports the policies in the new Local Plan. During Islington’s Local Plan review process, the NPPF and London Plan have also been subject to revision. The documents referred to in this topic paper are the NPPF (June 2019) and the London Plan (Intend to Publish version, December 2019).

The topic paper then provides discussion on a number of specific policies/elements of policies, including links to evidence (where relevant) and comments on relevant representations received during previous rounds of consultation.

Where relevant, the paper explains the reasons for changes in approach from the adopted Local Plan policies.

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2 Policy framework

National

The National Planning Policy Framework 2019 states that in regard to ensuring the vitality of town centres, planning policies should support the role that town centres play at the heart of local communities, by taking a positive approach to their growth, management and adaptation1.

Policies contained within the Inclusive Economy chapter beginning with a ‘R’ are in line with the NPPF and seek to take a holistic approach in meeting the NPPF’s aims of ensuring the vitality of town centres and other commercial centres; promoting healthy and safe communities; and promoting sustainable transport. Local evidence2 highlights that in Islington the inclusion of residential uses in Town Centres can actually have a detrimental impact upon the vitality and viability of Town centres, through negative impacts to the commercial function, higher value residential uses pricing out commercial uses, poor amenity of residents from noise disturbance, and harmful breaks in the continuity of shopfronts which reduces footfall and patronage.

Paragraph 85a of the NPPF requires a network and hierarchy of town centres to be defined. The Local Plan sets out this hierarchy clearly with two Major Town Centres and two District Town Centres, both supported by a range of 40 Local Shopping Areas. The varying functions of these town centres are explained in the Spatial Strategy Area policies.

The Local Plan has moved away from Primary and Secondary Retail Frontages to Primary Shopping Areas, as encouraged by NPPF paragraph 85b. The Council have interpreted this as a way to consolidate A1 retailing in the geographic and characteristic cores of town centres which then enables a wider variety of uses to occupy more peripheral town centre locations, thus addressing the economic changes in town centres and the shift towards more leisure/experience based activities. Town Centre boundaries were also reviewed, with only Angel requiring an amendment which sees its extension south-westwards. The Local Plan also encompasses the main town centre uses as defined in Annex 2 of the NPPF and include A1, A2, A3, A4, A5, D2 and Sui Generis uses as well as B1 and C1 uses. A5, Sui Generis (betting shops), B1 and C1 uses are subject to specific requirements in other policies in order to manage their specific impacts and reflect where they appear in the strategic priority hierarchy.

Policy R3 requires the sequential test to be followed in line with NPPF paragraph 86. The sequential test will be applied however, taking account of the need to retain the viability of all centres: town centres and local shopping areas by allowing main town centre use development of up to 200sqm to locate in local shopping areas.

NPPF paragraph 89 requires an impact assessment for retail and leisure development outside of town centres with a locally set floorspace threshold set if necessary. Policy R3 is in general conformity with the NPPF here and sets an impact assessment threshold of 0sqm. This threshold requirement is appropriate in the context of a small and densely developed borough with multiple competing uses and centre functions.

1 NPPF (2019) paragraph 85 2 Retail and Leisure Study 2017, paragraph 3.48

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This impact assessment will also aid in planning for a borough characterised by small shops.

Policies contained within the Inclusive Economy chapter also satisfy the NPPF’s requirement for promoting social interaction (paragraph 91) through such policies as R5 ‘Dispersed retail and leisure uses’ and R11 ‘Public Houses’; providing social, recreational and cultural facilities (paragraph 92) through policies such as R10 and R3.

Planning can have great influence over the health and wellbeing of the people, with the birth of the practice of town planning being intrinsically linked to the betterment of health. This has been recognised in the NPPF (paragraph 91c). Policy R8 seeks to address the pertinent and persistent challenges identified in Islington associated with obesity and problem gambling and seeks to plan for a borough in which the health and wellbeing of its population is seriously addressed, creating a fairer society.

The suite of policies explained within this topic paper adhere to NPPF paragraph 103, in that patterns of growth are actively managed so that development can be sustainable and limit the need to travel. The policies seek to enable access to goods and services to be accessible to all demographics through a range of active travel and sustainable public transport modes.

London

The London Plan – which is the Spatial Development Strategy (SDS) for Greater London - provides the London-wide planning framework to guide local plan-making. Local Plans must be in general conformity with the London Plan.

The Mayor is in the last stages of finalising the revised London Plan with an ‘intend to publish’ version now available.

This section of the topic paper only makes reference to the new London Plan given that it is likely to be adopted prior to the examination of Islington’s new Local Plan. Reference to the most recent version will therefore be referred to as the ‘London Plan’.

It is noted that the Mayor’s general conformity response to Islington’s Regulation 18 Local Plan (November 2018) assessed Islington’s draft Local Plan against the London Plan, and considered that it was in general conformity with the London Plan. The Mayor’s conformity response provided further comments on specific elements of the Local Plan; these are discussed below where relevant.

London Plan Policy SD6 encourages town centres to be promoted and enhanced as hubs for a diverse range of uses which act as the primary commercial locations outside of the CAZ. Town centres should promote sustainable modes of transport and contribute to Londoner’s sense of place and local identity. The adaptation and restructuring of town centres in light of the challenges presented by multi-channel shopping and changes in technology and consumer behaviour should be positively supported.

London Plan Policy SD7 classifies all town centres based on their function and size. Major town centres should be the focus for the majority of higher order comparison goods retailing and secure opportunities for higher density employment, leisure and residential development. District centres should focus on consolidating a range of retailing, leisure and employment uses.

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London Plan Policy SD8 requires a town centres first approach to be taken by adopting a sequential approach to accommodating town centre uses. The London Plan designates a hierarchy of Town Centres across Greater London, classified as either International, Metropolitan, Major or District centres. These designations reflect the existing role and function of the respective centre and give a broad indication about potential growth and regeneration in the centres, or as CAZ Frontage areas with a predominant retail function. Local Plan policies should clearly define town centre boundaries and any primary shopping areas. Intensification of town centres should be considered based on demand for commercial uses, transport capacity and opportunities, relationship with wider regeneration initiatives, local character and heritage assets and viability of development.

London Plan Policy SD9 encourages town centre strategies to be produced (which have been created through the spatial strategy area policies in the emerging Local Plan). Town Centre health checks should be undertaken to inform strategic and local policy implementation. Consideration of Article 4 Directions and partnership based approaches for land assembly should also be made.

London Plan Policy D12 places the responsibility for mitigating impacts from noise generating activities or uses on the proposed new noise sensitive development. This is often of particular relevance in town centres where commercial and residential uses can exist side by side.

London Plan Policy E9 directs development plans to identify future requirements and locations for new retail development, and set out policies to secure an appropriate mix of shops and other commercial units of different sizes. The policy also states that development plans should plan for comparison retail in major town centres; and convenience retail, particularly in district, local and neighbourhood centres, to secure inclusive neighbourhoods and a sustainable pattern of provision where there is less need to travel. Plans should also provide a framework to enhance local and neighbourhood shopping facilities and prevent the loss of retail and related facilities that provide essential convenience and specialist shopping.

London Plan Policy E9 also states that proposals for hot food takeaways should be resisted within 400 metres of schools (or within a locally determined boundary).

London Plan Policy E10 seeks to provide a sufficient supply and range of serviced accommodation, including the need for wheelchair accessible bedrooms, whilst resisting intensification of serviced accommodation where this compromises local amenity or the balance of local land uses.

London Plan Policy HC5 requires the growth and evolution of cultural facilities and creative industries to be supported. Local Plans should protect existing cultural venues and promote new ones, using Cultural Quarter designations to define locally distinct clusters. Vacant sites should consider the implementation of meanwhile uses to stimulate activity in the day and night.

London Plan Policy HC6 encourages development plans to promote the night time economy in appropriate locations, by creating safe and inclusive environments, promoting a diverse range of uses, addressing the cumulative impact of high concentrations of licensed premises and protecting night time cultural venues such as pubs and music venues.

London Plan Policy HC7 seeks to protect public houses that have heritage, economic, social or cultural value and support proposals for new pubs. The loss of public houses

4 must demonstrate there is no realistic prospect of the building being used as a pub in the future.

Local adopted policy

The Council’s existing Local Plan is made up of the Core Strategy (2011), the Development Management Policies (2013), the Local Plan (2013) and the Site Allocations document (2013).

The Core Strategy (2011) identifies the four town centres and notes that these areas and local shopping areas (LSAs) are the primary locations for retail and leisure development. The document promotes small shops (80sqm or less) to encourage independent retailing which contributes to Islington’s unique character. Cultural and community provision is directed to town centres and visitor accommodation is to also be directed to town centres.

The Development Management Policies (2013) adds detail to the Core Strategy policies, including defined boundaries for Town Centres and Local Shopping Areas. A1 retailing is specifically promoted and protected in town centres, primary and secondary frontages, local shopping areas and dispersed shop locations.

A two-year marketing and vacancy requirement applies for change of use away from ‘main town centre uses’ in town centres; A1 uses in primary and secondary frontages, local shopping areas and in dispersed locations; and A4 pubs (across the borough).

The ‘Location and concentration of uses’ policy of the adopted Local Plan restricts hot food takeaways within 200m of schools. It also resists overconcentration of specific uses that have potential to cause adverse individual or cumulative negative impacts.

The ‘Public Houses’ policy seeks to protect all pubs, requiring any change of use or redevelopment proposal to provide two-year marketing evidence; assurance that a new use would not affect the vitality/character of the area; the loss wouldn’t constitute a loss of a valued community service; or significant features of historic value are retained.

The ‘Hotels and Visitor Accommodation’ policy took a more laissez faire approach to hotel development in light of previous evidence than the emerging policy. Hotel development would be permitted in town centres or the CAZ. Criteria related to amenity and the need for 10% of rooms to be wheelchair accessible are present in the adopted policy and remain in the emerging policy.

The ‘Entertainment and Night Time Economy’ policy directs such activity to town centres provided there would not be any significant amenity impacts or overconcentration of similar uses. The emerging ‘Culture and Night Time Economy’ policy takes a more detailed approach, legislating on new cultural uses, redevelopment of cultural uses, loss of cultural uses, and proposals for new night time economy uses.

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3 Background

National trends demonstrate a general slowdown of growth after the 2008 financial crash with peak growth at 2.9% in 20143 and negative growth in convenience goods expenditure per capita (-0.9%) in 20184. The Retail and Leisure Study predicts 2019- 2023 will see no growth and potentially only modest growth of 0.1% per annum between 2023 and 20355. This slowed growth, coupled with Brexit uncertainty6, suggests a more flexible approach is needed, with a broader commercial focus rather than just A1 retailing. Notwithstanding this, the ability for town centres to sustain a viable and vibrant commercial offer is expected to be realised through commercial retail, leisure and office development.

The expansion of ‘special forms of trading’ including internet shopping and click and collect has created challenges for town centres to compete with these modern, more efficient channels for convenience and comparison goods shopping. The Retail Study forecasts growth in ‘special forms of trading’ market share of total retail sales to increase from 9.6% in 2016 to 13.6% in 20337.

The Retail Study 2017 assessed overall quantitative need for new (convenience and comparison goods) retail floorspace over the plan period, and also assessed the need for new commercial leisure uses and the ‘gaps’ in provision over the plan period. Paragraphs 12.33 to 12.45 provide an overview of the approach to these assessments. Identified need, especially over the short to medium term, is limited. The approach taken in the Local Plan reflects this by ensuring that existing provision is protected and allowing for increased provision, especially in Town Centres; large scale new allocations or strong policy presumptions for new retail floorspace are not considered necessary given the relatively small scale of capacity identified. The Hotels Study 2016 notes that likely growth in the number of hotel rooms in Islington is less than many other areas in London, with a large proportion of new hotel rooms focused in more peripheral areas. At present, the majority of visitor accommodation in Islington is in the south of the borough8.

Visitor accommodation development has seen considerable churn since 2001, with new stock replacing older accommodation. In addition, the quantum of new stock in the pipeline has seen a net growth in Islington’s hotel stock, in excess of 25% above the GLA’s benchmark target of 1,300 rooms by 20369. The emergence of letting websites such as AirBnB has changed the way that visitors use accommodation in London with over 4,759 listings in Islington in 2018 (6% of the London total)10. It is not entirely clear whether this issue of informal accommodation will attract new visitors or displace visitors from traditional accommodation11, or both.

3 Retail and Leisure Study (2017) paragraph 3.3 4 Retail and Leisure Study (2017) paragraph 3.5 5 Retail and Leisure Study (2017) paragraph 3.5 6 Retail and Leisure Study (2017) paragraph 3.6 7 Retail and Leisure Study (2017) table 3.3 8 Hotels Study (2016), paragraph 6.6 9 Hotels Study (2016), paragraph 6.9 10 Insideairbnb.com, December 2018 (accessed 18/12/2019) 11 Hotels Study (2016), paragraph 6.10

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Hotels can provide significant financial returns meaning they can outbid office uses12, even in prime office areas. Without restrictions on hotel uses, provision of offices in the borough could be undermined.

12 Hotels Study (2016), paragraph 6.11

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4 Policy R2: Primary Shopping Areas

The adopted Local Plan policy DM4.5 ‘Primary and Secondary Frontages’ designates parts of each of Islington’s four town centres as primary and secondary retail frontages. Identification of frontages was required by the NPPF 2012 paragraph 23, to promote the vitality and viability of town centres and provide high quality and accessible retail services which meet the needs of consumers. Primary frontages in the adopted Local Plan sought to include a high proportion of retail uses (70% in Major Town Centres; 60% in District Town Centres), while secondary frontages were to provide at least 50% A1 in order to allow for more diversity of uses but also to maintain a strong retail offer.

Since the current Local Plan was adopted there have been a number of changes that warrant a change in approach to town centre land use. With regard to primary shopping areas (PSAs) – a “defined area where retail development is concentrated”13 - the NPPF no longer directs LPAs to identify primary and secondary frontages within PSAs.

Policy R2 reflects the NPPF change by identifying PSAs. These are the core areas of the Town Centres. The boundaries for the PSAs have been derived based on concentrations of A1 uses, using as a starting point the extent of primary frontages and some secondary frontages. Accessibility has also been considered, particularly proximity to public transport. A consultation response made by landowner M&G Real Estate (ref. R19.0099) did raise concern with the principle of PSAs in terms of apparent inflexibility and potential impact on the vitality and viability of Town Centres. However, the Council considers that the principle of PSAs, to protect a core of retail in Town Centres, is appropriate and is aligned with national policy. Changing retail behaviour and the rise of internet shopping has not wholly displaced ‘bricks and mortar’ shopping, as noted in the Retail and Leisure Study.

The policy has flexibility to allow for non-A1 uses in the PSA, where the A1 percentage is maintained – this provides an appropriate balance between protecting A1 and encouraging uses which help to support A1.

PSA boundaries

The specific PSA boundaries for each Town Centre have been derived as follows:

Angel:

The PSA in Angel retains all of the current primary frontages and a select amount of the secondary frontages that are contiguous with the core of the Town Centre. The PSA extends northwards along to number 25 (Tesco), which currently acts as the anchor A1 store to the north of Angel’s centre and is accessible from Essex Road, and through Islington Green (which connects the two roads). The character and function of the Town Centre to the north of Islington Green is more mixed between retail and leisure, hence the PSA does not extend past this point. The distance to Angel station also increases as the Town Centre goes further north up

13 NPPF (February 2019), Annex 2: Glossary, page 70

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Essex Road, which undermines the aim of the PSA which is defined as the most accessible part of the Town Centre.

The PSA incorporates all of Camden Passage because the need for this Specialist Shopping Area to retain predominantly A1 uses is vital for sustaining its character and antique/curio function.

To the south, the PSA would stretch to the north side of the junction of Road and Islington High Street ceasing at number 1 Islington High Street which is currently the Co-operative Bank. This junction marks the edge of observably significant pedestrian footfall. South of the junction to St John Street is characterised mainly by A3 units and therefore is not an area of A1 retail that the PSA is characterised by. The junction is dominated by traffic with a heavy flow and crossing points are only available at Pelican Crossings. This means the pedestrian flow is disrupted here to make shopping disjointed from Islington High Street.

To the west, north of the junction of Tolpuddle Street and Liverpool Road is largely residential and would be unsuitable to include in the PSA. The PSA will run along Tolpuddle Street and include the Sainsbury’s car park which is currently identified as part of Site Allocation AUS6 so as to ensure this site is developed in a way that contributes to the retail function of the Town Centre. The PSA includes all of , where the density of A1 units is greater.

The central northern point of the PSA would cut in from Upper Street at the edge of the current primary frontage and run south-westwards along the south side of Parkfield Street joining up with the boundary at the junction of Liverpool Road and Tolpuddle Street. The PSA includes the entirety of the Angel Central shopping centre.

Nag’s Head:

The PSA in Nag’s Head is more linear than the other town centres due to the spatial layout of Nag’s Head, with most commercial units being located on Holloway Road. The Coronet Pub marks the start of Nag’s Head’s core and the more significant concentration of comparison goods retailers. South of the Coronet Pub, there is a lower observable footfall and higher vacancy rates which means a PSA is not justified here. The PSA will run along the east side of Holloway Road cutting westwards to join with the current secondary frontage at the junction with Camden Road. This is because the west side of the road up until here is completely residential and set back from the road.

The south east of the PSA includes the whole block bounded by Tollington Road, Holloway Road, Seven Sisters Road and Hertslet Road, which includes the Nag’s Head Shopping Centre, the Morrison’s supermarket and adjacent car park, (the latter is identified in the new Site Allocations document, site NH1)

The PSA runs northeast along Seven Sisters Road to the junction with Eburne Road (westside) and Hertslet Road (eastside). The section of the Town Centre between Herslet Road/Eburne Road and Hornsey Road is predominantly in A3 use which is not synonymous with the PSA A1 function.

The northwest of the PSA runs up Holloway Road until the southern side of the junction with Road, with the cinema - Nag’s Head current cultural/leisure anchor - just north of the PSA boundary. Further northwards of this point is predominantly A3 and A5 units.

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Finsbury Park:

Finsbury Park suffers from a poor quality public realm and illegible layout – largely due to the railway bridge - with no clearly identifiable retail core. The PSA in Finsbury Park seeks to promote an established retail core around the station, which promotes a more circular pedestrian flow as a result of public realm improvements from the City North development. The PSA then extends part way along each of Finsbury Park’s main roads - Stroud Green Road, Blackstock Road and Seven Sisters Road.

To the east along Blackstock Road, the PSA includes all units on the west side of the road up to no. 52; the east side is under Hackney Council’s jurisdiction. This part of Blackstock Road is poorly connected to the rest of the Town Centre but contains a large number of A1 convenience shops and with public realm improvements will have improved linkages with the station area. It correlates with existing secondary frontages.

The central part of the PSA is roughly bounded by Seven Sisters Road, Fonthil Road, Wells Terrace and Stroud Green Road. It includes the allocated site FP10 - the former George Robey Public House - at 240 Seven Sisters Road site, which is under construction. The PSA also covers part of Isledon Road and Coleridge Road, then crosses over Seven Sisters Road incorporating 201A Seven Sisters Road - identified in the site allocations document reference FP6. This marks the south-western extremity of the PSA; the retail offer west of this part of Seven Sisters Road is limited and of a lower quality.

The PSA incorporates all parts of Fonthill Road that are located within the Town Centre boundary, and follows the Town Centre boundary along Clifton Terrace and Lennox Road; it includes the entirety of Wells Terrace. Fonthill Road is a key part of the PSA as it is a Specialist Shopping Area where A1 uses require particular protection to sustain the character and function of the street as a fashion destination.

Northwards the PSA follows Stroud Green Road as far as the south side of the junction with Tollington Park, which covers the majority of existing primary frontages. This marks the end of predominantly A1 units; northwards from here becomes more predominantly A3 uses. The north side of Stroud Green Road is located within Haringey.

Archway:

The PSA in Archway is largely informed by the regeneration of Archway Mall and the recent creation of Navigator Square making a coherent town centre core.

Heading south from the intersection with Junction Road and Holloway Road, the PSA will run along Junction Road until the convergence with Brookside Road (east side) and Bredgar Road (west side). This is easily accessible from Archway Station and vacancy rates increase south of here. There have recently been several new occupiers to the south of the town centre which have been mainly A3, A4 and A2 uses.

To the west the PSA boundary will follow the town centre boundary down Vorley Road but will cut through the block on the inner side of the site allocation ARCH1 (Vorley Road/Archway Bus Station), so that it excludes the part of this site, which is allocated to be redeveloped for residential and business use.

Northwards the PSA extends to the MacDonald Road / Hill junction and includes Archway Close and Navigator Square (formerly known as the ‘Island site’), a high quality, newly developed public open space.

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Heading eastwards the PSA boundary stretches down Holloway Road, ending between the junctions with Giesbach Road and Elthorne Road. This incorporates all of the current primary frontage and a small section of current secondary frontage.

PSA A1 percentages

Policy R2 requires that within Major Town Centres (Angel and Nag’s Head) the Primary Shopping Area must have a proportion of A1 units at a minimum of 60% of all town centre units within the PSA. In Finsbury Park District Town Centre this is 55% and in Archway District Town Centre this is 50%. These figures were informed partly by retail survey information, but importantly they reflect the role of each Town Centre in the hierarchy of town centres and their unique needs.

The vacancy levels in the proposed primary shopping areas in Islington’s four town centres are generally low (Angel 7.3%, Nag’s Head 8.3%, Archway 5.1%, Finsbury Park 7.6%)14 and indicate these areas are currently healthy and viable retail environments. Although retailing faces a myriad of challenges, the Retail and Leisure Study forecasts an average growth rate of +2% per annum over the next two decades15, albeit far below the +8% per annum growth enjoyed historically16. There is still a clear role for existing floor space and physical store based retailing in town centres17 and the PSAs will help consolidate this retailing in accessible locations with high footfall and ensure their continued viability and important contribution to town centres vitality, character and social and economic function.

A two-year marketing and vacancy requirement applies to proposals which result in the percentage of A1 uses in a PSA falling below, or being further reduced below, the respective minimum A1 thresholds. This strong protection is necessary to ensure the continued provision of ‘bricks and mortar’ comparison and convenience retailing, while creating flexibility to allow for change of use away from A1 where the requirement is met; this allows the council to be confident a particular premises is no longer suitable for A1 use. The requirement mirrors the adopted frontage policy which also has a two- year marketing and vacancy requirement.

The retail survey data which informed the policy drafting was sourced in 2017. A subsequent update of the retail survey was conducted in 2019, which highlighted some changes (albeit relatively small) in the proposed PSA A1 percentages; these are shown in table 1. The minimum A1 thresholds are, however, still considered reasonable and appropriate, in order to consolidate a healthy retail mix appropriate to each town centres current circumstances and need.

Table 1: changes in PSA A1 percentages between 2017 and 2019 surveys

2017 Retail Survey 2019 Retail Survey Minimum A1 results results target Angel Town Centre 55.94% 50% 60% Nag’s Head Town 60.19% 56.25% 60% Centre Archway Town 45.79% 48.1% 50% Centre

14 Town Centre Retail Survey 2019 15 Retail and Leisure Study (2017) paragraph 3.23 16 Retail and Leisure Study (2017) paragraph 3.6 17 Retail and Leisure Study (2017) paragraph 3.58

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Finsbury Park Town 57.54% 50% 55% Centre

The A1 percentages, particularly for Angel, have been challenged in a Regulation 19 consultation response (ref. R19.0099), on the basis that they do not provide enough flexibility to ensure continued success of retail areas. The Council considers that the PSA percentages strike the right balance between protection of A1 and allowing diversification. The specific A1 percentages for each PSA are justified as follows:

Angel

The PSA currently has a 50% A1 concentration. Angel is a thriving area and is Islington’s most significant town centre, designated a major town centre, with a notable specialist shopping function at Camden Passage. Chapel Market is also a significant draw. Therefore, a 60% PSA A1 minimum target would seek to achieve and consolidate a higher level of A1 to reflect Angel’s significant retail role.

Nag’s Head

The PSA currently has a 56% A1 concentration. Nag’s Head is a major town centre with a significant catchment that tailors to local residents and residents beyond Islington. The survey results carried out as part of the Retail Study 2017 show 35.6% of respondents in the study area and 54.7% of respondents in Zone 3 like Nag’s Head because it is close to home18. The strong convenience goods offer demonstrates this local function and is something the council seeks to protect. However, there is limited quality leisure provision, meaning the minimum PSA target should expand and consolidate the retail offer but not be set at too high a level so as to discourage leisure uses. A 60% minimum A1 target is therefore considered appropriate and ensures alignment with Islington’s other major town centre at Angel.

Archway

The PSA currently has a 48% A1 concentration. The situation in Archway is atypical of the national average with a much higher A1 convenience offer but a significantly lower comparison goods offer19. A minimum A1 PSA concentration target of 50% will act to strengthen the A1 retailing in Archway by expanding and consolidating A1 provision. The Retail and Leisure Study 2017 observed that there is a limited representation of goods sold. The regeneration of Archway Town Centre includes the relocation of the market to Navigator Square and the Local Plan has numerous site allocations that seek to implement retail on the ground floors; this will increase opportunities for additional retail provision.

Finsbury Park

The PSA currently has a 50% A1 concentration. There is a strong convenience goods offer in Finsbury Park although a significantly weaker comparison goods offer than the national average20. A 55% minimum A1 PSA target would promote a healthy level of retailing whilst allowing for provision of night time economy uses in the centre of Finsbury Park which is underrepresented at the moment. The intensification of office and residential development in Finsbury Park will create more demand for retail, night-

18 Retail and Leisure Study (2017) paragraph 7.45 19 Retail and Leisure Study (2017) table 8.1 20 Retail and Leisure Study (2017) table 9.1

12 time and leisure activities and the spatially ambiguous centre of Finsbury Park would benefit from this, as more A1 could help to create a focal point for the area.

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5 Policy R3: Islington’s Town Centres

Islington’s four town centres will continue to be the focus for main town centre uses, namely A1, A2, A3, A4, A5, D2 and Sui Generis main town centre uses. This is in accordance with the NPPF definition of main town centre uses21. The status of Islington’s Town Centres is unchanged by the London Plan, with Angel and Nag’s Head as Major Town Centres and Archway and Finsbury Park as District Town Centres. Policy R3 seeks to continue the enhancement of town centres as commercial hubs that are highly accessible, sustainable, and contribute to the viability and vitality of these centres as well as providing a good level of amenity. It takes a similar approach to existing Local Plan policy DM4.4 ‘Promoting Islington’s Town Centres’.

Town Centre boundaries

Angel Town Centre is the only town centre with an amended boundary in the new Local Plan. This amendment is considered appropriate as it will incorporate a number of commercial main town centre uses in the area, roughly bounded by the western part of the current Town Centre boundary, Pentonville Road, Penton Street and Tolpuddle Street. Inclusion of these buildings will strengthen the Town Centre designation and will provide a more coherent commercial link between King’s Cross and Angel. The expansion of the boundary will also support night time economy uses and office expansion in line with key Local Plan priorities.

The proposed boundary amendment also includes the Lexington and the Public Carriage office on the western side of Penton Street:

 The Lexington is a renowned pub that provides a significant contribution to Islington’s live music scene. It’s inclusion in the town centre corresponds with the vision to nurture the night time economy in Angel Town Centre.  The Public Carriage office is a proposed site allocation for mixed use development including business floorspace. It could provide significant opportunities for development of main Town Centre uses and contribute to the improved vitality and viability of the Town Centre as a whole.

The boundaries for Nag’s Head, Finsbury Park and Archway are unchanged from the adopted Local Plan. The Council has considered whether reduced or expanded boundaries of these centres was necessary, for instance to reflect changes of use. However, retail surveys have demonstrated that the boundaries are still relevant and the Council considers that the boundaries address paragraph 85 of the NPPF.

Consultation responses were received proposing specific amendments to reduce the Town Centre boundaries in Finsbury Park (ref. R19.0006 – R19.0018, R19.0174) and Archway (ref. R19.0170).

A number of representations were received (ref. R19.0006 – R19.0018) from community members in Finsbury Park requesting that the Vale Police Station

21 NPPF (February 2019) Annex 2 Glossary

14 is removed from the boundary. The main justification put forward for the proposed change is to prevent attempts to open a Sainsbury’s Local store at the site; to date the site has been subject to several unsuccessful applications and appeals.

The Finsbury Park Town Centre boundary was adopted in the current Development Management Policies document in June 2013. The extent of the boundary reflects the concentration of Town Centre uses within Finsbury Park. The Council considers that the representation offers no meaningful justification to amend the boundary. Firstly, it is not appropriate to amend a boundary solely to exclude a particular operator. The Local Plan is a strategic document, which guides the development and use of land over the long term; it is not a reactive document to be amended in response to individual planning proposals.

The representations note that the prime purpose of Islington’s Town Centres is to protect PSAs, but this confuses policies R2 and R3. Policy R3 protects and promotes main town centre uses, while Policy R2 is focused on A1 uses, specifically maintaining a level of A1, essential for provision of a good level of A1 retailing. The representation relies on the criteria of policy R2 to support justification for why the site is an unsuitable town centre site, but given that policy R2 does not apply, and the PSA is located further west around the central part of the Town Centre, this element of the representation is not considered relevant or convincing. The representations seem to suggest that if an A1 use is not within a PSA then it shouldn’t be within the Town Centre; as noted above, PSAs are the core concentration of A1 but A1 uses are clearly suitable (and prevalent) outside PSAs; this approach is consistent with national and regional policy.

The representations also consider that the building clearly does not (and cannot because it is a listed building) have an active frontage, and that through its distinctive style and scale the building is very different from the rest of the buildings along this road. The style and scale of the building is not a particularly important determining factor in identifying Town Centre boundaries; it is the use of the building that is of relevance. In terms of active frontages, these are provided by the retail units at the site; as defined in the Local Plan glossary. The building contributes multiple ground floor units to the town centre, which is beneficial for the wider commercial offer of Finsbury Park Town Centre.

The respondents note that it is necessary to amend the boundary in order to be able to effectively protect the small independent shops along Blackstock Road located south of the former police station. No convincing evidence has been provided to support this claim. There is no absolute guaranteed adverse impacts on small shops arising from the development of larger A1 convenience stores. The Local Plan, particularly policies R3 and R6, has protections for small shops and requires impacts of larger scale retail to be assessed on a case-by-case basis. Where there are impacts supported by actual evidence, applications can be refused.

The representations note that moving the boundary will not change anything else because the police station is the most southern building within the Town Centre boundary. This is incorrect, as there are two commercial units at 213 and 215 Blackstock Road which are within the boundary. Regardless, the fact that a unit is right at the edge of a Town Centre boundary is not in itself justification for a boundary amendment; any amendments must be justified in planning terms, and would be primarily concerned with the building’s use.

Leaving aside the issues raised above, it is worth noting that the suggested amendment may not provide additional assistance in resisting an application for a

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supermarket on this site. If the site were outside the town centre, an application may trigger the requirement for an impact assessment, but such an assessment has been carried out as part of a previous appeal and the planning inspector considered this satisfactory. Such an application would trigger the sequential test which would require investigation of suitable town centre sites as a priority; it would not provide an ‘in- principle’ reason to resist a supermarket in an edge-of-centre site.

A representation was received (ref. R19.0174) suggesting the removal of 1 Prah Road (proposed site allocation FP5) from the Finsbury Park Town Centre boundary, on the basis that it currently occupies a sui-generis use, on a residential street, largely detached from the wider town centre boundary. The Council disagrees with the respondent’s justification. The sui generis existing use is a private members club which would be classed as a main town centre use. The site is proposed to be allocated for business floorspace, which is also a suitable main Town Centre use. Prah Road does have a number of residential uses but this site is at the very north of the street in very close proximity to commercial uses and . It is not, as suggested by the respondent, detached from the wider Town Centre boundary.

In regards to Archway Town Centre boundary one respondent (R19.0170) requested that 1 Elthorne Road is removed stating its inclusion is unsound and inconsistent with paragraph 85b of the NPPF and London Plan policy SD7 part B. The respondent notes that the Employment Land Study 2016 identifies that, in this part of Archway Town Centre, retail gives way to other uses, including D1 and C3 uses. The Council considers that the site is suitable for continued inclusion within the Town Centre. The existing use is a main Town Centre use and the site is subject to a proposed allocation for business-led mixed use development, which is clearly an appropriate mix of uses for a Town Centre. The surrounding context is also entirely commercial – particularly office and retail uses - and the site is easily accessible from Archway station. Policy R3 is in line with paragraph 85b of the NPPF as the extent of town centres and primary shopping areas has been made clear and represents a positive strategy to providing space for retail, leisure and cultural expansion.

Sequential test

The NPPF states that LPAs should apply a sequential test to planning applications for main town centre uses which are neither in an existing centre nor in accordance with an up-to-date plan. Main town centre uses should be located in town centres, then in edge of centre locations, and only if suitable sites are not available should out of centre sites be considered22. Further guidance on the application of the sequential test is provided in the NPPG23.

Policy R3 adapts the sequential approach, retaining the priority for main town centre uses to locate in town centres, but also incentivising further retail development in LSAs by removing the requirement for a sequential test in LSAs for main town centre use proposals under 200sqm. Other edge of centre or out of centre locations outside of LSAs would need to address the sequential test and other requirements of policy R3.

The 200sqm threshold has been proposed as this is just over double the size of a ‘small shop’ and therefore provides scope for development of a range of unit sizes in LSAs, while limiting larger units. This will assist with protecting and enhancing the vitality and viability of LSAs while ensuring that development is not of a scale that could have detrimental impacts on the viability of surrounding Town Centres. It is

22 NPPF (February 2019), paragraph 86 23 NPPG, Paragraphs 009 to 013, https://www.gov.uk/guidance/ensuring-the-vitality-of-town-centres

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noted that units over 200sqm may still be acceptable in LSAs, but they would need to meet the sequential test and other requirements of policy R3.

Impact assessment

Policy R3 sets out a local floorspace threshold of 0sqm for impact assessments, in line with paragraph 89 of the NPPF, meaning that any application for a main Town Centre use in edge or out-of-centre locations24 triggers an impact assessment.

This approach allows the Council to fully assess impacts on Town Centres and LSAs, which protect and enhance locations at the top of the Council’s retail hierarchy and helps to steer development to the most appropriate and accessible locations. It will help to futureproof town centres and local shopping areas and maximise their ability to retain their vitality and viability in potentially challenging economic circumstances.

Residential use

Policy R3 promotes main town centre uses and directs these uses towards town centres. B1 uses are also suitable in town centres, and are covered by policy B2. Other uses such as social infrastructure may be suitable where certain policy requirements are addressed.

Residential uses are considered to be the most problematic in terms of how they co- exist with a broad range of commercial uses found in Town Centres. The risks are threefold;

 residential uses will increase the resident population in close proximity to certain uses which might have noise impacts or cause other disturbance.  They can squeeze out other uses given the higher value of residential uses compared to commercial; and  They can interrupt commercial/retail active frontages and therefore cause harmful breaks in continuity of shopfronts, which can impact on footfall and patronage of retail and commercial uses.

In order to limit such impacts, Policy R3 directs residential uses to upper floors in Town Centres. However, upper floors in ‘main town centre use’ will need to comply with the two-year marketing requirement for change of use to residential. This will provide necessary balance between allowing residential uses while prioritising Town Centres for retail and commercial uses. Upper floor locations will also provide some degree of separation in terms of noise and disturbance, although policy R3 includes specific criteria in part G which refers to the agent-of-change principle. This will help to mitigate or prevent adverse impacts on retail and commercial uses.

The policy is clear that residential uses in town centres will be resisted at ground floor level or below and any such application would need to satisfy a comprehensive set of criteria, including two years marketing evidence, demonstration that the loss of ancillary space would not affect the functioning of the operation of future commercial occupiers, and the agent of change principle must be followed.

The Retail and Leisure Study highlights that due to the introduction of Permitted Development, which resulted in the loss of key office and retail accommodation which was often occupied and functioning effectively. This saw the introduction of residential

24 Excluding such locations that are within LSAs

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development near functioning commercial uses which are not necessarily suitable neighbours25. It is vital that the council has control over the development of commercial centres to counteract the impact of PD rights and risk impacts being exacerbated further. As noted in paragraph 4.73, policy R3 will apply to relevant prior approval assessments. The Council will monitor implementation of the policy and may introduce Article 4 Directions where relevant, to provide further control over PD rights. Policy R3 sets out positive policies and puts in place criteria to protect the retail and commercial function of Town Centres.

Office use

Offices are a suitable Town Centre use in principle. Paragraph 4.95 notes this, but also explains that suitability of offices will be determined in relation to other Local Plan policies, on a case-by-case basis. Policy B2 provides further clarity, directing offices to upper floors in PSAs to protect the core of retail, but noting that they are considered suitable on any floor elsewhere in Town Centres, provided they have an active frontage. This approach strikes an appropriate balance between promoting a valid main Town Centre use and contributing to the significant need for new office floorspace, while protecting the overarching retail function of Town Centres.

25 Retail and Leisure Study (2017) paragraph 3.53

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6 Policy R4: Local Shopping Areas

The adopted Local Plan Policy DM4.6 designates 40 LSAs, which are small/medium sized retail areas. The core aim of policy DM4.6 is to ensure LSAs contribute to an appropriate mix and balance of uses that maintains and enhances the retail and service function of the areas. No thresholds for A1 use were identified in existing Local Plan policy DM4.6 in order to provide flexibility to maintain and develop each LSAs unique role and function and this approach has been maintained in Policy R426. However, A1 retailing is the predominant use class and function of LSAs, therefore justifying the protection of ground floor retail units, especially from change to residential use that can be detrimental to the commercial function of LSAs.

National27 and regional28 policy both support identification and protection of local retail areas.

Land use

The fundamental requirement of Policy R4 is that all proposals must maintain and enhance the retail and service function of LSAs – this allows for a wide range of uses in principle but sets a clear priority for A1. Proposals involving the change of use of A1 must address certain criteria, but the policy takes a staggered approach which, dependent on if the change of use is to residential or another commercial use has less stringent criteria – particularly regarding marketing and vacancy periods – where the change is to another commercial use.

In conjunction with policy R3 (discussed above), which relaxes the requirement for a sequential test for main town centre use proposals up to 200sqm, the policy approach to LSAs is considered to be flexible, positive and well-balanced, prioritising A1 retail but also allowing a range of other commercial uses which could allow for diversification of these areas. This is important given the challenges facing the retail sector, discussed elsewhere in this topic paper and highlighted in the Retail and Leisure Study 2017.

Residential uses in LSAs are limited to upper floors; the approach and justification is similar to that set out for policy R3 discussed above. Compared to Town Centres, LSAs are even more vulnerable to small changes, such as changes of use to residential dwellings, which can impact on viability, vitality and character of the LSA, especially at ground floor level. LSAs largely provide a convenience function, making the loss of even a small number of retail units impactful upon the convenience function. Furthermore, a reduction in commercial uses in LSAs as a result of change of use to residential uses has a cumulatively detrimental impact to the function, viability, vitality and vibrancy of LSAs across the borough. Housing pressures, coupled with the perception of high street and retail decline can pose a threat to the survival of high

26 A 35% A1 threshold was applied to LSAs in the Finsbury Local Plan area – these will be removed in the new Local Plan. This is explained in the Bunhill and Area Action Plan topic paper. 27 NPPF (February 2019), paragraph 92 28 London Plan policy E9, discussed in policy framework section of this topic paper.

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street/local shopping area activities29. This necessitates more stringent criteria (compared to changes of use to other commercial uses) where change of use to residential is proposed.

LSA designation changes

The Council undertakes regular retail surveys to provide an up-to-date picture of the status of retail areas. The drafting of policy R4 was informed by the 2017 survey, and the Council have subsequently updated the survey to ensure that we have the most up-to-date information30 for the Local Plan review. Comparing the changes in use classes and vacancy levels in each LSA between 2012 (when a LSA health check was undertaken to support justification of the retail policies in the adopted local plan) and 2019 shows the following:

 A1 is the predominant use in 31 or 77.5% of LSAs, meaning A1 uses in these LSAs make up a greater proportion of the commercial mix than any other individual use class. Nine LSAs or 22.5% of LSAs have a non-A1 use as the predominant use class or are equal to the proportion of A1 uses, which tend to be A3 uses.  17 LSAs saw a decrease in the percentage of A1 units from 2012. The average decrease in A1 uses was 11.45% with the highest decrease being 36.82% and the lowest 0.28%, although eight of the 17 decreases in A1 use were minimal, at below 6%. Four LSAs A1 mix remained the same, and 17 increased the proportion of A1 use from 2012. This does not include the newly designated LSAs at Farringdon and Old Street because there is no data to compare the use class mix to.  14 LSAs saw an increase in vacancy rates; seven remained the same, and 17 saw a decrease in vacancy rates. The maximum increase in vacancy rate was 28.57% and the most minimal was 0.29%. The maximum decrease in vacancy rate was 17.84% and the lowest decrease was 1.25%.

These findings highlight the challenges A1 retailing faces, but still show that A1 is the priority use in the majority of LSAs in Islington. The 2019 survey also demonstrates more LSAs have seen vacancy levels decrease compared to LSAs that have seen an increase in vacancy levels, which points to a generally commercially healthy picture in these local centres. Surveys undertaken between 2012 and 2019 show that vacancy has fluctuated broadly across LSAs, due to natural churn of occupiers and different economic circumstances at the time each survey was taken.

Overall, the 2019 survey results demonstrate that the LSA designations remain appropriate. The survey highlighted that some changes were necessary; these are detailed in Table 2 below. Two new LSAs have also been proposed, in response to the London Plan which identifies CAZ retail clusters at Farringdon and . The Bunhill and Clerkenwell Area Action Plan topic paper provides further discussion on these new designations.

29 High Streets for All Report, GLA (2017), page 18: https://www.london.gov.uk/sites/default/files/high_streets_for_all_report_web_final.pdf 30 See Appendix 1

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Table 2. Reasons for LSA deletions and additions:

LSA Name of Amendment Justification for inclusion/removal unit(s)/address Upper Shell – 276 Upper Street Include in The garage is an appropriate LSA use with a Street boundary specific retail element and is located in the centre of the Upper Street LSA. Liverpool Zasman Vet – 144 Include in A pub, restaurant, convenience shop and Road/ Liverpool Road boundary. vets are all uses which provide a positive Le Petit Village – 142 contribution towards convenience retailing, Street Liverpool Road essential services or leisure. Vietnamese Cuisine – 205 Liverpool Road The Regent Pub – 201- 203 Liverpool Road Londis – 130 Liverpool Road Upper Sainsbury’s – 465 Include in Unit lies just outside of the current boundary Holloway Holloway Road boundary and provides a convenience retailing offer, which is an appropriate use for an LSA. Upper 481,483,485,489,491,49 Removed All these are in C3 residential use. Holloway 3,495,497,499,501,503, from 505,507,509,511,513,51 boundary 5,517- 519,521,523,525,527,52 9,531 – Holloway Road

Campdale Tufnell Park Tavern – Include in The inclusion of the Tufnell Park Tavern 162 Tufnell Park Road boundary would help secure and enhance the character of the area and provide a leisure offer in the LSA. It is an appropriate LSA use and is contiguous with the existing LSA units.

St Paul’s The Cut (A1) – 1 Include in Redevelopment of the Highbury Corner Corsica Street boundary gyratory means there is easier pedestrian Brewhouse and Kitchen access to these units. Both are appropriate (A4/A3) – 2a Corsica LSA uses. Street St Paul’s Sainsbury’s – 93 St Include in Unit lies just outside of the current boundary Paul’s Road boundary and provides a convenience retailing offer, which is an appropriate use for an LSA. Newington Yield (A3) and Trattoria Include in The units are all appropriate LSA uses and Green (A3) – Alliance House, boundary are contiguous with the existing LSA units. 44-45 ; Papa John’s (A5) – 35 Green Lanes; Tesco Express – 37 -43 Green Lanes; Dostlar Mens Club (SG) – 47a Green Lanes; Green House (B1) – 49 Green Lanes Hornsey 125-129 Tollington Way Removed The premises have been converted to C3 Road from use. Tollington boundary Westbourn Whole of the Local Delete whole Unit 8-10 is the only unit left in commercial e Road Shopping Area LSA use. All other units have been converted to designation C3. It is therefore appropriate to de-designate

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LSA Name of Amendment Justification for inclusion/removal unit(s)/address the LSA; the remaining A1 shop will be protected through the dispersed shops policy. Drayton 54, 56 Drayton Park Removed Both units have been converted to C3 use. Park from boundary Exmouth 69, 71 Rosoman Street Removed Both units have been converted to C3 use. Market from boundary Packington 15,17,19,21,23 Prebend Include in This small parade is adjacent to the current Estate Street boundary LSA boundary and it has a variety of uses that would enhance the existing small LSA. The protection of these commercial and retail uses is also important serve the dense residential development surrounding it. Archway Whole of the Local Delete whole There are only two units within a commercial Road Shopping Area LSA retail use. Therefore, an LSA designation is designation no longer appropriate. The remaining A1 unit will be protected under the dispersed shops policy. The remaining A4 unit will be protected under the Public Houses policy. Lower 261A, 269-277 Holloway Include in Newly developed A1 commercial units which Holloway Road boundary are appropriate LSA uses. Old Street Imperial Hall 104-122 New LSA The London Plan designates Shoreditch City Road (Unit 1,2,3,4). designation (which includes Old Street) as a CAZ retail cluster. The LSA designation responds to the 199 Old Street London Plan by identifying a specific 203 Old Street boundary for the CAZ retail cluster. It is 201 Old Street considered sensible to designate as an LSA 189-197 Old Street rather than an alternative designation. The 183-187 Old Street LSA is varied, including frontages on the Old 207A Old Street Street Promenade of Light, Shoreditch Grind 207 Old Street café, and ground floor units of the Grade II 213 Old Street listed Leysian Mission. The LSA also 205 Old Street contains larger units such as Argos and a number of A3 uses. Further information is provided in in the Bunhill and Clerkenwell Area Action Plan topic paper. Farringdon 87 Charterhouse Street New LSA The London Plan designates Farringdon as a 91-93 Charterhouse designation CAZ retail cluster. The LSA designation Street responds to the London Plan by identifying a 89 Charterhouse Street specific boundary for the CAZ retail cluster. It 93A Charterhouse is considered sensible to designate as an Street LSA rather than an alternative designation. 95 Charterhouse Street The opening of the Elizabeth Line and the 50 Cowcross Street proximity to the Culture Mile, along with 49 Cowcross Street changes to Smithfield Market, will result in 52 Cowcross Street larger numbers of people using the area. The 51 Cowcross Street LSA designation links the 90 Cowcross Street entrance to Smithfield Market. Cowcross 91 Cowcross Street Street hosts a variety of uses and is an 92 Cowcross Street important link within the LSA. 93 Cowcross Street 41 Cowcross Street 61-63 Cowcross Street 61 Cowcross Street 64-65 Cowcross Street 70-74 Cowcross Street 85 Cowcross Street

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LSA Name of Amendment Justification for inclusion/removal unit(s)/address 85 Market House Cowcross Street 88-89 Cowcross Street 75-77 Cowcross Street 78 Cowcross Street 48 Cowcross Street 36-38 Cowcross Street 41 Cowcross Street 46 Cowcross Street 43 Cowcross Street 32-33 Cowcross Street 19-25 Zinc House Cowcross Street 26-27 Cowcross Street Cowcross Studios 30 Cowcross Street 1 Cowcross Street 2-3 Cowcross Street 8 Cowcross Street 9-13 Cowcross Street 18A Cowcross Street 5 Cowcross Street 4 Cowcross Street 14-16 Cowcross Street 17 Cowcross Street 70-74 Cowcross Street 94 Cowcross Street 66 Cowcross Street 67-69A Cowcross Street 34-35 Cowcross Street 1-2 Faulkner’s Alley 1 Greenhill’s Rents 36 Greenhill’s Rents 1 St John Street 3-5 St John Street 7-9 St John Street 1 St John Street 8 St John Street 10 St John Street 16 St John Street 12-14 St John Street 101 St Turnmill Street 99-100 Turnmill Street

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7 Policy R5: Dispersed Retail and Leisure Uses

Policy DM4.7 of the adopted Local Plan protects A1 uses outside of Town Centres and Local Shopping Areas, to ensure accessible provision of essential daily goods is maintained. Two years of marketing and vacancy evidence is required to demonstrate there is no demand for continued A1 use. Policy R5 takes a similar approach but adds protection for A3 uses.

A1 use

National31 and regional32 policy both support protection of small shops and aim to ensure accessible retail provision.

Dispersed shops are the bottom rung in the retail hierarchy. Policy R5 seeks to support and protect A1 uses that can deliver provision of essential daily goods. However, the policy is flexible enough to allow change of use where it can be demonstrated, through continuous marketing and vacancy evidence for one year, that there is no demand for continued operation of A1 uses and that there is no prospect of the unit being used to provide an essential service.

The policy also does not permit Change of Use unless essential daily goods will still be available, post-Change of Use, to local communities within a short walking distance. This is an important point as it will ensure continued accessible provision and fulfil the aims of the NPPF and the London Plan by ensuring the best possible access to those facilities of most importance to communities.

The protection of small shops has the benefit of helping to mitigate the prevalence of food deserts which are defined by the Social Market Foundation (2018) as ‘areas which are poorly served by supermarkets and other types of food store, making it difficult for individuals to access healthy food at a good price’33. The Food Poverty in Camden and Islington report (2018) identifies access to healthy, affordable food is not distributed evenly around the borough34. Although policy cannot require that the A1 use sells fresh food, it is nonetheless important to support and protect a use that has the potential to provide local essential services.

Dispersed A1 food shops also provide access to essential services for vulnerable groups who have mobility issues or cannot afford to use public transport to access essential goods, which addresses the aims of London Plan policy GG1.

31 NPPF (February 2019), paragraphs 91 and 92 32 London Plan policy E9, discussed in policy framework section of this topic paper. 33 http://www.smf.co.uk/wp-content/uploads/2018/10/What-are-the-barriers-to-eating-healthy-in-the- UK.pdf 34 Food poverty in Camden and Islington, January 2018 page 35. https://opendata.camden.gov.uk/download/a6rj-bnun/application/pdf

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A3 use

Policy R5, in terms of supporting and protecting A3 uses is also consistent with the London Plan by providing spaces that facilitate social interaction and combat social isolation, which in turn improves mental health and wellbeing. Policy R5 therefore supports the social integration strategy 201835. A3 uses can also provide informal meeting places that can foster civic engagement and promote social cohesion and interaction.

Policy R5 includes A3 uses because they often contribute positively towards the vibrancy and character of places outside of Town centres and LSAs. Policy R5 acknowledges that A3 uses, as well as dispersed A1 shops, are important for the provision of essential daily goods and limiting the prevalence of food deserts. Local cafes and restaurants can act as informal community hubs and importantly provide spaces for people, especially the elderly and people with impaired mobility to socialise and benefit from social interaction near to their home. This is in line with the local plan’s wider objectives of inclusivity and specifically objectives five and six.

A3 uses have a shorter six-month marketing and vacancy period, which will allow the council to assess continued demand for the A3 unit but not to the detriment of the local area by unnecessarily prolonging vacancy. Given that A1 uses are a more important daily use, it is considered appropriate to have a longer marketing and vacancy period for A1 uses.

35 https://www.london.gov.uk/sites/default/files/final_social_integration_strategy.pdf

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8 Policy R7: Markets and specialist shopping areas

Policy R7 acknowledges the important contribution markets and specialist shopping areas (SSAs) make to town centres. Policy R7 builds on policy DM4.9 of the adopted Local Plan.

With regard to SSAs, the Local Plan identifies two at Camden Passage in Angel Town Centre, and Fonthill Road in Finsbury Park Town Centre. These areas have a unique function, focused on antique/curio shops and specialist clothing respectively. The NPPF36 states that planning policies should allow Town Centres to grow and diversify in a way that reflects their distinctive characters.

The adopted Local Plan identifies specialist shopping areas but does not have a specific A1 percentage threshold. This has been introduced in the new Local Plan to give additional opportunity for protection to these uniquely important areas.

The percentages are based on retail survey data which shows that the Fonthill Road SSA has approximately 84% of its total units in A1 use; and Camden Passage SSA has approximately 70% of its total units in A1 use. The minimum target level of 75% A1 for both SSAs is appropriate because this threshold works to address the unique circumstances of both SSAs. Fonthill Road is currently in excess of 75% A1 uses which would allow a small amount of flexibility in change of use to non-A1 commercial uses while retaining a healthy majority of units in A1 use to support the continued effective functioning of these areas. The Council is working to enhance Fonthill Road, supporting the clothing businesses to become more self-sufficient and attract new customers. It is therefore warranted that a 75% threshold would allow supporting service and leisure uses to further animate Fonthill Road without compromising its core retail function. Conversely Camden Passage, with an A1 mix below 75% would benefit from an aspirational 75% minimum threshold target as Camden Passage itself and the surrounding area has a strong leisure food and drink offer, making the preservation of the retail function paramount in sustaining Angel’s unique selling proposition. Even though the SSAs have a healthy A1 mix they are still not immune from wider retailing challenges, therefore a maximum 25% non-A1 commercial allowance will provide supporting uses to complement the A1 function.

Camden passage; Camden walk; Charlton place; Pierrepoint Row Fonthill Road; Goodwin Street; Wells Terrace The SSAs are not identified on the Policies Map, as they are relatively fluid areas and they may expand over time as other uses locate near to the SSAs for agglomeration purposes. The Council consider that policy R7 should apply to such additional uses, hence a formal designation would not be appropriate as it wouldn’t capture these additional uses. The percentage of A1 units will be assessed on a case-by-case basis, taking into account the observed extent of specialist uses at any given time, but generally it would likely be measured as follows:

 Camden Passage – all units on Camden Passage and Pierrepoint Row.

36 NPPF (February 2019), paragraph 85

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 Fonthill Road – all units on Fonthill Road within the Town Centre boundary; and units at the southern end of Wells Terrace.

A two-year marketing and vacancy period for a change of use that would result in the level of A1 falling below 75% of all units is considered appropriate for SSAs. Their designation is focused on retaining the unique A1 character, therefore it is necessary for the council to be confident that there is no prospect of continued A1 use. The required marketing exercise assesses the demand for A1 uses in general, as the use class system permits, and not the type of A1 use that may contribute to the specialist shopping function.

The council recognises the possibility that the existing uses could be replaced by other A1 uses, however considers it important that the opportunity to protect the SSA is maintained. The continued success of the SSA will be closely monitored as part of the monitoring framework.

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9 Policy R8: Location and concentration of uses

There are certain types of uses, which, if over-concentrated in a particular area or located in close proximity to other potentially sensitive uses, can cause a harmful effect on vitality and viability, character, function and amenity, and can have negative impacts on health and wellbeing. Policy R8 aims to limit the location and unacceptable concentration of such uses.

Evidence suggests that the proliferation of hot food takeaways and gambling establishments can cause particular adverse impacts. Policy R8 therefore aims to limit such proliferation to avoid exacerbating these impacts, specifically by restricting hot food takeaways near schools and applying quantitative restrictions on betting shops and hot food takeaways in certain areas. The policy reflects and builds on the adopted Local Plan policy DM4.3, which includes a restriction on hot food takeaways within 200m of schools and also allows for assessment of overconcentration impacts within a particular area (generally within 500m radius of a site). The Location and Concentration of Uses SPD provides further guidance on adopted policy DM4.3 and will remain relevant with regard to the new Local Plan.

Policy R8 is part of a wider strategy by Islington Council to provide a range of measures to combat obesity37. These include:

 Tackling advertising and sponsorship;  Developing a foods standards policy;  Improving access to free drinking water;  Supporting businesses and organisations to improve their food offer;  Increasing healthy food and education as public events; and  Raising public awareness.

Restrictions on certain potentially harmful uses are supported by national and regional policy. The NPPF38 states that planning policies and decisions should aim to achieve healthy, inclusive and safe places which enable and support healthy lifestyles, especially where this would address identified local health and well-being needs; and should take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community.

The NPPG39 adds further guidance to the NPPF policy, noting that planning can influence the built environment to improve health and reduce obesity and excess weight in local communities, and that LPAs can have a role by supporting opportunities for communities to access a wide range of healthier foods and consumption choices. Planning policies and supplementary planning documents can, where justified, seek to limit the proliferation of particular uses where evidence demonstrates this is appropriate (and where such uses require planning permission); this could include having regard to the impact of certain uses in proximity to locations

37https://democracy.islington.gov.uk/documents/s13121/Local%20Government%20Declaration%20on %20Sugar%20Reduction%20and%20Healthier%20Food%20- %20finalised%20whole%20report%20JdeG.pdf 38 NPPF (February 2019), paragraphs 91 and 92 39 NPPG, Paragraph 004, https://www.gov.uk/guidance/health-and-wellbeing

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where children and young people congregate such as schools, community centres and playgrounds; and over-concentration of certain uses within a specified area.

Policy E9(BA) of the London Plan states that development plans should manage clusters of retail and associated uses having regard to their positive and negative impacts on the objectives, policies and priorities of the London Plan including town centre vitality, viability and diversity; sustainability and accessibility; place-making or local identity; community safety or security; and mental and physical health and wellbeing.

Policy E9(C) of the London Plan states that development proposals containing A5 hot food takeaway uses should not be permitted where these are within 400 metres walking distance from the entrances and exits of an existing or proposed primary or secondary school. The policy notes that boroughs that wish to set a locally-determined boundary from schools must ensure this is sufficiently justified. Boroughs should also carefully manage the over-concentration of A5 hot food takeaway uses within town centres and other areas through the use of locally-defined thresholds in Development Plans.

Policy E9(D) of the London Plan states that where development proposals involving A5 hot food takeaway uses are permitted, boroughs should encourage operators to comply with the Healthier Catering Commitment (HCC) standard. Where justified, boroughs should ensure compliance with the HCC through use of a condition.

The London Plan inspectors report40 notes the impact that policy E9(C) could have in terms of restricting new hot food takeaways, but considers that on balance, the social and economic benefits of the policy, in terms of improving health and wellbeing, particularly in deprived areas, mean that it is sound. The report did recommend that the HCC element of the policy should be revised to encourage rather than require compliance with the HCC.

Hot food takeaways

Uses that serve unhealthy food can cause adverse impacts where they are clustered together or located in close proximity to a particular sensitive use. Although hot food takeaways can include healthy food options, they more commonly sell food high in fat, saturated fat and salt; by virtue of their concentration or location, they can encourage the consumption of unhealthy foods which undermines efforts to improve health and wellbeing.

As noted in the Hot Food Takeaways and health in Islington report provided at Appendix 2, obesity is a serious and persistent issue in Islington with year 6 school children being over the national average for all three categories: overweight, obese and severely obese41 The latest data from the National Child Measurement Programme shows that 21% of Reception children and 39% of Year 6 children are

40 https://www.london.gov.uk/sites/default/files/london_plan_report_2019_final.pdf, paragraphs 400 to 410 41 Department of Health (2017) Prevalence of Childhood obesity, borough, ward and MSOA. https://data.london.gov.uk/dataset/prevalence-childhood-obesity-borough

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overweight or obese42, the latter being significantly in excess of the national and London average.

Around 55% of obese children go on to be obese in adolescence, around 80% of obese adolescents will still be obese in adulthood and around 70% will be obese over the age of 3043. This causes multiple problems throughout a person’s life from school absences in younger years to a wide range of serious illnesses in adulthood, which limits a person’s ability to live a fulfilling life and costs the state considerable amounts of money in providing care44.

There is an average of 1.9 A5 units within 200m of each Islington school, with 23 schools having three or more A5 premises’ within 200m45. Evidence from the London Borough of Brent46, showed that an average of 50% of students visit an A5 premises after school at least once a week, with 62% of students frequenting takeaways if they are in close proximity to the school. As with the purpose of the junk food advertising ban on the TfL network brought in by the Mayor of London47, the constant exposure to unhealthy foods in the form of advertising and A5 premises’ is linked to more frequent use, and is also likely to increase the amount of impulse purchases. The London Plan and this Local Plan take a precautionary approach to not just tackle existing over- concentrations but mitigate future potential proliferation.

Policy R8(B)(i) restricts hot food takeaways within 200m of primary and secondary schools. As noted above, the London Plan policy E9 resists hot food takeaways within 400m of schools but allows a local threshold to be put in place. The Council consider that a smaller 200m threshold is appropriate in Islington, given the small size of the borough, which would mean that 400m is an effective ban on A5 uses. Also, this would be at odds with policies R3 and R4 which identify A5 uses as suitable uses for retail areas. It is noted that policy R8(B)(ii) has quantitative restrictions on A5 uses in LSAs which would alleviate concerns about potential overconcentration of A5 uses in a particular area.

The approach proposed by the council is proportionate and based on evidence, both local and national. Obesity is a multifaceted issue, with planning being one of a number of tools to tackle it. Public Health England’s 2017 guidance48 highlights that planning documents and policies to control the over-concentration and proliferation of hot food takeaways should form part of an overall plan for tackling obesity and should involve a range of different local authority departments and stakeholders. It also specifically encourages local planning authorities to restrict planning permission for takeaways and other food retail outlets in specific areas, such as within walking

42 National Child Measurement Programme, England 2018/19 School Year, tables 3A_R and 3A_6, available from: https://digital.nhs.uk/data-and-information/publications/statistical/national-child- measurement-programme/2018-19-school-year 43 Hot Food Takeaways and health in Islington, 2018, page 6 44 Hot Food Takeaways and health in Islington, 2018, page 6 45 Hot Food Takeaways and health in Islington, 2018, page 14 46 London Borough of Brent (2014) Takeaway use among Brent’s school students. https://www.brent.gov.uk/media/16403699/d26-takeaway-use-brent-school-students.pdf 47 Mayor of London (2018) The London Food strategy: healthy and sustainable food for London, page 11. https://www.london.gov.uk/sites/default/files/final_london_food_strategy.pdf 48 Health matters: obesity and the food environment, available here: https://www.gov.uk/government/publications/health-matters-obesity-and-the-food-environment/health- matters-obesity-and-the-food-environment--2

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distance of school. The changes to the NPPF and PPG noted above align with the PHE guidance.

As noted above, the Council’s adopted policy includes the same 200m restriction as that proposed in policy R8. This has been implemented successfully in Islington in the six years since adoption, and also in other London Boroughs49.

Where proposals for uses serving food and drink are permitted, including A5 uses, the Council will require the operator to achieve, and operate in compliance with, the Heathier Catering Commitment standard. The Council’s Environmental Health team operate HCC as part of inspections of food premises, making compliance not overly onerous. Islington have implemented a requirement for HCC through planning since the adoption of the Location and Concentration of Uses SPD in 2016; the SPD provides further information on the HCC.

The HCC has been successfully upheld on a planning appeal50, where the inspector noted that, in order to ensure that a HFT did not contribute adversely to dietary related health problems in the neighbourhood, a condition requiring the operator to sign up to the HCC was necessary.

The Regulation 19 consultation saw landowner M&G Real Estate (reference R19.0099) object to the policy on grounds that it is inappropriate to restrict food, drink and night time economy uses where these uses could add to the vitality and viability of town centres. Policy R8 appreciates the contribution to vitality and viability A5 uses can make to town centres which is why there are no specific A5 restrictions in Town Centres.

Kentucky Fried Chicken Ltd (reference R19:0107) made a representation objecting to Policy R8 on the grounds it is not positively prepared, justified or effective. The respondent claims the policy is not based upon existing concentrations of A5 uses within 200m of schools; there is no evidence of proliferation; and there is no evidence of A5 uses causing obesity more than any other use where food or drink is sold or that their existence within 200m of schools is a greater cause of obesity than their existence generally. The council disagrees with KFC’s objections. The council has identified that 23 schools have three or more A5 hot food takeaways within 200m of the school. There are also 17 schools with one A5 use within 200m and six schools with 2 A5 uses within 200m. This demonstrates a clear proliferation that distorts a healthy environment for children and provides daily exposure to these foods. It is acknowledged that there are 24 schools with no A5 uses within 200m, however, the logic of only tackling an over concentration when this has arisen is counterproductive and fails to tackle the clear and consistent child obesity problem in Islington. Obesity is a complex issue and one that can only be combated through a multi-faceted approach, with planning as but one of the solutions. It is however true that A5 uses consistently sell calorie dense foods, high in sugar, salt and fat as well as saturated fat. This, coupled with daily exposure at very low prices, is a contributing factor to poor diet and obesity.

49 See appeal reference APP/V5570/A/14/2227193, Food & Wine, 49 Upper Street, London N1 0PN, paragraph 6, available here: https://acp.planninginspectorate.gov.uk/ViewDocument.aspx?fileid=5879501; and APP/U5930/A/14/2217961, 272 Church Road, London, E10 7JQ, paragraphs 10-12. 50 See appeal reference APP/V5570/W/18/3219281, 55-57 Rosebery Avenue, Islington, London EC1R 4SD, paragraph 23, available here: https://acp.planninginspectorate.gov.uk/ViewDocument.aspx?fileid=31794572

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Regarding the specific percentage restriction set out in policy R8(B)(ii), this is justified on the basis of the need to maintain the predominant retail function of LSAs. Town Centres can accommodate a broad mix of uses including A5, especially outside PSAs; however, LSAs are more susceptible to vitality and viability impacts, and A5 uses have a particular function – different to A3, and A4 leisure uses – which makes their impacts much more pronounced where they are clustered. The Council considers a quantitative restriction is necessary to avoid such impacts. This approach does, however, still give flexibility for some A5 uses to develop; it is not a ban on A5 uses outright.

Betting shops and adult gaming centres

Betting shops and adult gaming centres (AGCs) can have negative impacts, particularly where there are high concentrations of these uses. This particularly relates to the impacts on vitality and viability, character, function and amenity of retail areas; and also the impact upon health and wellbeing including increasing levels of problem gambling.

The Council considers that betting shops and AGCs should be assessed together due to their similar function and impacts. Betting shops and adult gaming centres both have a significant focus on gambling, with particular emphasis on electronic gambling machines.

Problem gambling affects communities in a variety of ways and it is estimated that problem gambling affects up to six other people as well as the problem gambler. Those affected by a person’s problem gambling are often close family including children51. Problem gamblers often experience a variety of harms, including: financial harms; family harms; health harms; and school/college/work harms52.

Evidence shows certain people are more vulnerable to gambling related harm, including those with substance misuse problems, poor mental health and those living in deprived areas53. Whilst the evidence does not show that substance misuse causes problem gambling or vice-versa, it is clear that people with substance misuse problems are more vulnerable to problem gambling.

As is the case with hot food takeaways, locally specific conclusions of causal related harm cannot be attributed solely to a betting shop or concentration of such shops; however, by utilising the planning system to mitigate the potential impacts of such uses, in particular avoiding concentrations which can increase adverse impacts, this will help to achieve delivery of healthy places. This approach is consistent with the NPPF54 and NPPG55, which advocate use of planning policies to achieve healthy, inclusive and safe places, including enabling and supporting healthy lifestyles (with particular reference to mental health).

51 Goodwin BC., Browne M., Rockloff M. and Rose J. A typical problem gambler affects six others, International Gambling Studies 2017;17:2, 276-289 52 Royal College of Psychiatrists (https://www.rcpsych.ac.uk/mental-health/problems- disorders/problem-gambling) 53 Wardle, H. et al. (2016). Exploring area-based vulnerability to gambling-related harm: Developing the gambling-related harm risk index. Bath, UK: Geofutures 54 NPPF (February 2019), paragraphs 91 and 92 55 NPPG Paragraph: 003 Reference ID:53-003-20191101, available here: https://www.gov.uk/guidance/health-and-wellbeing#achieving-healthy-and-inclusive-communities

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The Location and Concentration of Uses SPD (2016) provides relevant guidance in terms of justification for policy R8 and to inform policy implementation. This includes explanation of the interaction between licensing and planning.

There are circa 59 betting shops in the whole borough, with 23 betting shops located in town centres. This has decreased from 68 betting shops identified in the Location and Concentration of Uses SPD, but is still a significant quantum. It is also noted that the changes to the gambling industry put in place following the adoption of the SPD (e.g. changes to maximum stake on Fixed Odds Betting Terminals) do not seem to have had any significant impact on the number of betting shops, despite the betting industry claiming that such changes would lead to significant shop closures.

Clustering of betting shops is particularly apparent in Nag’s Head, Finsbury Park and Archway which all feature highly on the Gambling Risk Index56. Wardle (et al, 2017) noted that gambling provision in England has a distinct spatial pattern, with gambling venues clustering in areas of greater deprivation57; this is of particular relevance to Archway, Nag’s Head and Finsbury Park, which are all amongst the more deprived areas identified through the Indices of Multiple Deprivation.

Clustering of betting shops is particularly problematic due to the prevalence of fixed- odds betting terminals (FOBTs) and other such games. A reduction in the maximum stake from £100 to £2 was introduced in April 201958. Although this could be a positive move to reduce gambling harm, policy R8 part B(iii) and (iv) is still justified, as a risk of harm from overconcentration remains from the general betting function, alongside potential impacts from new forms of gambling, such as proxy roulette games that have arisen since the FOBT stake reduction. There is already evidence59 that the gambling industry is attempting to circumvent the changes to FOBTs through introducing new games with high maximum stakes. Past evidence of the lack of adherence to regulations gives further cause for concern60. As noted in the Location and Concentration of Uses SPD, the licensing system, by itself, may not be sufficient to prevent harm where new betting shops are proposed, and therefore the planning system, operating alongside licensing, can assist with ensuring that impacts are prevented or mitigated.

61 The London Assembly paper on Empty Shops on London’s High Streets noted that certain uses, including betting shops, act to devalue the attractiveness of a high street as a destination and reducing its vitality and viability. There are numerous dismissed

56 Betting shops and subprime lenders in Islington: health impacts, 2018, figure 2, page 9, see Appendix 3 57 Wardle H., Asbury G. and Thurstain-Goodwin M. Mapping risk to gambling problems: a spatial analysis of two regions in England. Addiction Research & Theory 2017;6:512-524 58 House of Commons Library Fixed odds betting terminals briefing paper number 06946, page 28, available here: http://researchbriefings.files.parliament.uk/documents/SN06946/SN06946.pdf 59 The Guardian, Paddy Power and Betfred may face watchdog sanctions, available here: https://www.theguardian.com/business/2019/apr/02/paddy-power-and-betfred-pull-games-as- regulator-investigates 60 Gambling Commission (2018). https://www.gamblingcommission.gov.uk/news-action-and- statistics/News/paddy-power-betfair-to-pay-penalty-package-for-social-responsibility-and-money- laundering-failures-on-its-gambling-exchange 61 London Assembly Economic Committee. Open for business. Empty shops on London’s high streets. GLA, 2014. Available at https://www.london.gov.uk/sites/default/files/gla_migrate_files_destination/FINAL_Economy%20Com mittee_empty%20shops%20report.pdf

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planning appeals from across the country which note the adverse vitality and viability impacts of betting shops.

The London Assembly report also stated that one of the effects of clusters of betting shops is to reduce the offer of the centre by replicating a use. The research also found that a clustering of betting shops can increase the rents in town centres as national chains have the resources to pay higher rents.

The council consider betting shops to differ from ‘main town centre uses’ as they do not provide active frontages, with windows used to display odds and promotions; this creates a barrier between the street scene and internal shop area.

In terms of amenity impacts, perceptions of anti-social behaviour and crime are often synonymous with betting shops. The Location and Concentration of Uses SPD discusses this issue.

Due to the impact that betting shops can have, particularly on vitality and viability and on the achievement of healthy communities, it is considered justified and necessary to introduce quantitative restrictions to limit the amount of betting shops in town centres and LSAs.

The thresholds for LSAs set out in policy R8(B)(iii) have been determined through analysis of the Local Shopping Area Retail Surveys, findings from the Retail and Leisure Study 2017, and findings from the ‘Betting shops and subprime lenders in Islington: health impacts’ report produced by the Islington and Camden Public Health team (see appendix 3).

The policy restricts betting shops and adult gaming centres (combined) to less than 4% of units within LSAs of 26 units or more; or a maximum of two units in LSAs with 25 units or less. The policy takes this approach as a uniform percentage restriction applied to all LSAs would impose a complete moratorium on these uses in certain sized LSAs, which already have a betting shop or AGC. It is not the intention of the policy to institute a ban, only to restrict these uses to a level which prevents harm from clustering, due to the impacts noted above.

The current picture in Islington’s Local Shopping Areas is as follows:

 There are no LSAs with 26 units or more that have over 4% betting shops  There are no LSAs with 25 units or less that have more than two betting shops.

This shows that the policy is sufficiently flexible and pitched at an appropriate level to accommodate additional betting shops or AGCs where they meet relevant policies.

The thresholds for Town Centres set out in policy R8(B)(iv) are different to the LSA’s because of the scale and number of units in these centres, but have been informed by the Retail and Leisure Study 2017 and retail survey information. 1.5% is just above the national average figure for betting shops in town centres62 and is a figure that appropriately manages the varying scenarios in Islington’s four town centres by restricting an over concentration in town centres with an existing high concentration of betting shops/AGCs, whilst allowing betting shops to establish where an over concentration is not present, however, without creating one.

62 Retail and Leisure Study 2017, paragraph 11.54

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The retail survey 2019 highlights the existing concentrations of betting shops and adult gaming centres within the borough. Nag’s Head and Archway town centres have a concentration over the 1.5% threshold for betting shops/AGCs within town centres. Finsbury Park town centre would surpass the threshold with one more betting shop/adult gaming centre. Angel being the biggest town centre in Islington with 679 units would be able to accommodate a further 3 betting shops/adult gaming centres until the 1.5% threshold is met. Angel currently has a 1% mix of betting shops. The proposed threshold will therefore achieve a balance between allowing some development of new units while restricting potentially harmful levels to develop; the Retail and Leisure Study 2017 specifically advises the Council to monitor betting shop provision across all centres, but particularly Nag’s Head, Archway and Finsbury Park to prevent proliferation and to ensure a healthy balance and diversity of town centre uses. Appendix 1 shows analysis of the current mix of such uses and how near to the threshold centres are

The 200m walking distance limit is considered a sensible distance which will ensure that uses are not located in very close proximity to one another, limiting the impacts associated with clustering. 200m is enough to preclude clustering but is not overly onerous. It adds a spatial backstop to the broad 1.5% threshold, which by itself would not prevent localised clustering of units. For information, the Council has approximated the end to end North-South and East-West walking distances across the four town centres using GIS, to give an indication of how many units could be accommodated in principle:

 Angel o East-West = 510 metres o North-South = 1,500 metres  Nag’s Head o East-West = 1,080 metres o North-South = 510 metres  Finsbury Park o East-West = 1,680 metres o North-South = 480 metres  Archway o East-West = 550 metres o North-South = 670 metres

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10 Policy R10: Culture and the Night-Time Economy

The Retail and Leisure Study highlights that “although the leisure sector has not been immune to the impact of the recent economic downturn, leisure activities remain an important lifestyle choice for many consumers who are prioritising leisure over other areas of spending”63. Leisure and cultural uses are supported by the NPPF and the London Plan, which broadly note the wide variety of economic, social and cultural benefits that such uses can achieve. Both tiers of policy promote leisure and cultural uses in Town Centres.

The NPPF and the London Plan both refer to the ‘agent of change’ principle, which places the onus on applicants to mitigate the impact of development on existing uses in the area; this is particularly relevant for leisure, cultural and night-time economy uses, where residential use is proposed near to existing operations and may therefore result in complaints and businesses being forced to close.

The London Plan has classified town centres on their strategic night-time economy function involving a broad mix of activity during the evening and at night, including most or all of the following uses: culture, leisure, entertainment, food and drink, health services and shopping64. There are three classifications; NT1, NT2, NT3, with NT1 describing areas of international or national significance, NT2 describing areas of regional or sub-regional significance; and NT3 areas with more than local significance. Archway, Nag’s Head and Finsbury Park are classified as NT3, while Angel is classified as NT2

In his Regulation 18 conformity response, the Mayor of London considered that Islington’s approach to culture and the night time economy is positive and welcome, recognising the important role this plays, not only for the borough, but for London as a whole and promotes the Mayor’s vision for London as a 24-hour city.

Agent of change

Policy R10 refers to the ‘agent of change’ principle which is covered by policy DH5. The principle is supported by national and regional policy as noted above. Although the Agent of Change principle is applicable for all uses, it is especially pertinent and vital for the protection of cultural and night time uses such as music venues which contribute to the boroughs character. Music venues are already experiencing significant closures due to economic reasons65, but the drive for further residential development creates a significant additional risk that such development will increasingly be located near to music venues and other cultural facilities. Where such impacts are not adequately mitigated, this opens up the potential for future complaints, for example due to noise from live music or from people entering and leaving venues.

63 Retail and Leisure Study 2017, paragraph 11.5 64 London Plan 2018, Annex 1, Night time economy classification 65 The Rescue Plan for London’s Grassroots Music Venues, available from: https://www.london.gov.uk/sites/default/files/rescue_plan_for_londons_grassroots_music_venues_- _progress_update_-_jan_2017.pdf

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Due to the significant risks to culture and night-time economy use, and the potential implications for the achievement of social and economic objectives of the Local Plan, it is necessary to put in place a locally specific agent of change policy. The policy prioritises mitigation through physical measures which would guarantee that impacts do not materialise. Non-physical measures may be acceptable where they provide some certainty that impacts are mitigated. Deed of easements are a stated example which would provide a legally binding guarantee that protects existing commercial occupiers from impacts, for example by setting out a legally agreed acceptable noise level. This approach was utilised on an application in LB Southwark, where new housing was proposed near the Ministry of Sound nightclub66.

The Mayor of London, in his Regulation 18 conformity response, welcomed Islington’s use of the agent of change principle and noted that it is in line with policy D12 of the London Plan.

Cultural quarters

Policy HC5 of the London Plan encourages the identification of Cultural Quarters to protect and/or promote cultural activity. Cultural Quarters can be defined around existing clusters of cultural uses or be used to develop new clusters. The Council has designated three Cultural Quarters in line with this broad remit. A Cultural Quarter designation can reflect an aspiration to expand cultural provision in an area, or can cover areas where there is already a broader level of cultural activity which must be retained and enhanced. The Mayor of London, in his Regulation 18 conformity response, noted that the proposed cultural quarters were very welcome and supported by policy HC5 of the London Plan.

The Cultural Quarter designations do not place thresholds on specific uses in the way that other policies (e.g. policy R2) do. Instead, cultural quarter designations require development in these areas to be approached through the prism of whether the development would enhance the cultural appeal of the area, either through direct provision of cultural facilities; supporting daytime and night-time uses to enhance the vibrancy of these areas; renewal and enhancement of heritage or otherwise distinct townscape; or limiting the location of residential uses which are noise sensitive to sites which are less likely to limit the cultural function of these areas.

This approach accords with other policies in the Local Plan and works in conjunction with other policies such as policy DH5. The council’s approach to Cultural Quarters also complements policies R3 and R4 by allow diversification away from solely or predominantly traditional retailing areas to more balanced retail, leisure and cultural areas.

The policy requires two-years marketing and vacancy evidence to justify the loss or change of use of any cultural facility. This is an important requirement as it maximises the opportunity for continued cultural uses at a given location, which would therefore help to support the cultural function of the area. The policy requires marketing for continued cultural use but not the specific use that is on site; this provides flexibility for applicants as it allows potential for a broad range of cultural use to occupy the site. An approach which required marketing solely for the same cultural use would be overly restrictive, although it is noted that the policy has an additional criterion regarding the

66 See paragraph 432a of representation hearing addendum report, https://www.london.gov.uk/file/15261/download?token=nMt7Xc0M

37 impact on the character of the area and/or wider cultural function; this could apply regardless of marketing.

The Cultural Quarters at Angel Town Centre and the area around Clerkenwell and Farringdon will help to retain and enhance the established successful cultural activity prevalent in these areas.

The Cultural Quarter at Archway Town Centre will assist in developing the burgeoning cultural role of this area and complement ongoing regeneration. Archway is home to a variety of artistic and cultural organisations, which would benefit the heightened importance of culture that is afforded by the Cultural Quarter designation, for example through agglomeration benefits gleaned from new cultural uses locating in the area. Details of some of the cultural organisations in Archway and the surrounding area are listed in table 3:

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Table 3: Cultural organisations in Archway

Organisation Type Address Notes Bomb Factory Artist 9-15 Elthorne Rd, The Bomb Factory Art Foundation is an Space , artist-led, non-profit charity, founded in London N19 4AJ 2015 as an independent space for contemporary art in Archway, North London, The Bomb Factory offers affordable studio space, a gallery, and workshops to artists at any stage of their careers. Brief Fine Arts Arts based 15 Fairbridge Rd, Creative services Archway, London Services N19 3EW Limited Konzept Arts & Arts based 26 Despard Rd, Konzept Arts & Ideas is a brand new Ideas services London N19 5NW performing arts management company led by London and Berlin-based Producer Natalie Richardson Lauderdale Arts Hub Waterlow Park, An arts and education centre based in House Highgate Hill, Waterlow Park, Highgate in north London N6 5HG London, England. As an arts centre, it runs an extensive programme of performances, workshops, outreach projects and exhibitions. Caxton House Community 129 St John's Way, Creative Community Hub Hub London N19 3RQ Islington Community 21 Hatchard Rd, Islington Chinese Association is a Chinese Hub London N19 4NG London based registered charity with an Association aim to promote social cohesion across the United Kingdom Central St Educational 2 Elthorne Rd, Foundation Diploma in Art and Design, Martins - Art and Archway, London MA Fine Art, MA Art and Science Design N19 4AG courses and Short Courses National Youth Educational 443-445 Holloway It is committed to the development of Theatre - Film & Rd, London N7 6LW young people through the medium of Theatre creative arts, and aims to use theatre to aid in this objective Kogans Educational 637 Holloway Rd, We provide full-time and part-time acting Academy - Film & Archway, London and directing training/teaching actors for Theatre N19 5SS stage and screen Archway With Festival - Navigator Square, Annual book festival including music & Words Books Archway library, film screenings Hargrave Hall and more Hargarve Hall Film Hargrave Rd, Community Cinema showing free film Archway, London screenings N19 5SP LUX Film Waterlow Park NPO - Supporting and promoting artists' Centre, Dartmouth moving image practices. Park Hill, Highgate, London N19 5JF Tufnell Park Film The Lord A community asset run on a shoestring Film Club Palmerston, 33 with understated expertise, it quietly Dartmouth Park Hill, introduces people to each other and to Highgate, London films they may or may not have seen or NW5 1HU heard of before Jacksons Lane Theatre 269A Archway Rd, NPO - Jacksons Lane has been a Highgate, London N6 creative and cultural hub for North 5AA London for 40 years and is officially the

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UK's leading supporter of contemporary circus. Northern Soul Live Music 114 Junction Rd, Bar & Kitchen Archway, London N19 5LB Blind Summit Theatre Unit 10, Grenville NPO - Puppet based theatre located at Education Workshops, 2a the top of Hornsey Road Grenville Rd, Finsbury Park, London N19 4EH Scarabeus Theatre Caxton House 3RQ, Scarabeus is a dynamic aerial theatre 129 St John's Way, company, which has since 1988 London N19 3RU pioneered the creation of site responsive and touring performances outside conventional spaces. We have an international reputation for creating beautiful, poetic and spectacular shows. WTW Big Band Live Music Hargrave Rd, Collection of local musicians Archway, London N19 5SP Mother Redcap Live Music 665 Holloway Rd, Upper Holloway, London N19 5SE Aces & Eights Live Music 156-158 Fortess Rd, DJs and live bands in 1950s-style rock Tufnell Park, London 'n' roll cocktail bar with neon signs and NW5 2HP dark corners. Oak & Pastor Live Music 86 Junction Rd, Archway, London N19 5QZ Archway Tavern Live Music The Archway Tavern - 1 Archway Close, N19 3TD Boogaloo Live Music 312 Archway Rd, & Film Quiz Highgate, London N6 5AT

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11 Policy R11: Public houses

Since 2001 25% of UK pubs have closed; between January and June 2017 alone, 525 pubs closed nationwide. Small pubs in particular have seen a significant nationwide reduction, from 40,840 in 2002 to 22,840 in 201867. However, it has been reported that the rate in which pubs are closing has halved, due to measures such as the Asset of Community Value mechanism and a reduction in business rates68.

Local Plan policy R11 builds on the current public house policy DM4.10, which seeks to provide a more detailed assessment of the public houses that warrant protection against change of use; and the conditions that public houses must demonstrate to show reasonable measures have been taken to retain viability of the pub. This provides a more targeted approach to the protection of pubs and requires appropriate and documented measures to be undertaken to improve the viable operation of the pub; such measures must be proven unsuccessful in order for a change of use to be acceptable. The policy also requires marketing and vacancy evidence (as per the adopted Local Plan policy).

This approach provides appropriate balance in terms of protecting pubs and encouraging development of economic, social or cultural value. Whilst the policy approach goes further than for other cultural uses, this is considered to be justified given the scale of closure and the contributions pubs can make to the community.

Public houses form part of the special character of Islington and there is both public and political support to retain these. Traditionally, public houses have been places where the social character of communities is most obviously demonstrated, providing civic space for community events and activities and socialising space which facilitates interaction between people from different walks of life. They are acknowledged across the UK as an important social institution and have contributed significantly to many local economies. The GLA Economics paper: Closing Time-London’s Public Houses notes that, in London, given the spread of people across the capital and high rents restricting people to smaller properties with less space, socialising in pubs can play a more pronounced role in facilitating social cohesion69. Policy R11 aims to retain public houses so they can continue to provide an important social and economic function within Islington’s local communities for years to come. The policy allows some flexibility for additional economic benefits by setting out support for small-scale visitor accommodation on upper floors of public houses (provided certain criteria is met).

Public houses are defined in the NPPF as community facilities and planning policies should plan positively for the provision of such facilities to enhance the sustainability of communities and residential environments70. The NPPF71 also directs planning policies to guard against the unnecessary loss of valued facilities and services. Policy R11 is consistent with the NPPF in that public houses are recognised as being integral to well-functioning communities. However, instead of having a blanket protection for pubs, it must be shown that the pub contributes to the borough in social, cultural or

67 J.Barrie (2019) https://inews.co.uk/news/consumer/pubs-closing-down-uk-figures-camra-latest/ 68 https://www.theguardian.com/business/2019/jul/22/uk-pub-closure-rate-halves-as-communities- fight-back 69 https://www.london.gov.uk/sites/default/files/closing-time-pubs-final.pdf 70 NPPF (February 2019), paragraph 92a 71 NPPF (February 2019), paragraph 92c

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economic ways. This provides flexibility to allow for the change of use of a pub if a pub is unable to demonstrate a demonstrable contribution to community/social/economic value. Specific criteria will apply to any proposal involving the change of use, redevelopment and/or demolition of a public house.

Public houses can often be heritage assets. Paragraph 185 of the NPPF states that plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay and other threats. This includes the ‘wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring, as well as the opportunities to draw on the contribution made by the historic environment to the character of a place’72. Policy R11 has a specific criterion to ensure retention of significant features of historic or character value.

The Mayor of London’s Regulation 18 conformity response notes that Islington’s approach to the protection of public houses is welcome and is in line with Policy HC7 of the London Plan. The GLA also suggested that the policy should support new pub proposals, in line with London Plan policy HC7. Although this is not specifically addressed in Policy R11, new pubs are clearly supported when the Local Plan is read as a whole, particularly when considering policies, R1, R3 and R10.

The London Plan inspectors report73 supports London Plan policy HC7, noting that the policy as a whole appropriately reflects the dual pressures of closure and threat of redevelopment to public houses.

72 NPPF 2019, paragraph 185(c) 73 Paragraphs 341-344, Available here: https://www.london.gov.uk/sites/default/files/london_plan_report_2019_final.pdf

42

12 Policy R12: Visitor accommodation

The NPPF74 encourages planning policies to ‘allocate a range of suitable sites in town centres to meet the scale and type of development likely to be needed’. The NPPF defines hotels as a ‘main town centre use’75.

Hotels are strategically important to support the operations of other businesses, however, from a broader economic perspective, hotels play a supporting economic role while other business types in the B-Use Class play a driving economic role76. Due to the surpassing of the required number of hotel bedrooms as set out by the GLA and the projected demand for 400,000sqm of additional office floor space by 203677, the approach taken to limit new visitor accommodation development to allocated sites and extensions of existing visitor accommodation is appropriate.

Islington Council has a strong record of delivering visitor accommodation. The Hotels in Islington Study 2016 cites the GLA benchmark of 1,300 visitor accommodation rooms to be delivered between 2012-203678. The GLA benchmark for each borough is set out in evidence which supports the London Plan; however, this is not, and has never been, a formal borough-level target. The adopted London Plan 2016 and new London Plan only refer to a strategic London-wide target, which is a clear indication that the Mayor considers there are a variety of options and locations for meeting this strategic target/demand for visitor accommodation.

The 2016 study notes that Islington has delivered 1,827 visitor accommodation rooms since 2001, with a further 1,626 room in the pipeline. This pipeline, if delivered, would exceed the benchmark by 25%79.

GLA evidence which informed the London Plan estimates that London will need to add an additional 58,140 rooms to the serviced accommodation supply by 2041, at an average of 2,236 rooms per annum – this strategic benchmark is reflected in policy E10 of the London Plan. The evidence sets out an indicative demand for rooms per borough – for Islington it identifies demand for 2,431 bedrooms to be built in Islington between 2015 and 204180. The borough benchmarks are not a formal part of London Plan policy and are not to be considered as borough level targets.

The paper looks at hotel supply and demand in isolation; the only way hotel demand could be met in boroughs such as Islington, where available land is scarce and there are many competing development pressures, is by prioritising hotel above other uses. Policy E10 of the London Plan promotes visitor accommodation in the CAZ and town

74 NPPF (February 2019), paragraph 85d 75 NPPF (February 2019), Annex 2 Glossary, page 68 76 Hotels Study (2016), Management summary, page ii 77 Employment Land Study (2016), paragraph 7.3.4 78 Hotels Study (2016), Management summary, page ii 79 Hotels Study (2016), paragraph 5.22 80 Projections of demand and supply for visitor accommodation in London to 2050, table 14, page 37. https://www.london.gov.uk/sites/default/files/visitor_accommodation_-_working_paper_88.pdf 43 centres, but has other policies, e.g. those promoting new office, which direct to the same locations. Therefore, the London Plan sets the strategic context which promotes uses in relation to certain locations, and, for local plan-making purposes, necessitates balancing the strategic context with the need for other land uses as well as hotels. As noted in the Employment Topic Paper, the evidence of need for new business floorspace in Islington is overwhelming.

Leaving aside the issue of the benchmark, the GLA paper has some issues including:

 It doesn’t reflect the deregulation of short term lets in projections, which could help meet some demand for visitor accommodation. Evidence81 suggests there are over approximately 3,000 listings for a whole home/flat in Islington, let at an average 83 days per annum (around a quarter of a year). These listings could be considered analogous to around 750 hotel rooms (in terms of available supply over a full year), which is a significant stream of supply.

 Like most projections, there are a significant number of variables which underpin the target identified in the paper, such as estimates of visitor nights. However, in the case of visitor accommodation, the variables are complex and dependent on macro-economic and political issues. Therefore, there should be considerable caution when using the outputs of the paper.

 For the gross scenario, the paper applies a rate of closure of 0.4% uniformly across boroughs; this is based on the average share of the total serviced rooms supply that has closed over the past five years. However, the closure rate from borough to borough could be significantly different, and in boroughs where hotels are more viable (like Islington), it is reasonable to expect that closures would be less than average. Even a minor change to the modelled closure rate could have a significant impact on the gross figure.

Although the updated GLA evidence points to a significant increase in visitor accommodation, the GLA’s response to the Regulation 18 consultation was supportive of Islington’s balanced approach to visitor accommodation and acknowledged the need to prioritise office floor space. The strong viability of hotels suggests without planning constraints they may be able to outbid office uses in most parts of the borough, therefore, outside of specified locations, unconstrained replacement of offices with hotels will conflict with the need to protect core employment areas82.

Taking into account relevant evidence, the high past delivery rate of visitor accommodation bedrooms and the significant need for other priority uses, it is appropriate for Local Plan policy R12 to take a more restrictive approach to future development of visitor accommodation by focusing development to sites with a specific allocation for visitor accommodation, or sites with existing visitor accommodation (through intensification/redevelopment). This ensures the best use of land in the borough to meet the broadest range of needs, while potentially forming a significant element of visitor accommodation supply, especially given the significant quantum of existing visitor accommodation in the borough which gives ample opportunity for future intensification (pending consistency with relevant Local Plan policies); it is estimated Islington currently has 4,495 visitor accommodation bedrooms, with 3,335 of these being ‘hotel’ bedrooms83.To be clear, an allocation for commercial or town centre uses

81 http://insideairbnb.com/london/ - accessed on 02/12/2019 82 Hotels in Islington Study (2016), paragraph 6.11 83 Hotels in Islington Study (2016), Figure 16 44 would not satisfy policy R12 – the wording of the allocation must specifically reference visitor accommodation.

London Plan Policy E10 encourages the provision of accessible bedrooms, which is reflected in the Local Plan. Policy R12 requires 10% of new bedrooms to be fully wheelchair accessible and requires visitor accommodation and ancillary facilities to be designed to be ‘visitable’ so that people of all physical abilities can access and enjoy all parts of the visitor accommodation. This ensures inclusive access for all.

Respondents to the Regulation 18 consultation considered that policy R12 was overly restrictive and visitor accommodation on sites with existing planning permission should be subject to the already adopted policy. The sole Regulation 19 consultation response from a developer/landowner (ref. R19.0137) argued that sites with good access to public transport should be considered. As noted above, the Council has significant needs to plan for, including offices and housing. There is no logical reason to effectively exempt sites with existing planning permission from the requirements of policy R12. If the permission is delivered then policy has no impact, and in fact would allow further intensification in principle. If a permission is not delivered, it is appropriate that these should be subject to updated policy requirements to reflect new local evidence and arising priority uses. Islington enjoys good transport links, which would allow many sites to come forward for visitor accommodation development, making the delivery of evidenced priority uses much more challenging.

45 Appendix 1

Retail Survey 2019 analysis

46 Table A1.1 Primary Shopping Areas Town Centre Minimum A1 Total number shop of ground floor Total number threshold units of A1 shop Total current units A1 shop % Angel 60% 262 130 50% Nag's Head 60% 96 54 56% Finsbury Park 55% 275 140 51% Archway 50% 79 38 48%

Table A1.2 Vacant units within Primary Shopping Areas Town Total number of Centre Vacant Units Total number % Mix of (2019) % of vacant of Vacant Units vacant units units (2019) (2017) (2017) Angel 19 7% 11 4% Nag’s Head 9 9% 2 2% Finsbury 22 Park 8% 28 9.9% Archway 4 5% 11 12.7%

Table A1.3 Specialist Shopping Area A1 mix Market & Specialist Shopping Areas Total number of Total number of A1 units shop units A1 % Camden Passage 37 25 70% Fonthill Road 79 66 84%

Table A1.4 Specialist Shopping Area vacancy rates Specialist Total number Shopping of Vacant Units % Mix of Total number Areas (2019) vacant units of Vacant Units % Mix of (2019) (Since 2017) vacant units Camden 2 Passage 5% 1 3% Fonthill Road 6 8% 4 5%

47

Table A1.5 Town Centre betting shop/adult gaming centres Town Centre Number of Betting Total number of Shops/Adult Betting shop/Adult units Gaming Centres Gaming Centres % Angel 679 7 1% Nag's Head 326 9 3% Finsbury Park District 427 6 1% Archway District 201 4 2%

Table A1.6 Local Shopping Area betting shop/Adult Gaming Centres 4% threshold limits for Local Shopping Areas with 26 units or more LSA Name LSAs that will Total number Number of trigger the of units Betting Shops % mix policy Balls Pond Road 32 0 0% Brecknock Road 26 0 0% Caledonian Road (central) 126 3 2% Caledonian Road (Copenhagen St) 37 0 0% Crouch Hill 1 more would 35 1 3% trigger 4% Essex Road 1 more would 50 1 2% trigger 4% 61 1 2% Farringdon 66 0 0% Highbury Barn 1 more would 33 1 3% trigger 4% Hornsey Road (Tollington) 40 0 0%

48 Hornsey Road North 1 more would 38 1 3% trigger 4% Kings Cross 65 0 0% 173 1 1% Newington Green 80 2 3% Seven Sisters Road 49 2 4% triggered St Pauls 1 more would 47 1 2% trigger 4% Upper Holloway 62 1 2% Upper Street 114 1 1% Whitecross Street 72 1 1%

Table A1.7 Local Shopping Area betting shop/AGC two or more threshold limits for LSAs with 25 units or less LSA Name Total number of Number of Betting LSAs that will trigger units Shops the policy Amwell Street 22 0 Caledonian Road another one would be (Cottage Road) resisted on the grounds it 24 1 would create '2 or more' Campdale 10 0 Place 5 0 Cardwell Terrace 7 0 Drayton Park 6 0 Embassy 17 0 Grosvenor Avenue 5 0 Highgate Hill 8 0 Hillmarton Terrace 5 0 Hillrise 7 0 King Henrys Walk 9 0

49 Liverpool Road Barnsbury St 25 0 New North Road 16 0 Old street 15 0 Packington Estate 8 0 Roman Way 4 0 Southgate Road 10 0 St. Peter's Street 11 0 Tollington Park 9 0 Whitehall park 9 0

Table A1.8 Local Shopping Area A5 hot food takeaway 4% threshold limits for LSAs with 26 units or more LSA Name LSAs that will Total number Number of A5 trigger the of units units % mix policy

Balls Pond Road

32 2 6% Brecknock Road 26 3 12% Caledonian Road (central) 126 9 7%

Caledonian Road (Copenhagen St) 1 more would 37 1 3% trigger 4% Crouch Hill

35 2 6% Essex Road 50 3 6% Exmouth Market 61 1 2%

50 Farringdon 66 3 5% Highbury Barn 33 2 6% Hornsey Road (Tollington)

40 4 10% Hornsey Road North 38 4 11% Kings Cross 1 more would 65 2 3% trigger 4% Lower Holloway 173 11 6% Newington Green 80 4 5% Seven Sisters Road 1 more would 49 1 2% trigger 4% St Pauls 47 4 9% Upper Holloway 1 more would 62 2 3% trigger 4% Upper Street 114 1 1% Whitecross Street 72 1 1%

Table A1.9 Local Shopping Area A5 hot food takeaway two or more threshold limits for LSAs with 25 units or less LSA Name Total number of units Number of A5 units Amwell Street 22 0 Caledonian Road (Cottage Road) 24 0 Campdale 10 0 Canonbury Place 5 0 Cardwell Terrace 7 0 Drayton Park 6 0 Embassy another one would 17 1 be resisted on the

51 grounds it would create '2 or more' Grosvenor Avenue 5 0 Highgate Hill another one would be resisted on the grounds it would 8 1 create '2 or more' Hillmarton Terrace another one would be resisted on the grounds it would 5 1 create '2 or more' Hillrise another one would be resisted on the grounds it would 7 1 create '2 or more' King Henrys Walk 9 0 Liverpool Road Barnsbury St 25 0 New North Road another one would be resisted on the grounds it would 16 1 create '2 or more' Old street another one would be resisted on the grounds it would 15 1 create '2 or more' Packington Estate 8 0 Roman Way 4 0 Southgate Road 10 0 St. Peter's Street 11 0 Tollington Park 9 0 Whitehall Park 9 0

Town Centre Number of A4 drinking establishments Number of A4 units in 2017 units in 2019 Net change Angel 35 36 1 Nag's Head 8 10 2 Finsbury Park District 7 10 3

52 Archway District 4 4 0

Table A1.11 Local Shopping Areas A4 uses LSA Name Number of A4 Number of A4 units in 2017 units in 2019 Net Loss Net Gain Hillrise 0 0 0 0 Whitehall Park 0 0 0 0 Highgate Hill 0 0 0 0 Couch Hill 1 2 0 1 Hornsey Road North 1 1 0 0 Hornsey Road (Tollington) 0 0 0 0 Tollington Park 1 1 0 0 Seven Sisters Road 1 1 0 0 Upper Holloway 4 4 0 0 Campdale 1 1 0 0 Cardwell Terrace 0 0 0 0 Hillmarton Terrace 0 0 0 0 Brecknock Road 0 0 0 0 Highbury Barn 1 1 0 0 Drayton Park 1 2 0 1 Grosvenor Avenue 0 0 0 0 Newington Green 2 2 0 0 King Henry's Walk 1 1 0 0

53 Ball's Pond Road 0 0 0 0 St Paul's 1 2 0 1 Lower Holloway 4 6 0 2 Roman Way 0 0 0 0 Caledonian Road (Cottage Road) 0 0 0 0 Caledonian Road (Central) 4 3 1 0 Caledonian Road (Copehngaden Street) 0 0 0 0 Liverpool Road/Barnsbury street 0 2 0 2 Upper Street 11 9 0 1 Canonbury Place 0 0 0 0 Embassy 0 0 0 0 Essex Road 2 2 0 0 Southgate Road 1 2 0 1 New North Road 1 1 0 0 St Peters Street 1 1 0 0 Kings Cross 5 6 1 2 Amwell Street 1 1 0 0 Packington Estate 0 0 0 0 Exmouth Market 3 3 0 0

54 Whitecross Street 2 2 0 0 Old street New LSA for 2019 (no 2017 data) 0 n/a n/a Farringdon New LSA for 2019 (no 2017 data) 5 n/a n/a

55

Appendix 2

56

Fast food takeaways and health in Islington: health impacts

57 Camden and Islington Public Health February 2020

58 1. Introduction

A healthy community is a good place to grow up and grow old in. It is one which supports healthy behaviours and supports reductions in health inequalities. It should enhance the physical and mental health of the community.

National Planning Policy Framework Guidance Paragraph: 005 Reference ID: 53-005-20140306

Local planning policy history: fast food takeaways

Islington Council takes a holistic approach to tackling obesity which includes:

 Creating an environment that supports good health and wellbeing by o Improving the food environment o improving the food offer o promoting physical activity.  Long established multi-sectoral partnerships including Proactive Islington and the Islington Food Strategy Group oversee action in these key areas.  Encouraging settings such as workplaces, schools and children’s centres to promote good health (UNICEF baby friendly, healthy schools/children’s centres).  Supporting people to adopt healthy lifestyles. These include the Families for Life programme, healthy living nurses, ‘and work with disabled young people.

Islington’s Core Strategy (adopted in February 2011) recognised that Islington has a significant diet- related health problem, including high rate of childhood obesity. As part of the council’s strategic approach to tackling this problem the Core Strategy committed to publishing a supplementary planning document that would help address the health impact of hot food takeaways, particularly those located close to schools. The policy was further developed in the Development Management Policies (adopted June 2013), which stated in Policy DM4.3, Location and concentration of uses:

A. Proposals for cafés, restaurants, drinking establishments, off licences, hot food takeaways, lap dancing clubs, nightclubs, casinos, betting shops, amusement centres and other similar uses will be resisted where they:

I. Would result in negative cumulative impacts due to an unacceptable concentration of such uses in one area; or II. Would cause unacceptable disturbance or detrimentally affect the amenity, character and function of an area.

The policy was given further detail in the Location and Concentration of uses Supplementary Planning Document adopted in April 2016

59  HFT 1: When an application for a hot food takeaway is received, various council departments and partner organisations will be consulted for comments on potential impacts and to source evidence and statistics (where possible).

60  HFT2: All applications for A5 uses should be accompanied by a completed Islington ‘Planning for Health’ self-assessment. The aim of the self-assessment is to encourage applicants to fully consider the health impacts of their proposal, in particular how any negative impacts will be mitigated/prevented; and to ensure that case officers have sufficient information to assess the impacts of the application.  HFT 3: Any applications for A5 units within a 200m radius of a primary or secondary school will be resisted.  HFT 4: All permitted applications involving A5 uses will be conditioned to require the operator to achieve, and operate in compliance with, the Healthy Catering Commitment standard.  HFT 5: All applications involving A5 uses should be accompanied by a Hot Food Takeaway Management and Operating Strategy.

This paper has been prepared by Camden and Islington Public Health to provide updated supporting evidence for the Local Plan review. The following sets out:

 the national and regional policy context;  the overweight and obese health picture in Camden;  obesity and the environment;  a review of hot food takeaways and their impact on health; and lastly  Camden’s role in tackling obesity.

2. National and regional planning policy context

National Planning Policy Framework (NPPF)

The National Planning Policy Framework set out the Government’s planning policies for England and how these are expected to be applied. It sets out the Government’s requirements for the planning system to the extent that it is relevant, proportionate and necessary.

The purpose of the planning system is to contribute to the achievement of sustainable development, defined in the UK’s Sustainable Development Strategy Securing the Future.

This sets out five guiding principles of sustainable development:1

a. living within the planet’s environmental limits; b. ensuring a strong, healthy and just society; c. achieving a sustainable economy; d. promoting good governance; and e. using sound science responsibly.

61 The planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Local planning authorities should create a shared vision with communities of the residential environment and facilities they wish to see.2

Taking account of and supporting local strategies to improve health, social and cultural wellbeing for all, and delivering sufficient community and cultural facilities and services to meet local needs is one of the 12 core land-use planning principles that should underpin both plan-making and decision-taking.3 When preparing local plans, local planning

62 authorities should work with public health officers and health organisations to understand and take account of the health status and needs of the local population and the barriers to improving health and wellbeing.4 Guidance on the NPPF clarifies that the local health and wellbeing strategy and other relevant health improvement strategies in the area should be considered by the local plan.

Chapter 8 of the NPPF focuses on promoting healthy communities. Paragraph 70 requires planning policies and decisions to plan positively for the provision and use of community facilities, including local shops and other local services.

National Planning Practice Guidance defines the role of health and wellbeing in planning, which is to ensure that health and wellbeing is considered in local and neighbourhood plans and decision making. The guidance includes the range of issues that should be considered through the plan making and decision making processes in respect of health, the issues of relevance are:

 the local plan promotes health, social and cultural wellbeing and supports the reduction of health inequalities;  the local plan considers the local health and wellbeing strategy and other relevant health improvement strategies in the area; and  opportunities for healthy lifestyles have been considered (e.g. planning for an environment that supports people of all ages in making healthy choices, helps to promote active travel and physical activity, and promotes access to healthier food, high quality open spaces and opportunities for play, sport and recreation)

The New London Plan.

The Mayor of London has consulted on his draft London Plan 2017, which is the overall strategic plan for London, with publication expected in March 2020. The new Lonon Plan sets out a fully integrated economic, environmental, transport and social framework for the development of the capital.

The new London Plan includes important policies for improving health and addressing health inequalities which seek to address the main health issues facing the capital, including obesity. Policies that are particularly applicable to access to healthy food are:

 Policy GG3 A: Ensure that the wider determinants of health are addressed in an integrated and co-ordinated way, taking a systematic approach to improving the mental and physical health of all Londoners and reducing health inequalities.  Policy GG3 G Seek to create a healthy food environment, increasing the availability of healthy food and restricting unhealthy options.  Policy E9 C Development proposals containing A5 hot food takeaway uses should not be permitted where these are within 400 metres walking distance of an existing or proposed primary or secondary school. Boroughs that wish to set a locally- determined boundary from schools must ensure this is sufficiently justified. Boroughs should also consider whether it is appropriate to manage an over-concentration of A5 hot food takeaway uses within Local, District and other town centres through the use of locally-defined thresholds in Development Plans.

63  Policy E9 D Where development proposals involving A5 hot food takeaway uses are permitted, these should be conditioned to require the operator to achieve, and operate in compliance with, the Healthier Catering Commitment standard.

When choosing what food to buy, 83% of people are most likely to say that healthiness matters to them a great deal or quite a lot.5

The Healthy Catering Commitment is a voluntary scheme to recognise food outlets which offer healthier food options, and make simple affordable changes to the food that they sell to make it healthier for their customers.

To achieve the award, takeaway stores need to show a range of healthier practices such as using healthier oils (rapeseed, sunflower, corn oil) instead of lard or palm oil, limit salt usage, promote water and low sugar drinks, and consider healthier sides such as salad, sweetcorn or jacket potatoes as an alternative to chips.

The draft London Plan 2017 seeks to address inequalities and obesity across a range of mechanisms in addition to healthy food choices, including the Healthy Streets approach and modal shift towards active travel (described in more detail in the Mayor’s draft Transport Strategy) and access to sport and recreation.

The Greater London Authority has produced a Takeaways Toolkit6 to help local authorities develop their responses to the health impacts of fast food takeaways. The toolkit has three main recommendations for boroughs:

 making food healthier – working with takeaway businesses and the food industry to make healthier fast food.  starting them young – schools should have strategies to reduce the amount of unhealthy food children eat at lunch and on their journey to and from school.  planning for health – use regulatory and planning measures to address the proliferation of hot food takeaway outlets.

Recently, the London Health Commission’s Better Health for London report favoured a much stronger approach to reducing the availability of fast food to London’s schoolchildren, citing 73% of people asked thought the number of fast food outlets near schools should be limited.7

The Government published its Childhood Obesity Strategy in August 2016,8 which introduced a number of measures to reduce the prevalence of obesity in children, including:

64  A Soft Drinks Levy introduced from April 2018, with revenue from the levy to be invested in programmes to reduce obesity, encourage physical activity, and provide balanced diets for school aged children  A challenge to industry to reduce sugar content by 20% by 2020. Sugar reduction can be through product reformulation, reduced portion size, and replacing sugar with lower sugar alternatives  Recommitting to the Healthy Start Scheme, which offers vouchers that can be exchanged for fresh or frozen fruit and vegetables and milk to low income pregnant women and low income families with children under 4  New standards to improve school meals  Clearer food labelling

3. Health in Islington: overweight and obesity

With children and young people, body mass index (BMI) varies with age and sex, so age and sex specific BMI growth charts must be used to classify weight status. The range of heights and weights for age and the number of children in the population are divided into centiles (100ths). Children who are the right weight for their height will lie between the 25th and 75th BMI centile. Overweight is classified as over then 91st BMI centile while obese is over the 98th centile.

Diet and related health problems in Islington

Children and young people who are obese are more likely to suffer from poor self-esteem and are less likely to socialise and do well at school. Health conditions such as high blood pressure, diabetes, poor lung function, bone problems and early puberty are also more common among obese children and young people. As a consequence, overweight and obese children are more likely to experience episodes of illness, health related limitations and require more medical care than normal weight children. Overweight children are 27%more likely to be absent from school, and obese children 54% more likely to be absent from school compared to their normal weight peers.9 This can on adverse impact on their educational attainment.

Obese children and adolescents are around five times more likely to be obese in adulthood than those who were not obese. Around 55% of obese children go on to be obese in adolescence, around 80% of obese adolescents will still be obese in adulthood and around 70% will be obese over the age of 30.10

Being obese or overweight also increases the risk of developing a range of serious diseases in adulthood, including type 2 diabetes, a range of cancers (including colon, ovary and breast), gall bladder disease, female infertility, osteoarthritis, stroke, dementia, hypertension, and circulatory disease. Children who are overweight or obese are at an increased risk of overweight or obesity in adulthood. According to the Joint Strategic Needs Assessment, cardiovascular conditions are one of

65 the leading causes of early death in Islington, CVD mortality rates are still higher than London and England, despite falling since 2001/03. Consequently, obesity is an important factor contributing to Islington’s inequality gap in life expectancy.

66 Overweight and obesity

The National Child Measurement Programme (NCMP) measures the weight and height of children in reception class (aged 4 to 5 years) and year 6 (aged 10 to 11 years) to assess the prevalence overweight and very overweight children within primary schools. The NCMP is widely recognised as a world-class source of public health intelligence and has UK National Statistics status. The programme has been running since 2005. It is important to note that as the programme measures weight in reception and year 6 children, each year represents a different population. Therefore, changes between the proportions of overweight and very overweight between years reflect a different cohort, and not changes in weight status among the same pupils year-on-year.

In Islington, the proportion of overweight and very overweight reception year children has remained stable from 22.7% in 2006/07 and 22.8% in 2016/17 (Figure 1), similar proportions to London and England, having peaked in 2010/11 at 26.3% when Islington had a significantly higher proportion of overweight and very overweight children compared to both London and England.

The proportion of Islington year 6 children who were overweight or very overweight has remained stable at 39.4% in 2006/07 and 39.1 in 2016/17 (Figure 2. The proportion of very overweight year 6 children in Islington is similar to London but significantly higher than England.

Figure 1: Weight status, Reception class, Figure 2: Weight status, Year 6, Islington, Islington, 2016/17 2016/17

Source: NCMP, 2017

Figure 3 shows the prevalence of overweight and very overweight in Reception year children in 2014/15 to 2016/17 by middle super output area ((MSOAs) a small geographical area with an average population of 7,200), whilst Figure 4 shows the prevalence of overweight and very overweight in year 6 children in 2014/15 to 2016/17 by middle super output area. 67 Figure 3: Prevalence of overweight and very Figure 4: Prevalence of overweight and very overweight in Reception year children, overweight in Year 6 children, 2014/15 to 2014/15 to 2016/17, by middle super output 2016/17, by middle super output area area

Contains OS data © Crown copyright and database right (2018) Contains OS data © Crown copyright and database right (2018)

Source: NCMP, 2018

For other age groups of children and young people, limited data are available in the GP record. In 2012, one third of children aged 0-18 years (based on 36 of Islington’s 37 GP practices) had their BMI recorded at some point in time (11,580 children). However, only 14% have had their BMI recorded within the previous 24 months (5,580 children). This means that about 28,080 children registered with Islington’s GPs had never had their BMI recorded at the practice and a further 6,000 children had not had their BMI recently recorded (within the past 24 months).

Trend evidence from English general practices shows an increase in the proportion who have excess weight across all age groups and for boys and girls (Figure 5)

68 Figure 5: Trend in body mass index across 375 English general practices, children aged 2 to 15, by sex, 1994 to 2013

11 Source: van Jaarsveld CHM and Gulliford MC, 2015

Modelled prevalence of overweight and in people aged 18 and over in Islington for 2015/16 is 50.9%, which is significantly lower than both England (61.3%) but similar to London (55.2%%).12 Data from Islington’s Public Health GP dataset (2015) gives a prevalence of overweight of 28.4% and a prevalence of obesity of 17.2%. There is a north/south divide in the prevalence of adult overweight and obesity, with the north having a prevalence greater than the Islington average and the south having a prevalence lower than the Islington average (Figure 6). It should be noted, however, that recording of body mass index in GP records is incomplete.

69 Figure 6: Adult overweight and obesity prevalence in Islington

Source: Islington Public Health GP Dataset, 2015

Weight and health inequalities in Camden

According to the 2012 Public Health GP Dataset, adults living in the 40% of areas that are most deprived in Islington were more likely to be overweight and obese compared to the Camden average, whilst those living in the least deprived were least likely to be overweight or obese.

NCMP data show that overweight and obesity varies by gender, age, ethnicity and socio- economic factors. Children from the most deprived areas have levels of obesity almost twice that of those who live in the least deprived areas. Among reception pupils, those who are Black African have significantly higher levels of obesity than any other ethnic group. Year 6 pupils (10-11 year olds) from Black and South Asian ethnic groups have higher levels of obesity compared to White British pupils. There is a similar number of boys and girls in reception (4-5 year olds) who are overweight and obese. By year 6, there are more boys than girls who are overweight and obese.

Costs of obesity

In 2007, the total annual cost to the NHS of diseases for which elevated BMI is a risk factor is estimated at £17.4 billion, of which overweight and obesity is estimated to account for £4.2 billion. This was predicted to increase to £6.3 billion for NHS costs attributable to overweight and obesity.13. The estimated costs to the NHS in Camden for treating overweight and obesity and related diseases 14 has been estimated at £73.6 million in 2015

4. Obesity and health

70 The causes of obesity are complex, it is now generally accepted that the current prevalence of obesity in the UK population is primarily caused by people’s biological susceptibility interacting with a changing environment that includes more sedentary lifestyles and

71 increased dietary abundance.13 In their Lancet article, Roberto and colleagues15 describe this as an interaction between two truths: individuals’ personal responsibility for their health and environmental factors that exploit biological, psychological, social, and economic vulnerabilities that promote overconsumption of unhealthy foods. A vicious cycle is then created. Preferences and demand for unhealthy products are not only shaped by the environment, but they then in turn sustain existing environments that encourage consumption of unhealthy foods. This cycle makes it difficult for people to act in their self- interest, but can be broken with regulatory actions from governments and efforts from industry and civil society.

The complexity is captured in the report’s full obesity system map (Figure 7). The map’s “food consumption cluster” includes many characteristics of the food market such as abundance and variety, nutritional quality, energy density, and portion size of food, whilst pressure for growth and profitability, the cost of ingredients and efforts to increase efficiency of production are characteristics of the map’s “food production cluster”, both clusters being relevant to the availability of fast food. Although representing just two aspects of this complex map, the report states that it is important to remember that the system is highly interconnected, for example intervening in ‘food consumption’ will have an impact on physical activity and individual psychology.

Childhood obesity can have a harmful effect on the body in a variety of ways. Obese children are more likely to have high blood pressure and high cholesterol, which are risk factors for cardiovascular disease, an increased risk of impaired glucose tolerance, insulin resistance and type 2 diabetes, breathing problems such as sleep apnoea and asthma, joint problems and musculoskeletal discomfort, and fatty liver disease, gallstones, and gastro-oesophageal reflux (i.e., heartburn). Obese children and adolescents have a greater risk of social and psychological problems, such as discrimination and poor self-esteem, which can continue into adulthood.16

There has been consistent strong evidence that childhood overweight and obesity are maintained into adulthood.17 Adult obesity is associated with a number of serious health 16 conditions including heart disease, diabetes, and some cancers.

72 Figure 7: The Foresight Obesity Map

Source: Foresight. Tackling Obesities: Future Choices, 2007

Overweight, obesity and the environment: UK policy

The Marmot Review,18 a government-commissioned strategic review of health inequalities in England, identified that a lack of attention paid to health and health inequalities in the planning process can lead to unintended and negative consequences, and that if no action were taken, the cost of treating the various illnesses that result from inequalities in the level of obesity alone will rise from £2 billion per year to nearly £5 billion per year in 2025. The report recommended prioritising policies and interventions that reduce health inequalities by improving the food environment in local areas across the social gradient.

The National Institute for Health and Care Excellence issued its evidence-based public health guidelines on preventing cardiovascular disease19 in 2010. It recommended that local authorities should be encouraged to restrict planning permission for fast food takeaways and other food retail outlets in specific areas (for example, within walking distance of schools), and should be supported to implement existing planning policy guidance in line with public health objectives. The approach taken in the Islington Local Plan is consistent with this recommendation.

Healthy Lives, Healthy People is the government’s response to the Marmot review. It recognises that the quality of the environment around us also affects the community. It recognises that access

73 to good-quality food is one of many factors that influence the health and wellbeing of the local population. The strategy recognises that “health considerations are an important part of planning policy”.

74 A 2014 Public Health England briefing20 written in conjunction with the Local Government Association and the Chartered Institute of Environmental Health highlighted that:

“One of the dietary trends in recent years has been an increase in the proportion of food eaten outside the home, which is more likely to be high in calories. Of particular concern are hot food takeaways, which tend to sell food that is high in fat and salt, and low in fibre, fruit and vegetables.”

Physical activity and weight

The “energy balance equation”, in which to maintain body weight the amount of energy (calories) consumed must equal the amount of energy expended is an important concept in preventing overweight and obesity, As an example, the energy expenditure required by a 50kg teenager (the average weight for a 14-year old) to burn off 500 calories (roughly a burger and small chips), would be 60 minutes of competitive football or running at 6mph, 70 minutes of BMX biking, 90 minutes of dancing, or 120 minutes of skateboarding (Figure 8).

Figure 8: The energy equation

The role of physical activity on health and wellbeing has been well documented, but its role as the key strategy in tackling obesity is less clear. Most studies that have researched physical activity and diet in relation to obesity have been based on self-reporting of both measures, which can be limited by recall bias (where people may not recall past events) or response boas (where people often are more likely to under-report behaviours perceived as undesirable or unhealthy, and more likely to over-report behaviours seen as desirable or healthy).

Recently, published literature has questioned the role of physical activity in tackling obesity. One review highlighted that trials provide generally consistent evidence that intake will rise to match expenditure making weight loss from increased exercise difficult, if not impossible, for many people, and that numerous trials have indicated that exercise plus calorie restriction achieves virtually the same result in weight loss as calorie restriction alone.21 Malhotra and colleagues22 take a similar view, and point out that up to 40% of people with normal body mass index will harbour metabolic

75 abnormalities usually associated with obesity, including high blood pressure, dyslipidaemia, non- alcoholic fatty liver disease and cardiovascular disease, as a result of poor diet. In a systematic review and meta-analysis,23 Johns and colleagues found that programs based on physical activity alone were less effective than

76 combined behavioural weight management programs combining diet and physical in both the short- and long-term

5. Schools in Islington

The Department for Education’s database24 lists 70 schools in Islington, with the type of school (based on the age of pupils), set out in Table A2.1.

Table A2.1: Schools in Islington

Primary school 51 Primary and secondary school 1 Secondary school 3 Secondary school and sixth form 7 Sixth form 2 Primary, secondary and sixth form 6 Total 70 Note: special schools and pupil referral units are not included

Source: Department for Education 2018

There is an average of 1.9 A5 hot food takeaways (A5-HFT) within 200m of each Islington school, based on the postcode centroids of the school and A5 HFT premises. 24 schools have no A5 HFTs within 200m, however 23 schools have three or more A5 HFTs within 200m. The frequency of A5 HFTs within 200m of school is shown in Table A2.1. The number of A5 HFTs per postcode and 200m radii around schools is shown in Figure 1.

For primary schools, there is an average of 2.1 A5 hot food takeaways (range 0 to 8) within 200m, for secondary schools there is an average of 1.3 A5 HFTs (range 0 to 6) within 200m.

When looking at the frequency of all outlets likely to sell hot food to take away within 200m of schools, the average number of outlets per school is 2.9, ranging from no outlets (14 schools) to 22 outlets (one school). 16 schools have eight or more outlets likely to sell hot food to take away within 200m. The number of non-A5 HFTs per postcode and 200m radii around schools is shown in Figure 1.

For primary schools, there is an average of 5.3 total hot food takeaway outlets within 200m (range 0 to 22); for secondary schools there is an average of 3.3 total HFT outlets (range 0 to 15) within 200m (Figure 9, Table A2.2 and Table A2.3)

77 Figure 9: HFT frequency and schools' 200m Table A2.2: frequency of A5 HFTs radii within 200m of a school

No of A5 HFTs Number of schools within 200m 0 24 1 17 2 6 3 11 4 4 5 2 6 2 7 2 8 2 Table A2.3: frequency of all HFTs within 200m of a school

No of all HFTs Number of schools within 200m 0 14 1 12 2 7 3 4 4 8 5 4 6 3 Contains OS data © Crown copyright and database right (2018) 7 2 8+ 16 Source: Islington Planning Department, 2018; Department for Education 2018.

6. Review of the evidence on takeaway hot food outlets – and their impact on health

Fast food typically incorporates all of the potentially adverse dietary factors, including saturated and trans fat, high glycaemic index, high energy density, and, increasingly, large portion size. Additionally, these foods tend to be low in fibre, micronutrients, and antioxidants.25

Fast food takeaways and proximity to schools

78 Three systematic reviews26,27,28 and one semi-systematic review29 that assessed access to fast food takeaways and their proximity to schools were found. Systematic reviews are considered the most reliable source of evidence. The purpose of a systematic review is to sum up the best available research on a specific question. Systematic reviews are particularly useful in bringing together a number of separately conducted studies, sometimes with conflicting findings, and synthesising their results.

The reviews identified a number of limitations in the evidence:

79  The majority of studies included in all three reviews were cross-sectional, a type of study that can find an association between a risk factor and an outcome, but which cannot establish whether the outcome was caused by the risk factor.  The reviews found considerable differences in how access and proximity were defined and measured between studies, which made it difficult to draw any form conclusions.  A third area of concern was the definition of a fast food takeaway. Studies tended to use either a broad measure that included all “limited service restaurants”, or use trade names to identify fast-food chains derived from various sources. Both are problematic: the former cannot distinguish adequately between fast food outlets and other food outlets that may serve healthier food, whilst the second omits independent outlets which, in 2009, formed 47% of the market in the UK.30

Findings from a 2011 systematic review of 40 studies on access to fast food demonstrated that fast food restaurants were prevalent in low-income and ethnic minority areas and around schools.31 Findings relating to body mass index (BMI) were too uncertain to draw solid conclusions on the relationship between fast food access and BMI. The lack of individual BMI data based on measured values was a significant limitation.

In a systematic review conducted by Williams et al., focused specifically on the food retailing environment around schools, there was little reported evidence for an effect of the school food environment on food consumption patterns and limited evidence of an effect on food purchases. However, a major limitation of the study was that where various analyses of proximity of fast food outlets to schools were reported in the same study, the authors only included a buffer of 800m from schools, whereas other studies suggest an increasing effect as proximity to school increases.32,33 In another study, Seliske et al found that measuring proximity using road networks rather than circular buffers more accurately reflected behaviours. 34

Engler-Stringer and colleagues28 reviewed the evidence on the influence of the community and consumer nutrition environments on the diet of children under the age of 18 years. Twenty-two out of 26 studies reviews showed at least one association between availability of food outlets and consumption of fruit and vegetables, fast food intake or total energy intake. Four studies reported only null associations.

There have been a number of studies published subsequently that were not included in the reviews above.

Seliske et al. found that by using a focused measure of where students eat their lunch, they were able to demonstrate that the food retail environment surrounding schools is strongly related to student’s eating behaviours during the school day. However, whilst they measured where students typically ate their lunch during the school day, they did not consider students’ use of fast-food 34 takeaways after school, which is a major limitation.

A study of 3,620 children aged 13 in a UK birth cohort study showed that increased exposure to fast food increased the frequency of visits to fast food outlets, which in turn was associated with higher body mass index standard deviation score (BMISDS, the recommended measure of body mass for children). Deprivation was the largest contributing variable to the exposure.35 A subsequent analysis of the 4,827 participants aged 13 to 15

80 years from the birth cohort confirmed that the consumption of fast food was associated with a higher BMISDS, higher body fat percentage, and increased odds of being obese, although this was not consistent across geographical areas.36

An observational study37 of children aged 3–14 years who lived within the Leeds metropolitan boundaries (n=33,594) using individual level height/weight data and geographic information systems found a significant positive correlation between the density of fast food outlets and higher deprivation. A higher density of fast food outlets was also significantly associated with the child being obese (or overweight/obese) taking into account sex, age and deprivation.

A Canadian cohort study found that residing in neighbourhoods with poorer access to fast- food restaurants and convenience stores was associated with a lower likelihood of eating and snacking out, and that children attending schools in neighbourhoods with a higher number of unhealthy relative to healthy food establishments scored most poorly on dietary outcomes.38

A study of over 9,000 children and adolescents found that fast-food was associated with a net increase in daily total energy intake of 126.29 kcal for children and 309.53 kcal for adolescents and with higher intake of regular soda (73.77 g for children and 163.67 g for adolescents) and sugar- sweetened beverages generally. Fast-food consumption increased intake of total fat (7.03g; 14.36 g), saturated fat (1.99g; 4.64 g), and sugar (5.71g; 16.24 g) for both children and adolescents respectively, and sodium (396.28 mg) and protein (7.94 g) for adolescents. Additional key findings were that adverse effects on diet were larger for lower-income children and adolescents and among adolescents, and increased soda intake was twice as large when fast food was consumed away from home than at home.39

In Newcastle, Gallo et al. found that there were more total food outlets in school fringe areas which had obesity prevalence rates above the national and local average compared to those areas which had lower prevalence rates.40

In their report “The School Fringe”, Sinclair and Winkler found that local independent shops offered child-size portions at child-size prices. They organised fast service in busy periods, and even took on extra staff. Their food was fattier, on average 45% of calories from fat, versus 32% from other fringe shops. The most popular type of food retail shop in the urban setting was the supermarket, with more visits than all takeaways put together, although the proportion of food bought in supermarkets compared with fast food takeaways was not clear.41 A report on fast food outlets in Tower Hamlets, London, found that school pupils formed a large proportion of customers of fast food, and that fast food outlets were offering special deals for children which were often made and stacked up in advance to ensure schoolchildren are served quickly during lunchtime or on their way home from school. The report also found that small business advisors often encouraged prospective owners to either open or purchase fast food outlets near schools and colleges because of the significant sales potential offered by schoolchildren and young adults.42 This latter report also noted that competition from overprovision was problematic for many business owners, who felt that they had to sell cheaper unhealthier products because of the higher profit margins on this type of food.

81 A study on the consumption of takeaway and fast food in Tower Hamlets showed that children frequently purchased chips on their own or with other fried items like fried chicken or pizzas. In addition, 70% preferred sweetened soft drinks over other drinks when purchasing fast food. The products that were purchased were calorie dense, high in sugar, salt and fat as well as saturated fat. The study concluded that actions need to be taken to either limit the ability of children to access fast food outlets or to substitute healthier foods and drinks available at fast food outlets. One limitation of the study, however, was that it was unable to differentiate between the impact of proximity to schools and proximity to homes.43

Also in Tower Hamlets London, Caraher et al. found that there were concentrations of fast- food outlets near schools and that students reported using these, including reports of skipping lunch in order to save money and eat after school at these outlets. Food from fast- food outlets was high in fat, saturated fat, and salt, but these were not the only source of such foods, and many of the students reporting buying from shops near the school or on the way to or from school. At lunchtime food outlets were less likely to be used by school students in areas near schools that had a closed gate policy.44

The London Borough of Brent undertook research45 in 2014 among 2,418 secondary school pupils in seven schools, four of which had a fast food takeaway within 400m of the school and three did not. Findings included:

 50% of students visit a hot food takeaway after school at least once in an average week; students from schools with no nearby takeaways are less likely do so (43%) than students from schools with nearby takeaways (62%).  20% of students would walk 4 minutes, and 17% of students would walk up to 10 minutes for hot food takeaways at lunch time  27% of students said they would not bother going out at lunch if they had to walk more than 8 minutes  Of students who do not visit takeaways, 48% said the main reason they don’t is because they are unhealthy, 52% from outside the buffer zone compared to only 38% inside, and 38% don’t go as it takes too long, 43% of these from outside and only 29% from inside the zone thought this.  The most popular reason for visiting were the taste (62%), and that its cheap (39%), and easy (37%).

Pearce and colleagues undertook a longitudinal study46 of proximity to fast food outlets using data on 1,577 children from the National Child Measurement Programme in 2006/7 (reception year) and 2012/13 (year 6). A moderate association was found between deprivation score and accessibility, and children who had greater access to fast food outlets were nearly twice as likely to gain significant weight compared to children who had no access to fast food outlets.

In a multicentre, multi-country cross-sectional study of 72,900 children in 17 countries and 199,135 adolescents in 36 countries, Braithwaite and colleagues47 reported fast-food consumption as high in childhood and increased in adolescence. Compared with infrequent fast-food consumption, frequent and very frequent consumption was associated with a higher BMI in children.

82 There is far less published evidence regarding fast food outlets’ proximity to primary schools. However, industry data show that 29% of family visits to fast food outlets are influenced by children’s choices in what the company describes as its “Dine out pester power scorecard”.48 Whilst a large proportion of these visits are promoted through television and other advertising, they are often supported by promotions such as free toys, sold in packaging attractive to young children, or branded with names appealing to young children. No research on how this links with proximity to schools was found.

Fast food outlet density

In a systematic review49 if of 12 fast food access studies, ten found fast food restaurants were more prevalent in areas with higher concentrations of ethnic minority groups in comparison with Caucasians. Six adult studies found higher body mass index was associated with living in areas with increased exposure to fast food; although four studies did not find associations.

In their semi-systematic review, Fraser and colleagues50 found that 14 of 16 studies reported a positive correlation between fast food outlet density and area deprivation. The authors found mixed results for the association between fast food availability and weight status, but some evidence that greater exposure to fast food is associated with a lower fruit and vegetable intake. In the review, six out of nine studies which looked at food consumption in relation to the availability/location of fast food outlets found a significant association in the expected direction.

Burgoine and colleagues51 examined the association between environmental exposure to takeaway food outlets, takeaway food consumption, and body weight, in the for home, work place, and commuting route environments among 5,442 adults aged 29 to 62 years in Cambridgeshire. The researchers found that exposure to takeaway food outlets in home, work, and commuting environments combined was associated with marginally higher consumption of takeaway food, greater body mass index, and greater odds of obesity.

7. Islington’s integrated approach to tackling overweight and obesity

Islington Council is taking an integrated, multifactorial approach to reducing overweight and obesity as part of an overall healthy lives This approach includes creating an environment that supports good health and wellbeing by improving the food offer and promoting physical activity.

Islington’s Joint Health and Wellbeing Strategy’s vision for Islington is for a community of healthy, connected and resilient people, where residents live, work and play in places that support and promote health. It seeks to develop a healthy environment to encourage access to

83 healthy food, physical activity and active travel (including walking) for families in their everyday lives.

Working with partners in the Clinical Commissioning group, communities and commissioned services, as well as neighbouring boroughs, the Council is implementing

84 a range of measures, from a universal supportive offer through to targeted services where need is greatest.

Islington and its wellbeing partner Haringey are at the forefront of the movement across London to sign up to the Local Government Declaration on Sugar Reduction and Healthier Food. The Declaration supports a whole-systems approach, helping to address unhealthy eating through targeted action under the six key areas of commitment.

Signing the Declaration makes clear the Councils’ commitment to tackling the causes of obesity. The aim of signing the Declaration is not to ban sugar or eliminate choice for our residents. Instead, it is about making a range of changes to the wider food environment which make it easier, more convenient and / or more affordable for residents to make healthier choices. Islington’s pledges are:

Tackle advertising and sponsorship:

 Develop a policy on advertising, sponsorship and corporate partnerships  Improve the food controlled or influenced by the council

Develop a Food Standards Policy:

 Reduce the sale of sugar sweetened soft drinks from council-owned or managed premises

Reduce prominence of sugary drinks and promote free drinking water

 Improve and promote access to free drinking water

Support businesses and organisations to improve their food offer:

 Continue to promote the Healthier Catering Commitment (currently around 250 businesses have achieved Healthy Catering Commitment status) and London Healthy Workplace charter to achieve health benefits  Support the Whittington Hospital to improve their healthy food offering across catering, retail and vending food offering across catering, retail and vending points.

Public events:

 Increase the healthy food offer at Council organised events

Raise public awareness

85  Sign up to the Sugar Smart campaign

Islington’s offer of services follows a lifecourse approach to tackling obesity and the risk factors for obesity.

The Islington Breastfeeding and Weaning Peer Support Project is a free service for new mums in Islington. In both the Whittington and UCH hospitals a team of friendly and experienced breastfeeding supporters and helpers support parents and babies in the

86 postnatal wards every day. The service also contacts new mums shortly after they have been discharged from hospital to offer telephone support in their first few days at home with their babies. The service runs seven friendly and welcoming weekly breastfeeding drop-in groups at children’s centres across Islington, where mums can just turn up and see a breastfeeding supporter and meet other mums and babies.

Families for Life programmes are open to all families living with a child at school, or registered with a GP in Camden or Islington. Four programmes operate across settings including schools, community centres and children’s centres:

 Families for Life – Early Years: fun and active play, healthy eating and general healthy living workshops delivered via a series of weekly workshops held over 4 weeks. Available to families with children aged 2-4; parent and child attend together  Families for Life – Primary: fun and active play, healthy eating and general healthy living workshops delivered via a series of weekly workshops held over 4 weeks. Available to families with children aged 5-11; parent and child attend together.  Families for Life – Family Kitchen: family cooking and eating workshops held in early years and primary children’s settings. Available to families with children aged 2-11; parent and child attend together.  Families for Life – Healthy Parents: Healthy eating and healthy living workshops to help parents support their children to stay active and eat well. The programme covers cooking and nutrition, active living and behaviour change. Parents attend without children.

The Enhanced Healthy Living Service is a multi-disciplinary team (MDT) which includes a Consultant Paediatrician, Healthy Living Practitioners in Camden and Islington, A Clinical Psychologist and an Assistant Psychologist. The service supports families who have children aged 5-17 years who have a BMI over the 91st centile (within the obese range). The child or young person must live in or attend a school in Islington.

The Healthy Living Practitioners offer advice and guidance around diet, exercise and healthy lifestyle changes. The Clinical Psychologist and Assistant psychologist offer assessment and support to families and young people who have psycho-social factors that make it difficult to implement the advised healthy lifestyle changes or who have mental health concerns related to their weight. The Consultant Paediatrician offers consultation on the medical factors and risks of obesity. The Enhanced Healthy Living MDT works closely with other professionals and local services and offers appointments within clinics, homes and schools.

ProActive Islington was set up in 2005 and brings together organisations in the borough that provide, promote or commission sport and physical activity. It provides a strategic and coordinated approach to promote physical activity and its benefits across the borough. The strategy targets communities that are less involved in sport and physical activity than the rest of the borough; live in areas of deprivation; and have greater health inequalities, combating this by providing services that are easy for people to access. A physical activity needs

87 assessment is underway (March 2018) which will inform the next iteration of the ProActive strategy.

8. Conclusions

This document reviews the national and regional policy context, levels of overweight and obesity in Islington, the links between obesity and poor health, the links between physical activity and weight, and reviews the evidence base on takeaway hot food outlets and their impact on health.

The national and regional policy supports tackling overweight and obesity through planning policy. Levels of overweight and obesity among Islington’s children are similar to levels in England, levels which nationally are considered to be too high. There is evidence that overweight and obesity in childhood increases the risk of overweight and obesity in adulthood. There is also evidence that overweight and obesity are detrimental to health and wellbeing.

The evidence highlights the need for local planning authorities to manage the proliferation of fast food outlets as a means of combating their adverse impact on public health. In particular, such management should be scaled up around schools as evidence shows that an increasing number of hot food takeaway shops are operating within easy walking distance to schools. Overall there is evidence that, although availability of high density, high fat and high sugar food is not the only factor that influences diet and obesity, it is a significant contributing factor which needs to be taken into consideration as part of an integrated approach to managing overweight and obesity.

Whilst issues around pricing and competition are not planning considerations, the proximity of hot food takeaways, which may be considered inappropriately sited near to youth establishments, is a planning consideration.

Based on then evidence, policies that restricts the opening of new hot food takeaways within 200m of schools (a distance considered to be equivalent to a five-minute walk), talking overconcentration of hot food takeaways, and requiring robust health impact assessments for applications of hot food takeaways near to sensitive uses would be helpful in supporting the wide range of programmes that aim to tackle overweight and obesity among residents.

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47 Braithwaite I, Stewart AW, Hancox RJ, et al. Fast‐food consumption and body mass index in children and adolescents: an international cross‐sectional study. BMJ Open 2014;4:e005813

48 NDC Group (December 2014). Pester power drives 763 million family eat‐ out visits per year in Britain. https://www.npdgroup.co.uk/wps/portal/npd/uk/news/press‐ releases/pester‐power‐drives‐763‐million‐ family‐eat‐out‐visits‐per‐year‐in‐ britain/ (accessed 16th June 2015)

49 Fleischhacker SE., Evenson KR., Rodriguez DA. and Ammerman AS. A systematic review of fast food access studies. obesity reviews (2011) 12, e460–e471

50 Fraser LK., Edwards KL., Cade J and Clarke GP. The Geography of Fast Food Outlets: A Review. Int. J. Environ. Res. Public Health 2010, 7(5), 2290‐2308

51 Burgoine, T., Forouhi, NG., Griffin, SJ., Wareham, NJ. and Monsivais, P. Associations between exposure to takeaway food outlets, takeaway food consumption, and body weight in Cambridgeshire, UK: population based, cross sectional study. BMJ 2014;348:g1464

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Appendix 3

93 | P a g e

Betting shops and subprime lenders in Islington: health impacts

Camden and Islington Public Health June 2018

94 | P a g e 1. Introduction

This paper summarises the evidence base regarding the association between gambling premises and health and wellbeing, and sub-prime credit premises and health and wellbeing. A public health approach to tackling harm from gambling and debt needs to address the effects of gambling and debt on the individuals’ families and close associates, and on the wider community – as well as on those who suffer harm from their own gambling or debt. It needs to recognise that a successful strategy cannot focus solely on individual gamblers or individuals in debt but also needs to encompass products, environments and marketing and the wider context in which gambling occurs. National policy

A healthy community is a good place to grow up and grow old in. It is one which supports healthy behaviours and supports reductions in health inequalities. It should enhance the physical and mental health of the community.

National Planning Policy Framework Guidance Paragraph: 005 Reference ID: 53-005-20140306

The National Planning Policy Framework (NPPF) sets out the role planning in promoting healthy communities in planning in paragraphs 69 to 78.1 The NPPF recognises that the built and natural environments are major determinants of health and wellbeing. Key considerations from the NPPF include:

 the local plan promotes health, social and cultural wellbeing and supports the reduction of health inequalities;  the local plan considers the local health and wellbeing strategy and other relevant health improvement strategies in the area;  opportunities for healthy lifestyles have been considered (e.g. planning for an environment that supports people of all ages in making healthy choices, helps to promote active travel and physical activity, and promotes access to healthier food, high quality open spaces, green infrastructure and opportunities for play, sport and recreation).

The NPPF describes a healthy community as a good place to grow up and grow old in, which supports healthy behaviours and supports reductions in health inequalities. A healthy community should enhance the physical and mental health of the community and, where appropriate, encourage:

 Active healthy lifestyles that are made easy  The creation of healthy living environments for people of all ages

The Town and Country Planning (Use Classes) Order 1987 (as amended) (‘the UCO’) was amended in April 2015 to move betting shops and payday loan shops from planning class use A2 into the ‘sui generis’ use class. As noted in the initial consultation on the use class change, the Government made this change to support

95 | P a g e local communities and local planning authorities in shaping their local area, in response to repeated requests from local authorities

96 | P a g e and local communities that every betting shop and payday loan shop application should require planning permission and be specifically considered by local authorities. These changes mean that new or change of use to a betting shop or payday loan shop will now have to apply for express planning permission, rather than benefiting from permitted development rights. The changes do not create a presumption of refusal; therefore, robust guidance and assessment criteria are needed to fully assess these applications.

In the Government response to the consultation on proposals for changes to Gaming Machines and Social Responsibility Measures published in May 2018, the Government indicated that where an increase in the number of licences betting offices is considered to be a local issue, having an up-to-date, relevant local plan in place will support the local planning authority in the determination of any applications for planning permission. Regional planning policy

The draft London Plan 2017 Policy SD6 promotes a diverse range of uses to support the vitality and viability of town centres, and notes that over-concentrations of some uses such as betting shops, pawnbrokers, pay- day loan stores, amusement centres, and hot food takeaways, can give rise to particular concerns regarding the impact on mental and physical health and wellbeing, amenity, vitality, viability and diversity. The plan states that proliferation and concentration of these uses should be carefully managed through Development Plans, particularly in town centres that are within Strategic areas for Regeneration (including Angel and Nag’s Head in Islington), which tend to have higher numbers of these premises.

This strengthens Policy 4.8 g in the current plan, which seeks to manage clusters of uses having regard to their positive and negative impacts on the objectives, policies and priorities of the London Plan.

Local planning policy

In June 2013, Islington Council adopted its Development Management Policies Development Plan Document, an integral part of its Local Plan. In this document, Policy DM4.3 resists proposals for certain uses (including betting shops, adult gaming centres and other similar uses) where they i) would result in negative cumulative impacts due to an unacceptable concentration of such uses in one area; or ii) would cause unacceptable disturbance or detrimentally affect the amenity, character, and function of an area. Part B of this policy resists those uses where they would be in proximity to schools or sensitive community facilities.

The policy was afforded more detailed guidance in the Location and concentration of uses supplementary planning document, adopted in April 2016. This document states that:

Betting Shops

 When an application for a betting shop is received, various Council departments and partner organisations will be consulted for comments on potential impacts and to source evidence and statistics where possible.  All applications for betting shops should be accompanied by a completed Islington Planning for Health assessment.

97 | P a g e  All applications for betting shops will be conditioned to require the display of information about debt advice services and gambling addiction charities.  All applications for betting shops will be conditioned to require the operator to sign up and maintain compliance with community safety and good practice schemes  All applications for betting shops should be accompanied by a Betting Shop Management and Operating Strategy

Payday Loan Shops

 When an application for a payday loan shop is received, various Council departments and partner organisations will be consulted for comments on potential impacts and to source evidence and statistics where possible.  All applications for payday loan shops should be accompanied by a completed Islington Planning for Health assessment.  All applications for betting shops will be conditioned to require the display of information about debt advice services and local credit unions  All applications for payday loan shops will be conditioned to require the operator to sign up to and maintain compliance with good practice schemes.  All applications for payday loan shops will be conditioned to require the operator to display information about their interest rates, fees and charges.

Gambling licensing policy

The responsibility for regulating gambling is shared between the Gambling Commission and local authorities. The Gambling Commission is responsible for issuing operating licences to organisations and individuals who provide facilities for gambling and personal licences to persons working in the gambling industry. The Commission will take the lead role on ensuring that gambling is conducted in a fair and open way through the administration and enforcement of operating and personal licence requirements. The Commission will also be responsible for remote gambling activities such as facilities provided via the Internet, television or radio.

The main functions covered by local licensing authorities are:

 licensing premises for gambling activities  considering notices for the temporary use of premises for gambling  granting permits for gaming and gaming machines in clubs  regulating gaming and gaming machines in alcohol licensed premises  granting permits for family entertainment centres with lower stake gaming machines  granting permits for prize gaming  considering occasional use notices for betting at tracks  registering small lotteries  tackling illegal gambling activity  ensuring compliance with gambling authorisations issued by the authority

98 | P a g e The Gambling Act does not permit the authority to take into account whether a proposal is likely to be permitted in accordance with the law relating to planning or other consents when considering a premises licence application.

99 | P a g e 2. Gambling related harm

The evidence shows that certain people are more The Problem Gambling Severity vulnerable to gambling-related harm, including those with substance misuse problems, poor mental Index (PGSI) is a screening tool used to measure health, and those living in deprived areas.2 In the the severity of gambling problems in general community, the rate of problem gambling among population research, as opposed to the Diagnostic people with substance use disorders is nearly three and Statistical Manual of Mental Disorders (DSM-IV times that of people with no identifiable disorder3, and DSM-V) criteria used in clinical studies. The PGSI and in a substance misuse treatment sample, 13% denotes the most problematic gambling behaviour met problem gambling criteria.4 This compares to as “at risk”, whist the DSM-IV and DSM-V denote the between 0.6% and 1.1% of the general UK most problematic gambling behaviour as “problem population aged 16 and over.5 People with co- gambling”. Whilst there is a high degree of morbid gambling and substance misuse disorders correlation between the two, it should be noted that are less likely to they are different scoring systems and may not be directly comparable. achieve short-term abstinence from gambling.6 Whilst the evidence does not show that substance misuse causes problem gambling or vice-versa, it is clear that people with substance misuse problems are more vulnerable to problem gambling.

In their report about gambling behaviour in Great Britain using data combined from the Health Survey for England (HSE) 2015, and the Scottish Health Survey (SHeS) 2015 and the Wales Omnibus in 2015,7 Conolly and colleagues estimate that machines in bookmakers are played by 31.7% of at-risk gamblers (as defined by the Problem Gambling Severity Index), compared to 23.6% of low risk gamblers. Machines in bookmakers were the second most prevalent form of gambling among at-risk gamblers after online gambling on slots, casino or bingo games (Figure 1), although higher prevalence of use among at risk gamblers was seen in all forms of gambling. The authors note that those who gamble frequently tend to take part in multiple forms of gambling.

Figure 1 Prevalence of at-risk gambling behaviour by gambling activity, 2015

Source: Conolly and colleagues 2017

100 | P a g e It has been estimated that problem gambling affects up to six others, compared to one to three others for non-problem gambling. Those most often identified were close family members, including spouses and children, as the people impacted by others’ gambling problems.8

Whilst the gambling industry funds treatment services for problem gambling, including the National Gambling Helpline, counselling services, residential care facilities and an NHS clinic for those with more complex social or psychiatric presentations – only treat 8,000 clients, of whom 90% of problem gamblers.9 This represents treatment for fewer than 2% of problem gamblers.

3. Betting shops, adult gaming centres

There are currently 59 betting shops in Islington, is defined as gambling four adult gaming centres (one has separate Problem gambling licences for the ground floor and basement), and that disrupts or damages personal, family or recreational pursuits. About 9 people in every six sub-prime credit shops (that offer cheque 1,000 experience problem gambling, however, a cashing, pawnbroking, and/or pay day loans). further 70 people out of every 1,000 gamble at These are shown in the map in Figure 2. risky levels that can become a problem in the There is evidence of clustering of betting shops future. and/or adult gaming centres in Islington, with an Problem gamblers are more likely than other people to experience the following harms: average of 3.6 other betting shops within 500 metres of each . Financial harms: overdue utility bills; betting shop (range: 0 to 8). Clustering is borrowing from family friends and loan sharks; debts; pawning or selling particularly noticeable in the Nag’s Head area, but possessions; eviction or repossession; also Archway, Finsbury Park, and Caledonian Road. defaults; committing illegal acts like fraud, Each of these areas also has a sub-prime credit theft, embezzlement to finance gambling; shop, with an average of 5.5 betting shops within a bankruptcy; etc... 500m radius of each sub-prime credit shop (range: . Family harms: preoccupied with gambling so 2 to 9) Adult gaming centres are located in Nag’s normal family life becomes difficult; increased Head and Angel, with nine betting shops within a arguments over money and debts; emotional and physical abuse, neglect and violence 500 metre radius of each adult gaming centre in the towards spouse/partner and/or children; Nag’s Head area and four in the Angel area. These relationship problems and separation/divorce. are shown in Figure 2 alongside the Gambling Risk . Health harms: low self-esteem; stress- related Index for Islington. disorders; anxious, worried or mood swings; poor sleep and appetite; substance misuse; Noting that in England gambling provision has a depression, suicidal ideas and attempts; etc... distinct spatial pattern, with gambling venues . School/college/work harms: poor school, clustering in areas of greater deprivation Wardle college or work performance; increased and colleagues developed the Gambling Risk absenteeism; expulsion or dismissal Index.10 The Index is a geo-spatial model that includes local data on evidence-based risk factors Source: Royal College of Psychiatrists for

101 | P a g e problem gambling. The model includes the numbers of young people, those from minority ethnic groups, the unemployed, residents with certain mental health diagnoses, the location of substance abuse/misuse treatment centres, food banks, homelessness shelters, educational establishments and payday loan shops. Data are synthesised to produce a single, weighted risk index. The Gambling Risk Index was calculated for Islington using the same methodology. Clustering of betting shops may be considered particularly problematic from a health and wellbeing view due to the prevalence of fixed-odds betting terminals (FOBTs). FOBTs are electronic gaming machines that currently allow up to £100 to be gambled every 20 seconds. It has been recognised since at least 2003 that the proliferation of such machines risks seriously increasing problem gambling,11 and so the Gambling Act 2005 restricted the number of machines per gambling premises to four, reflecting the code of practice in place prior to the Act. Recently, in its submission to a review by the Department for Digital, Culture, Media and Sport, the Gambling Commission recommended reducing the maximum stake from £100 to £30. However, the Government announced in May 2018 that, subject to secondary legislation and parliamentary approval, the maximum stake for FOBTs is to be cut to £2.12 However, media reports suggest that legislation to reduce the maximum stake on FOBTs will not take effect until 2020.13

There is limited academic evidence for the role of FOBTs in problem gambling, reflecting that many problem gamblers gamble across a variety of platforms. Additionally, small sample sizes in studies has hindered statistical significance in many studies. One UK study of 736 problem gamblers found that gambling addiction severity was related to gambling involvement and, for a given level of gambling involvement, gambling addiction severity may vary according to gambling type, with a particularly significant increase for FOBT and gaming machine gambling.14 In another UK study with a smaller sample of 30 problem gamblers, the preferred form of gambling was FOBTs in some 60% of the sample.15

In 2013, the Responsible Gambling Strategy Board highlighted growing concern among people who use multiple venues:

(…) there is a growing group of gamblers participating in machines in bookmakers who might be more at risk of problem gambling given that age, gender and income are all correlated with problem gambling. In addition, the evidence points to a further high risk group of machine gamblers – multi-venue machine gamblers.11

In 2017, the Fixed Odds Betting Terminals All Party Parliamentary Group published their inquiry into FOBTs, including the key finding that:

There are many evident and growing problems associated with FOBTs. In addition to the link with FOBTs to problem gambling, wider gambling related harm and increased levels of crime, there is also evidence of greater bookmaker clustering in areas of higher social deprivation and potentially higher levels of vulnerability.11

A gambling industry commissioned evaluation of self-exclusion schemes found that one in 20 problem gamblers had breached their self-exclusion and gambled. Upholding the self- exclusions was heavily reliant on a member of staff in remembering individuals, and the volume of self-exclusions, most of which were FOBT related, with FOBTs often sited out of

102 | P a g e view, were seen as barriers to the effectiveness of the schemes (Chrysalis Research, 2017). An additional betting shop close to an existing premises with up to four additional FOBTs is therefore likely to weaken the effectiveness of self-exclusion schemes.

103 | P a g e Figure 2: Gambling premises and sub-prime credit premises in Islington, with the gambling risk index

Source: NOMIS (Census 2011 (youth, ethnicity), unemployment); DCLG (Index of multiple deprivation 2015); C&I GP Dataset 2012 (Prevalence of mental disorders); LBI planning (location of betting shops, adult gaming centres, and sub-prime credit); LBI licensing (location of betting shops and adult gaming centres); DfE (location of schools and colleges) LBI Housing (Homelessness/hostels); LBI Public Health (location of drug and alcohol services).

Contains OS data © Crown copyright and database right (2018)

104 | P a g e Betting shops and crime

When crime and gambling questions are asked in general population studies, a number of them have consistently shown that a small but significant minority of respondents get into criminal trouble because of their gambling whereas surveys specifically sampling problem gamblers show very high rates of reported involvement in crime. Furthermore, problem gamblers undergoing treatment typically report engaging in “white collar” crimes that tend to involve a breach of trust, whereas problem gamblers in prison are more likely to include those guilty of committing street crimes such as burglary, robbery, pimping, prostitution, selling drugs, and fencing stolen goods.16

In 2016, the Bishop of St Albans reported a freedom of information request to the Metropolitan Police which revealed Figure 3: Betting shops and crime, that between 2010/11 and 2015/16 there had been a 68% rise in 2015-2017 violent crime associated with betting shops across the capital 17 (837 violent crimes in 2015/16). An important point to note is that these crimes took place in betting shops, rather than crimes near to betting shops. Robberies taking place in betting shops increased by 17% (to 237) over the same period.18

During the three calendar years 2015, 2016 and 2017 there were 278 crimes reported where the location was marked betting shop (Table A3.1).

Criminal damage and violence against the person were the most common crime types in all three years. The number of crimes has remained constant over the three years. The highest number of crimes recorded in betting shops was in the Nag’s Head area, which accounted for 32% of betting shop crime but 8% to 10% of betting shops (Figure 3).

Table A3.1: Crime recorded at Islington betting shops, 2015, 2016 and 2017

Crime type 2015 2016 2017 Total Percentage Criminal Damage 33 35 28 96 35% Violence Against the Person 35 35 26 96 35% Theft and Handling 11 13 14 38 14% Burglary 3 0 5 8 3% Robbery 7 9 4 20 7% Other Crime 3 2 15 20 7% Total 92 94 92 278 100% Source: Safer Islington Partnership

105 | P a g e 4. Subprime credit and debt

Richardson et al.19 reviewed the relationship between personal unsecured debt and health. Overall results from a review of the relationship between unsecured debt and health suggest that unsecured debt increases the risk of poor health. Significant relationships were found between debt and physical and mental health. Some studies included in the review showed a dose–response effect with more severe debts being related to more severe health difficulties

Problem debt has been associated with a number of mental disorders, including depression, suicide and attempted suicide, problem drinking, drug dependence, neurotic disorders, and psychotic disorders. In terms of physical health, debt has been linked to, poorer self-rated physical health, long term illness or disability, chronic fatigue, back pain, higher levels of obesity, and worse health related quality of life.

A 2011 report for the Department of Health found that individuals who initially have no mental health problems but found themselves having unmanageable debts, had a 33% higher risk of developing depression and anxiety related problems within a 12-month period compared to the general population who do not experience financial problems.20 The Islington Debt Coalition is a partnership of local and national agencies led by The Competition and Markets Authority found in Islington Council to prevent residents getting into 2015 that 83% of payday loan customers had debt and to help those already in debt. It has taken out a loan online and 29% of customers had published a Directory of Debt and Money Advice taken out a payday loan on the high street. There Services for Islington Residents available at was some overlap, with 12% of customers having used both channels. The average amount lists/public- borrowed on the high street (£180) was lower records/communityandliving/information/factshee than that borrowed online (£290). Fewer high ts/20152016/20151216directoryofadviceservicesf street loans were repaid on time compared to orislingtonresidentsversion4dec2015 online loans. 76% of payday loan customers took out more than one loan in 2012. High street The coalition members are: borrowers typically had incomes below the UK average, whilst across all payday loans incomes were similar to the UK average. 21 There is a lack Age UK, Christians Against Poverty, Citizens Advice of published academic research on the Islington, Circle Housing, City and Islington College, association between unsecured debt and Cripplegate Foundation, Disability Action in Islington, gambling. The Campaign for Fairer Gambling Family Mosaic, Fair Finance, Fit Money, Help on Your commissioned a market research company to Doorstep, Hyde Housing Association, Job Centre Plus, survey betting shop users’ awareness, usage and Credit Union, Islington Council, Islington Housing attitudes towards betting shop services with a Association Group, Islington Law Centre, Islington particular focus on FOBTs.22 The survey found People’s Rights, Money Advice Service, that 32% of FOBT players had borrowed money to fund their gambling, with 45% borrowing from a payday loan company or pawnbroker, 68% from personal credit, and 79% from family and friends (the

106 | P a g e total is greater than 100% as some respondents borrowed from multiple sources. A greater proportion of respondents who borrowed money to gamble held attitudes indicative of problem gambling (such as chasing losses, worrying about expenditure on gambling, and gambling until all their money had gone) compared to those gamblers who did not borrow money. However, the proportion of borrowing from physical payday loan shops and those borrowing from online payday loan companies was not clear in the report. Gambling, along with mental health problems and substance misuse, was a factor leading to problematic spending and borrowing and prevented keeping on top of finances in Islington.23

The Camden and Islington Public Health Report in 2014, Widening the focus: tackling health inequalities in Camden and Islington24 makes recommendations to help reduce the health inequalities. One recommendation is that Camden and Islington should use their planning powers to support the development of ‘healthy high streets’. The report specifically suggests taking action to reduce the number of betting shops and payday loan establishments, to reduce debt.

The London Capital Credit Union is a not for profit savings and loans co- operative that encourages saving as a way of preventing debt. It also provides information and support to people who may struggle with debt. The low cost Saver Loans help reduce the cost of borrowing and provide a way of moving from being a borrower to being a saver.

Services are available to anyone living, working or studying in Islington, Haringey, Hackney, Camden, Barnet or the City of London and are equally available to those with a poor credit rating.

The Credit Union offers its members help with financial planning and the way to a debt free future.

This service can support clients with:

Debt advice and help with money Help with benefits or grants Advice about consumer law https://www.credit-union.coop/

5. Healthy streets

The London Assembly paper on Empty Shops on London’s High Streets25 considered the perception amongst many that certain uses, including betting shops, act to devalue the attractiveness of a high street as a destination and reducing its vitality and viability. It stated that one of the effects of clusters of betting shops is to reduce the offer of the centre by replicating a use. The research also found that a clustering of betting shops can increase the rents in town centres as national chains have the resources to pay higher rents.

For many people, the local high street still represents the heart of the community, serving important roles as places of social contact and interaction for diverse segments of the society; particularly for those who are less mobile and for whom local shopping plays a vital role as a regular (and sometimes their only) source of social contact.26 Such a role has a

107 | P a g e range of health benefits, including access to food, goods and services, reduced social isolation, and increased physical activity.

6. Conclusion

This document reviews the national and regional policy context, prevalence of problem gambling, the links between problem gambling and debt with poor health, and reviews the evidence base on betting shops and subprime loan shops and their impact on health.

The national and regional policy supports tackling gambling and debt through planning policy. The evidence highlights the need for local planning authorities to manage the overconcentration of gambling and sub- prime lending outlets as a means of combating their adverse impact on public health.

Based on then evidence, policies that resists overconcentration and the opening of betting shops, adult gaming centres and subprime lenders and requiring robust health impact assessments for applications of such uses near to sensitive community uses would be helpful in supporting programmes that aim to tackle problem gambling and debt among residents.

7. References

1 https://www.gov.uk/guidance/health-and-wellbeing

2 Wardle, H. et al. (2016). Exploring area-based vulnerability to gambling-related harm: Developing the gambling-related harm risk index. Bath, UK: Geofutures

3 el-Guebaly N et al. “Epidemiological associations between gambling behavior, substance use & mood and anxiety disorders,” Journal of Gambling Studies 2006;22(3)275–287

4 Langenbucher J. et al. Clinical features of pathological gambling in an addictions treatment cohort. Psychology of Addictive Behaviors 2001;15(1): 77–79 5 Conolly A et al. Gambling behaviour in Great Britain in 2015. NatCen, 2017

6 Hodgins DC and El-Guebaly N The influence of substance dependence and mood disorders on outcome from pathological gambling: five-year follow-up. Journal of Gambling Studies 2010;26(1) 117–127

7 Conolly A., Fuller E., Jones H., Maplethorpe N., Sondaal A. and Wardle H. Gambling behaviour in Great Britain in 2015. Evidence from England, Scotland and Wales. NatCen Social Research 2017. Available at http://www.gamblingcommission.gov.uk/PDF/survey-data/Gambling-behaviour-in-Great- Britain-2015.pdf [accessed 17th April 2017]

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9 Responsible Gambling Trust. Report and Financial Statements: 2016-17. Available from http://www.gamcare.org.uk/sites/default/files/file_attach/GamCare%20Annual%20Review%202016- 17.pdf [accessed 27th April 2018]

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111 | P a g e