Key Arguments Against the Application
The strongest evidence-based arguments to use when objecting to the Adult Gaming Centre premises licence application
These are the arguments that carry the most weight in the licensing process. Each one links directly to a recognised legal framework or evidence base that licensing officers and committee members are required to consider. All representations must be grounded in the licensing objectives of the Gambling Act 2005.
The Gambling Act 2005 Licensing Objectives
Every gambling premises licence must promote three statutory objectives. The Licensing Committee must assess whether granting this licence would undermine them. This application raises serious concerns on all three:
- Preventing gambling from being a source of crime or disorder: Adult Gaming Centres have a documented association with antisocial behaviour, petty crime, and disorder in the surrounding area, particularly during evening hours.
- Ensuring that gambling is conducted in a fair and open way: AGCs rely on category C and category D machines, which are designed to maximise play time and expenditure. There is no meaningful requirement for operators to ensure play is “fair” in any consumer-protection sense.
- Protecting children and other vulnerable persons from being harmed or exploited by gambling: This is the most directly relevant objective for this application. The proposed site is within 1km of multiple schools, family support services, and supported housing for adults with mental health needs (all shown on the risk map).
Proximity to Facilities
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The Local Area Risk Assessment (LARA) for this application lists facilities within 1km of the site. These include:
- Educational facilities including schools and a college
- Family support centres and employment services
- Supported housing for residents with complex needs
- Places of worship serving large congregations
- Multiple pubs and shops selling alcohol
This concentration of vulnerable users in the immediate vicinity makes this site particularly inappropriate for an AGC.
Crime
Crime levels are undeniably an issue in Ashford. The heatmap below shows recorded crimes by type across the LSOAs (small geographical chunks of the UK) that make up the Ashford area, covering April 2023–March 2026.
Spelthorne 003C is the LSOA that contains Church Road and the very centre of Ashford (source):
The area around Church Road (Spelthorne 003C) has the highest levels of shoplifting, public order offences, anti-social behaviour, and among the highest levels of violent and sexual offences in Ashford.
Use these arguments in your objection letter, or share this page with community groups preparing their own representations.