Item 7.11 - Spar - Health Board Letter of Objection Redacted
West Dunbartonshire Council · 16 June 2026
Back to Licensing Board — 16 June 2026 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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West Dunbartonshire Health & Social Care Partnership West Dunbartonshire Alcohol & Drug Partnership (ADP) Dumbarton Joint Hospital Cardross Road Dumbarton G82 5JA Tel: Date: 27th May 2026 Dat2026 Dear Clerk to the Licensing Board, LICENSING BOARD APPLICATION: 0327 Thank you for notification of the above application for a provisional premises licence in respect of Spar, 50 North Elgin Street, Clydebank, G81 1BZ. I, acting on behalf of West Dunbartonshire Alcohol and Drug Partnership (WDADP), have reviewed the application and the relevant evidence and object to the licence requested on the grounds that: • it is inconsistent with the licensing objective of Protecting and Improving Public Health; and • the application relates to premises located within a designated area of overprovision identified within the West Dunbartonshire Licensing Board Statement of Licensing Policy. The application relates to a proposed convenience store operating from a former community centre premises located within Intermediate Zone IZ01 Clydebank East including Whitecrook. The West Dunbartonshire Licensing Board Statement of Licensing Policy (November 2023) identifies IZ01 Clydebank East including Whitecrook as a designated area of overprovision. In reaching its Assessment of Overprovision, the Licensing Board assessed evidence relating to: • Alcohol Related Hospital Admissions;
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West Dunbartonshire Health & Social Care Partnership • Alcohol Related Death Rate; • Alcohol Related Mental Health; • the Scottish Index of Multiple Deprivation; • police incidents including assaults, domestic incidents, disorder and alcohol specific crimes; and • the number, capacity and licensed hours of licensed premises. At paragraph 29.11 of the Statement of Licensing Policy, the Licensing Board identified IZ01 Clydebank East including Whitecrook as an area of overprovision. Accordingly, there is a rebuttable presumption against the grant of further off-sales premises licences within that locality. The Licensing Board, in adopting its current Assessment of Overprovision, utilised alcohol-related health indicators for IZ01 Clydebank East including Whitecrook which demonstrate disproportionately high levels of alcohol- related harm both in comparison to the Scottish average and relative to other Intermediate Zones within West Dunbartonshire. Published data for the area includes: • Alcohol-related hospital admissions: 128.5 per 10,000 population compared to the Scottish average of 61.1, being more than double the national average and the second highest rate of all Intermediate Zones within West Dunbartonshire; • Alcohol-specific deaths: 15.8 per 10,000 population compared to the Scottish average of 5.8, being almost three times higher than the national average and among the highest rates recorded across West Dunbartonshire Intermediate Zones; and • Alcohol-related mental health admissions: 31.6 per 10,000 population compared to the Scottish average of 12.8, being almost two and a half times higher than the national average. These indicators are of particular concern within the wider context that West Dunbartonshire itself continues to experience some of the highest levels of alcohol-related mortality in Scotland, with the latest available national data demonstrating that the local authority has the fourth highest alcohol-specific mortality rate nationally1. 1 National Records of Scotland, Alcohol-specific deaths 2024 (23 September 2025), available at: National Records of Scotland – Alcohol-specific deaths 2024
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West Dunbartonshire Health & Social Care Partnership The relevant health indicator data is set out in Appendix 1. These indicators demonstrate a substantial and disproportionate burden of alcohol-related harm within the local area. The proposed alcohol display area is also substantial for a convenience-style premises and comparable in scale to alcohol display areas associated with significantly larger supermarket-format stores. The proposal seeks to introduce an additional alcohol outlet within a locality already identified by the Licensing Board as experiencing overprovision and significant alcohol-related health inequalities. The evidence available indicates that communities experiencing high levels of deprivation are disproportionately impacted by alcohol-related morbidity and mortality. The objection is not based on the proposition that alcohol-related harms can be attributed to any individual premises in isolation, but rather on the cumulative impact of additional alcohol availability within a locality already identified by the Licensing Board as experiencing overprovision and significant alcohol-related harm. In considering the licensing objectives, it is relevant that the locality continues to experience significant alcohol-related health inequalities and socioeconomic deprivation associated with increased alcohol-related harm. The West Dunbartonshire Alcohol and Drug Partnership has a strategic responsibility to reduce alcohol-related harm and health inequalities across West Dunbartonshire. The Partnership’s strategic priorities include prevention, early intervention, reducing alcohol-related deaths and hospital admissions, and addressing the impact of alcohol-related harm within communities. Relevant WDADP strategic documentation is attached at Appendix 2 for information. For the avoidance of doubt, this objection relates solely to the proposed sale of alcohol from the premises and the application of the licensing objectives and overprovision policy. It does not relate to the operation of the retail premises generally, nor to any potential employment or wider economic benefits associated with the proposed development. Having considered the application, the Licensing Board Statement of Licensing Policy, and the relevant public health evidence, I object to the grant of the provisional premises licence on behalf of West Dunbartonshire Alcohol and Drug Partnership on the basis that the application is inconsistent with the licensing objective of Protecting and Improving Public Health and relates to premises situated within a designated area of overprovision.
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West Dunbartonshire Health & Social Care Partnership In the circumstances, it is submitted that the application does not provide sufficient justification to depart from the presumption against grant created by the Board’s overprovision policy. Yours sincerely, Chris Kelly Strategy Officer West Dunbartonshire Alcohol and Drug Partnership Appendices Appendix 1 – Overprovision Evidence to the West Dunbartonshire Licensing Board from NHS Greater Glasgow and Clyde and West Dunbartonshire Health and Social Care Partnership Appendix 2 – West Dunbartonshire Alcohol and Drug Partnership Terms of Reference / Strategic Priorities