Item 5 - Statement of Licensing Policy – Overprovision – Evidence from NHS Greater Glasgow and Clyde and West Dunbartonshire HSCP

West Dunbartonshire Council · 9 May 2023
Back to Licensing Board — 9 May 2023 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

WEST DUNBARTONSHIRE LICENSING BOARD
Report by Clerk to the Licensing Board
9 May 2023
Subject: Statement of Licensing Policy – Overprovision – Evidence from  
NHS Greater Glasgow and Clyde and West Dunbartonshire HSCP
1 Purpose
1.1 To submit information detailing alcohol and public health statistics as
contained in the NHS Greater Glasgow and Clyde and West Dunbartonshire
Health and Social Care Partnership (“HSCP”) Overprovision Assessment
report as annexed at Appendix A; and
1.2 To submit information detailing the outcome of a public consultation on
alcohol consumption and purchasing habits in West Dunbartonshire as
carried out by the West Dunbartonshire HSCP as annexed at Appendix B.
2 Recommendations
2.1 It is recommended that the Licensing Board:-
(a) Notes the terms of the information submitted from NHS Greater
Glasgow and Clyde and West Dunbartonshire HSCP;
(b) Considers whether to request any further data or information from NHS
Greater Glasgow and Clyde and West Dunbartonshire HSCP and in
particular information relating to the impact of Minimum Unit Pricing on
the alcohol and public health statistics detailed in the Overprovision
Assessment report; and
(c) Hears from Doctor Daniel Carter, Consultant in Public Health Medicine,
in explanation of the aforementioned Overprovision Assessment report.
3 Background
3.1 At its meeting on 1 November 2022, the Licensing Board considered a report
from its Clerk outlining matters relating to the development of its Policy and
Assessment of Overprovision. It subsequently agreed to various actions
including requesting that West Dunbartonshire Alcohol Drug Partnership and

Page 2

the NHS Greater Glasgow and Clyde provide statistical evidence to inform its
considerations around Overprovision. 
3.2 As Members will be aware, Section 7 of the Licensing (Scotland) Act 2005
requires the Board’s Policy Statement to include a statement detailing the
extent to which the Licensing Board considers there to be overprovision of (a)
licensed premises; or (b) licensed premises of a particular description, in any
locality within the Board’s area (“Assessment of Overprovision”). 
3.3 In order to stand up to scrutiny, the Licensing Board’s Assessment of
Overprovision must be evidence based. When considering any evidence, the
Board must have due regard to the five licensing objectives: preventing crime
and disorder; securing public safety; preventing public nuisance; protecting
and improving public health; and protecting children and young persons from
harm.
3.4 The information provided by NHS Greater Glasgow and Clyde and West
Dunbartonshire HSCP relates to the licensing objectives of protecting and
improving public health and protecting children and young persons from harm.
4 Main issues
Information set out in the Overprovision Assessment report
4.1 The wide-ranging report from the NHS Greater Glasgow and Clyde and West
Dunbartonshire HSCP at Appendix A summarises the statistical information
obtained by the NHS Greater Glasgow and Clyde and its partners. The report
provides similar data to that which was provided to the Licensing Board in
2018. This data helpfully draws not only upon current local data but also sets
West Dunbartonshire’s position in a national context. 
4.2 Doctor Daniel Carter, Consultant in Public Health Medicine, will speak to the
report at the meeting.
4.3 The Overprovision Assessment report contains statistical information relating
to the overall position within West Dunbartonshire as well as information that
relates to specified intermediate data zones. 
4.4 This report highlights various statistics that will be of interest to Members and
the information set out here is intended to assist Members with a high level
overview of the report. For the avoidance of doubt, the Licensing Board will
consider the report in full when determining its Assessment of Overprovision.
4.5  Points of particular note are:

Page 3

• 85% of alcohol is sold in supermarkets and off-sales.
• The rate of alcohol-related hospital admissions in West Dunbartonshire
is higher than the Scottish average.
• In 2021, 40 alcohol specific deaths were recorded in West
Dunbartonshire.  This is the highest number of alcohol specific deaths
in the time period from 2010.  Alcohol specific death rates for West
Dunbartonshire remain higher than for Scotland as a whole.
• Female alcohol specific death rates are rising rapidly whilst the male
rate is in decline and is the lowest since 2002.
• Rates of alcohol related mental health hospital admissions are higher
than the Scottish average and have consistently been higher for the
available time period (2013-2022)
• The highest rates of alcohol ambulance calls are for males in the age
groups 35-44 and 55-64.
• The impact on children and families of non-dependent parental drinking
has been highlighted by research.  Locally, concerns about parental
alcohol abuse continue to be identified at a number of case
conferences for children on the child protection register.
4.6 The Overprovision Assessment report breaks alcohol harm data down by
intermediate data zones. These intermediate data zones are designated areas
used for the dissemination of statistics. There are 18 intermediate zones
within West Dunbartonshire. The population of these areas range from 3,464
to 7,162 persons. Members will be aware that the Licensing Board’s current
Overprovision Assessment makes use of intermediate data zones. 
4.7 The following information presented on an intermediate data zone level is of
particular note:
• Local Alcohol Related Hospital Admissions data shows that only three
intermediate zones of the 18 within West Dunbartonshire are lower
than the national average rate of 61.1 per 10,000 population in
2021/22.
• Local data in relation to Alcohol Specific Deaths in 2019/21 shows that
only seven of the 18 intermediate zones comprising West
Dunbartonshire are lower than the Scottish average of 5.8 deaths per
10,000 population. Further 10 intermediate zones have seen this
indicator increase since the start of the Licensing Board’s current
Statement of Licensing Policy.
• The data for 2021/22 shows that six West Dunbartonshire intermediate
zones had a lower rate of Alcohol Related Mental Health Admissions
than Scotland (12.8 per 10,000 population).

Page 4

• The data shows all intermediate zones within West Dunbartonshire
have residents living in the 40% most deprived Scottish Index of
Multiple Deprivation quintiles.
• An analysis of the three main alcohol related health indicators (Alcohol
Related Hospital Admissions, Alcohol Specific Deaths, and Alcohol
Related Mental Health Admissions) has been undertaken by
Intermediate Zone.  All Intermediate Zones have two or more indicators
worse than the Scottish average except for IZ05 (Goldenhill, Parkhall
North, East Kilbowie & Hardgate Central), IZ07 (Duntocher & Cochno),
and IZ09 (Old Kilpatrick).
Community Consultation on Alcohol 2022
4.8 The West Dunbartonshire HSCP carried out a public consultation on alcohol
consumption and purchasing habits between 15 November and 14 December
2022. Members should note that the consultation report details that the
findings presented provide context to other evidence that the Board will
consider. However the number of responses (224) “does not form a
representative sample for the population of West Dunbartonshire…In addition,
the self-selection sampling method may produce basis in findings.”
4.9 The report contains the following findings of particular note:
• 50% of respondents reporting drinking at home, 20% at a pub, bar or
nightclub, 16% report they do not drink alcohol and the remaining 14%
drink at a mix of family homes, restaurants and other venues.
• Over 79% of respondents report purchasing alcohol for consumption off
the premises.
• 52% of respondents travel more than five minutes but less than 15
minutes when purchasing alcohol, 31% report travelling less than five
minutes with 17% reporting that they travel for more than 15 minutes
when purchasing alcohol.
Next steps
4.10 The Licensing Board have received reports detailing further statistical
information received from Police Scotland and other partners as well as the
outcome of a pre-consultation survey with key stakeholders and a report from
the Licensing Forum. Having considered all this information, they will progress
with identifying a locality or localities where they consider there to be
overprovision and thereafter consult with the relevant parties.

Page 5

5 People Implications
5.1 The work involved in gathering evidence and preparing the Policy has
workload implications for the Board during 2023 but this can be
accommodated within existing staffing resources.
6 Financial and Procurement Implications
6.1 The Policy will allow applicants to assess whether there are sufficient
prospects of success should they proceed with an application. Therefore a
clear policy will assist applicants in avoiding unnecessary expenditure on
lodging and legal fees.
6.2 A Policy that is legally unsound or based on erroneous material is more likely
to be legally challenged. Such a challenge, should it be successful, will leave
the Board liable to possibly substantial legal fees. A well-evidenced Policy will
diminish the chances of a successful legal challenge.
7 Risk analysis
7.1 It is a legal requirement to adopt a new Policy. This requires to be done by
November 2023. Failure to do so would result in reputational loss for the
Licensing Board. Furthermore, the lack of a Policy could undermine the
Licensing Board’s ability to scrutinise applications.
8 Equalities Impact Assessment (EIA)
8.1 An EIA will be required for the new Policy.
9 Environmental Sustainability
9.1 The Environmental Assessment (Scotland) Act 2005 places a duty on the
Council to identify and assess the environmental consequences of its
proposals.
9.2 Under the provisions of the Local Government in Scotland Act 2003, the
Council has to discharge its duties in a way which contributes to the
achievement of sustainable development. In terms of the Climate Change Act,
the Council has a general duty to demonstrate its commitment to sustainability
and the community, environmental and economic impacts of its actions.
9.3 The information contained within this report has been considered under the
Act. However, no action is required as the Act does not apply to the matters
presented in this report.

Page 6

10 Consultation
10.1 The preparation of the Policy will be undertaken in consultation with the Local
Licensing Forum which will involve representatives from different parts of the
trade, community, police, health, young people etc. Community Planning
partners will be involved in preparation of the data and the Forum, Police,
licensed trade and Council will be asked for preliminary views on areas to be
reviewed. Thereafter there will be a full public consultation on either a
proposed Policy or Issues Paper by the middle of 2023.
11 Strategic Assessment
11.1 In terms of the Council's Strategic Priorities, the purpose of licensing is to
make sure our communities are resilient and thriving.
Alan Douglas
Clerk to the Licensing Board
20 April 2023
Person to Contact: Michael McDougall, Depute Clerk to the Licensing
Board, Regulatory and Regeneration, West
Dunbartonshire Council, Municipal Buildings,
Dumbarton G82 1NR 
e-mail: michael.mcdougall@west-
dunbarton.gov.uk
Appendices:
Background Papers: None
Wards Affected: All
Appendix 1: Overprovision Assessment
Appendix 2: Community Consultation of Alcohol 2022