Document Pack (Bookmarked) - Planning Committee 05 11 25
West Dunbartonshire Council · 5 November 2025
Back to Planning Committee — 5 November 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Agenda Planning Committee Date: Wednesday, 5 November 2025 ___________________________________________________________________ Time: 10.00 ___________________________________________________________________ Venue: Civic Space, Council Offices, 16 Church Street, Dumbarton G82 1QL ___________________________________________________________________ Contact: Nicola Moorcroft, Committee Officer Nicola.moorcroft@west-dunbarton.gov.uk Committee.admin@west-dunbarton.gov.uk Dear Member Please attend a meeting of the Planning Committee as detailed above. The business is shown on the attached agenda. Yours faithfully PETER HESSETT Chief Executive Page 1
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Distribution:- Provost Karen Murray Conaghan Councillor Lawrence O’Neill (Chair) Councillor Gurpreet Singh Johal (Vice Chair) Councillor Kevin Crawford Councillor Ian Dickson Councillor Fiona Hennebry Councillor Chris Pollock Councillor Lauren Oxley Councillor Hazel Sorrell Councillor Clare Steel All other Councillors for information Date of Issue: 23 October 2025 Page 2
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PLANNING COMMITTEE WEDNESDAY, 5 NOVEMBER 2025 AGENDA 1 APOLOGIES 2 DECLARATIONS OF INTEREST Members are invited to declare if they have an interest in any of the items of business on this agenda and the reasons for such declarations. 3 OPEN FORUM The Committee is asked to note that no open forum questions have been submitted by members of the public. 4 MINUTES OF PREVIOUS MEETING 5 - 6 Submit for approval, as a correct record, the Minutes of Meeting of the Planning Committee held on 8 October 2025. 5 PLANNING APPLICATIONS Submit report by the Planning, Building Standards and Environmental Health Manager, in respect of the following Planning applications:- (a) DC25/012/FUL: Construction of a new full-size 3G 7 - 18 synthetic pitch including drainage, floodlighting and fencing at Argyll Park, Argyle Street, Alexandria by West Dunbartonshire Council. (b) DC25/103/FUL: Removal of conservatory and garden shed, To Follow replace with single storey extension at 37 Islay Drive, Old Kilpatrick G60 5EP by Ms Fiona Hennebry. 6 SCOTTISH GOVERNMENT CONSULTATION ON 19 - 40 EXPANSION OF PERMITTED DEVELOPMENT RIGHTS Submit report by the Planning, Building Standards and Environmental Health Manager, seeking approval of the response to Scottish Government Consultation on Expansion of Permitted Development Rights. Page 3
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PLANNING COMMITTEE At a Meeting of the Planning Committee held in the Council Chambers, Clydebank Town Hall, 5 Hall Street, Clydebank, on Wednesday, 8 October 2025 at 10.00 a.m. Present: Provost Karen Murray Conaghan and Councillors Kevin Crawford, Ian Dickson, Fiona Hennebry, Lawrence O’Neill, Lauren Oxley, Chris Pollock and Clare Steel. Attending: Michael Mulgrew, Planning, Building Standards and Environmental Health Manager; James McColl, Development Management Team Leader; Wojciech Borowski, Planning Officer; Clare Laurenson, Principal Officer Development Planning and Place; Matthew Spurway, Development Planning and Place Officer; Chrstopher Anderson, Principal Solicitor and Section Head and Lynn Straker, Committee Officer. Apologies: Apologies for absence were intimated on behalf of Councillors Gurpreet Singh Johal and Hazel Sorrell. Councillor Lawrence O’Neill in the Chair DECLARATIONS OF INTEREST It was noted that there were no declarations of interest in any of the items of business on the agenda. OPEN FORUM The Committee noted that no open forum questions had been submitted by members of the public. MINUTES OF PREVIOUS MEETING The Minutes of Meeting of the Planning Committee held on 10 September 2025 were submitted and approved as a correct record. VARIATION IN ORDER OF BUSINESS Having heard Councillor Lawrence O’Neill, Chair, the Board agreed to vary the order of business as hereinafter minuted. ITEM 4 Page 5
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LOCAL PLACE PLAN VALIDATION – OLD KILPATRICK PLACE PLAN 2025 A report was submitted by the Planning, Building Standards and Environmental Health Manager, seeking approval to validate and register the Old Kilpatrick Place Plan 2025. After discussion and having heard the Development Planning and Place Officer and Councillor Lawrence O’Neill in further explanation and in answer to Members’ questions, the Committee agreed to approve the validation of the Old Kilpatrick Place Plan 2025, as set out in Appendix 1 of the report. PLANNING APPLICATION A report was submitted by the Planning, Building Standards and Environmental Health Manager, in respect of the following Planning application:- DC25/119/FUL: Application under Section 42 of the Town and Country Planning (Scotland) Act 1997 (as amended) for the variation of condition 12 of planning permission DC23/098/FUL to remove reference to "community" from allotments at St Joseph’s Primary School, Faifley Road, Faifley, Clydebank by West Dunbartonshire Council. After discussion and having heard the Planning, Building Standards and Environmental Health Manager and the Development Management Team Leader and Councillor Lawrence O’Neill in further explanation of the report and in answer to Members’ questions, the Committee agreed to continue the application to a future meeting of the Planning Committee, to allow further information to be gathered and consultation with Faifley Community Council to take place, before a decision is made. The meeting closed at 10.55 a.m. Page 6
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WEST DUNBARTONSHIRE COUNCIL Report by Planning, Building Standards and Environmental Health Manager Planning Committee: 5th November 2025 DC25/012/FUL: Construction of a new full-size 3G synthetic pitch including drainage, floodlighting & fencing at Argyll Park, Argyle Street, Alexandria by West Dunbartonshire Council. 1. REASON FOR REPORT 1.1 The application has been subject to a substantial body of objection. Under the terms of the approved Scheme of Delegation, it therefore requires to be determined by the Planning Committee. 2. RECOMMENDATION 2.1 Grant planning permission subject to the conditions set out in Section 9 below. 3. DEVELOPMENT DETAILS 3.1 The application relates to a site within Argyll Park which is located on Argyle Street in Alexandria. Argyll Park has a range of existing sports facilities including tennis courts, grass football pitches, a synthetic pitch, a bowling club, a changing pavilion and a play park. The application site itself is known as “pitch 1” and is located between the car park which is accessed from Heather Avenue and the existing synthetic pitch which was granted planning permission in 2015. 3.2 The proposed works include: The replacement of the existing grass pitch with a full-size 3G synthetic pitch measuring 97m by 56m with a 1.5m hardstanding spectator area. The erection of a 6-column LED floodlighting system measuring 15m in height. Drainage works. The erection of perimeter fencing measuring 3m in height and extending to 5m in heigh behind the goal ends. The erection of 3m high, solid acoustic fencing at goal ends. 3.3 The proposed hours of use contained within the Design and Access Statement are Monday to Sunday, 8am until 10pm. ITEM 5a Page 7
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4. CONSULTATIONS 4.1 West Dunbartonshire Council Roads Service No objections subject to conditions relating to mechanical road brush to be provided; no deliveries during the period of construction between 8.30am and 9.00am and 2.30pm and 3.30pm due to proximity to a school; and banksmen to be used for deliveries for ingress and egress. 4.2 West Dunbartonshire Council Environmental Health Service No objections subject to conditions relating to the hours of operation of the facility including the flood lighting, the acoustic fence, construction hours, vehicle delivery times during construction, contaminated land and dust. 4.3 West Dunbartonshire Council Roads Service (Flooding) No objections 5. REPRESENTATIONS 5.1 Six objections were received to the application. The detail of each objection is available for public viewing in the electronic planning file for the application. The concerns raised in the objections can be summarised as follows: Parking There is a parking issue, particularly when there are tournaments on. Flood Lighting The floodlight pitch is in operation until 10pm. The floodlights may shine into homes. Noise Balls hitting the fence is annoying. There is an existing 3G pitch with floodlights and associated noise, shouting, swearing and general anti-social behaviour. Another pitch would double the noise and anti-social behaviour. Other Concerns Queries relating to the number of trees to be felled Views will be of a fence rather than a park The park should be maintained for all rather than for footballers People are using the pitch without permission and children are there without supervision. 5.2 The points and concerns raised in the objections are considered in Section 7 below. Page 8
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6. ASSESSMENT AGAINST THE DEVELOPMENT PLAN National Planning Framework 4 (NPF4) 6.1 Policy 1 aims to tackle the climate and nature crises by requiring that significant weight be given to these issues when considering all development proposals. Policy 2 relates to the climate in the form of climate mitigation and adaptation, while Policy 3 seeks to protect biodiversity, reverse biodiversity loss, and deliver positive effects from development and strengthen nature networks. Overall, the proposal provides an improved sports facility, within a park which provides extensive sports and play facilities and as such is considered a sustainable location. No biodiversity matters arise. It is considered that the nature and scale of development proposal would have a neutral effect in respect of Policies 1, 2 and 3. 6.2 Policy 14 aims to promote and facilitate well designed development that makes successful places by taking a design-led approach and applying the place principle. Criterion (d) states that proposals which are detrimental to the amenity of the surrounding area or inconsistent with the six qualities of successful places will not be supported. Policy 15 relates to local living and 20-minute neighbourhoods and supports local access to sport and recreation facilities. The proposal complies with the above policies as the proposal will contribute towards local living without significant adverse effects on local amenity, this issue is discussed in detail in Section 7 below. 6.3 Policy 21 aims to encourage, promote and facilitate spaces and opportunities for play, recreation and sport. The proposal is for the enhancement of an existing sports facility and as such in in line with the aims of the policy. 6.4 Policy 23 aims to protect people and places from environmental harm and encourage, promote and facilitate development that improves health and wellbeing. Criterion (a) supports development proposals that will have positive effects on health, including proposals that incorporate opportunities for exercise. Criterion (e) advises that development proposals which are likely to raise unacceptable noise issues will not be supported. The proposal is considered acceptable with reference to this policy as, a sports facility will be provided, and no unacceptable noise issues are predicted to be created. This issue is discussed further in Section 7 below. 6.5 Having assessed the proposal with reference to NPF4, it is considered that the proposal accords with the policies, subject to conditions. West Dunbartonshire Adopted Local Plan 2010 6.6 Policy GD1 seeks to ensure that all new development enhances the Plan area and environmental quality in general through an emphasis on high quality design. Proposals are required to meet a number of criteria, including the need to be appropriate to the local area in terms of land use and layout and design; be energy efficient and meet the roads, parking and access requirements of the Council. It is considered that the development is appropriate for the location and in addition no objections from consultees have been received. This issue is discussed further in Section 7 below. Page 9
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6.7 The character and amenity of existing residential areas, identified on the Proposals Map, will be safeguarded and where possible enhanced in accordance with Policy H5. This includes proposals needing to reflect the character of the surrounding area in terms of scale, density, design and materials; the need to retain trees; and the requirement to avoid over development which would have an adverse effect on local amenity, access and parking or would be out of scale with surrounding buildings. As discussed below, it is considered that the development is appropriate for the location and in addition no objections from consultees have been received. 6.8 Policy E 1 relates the Council’s biodiversity duty. No biodiversity matters arise. 6.9 The site is located with an area identified as open space and as such, Policy R1 applies. Policy R1 states that developments on existing sports pitches shall not be redeveloped except in certain circumstances. This includes where the playing field which would be lost as a result of the proposed development would be replaced by a new playing field of comparable or greater benefit for sport and in a location which is convenient for its users or the upgrading of an existing playing field to provide a better quality facility, either within the same site or at another location which is convenient for its users and which maintains or improves the overall playing capacity in the area. Policy R3 relates to the enhancement of open space and sports facilities and supports the upgrade recreation facilities as and when resources allow. The proposal is for the existing pitch to be replaced with a synthetic, all-weather pitch with lighting which will increase the times which the facility can be used. As such the proposal is considered to be in accordance with the policies. 6.10 Policy F2 requires the drainage of development proposals to satisfy the principles of Sustainable Urban Drainage Systems (SUDS) and comply with the guidance in the “Sustainable Urban Drainage Systems (SUDS) Design Manual for Scotland and Northern Ireland” published by the Sustainable Urban Drainage Scottish Working Party. The proposal includes drainage and is considered to be acceptable. 6.11 Having assessed the proposal with reference to the adopted Local Plan, it is considered that the proposal accords with the policies, subject to conditions. 7. ASSESSMENT AGAINST MATERIAL CONSIDERATIONS West Dunbartonshire Local Plan (LDP2) Proposed Plan 7.1 On 15 March 2023, the Planning Committee took a decision that the Council would not adopt Local Development Plan 2. The Proposed Local Development Plan 2 (LDP2), incorporating the recommended modifications of the Examination Report received on 22 April 2020, which were accepted by the Planning Committee of 19 August 2020, remains the Council’s most up to date spatial strategy and is therefore afforded significant weight in the assessment and determination of planning applications, subject to compatibility with NPF4. The Scottish Ministers’ Direction relating to the adoption of LDP2, dated 18 December 2020, is also a material consideration. Page 10
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7.2 Policy CP1 requires new development to take a design-led approach to creating sustainable places, which put the needs of people first and demonstrates the six qualities of successful places. The proposal is considered to appropriately located and designed and as such is in accordance with the policy. 7.3 Policy H4 aims to protect, preserve and enhance the residential character and amenity of existing residential areas, including a presumption against the establishment of non-residential uses within, or in close proximity of residential areas, which would potentially be detrimental to local amenity, or which would cause unacceptable disturbance to local residents. Further to the detailed assessment set out below, it is considered that the proposal will not have a significant adverse effects on amenity. The proposal therefore complies with the above Policy. 7.4 Policy GI1 states that playing fields and sports pitches should not be developed upon apart from in certain circumstances. This includes where a new or upgraded playing field of comparable or greater benefit for sport is provided in a location which is convenient for its users and which maintains or improves the overall playing field capacity in the area. The new facility is to be provided on the site of the existing facility and as such is considered to be in accordance with the policy. 7.5 Policy ENV8 relates to light and noise. All development proposals shall incorporate design measures which minimise or reduce light pollution. All new development must also ensure that significant adverse noise impacts on surrounding properties and uses are avoided. Conditions are proposed which ensure the proposal is in accordance with the policy. 7.6 Having assessed the proposal with reference to the proposed Local Development Plan 2, it is considered that the proposal accords with the policies, subject to conditions. Principle of Development 7.7 The application site is located in an existing park with various other sports facilities surrounding. The area is identified in both the adopted Local Plan and the proposed Local Development Plan 2 as an area of open space. The proposal is to upgrade the existing sports facility from a grass pitch to a 3G synthetic pitch with associated fencing and floodlighting. The proposal to upgrade the sports facility maintains the open space and upgrades the existing sports provision. As such the proposal is in accordance with the policies relating to sports facilities and open space and is in principle acceptable in this location. Design, Appearance and Visual Amenity 7.8 The proposal is of a standard design for sports facilities of this type with the existing, adjacent synthetic pitch also having fencing and floodlights. The fencing around the existing pitch is 5m in height with 15m high floodlights. The current proposal includes fencing of differing heights and designs. At the goal ends there will be 5m high twin wire fencing as well as a 3m high, solid acoustic fence located just behind this. To the sides of the pitch, it is proposed to have 3m high twin wire fencing. Whilst the addition of a 3m high solid fence will have a visual impact on the park, it is considered that on balance the proposal is acceptable. Page 11
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This is due to the requirement of the acoustic fence in relation to noise and neighbouring properties. The 15m high floodlights will not be out of place within the park due to the existing floodlights being of the same height. Overall, it is considered that the design and appearance of the sports facility is acceptable within the park. Roads and parking 7.9 In considering the impact upon roads, traffic flow, parking and general road safety, the application site is situated within an existing park. There are a number of bus stops on Argyle Street, Govan Drive, North Main Street, Heather Avenue and Colquhoun Drive, with a number of bus routes serving the area. Balloch Train Station is an approximate 12-minute walk away also. There is an adjacent car park accessed from Heather Avenue. The assessment of roads and parking matters is principally guided by the consultation response from the Council’s Roads Service. The Council’s Roads Service provided no objection to the proposal subject to conditions to address a variety of matters during the construction phase of the development. These relate to a mechanical road brush being provided; no deliveries between 8.30am and 9.00am and 2.30pm and 3.30pm due to proximity to a school; and banksmen being used for delivery access and egress. No concerns have been raised in regard to traffic and parking issues and no conditions are recommended by Roads in respect of the operation of the completed development. As such, the proposal is not considered to have an adverse impact upon the traffic and parking of the town centre area. It is recommended that the granting of any permission includes conditions relating to delivery times during construction and the use banksmen. Residential Amenity 7.10 The proposal has residential properties located to the north on Argyle Street as well as to the south on Heather Avenue. It is accepted that any development project will generate an element of noise and activity during construction, and this cannot be a determining factor in the assessment of the application. However, subject to the conditions recommended by Environmental Health, including those in respect of construction hours and dust control, a suitable level of residential amenity will be maintained during the construction phase. Between the proposed facility and Argyle Street are other sports pitches and courts and between the residential properties on Heather Avenue and the proposal is a line of trees and a road. Whilst it is accepted that the proposed upgrade has the potential to cause noise, the noise impact assessment has concluded that subject to the installation of an acoustic fence no unacceptable noise disturbance will be created. The Council’s Environmental Health Service were consulted on the application and have no objections to the proposal subject to conditions. As such it is recommended that any granting of permission should include a condition to ensure the acoustic barrier is erected and maintained for the lifetime of the development. In addition, a condition is recommended in order to limit the times when the facility can be operated in order to protect residential amenity. There are conflicting details provided within the Noise Impact Assessment (NIA) and the Design Statement as to the proposed operational hours. Environmental Health have recommended that the hours proposed within the NIA be conditioned in order to protect residential amenity. Page 12
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7.11 The proposal also includes floodlights, and a Lighting Impact Report has been provided. Further to the consultation response from Environmental Health, it is recommended that any granting of permission also limit the hours in which floodlights can operate to be in line with the hours of operation for the facility in order to protect the neighbouring residential amenity from unacceptable impacts from light. Subject to condition, it is considered that the proposal would not have a significant adverse effect on residential amenity. Other Matters raised by Consultees 7.12 The Council’s Environmental Health Service were consulted on the application and had no objections to the proposal subject to conditions. Conditions relating to the hours of operation, the acoustic fence, construction hours, dust and vehicle delivery times are discussed above. The further conditions relate to contaminated land. As such it is recommended that any granting of permission should include such condition in order to protect public health and to ensure that the site is suitable for its intended use. Other Matters raised in representations 7.13 It has been queried how many trees are to be felled for the construction of the sports facility. The existing trees are shown as being retained on the General Arrangement Plan. A condition is recommended to ensure that the trees are protected during the construction phase of the development. 7.14 With respect to the outstanding issues raised in the representations and not already assessed above, views being altered has been highlighted. Private individuals do not have a right to a view and as such this is not a material consideration for the planning application. 7.15 Whilst 3G pitches can be used for a variety of sports including football, rugby, lacrosse and American football, the pitch proposed is arranged for football and 7v7 football. An objector has stated that the park should be maintained for all rather than footballers. There is a range of sports facilities available at Argyll Park and the policies do not limit facilities in accordance with the type of sport to be played. 7.16 Finally, concerns have been raised regarding the pitch being used without permission, users gaining access via climbing fences and children accessing the facility without supervision. Such matters cannot be controlled by the planning system and as such are not a consideration of the planning application. 8. CONCLUSION 8.1 Overall, the proposal for a full size, 3G pitch will provide opportunities for sport to be played during times of the year when inclement weather would deem the natural grass surface unplayable or dangerous. The application site is located within an existing park which is designated an open space within both the adopted Local Plan and Proposed Local Development Plan 2. The upgrade of the existing grass pitch to a synthetic pitch with associated fencing, drainage and floodlighting is supported in principle in such an area. Whilst the objections received are acknowledged, there are no material planning considerations that suggest that planning permission should be refused. Page 13
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Following consideration of the proposal and informed by the consultation responses from the Council’s Environmental Health Service and Roads Service, it is concluded that, subject to the conditions below, the proposal is in accordance with policies set out in National Planning Framework 4, the adopted Local Plan and proposed Local Development Plan 2. 9. CONDITIONS 1. Prior to the commencement of any works on site, full details of tree protection measures for all trees within or adjacent to the application site shall be submitted to and approved in writing by the Planning Authority. The approved measures shall be erected in accordance with British Standards Recommendations for trees in Relation to Construction, currently BS 5837:2012, to the satisfaction of the Planning Authority and not removed during the course of all works in both implementing the development hereby permitted and during the removal works. Reason: To ensure the retention of and avoidance of damage to trees during development and site reinstatement works. 2. Unless otherwise agreed in writing by the Planning Authority, the opening hours for the sports facility and the use of the associated floodlighting system approved by this application shall be as set out within the Adnitt Acoustics Scotland, First Issue Noise Impact Assessment (dated 29 August 2024): Mondays to Fridays: 0900-2200 Saturdays and Sundays: 0900-2100 Notwithstanding the above hours, all external lighting luminaries shall be turned off when the sports facility is not in use. Reason: To ensure that the development does not adversely affect the amenity of neighbouring properties by creating excessive noise. 3. Prior to commencement of the use, the acoustic barrier as detailed on plans “100 – General Arrangement” and “301 – Fencing Detail” shall be erected. The fence shall have a minimum mass of 10kg/m2 which can be certified for the lifetime of the barrier. The fence shall thereafter be maintained for the lifetime of the development to the satisfaction of the Planning Authority. Reason: To ensure that the development does not adversely affect the amenity of neighbouring properties by creating excessive noise. 4. During the period of construction, all works and ancillary operations (including deliveries) which are audible at the site boundary, shall be carried out between the following hours unless otherwise approved in writing by the Planning Authority: Mondays to Fridays: 0800-1800 Saturday: 0800-1300 Sundays and public holidays: No working Page 14
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Reason: To ensure that the development does not adversely affect the amenity of neighbouring properties by creating excessive noise and disturbance at unsocial hours. 5. Unless otherwise agreed in writing, during the period of construction, no commercial vehicle making deliveries to or collecting material from the development shall enter or leave the site: Before 08:00 Between 08:30 and 09:00 Between 14:30 and 16:30 or after 18:00. A banksman shall be used during the access and egress of all delivery vehicles, service vehicles and any other vehicles calling at the site. Reason: To minimise noise and disturbance to nearby residents at unsocial hours and due to the proximity to a school. 6. The presence of any previously unexpected contamination that becomes evident during the development of the site shall be reported to the Planning Authority in writing within one week, and work on the site shall cease. At this stage, if requested by the Planning Authority, an appropriate investigation and risk assessment shall be undertaken and a remediation strategy shall be submitted to and approved by the Planning Authority prior to the recommencement of site works. The approved details shall be implemented as approved. Reason: To protect public health and to ensure that the site is suitable for its intended use. 7. If there is a requirement to either re-use site won material or to import material then the assessment criteria and sampling frequency that would adequately demonstrate its suitability for use shall be submitted to and approved by the Planning Authority prior to any material being re-used or imported. In addition to this and in accordance with BS3882:2015 and BS8601:2013, material to be used in the top 300mm shall also be free from metals, plastic, wood, glass, tarmac, paper and odours. On completion of the works and at a time and or phasing agreed by the Planning Authority, the developer shall submit a verification report containing details of the source of the material and appropriate test results to demonstrate its suitability for use. Reason: To protect public health and to ensure that the site is suitable for its intended use. 8. Unless otherwise approved in writing by the Planning Authority, no development shall commence on site until such time as a scheme for the control and mitigation of dust has been submitted to and approved in writing by the Planning Authority. The scheme shall identify likely sources of dust arising from the development or its construction, and shall identify measures to prevent or limit the occurrence Page 15
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and impact of such dust. The approved scheme shall thereafter be implemented fully prior to any of the identified dust generating activities commencing on site and shall be maintained thereafter, unless otherwise approved by the Planning Authority. Reason: To minimise the occurrence of dust, in the interests of the amenity of the area. Michael Mulgrew Planning, Building Standards and Environmental Health Manager Date: 5th November 2025 Person to Contact: Michael Mulgrew, Planning, Building Standards and Environmental Health Manager Email: Michael.Mulgrew@west-dunbarton.gov.uk James McColl, Development Management Team Leader Email: James.McColl@west-dunbarton.gov.uk Appendix: Location Plan Background Papers: 1. Application forms and plans 2. Representations 3. Consultation responses 4. National Planning Framework 4 5. West Dunbartonshire Local Plan 2010 6. Proposed West Dunbartonshire Local Development Plan 2 2020, as amended Wards affected: Ward 1 (Lomond) Page 16
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¯ Scale: 1:2,500@A422/10/2025 ITEM 5a - APPENDIX 1 DC25/012/FUL - Map West Dunbartonshire Council 16 Church Street Dumbarton G82 1QL t and database right 22/10/2025.All rights reserved. West Dunbartonshire OS Licence Number 100020790. Reproduced by permission of Ord Survey on behalf of HMSO. ( Page 17C) Crown copyrigh
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WEST DUNBARTONSHIRE COUNCIL Report by the Planning, Building Standards and Environmental Health Manager Planning Committee: 5th November 2025 ___________________________________________________________________ Subject: Scottish Government Consultation on Expansion of Permitted Development Rights 1. Purpose 1.1 The purpose of this report is to seek formal committee approval of the response to the consultation. 2. Recommendation 2.1 It is recommended that Planning Committee agrees the response noted at Appendix 1 that was submitted to Scottish Government with the agreement of the Chair of the Planning Committee. 3. Background 3.1 The Scottish Government is consulting on proposed changes to Permitted Development Rights (PDR’s) to address the nationally declared housing emergency and to support the deployment of heat networks and domestic air source heat pumps. 3.2 The consultation can be grouped into 3 main areas: Rural homes Town Centre/Class 1A Increasing the scope of householder permitted development rights and renewables (including heat networks) 3.3 The consultation period (3rd September 2025 to 27th October 2025) clashed with committee deadlines for October Committee meeting and allowing sufficient officer time to review the consultation content. An extension to Friday 7th November to allow consideration at the Committee meeting on 5th November was sought, but this was declined by Scottish Government. The Planning, Building Standards and Environmental Health Service Manager expressed disappointment in this stance to Scottish Government officials. Scottish Government confirmed we could submit a response after the deadline but that they may not be able to take this into account as it would be a late response. 3.4 In this circumstance, officers are able to prepare a draft response and have that agreed by the Chair of the relevant committee and submit on that basis. The response is then formally ratified by the relevant committee at its next meeting. ITEM 6 Page 19
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3.5 Officers engaged with the Chair of Planning Committee on the consultation and the proposed response. The Chair agreed the response set out at Appendix 1 and this was submitted to the Scottish Government prior to the deadline. 4. Main Issues Summary of the proposed response 4.1 The full response to all questions is set out in Appendix 1, with the general position of the Council being that the Council supports the targeted expansion of PDR’s but stresses the need for appropriate controls to avoid unintended consequences, especially in unsustainable locations. Rural Homes . 4.2 The proposed response notes that within a West Dunbartonshire context we have not had any notifications under Classes 18B or 22A which allow the conversion of agricultural buildings/forestry buildings to residential use as we a primarily urban authority. 4.3 Whilst we would support small extensions to converted buildings, we do however express caution about increasing unit and floor space limits under these classes due to concerns around individual and cumulative impact on infrastructure and increasing housing development in potentially unsustainable locations distant from services. Similarly, we do not support expansion of new build homes via PDR in rural areas due to concerns around landscape impact, infrastructure, sustainability and impact on Green Belt. We consider that this type of development should still be assessed via the standard planning application process. Town Centre Living/Class 1A 4.4 The consultation is aimed at Town Centre living, however, it is difficult to restrict this due to varying definitions at a local level and no single agreed national definition. Such designations are noted in Local Development Plans and subject to change over time. The consultation therefore notes that any changes would apply to Class 1A units. Class 1A covers a broad range of uses such as shops, hairdressers, post officers, cold food shops, banks, estate agents and other services which is appropriate to provide in a shopping area and where the sale, display or service is principally to visiting members of the public. In this regard, whilst generally covering town and local centres, any changes would also apply to Class 1A units outwith these defined centres. The consultation does explicitly exclude areas such as covered shopping malls and retail parks. 4.5 The consultation seeks views on allowing ground floor Class 1A units and/or the upper floors of such units to be converted to residential use. The response Page 20
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notes that we would oppose the conversion of ground floor units due to the loss of active frontages and impacts on the viability and vitality of Town Centres. Such blanket use could result in a detriment of a Town Centre’s offer. We also express general placemaking concerns around amenity, parking and infrastructure etc. In relation to upper floors, the response is more supportive and in principle this could be achieved but the parameters of any permitted changes need to ensure that: They address amenity impacts from other uses, such as those that generate noise and odour. They should include minimum space standards to avoid substandard units. They ensure that separate access from ground floor commercial units to residential units are provided. Limits on unit numbers and parking impacts are considered. Short term lets and Houses in Multiple Occupancy are excluded from any proposed PDR. Flood risk and accessibility is considered. Covered shopping malls and retail parks are clearly excluded from PDR. 4.6 Development, as defined in section 26 of The Town and Country Planning (Scotland) Act 1997, requires planning consent. For an effective and proportionate planning system not all works meeting this definition require express planning consent from the relevant Planning Authority and a variety of Permitted Development Rights exist. Permitted Development is further split into 2 main methods. Permitted development can be unambiguous and clear on exact parameters (size, location etc) without the need for express planning consent. The other is known as Prior Notification/Prior Approval. This requires notification to the Planning Authority that works are to be carried out that is permitted development but often allows the Planning Authority to convert this to a Prior Approval on certain matters. It is not open to Planning Authorities to query the principle, but it does allow consideration of specific matters such as materials. The Prior Notification/Prior Approval route is generally not supported by Planning Authorities as these processes generally cause confusion for applicants, officers and communities due to their complexity and often narrow focus of what can be controlled. Due to their short timescale and limited fee, these types of application do not reflect the workload and complexity experienced by Planning Authorities. It is also important to note that this route, in the vast majority of circumstances, does not allow for notification or consultation by the Planning Authority to neighbours or consultees. This route also carries legal risk to the Planning Authority as, unlike a planning application, Prior Notifications have to be responded to no later than 28 days after their submission, otherwise deemed consent exists and the Planning Authority has no further control over the development. It is for these reasons that the response reinforces our view that we would not be supportive of any new Prior Notification/Prior Approval mechanisms and any changes should be unambiguous as to whether they are permitted development or require planning permission. Page 21
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4.7 Should the Scottish Government proceed with requiring Prior Notifications/Prior Approval, we seek to ensure appropriate matters are considered and that the fee and timescale to respond to these are substantially increased. For this reason, we do note that in that event, such a process would be no quicker than a traditional planning application. Increasing the scope of householder permitted development rights and renewables (including heat networks) 4.8 The response sets out that we are supportive of changes that may expand householder PDR to allow homeowners to make better use of their existing properties. Matters under consideration include: Increasing the maximum ground area covered by an extended building. Amending the external dimension restrictions, for example in Conservation Areas. Increasing the amount of side and rear curtilage that can be developed under PDR. Amending the PDR for alterations to roofs to allow greater use of loft space. 4.9 We also support clearer standards for Air Source Heat Pumps and the expansion of existing permissions to allow for 2 pumps on detached homes, subject to noise safeguards. We also set out that we are supportive of the view that Air Source Heat Pumps for heating and cooling but not solely cooling. 4.10 In relation to heat networks, we are supportive of measures to enable easier and more simpler connections, but we would seek there to be a clear exclusion or restriction in sensitive areas, such as Conservation Areas of sites of archaeological interest. Key summary of the response 4.11 West Dunbartonshire Council is supportive of Permitted Development expansion where it improves housing delivery, respects local context and infrastructure capacity, and maintains planning oversight where necessary. However, the Council urges caution that any PDR expansion has to avoid undermining strategic local and national planning goals, particularly in rural and town centre settings, and recommends robust safeguards to ensure quality, sustainability and overall community benefit. 5. People Implications 5.1 There are no people implications associated with this report. 6. Financial and Procurement Implications 6.1 There are no financial or procurement implications associated with this report. Page 22
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7. Risk Analysis 7.1 There is no financial, reputational or legal risk associated with this report. The Council is not statutorily required to respond to this Scottish Government consultation but will be bound by the outcome of the consultation and any resulting changes to Permitted Development Rights. 8. Equalities Impact Assessment (EIA) 8.1 Not required. 9. Consultation 9.1 This is a Scottish Government consultation seeking the views of all stakeholders. The Council has been consulted as Planning Authority and the Council is not required to consult with any other party to form its response. 9.2 As set out in section 3 of this report, officers consulted with the Chair of Planning Committee on the content of Appendix 1 that was submitted as the Council’s response to the consultation within the set deadline. 10. Strategic Assessment 10.1 The new Local Development is considered to be relevant to, and will help deliver, all of the Council’s strategic priorities: Our Communities – Resilient and Thriving Our Environment – A Greener Future Our Economy – Strong and Flourishing Our Council – Inclusive and Adaptable Michael Mulgrew Planning, Building Standards and Environmental Health Manager Date: 22 October 2025 ___________________________________________________________________ Person to Contact: Michael Mulgrew, Planning, Building Standards and Environmental Health Manager, Michael.mulgrew@west-dunbarton.gov.uk Appendices: Appendix 1 – Permitted Development Rights Consultation Response Background Papers: Permitted development rights to support provision of new homes - Scottish Government consultations - Citizen Space Wards Affected: All Page 23
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Permitted development rights to support the provision of new homes Respondent Information Form Please Note this form must be completed and returned with your response. To find out how we handle your personal data, please see our privacy policy: https://www.gov.scot/privacy/ Are you responding as an individual or an organisation? Individual X Organisation Full name or organisation’s name Phone number Address Postcode Email Address The Scottish Government would like your permission to publish your consultation response. Please indicate your publishing preference: x Publish response with name Publish response only (without name) Do not publish response We will share your response internally with other Scottish Government policy teams who may be addressing the issues you discuss. They may wish to contact you again in the future, but we require your permission to do so. Are you content for Scottish Government to contact you again in relation to this consultation exercise? x Yes No West Dunbartonshire Council 16 Church Street, Dumbarton G82 1QL Development.management@west- dunbarton.gov.uk Information for organisations: The option 'Publish response only (without name)’ is available for individual respondents only. If this option is selected, the organisation name will still be published. If you choose the option 'Do not publish response', your organisation name may still be listed as having responded to the consultation in, for example, the analysis report. ITEM 6 - APPENDIX 1 Page 24
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Questionnaire Question 1 Do you consider that the maximum limit in Classes 18B and 22A of five residential units per agricultural unit or forestry building should be changed? Yes No X Unsure Please explain your answer including (if appropriate) how you consider the limit should change. Question 2 Do you believe the current floor space maximum of 150 square metres in Classes 18B and 22A should be removed or increased? Yes No X Unsure Please explain how and why West Dunbartonshire is a small, urban planning authority and we have little practical experience in applying Classes 18B and 22A. In general, however, we have concerns that expansion beyond the current permitted five residential units would, in certain circumstances, result in small residential clusters being located in unsustainable locations, i.e. remote from local services. It is also likely to have implications for existing infrastructure provision, including roads, drainage and waste provision, due to the increased requirements of a residential use. As West Dunbartonshire has little practical experience in applying Classes 18B and 22A, we are content with the current limit and would express concern if it was to be increased and resulting implications on creation of larger units in unsustainable locations. Page 25
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Question 3 Do you believe that small extensions and/or separate buildings should be allowed as part of the conversion of an agricultural or forestry building to residential use under PDR? X Yes No Unsure Please explain your answer. Question 4 Do you consider that any of the current location-based restrictions in relation to Classes 18B and 22A should be removed and if so, which? Yes x No Unsure Please explain your answer. We would have no objection to allowing small scale extensions to buildings, subject to appropriate controls on size, However, it is considered unlikely that this would result in any significant uptake in the use of these PDRs due to the limited number of such buildings within West Dunbartonshire. The works permitted under Class 18B, including partial demolition of buildings, installation of utility infrastructure, changes to the external appearance of buildings and the provision of new vehicle access, have the potential to adversely affect the curtilage of a listed building, a site of archaeological interest and safety hazard areas. To ensure that these impacts are adequately assessed and mitigated through the planning application process, these location-based restrictions should be retained. As West Dumbartonshire does not include croft land or military explosives areas, we cannot comment on the appropriateness of these restrictions. Page 26
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Question 5 Do you consider the prior notification and approval mechanism (including the relevant matters and fee) associated with Classes 18B and 22A should be changed? x Yes No Unsure Please explain your answer. Question 6 Do you consider that PDR should allow the change of use of any other buildings on agricultural/forestry land to residential? If so, to which type(s) of building should the PDR be extended, and why? Yes No X Unsure Generally, the prior notification / prior approval processes are not favoured by Planning Authorities. This is a position we share and it is considered that the prior notification / prior approval process simply adds confusion for applicants, neighbours and planning officers. It is considered that for clarity for all stakeholders a development should either be permitted development (subject to appropriate constraints/restrictions) or require planning permission. If the prior notification / prior approval mechanism continues to be used, the timescale for considering such applications should be aligned with planning applications (i.e. 2 months). Fees will also require to reflect the staff time associated with such submissions, which can be similar to that associated with planning applications. A situation of a prior notification becoming a prior approval should allow further time for consideration and should not result in a situation where the prior approval essentially results in a defacto planning application, potentially for less fee but with the same work. and effort. If the considerations for a prior approval end up being similar to a planning application, no benefits arise and a planning application should simply be required. Page 27
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Please explain your answer Question 7 Do you consider that the PDR under Classes 18B or 22A should be expanded or revised in any other way? Yes x No Unsure Please explain your answer Question 8 Do you believe that there should be new PDR for the replacement of agricultural and forestry buildings with new-build homes in particular circumstances? If so, in what circumstances? Yes x No West Dunbartonshire Council do not have a view on this matter. No. Page 28
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Unsure Question 9 Do you believe that there should be new PDR for new-build homes in any particular types of rural areas in particular circumstances? If so, in what types of rural areas in what circumstances? Yes x No Unsure Please explain your answer Question 10 Do you consider that proposals to convert the ground floor or entirety of buildings in town and city centres to residential use should benefit from PDR? Yes x No Unsure We would not be supportive of allowing demolition and replacement of an existing agricultural or forestry building as permitted development as new build homes have the potential to significantly change the landscape and undermine the purpose of the Green Belt. The appropriateness of new build homes requires an assessment of the site context and the proposal, in terms of siting, design, layout, access and drainage etc. Given the numerous permutations of these elements, it would not be appropriate to apply a catch all approach like Permitted Development Rights to new build homes in these locations. The appropriateness of new build homes in any rural area requires an assessment of the site context, e.g. access, visual prominence and flood risk, and the proposal in terms of siting, design, layout, access and drainage etc. Given the numerous permutations of site context and design solutions, it would not be appropriate to apply a catch all approach like Permitted Development Rights to new build homes in any rural area. If such an approach was adopted, the prior notification/approval process would likely need to be extensive, which would negate the purpose of Permitted Development Rights. The provision of new homes via PDR would also make it difficult to plan infrastructure delivery. Page 29
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Please explain your answer Question 11 Do you consider that there should be PDR for the change of use of properties above Use Class 1A premises to residential use? x Yes No Unsure Please explain your answer Question 12 Do you have any comments about the prospect that the PDR would allow a change of use to residential from any existing use? The conversion of Class 1A uses at the ground floor level raises numerous concerns. It is acknowledged that with the change to shopping habits, town centres no longer have a monofunctional sole retail offering, and with the associated reduction in demand for traditional town centre retail (Class 1A) premises, the evolving nature of town centres will require to be carefully managed. However, permitted development rights (PDRs) allowing the conversion of ground floor premises into residential would raise significant concern in terms of the loss of active frontages, loss of vitality and also potential amenity issues which would undermine town centre placemaking. In particular, such conversions may result in residential properties fronting directly onto busy locations with no defendable space to the front of windows. Such an approach could also be contrary to established development plan policies which seek to safeguard the retail frontage within town centres. In locations outwith town centres, to which this proposed PDR would also apply, this may be acceptable on a case by case basis. As such, we do not feel it could be appropriately controlled by PDR and would require individual assessment. Upper floors which are redundant or disused currently offer no contribution to the wider town centre. While conversion to a residential use under PDR could, potentially, be supported, any PDR would require to consider how a range of issues are to be addressed. These include the impacts from existing established uses within the town centre on the residential amenity of new dwellings. For example, hot food takeaways within adjacent premises which predate any conversion to residential conversion and do not take account of residential property in their established operation, such as the mechanism for discharging cooking odours. Such conflict could adversely impact upon the operation of such established uses which in turn could have a negative effect on the vitality and viability of the town centre and amenity of its residents. We would further note the supportive policy position of NPF4 in relation to town centre living and consideration would need to be given in an PDR to those policy criteria. Should there be separate classes of PDR for class 1A premises themselves and for upper storeys above such premises? This is something that should be considered given the variety of different circumstances that may occur. For example, the conversion of premises within covered Malls should not be included within any PDRs, nor should any upper floor premises within such settings. Access to premises would also require to be considered. Upper premises would require a separate and self-contained access and it would not be desirable or appropriate to allow a situation where an upper floor being converted was accessed via a ground floor retail unit for example Page 30
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X Yes No Unsure Please explain your answer Question 13 Do you think PDR for the change of use of properties above Use Class 1A premises to residential use should include any limits on the minimum or maximum floorspace, size and/or number of residential units that can be formed? X Yes No Unsure While we would support the principle of allowing the conversion of any existing upper floor uses to residential, consideration should be given to the percentage of upper units that could be converted, in order to ensure an adequate supply for Class 1A uses. Consideration should also be given to what, if any, impacts the conversion of upper floor units may have on the operation of linked ground floor units. The concerns raised in relation to Q11 would also apply. Whilst it is not proposed that the increase in PDR in Scotland would be as extensive as in England, we would draw the Scottish Governments attention to research regarding the impact of extensive residential conversion PDR’s in England, such as https://www.ucl.ac.uk/bartlett/planning/sites/bartlett/files/tcpa_room_the_breathe_examples_ -_clifford_et_al.pdf , the Clifford_Post-retail high street - Submission draft for Built Environment Special Issue v3 clean.pdf,and the review of PDR to residential commissioned by MHCLG on the quality housing provided through permitted development and full planning permission. Page 31
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Please explain your answer and describe what you think the limits should be, if any Question 14 What other potential limits, restrictions and exclusions to such PDR should be considered? Question 15 Do you consider that a prior notification and approval mechanism should be required in respect of a PDR for ‘town centre living’ as discussed in the consultation? If yes, what matters do you consider should potentially be subject to prior approval? Yes X No Unsure There is a risk that PDRs could result in the creation of small, sub-standard flats and accordingly there would require to be a minimum floor space, or perhaps restrictions on the make-up of units to ensure that a situation of a high number of studio flats in a very dense arrangement is avoided as any balanced policy judgement would be removed from the decision making process. Limits on the number of units converted to residential may also be required to mitigate cumulative. Although it is acknowledged that a form of cumulative limit may be impossible to control when there are many different premises under different ownerships, we would encourage Scottish Government to investigate this matter. Concerns would arise in terms of parking, with potential pressure on infrastructure if there were suddenly a large number of residential properties created. This would be particularly acute if larger “family” sized flats were formed in a particular area together with a substantial loss of retail floorspace. The potential to use converted premises as short term lets would also require to be considered and this may be difficult to control without a STL control area. The potential interaction with HMO’s would also require to addressed and the use as HMOs would require to be restricted. Any PDRs should relate to mainstream houses and flats only. The conversion to residential would result in an increase in land use vulnerability in terms of flooding and PDRs could result in a significant increase in population at area at risk of flooding, thus potentially putting people at risk. Restrictions in this respect would be required. Additionally, restrictions on PDRs being available only within defined town and local centres as per Local Development Plans to ensure any new properties are within accessible areas and contribute to 20 minute neighbourhoods should be explored. Page 32
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Please explain your answer Generally, the prior notification / prior approval processes are not favoured by Planning Authorities. This is a position we share and it is considered that the prior notification / prior approval process simply adds confusion for applicants, neighbours and planning officers. It is considered that for clarity for all stakeholders a development should either be permitted development (subject to appropriate constraints/restrictions) or require planning permission. However, in order to negate many issues that could arise via the uncontrolled use of PDRs, it is accepted that some form of mechanism to control such changes may be required. This could ensure that the potentially significant impact upon town centres has an element of control, converted premises are in the correct location and no likely to be affected adversely be a variety of factors such as flooding, incompatibility with adjacent uses, incompatibility with 20 – minutes neighbourhoods etc. Such a process would allow the use of PDRs to be monitored and recorded and also to ensure that restrictions are being adhered to. If a prior notification / approval process was introduced, then given the potential complexities that could arise, the timescale for considering such applications should be aligned with planning applications (i.e. 2 months). Fees will require to reflect the staff time associated with such submissions which can be similar to that associated with planning applications. A situation of a prior notification becoming a prior approval should allow further time for consideration and should not result in a situation where the prior approval essentially results in a defacto planning application, potentially for less fee but with the same work and effort. If the considerations for a prior approval end up being similar to a planning application, no benefits arise and a planning application should simply be required. Question 16 Should any such PDR (permitting the change of use of floors above Use Class 1A premises) also permit certain external alterations of a building to facilitate the conversion to residential use, if so what alterations? X Yes No Unsure Please explain your answer Question 17 We would support the principle of minor external alterations that do not significantly alter the external appearance of the building. For example, controls mirroring the current restrictions within Conservation Areas. However, in any event, we would note that such alterations should be clearly defined and not left to interpretation. Page 33
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Please provide any other comments regarding the potential options to introduce PDR for ‘town centre living’ proposals as discussed in the consultation. Question 18 Do you consider that any expanded PDR for rural homes (described in chapter 2) should be subject to a condition prohibiting the use of the new units for short-term letting? X Yes No Unsure Please explain your answer Question 19 Do you consider that any ‘town centre living’ PDR (described in chapter 3) should be subject to a condition prohibiting the use of the new units for short-term letting? x Yes No Unsure Please explain your answer None. As the clear intention of any expanded PDR for rural homes would be to deliver new ‘homes’, and in the context of the declared local and national housing emergencies, we would consider it appropriate to attach a condition prohibiting short term let use, until such time that the latter is approved through a change of use permission. As the clear intention of any expanded PDR for town centre living would be to deliver ‘homes’, we would consider it appropriate to attach a condition prohibiting short term let use, until such time that the latter is approved through a change of use permission. We would also seek to clarify that reference to condition in this sense means as part of the criteria for the PDR itself and not something that would be required to be attached as planning condition on individual applications. Page 34
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Question 20 Do you consider that it would be appropriate to amend PDR for existing dwellinghouses, to allow homeowners to make better use of their existing properties? x Yes No Unsure Please explain your answer Question 21 Do you consider that the reference in the PDR for domestic air source heat pumps (ASHPs) should be revised to make it clear that the installation must comply with Microgeneration Certification Scheme (MCS) 020 a)? x Yes No Unsure Please explain your answer Question 22 Do you consider that air source heat pumps (ASHPs) installed on domestic properties under PDR should be permitted to be used for heating and cooling but not solely cooling? X Yes No Unsure The MCS includes noise thresholds for ASHPs which help safeguard residential amenity. Class 6H(3)(c) of the PDR, which currently requires ASHPs to comply with MCS Planning Standards for air source heat pumps or equivalent standards, should be revised to require compliance with the MCS only as it is widely accepted as being the industry standard and it is not clear what the equivalent standards are. West Dumbartonshire supports the principle of amending the PDR for existing dwellinghouses to allow homeowners to make better use of their existing properties. Page 35
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Please explain your answer Question 23 Do you consider that the PDR for domestic ASHPs in Scotland should be amended to allow for the installation of up to two ASHPs on a detached dwellinghouse? X Yes No Unsure Please explain your answer Question 24 Do you consider that proposals that would result in more than one ASHP being installed on flatted buildings or on terraced or semi-detached properties should continue to be assessed on a case-by-case basis by planning authorities? Yes No x Unsure Please explain your answer No objection. West Dunbartonshire Council would have no objection to this but advice should be taken to ensure that this does not give rise to amenity impacts from noise. There is insufficient information presented in the consultation paper to provide a firm view on this question. However, as distances between detached houses, semi- detached house and terraces can vary so a case by case basis would be appropriate. Page 36
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Question 25 Do you consider that any other changes should be made to the existing PDR for the installation of ASHPs in Scotland? Yes X No Unsure Please explain your answer Question 26 Do you consider that it would be appropriate to have PDR for the installation (and subsequent repair and maintenance) of connections from individual buildings to heat networks? Yes No X Unsure Please explain your answer Question 27 What are your views on the accuracy and scope of the environmental baseline set out in the environmental report? Whilst West Dunbartonshire Council can support this in principle, clearly defined parameters would need to be in place to ensure that Conservation Areas, sites or Archaeological interest etc would need to remain protected. Page 37
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Question 28 What are your views on the predicted environmental effects of the proposals as set out in the environmental report? Please give details of any additional relevant sources. Question 29 What are your views on the assessment of alternatives as set out in the environmental report? Question 30 What are your views on the proposals for mitigation, enhancement and monitoring of the environmental effects set out in the environmental report? Question 31 No Comment. No Comment. No Comment. No Comment. Page 38
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Please provide any comments on the partial Business and Regulatory Impact Assessment (BRIA) and information on the potential business or regulatory impacts of any of the options identified in this consultation. Question 32 Are you aware of any examples of how any of the options identified in this consultation may affect, either positively or negatively, those with protected characteristics? If yes, please provide further detail Question 33 Please provide any comments or information on the potential impacts on children’s rights and wellbeing of any of the options identified in this consultation Question 34 Do you have any information or comments on the potential impacts on island communities of any of the options identified in this consultation? No Comment. No Comment. No Comment. Page 39
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Question 35 Are you aware of any examples of potential impacts, either positive or negative, that the options identified in this consultation may have on groups or areas at socio-economic disadvantage (such as income, low wealth or area deprivation)? If yes, please provide further detail. Question 36 Do you agree that a Fairer Scotland Duty assessment is not required in relation to the options set out in this consultation? No Comment. No Comments. No Comments. Page 40