Document Pack (Bookmarked) Planning Committee 11 09 24
West Dunbartonshire Council · 11 September 2024
Back to Planning Committee — 11 September 2024 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
Agenda Planning Committee Date: Wednesday, 11 September 2024 ___________________________________________________________________ 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
Page 2
Distribution:- Councillor Lawrence O’Neill (Chair) Councillor Gurpreet Singh Johal (Vice Chair) Councillor Ian Dickson Councillor Daniel Lennie Councillor Douglas McAllister Councillor June McKay Provost Karen Murray Conaghan Councillor Chris Pollock Councillor Hazel Sorrell Councillor Sophie Traynor All other Councillors for information Date of Issue: 29 August 2024 Page 2
Page 3
PLANNING COMMITTEE WEDNESDAY, 11 SEPTEMBER 2024 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 - 15 Submit for approval, as a correct record, the Minutes of Meeting of the Planning Committee held on 7 August 2024. 5 NOTE OF VISITATIONS 17 Submit, for information, a Note of Site Visitations carried out on 5 August 2024. 6 PLANNING APPLICATION Submit reports by the Chief Officer – Regulatory and Regeneration in respect of the following Planning application:- DC23/086/FUL: (Continued item) Erection of new activity 19 - 34 centre incorporating a community hub and bicycle workshop, together with associated works at South Canal Bank, Sylvania Way, South Clydebank by West Dunbartonshire Council. 7/ Page 3
Page 4
7 PAY DAY LENDING AND BETTING SHOP 35 - 141 PLANNING GUIDANCE Submit report by the Chief Officer – Regulatory and Regeneration seeking approval of the finalised version of Pay Day Lending and Betting Offices Planning Guidance for use in making planning decisions. Page 4
Page 5
PLANNING COMMITTEE At a Meeting of the Planning Committee held in the Council Chambers, Clydebank Town Hall, 5 Hall Street, on Wednesday, 7 August 2024 at 10.00 a.m. Present: Provost Douglas McAllister and Councillors Ian Dickson, Gurpreet Singh Johal, Daniel Lennie, June McKay, Karen Murray Conaghan, Lawrence O’Neill, Chris Pollock, Hazel Sorrell and Sophie Traynor. Attending: James McColl, Development Management Team Leader; Amy Melkevik, Lead Planning Officer; Ash Hamilton, Planning Officer; Nigel Ettles, Principal Solicitor and Nicola Moorcroft, Committee Officer. Councillor Lawrence O’Neill in the Chair DECLARATIONS OF INTEREST Councillor Sophie Traynor declared an interest in item DC23/039/FUL: Installation of driveway (Retrospective) at 49 Briar Drive, Clydebank G81 3HT, by Mr Steven Messenger, the applicant being known personally by Councillor Traynor. Councillor Traynor left the meeting during consideration of this item. 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 5 June 2024 were submitted and approved as a correct record. NOTE OF VISITATIONS A Note of Visitations carried out on 3 June 2024, a copy of which forms Appendix 1 hereto, was submitted and noted. ITEM 4 Page 5
Page 6
PLANNING APPLICATIONS Reports were submitted by the Chief Officer – Regulatory and Regeneration in respect of the following Planning applications:- Having previously declared an interest in the following item, Councillor Traynor left the meeting at this point. (a) DC23/039/FUL (Continued item): Installation of driveway (Retrospective) at 49 Briar Drive, Clydebank G81 3HT by Mr Steven Messenger. Reference was made to a site visit which had been undertaken in respect of the above application. After discussion having heard the Development Management Team Leader and Raymond Walsh (WDC Roads and Transportation) in further explanation, and in answer to Members’ questions, the Committee agreed to refuse planning permission subject to the conditions set out in Section 9 of the report, as detailed within Appendix 2 hereto. Councillor Traynor rejoined the meeting at this point. (b) DC23/086/FUL (Continued item): Erection of new activity centre incorporating a community hub and bicycle workshop, together with associated works at South Canal Bank, Sylvania Way, South Clydebank by West Dunbartonshire Council. Reference was made to a site visit which had been undertaken in respect of the above application. After discussion having heard the Development Management Team Leader, in further explanation, and in answer to Members’ questions, the Committee agreed that this item be continued at a future meeting of the Planning Committee, with the applicant in attendance at that meeting to answer any questions Members may have. (c) DC22/245/FUL: Formation of a dwellinghouse with the re-establishment of the derelict Ferrydyke cottage into a family home, involving the renovation of the existing property inclusive of the construction of a dormer and extension to the rear together with associated works at Former Ferry Dyke Canal House, Portpatrick Road, Old Kilpatrick by Mr Farhat Malik. Reference was made to a site visit which had been undertaken in respect of the above application. The Development Management Team Leader was heard in further explanation, and in answer to Members’ questions. The Chair invited Mr John Foster, the Applicant’s Agent, to address the Committee. Mr Foster was heard in respect of the application and in answer to Members’ questions. Page 6
Page 7
The Chair invited Ms Isobel Plunkett (on behalf of Old Kilpatrick Community Council), to address the Committee. Ms Plunkett was heard in respect of the application. After discussion, Councillor Daniel Lennie, seconded by Councillor June McKay moved: that the Committee grant planning permission, subject to conditions and/or legal agreement, as appropriate, relating to onsite parking and a Green Space contribution from the developer. As an amendment, Councillor Lawrence O’Neill, seconded by Provost Douglas McAllister, moved: that the Committee refuse planning permission for the reasons set out in Section 9 of the report. On a vote being taken, 1 Member voted for the amendment and 9 Members voted for the motion, which was accordingly declared carried. ADJOURNMENT The Chair adjourned the meeting for a short recess. The meeting reconvened at 11.40 a.m. with the Elected Members listed in the sederunt present. (d) DC23/217/FUL: Erection of a Class 1A retail foodstore with associated access, car parking, landscaping and associated works at land to southeast of Castle Street, Dumbarton by Aldi Stores Ltd. Reference was made to a site visit which had been undertaken in respect of the above application. The Development Management Team Leader was heard in further explanation, and in answer to Members’ questions. The Chair invited Mr Andy Doyle, Applicant, to address the Committee. Mr Doyle was heard in respect of the application and in answer to Members’ questions. After discussion, the Committee agreed to the Committee agreed to grant planning permission subject to the conditions set out in Section 9 of the report, as detailed within Appendix 3 hereto, with an amended condition 4 as follows: that unless first agreed, in writing, by the Planning Authority, all recommendations set out within the Level 3 Flood Risk Assessment dated 5th April 2024, shall be incorporated into the development to the satisfaction of the Planning Authority. CONSULTATION ON SECTION 36 APPLICATION TO SCOTTISH GOVERNMENT ENERGY CONSENTS UNIT: DC23/223/S36 A report was submitted by the Chief Officer – Regulatory and Regeneration seeking a response to a consultation received from the Scottish Government Energy Page 7
Page 8
Consents Unit, on behalf of the Scottish Ministers, regarding a proposed wind farm development comprising up to ten wind turbines of approximately 7 megawatts (MW) each, with a maximum blade tip height of up to 250m, and Battery Energy Storage System (BESS) with a capacity up to 20 MW. After discussion and having heard the Development Management Team Leader in further explanation and in answer to Members’ questions, the Committee agreed to the position set out in Section 10 and to submitting the report to the Scottish Ministers, as presenting the Council’s full, formal response to the consultation advising of the Council’s objection. The meeting closed at 12. 25 p.m. Page 8
Page 9
APPENDIX 1 PLANNING COMMITTEE NOTE OF VISITATIONS – 3 JUNE 2024 Present: Councillors Karen Murray Conaghan, June McKay (first site visit only), Chris Pollock and Sophie Traynor (first site visit only). Attending: James McColl, Development Management Team Leader and Amy Melkevik, Lead Planning Officer. SITE VISITS Site visits were undertaken in connection with the undernoted planning applications:- South Bank of the Forth and Clyde Canal, Sylvania Way, South Clydebank DC23/086/FUL: Erection of new activity centre incorporating a community hub and bicycle workshop, together with associated works by West Dunbartonshire Council. 49 Briar Drive, Clydebank G81 3HT DC23/039/FUL: Installation of driveway (Retrospective) by Mr Steven Messenger. Page 9
Page 10
APPENDIX 2 DC23/039/FUL (Continued item): Installation of driveway (Retrospective) at 49 Briar Drive, Clydebank G81 3HT by Mr Steven Messenger. REFUSE full planning permission subject to the following conditions:- 1. The development does not provide sufficient depth in which to park a vehicle off street which will result in pedestrians and, in particular, wheelchair users and those with prams to be unable to use the public footway. As such the development is contrary to Policy 14 of NPF4, Policy GD1 of the adopted West Dunbartonshire Local Plan and Policy CP1 of the West Dunbartonshire Local Development Plan 2 which requires proposals to improve the quality of an area and to be supported by the six qualities of successful places. 2. The proposal is contrary to Policy 16 of NPF4, Policy H5 of the adopted West Dunbartonshire Local Plan and Policy H4 of the West Dunbartonshire Local Development Plan 2 due to the disruption to the residential amenity of the area resulting from the potential obstruction of the footway. 3. The proposal would potentially bring pedestrians and vehicles into conflict, to the detriment of road and pedestrian safety. Page 10
Page 11
APPENDIX 3 DC23/217/FUL: Erection of a Class 1A retail foodstore with associated access, car parking, landscaping and associated works at land to southeast of Castle Street, Dumbarton by Aldi Stores Ltd. GRANT full planning permission subject to the following conditions:- 1. Prior to the commencement of development on site, exact details and samples of all proposed external materials shall be submitted to and approved in writing by the Planning Authority. Thereafter, unless otherwise agreed in writing with the Planning Authority, the development shall be completed in strict accordance with the approved material details and palette unless otherwise first agreed in writing by the Planning Authority. 2. Prior to the commencement of development on site, full details of all hard surfaces shall be submitted for the further written approval of the Planning Authority. The development shall thereafter proceed in accordance with the approved details unless otherwise first agreed in writing by the Planning Authority. 3. Prior to the commencement of development on site, details of the design and location of all bin stores, cycle storage, street furniture, trolley parking and lighting shall be submitted for the further written approval of the Planning Authority and shall be implemented as approved. The development shall thereafter be completed in accordance with the approved details prior to any of the foodstore becoming operational unless otherwise first agreed in writing by the Planning Authority. 4. All recommendations set out within the Level 3 Flood Risk Assessment dated 5th April 2024 shall be incorporated into the development to the satisfaction of the Planning Authority. 5. Notwithstanding condition 4 above and prior to the commencement of development on site, full details of a flood mitigation and evacuation plan for the development shall be submitted for the written approval of the Planning Authority. Thereafter, the flood mitigation and evacuation plan shall be adhered to at all times, unless otherwise agreed with the Planning Authority. 6. The approved hard and soft landscaping and all associated approved planting details shall be implemented within a timescale to be agreed with the Planning Authority prior to the commencement of works on site. 7. Prior to the commencement or works on site and notwithstanding the approved plans, a detailed management and maintenance scheme for the proposed landscaping shall be submitted to and agreed in writing by the Planning Authority. For the avoidance of doubt, the scheme shall include a minimum of one clean out per year from October to January of the hereby Page 11
Page 12
proposed bird boxes and detailed of the maintenance of the wildflower areas. The plan shall thereafter implemented in perpetuity, unless otherwise agreed with the Planning Authority. 8. That any trees, shrubs or areas of grass which die, are removed, damaged or become diseased within five years of completion of the landscaping shall be replaced within the following year with others of a similar size and species. 9. Notwithstanding the approved plans, prior to the commencement of any works on site, full details of the incorporation of low and/or zero carbon technologies shall be submitted to and approved in writing by the Planning Authority. Thereafter the development shall be undertaken in accordance with the approved details unless otherwise first agreed in writing by the Planning Authority. 10. All recommendations within the Preliminary Ecological Appraisal dated October 2023 and hereby approved, shall be implemented in full to the satisfaction of the Planning Authority. 11. Notwithstanding condition 10 above, no works shall commence on site during the months of March to August (inclusive) until a full nesting bird survey is undertaken, the methodology and findings of which shall be submitted to and approved by the Planning Authority. For the avoidance of doubt, this survey shall be conducted within 48 hours of the commencement of any works. 12. Notwithstanding the approved plans, detail of access points for hedgehogs shall be included on any boundary fencing treatment, details of which shall be submitted to and approved in writing by the Planning Authority. Thereafter, the access points shall be maintained for the duration of the existence of the development. 13. Prior to the commencement of the hereby approved works, further survey shall be carried out to establish if the redshank bird species is present on site or in its vicinity. Thereafter, and notwithstanding the approved plans, details of screening of the site and any other appropriate mitigation measures during the works phase to avoid displacement of the redshank birds and any other relevant species of wild animals shall be submitted to and approved in writing by the Planning Authority. Thereafter, the approved screening shall be in place and maintained for the duration of the works. 14. Development shall not commence until a Bird Hazard Management Plan has been submitted to and approved in writing by the Planning Authority in consultation with Glasgow Airport. The submitted plan shall include details of: • Management of any flat / shallow pitched / green roofs on buildings within the site which may be attractive to nesting, roosting and ‘loafing’ birds. The management plan shall comply with Advice Note 8: “Potential Bird Hazards from Building Design”. Page 12
Page 13
• The Bird Hazard Management Plan shall be implemented as approved and on completion of the development shall remain in force for the lifetime of the development. No subsequent alterations to the plan are to take place unless first submitted to and approved in writing by the Planning Authority in consultation with Glasgow Airport. 15. All plant and equipment (including any ventilation system) to be installed or operated shall be enclosed, attenuated and/or maintained such that any noise therefrom shall not exceed International Standards Organisation (ISO) Noise Rating 35 between 0700 and 2300 hours daily, within any nearby residential property, with windows slightly open for ventilation, when measured and/or calculated and plotted on an ISO rating curve chart. 16. No commercial vehicle making deliveries to or collecting material from the development during construction shall enter or leave the site before 0800 or after 1800. 17. During the period of construction, all works and ancillary operations which are audible at the site boundary (or at such other place(s) as may first be agreed in writing with the Planning Authority), shall be carried out between the following hours unless otherwise approved in writing by the Planning Authority: • Mondays to Fridays: 0800 – 1800 • Saturdays: 0800 – 1300 • Sundays and public holidays: No working 18. No piling works shall be carried out until a method statement has been submitted to and approved in writing by the Planning Authority. This statement shall include an assessment of the impact of the piling on surrounding properties, taking into account the guidance contained in BS 6472: 1984 ‘Evaluation of Human Response to Vibration in Buildings’. It shall detail any procedures which are proposed to minimise the impact of noise and vibration on the occupants of surrounding properties. This statement shall be prepared by a suitably qualified person, and the piling works shall thereafter be carried out in accordance with the approved method statement. 19. No development (other than investigative works) shall commence on site until such time as a detailed remediation scheme for the site has been submitted to and approved in writing by the Planning Authority. The scheme shall be prepared by a suitably qualified person and shall detail the measures necessary to bring the site to a condition suitable for the intended use by removing unacceptable risks to human health, buildings and other property, and the natural and historical environment. The scheme shall include details of all works to be undertaken, the remediation objectives and criteria, a timetable of works and/or details of the phasing of works relative to the rest of the development, and site management procedures. The scheme shall ensure that upon completion of the remediation works the site will not qualify as contaminated land under Environmental Protection Act 1990 Part IIA in relation to the intended use of the land after remediation. Page 13
Page 14
20. 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 scheme 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. 21. 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 validation report containing details of the source of the material and associated test results to demonstrate its suitability for use. 22. 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 this 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 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 this Authority. 23. Prior to the commencement of development on site an air quality impact assessment in accordance with the Environmental Protection UK guidance document “Guidance on land - use planning and development control: Planning for air quality January 2017” shall be submitted to and approved by the Planning Authority. The findings of the assessment shall be implemented prior to the development commencing on site or within a timescale agreed by the Planning Authority. 24. Prior to the commencement of development on site, a Delivery Management Plan shall be submitted to and approved in writing by the Planning Authority. Deliveries to the foodstore shall only occur between the hours of 0700 hours and 2300 hours. All deliveries and other servicing of the site shall then be undertaken in accordance with the approved Delivery Management Plan at all times thereafter. 25. Notwithstanding the approved plans and prior to the commencement of development on site, final details of the foul and surface water drainage system shall be submitted for the written approval of the Planning Authority. The drainage system shall incorporate the principles of Sustainable Drainage Page 14
Page 15
Systems (SuDS) within its design, and thereafter shall be implemented prior to the occupation of the foodstore hereby permitted. 26. That all surface water shall be intercepted within the site both during construction and on completion of the development and full details of measures to ensure that surface water run-off is contained within the site shall be submitted to and approved in writing to the Planning Authority prior to the commencement of any works on site. The measures shall be implemented and maintained as approved. 27. The foodstore shall not be brought into use until the vehicle parking spaces associated with it have been provided within the site in accordance with the approved plans. The spaces shall thereafter be kept available for parking at all times. Page 15
Page 16
Page 16
Page 17
PLANNING COMMITTEE NOTE OF VISITATIONS – 5 AUGUST 2024 Present: Councillors Karen Murray Conaghan, Gurpreet Singh Johal (first two visits only), Lawrence O’Neill, Chris Pollock and Sophie Traynor. Attending: James McColl, Development Management Team Leader and Amy Melkevik, Lead Planning Officer. SITE VISITS Site visits were undertaken in connection with the undernoted planning applications:- Land to southeast of Castle Street, Dumbarton. DC23/217/FUL: Erection of a Class 1A retail food store with associated access, car parking, landscaping and associated works by Aldi Stores Ltd. Former Ferry Dyke Canal House, Portpatrick Road, Old Kilpatrick DC22/245/FUL: Formation of a dwellinghouse with the re-establishment of the derelict Ferrydyke cottage into a family home, involving the renovation of the existing property inclusive of the construction of a dormer and extension to the rear together with associated works by Mr Farhat Malik. Kilpatrick Hills, East of Alexandria DC23/223/S36: Consultation on section 36 application to Scottish government energy consents unit. ITEM 5 Page 17
Page 18
Page 18
Page 19
WEST DUNBARTONSHIRE COUNCIL Report by Planning, Building Standards and Environmental Health Manager Planning Committee: 11th September 2024 DC23/086/FUL: Erection of activity centre incorporating a community hub and bicycle workshop, together with associated work on land adjacent to the south bank of the Forth and Clyde Canal, Clydebank by West Dunbartonshire Council. 1. PURPOSE 1.1 To provide the Committee with the opportunity to further consider the planning application with the applicant in attendance for Members questions following continuation from August Planning Committee, and to seek the Committee’s decision on the application. 2. RECOMMENDATION 2.1 Grant planning permission subject to the conditions set out in Appendix 2. 3. BACKGROUND 3.1 The above planning application was to be considered by Planning Committee on 5th June 2024. Due to the relevant Officer from the Planning Service being unable to attend Committee, it was determined by the Planning Committee to continue the application without consideration, to allow for the relevant Officer to attend, present the application and answer Members questions. It was subsequently considered by Planning Committee on 7th August. Due to the applicant being unable to attend August Committee, it was determined to further continue the application to allow the applicant to attend and answer Members questions. 4. MAIN ISSUES 4.1 There are no material changes to the Development Plan position, the circumstances of the site, proposal or the assessment since August Committee. 4.2 It remains the case that the proposal is welcomed and would provide a high quality, community focused activity centre that would contribute to the ITEM 6 Page 19
Page 20
mix of uses and vitality of the Town Centre and help connect people with the canal, without any detrimental effects on local amenity. 4.3 The proposal presents no conflict with the policy requirements of NPF4, the adopted Local Plan, the proposed Local Development Plan 2 and associated Planning Guidance. 4.4 During consideration of the application at Committee on 7th August, Members raised questions relating to the possible retention and reuse of the existing granite features within the site and also the management of construction traffic during the development. Members were advised that additional conditions could be added to address these matters. Two additional planning conditions, relating to a Construction Traffic Management Plan and the retention and reuse of the granite feature seating, are therefore recommended in addition to those proposed in the Committee Report (05/06/2024), attached as Appendix 1. These conditions have been added to an updated listed of conditions, set out in the attached Appendix 2. 5. PEOPLE IMPLICATIONS 5.1 None. 6. FINANCIAL AND PROCUREMENT IMPLICATIONS 6.1 There are no financial or procurement implications in terms of this report. 7. RISK ANALYSIS 7.1 No risks have been identified. 8. EQUALITIES IMPACT ASSESSMENT (EIA) 8.1 Not required. 9. ENVIRONMENTAL SUSTAINABILITY 9.1 There are no environmental sustainability issues in terms of this report. 10. CONSULTATION 10.1 Consultation was undertaken as part of planning processes associated with the planning application. 11. STRATEGIC ASSESSMENT Page 20
Page 21
11.1 There are no strategic issues. Alan Douglas Chief Officer – Regulatory and Regeneration Date: 11th September 2024 Person to Contact: James McColl, Development Management Team Leader James.McColl@west-dunbarton.gov.uk Appendix 1: DC23/086/FUL Committee Report (05/06/2024) Appendix 2: Appendix 3: Updated Recommended Conditions Location Plan Wards affected: Ward 5 (Clydebank Central) Page 21
Page 22
WEST DUNBARTONSHIRE COUNCIL Report by Chief Officer – Regulatory and Regeneration Planning Committee: 5th June 2024 DC23/086/FUL: Erection of activity centre incorporating a community hub and bicycle workshop, together with associated work on land adjacent to the south bank of the Forth and Clyde Canal, Clydebank by West Dunbartonshire Council. 1. REASON FOR REPORT 1.1 The planning application raises issues that in the opinion of the appointed officer merits the determination of the application by Committee. 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 site relates to a 943sqm area of land located adjacent to the South Bank of the Forth and Clyde Canal and the NCR 7 cycle route, to the south of the Clyde Shopping Centre, Clydebank. The site is linear in form, slopes gently down from south to north, and is comprised of amenity grass and 8 trees, most of which are located along the northern extent. The site also includes 5 sculptured seating elements. Currently, the site functions as open space and is part of a wider area that forms the southern canal bank. 3.2 The site is situated within Clydebank Town Centre and surrounded by a mix of uses, with a church to the south, Clydebank Shopping Centre and amenity greenspace to the north, Clydebank Bandstand and South Sylvania Way to the west and a walkway and greenspace to the east. The site of the former Playdrome Leisure Centre, for which planning permission has been granted for a residential development, lies to the southeast. 3.3 Planning permission is sought for the development of an activity centre which includes a community hub and associated kitchen, launderette, coffee hatch, bicycle store, workshop and landscaping. It is indicated that the Community Hub will host a range of recreational and educational activities, such as yoga and cooking classes. The proposed modular building would have a footprint of 234sqm, being 6.7m D x 35m L, with the flat roof rising to a highest point of 3.85m and overhanging the building footprint by approximately 1.3m on the northern elevation to create a covered corridor (loggia). The building is comprised of two parts connected by a roofed external cycle storage area which can be closed off at the sides. A condenser store is located at the eastern end. All window openings are floor to ceiling, with five windows and a door proposed on the northern elevation, four windows on the southern elevation and one window on the western elevation, all of which would be fitted with folding security shutters. Two skylights are also proposed. ITEM 6 - APPENDIX 1 Page 22
Page 23
The building would be comprised of a polished pre-cast concrete base rising to a highest point of 1m, with the walls finished with a series of metal fins infilled with perforated 1.5m wide metal mesh panels. The windows would be comprised of aluminum with the door being metal. The walls, windows and door would be finished in a powder coated Green RAL 6003 colour. No information has been provided on the finish of the membrane roof. 3.4 With respect to the wider site, a hardstanding area is proposed within the northern half of the western extent, along with a gravel pathway along the eastern and southern elevations. A wild garden is further proposed adjacent to the southern elevation. 3.5 While the application indicates that there would be illuminated signage on the northern elevation, this will require to be assessed under a separate application for Advertisement Consent. 3.6 In support of the proposal, the applicant has submitted a range of documentation and information, including a Design Statement, Tree Report, and Preliminary Ecological Appraisal. 4. CONSULTATIONS 4.1 West Dunbartonshire Council Roads Service have no objection to the proposal in respect of roads and parking together with flooding matters. 4.2 West Dunbartonshire Council Environmental Health Service have no objection, subject to two conditions on construction and operating hours. 4.3 West Dunbartonshire Council Biodiversity Officer has no objection, subject to two conditions relating to landscaping and biodiversity enhancement. 4.4 Historic Environment Scotland had initially objected due to the potential impact upon the canal which is a scheduled monument, but following further consideration the objection was removed. 5. REPRESENTATIONS 5.1 None received. 6. ASSESSMENT AGAINST THE DEVELOPMENT PLAN National Planning Policy 4 6.1 Policy 1 relates to tackling the climate and nature crises and states that when considering all development proposals significant weight will be given to the global climate and nature crises. Policy 2 also relates to the climate in the form of climate mitigation and adaptation and states development proposals will be sited and designed to minimise lifecycle greenhouse gas emissions as far as possible and development proposals will be sited and designed to adapt to current and future risks from climate change. 6.2 Policy 3 seeks to protect biodiversity and deliver positive effects from development, requiring that local development includes appropriate measures to conserve, restore and enhance biodiversity. It is noted that measures should be proportionate to the nature and scale of development. Page 23
Page 24
6.3 Policy 6 aims to protect and expand forests, woodland and trees. It advises that proposals will not be supported where they result in the loss of ancient woodlands, ancient and veteran trees, or individual trees of high biodiversity value. Where woodland is removed, compensatory planting is expected to be delivered. 6.4 Policy 7 aims to protect and enhance historic environment assets and places, with proposals affecting scheduled monuments only supported where direct impacts on the integrity and setting of scheduled monuments are avoided or exceptional circumstances have been demonstrated to justify the impacts on the monument and any impacts have been minimised. 6.5 Policy 12 relates to waste and advises that development proposals will set out how much waste the proposal is expected to generate and how it will be managed. 6.6 Policy 13 supports proposals where they provide direct, easy, segregated and safe links to local facilities via walking, wheeling and cycling networks and are accessible by public transport. 6.7 Development proposals will be designed to improve the quality of an area whether in urban or rural locations and regardless of scale, as per Policy 14. Policy 15 relates to local living and 20 minute neighbourhoods, with development proposals required to contribute to both, where relevant, through local access to a wide range of facilities and activities, including lifelong learning and recreation facilities 6.8 Under part (f) of Policy 19, proposals for buildings that will be occupied by people will be supported where they are designed to promote sustainable temperature management, for example by prioritising natural or passive solutions such as siting, orientation, and materials. 6.9 Green infrastructure is considered through Policy 20. Proposals that result in fragmentation or net loss of existing green infrastructure will only be supported where it can be demonstrated that this would not result in or exacerbate a deficit in green infrastructure provision, and the overall integrity of the network will be maintained. 6.10 Policy 21 seeks to promote and facilitate spaces and opportunities for play, recreation and sport. It advises that development proposals likely to be occupied or used by children and young people will be supported where they incorporate well designed, good quality provision for play, recreation, and relaxation that is proportionate to the scale and nature of the development and existing provision in the area. 6.11 Policy 22 addresses flood risk and water management, stating that proposals will not increase the risk of surface water flooding to others, or itself be at risk; manage all rain and surface water through sustainable urban drainage systems (SUDS), and seek to minimise the area of impermeable surface. 6.12 Policy 23 aims to safeguard people from environmental harm and promote and facilitate development that improves health and wellbeing. Development proposals that will have positive effects on health will be supported. Policy 24 supports proposals that incorporate appropriate, universal, and future-proofed digital infrastructure. Page 24
Page 25
6.13 Policy 27 seeks to promote and facilitate development in our city and town centres, advising that proposals that enhance and improve the vitality and viability of city, town and local centres, including proposals that increase the mix of uses, will be supported. 6.14 The proposed development is supported by NPF4 and is assessed fully in Section 7 below. West Dunbartonshire Adopted Local Plan 2010 6.15 Policy GD1 seeks to ensure that all new development is of a high quality of design and respects the character and amenity of the local area. 6.16 Policy RET 5 advises that applications for non-retail uses within the designated town centres will be favourably considered where they contribute to the vitality and viability of the town centre and do not conflict with other Local Plan policies. 6.17 Policy R1 relates to the retention of existing open space. It includes a presumption against development which adversely affects the use, character or amenity of areas of functional and valued open space. Developments on existing open space will be considered against the existing or potential future use, quality, function and value of the open space and the sufficiency of provision of the facility type in the local area. 6.18 Policy T1 and T4 require sites to be integrated with sustainable travel. Policy E1 relates to the Council’s Biodiversity duty and Policy E5 requires new development proposals to consider impacts on trees and incorporate suitable tree planting. Policies F1 and F2 aim to ensure that new development is not at risk from, and does not increase the risk of flooding, and has suitable SUDS drainage infrastructure. Policy DC7 supports the inclusion of on-site micro-renewable technologies. 6.19 Policy BE 5 advises that the Council will resist any development proposals that would have an adverse impact on or affect the setting of a Scheduled Ancient Monument, unless a number of criteria are met. 6.20 Policy R 4 seeks to ensure that new development on or adjacent to the Forth and Clyde Canal is compatible and appropriate, with Policy R 4C encouraging recreational activities adjacent to the canal. Policy R 4F notes that development of canal-side sites should, wherever possible, be oriented towards and integrate with the canal, overlook the canal to provide a supervised edge and provide direct access to the existing canal side paths. 6.21 The proposal complies with the policies of the adopted local plan and is assessed fully in Section 7 below. 7. ASSESSMENT AGAINST MATERIAL CONSIDERATIONS West Dunbartonshire Local Development 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 25
Page 26
7.2 Policy CP1 seeks to ensure that development is of a high quality, adaptable and designed to be suitable for a mix of occupants. It indicates that all new development will be expected to contribute towards creating successful places by having regard to the six qualities of a successful place (distinctive, adaptable, resource efficient, easy to get to/move around, safe and pleasant, and welcoming). Policy CP2 requires the integration and consideration of green infrastructure from the outset of the design process through to its maintenance and stewardship of the resource. 7.3 Clydebank Policy 1 advises that the Council will encourage proposals adjacent to the Forth and Clyde Canal which introduce a mixture of uses associated with a leisure and evening economy, such as recreational activities. These uses will be supported where they will help to transform this area into a well-used multi-functional Town Centre that extends a range of activities into the evening and makes the Canal a focal point for activity, whilst also being complimentary to existing Town Centre uses. In line with this, the Clydebank Town Centre Development Strategy supports the transformation of the area around the Forth and Clyde Canal into a focal point and multi-functional area for recreation which connects people again with the Canal. Policy FCC1 advises that development alongside the Forth & Clyde Canal should enhance this green network asset. Development that would have an adverse impact on the canal or its setting will not be permitted. 7.4 Policy SC1 advises that proposals for retail, commercial and leisure investment, and other key Town Centre uses, should align with the sequential approach and the preferred uses set out in Table 5, which includes Class 11 – Assembly and Leisure. Developments are directed sequentially to Town Centres in the first instance. 7.5 Policy GI1 relates to open space and outdoor sports facilities. It advises that development which would result in the loss of open space which is, or has the potential to be, of quality and value will not be permitted unless provision of additional open space of equal or enhanced quality and value is provided. 7.6 Policy BE1 advises that where development would adversely affect a scheduled monument or the integrity of the setting of a scheduled monument, permission would only be granted in exceptional circumstances. 7.7 Policy CON4 sets out a need for all developments to install sufficient broadband provisions. 7.8 Policies ENV1, ENV4, ENV 5 and ENV6 are all similar to the ecology, tree, water environment and flooding policies of the adopted Local Plan. Policy ENV8 requires developments to address air quality, lighting and noise as part of the planning process. 7.9 Policy RE4 encourages micro-generation and heat recovery technologies within or associated with individual properties, with Policy RE5 advising that new buildings are required, as far as possible, to integrate low and/or zero carbon generating technologies. 7.10 It is considered that the application complies with the relevant policies above, as set out in the assessment below. Creating Places Planning Guidance and Green Network and Green Infrastructure Planning Guidance Page 26
Page 27
7.11 The Creating Places Guidance – November 2022 seeks to achieve high quality development with a design led approach based on a thorough appraisal of the site and an analysis of its context and sets out that this is expected for all development proposals. The Green Network and Green Infrastructure Guidance - November 2022 seeks to ensure that the proposal integrates landscaping and green infrastructure as part of the setting of the new development and open space created. This will include a focus on biodiversity enhancement. Following a full assessment, it is concluded that the proposal presents no conflict with the aims of the guidance. Principle of Development 7.12 While the application site is not allocated for a specific use in the Proposals Maps of the Local Plan and proposed LDP2, it is located in Clydebank Town Centre and subject to the policy requirements associated with this location. It is considered that a community focused Activity Hub located adjacent to the Canal would contribute to the provision of a mix of uses within the Town Centre, thereby improving the vitality and viability of the Centre. The proposed provision of recreational and educational opportunities would also promote lifelong learning, health and wellbeing and help create a multi-functional area that connects people with the Canal. In light of the above, the principle of development is supported by Policy 15, Policy 21, Policy 23 and Policy 27 of NPF4, Policy RET 5 and Policy R 4C of the Local Plan, and Clydebank Policy 1, Clydebank Town Centre Development Strategy and Policy SC1 of the proposed LDP2. 7.13 It is noted that the site, which is comprised of amenity grass, trees and sculptured seating, has value as open space. While it is not identified as open space in the Proposals Maps of the Local Plan and proposed LDP2, Policy R 1 and Policy GI1 of the respective Plans safeguard open space which is, or has the potential to be, of quality and value. Policy 20 of NPF4 advises that development proposals that result in the fragmentation or net loss of existing blue and green infrastructure will only be supported where it can be demonstrated that the proposal would not result in or exacerbate a deficit in blue or green infrastructure provision, and the overall integrity of the network will be maintained. With significant areas of similar amenity grassland located along the canal to the north and east of the application site, it is considered that the proposal, which would result in approximately a third of the existing open space being lost, would not result in or exacerbate a deficit in green infrastructure at this location. It is also considered that a proposal of this nature will enhance facilities at this location and compliment the wider areas of open and public space that form this part of the southern canal bank. In this context, the proposal complies with Policy 20 and is acceptable. Site Layout, Design and Appearance 7.14 New development requires to be well designed, take cognisance of the setting into which it is introduced and provide high quality, well designed buildings, whilst recognising the impact on existing neighbouring properties. 7.15 The 234sqm building footprint is appropriate relative to the 943sqm site size, with the single storey scale and linear form aligning with and complimenting the adjacent cycle path and Canal. The building would have a contemporary and attractive appearance, with the use of floor to ceiling windows/door, projecting fins infilled with perforated mesh panels and an overhanding roof providing a good degree visual diversity and interest. With the front elevation orientated towards the Canal, the proposal would also provide an active frontage that engages positively with the Canal. The proposed Green RAL 6003 colour finish would also blend in with the surrounding greenspace. Page 27
Page 28
While samples of the proposed materials and colour finish have not been provided in advance of the determination of the application, these can be secured through condition and subject to approval prior to the commencement of development. 7.16 It is noted that the application does not include information on the provision of low and/or zero carbon generating technologies, as required by Policy RE5. This matter can, however, be addressed through condition. 7.17 Overall, it is considered that the proposal would create a well-designed development that addresses the six qualities of successful places by having a distinctive identity, using high quality materials and being well connected and sustainable. As such, it complies with Policy 15 of the NPF4 and policies GD1, DS1 and CP1 of the adopted and proposed Plans, alongside the Creating Places Guidance (2022). Residential Amenity 7.18 The layout and scale of development proposed relative to the proximity of existing housing raises no concerns with respect to privacy, overshadowing or overbearing effects. While the development will undoubtedly bring additional activity to the area, it is unlikely to result in any noise or activity beyond that typically found in a Town Centre during the day. It is noted that the Activity Centre will not operate before 9am or beyond 8pm and a condition can be attached to secure these operating hours. Although it is accepted that the construction phase will produce an element of short term noise and disruption, the consultation response from the Council’s Environmental Health Service highlights the requirement for the construction of the development to be undertaken in a way that ensures that adjacent residential amenity is not adversely affected, which can be secured through condition. Trees, Open Space and Landscaping 7.19 While the submitted Tree Survey identifies eight trees on the site, comprising 2 Wild Cherry, 3 Norway Maple, 2 Callery Pear and 1 London Plane, it notes that there are no ancient or veteran trees on the site. Although six trees would need to be removed to accommodate the development, the proposal complies with Policy 20 and Policy ENV4 as no ancient or veteran trees or those covered by a TPO would be removed. It is noted that, following pre-application discussions, the applicant has included a wild garden as part of the landscaping in an effort to offset the loss of trees. 7.20 The proposal would provide approximately 630sqm of open space, comprised of hardstanding and grassed areas. While a detailed landscaping scheme has not been submitted, a gravel walkway is proposed adjacent to the eastern and southern elevations, along with a hardstanding area within the northwest extent and a wild garden adjacent to the southern elevation. The approach outlined is acceptable in principle and a detailed landscaping scheme can be secured through condition. Traffic, parking and road safety 7.21 The proposal raises no concerns with respect to traffic generation and road safety due to the scale and nature of the development and the excellent public transport and active travel connections associated with a Town Centre location. While no dedicated parking is proposed, it is considered that there is adequate parking within this Town Centre location. It is also noted that the consultation response from the Roads service raised no objection in relation to these issues. Transport and Connectivity 7.22 With the site being located in the Town Centre, it is accessible to a wide range of local services and within a 5 min walk of frequent public transport services to centres across West Dunbartonshire and beyond to Glasgow and Helensburgh. Page 28
Page 29
The site is also located adjacent to the NCR 7 cycle path. It is therefore concluded that the development is provided in an appropriate location within an established settlement accessible by means other than the private car. Flooding and Drainage 7.23 The proposal raises no concerns with respect to flooding as the site is not identified as being at risk on SEPA’s Flood Maps. The consultation response from the Council’s Flooding Officer also raised no objection. In relation to drainage, the application indicates that foul wastewater would be discharged to the public sewer, with surface water discharged to the canal. While no detailed information on drainage, including the use of SUDS, has been provided, this matter can be addressed through condition. The proposal is therefore acceptable, subject to condition. Ecology 7.24 The preliminary ecological appraisal submitted with the application found that the habitats on the site were of low conservation value, with no evidence of protected species and limited scope for nesting birds. The appraisal includes a number of recommendations, such the minimisation of light spill, which can be secured through condition. The Council’s Biodiversity Officer has no objection to the Preliminary Ecological Appraisal, but requests that a detailed Landscaping Scheme and Biodiversity Enhancement Plan be provided, which can again be secured through condition. Cultural Heritage 7.25 A large portion of the application site is located within the Forth and Clyde Canal Canal: Old Kilpatrick - Linnvale Scheduled Monument, which includes the canal, towpath and areas to either side in which traces of activities associated with its construction and use may survive. While Historic Environment Scotland initially objected to the proposal due to concerns about the potential adverse effects of the proposal, the objection was subsequently removed after discussions with the applicant. In light of this, the proposal is acceptable in this context. Waste Provision 7.26 The proposal is expected to generate a level of waste commensurate to a community facility of the scale proposed. A refuse store is proposed within the eastern corner of the building, which is acceptable. 8. CONCLUSION 8.1 The proposal is welcomed and would provide a high quality, community focused activity centre that would contribute to the mix of uses and vitality of the Town Centre and help connect people with the canal, without any detrimental effects on local amenity. 8.2 The proposal presents no conflict with the policy requirements of NPF4, the adopted Local Plan, the proposed Local Development Plan 2 and associated Planning Guidance. 9. CONDITIONS 1. Prior to the commencement of development on site, exact details and samples of all proposed external materials shall be submitted to and approved in writing by the Planning Authority. Thereafter, unless otherwise agreed in writing with the Planning Page 29
Page 30
Authority, the development shall be completed in strict accordance with the approved material details and palette. 2. Prior to the commencement of development on site, full details of all hard surfaces shall be submitted for the further written approval of the Planning Authority. The development shall thereafter proceed in accordance with the approved details. 3. Prior to the commencement of development on site, a detailed soft landscaping plan shall be submitted to and approved in writing by the Planning Authority. Thereafter, unless otherwise agreed in writing with the Planning Authority, the development shall be completed in strict accordance with the approved plan. 4. Prior to the commencement of development on site, a Biodiversity Enhancement Plan setting out how the proposal enhances biodiversity beyond the current baseline, together with the implementation on site, shall be submitted to and approved in writing by the Planning Authority. Thereafter, unless otherwise agreed in writing with the Planning Authority, the development shall be completed in accordance with the approved plan. 5. The approved hard and soft landscaping and all associated approved planting details shall be implemented within a timescale to be agreed with the Planning Authority prior to the commencement of works on site. 6. That any trees, shrubs or areas of grass which die, are removed, damaged or become diseased within five years of completion of the landscaping shall be replaced within the following year with others of a similar size and species. 7. All recommendations within the Preliminary Ecological Appraisal dated August 2022 and hereby approved, shall be implemented in full to the satisfaction of the Planning Authority. 8. That prior to the commencement of works on site, full details of the proposed drainage regime, inclusive of calculations and overland flow details, shall be submitted to and approved in writing by the Planning Authority. The drainage regime shall then be implemented and maintained as approved at all times thereafter. 9. That all surface water shall be intercepted within the site both during construction and on completion of the development and full details of measures to ensure that surface water run-off is contained within the site shall be submitted to and approved in writing to the Planning Authority prior to the commencement of any works on site. The measures shall be implemented and maintained as approved. 10. Prior to the operation of the Activity Centre, the developer shall install the necessary infrastructure to enable the development to be connected to the existing fibre optic network, where available in West Dunbartonshire, and in accordance with the relevant telecommunications provider’s standards. 11. Prior to the commencement of any works on site, full details of the incorporation of low and/or zero carbon technologies shall be submitted to and approved in writing by the Planning Authority. Thereafter the development shall be undertaken in accordance with the approved details. 12. The development hereby approved shall only operate between the hours of 9am- 8pm Mon-Fri, unless otherwise agreed in writing by the Planning Authority. Page 30
Page 31
13. During the period of construction, all works and ancillary operations which are audible at the site boundary (or at such other place(s) as may first be agreed in writing with the Planning Authority), shall be carried out between the following hours unless otherwise approved in writing by the Planning Authority: Mondays to Fridays: 0800 – 1800 Saturdays: 0800 – 1300 Sundays and public holidays: No Working Alan Douglas Chief Officer – Regulatory and Regeneration Date: 5th June 2024 Person to Contact: James McColl, Development Management Team Leader James.McColl@west-dunbarton.gov.uk Appendix: Location Plan Background Papers: 1. Application forms and plans 2. Consultation responses 3. National Planning Framework 4 4. West Dunbartonshire Local Plan 2010 5. Proposed West Dunbartonshire Local Development Plan 2 2020, as amended 6. ‘Green Network and Green Infrastructure’ Planning Guidance (2022) 7. Creating Places Planning Guidance (2022) Wards affected: Ward 5 (Clydebank Central) Page 31
Page 32
DC23/086/FUL: Erection of activity centre incorporating a community hub and bicycle workshop, together with associated work on land adjacent to the south bank of the Forth and Clyde Canal, Clydebank by West Dunbartonshire Council. UPDATED RECOMMENDED CONDITIONS 1. Prior to the commencement of development on site, exact details and samples of all proposed external materials shall be submitted to and approved in writing by the Planning Authority. Thereafter, unless otherwise agreed in writing with the Planning Authority, the development shall be completed in strict accordance with the approved material details and palette. 2. Prior to the commencement of development on site, full details of all hard surfaces shall be submitted for the further written approval of the Planning Authority. The development shall thereafter proceed in accordance with the approved details. 3. Prior to the commencement of development on site, a detailed soft landscaping plan shall be submitted to and approved in writing by the Planning Authority. Thereafter, unless otherwise agreed in writing with the Planning Authority, the development shall be completed in strict accordance with the approved plan. 4. Prior to the commencement of development on site, a Biodiversity Enhancement Plan setting out how the proposal enhances biodiversity beyond the current baseline, together with the implementation on site, shall be submitted to and approved in writing by the Planning Authority. Thereafter, unless otherwise agreed in writing with the Planning Authority, the development shall be completed in accordance with the approved plan. 5. The approved hard and soft landscaping and all associated approved planting details shall be implemented within a timescale to be agreed with the Planning Authority prior to the commencement of works on site. 6. That any trees, shrubs or areas of grass which die, are removed, damaged or become diseased within five years of completion of the landscaping shall be replaced within the following year with others of a similar size and species. 7. All recommendations within the Preliminary Ecological Appraisal dated August 2022 and hereby approved, shall be implemented in full to the satisfaction of the Planning Authority. 8. That prior to the commencement of works on site, full details of the proposed drainage regime, inclusive of calculations and overland flow details, shall be submitted to and approved in writing by the Planning Authority. The drainage regime shall then be implemented and maintained as approved at all times thereafter. 9. That all surface water shall be intercepted within the site both during construction and on completion of the development and full details of measures to ensure that surface water run-off is contained within the site shall be submitted to and approved in writing ITEM 6 - APPENDIX 2 Page 32
Page 33
to the Planning Authority prior to the commencement of any works on site. The measures shall be implemented and maintained as approved. 10. Prior to the operation of the Activity Centre, the developer shall install the necessary infrastructure to enable the development to be connected to the existing fibre optic network, where available in West Dunbartonshire, and in accordance with the relevant telecommunications provider’s standards. 11. Prior to the commencement of any works on site, full details of the incorporation of low and/or zero carbon technologies shall be submitted to and approved in writing by the Planning Authority. Thereafter the development shall be undertaken in accordance with the approved details. 12. The development hereby approved shall only operate between the hours of 9am-8pm Mon-Fri, unless otherwise agreed in writing by the Planning Authority. 13. During the period of construction, all works and ancillary operations which are audible at the site boundary (or at such other place(s) as may first be agreed in writing with the Planning Authority), shall be carried out between the following hours unless otherwise approved in writing by the Planning Authority: Mondays to Fridays: 0800 – 1800 Saturdays: 0800 – 1300 Sundays and public holidays: No Working 14. Prior to the commencement of development on site, a Construction Traffic Management Plan shall be submitted for the written approval of the Planning Authority. The Plan will thereafter be implemented as approved, unless otherwise agreed in writing by the Planning Authority. 15. That any existing granite feature/seating areas to be removed as part of the development will be retained and re-used within the site. Where it is demonstrated that these elements cannot be re-used within the site, they shall be re-used within the immediate local area. Prior to removal from site, the position of the re-used features shall be submitted to and agreed in writing by the Planning Authority, and works shall proceed as approved unless otherwise first agreed in writing by the Planning Authority. Page 33
Page 34
ITEM 6 - APPENDIX 3 Page 34
Page 35
WEST DUNBARTONSHIRE COUNCIL Report by Planning, Building Standards and Environmental Health Manager Planning Committee: 11 September 2024 Subject: Pay Day Lending and Betting Shop Planning Guidance 1 Purpose 1.1 The purpose of the report is to seek approval of the finalised version of Pay Day Lending and Betting Offices Planning Guidance for use in making planning decisions. 2. Recommendations 2.1 It is recommended that the Committee approves the finalised version of the Pay Day Lending and Betting Shops Guidance in Appendix 1. 3. Background 3.1 In 2016 the Council adopted guidance to control pay day lending and betting shops in town centres due to their number and concentration in specific locations. Research showed a majority of users of the town centres felt that too many of these uses in town centres, that they did not improve the vibrancy or vitality of the town center, and they had a negative impact on health and wellbeing. 3.2 The proposed 2020 Local Development Plan 2 (LDP2) indicates that the guidance should be updated to reflect new policy. Whilst LDP2 will not now be adopted and does not form part of the development plan, it is a material consideration in planning decisions, and it is the most up to date spatial strategy for the Council’s planning area. Additionally, the Fourth National Planning framework (NPF4) became part of the statutory development plan in February 2023. Policy 27 of NPF4 now includes provisions enabling planning authorities to refuse proposals for pay day lending and betting shops where it is considered further provision will undermine the character and amenity of the area or health and wellbeing of communities, particularly in disadvantaged areas, in Policy 27. 4. Main Issues 4.1 The Planning Committee approved a draft of the guidance for consultation at the meeting on 14th February 2024. The consultation took place between 13th May to the 5th July and was carried out by online survey. A final version of the guidance and background information with all changes reflecting comments received is contained in Appendix 1 and Appendix 2 respectively. Changes as a result of the consultation are underlined and deleted text is struck through. Page 1 ITEM 7 Page 35
Page 36
Appendix 3 contains the consultation report, detailing the responses received to the consultation. 4.2 The guidance sets limits on the number of pay day lending and betting shops allowable in town and local centres. It also highlights where there are known clusters of these uses where additional premises of this type would be detrimental to character, amenity and community health. 4.3 The consultation received 17 responses to the online survey. The majority of respondents agreed that the summary of evidence and local context within the guidance was clear and appropriate. One respondent stated that local centres should be considered as these are often nearer to where people live and more accessible than town centres. The Background Evidence and Guidance has been updated to provide more information on Betting Shops in local centres and elsewhere. 4.4 The majority agreed that a cap on the number of pay day lending and betting shops was appropriate. One respondent noted that the cap proposed on pay day lenders would mean none would be acceptable in Alexandria, as there are currently none at the moment. They noted that this would not be overprovision. 4.5 Most of respondents stated it was appropriate to expand the application of the guidance to whole town centre areas and all respondents agreed that the guidance should apply to Alexandria Town Centre. Respondents that disagreed stated that the scope of the guidance should be wider and cover all settlements with small centres. 4.6 All but one respondent agreed that the correct clusters had been identified within the guidance, but it was reiterated that all centers should be considered, and that there was a risk that restricting these uses in town centres would “push” them out to other locations. 4.7 The majority of respondents stated that the application of NPF4 Policy 27 and town centre policies from LDP2 were clear, however one respondent noted the difference terminology in LDP2 does not align with NPF4 policy wording. The concern being that this would affect the clarity of the guidance. The same results and comments were given regarding the application of LDP2 policy on Local Centres and Pay Day Lending and Betting Shops. 4.8 In other comments, one respondent noted that a particular betting shop operator had multiple establishments in Dumbarton and suggested one of their premises should be made to close. This is not possible through the planning system, which regulates the use of land and buildings, not the individuals or companies involved in the use. There would be nothing to prevent an operator closing and another operating moving into the same premises, making use of the existing planning permission. 4.9 Following the consultation the main changes to the guidance are Page 2Page 36
Page 37
Information on pay day lending and betting shops within local centres at Hardgate, Dalmuir, and Dumbarton East has been added. The number of betting offices in Clydebank in table 1 has been updated to reflect the number in the updated background information. Greater emphasis has been placed on National Planning Framework 4 as the most up to date part of the development plan in West Dunbartonshire. Amended the application of NPF4 Policy 27 to clarify that the cap on pay day lending and betting uses is a cap on both uses in combination. College Way has been removed from the description of the cluster in Dumbarton Town Centre, as one operator moved from here to the high street. Application of Policy SC4 for from Local Development Plan 2, relating to Local Centres, has been changed to place a cap on the number of pay day lending and betting shops that will be supported by the Council in Local Centres. Next steps 4.10 On approval by the Planning Committee the finalised version of the document will become a material consideration in planning decisions and will supersede the existing guidance. 5. People Implications 5.1 There are no people implications associated with this report. 6. Financial & Procurement Implications 6.1 There are no financial or procurement issues associated with this report. 7. Risk Analysis 7.1 Maintaining up-to-date Planning Guidance will help the Council to achieve the right type of development in the right place. In this case it will help to limit the number of pay day lending and betting shops in town and local centres, therefore limiting their impacts on health and wellbeing and town centre vitality. 8. Equalities Impact Assessment 8.1 The draft guidance document was subject to equality impact assessments. The proposed changes to the documents are not considered to amend the conclusions of this assessment, which are summarised below. The full assessment can be seen in Appendix 4. 8.2 Access to gambling opportunities increase the likelihood of problem gambling. Males between the ages of 16 and 20 are more likely to be problem gamblers. Page 3Page 37
Page 38
8.3 Betting shops tend to concentrate in more deprived areas and pay day loans are often used to bridge gaps between paychecks. This means that the negative effects on household finances wellbeing of debt and problem gambling disproportionately affect people in deprived areas. 8.4 It is expected that the restriction on number and clustering of pay day lending and betting shops will have a positive benefit on the wellbeing of users of town and local centres. It is accepted that there is an economic trade off as it restricts the uses that can take place within town and local centres. 9. Environmental Sustainability 9.1 A pre-screening has been submitted to the Scottish Government Strategic Environmental Assessment Gateway advising that it is considered that the guidance will have no or minimal effects on the environment. 10. Consultation 10.1 A questionnaire was sent out to the Citizens Panel to gauge attitudes on the number and clustering of pay day lending and betting shops, and their effect on town centre vitality and community wellbeing. 10.2 Consultation has been undertaken on the draft Planning Guidance documents as set out in paragraph 4.1 11. Strategic Assessment 11.1 The Pay Day Lending and Betting Shop Guidance will support the Council’s strategic priorities of ‘Our Communities – Resilient and Thriving. Michael Mulgrew Planning, Building Standards and Environmental Health Manager 11 September 2024 ________________________________________________________________ Person to Contact: Michael Mulgrew, Planning, Building Standards and Environmental Health Manager michael.mulgrew@west-dunbarton.gov.uk Cameron Clow, Development Planning & Place Officer cameron.clow@west-dunbarton.gov.uk Appendices: Appendix 1 – Pay Day Lending and Betting Shops Planning Guidance Page 4Page 38
Page 39
Appendix 2 – Pay Day Lending and Betting Shops Planning Guidance Background information Appendix 3 – Pay Day Lending and Betting Shops Planning Guidance Consultation Report Appendix 4 – Pay Day Lending and Betting Shops Planning Guidance Equalities Impact Assessment Background Papers: None Wards Affected: Ward 2: Leven Ward 3: Dumbarton Ward 4: Kilpatrick Ward 5: Clydebank Central Ward 6: Clydebank Waterfront Page 5Page 39
Page 40
Pay day lending and betting shops Planning Guidance ITEM 7 - APPENDIX 1 Page 40
Page 41
Introduction Health and wellbeing of communities is a consideration when making decision on planning and development in the high street. The Fourth National Planning Policy Framework (NPF4) changes the approach taken to development and uses within town centres, local centres and commercial areas, with a focus on health and wellbeing of the local community, particularly disadvantaged communities. This includes a greater ability to control the proliferation of uses that undermine the health and wellbeing of communities, including hot food takeaways, betting offices, and high interest money lending premises (also known as pay-day lenders). Concerns have been expressed by the Council and within the community about the overall number and clustering of pay day lending and betting shops in Clydebank and Dumbarton town centres in relation to impact on the character and amenity of town centres and the well- being of communities. The council has previously issued planning guidance to reduce the proliferation of these uses. This guidance updates the Council’s 2016 planning guidance for pay day lending and betting shops in town centres. It incorporates some evidence from the 2016 guidance, including citizens panel and focus group findings, as well as an updated citizens panel survey and literature review. Definitions This guidance relates to the offering of these services in premises. The Financial Conduct Authority’s definition states that a payday lender offers high cost short-term credit where: APR is equal to or higher than 100%; Credit is provided for any period up to12 months; Credit is not secured by a mortgage, charge or pledge. Betting is defined by the Gambling Act 2005 as the making or accepting of a bet on: the outcome of a race, competition or other event or process; the likelihood of anything occurring or not occurring; and whether anything is or is not true. Betting offices and pay day loan shops are classified as Sui Generis in the Town and Country Planning (Use Classes) (Scotland) Order 1997 as amended. Local Context This guidance is based on evidence collected in 2015 for the original version and additional evidence collected in 2023. The evidence is not detailed in this document but can be accessed on the council’s website. https://www.west-dunbarton.gov.uk/council/key-council-documents/local-development- planning/other-guidance-and-information/ Development Plan | West Dunbartonshire Council (west-dunbarton.gov.uk) In summary the background evidence identifies that: The socio-economic profile of West Dunbartonshire means that it is vulnerable to the ill-effects of gambling and high-interest short- term credit. There is already a significant presence of these uses in West Dunbartonshire, Page 41
Page 42
including a cluster of such uses in Clydebank town centre, on South Sylvania Way, and Dumbarton town centre, in and around the high street. There is evidence of a much higher betting shop licence/ population ratio than similar sized authoritiescouncil areas The majority of residents of West Dunbartonshire held negative views in respect of the contribution these uses make to the vitality and viability of the area’s town centres. The majority of users of each town centre consider that there are too many pay day lending and betting shops. Pay day lending uses do not contribute significantly to daytime footfall, and betting shops only make a limited contribution to evening footfall. Table 1 shows the current number of Pay Day Lending and Betting Offices in each town centre. Table 1: Number of Pay day Lending and Betting Offices in Town Centres Dumbarton Clydebank Alexandria Pay Day Lending 2 3 - Betting Office 3 23 3 Total 5 56 3 Table 2 shows the number of Betting shops in local centres. Table 2 Number of Betting Offices in Local Centres Betting Shops in Local Centres Dalmuir 2 Hardgate 2 Glasgow Road, Dumbarton 0 There are no pay day lenders within any of the Local Centres Planning Policy Context National Planning Framework 4 NPF4 is part of the statutory Development Plan and having been adopted by Scottish Ministers in January 2023 is the most recent part of the development plan in West Dunbartonshire. Policy 27 in NPF4 sets out the national approach to town, local and commercial centres and part C focusses on non-retail uses, stating: “Development proposals for non-retail uses will not be supported if further provision of these services will undermine the character and amenity of the area or the health and wellbeing of communities, particularly in disadvantaged areas. These uses include: i. Hot food takeaways, including permanently sited vans; ii. Betting offices; and iii. High interest money lending premises.” Proposed Local Development Plan 2 (as modified 2020) Page 42
Page 43
Proposed Local Development Plan 2 (as modified 2020) (LDP2) is a material consideration in the Council’s decision-making and the Council’s most up to date spatial strategy. The Network of Retail Centre Strategy is set out in Table 4 of LDP2 and defines the nature and function of town centres, local centres and commercial centres within West Dumbarton. These areas are defined on proposals maps. Policy SC1 sets out the sequential approach to local town and commercial centres, setting out the preferred locations to town centre retail, leisure and commercial uses. Policy SC2 Core Town Centre Areas supports, shops, professional services, food and drink uses, hotels and hostels, assembly and leisure, and public houses within the core town centre area. It also explicitly states that applications will be supported where they comply with the supplementary guidance on pay day lending and betting shops. The policy refers to table 5 which sets out appropriate uses within Town Centres and Core Town Centre Areas. Policy SC3 Other Town Centre Areas supports uses in other town centre areas that encourage visits to the town centre, including public service and leisure uses. The policy states that thethat the over-proliferation of one type of non-retail use, or proposals that would have a detrimental impact on the overall character and amenity of the area will not be supported by the Council. Policy SC4 Local Centres supports Class 1, Class 2, public houses, and hotels within local centres. It also states that non retail uses may be appropriate, however is dependent on the impact to the character of the local centre, the amenity of the surrounding area, in particular the proximity to homes and schools. LDP2 identifies 3 local centres: in Dalmuir along Dumbarton Road; in Hardgate at the roundabout where Glasgow Road meets Kilbowie Road; and in Dumbarton along Glasgow Road. Application of NPF4 Policy 27 part C Evidence identifies concentrations of pay day Llending and betting offices uses in Dumbarton and Clydebank Town Centres and concentrations of betting offices in Alexandria Town Centre. The evidence (survey and literature review) also identifies negative effects on health and wellbeing associated with these uses. Survey evidence identifies that these uses negatively impact the vibrancy and vitality of town centres. The Socio economic profile of West Dunbartonshire identifies that the area can be described as “disadvantaged”. Therefore, applications which increase number of these uses within any town centre beyond the numbers combined total for that town centre recorded in Table 1 will not be supported. Given that the majority view of local residents that there are “too many” of these premises, where new applications do not cause the number to exceed the current number in Table 1 consideration will be given to the existing number and concentration of these uses already in the town centre. When applying this policy to local centres, consideration will be given to the number pay day lending shops and betting offices within the centre at the time of the application.There are concerns that restricting these uses in town centres will “push” these uses out to local centres or other areas. To prevent overprovision and undesirable clustering in local centres no more than two pay day lending or betting offices (combined) will be supported. Page 43
Page 44
Application of Local Development Plan Policy SC2 Criteria and SC3 The council will also consider the additional criteria in Policy SC2 and SC3 of LDP2. Would the change significantly reduce the retail offer of the core retail area, or parts of it? Whilst this is a relevant consideration in any application for change of use from retail to a pay day lending or betting use, as it is about the loss of retail rather than what the unit is to become, there is no specific guidance to be offered. Would the change lead to the concentration of a particular use to the detriment of the town centre’s vitality and viability? Where the application would lead to concentrations of pay day lending and betting shops within close proximity of each other, where the Council considers there is already sufficient provision, or where their introduction would be to the detriment of shopping environment, no further uses of this type will be supported. Based on recent Town Centre Retail Surveys the following such areas are identified as existing clusters: The southern part of Clydebank town centre comprising Sylvania Way South and Chalmers Street; Dumbarton Town Centre comprising High Street, College Way and Riverside Lane Alexandria Town Centre As town centre uses and occupancy are dynamic, it is advised that for any application for pay day lending and betting shops, the current numbers of such uses within close vicinity of the application site are taken into account to understand if a new concentration of uses is arising. The evidence of the Council’s Citizen’s Panel survey and focus groups is that the majority of West Dunbartonshire residents feel that there are too many pay day lending and betting shops in town centres and very few felt that these uses contributed to the vitality/vibrancy of the town centres. There was majority concern about the clustering of these uses and a majority felt that more of these uses would have a detrimental effect on the vitality and vibrancy of the town centres. Would the proposed use contribute to the vibrancy of the town centre by increasing footfall? The evidence from the footfall survey is that pawnbrokers offering pay day lending services attracted very few customers in relation to other town centre uses. Therefore, pay day lending uses will not be supported on the basis that they will contribute to footfall and the vitality of the town centre. Over the course of a day, betting shops were found to attract a level of customers that compared well to other town centre uses. However, the evidence that they increased evening activity was mixed. Therefore betting shops will not be supported on the basis that they contribute to evening footfall and vitality. Are there other suitable locations in the town centre for the proposed use to locate? Local Development Plan 2 Policy SC3: ‘Other Town Centre Areas’ allows a full range of town centre uses, and other uses that would benefit the town centre, while also protecting against Page 44
Page 45
harmful concentrations of any particular use. The impact on community well-being may also be a relevant consideration in these areas and also within Local Centres. The council will consider applications in town centre or local centre locations which do not cause an increase to existing or new clustering of pay day lending and betting shop uses, provided the proposals do not cause a particular town centre to exceed the number of premises in the Table 1. Has the unit affected by the proposal been vacant and suitably marketed for retail use? The Council accepts that a vacant ground floor unit is a lost opportunity to generate additional activity and commerce within a town centre, and that generally speaking it is of greater benefit to have a unit occupied. However, it is the Council’s position that this should not be an overriding factor in any planning decision on change of use applications. In areas where there is already a cluster of betting and pay day lending shops or the number in back ground evidence Table 1would be exceeded the fact that a unit is vacant should be a lesser consideration. Application of Policy SC4 When considering applications for pay day lending shops or betting offices in Local Centres the Council will not support proposals that lead to overprovision or undesirable cluster of these uses, which affect amenity and character of the surrounding areaconsideration will be given to the number of these premises already within the Local Centre and the impact additional premises may have on the character of the surrounding area. In Local Centres where the application would lead to concentrations of pay day lending and betting shops within close proximity of each other, where the Council considers there is already sufficient provision, or where their introduction would negatively impact the character and amenity of the centre, no further uses of this type will be supported.Proposals increasing the combined number of pay day lending or betting shops beyond two will not be supported. Community well-being West Dunbartonshire is one of Scotland’s more deprived Council areas. Evidence has also been presented that there is a significantly higher number of betting shops per person in West Dunbartonshire than in other similar sized authorities suggesting a link between gambling and deprivation. The community have also raised significant concerns about the impact of pay day lending and gambling on community well-being. ThereforeTherefore, community well-being should be considered as a material consideration in the assessment of applications for pay day lending and betting shops, and that the evidence approved within this guidance should give weight to that consideration. Page 45
Page 46
This document is also available in other languages, large print and audio format on request. Arabic Hindi Punjabi Urdu Chinese (Cantonese) Polish British Sign Language BSL users can contact us via contactSCOTLAND-BSL, the on-line British Sign Language interpreting service. 01389 737527 West Dunbartonshire Council, 16 Church Street, Dumbarton, G82 1QL communications@west-dunbarton.gov.uk Page 46
Page 47
Pay day lending and betting shops Draft Planning Guidance Background Information ITEM 7 - APPENDIX 2 Page 47
Page 48
West Dunbartonshire: profile and vulnerability to gambling and high interest debt West Dunbartonshire is a mixed urban-rural area sitting in the north-west of the Glasgow city-region. In 2021, West Dunbartonshire’s population was officially estimated to be 87,800, the majority of which lived in the urban areas of Clydebank, Dumbarton and the Vale of Leven. The West Dunbartonshire Council planning authority area excludes that part of the Council area within the Loch Lomond and the Trossachs National Park i.e northern parts of Balloch and the rural area to the east and west of Loch Lomond. West Dunbartonshire’s three main town centres - Alexandria, Clydebank and Dumbarton - and the majority of the urban area sit within the Council planning authority area. Map 1: West Dunbartonshire Council and Planning Authority area On many measures, West Dunbartonshire can be identified as one of Scotland’s most deprived Council areas. In 2020, 48 of West Dunbartonshire’s 121 datazones (39.67%) were within Scotland’s 20% most deprived datazones, and 9 (7.44%) were within Scotland’s 5% most deprived datazones1. Table 1 provides further evidence that West Dunbartonshire compares 1 SIMD (Scottish Index of Multiple Deprivation) https://simd.scot/#/simd2020/BTTTFTT/9/-4.0000/55.9000/ Page 48
Page 49
poorly to the Scottish average when considering health, benefits and earnings data. Table 1: West Dunbartonshire/Scotland comparison of employment, benefits and earnings data Measure West Dunbartonshire Scotland Economically active % of residents aged 16 - 64 77.0% 77.2% Unemployment % of economically active residents 3.4% 3.4% Long-term sick % of economically inactive 41.6.7% 31.9% Earnings per residence per week £616.00 £640.03 Out-of-work benefits % of residents aged 16 - 64 claiming Job Seekers Allowance 2.1% 1.4% Benefit claimants % of residents aged 16 - 64 14.6% 10.2% Since 2016, when the pay day lending and betting shop guidance was first implemented, Economic activity and unemployment have improved in West Dunbartonshire to be on equivalent to the rest of Scotland. However, weekly earnings in the area are still lower than Scotland as a whole, and a greater number of people claim benefits. A higher proportion of those who are economically inactive due to long term illness, which is more than scotland as a whole. Commissioned by the Responsible Gambling Fund, research prepared by Geofutures and the National Centre for Social Research2 investigated relationships between the location of gambling machines and the socio-demographic and economic environment in which they are situated. The research found that areas with a high density of fixed odds betting terminals tend to have poorer socio-economic indicators. The report identifies Clydebank as being a High Density Machine Zone - an area where there is a high density of gambling machines. It finds that areas of high machine density tend to have poorer socio-economic indicators, with a higher proportion being low income areas and a higher proportion of residents being economically inactive. Of those who are economically active, a greater number active are in the lowest socio-economic sub-groups. Table 2 provides evidence of this showing that West Dunbartonshire has a higher number of betting shop licences per person than other local authorities with a similar population, but which do not have as high a proportion of data zones within the 20% most deprived 2 2Wardle H., Keily R., Thurstain-Goodwin M. and Astbury G. 2011. Mapping the social and economic characteristics of high density gambling machine locations. National Centre for Social Research and Geofutures Ltd. Page 49
Page 50
Table 2: Local Authority population and betting shop licence comparison3 Local authority area Population Betting shop licences Persons per licence East Renfrewshire Council 96,600 10 9660 Midlothian Council 94,700 5 18940 Stirling Council 93,500 9 10389 West Dunbartonshire Council 87,800 19 4621 Argyll and Bute Council 86,200 5 17240 Since 2016 the number of betting shop licences has decreased across all the authorities in Table 2. However, West Dunbartonshire still has a significantly higher level of betting office licences than authorities of a similar population size. 3 Betting shop licence figures derived from www.stopthefobts.org, January 2023. Original source is www.gamblingcommission.gov.uk Page 50
Page 51
Current situation The Council undertakes a town centre outlet survey in Spring each year to record what types of uses are occupying town centre units and to analyse the year on yearyear-on-year change in the mix of uses and vacancy rates. Maps 2, 3 and 4 highlight betting offices and pay day lending premises in Clydebank, Dumbarton, and Alexandria town centres, and those premises with planning permission. The information was collected in the 2023 town centre survey. Clydebank Town Centre The Clyde Shopping Centre forms the majority of Clydebank town centre. The northern part of the centre is a modernised enclosed mall, and the southern part (Sylvania Way South) an unenclosed, but partially covered and fully pedestrianised, shopping area. The northern mall is adjoined by some larger retail units including a superstore, a cinema and restaurant uses, and car parking. Clydebank has good access links with a rail station in the town centre and another nearby, designated bus and taxi areas, and parking adjoining the shopping centre. Map 2:Clydebank town centre A core retail area is identified within the town centre by the Local Development Plan 2. Policy SC2 aims to maintain a quality retail offer at the heart of the town centre and control against a proliferation of Class 2 uses. This covers the enclosed mall, adjoining large retail units and Sylvania Way South Page 51
Page 52
Table 3 details the number of betting shops and premises offering high interest lending in Clydebank town centre. Pay day lending and gambling uses are clustered on Sylvania Way South, where there are 3 betting shops and 3 premises offering high interest lending. There is also an amusement arcade on Sylvania Way South, another within the indoor market on Sylvania Way South and another close-by on Chalmers Street. There is another betting shop nearby on Chalmers Street. Another premises offering high-interest lending can be found on Sylvania Way Sylvania Way South is an area where the cluster of betting and pay day lending shops is very noticeable. This is particularly significant as it serves as a main gateway to the town centre linking Clydebank rail station and main bus stops on Chalmers Street with the rest of the town centre. Table 3: Betting shop and high interest lending premises in Clydebank town centre Clydebank town centre 2023 2015 Betting shop premises 32 3 High-interest lending premises 3 4 Dumbarton Town Centre The town centre is based around the historic High Street and the more modern Artizan Centre. Beyond this area is a mix of residential and civic uses such as the Sheriff Court, municipal buildings and library. The town centre is served by a rail station and several bus services which make use of the High Street. Map 3: Dumbarton town centre There is a core retail area identified within the town centre by the Local Development Plan 2, the purpose of which is to maintain a quality retail offer at the heart of the town centre and Page 52
Page 53
control against a proliferation of Class 2 uses. This covers the central part of the High Street and the Artizan Centre (College Way). All Pay day lending/pawn shops and betting offices within Dumbarton town centre are within or vey near to the core retail area. Table 4 details the number of betting shops and premises offering high interest lending in Dumbarton town centre. Pay day lending and betting shops are found along the High Street and in the Artizan Centre. Table 4: Betting shop and high interest lending premises in Dumbarton town centre Dumbarton town centre 2023 2015 Betting shop premises 3 3 High-interest lending premises 2 2 Alexandria Town Centre Alexandria town centre is built mostly around Main Street, Alexandria, which is a traditional high street, with Mitchell Way forming a more modern, pedestrian shopping street and Bank Street. The town centre is accessible by rail and bus services and contains a mix of retail public services, business and residences. Map 4: Alexandria town centre Unlike Clydebank and Dumbarton Alexandria does not have a core retail identified in LDP2Local Development Plan 2 (2020 as modified) (LDP2), however it there are a number of development opportunities for the town centre identified, including: the redevelopment of Mitchell Way, improvements to the public realm and residential opportunities. There are no high interest lending premises in Alexandria Town Centre, however there are a Page 53
Page 54
number of betting shops along Main Street Table 5: Betting shop and high interest lending premises in Alexandria town centre Alexandria town centre 2023 2015 Betting shop premises 3 3 Changes To number and clustering since 2015 The number and clustering of pay day lending and betting shops has broadly remained very similar since 2015, although there hashave been some changes in premises. In Clydebank there is still a concentration of these premises in Sylvania Way South. In Dumbarton the premises are mainly along the high street. Local Centres West Dunbartonshire has three local centres defined in LDP2: Dalmuir, Hardgate, and Glasgow Road in Dumbarton. Betting Shops in Local Centres Dalmuir 2 Hardgate 2 Glasgow Road, Dumbarton 0 There are no pay day lenders in any of the local centres. The council does not hold past information on the number of betting offices in local centres. Other Locations There are other locations in the West Dunbartonshire planning area outside of formally designated town and local centres in LDP2, where shops and other services are clustered. While policies on town and local centres would not apply in these locations, they can be important in providing local services and access to day-to-day needs. There are some betting offices in these locations: Radnor Street Clydebank Duntocher Road, Parkhall Page 54
Page 55
Literature review The Royal Society for Public Health’s report ‘Health on the High Street’4 considers the positive and negative impacts of a range of town centre uses on health. Health was considered holistically with consideration given to: Healthy lifestyle choices Social interaction Access to health care services and health advice Mental wellbeing The report used literature review, consultation with public health experts and a survey of a representative sample of 2000 members of the public to score a range of different high street uses in terms of their impact on health. Uses were given a score against each criteria ranging from +2 where the use had a positive impact on health to -2 where the use had a negative impact on health. A score of 0 was awarded when the impact was considered neutral. For pay day lending shops: 68% of those surveyed believe they discourage healthy choices 65% of those surveyed believe they have a negative impact on mental wellbeing 57% of those surveyed believe they have no effect on providing access to health services Payday lending services were generally used to bridge gaps in finance to the next pay checkpaycheck, with people on low incomes more likely to use pay day lending services. The typical borrower is single, earns less than £20,000 a year and has at least one child, according to research from a payday loan company. For betting shops: 54% of those surveyed believe they discourage healthy choices 49% of those surveyed say they have no effect on promoting social interaction 52% of those surveyed say they have a negative impact on mental wellbeing Greater accessibility to gambling was found to have increase problem gambling. Gambling machine density is disproportionality greater in areas of socioeconomic deprivation, and in areas with a younger than average population profile. An update to Health on the High Street was undertaken in 20185, titled ‘Health on the High Street: Running on Empty’. It found that pay day loan shops declined on high street across the UK by a third, largely because of new regulations making payday lending less profitable. It also found that the increase in the number of betting shops had been halted in London where restrictions have been put in place, indicating planning restrictions are effective at reducing the proliferation of these uses. The Royal Society for Public Health also published information on the impact of debt on a personsperson’s health and wellbeing titled ‘Life on Debt Row’6. The report identified that there is a statistically significant relationship between debt and a number of negative health outcomes, including mental disorder, suicide attempts, drinking problems, drug dependence, depression, OCD, and anxiety. Households are more likely to be in debt problems if they have a low income. 4 b6f04bb8-013a-45d6-9bf3d7e201a59a5b.pdf (rsph.org.uk) 5 rsph.org.uk/static/uploaded/dbdbb8e5-4375-4143-a3bb7c6455f398de.pdf 6 75b46b96-10e8-48a3-bc597f3d65d91566.pdf (rsph.org.uk) Page 55
Page 56
When compared to other forms of debt, payday loans had the greatest effect on wellbeing with more people with payday loan debt reporting the following issues than people with other forms of debt: they spent less time with others’ they ate less as they could not afford healthy food; their housing is negatively effectedaffected; they could not afford time off or transport to access health care. When studying the impact of gambling on individuals and their social network7, the University of Glasgow found that: those with easy access to gambling opportunities gambled more, and moving away from areas where gambling was a problem tended to encourage reduction; significant life events could cause someone to gamble more; and problematic gambling could affect relationships. Citizens Panel Survey 2016 Survey The Council undertook a survey of its Citizen’s Panel in August/September 2015. The survey results provide information of how residents within West Dunbartonshire view uses such as pay day lending and betting shops in terms of how they contribute to the vitality and viability of the area’s town centres. The full survey is included as Appendix 1. Some headline statistics are included below. With regard to Pay day lending shops 90% of respondents did not feel they were important for a vibrant town centre 38% disagreed and 50% strongly disagreed that they were important because they helped to fill vacant premises. 19% agreed and 57% strongly agreed that they charge very high interest rates 27% agreed and 63% strongly agreed they make it too easy for vulnerable people to get a loan 68% of people strongly disagreed that they add to the vibrancy of the town centre. 27% agreed and 44% strongly agreed that there are too many of them 34% agreed and 37% strongly agreed that they are not good for the wellbeing of the community. With regard to betting offices: 94% of respondents did not feel they were important for a vibrant town centre. 42% disagree and 39% strongly disagree that they are important for filling vacant premises 35% agree and 44% strongly agree they make it too easy to gamble. 36% agree and 44% strongly agree that there are too many of them. 34% agree and 32% strongly agree that they are not good for community wellbeing. Regarding the number and clustering of pay day lenders and betting offices: 44% were quite concerned and 31% were very concerned about the overall number of pay day lending and betting offices. 38% were quite concerned and 32% were very concerned about the clustering of pay day lending and betting offices. 20% of people agreed and 75% of people agreed the council should be able to control the number and clustering of pay day lending and betting shops in town centres. 7 https://www.physci.gla.ac.uk/media/Media_310864_smxx.pdf Page 56
Page 57
2023 Survey The council repeated Citizens Panel surveyPanel survey in 2023 with the citizens panel in order to understand if there were any changes in attitudes to the pay day lending and betting offices in town centres. The repeated survey stuck to the original as closely as possible with a couple of exceptions. The question asking respondents agreed or disagreed that pay day lending and betting offices “offices “attracted the wrong sort of people” was changed to “they attract antisocial behaviour” at the recommendation of Performance and Strategy Officers. When asking if respondents were concerned about the number and clustering of pay day lending and betting shops, this was combined to a single question for each use, rather than asking about numbering and clustering separately. The question “To what extent do you agree that the Council should be able to restrict the number and clustering of pay day lenders and betting offices in your town centre?” was not included in the 2023 survey. The full survey is shown in appendix 2 With regard to Pay day lending shops 89% of respondents did not feel they were important for a vibrant town centre 30% disagree and 51% strongly disagree that they are important because they help to fill vacant premises. 22% agree and 47% disagree that they charge very high interest rates. 28% agree and 54% strongly agree that they make it too easy for vulnerable people to get a loan. 24% disagree and 61% strongly disagree that they add vibrancy to the town centre. 29% agree and 37% strongly agree there are too many of them. 31% agree and 35% strongly agree they are not good for the wellbeing of the community. With regard to betting offices: 86% of respondents did not feel they were important for a vibrant town centre 36% disagree and 38% strongly disagree that they are important for filling vacant premises 30% agree and 48% strongly agree they make it too easy to gamble. 32% agree and 38% strongly agree that there are too many of them. 33% agree and 35% strongly agree that they are not good for community wellbeing. Regarding the number and clustering of pay day lenders and betting offices: 40% or respondents were quite concerned and 26% were very concerned about the number and clustering of betting offices in townin town centres. 39% were quite concerned and 23% were very concerned about the number and clustering of pay day lenders in town centres. Conclusions from surveys Results from both surveys indicate that residents think the number and clustering of pay day lending and betting shops have a negative impact on the vibrancy of the town centre and that theythat they are not goof for community wellbeing. There is some difference to the degree of agreement or disagreement with the questions between the two surveystwo surveys , the same conclusions can be drawn from both. Page 57
Page 58
Customer/ footfall counts The Council undertook a survey of the number of customers visiting a variety of different shop/service types in Clydebank and Dumbarton town centres in September and October 2016. Full details of the survey methodology and full results are set out in Appendix 3. Alexandria was not included in the study or the initial guidance, and so there is not data relating to customer or footfall counts in Alexandia. The purpose of the survey was to gain an understanding of how many customers use such as pay day lending and betting shops attracted to the town centres in comparison to other uses. The results for Clydebank town centre indicate that whilst the betting shop surveyed attracted a comparable level of customers over the daytime period (9.30am to 5.30pm) to other uses, the pawnbroker surveyed attracted a significantly smaller amount of customers. Similar results were found in Dumbarton. Clydebank results Page 58
Page 59
Page 59
Page 60
Dumbarton results Page 60
Page 61
Page 61
Page 62
Evening results Clydebank Evening Count Dumbarton evening count Time Unit Tally 17.30 - 18.00 Ladbrokes 9 18.00 - 18.30 Paddy Power 10 18.00 - 18.30 Ladbrokes 3 Time Unit Tally 17.30 - 18.00 William Hill 10 18.00 - 18.30 William Hill 10 18.00 - 18.30 William Hill 9 Page 62
Page 63
Conclusions This background information offers the following evidence in respect of pay day lending and betting office uses in town centres The socio-economic profile of West Dunbartonshire means that it is vulnerable to the ill-effects of gambling and high-interest short- term credit. There is already a significant presence of these uses in West Dunbartonshire, including a cluster of such uses in Clydebank town centre. There is evidence of a much higher betting shop/ population ratio than similar sized authorities The majority of residents of West Dunbartonshire held negative views in respect of the contribution these uses make to the vitality and viability of the area’s town centres. Pay day lending uses do not contribute significantly to daytime footfall, and betting shops only make a limited contribution to evening footfall. Page 63
Page 64
Appendix 1: Citizens Panel Research Report 2015 Page 64
Page 65
Supplementary Guidance on Pay Day Lending and Betting Offices Premises Citizens’ Panel Research Report by For further information contact: Jim Patton Director Hexagon Research and Consulting Suite 401 47 Timber Bush Edinburgh EH6 6QH Tel: 0131 669 9574 e-mail: jim@hexagonresearch.co.uk September 2015 Page 65
Page 66
Contents Page 1. Introduction 3 2. Background and Objectives 4 3. Our Approach 6 4. The Importance of a vibrant town centre 8 5. Pay day lenders 16 6. Betting offices 21 7. The number and clustering of pay day lenders and betting 25 offices in town centres 8. Concluding Comments 32 Appendix 1: The West Dunbartonshire Citizens’ Panel 33 Appendix 2: Focus group discussion guide 37 Appendix 3: Survey questions 41 Page 66
Page 67
1. Introduction This document sets out our report for West Dunbartonshire Council on Citizens’ Panel research conducted to help build the evidence base to support the development of Supplementary Guidance on Pay Day Lending and Betting Offices Premises. In our report: Section 2 sets out the background to and objectives of the assignment Section 3 outlines our approach to designing and conducting the research programme Section 4 presents Panel members’ views on the importance of a vibrant town centre Section 5 deals with respondents’ attitudes to pay day lenders in local town centres Section 6 assesses Panel members’ views on betting offices in their local town centre Section 7 establishes Panel members’ views on the impact of the number and clustering of pay day lenders and betting offices in local town centres Section 8 sets out our concluding comments Page 67
Page 68
2. Background and Objectives A recent report on pay day lending and gambling in Scottish town centres and neighbourhoods1 cited the importance of town centres as a base for small businesses and local jobs as well as the important role they play in community identity. This was echoed in a second report2 which saw town centres as an important part of vibrant communities and a critical engine for economic growth in local areas. It regarded high streets as having an important role to play in supporting the public’s health; a healthy high street can provide the public with healthy choices, support community cohesion and social interaction, promote access to health services and support individual well beingwellbeing. Both reports also highlighted a growing concern with the clustering of pay day lenders and betting offices in town centres, with the Scottish Government’s policy objectives in relation to this aiming to: Improve town centres, creating vibrant community hubs with a range of services by tackling the increasing numbers and clustering of pay day lenders and betting offices Minimise exposure and potential adverse risk to vulnerable individuals of pay day lenders via town centres Minimise exposure and potential adverse risk to vulnerable individuals through gambling via town centres However, the report from the May 2014 summit recognised that a key barrier to more coherent action was the complex nature of reserved and devolved legislation; Planning and Business rates are devolved while Financial Services, Consumer Credit and Gambling are reserved. Consequently, the Scottish Government and local authorities have limited controls on how to address concerns about the impact of pay day lenders and betting offices. Nevertheless, it was felt the Planning system could be used to guard against clustering of these types of premises. 1 Tackling Payday Lending and Gambling in Scottish Town Centres and Neighbourhoods. A report from a summit hosted by the Minister for Local Government and Planning, Scottish Government. May 2014. 2 Health on the High Street. Royal Society for Public Health. 2015 Page 68
Page 69
West Dunbartonshire Council’s Planning and Building Standards Department is now involved in a pilot project supported by the Scottish Government which involves the preparation of Supplementary Planning Guidance in relation to planning applications for pay day lenders and betting offices. The purpose of the pilot is to strengthen/develop the evidence base available when the Council wants to refuse planning applications for pay day lenders and betting offices. The Supplementary Guidance is required to be based on a policy in the Council’s existing Local Development Plan, which sets out criteria for the assessment of non-retail uses (such as pay day lenders and betting offices) in core retail areas. These criteria arecriteria a r e : a) Whether the change would significantly reduce the retail offer of the core retail area, or parts of it;it. b) Whether the change would lead to the concentration of a particular use to the detriment of the town centre’s vitality and viability;viability. c) The contribution the proposed use would make to the vibrancy of the town centre by increasing footfall;footfall. d) The availability and suitability of other locations in the town centre for the proposed use to locate; and e) Whether the unit affected by the proposal has been vacant and suitably marketed for retail use. Criteria a, d and e can be assessed objectively as they are based on unit size or availability of units. Criteria b and c are more subjective and quite often based on a single officer’s assessment. The Council therefore commissioned Hexagon Research and Consulting to develop more objective evidence for these criteria (b & c) based on public opinion. Our approach to developing this evidence base is outlined in Section 3. Page 69
Page 70
3. Our Approach There is a requirement to generate robust and credible data to support the Supplementary Guidance which can withstand scrutiny as it will be used in reports to the Planning Committee and be subject to independent scrutiny by Reporters considering appeals. It is also important that any evidence has not been derived from what could be viewed as ‘leading’ questions. To meet these requirements, we recommended using the West Dunbartonshire Citizens’ Panel, a group of over 1,500 adults evenly divided between the Regeneration areas and the rest of West Dunbartonshire (more details of the Panel are attached at Appendix 1). In our view the Panel provided the ideal basis to conduct a two stagetwo-stage research programme: Stage 1 - Focus group research Two focus groups with members of the Citizens’ Panel were held in Clydebank and Dumbarton with the overall aim was of establishing respondents’ views on the impact of the clustering of pay day lenders and betting offices on their town centre (positive and negative). Respondents’ views on how to deal with any concerns about these types of premises, including amending the Planning guidance, were also sought. Each focus group was based on an agreed discussion guide (attached at Appendix 2), with the aim of obtaining respondents’ views in an unprompted way. With the agreement of respondents, the focus groups were recorded to ensure their comments are presented accurately and verbatim comments can be included in our report (although these have been anonymised). Once detailed transcriptions of the discussions were made, the recordings were deleted. The focus groups were held on the 24th24th July 2015. Location Number of respondents Breakdown of respondents Garshake, Dumbarton 7 4 male, 3 female Town Hall, Clydebank 8 4 male, 4 female Page 70
Page 71
Stage 2 - Survey of the Citizens’ Panel On completion of the focus group programme, the second stage involved a survey of all members of the Citizens’ Panel. A postal survey approach was adopted for the survey which covered a number of issues in addition to the questions required for the evaluation of pay day lenders and betting offices (see Appendix 3). Questionnaires were sent out to Panel members in early August 2015. By early September, a final response of 1,028 returns had been achieved (68%), and the table below illustrates the high level of accuracy that can be attributed to the results derived from this response overall, as well as for the two main sub areas. Survey Response West Dunbartonshire Dumbarton Clydebank Alexandria Sample achieved 1,028 316 443 269 Sampling error ± 3.0% ± 5.5% ± 4.7% ± 6.0% As illustrated above, results for the Panel as a whole have sampling errors limited to only ± 3%. This means, for example, that if 50% of Panel members say they support the proposal for the Council to introduce planning policies so they would have stronger control over the change of a use of a property into a pay day lender or a betting office, the real figure would be in a narrow range, from only 47% to 53%. The sampling errors for the three towns rise marginally to a range from only ± 4.7% to ± 6.0% and our analysis includes a breakdown by town as well as for West Dunbartonshire as a whole. Page 71
Page 72
4. The importance of a vibrant town centre Surveyed Panel members from Dumbarton use their town centre less regularly than those in the other two towns. For example, only 39% said they visited the town weekly, compared to 56% of those from Clydebank and 61% from Alexandria. Despite this, there is widespread agreement across all three towns on the importance of a vibrant town centre. Almost three quarters (72%) agree this is ‘very important’ while only 1% stated that a vibrant town centre was ‘not very important’. How often would you visit your local town centre? Dumbarton Clydebank Alexandria West Dunbartonshire Daily 12% 8% 16% 12% 2-3 times a week 27% 48% 45% 41% Once a week 33% 22% 23% 25% 2-3 times a month 20% 12% 9% 14% Once a month 6% 6% 0% 4% Less thanLess than once a 2% 4% 7% 4% Never 0% Under 1% Under 1% Under 1% How important do you think it is to have a vibrant town centre? Dumbarton Clydebank Alexandria West Dunbartonshire Very important 74% 67% 78% 72% Quite important 25% 30% 21% 26% Not very important 1% 1% 2% 1% Not important at all 0% 0% 0% 0% Don’t know 0% 2% 0% 1% There was also unanimous support among focus group respondents for the concept of a vibrant town centre, with many citing reasons such as its importance to the health and well beingwellbeing of the local community, as a base for community activity and an important centre of employment. Page 72
Page 73
Of courseOf course, a vibrant town centre is important. It’s a sign of the health of the local community. Clydebank respondent A town centre should be about more than just shopping. It should encourage people to use it for social and recreational purposes, to provide a focus for community activity. Clydebank respondent At one time the town centre had the post office, the big army recruitment centre, the Council office where you could pay your rent and rates, the Registrar, as well as a good range of shops. There were important civic functions as well as good commercial outlets. It provided a wide range of activities and was an important centre of employment. That’s what a vibrant town centre needs. Dumbarton respondent The features which most survey respondents regard as ‘very important’ in a vibrant town centre include: A wide range of shops (79%) Good quality shops (74%) Banks (70%) Pharmacy/health facilities (68%) Conversely, those which were regarded as being of least importance focused on: Betting offices (59% stated these were ‘not important at all’) Pay day lenders/pawn shops (57%) These priorities were also reflected across the three town centres. Page 73
Page 74
How important are the following in a vibrant town centre? Very important Quite important Not very important Not important at all Don’t know Wide range of shops 79% 21% Under 1% Under 1% 0% Fast food outlets 11% 42% 41% 6% Under 1% Pharmacy/health facilities 68% 30% 2% Under 1% 0% Pubs 3% 43% 43% 11% Under 1% Charity shops 5% 49% 35% 10% 1% Cafes and restaurants 36% 57% 5% 2% 0% Betting offices Under 1% 5% 35% 59% 1% Libraries/museums/art galleries 42% 50% 7% 1% 0% Banks 70% 29% 1% Under 1% Under 1% Good quality shops 74% 24% 1% 1% Under 1% Pay day lenders/pawn brokers Under 1% 6% 33% 57% 3% Green/open spaces 38% 50% 9% 2% Under 1% ‘Pound’ shops 11% 45% 30% 12% 2% Leisure facilities (cinema etc) 45% 48% 5% 2% 0% Local Government/civic uses 33% 51% 12% 2% 2% Page 74
Page 75
‘Very important’ aspects of a vibrant town centre Dumbarton Clydebank Alexandria Wide range of shops 77% 76% 87% Fast food outlets 9% 10% 15% Pharmacy/health facilities 73% 60% 73% Pubs 6% 2% 1% Charity shops 8% 4% 5% Cafes and restaurants 44% 30% 39% Betting offices 0% 1% Under 1% Libraries/museums/art galleries 36% 46% 43% Banks 75% 60% 78% Good quality shops 81% 72% 70% Pay day lenders/pawn brokers 0% 1% 0% Green/open spaces 34% 41% 38% ‘Pound’ shops 11% 9% 14% Leisure facilities (cinema etc) 45% 46% 43% Local Government/civic uses 38% 25% 38% Base: respondents stating “very important” Focus group respondents agreed that the key aspects of a vibrant town centre should include good quality shops, as well as community facilities and services and effective traffic management. Better quality shops hashave to be the starting point, but the town centre should also be a place for people to interact, so meeting places, places to sit, cafes and so on are needed. Clydebank respondent I also think a town centre needs community services such as a library, or a health centre or the Council’s one stop shop. It shouldn’t just be about shopping. Clydebank respondent There should be good traffic management to encourage the traffic to flow along the High Street. The one-way system is meant to do thatthat, but the parking is rarely policed and you get people parking on both sides of the road. So, when a bus 1 Page 75
Page 76
stops at a bus stop, it holds up all the traffic because the road isn’t wide enough for cars to get past. Dumbarton respondent Panel members were then asked to indicate the extent to which they were satisfied with each of these aspects of their own town centre. A very high level of satisfaction was recorded for banks (89%) and pharmacy/health facilities (86%), while over half were also satisfied with cafeswith cafes and restaurants (60%) and libraries, museums and art galleries (58%). Conversely, more than half of all Panel members were dissatisfied with the range (57%) and quality (56%) of shops and approximately a third dissatisfied with pay day lenders/pawn shops (34%) and betting offices (32%). This pattern was largely repeated across each town centre apart from significantly higher satisfaction in Clydebank for: Leisure facilities (70%) Local government/civic uses (58%) The range (44%) and quality (42%) of shops Fast food outlets (40%) Page 76
Page 77
How satisfied are you with the following in your town centre? Very satisfied Quite satisfied Neither satisfied nor dissatisfied Quite dissatisfied Very dissatisfied Don’t know The range of shops 2% 22% 19% 37% 20% 0% Fast food outlets 5% 25% 47% 12% 9% 2% Pharmacy/health facilities 25% 61% 10% 4% Under 1% Under 1% Pubs 6% 27% 49% 9% 3% 6% Charity shops 6% 42% 41% 9% 1% 1% Cafes and restaurants 6% 54% 22% 12% 5% 1% Betting offices 4% 5% 51% 15% 17% 8% Libraries/museum s/art galleries 10% 48% 24% 10% 5% 3% Banks 30% 59% 7% 3% Under 1% 1% The quality of the shops 4% 25% 14% 36% 20% 1% Pay day lenders/pawn brokers 3% 5% 47% 16% 18% 11% Green/open spaces 8% 37% 27% 21% 7% Under 1% ‘Pound’ shops 7% 29% 42% 10% 8% 4% Leisure facilities (cinema etc) 6% 28% 20% 24% 19% 3% Local Government/civic uses 4% 34% 39% 12% 4% 7% Page 77
Page 78
Satisfied with aspects of your local town centre Dumbarton Clydebank Alexandria The range of shops 8% 44% 11% Fast food outlets 27% 40% 18% Pharmacy/health facilities 92% 78% 93% Pubs 40% 26% 35% Charity shops 44% 51% 46% Cafes and restaurants 50% 68% 56% Betting offices 6% 12% 9% Libraries/museums/art galleries 44% 67% 61% Banks 88% 89% 90% The quality of the shops 13% 42% 29% Pay day lenders/pawn brokers 5% 7% 13% Green/open spaces 37% 49% 47% ‘Pound’ shops 44% 41% 17% Leisure facilities (cinema etc) 8% 70% 4% Local Government/civic uses 24% 58% 23% Base: respondents stating “very satisfied” or “quite satisfied” These findings were consistent with the views of focus group respondents. Dumbarton residents in particular complained about the poor range of shops, the prevalence of charity shops and that there were too many empty properties. There is very little in the town centre now. I would only go in maybe once every few weeks, usually to the bank. I think the authorities are just papering over the cracks with the town centre. It really is a terrible place and just doesn’t work. Dumbarton respondent People do their food shopping out of town or go to the shopping centre in Clydebank. I don’t know many people who would come into Dumbarton on a regular basis because the shops are so poor. Dumbarton respondent The shopping centre at Clydebank is undercover. They tried to put up some cover at the Artizan Centre, some sheets of glass like an awning, but it’s very poorly Page 78
Page 79
designed and when it rains, the water just pours in. And they are never cleaned so the appearance is very off-putting. Dumbarton respondent Unfortunately, the town centre is now full of charity shops. I know they are serving a purposepurpose, but you wouldn’t decide to go into town to look in the charity shops. They don’t really add anything to the vitality of the High Street. Dumbarton respondent There are too many empty shops on the High Street. That is even worse than having lots of charity shops; it creates an air of neglect and decay. Dumbarton respondent Clydebank focus group respondents said they visited their town centre more frequently, with some saying the shopping centre met most of their needs. However, there was a concern that the town didn’t have a genuine town centre, only a shopping centre, with none of the community focus they would prefer to see. Some also said there were too many charity shops and ‘pound’ shops. I think the shopping centre is perfectly adequate. I use it every day for my food shopping and there is also a bank. Clydebank respondent The town centre used to be around here (the Town Hall). We don’t really have a town centre, just a shopping centre. You’ve got 3 Queens Square where they re- instated the old bandstand and there are occasions when some event is put on. But now a cycle path goes right through it and you take your life in your hands walking across it. They spent £2.2m doing up 3 Queens Square in an attempt to improve the town centre but to me it was a complete waste of money. It doesn’t provide a community focus for the town. Clydebank respondent I don’t use it (the shopping centre) as much as I used to as it has become dominated by places like pound shops. Clydebank respondent There are too many charity shops, especially when they seem to be concentrated in one part of the centre. Clydebank respondent Page 79
Page 80
5. Pay day lenders To help the Council develop its evidence base to supportto support new Planning Guidance, survey respondents were asked to state the extent to which they agreed or disagreed with ten statements about pay day lenders/pawn brokers in their town centre (to minimise bias, the statements were phrased to reflect both positive and negative views of pay day lenders/pawn brokers). As illustrated in the table below, there is a very high level of agreement that pay day lenders/pawn brokers: Make it tooit too easy for vulnerable people to get a loan (90% agreed with this statement) Charge very high interest rates (76%) There are too many of them (71%) They are not good for the well beingwellbeing of the town centre (71%) Significantly, 92% also disagreed that pay day lenders/pawn brokers add to the vitality/vibrancy of the town centre (with 68% ‘disagreeing strongly’). There was also little support for the role pay day lenders/pawn brokers play in helping to fill vacant premises (88% disagreed that this was important, with 50% ‘disagreeing strongly’) or by paying business rates (62% disagreed that this was important). These views were also strongly reflected within each of the three towns. Page 80
Page 81
Do you agree or disagree with the following statements about pay day lender/pawn brokers in your town centre? Strongly agree Agree Disagree Strongly disagree Don’t know They are important because they help to fill vacant premises 1% 6% 38% 50% 5% They charge very high interest rates 57% 19% 1% 3% 20% They make an important contribution to the area by paying business rates 1% 15% 38% 24% 22% They make it too easy for vulnerable people to get a loan 63% 27% 3% 1% 6% They add to the vitality/vibrancy of the town centre Under 1% 2% 24% 68% 6% There are too many of them 44% 27% 7% 6% 16% They provide an important service for those who can’t access mainstream financial institutions 3% 21% 39% 24% 13% They attract the wrong type of people into the town/put others off 21% 30% 25% 7% 17% They are a valuable employer in the town centre 2% 9% 37% 25% 27% They are not good for the well being of the community 37% 34% 8% 6% 15% Page 81
Page 82
Agreement with statements in your local town centre about pay day lenders/pawn shops Dumbarton Clydebank Alexandria They are important because they help to fill vacant premises 10% 8% 3% They charge very high interest rates 88% 74% 66% They make an important contribution to the area by paying business rates 22% 14% 11% They make it too easy for vulnerable people to get a loan 92% 87% 91% They add to the vitality/vibrancy of the town centre 5% 2% 2% There are too many of them 80% 75% 55% They provide an important service for those who can’t access mainstream financial institutions 30% 24% 16% They attract the wrong type of people into the town/put others off 49% 53% 49% They are a valuable employer in the town centre 20% 6% 8% They are not good for the well being of the community 66% 70% 76% Base: respondents stating “strongly agree” or “agree” Focus group respondents were also asked if they felt there was a role for pay day lenders in their town centres. Only a few agreed, saying that they suited some people. Page 82
Page 83
There is clearly a demand for them, so they must provide a service for some people. I guess for some people they are a necessity. Dumbarton respondent I do some volunteering work with St. Vincent de Paul and I see the lower end of the social scale. A Credit Union is a brilliant thingthing, but a lot of people just can’t get access to these because they can’t save, whether it’s through drugs or alcohol dependence. For some the only option is the pay day lender. They are convenient in the sense that some people can get a small loan to see them through a short period until their benefits or wages are paid. Unfortunately, it doesn’t always work out as simple as that and astronomical rates of interest are charged. Clydebank respondent However, the overwhelming view of focus group respondents was that pay day lenders were unwelcome in their town centres because of the high interest rates they charge, that their presence was not a sign of a healthy community as well as a feeling that the pawn broking aspect of some of the shops encouraged criminal behaviour. I work in the local Credit Union. Why on earth do people go in tointo these pay day lenders when there is a Credit Union on their doorstep? The interest in the Credit Union is 1% on the reduced balance. They can save to get some money behind them and get a loan when they need it at a low rate of interest. Clydebank respondent The pay day lenders argue that their loans are meant to be paid off quickly and the interest payable is usually a relatively small amount, but we all know they don’t work like that. People borrowing the money usually extend the loan or take out another one and the interest piles up. Clydebank respondent I can’t see what value they (pay day lenders) bring to the community other than to a small desperate minority. When you see these shops the impression you get is of a community that has problems. They are not a sign of a healthy and vibrant community. Clydebank respondent Some people just see what they are getting (a pay day loan) and don’t think about the consequences. It’s the same with the crowds you see in places like ***** ***** where they will get a TV valued at £600 for a few pounds a week but end up paying £3,000 for it as the weekly payments go on forever. Clydebank respondent My main concern is that the pay day lenders do not screen people properly so that they lend responsibly. They seem happy to lend to anyone and are probably glad when the customer can’t pay back on time so they can add even more interest. That’s not the type of business we should welcome on our High Street. Dumbarton respondent Page 83
Page 84
My worry is that they look like they are fences for criminal behaviour, offering cash for goods with little concern where they came from. Clydebank respondent I would prefer another couple of empty shops if it meant getting rid of these places (pay day lenders) from the High Street. They create the wrong impression and attract a criminal element. Dumbarton respondent I work in a charity shop and one of the lads who comes in from time to time told me when he is skint he nicks the footballs from outside ** ***** then* then sells them to the pawn broker shop. He says he never gets asked where the things come from. Dumbarton respondent These pawn broker places just encourage crime. I know of one lad who broke into a church and stole two big brass candlesticks. When the Police found them in a pawn broker’s shop, the manager said he had bought them that morning for a fiver. They were obviously worth a lot moremore, but the manager turned a blind eye to where they had come from. We don’t want that sort of thing going on in our town centre. Dumbarton respondent Page 84
Page 85
6. Betting offices A similar approach was adopted to establish Panel members’ views on betting offices in their town centre. Of the nine statements about betting offices, those which most survey respondents agreed with were: There are too many of them (80%) They make it too easy to gamble (79%) They are not good for the well beingwellbeing of the community (66%) The majority of respondents also disagreed that betting offices: Added vitalityAdded vitality and vibrancy to their town centre (85% disagreed, with 41% ‘strongly disagreeing’) Were important because they help to fill vacant premises (81% disagreed) Page 85
Page 86
Do you agree or disagree with the following statements about betting offices in your town centre? Strongly agree Agree Disagree Strongly disagree Don’t know They are important because they help to fill vacant premises 1% 13% 42% 39% 5% They make it too easy to gamble 44% 35% 13% 3% 5% They make an important contribution to the area by paying business rates 2% 26% 30% 20% 22% There are too many of them 44% 36% 6% 2% 12% They add to the vitality/vibrancy of the town centre 2% 7% 44% 41% 6% They attract the wrong type of people into the town/put others off 20% 28% 28% 9% 15% They provide an important service for those who like to gamble 4% 40% 25% 17% 14% They are not good for the well being of the community 32% 34% 17% 3% 14% They are a valuable employer in the town centre 3% 20% 32% 19% 26% Page 86
Page 87
Agreement with statements about betting shops Dumbarton Clydebank Alexandria They are important because they help to fill vacant premises 11% 15% 17% They make it too easy to gamble 86% 81% 68% They make an important contribution to the area by paying business rates 24% 27% 32% There are too many of them 75% 83% 83% They add to the vitality/vibrancy of the town centre 9% 6% 15% They attract the wrong type of people into the town/put others off 55% 46% 46% They provide an important service for those who like to gamble 47% 44% 39% They are not good for the well being of the community 67% 69% 62% They are a valuable employer in the town centre 29% 19% 22% Base: respondents stating “strongly agree” or “agree” Several focus group respondents acknowledged that betting offices have been around for a long time and can provide a useful service for some people. There was also an acceptance that they help to create employment and contribute income to the area through the payment of business rates. The bookie’sbookies has always been part of our society and I’m sure there are some who enjoy the odd punt. I had a friend who went to the bookies each morning to place his bets then came home and spent the afternoon watching the races on the TV. It wouldn’t appeal to meme, but he enjoyed it and it got him out of the house every day. Dumbarton respondent Page 87
Page 88
I’ve got a neighbourneighbour, and he likes to have a wee bet now and then. I’m not opposed to that but surelysurely, we don’t need to have more than one or two in the town. Clydebank respondent At least they pay business rates to the Council rather than there being even more depressing empty premises which generate no income. It might not be the shop that you want but it provides employment for some people. Dumbarton respondent However, there was widespread concern among most focus group respondents about the number of betting offices, their siting at the heart of town centres and the growth of fixed odds betting terminals. Clydebank is a deprived area and people can’t afford to lose money through gambling so I’m opposed to them being in busy places where people passing by might be tempted to go in. Clydebank respondent As well as the bookies there are places in the shopping centre where there are loads of fruit machines where kids as young as 10 or 12 can go. I think it’s incredible that we are encouraging school kids to go to these places. In a few years timeyear’s time they will graduate to the bookies and a lifetime of debt. Clydebank respondent In the olden days they (betting offices) were hidden up closes but now they are right on the High Street. Unfortunately, they now seem to be right at the centre of our community. Dumbarton respondent These fixed odds betting terminals just eat money. I heard that they keep about 99 pence out of every pound bet. Dumbarton respondent The profit from the slot machines (fixed odds betting terminals) is massive. They are a real menace. Clydebank respondent Page 88
Page 89
7. The number and clustering of pay day lenders and betting offices in town centres Given the views expressed above in relation to the perceived impact of pay day lenders and betting offices in West Dunbartonshire’s town centres, it is not surprising that the majority of Panel members stated they were concerned about the number of these premises (75%) as well as their clustering in particular parts of the town centres (70%). Conversely, typically only one in five respondents stated they were ‘not very concerned’ or ‘not concerned at all’. Are you concerned about the number and clustering of pay day lenders and betting offices in your town centre? Very concerned Quite concerned Not very concerned Not concerned at all Don’t know The overall number of pay day lenders and betting offices in the town centre 31% 44% 15% 3% 7% The clustering of pay day lenders and betting offices in particular parts of the town centre 32% 38% 18% 3% 9% Are you concerned about the number and clustering of pay day lenders and betting offices in your town centre? Dumbarton Clydebank Alexandria The overall number of pay day lenders and betting offices in the town centre 82% 75% 69% The clustering of pay day lenders and betting offices in particular parts of the town centre 69% 77% 59% Base: respondents “very concerned” or “quite concerned” Page 89
Page 90
Focus group respondents in both towns also raised the issue (unprompted) of the clustering of pay day lenders and betting offices, with most saying they would prefer to see fewer of these outlets in their town centre. In the lower part of Clydebank (shopping centre) all you have are charity shops, pound shops, pay day lenders, pawn shops and bookies. We definitely don’t need any more of these. I understand some people want these placesplaces, but we really don’t need three or four of each in such a small area. Clydebank respondent The top half of the centre is not too bad; there are some good shops there. But the bottom part is all pound shops, charity shops, bookies, fruit machine places. There is also a beautiful listedbeautiful, listed building, the old Co-operative building that is lying empty. Clydebank respondent There are three pay day lenders or pawn shops in a row at the bottom end of the shopping centre. I think there are more now than there were a few years ago. It’s definitely not a problem that is going away. Clydebank respondent I wouldn’t want to see any more betting shops in the town centre. This is a deprived area and betting shops can be fatal for those who have a gambling addiction. Dumbarton respondent You also get these ‘cash generator’ type of shops opening all the time. They can be good to get your foreign exchange when you’re going on holiday, but the pawn broking and pay day loans side of the business is not welcome. Dumbarton respondent Two of the Council’s key criteria for the assessment of non-retail uses (such as pay day lenders and betting offices) in core retail areas are: Whether a change would lead to the concentration of a particular use to the detriment of the town centre’s vitality and viability or, Whether the proposed use would make a contribution to the vibrancy of the town centre by increasing footfall As illustrated in the table below, the vast majority of survey respondents (82%) agree that more pay day lenders and betting offices would have a detrimental effect on the vitality and vibrancy of their town centre. Conversely, only 4% agreed that more pay day lenders and betting offices would improve the vitality and vibrancy and vitality of their Page 90
Page 91
town centre by increasing footfall. In addition, 81% agreed that more pay day lenders and betting offices would be bad for the health and well beingwellbeing of the local community. These views were strongly reflected within each of the three towns. The effect of more pay day lenders and betting offices in your town centre Strongly agree Agree Disagree Strongly disagree Don’t know It would have a detrimental effect on the vitality and vibrancy of the town centre 51% 31% 8% 1% 9% It would improve the vitality and vibrancy of the town centre by increasing footfall 2% 2% 45% 45% 6% It would be bad for the health and well being of the community 43% 38% 6% 3% 10% The effect of more pay day lenders and betting offices in your town centre Dumbarton Clydebank Alexandria It would have a detrimental effect on the vitality and vibrancy of the town centre 86% 77% 87% It would improve the vitality and vibrancy of the town centre by increasing footfall 2% 6% 3% It would be bad for the health and well beingwellbeing of the community 84% 81% 77% Base: respondents stating “strongly agree” or “agree” Survey respondents were asked to state the extent to which they agreed that the Council should be able to restrict the number and clustering of pay day lenders and betting offices in their town centre. Overall, 95% agreed with this statement, with 75% ‘strongly agreeing’, a pattern found across all three town. Less than 1% disagreed. Page 91
Page 92
To what extent do you agree that the Council should be able to restrict the number and clustering of pay day lenders and betting offices in your town centre? Dumbarton Clydebank Alexandria West Dunbartonshire Strongly agree 76% 77% 69% 75% Agree 19% 18% 24% 20% Disagree 0% 1% 0% Under 1% Strongly disagree 0% 1% 0% Under 1% Don’t know 5% 3% 7% 5% There was also universal agreement among focus group respondents that steps should be taken to prevent more pay day lenders and betting offices from opening in town centres, and in particular, from clustering in particular parts of the town centre. I’m a gambler and I like the fact that having two or three bookies in the town centre means there is competitioncompetition, and I can get shop around to get better odds, but we don’t need any more than the ones we’ve got. Two or three is plenty. Clydebank respondent We do not want more pay day lenders and bookies opening in the shopping centre or the streets around it. We made that clear during the Harry Corry case. We were up in arms about it. Clydebank respondent It would be a backward step to allow too many of these (pay day lenders and betting offices) to be located on the High Street. Even though it might reduce the number of empty premises, it would be detrimental to the well beingwellbeing of our town and the community. Dumbarton respondent If there was a growth in the number of pay day lenders and bookies in Dumbarton, you may as well turn the lights out because it would destroy the town. People would avoid the High Street full stop. The High Street would be dead. Dumbarton respondent They give them catchy names likelike, but they are basically pawn shops. I get the feeling these are the only shops which can fill up the empty spaces in the High StreetStreet, but I wouldn’t say that was a good thing because there are simply too many of them already. I can understand some people may need them but surely one or two on the High Street is enough. Dumbarton respondent Page 92
Page 93
The real problem is the proximity of bookies in one place. If there was one at either end of the shopping centre, I don’t think people would complain. But having them concentrated near each other, and near pawn shops or pay day lenders, is going to create an environment that is very off putting to most people coming into the centre. Clydebank respondent Siting a bookie’s next to a pay day lender or a pawn broker is just asking for trouble. Clydebank respondent Surely it has reached the point where the local authorities can say, ‘That’s it. There aren’t going to be any more bookies or any more pay day lenders’lenders. I assume business of that nature have to be licensed so surely the Council can just stop awarding licenses to restrict the numbers. Dumbarton respondent The Council licenses bookies so I can’t see why they don’t refuse more licenses to reduce the number of premises. Dumbarton respondent Can’t the Council set a cap on the number of licenses issued? Clydebank respondent I don’t think the Council can do that (cap the number of licenses) because the Harry Corry case was an example of where the Council seemed unable to prevent the application for another betting office. Clydebank respondent What made me angry recently was when Harry Corry was closing someone wanted to use the site for another bookie’s shop. The people of Clydebank all said no; we don’t want another bookie’s. That’s the last thing we need. But the Council said they can go ahead and open a bookie’sbookies there. How can the Council take a decision like that against the wishes of the people? What can the people of Clydebank do to stop more bookies being opened if the Council won’t help? It feels like we don’t have a voice. Clydebank respondent Respondents were informed that the Council has limited powers to address the number and clustering of pay day lenders and betting offices in town centrescentres, but one option would be to introduce planning policies so that the Council would have stronger control over the change of use of a property into a pay day lender or a betting office. As illustrated in the table below, 95% of Panel members said they would support thissupport this proposal, with more than two thirds (68%) saying they would ‘strongly support’ it. Only 2% said they opposed it. Page 93
Page 94
To what extent would you support planning policies so that the Council would have stronger control over the change of a use of a property into pay day lender or a betting office? Dumbarton Clydebank Alexandria West Dunbartonshire Strongly support 67% 72% 61% 68% Support 30% 21% 32% 27% Oppose 1% 4% Under 1% 2% Strongly oppose 0% 1% 0% Under 1% Don’t know 2% 2% 7% 3% This proposal was also widely welcomed by focus group respondents as an effective way to prevent the future clustering of pay day lenders and betting offices in their town centres. That’s definitely something I would support. If only the Council had those powers at the time of the Harry Corry case, we would have felt a lot happier. At the time we felt we were being ignored but now I understand the Council and the Scottish government had no option. Clydebank respondent It clearly won’t help with the existing problem of bookies and pay day lenders. We have to accept that. But it will ensure the problem won’t get any worse. Clydebank respondent The Council should be in a position to be able to refuse an application for a new bookie’s or pay day lender if they feel there are too many of them in the area already and more would be detrimental to the well beingwellbeing of the town. If the simplest way to do that is to amend the planning laws, then I’m all for that. Dumbarton respondent A lot of the political parties mentioned taking action against the proliferation of pay day lenders and betting offices in their manifestos. It’s good to see that now seems to be bearing fruit. The pay day lenders are the scourge of our nationnation, and they need to be stopped. Clydebank respondent That sounds a lot better than playing around with the business rates. It tackles the issue head on by refusing to allow more premises to be turned into pay day lenders or bookies shops. Dumbarton respondent Page 94
Page 95
I’m delighted to hear that action is being taken on this (dealing with the clustering of pay day lenders and betting offices). It restores your faith in the political process. Clydebank respondent The Scottish government has been criticised for being too authoritarian but this (the clustering of pay day lenders and betting offices) is an issue which does need intervention. Dumbarton respondent Page 95
Page 96
8. Concluding Comments The survey and focus group research programme with members of the West Dunbartonshire Citizens’ Panel has generated feedback on three key issues: The importance of a vibrant town centre – respondents widely acknowledged the vital role a vibrant town centre can play in promoting community well beingwellbeing and cohesion Major concerns about the number and clusteringand clustering of pay day lenders and betting offices – there was universal concern about the number of pay day lenders and betting offices premises, and in particular, their clustering in some of the busiest parts of town centres where they had an unhealthy impact on community well beingwellbeing. Significantly, 82% of survey respondents agreed that more pay day lenders and betting offices would be detrimental to their town centre’s vitality and vibrancy (Criterion b for the assessment of non-retail uses in core retail areas) Only 4% stated that more pay day lenders and betting offices would improve the vitality and vibrancy of the town centre by increasing footfall (Criterion c) 95% of Panel members agreed that the Council should be able to restrict the number and clustering of pay day lenders and betting offices in town centres Widespread support for Supplementary Planning Guidance – there was widespread support (95%) for planning policies which would give the Council stronger control over the change of use of a property into a pay day lender or a betting office Jim Patton Director Hexagon Research and Consulting September 2015 Page 96
Page 97
Appendix 1 West Dunbartonshire Citizens’ Panel Page 97
Page 98
The West Dunbartonshire Citizens’ Panel was recruited with the following aims: To be representative of local residents and willing to be surveyed on a regular basis about the policies and services of the community planning partners To recruit approximately 500 Panel members from the regeneration areas and a further 500 across the rest of West Dunbartonshire To allow these views to be fed into the decision-making processes of the community planning partners To keep Panel members informed of the actions taken by community planning partners in response to the views expressed Previous Recruitment Exercises The original Panel recruitment exercise in 2005 produced 1,185 members, with 542 in thein t h e Regeneration areas and 639 across the rest of West Dunbartonshire. With the aim of running typically four surveys with the Panel each year, it was agreed to refresh the Panel on a regular basis and refresh exercises were carried out in October 2007, March 2009, February 2011, September 2012 and March 2014. The 2014 Refresh Between late February and late March 2014, two exercises were completed to refresh the Panel: To replace those removed from the Panel, a fresh sample of 7,500 residents was drawn from the edited edition of the 2013 Electoral Register for West Dunbartonshire. Of these, 5,000 lived in the Regeneration areas and 2,500 lived elsewhere within West Dunbartonshire. Based on previous recruitment exercises, it was anticipated there would be an interest to join the Panel from approximately 5% of those from the Regeneration areas and 10% from those who lived elsewhere in West Dunbartonshire, generating approximately 500 new Panel members. The recruitment questionnaire (Appendix 1) was therefore issued to Page 98
Page 99
the sample of 7,500 which generated 511 responses from residents who ticked a declaration to indicate they wished to become Panel members In recognition of wanting to maintain the Panel at a similar size, the response to the last two survey exercises was examined, revealing 490 Panel members who had not replied to either. These were sent a letter advising them they would be withdrawn from the Panel unless they indicated they wished to remain Panel members through a Freepost reply. However, none responded to say they wished to remain Panel members, leaving a core of 992 Panel members before the refresh exercise When the 511 new Panel members were added to the 992 existing Panel members, this gave a refreshed Panel of 1,503 members, with 747 in the regeneration areas and 756 in the rest of West Dunbartonshire. 2014 Panel Characteristics Overall, the 2014 Panel has a very similar composition to the 2012 Panel and also continues to reflect many of the characteristics of the West Dunbartonshire adult population, with most variations being limited to only a few percentage points (a full breakdown is provided in Appendix 2 to this report). This is particularly the case in terms of the following characteristics: Residents aged 30-59 (53.5% of the Panel compared to 50.9% in the Council’s estimate) Gender (56.1% of the Panel is female compared to 53.6% in the Council’s estimate) Ethnicity (the Council estimates 99.3% of the adult population is white. Excluding ‘not stated’ responses, the Panel has 97.8% white members) Residents in owner occupation (62.6% of the Panel compared to 58% in the Council’s estimate) Page 99
Page 100
However, the principal difference is that the Panel has a higher proportion of who are aged 60+ (37.1% compared to 28.8% in the Council’s estimate). Page 100
Page 101
Appendix 2 Focus group discussion guide Page 101
Page 102
Supplementary Guidance on Pay Day Lending and Betting Offices Premises Focus Group Discussion Guide Introduction Welcome respondents and outline purpose of discussion: Stress the confidentiality of the discussion Your town centre How often do you visit your town centre? What do you visit the town centre for? Overall, how important is it to have a town centre that is ‘vibrant’ and has a positive impact on the well beingwellbeing of the local community? Why do you say that? Prompt: Good for community cohesion Important for the local economy Provides an identity for the town Diverse range of shopping outlets Important community facilities Important business location A ‘vibrant’ town centre What are the characteristics you would associate with a good town centre? Prompt: Good range of shops Pharmacies/health facilities Leisure centres/health clubs Libraries Museums/art galleries Pubs Cafes and restaurants Good open/green spaces Good parking facilities Good public transport What are the characteristics you would associate with a town centre that was not good? Prompt: PDLs BOs Tanning salons Fast food outlets Vacant premises Litter Traffic congestion Page 102
Page 103
Rating your town centre Overall, how would you rate your town centre on these characteristics? What do you regard as the best aspects of your town centre? What do you regard as the worst aspects of your town centre? Prompt: Clustering of PDLs and BOs PDLs What are your views on the presence of PDLs in your town centre? First of all, your positive views. Prompt: They help fill vacant premises They help increase the footfall in the town centre They provide a service for those who can’t access mainstream financial institutions Have you any negative views on the presence of PDLs in your town centre? Prompt: They exploit the most vulnerable by making it too easy to get a loan They charge very high interest rates They are aggressive when pursuing payment There are too many of them They create a bad impression They attract the wrong type of people into the town/put others off They are not good for the well beingwellbeing of local communities BOs What are your views on the presence of BOs in your town centre? First of all, your positive views. Prompt: They help fill vacant premises They help increase the footfall in the town centre They provide a service for those who like to gamble Have you any negative views on the presence of BOs in your town centre? Prompt: They exploit the most vulnerable by making it too easy to gamble There are too many of them They create a bad impression They attract the wrong type of people into the town/put others off They are not good for the well beingwellbeing of local communities Page 103
Page 104
Clustering of PDLs and BOs Do you think that allowing more properties to change their use to become PDLs or BOs would affect the town centre? In what way? Positive prompts: It would be good for the vibrancy and vitality of the town centre It would be good for community well being It would help fill vacant premises It would help increase the footfall in the town centre It would provide a service for those who like to gamble Negative prompts: It would not be good for the vibrancy and vitality of the town centre It would not be good for community well being They exploit the most vulnerable by making it too easy to gamble There are already too many of them They create a bad impression They attract the wrong type of people into the town/put others off Solutions To what extent would you say you were concerned about the clustering of PDLs and BOs in your town centre? Overall, do you think action is needed to curtail the number and clustering of PDLs and BOs in your town centre? What steps do you think should be taken? Prompt: They should be charged higher business rates Planning permission should be refused for a change of use to a PDL or BO Closing remarks Council’s role in pilot scheme to develop supplementary guidance by September for the Scottish Government Thank respondents and end Page 104
Page 105
Appendix 3 Survey Questions Page 105
Page 106
Section 2: Your Town Centre Q7. Which of the following do you regard as your local town centre? Dumbarton (the High Street, including the Artizan Shopping Centre) 01 Clydebank (the Clyde Shopping Centre, Sylvania Way South and the streets near this) 02 Alexandria (Main Street, Bank Street and Mitchell Way) 03 Q8. How often do you visit your local town centre? Daily 01 2-3 times a week 02 Once a week 03 2-3 times a month 04 Once a month 05 Less than once a month 06 Never 07 Q9. How important do you think it is to have a vibrant town centre? Very important 01 Quite important 02 Not very important 03 Not important at all 04 Don’t know 05 Page 106
Page 107
Q10. How important are the following in a vibrant town centre? Very important Quite important Not very important Not important at all Don’t know Wide range of shops 01 02 03 04 05 Fast food outlets 01 02 03 04 05 Pharmacy/health facilities 01 02 03 04 05 Pubs 01 02 03 04 05 Charity shops 01 02 03 04 05 Cafes and restaurants 01 02 03 04 05 Betting offices 01 02 03 04 05 Libraries/museums/art galleries 01 02 03 04 05 Banks 01 02 03 04 05 Good quality shops 01 02 03 04 05 Pay day lenders/pawn brokers 01 02 03 04 05 Green/open spaces 01 02 03 04 05 ‘Pound’ shops 01 02 03 04 05 Leisure facilities (cinema etc) 01 02 03 04 05 Local Government/civic uses 01 02 03 04 05 Page 107
Page 108
Q11. Thinking of your own town centre, how satisfied or dissatisfied are you with the following Very Satisfied Quite Satisfied Neither satisfied nor dissatisfied Quite dissatisfie d Very dissatisfied Don’t Know The range of shops 01 02 03 04 05 06 Fast food outlets 01 02 03 04 05 06 Pharmacy/health facilities 01 02 03 04 05 06 Pubs 01 02 03 04 05 06 Charity shops 01 02 03 04 05 06 Cafes and restaurants 01 02 03 04 05 06 Betting offices 01 02 03 04 05 06 Libraries /museums/art galleries 01 02 03 04 05 06 Banks 01 02 03 04 05 06 Good quality shops 01 02 03 04 05 06 Pay day lenders/pawn brokers 01 02 03 04 05 06 Green/open spaces 01 02 03 04 05 06 ‘Pound’ shops 01 02 03 04 05 06 Leisure facilities (cinema etc) 01 02 03 04 05 06 Local Government/ civic uses 01 02 03 04 05 06 Page 108
Page 109
Pay Day Lenders/Pawn Brokers Q12. To what extent do you agree or disagree with the following statements about pay day lenders/pawn brokers in your town centre? Strongly agree Agree Disagree Strongly disagree Don’t know They are important because they help to fill vacant premises 01 02 03 04 05 They charge very high interest rates 01 02 03 04 05 They make an important contribution to the area by paying business rates 01 02 03 04 05 They make it too easy for vulnerable people to get a loan 01 02 03 04 05 They add to the vitality/vibrancy of the town centre 01 02 03 04 05 There are too many of them 01 02 03 04 05 They provide an important service for those who can’t access mainstream financial institutions 01 02 03 04 05 They attract the wrong type of people into the town/put others off 01 02 03 04 05 They are a valuable employer in the town centre 01 02 03 04 05 They are not good for the well being of the community 01 02 03 04 05 Page 109
Page 110
Betting Offices Q13. To what extent do you agree or disagree with the following statements about betting offices (‘bookies’) in your town centre? Strongly agree Agree Disagree Strongly disagree Don’t know They are important because they help to fill vacant premises 01 02 03 04 05 They make it too easy to gamble 01 02 03 04 05 They make an important contribution to the area by paying business rates 01 02 03 04 05 There are too many of them 01 02 03 04 05 They add to the vitality/vibrancy of the town centre 01 02 03 04 05 They attract the wrong type of people into the town/put others off 01 02 03 04 05 They provide an important service for those who like to gamble 01 02 03 04 05 They are not good for the well being of the community 01 02 03 04 05 They are a valuable employer in the town centre 01 02 03 04 05 Page 110
Page 111
Q14. To what extent are you concerned about the number and clustering of pay day lenders and betting offices in your town centre?Very Concerned Quite Concerned Note Very Concerned Not Concerned at all Don’t know The overall number of pay day lenders and betting offices in the town centre 01 02 03 04 05 The clustering of pay day lenders and betting offices in particular parts of the town centre 01 02 03 04 05 Q15. What would be the effect of more pay day lenders and betting offices being opened in your town centre? Please state whether you agree or disagree with the following statements Very Concerned Quite Concerned Note Very Concerned Not Concerned at all Don’t know It would have a detrimental effect on the vitality and vibrancy of the town centre 01 02 03 04 05 It wouldIt would improve the vitality and vibrancyand vibrancy of the town centre by 01 02 03 04 05 It wouldIt would be bad for the health and well beingwellbeing of the community 01 02 03 04 05 Q16. To what extent do you agree the Council should be able to restrict the number and clustering of pay day lenders and betting offices in your town centre? Strongly agree Agree Disagree Strongly disagree Don’t know 01 02 03 04 05 Page 111
Page 112
Q17. The Council has limited powers to address the number and clustering of pay day lenders andbettingand betting offices in town centres. One option would be to introduce planning policies so the Council would have stronger control over the change of a use of a property into a pay day lender or a betting office. To what extent would you support this option? Strongly support support oppose Strongly oppose Don’t know 01 02 03 04 05 Page 112
Page 113
Appendix 2: Citizens Panel Results 2023 Page 113
Page 114
2023 Citizens Panel Survey Results – Pay Day Lending and Betting Shops Questionnaires were sent out to the members of the citizens panel via an online questionnaire. 282 responses were received..received. The questions were a copy of a selection of questions from the citizens panel survey undertaken in 2015, which provides the background for the original 2016 guidance. While this citizenscitizen’s panel survey could not include all the questions of the original survey, the included questions were used to gauge if attitudes towards Payday lending/pawn shops and betting offices had changed. In the original survey specific questions on hot food takeaways were not included. For consistency Hot food takeaway questions were the same as pay day lending and betting shop questions. Alongside the results to each question there will be a comparison made to the results to the same question in the original 2015 survey. Town Centres Which of the following do you regard as your local town centre Dumbarton Clydebank Alexandria 80 137 65 28% 49% 23% Almost half of respondents (49)%49) % considered Clydebank their local town centre. Slightly over a quarter of respondents (28%) considered Dumbarton their local town centre and slightly under a quarter of respondents (23%) considered Alexandria their local town centre. Importance to a vibrant town centre Very important Quite Important Not very important Not Important at all Don't know Betting offices 1% 5% 24% 62% 7% Pay day lending/pawn shops 1% 3% 17% 71% 8% Pay day lending and betting shops were generally unimportant to a vibrant town centre. Pay day lending/pawn shops had the strongest negative response, with 71% of respondents stating they were “not important at all” and 17% saying they were “not very important”. The response to betting offices was also negative overall, but less strong with 62% of respondents stating they were “not important at all” and 24% saying they were “not very important”. The negative response to Pay day lending/pawn brokers in the 2023 survey was stronger than in the 2015 survey, with 14% more respondents stating they were “not important at all”. A similar proportion of respondents stated they were “very important” or “quite important” in each survey and there was 5% increase in those stating “don’t know” in the 2023 survey. The response to betting offices in the 2023 survey was similar to the 2015 survey, however in the 2016 survey 6% more respondents saidsaid, “don’t know”. “Very important” aspects of a town centre Dumbarton Clydebank Alexandria Hot food takeaways 11% 7% 8% Page 114
Page 115
Betting offices 3% 1% 0% Pay day lending/pawn shops 1% 1% 0% Very few respondents stated that any of the premises asked about were “very important”. A similar proportion of respondents stated that pay day lending/pawn shops and betting offices were “very important” in 2015 and 2023. Pay Day lenders/Pawn Brokers Do you agree or disagree with the following statements about pay day lenders/pawn brokers in your town centre Strongly Agree Agree Disagree Strongly Disagree Don't know Important because they help to fill vacant premises 2% 8% 30% 51% 9% Charge very high interest rates 47% 22% 3% 6% 23% Perform a valuable contribution to the area by paying business rates 2% 20% 25% 31% 22% Make it too easy for vulnerable people to get a loan 54% 28% 1% 6% 11% Add to the vibrancy/vitality of the town centre 1% 5% 24% 61% 9% There are too many of them. 37% 29% 6% 4% 23% Provide an important service to those who can't access mainstream finance 4% 24% 24% 27% 21% Attract anti-social behaviour/put others off. 21% 28% 13% 4% 34% Are a valuable employer in the town centre 2% 13% 32% 26% 27% Are not good for the wellbeing of the community 35% 31% 6% 8% 19% While the exact proportion of responses differ between the 2015 and 2023 surveys the same general trends appeared, specifically agreement or strong agreement that: Make it tooit too easy for vulnerable people to get a loan (90% agreed with this statement in 2015 and 82% in 2023); Charge very high interest rates (76% agreed withagreed with this statement Page 115
Page 116
in 2015 and 69% in 2023); There are too many of them (71% agreed withagreed with this statement in 2015 and 66% in 2023); They are not good for the well beingwellbeing of the community (71% agreed with this statement in 2015 and 71% in 2023). In most cases agreement was lower in 2023 than in 2015, however there is still a majority agreement. There is still a majority disagreeing with the following statements about Pay day lenders/pawn brokers: they add to the vibrancy of the town centre (92% disagreed in 2015 and 85% in 2023);). important for filling vacant premises (88% disagreed this was important in 2015 and 85% in 2023);). They perform a valuable contribution to business rates (62% disagreed with this statement in 2015 and 56% in 2023). Respondents who agree or strongly agree with the following statements about pay day lenders/pawn shop Dumbarton Clydebank Alexandria Important because they help to fill vacant premises 10% 12% 9% Charge very high interest rates 76% 64% 69% Perform a valuable contribution to the area by paying business rates 20% 25% 20% Make it too easy for vulnerable people to get a loan 88% 79% 83% Add to the vibrancy/vitality of the town centre 5% 7% 5% There are too many of them. 63% 72% 58% Provide an important service to those who can't access mainstream finance 18% 31% 37% Attract anti-social behaviour/put others off. 53% 49% 43% Are a valuable employer in the town centre 13% 17% 15% Are not good for the wellbeing of the community 66% 69% 63% Betting Offices Do you agree or disagree with the following statements about Betting Offices Agree Strongly Agree Disagree Strongly Disagree Don't know Are important because 16% 3% 36% 38% 7% Page 116
Page 117
they help to fill vacant premises Make it too easy to gamble 30% 48% 11% 3% 7% Make an important contribution to the area by paying business rates 32% 2% 26% 19% 21% Are too many of them 32% 38% 9% 2% 18% Add to the vitality/ vibrancy of the town centre 9% 1% 41% 38% 11% Attract anti-social behaviour/put others off. 29% 22% 18% 2% 28% Provide an important service for those who like to gamble 36% 5% 22% 21% 16% Are not good for the wellbeing of the community 33% 35% 10% 5% 16% Are a valuable employer in the town centre 24% 4% 23% 24% 25% While the exact proportion of responses differ between the 2015 and 2023 surveys the same general trends appeared, specifically agreement or strong agreement that: There are too many of them (80% of participants agreed or strongly agreed in 2015 and 70% in 2023) They make it too easy to gamble (79% of participants agreed or strongly agreed in 2015 and 78% in 2023) They are not good for the wellbeing of the community (66% of participants agreed or strongly agreed in 2015 and 68% in 2023) There was mostly disagreement or strong disagreement that They added vitalityadded vitality and vibrancy to their town centre (85% disagreed in 2015 and 71% in 2023) They were important because they help to fill vacant premises (81% disagreed in 2015 and 74% in 2023) Respondents who agree or strongly agree with the following about betting offices: Dumbarton Clydebank Alexandria Are important because they help to fill vacant premises 24% 17% 15% Make it too easy to gamble 83% 77% 74% Make an important contribution to the area by 35% 31% 42% Page 117
Page 118
paying business rates Are too many of them 65% 74% 71% Add to the vitality/vibrancy of the town centre 14% 7% 11% Attract anti-social behaviour/put others off. 51% 55% 43% Provide an important service for those who like to gamble 45% 37% 45% Are not good for the wellbeing of the community 64% 74% 65% Are a valuable employer in the town centre 34% 23% 32% There The Number of Pay Day Lenders/Pawn Shops and Betting offices Are you concerned about the number and clustering of pay day lenders and betting offices in your town centre? Not concerned at all Not very concerned Quite concerned Very concerned Don't know Number of betting offices in the town centre 5% 20% 40% 26% 8% Number of pay day lending/pawn shops in the town centre 5% 19% 39% 23% 14% Over 60% or respondents were either quite concerned or very concerned about the number of pay day lending/pawn shops and betting offices in their town centre in the 2023 survey. This is the majority of respondents however the proportion of respondents concerned is down from 75% in the 2015 survey Respondents who are “quite concerned” or “very concerned” about the number of pay day lending and betting offices Dumbarton Clydebank Alexandria Betting offices 54% 72% 71% Pay day lending/pawn shops 46% 72% 62% Respondents in Clydebank and Alexandria were significantly more concerned than Page 118
Page 119
respondents in Dumbarton Effect of more pay day lending and betting in the Town Centre Strongly Agree Agree Disagree Strongly Disagree Don't know Would have a detrimental effect oneffect on the vitality and vibrancy of the town centre 45% 38% 2% 1% 13% Would improve the vitality and vibrancyand ofvibrancy of the town centre by increasing footfall 3% 4% 43% 38% 12% Would beWould be bad for the health and well beingwellbeing of the community 40% 41% 4% 0% 15% Respondents in 2023 had a similar view to respondents in 2015, that more pay day lenders and betting would be detrimental to the town centre and bad for the health and wellbeing of the community. Agree or strongly agree with statements on the effect of more pay day lending and betting on town centres Dumbarton Clydebank Alexandria Would have a detrimental effect oneffect theon vitalitythe andvitality and vibrancy of the town centre 83% 81% 89% Would improve the vitality and vibrancyand ofvibrancy theof townthe town centre by increasing footfall 9% 8% 3% Would beWould badbe bad for the health and well beingwellbeing of the community 84% 80% 82% The proportion of users of different town centres agreeing or strongly agreeing with all of the above statements is very similar. A slightly larger proportion of users of Alexandria town centre agreed they would have a detrimental effect on vitality and vibrancy of the town centre. A slightly lower proportion of users of Alexandria town centre agreed they would improve vibrancy and vitality by increasing footfall. Page 119
Page 120
Appendix 3: Betting Office and Pay day loan customer count Introduction This research provides background information in support of the Pay Day Lending and Betting Shops Planning Guidance. The guidance will assist in the decision making of planning applications for pay day lending and betting shops. It was considered it would be useful to establishto establish what contribution pay day lending and betting shops make to footfall in Clydebank and Dumbarton town centres in comparison to other town centre uses. Survey methodology A total of 6 units were surveyed in each town centre across the typical shopping hours of 9.30am - 5.30pm and extended to count evening footfall generated by betting shops. This was carried out on a Thursday 10th September and Saturday 12th September in Clydebank; and Saturday 19th September and Thursday 1st October in Dumbarton; two days for each town centre. Of the 6 units surveyed in each town centre, a betting office and pay day lender were included, as well as 4 other retail/commercial related uses (see charts below). The method was to count the number of people entering each unit, with some exclusions such as young children, staff and postal workers. Surveys were based on a 10 minute10-minute count per unit per hour, and therefore do not reflect the actual footfall count for the day. However, the results have been weighted to reflect what an average count for the day would have been, based on the 10-minute results. The weighted results can be seen in the charts below. A further evening count of the betting offices was undertaken to gauge footfall coming into the centre after normal shop opening hours. The survey was undertaken by Council staff. Footfall results Figures 1 and 2 show the Clydebank results for each day. On Thursday the betting office was the fourth busiest shop, with the charity shop, newsagent and bakery attracting more customers. On Saturday, the betting office was the 2nd busiest unit, with the highest number of customers visiting the newsagent. For both survey days, the pawnbroker attracted the least customers of all six units. It should be noted that the bank on both days closed earlier than the other stores (4.30pm on Thursday and Page 120
Page 121
3.30pm on Saturday), as did the pawnbroker on the Thursday count (4.30pm). Results have been weighted to reflect the average count for that day Figure 1 *Bank and Pawnbroker closed during last hour of count (4.30pm - 5.30pm) Page 121
Page 122
1Figure 2 *Bank closed during last two hours of count (3.30pm - 5.30pm) Figures 3 - 5 show the results for Dumbarton. Thursday’s footfall was of a similar pattern to Clydebank, the betting shop was the fourth busiest unit when compared to the others. On Saturday morning the betting shop faired the busiest with higher footfall than the other units surveyed. In the afternoon this dropped to the third highest footfall. The pawnbroker took the second lowest footfall on Thursday with only the card shop taking less. On Saturday the pawnbroker had the lowest footfall for both morning and afternoon. There are two separate charts displayed for Saturday. This is due to the bank closing at midday, and for the afternoon a public house was surveyed instead. Figure 3 Page 122
Page 123
Figure 4 Figure 5 Evening count This provided evidence of the footfall attracted into the centres during evening hours, after the Page 123
Page 124
typical closing hours of other stores. Betting shops in both town centres were open late into the evening. In Clydebank two betting shops were surveyed for half hour periods between 5.30pm and 7and 7pm on Thursday 12 September. In Dumbarton. A single betting shop was surveyed between 5.30pm and 7.00pm on Thursday 1 October, with numbers recorded for half hour periods. Summary From the results above, it is demonstrated that the betting offices attract a similar and at times higher footfall than that of other high street retailers/commercial users. It is also evident that such uses attract footfall into the early evening. Generally speaking, the pawnbrokers did not have many customers in comparison to other high street occupiers. Page 124
Page 125
Customer count - actual recorded results Clydebank: Thursday 10th September Weather conditions: Good, generally sunny throughout Hour: 9.30 - 10.30 Hour: 10.30 - 11.30 Hour: 11.30 - 12.30 Unit Tally Unit Tally Unit Tally Clydesdale Bank 7 Clydesdale Bank 5 Clydesdale Bank 3 Paddy Power 4 Paddy Power 8 Paddy Power 11 British Heart Foundation 5 British Heart Foundation 13 British Heart Foundation 22 H & T Pawn 2 H & T Pawn 1 H & T Pawn 3 RS McColl 14 RS McColl 11 RS McColl 16 Greggs 8 Greggs 11 Greggs 22 Hour: 12.30 - 13.30 Hour: 13.30 - 14.30 Hour: 14.30 - 15.30 Unit Tally Unit Tally Unit Tally Clydesdale Bank 7 Clydesdale Bank 4 Clydesdale Bank 4 Paddy Power 10 Paddy Power 8 Paddy Power 5 British Heart Foundation 12 British Heart Foundation 7 British Heart Foundation 3 H & T Pawn 1 H & T Pawn 2 H & T Pawn 2 RS McColl 14 RS McColl 10 RS McColl 7 Greggs 18 Greggs 13 Greggs 3 Hour: 15.30 - 16.30 Hour: 16.30 - 17.30 Unit Tally Unit Tally Clydesdale Bank 10 Clydesdale Bank CLOSED Paddy Power 2 Paddy Power 5 British Heart Foundation 2 British Heart Foundation 1 H & T Pawn 1 H & T Pawn CLOSED RS McColl 9 RS McColl 10 Greggs 3 Greggs 3 Clydebank: Thursday 10th September, evening count Weather conditions: Good, light Time 17.30 - 18.00 Unit Ladbrokes Tally 9 18.00 - 18.30 Paddy Power 10 18.00 - 18.30 Ladbrokes 3 Page 125
Page 126
Customer count -actual recorded results Clydebank: Saturday 12th September Weather conditions: Overcast, occasional rain Hour: 9.30 - 10.30 Hour: 10.30 - 11.30 Hour: 11.30 - 12.30 Unit Tally Unit Tally Unit Tally Royal Bank of Scotland 16 Royal Bank of Scotland 13 Royal Bank of Scotland 16 Paddy Power 5 Paddy Power 17 Paddy Power 16 British Heart Foundation 6 British Heart Foundation 12 British Heart Foundation 10 H & T Pawn 1 H & T Pawn 0 H & T Pawn 2 RS McColl 21 RS McColl 21 RS McColl 22 Greggs 6 Greggs 10 Greggs 12 Hour: 12.30 - 13.30 Hour: 13.30 - 14.30 Hour: 14.30 - 15.30 Unit Tally Unit Tally Unit Tally Royal Bank of Scotland 10 Royal Bank of Scotland 6 Royal Bank of Scotland 13 Paddy Power 17 Paddy Power 13 Paddy Power 22 British Heart Foundation 19 British Heart Foundation 16 British Heart Foundation 10 H & T Pawn 1 H & T Pawn 4 H & T Pawn 1 RS McColl 14 RS McColl 14 RS McColl 10 Greggs 8 Greggs 23 Greggs 7 Hour: 15.30 - 16.30 Hour: 16.30 - 17.30 Unit Tally Unit Tally Royal Bank of Scotland Paddy Power x 4 Royal Bank of Scotland Paddy Power x 13 British Heart Foundation 9 British Heart Foundation 9 H & T Pawn 0 H & T Pawn 1 RS McColl 13 RS McColl 12 Greggs 10 Greggs 5 Page 126
Page 127
Customer count -actual recorded results Dumbarton: Saturday 19th SeptemberWeather conditions: Cloudy Hour: 9.30 - 10.30 Hour: 10.30 - 11.30 Hour: 11.30 - 12.30 Unit Tally Unit Tally Unit Tally Ramsdens 1 Ramsdens 2 Ramsdens 4 Bank of Scotland 12 Bank of Scotland 17 Bank of Scotland 18 Superdrug 6 Superdrug 1 Superdrug 9 William Hill 14 William Hill 20 William Hill 27 Farmfoods 10 Farmfoods 2 Farmfoods 16 Hallmark & Thorntons 0 Hallmark & Thorntons 7 Hallmark & Thorntons 6 Hour: 12.30 - 13.30 Hour: 13.30 - 14.30 Hour: 14.30 - 15.30 Unit Tally Unit Tally Unit Tally Ramsdens 4 Ramsdens 5 Ramsdens 0 Bank of Scotland 5 Bank of Scotland 3 Bank of Scotland 3 Superdrug 5 Superdrug 3 Superdrug 10 William Hill 8 William Hill 8 William Hill 6 Farmfoods 13 Farmfoods 12 Farmfoods 4 Hallmark & Thorntons 2 Hallmark & Thorntons 0 Hallmark & Thorntons 5 Hour: 15.30 - 16.30 Hour: 16.30 - 17.30 Unit Tally Unit Tally Ramsdens 2 Ramsdens 0 Bank of Scotland 5 Bank of Scotland 2 Superdrug 5 Superdrug 4 William Hill 1 William Hill 4 Farmfoods 9 Farmfoods 7 Hallmark & Thorntons 4 Hallmark & Thorntons 1 Page 127
Page 128
Customer count -actual recorded results Dumbarton: Thursday 1st October Weather conditions: Foggy start, clear/sunny for remainder Hour: 9.30 - 10.30 Hour: 10.30 - 11.30 Hour: 11.30 - 12.30 Unit Tally Unit Tally Unit Tally Ramsdens 1 Ramsdens 0 Ramsdens 3 Bank of Scotland 16 Bank of Scotland 22 Bank of Scotland 12 Superdrug 2 Superdrug 8 Superdrug 6 Farmfoods 8 Farmfoods 10 Farmfoods 25 Hallmark & Thorntons 0 Hallmark & Thorntons 1 Hallmark & Thorntons 2 William Hill 1 William Hill 1 William Hill 2 Hour: 12.30 - 13.30 Hour: 13.30 - 14.30 Hour: 14.30 - 15.30 Unit Tally Unit Tally Unit Tally Ramsdens 2 Ramsdens 3 Ramsdens 3 Bank of Scotland 18 Bank of Scotland 17 Bank of Scotland 7 Superdrug 9 Superdrug 8 Superdrug 9 Farmfoods 10 Farmfoods 20 Farmfoods 15 Hallmark & Thorntons 4 Hallmark & Thorntons 1 Hallmark & Thorntons 1 William Hill 6 William Hill 3 William Hill 11 Hour: 15.30 - 16.30 Hour: 16.30 - 17.30 Unit Tally Unit Tally Ramsdens 0 Ramsdens 2 Bank of Scotland 9 Bank of Scotland 8 Superdrug 4 Superdrug 2 Farmfoods 15 Farmfoods 18 Hallmark & Thorntons 1 Hallmark & Thorntons 0 William Hill 3 William Hill 4 Dumbarton: Thursday 1st October, evening countWeather conditions: Good, light Time 17.30 - 18.00 Unit William Hill Tally 10 18.00 - 18.30 William Hill 10 Page 128
Page 129
18.00 - 18.30 William Hill 9 Page 129
Page 130
Pay day lending and betting shops Draft Planning Guidance Consultation Report ITEM 7 - APPENDIX 3 Page 130
Page 131
Introduction This report presents analysis of the results of the Draft Pay Day Lending and Betting Shop planning guidance consultation and the changes to the guidance resulting from the feedback. The consultation took place between 13th May and 5th July 2024 and took the form of an online survey. The survey was circulated to the Local Development Planning Mailing list, promoted on the council’s social media, and circulated to the Council’s Citizen Panel. Responses are also made to individual comments provided in the survey. Some comments go beyond the remit of the planning system and advice has been sought from legal colleagues with regard to the licencing of gambling premises where necessary. Key Findings and Changes The survey received 17 responses. All respondents identified themselves as individuals, with none identifying as community councils, community groups, businesses, or agents. Summary of Views The table below presents the responses to the “yes or no” questions in the survey. Yes No No Response Is the summary of the evidence and local context within the guidance clear and appropriate? 16 1 - Do you consider a cap on the number of pay day lending and betting shops within town centres to be appropriate? 15 2 - The current version of this guidance only applies to core retail areas of Clydebank and Dumbarton Town centres. This updated guidance will apply to whole town centre areas. Is this appropriate? 16 1 - The current version of this guidance does not apply to Alexandria Town Centre. This updated guidance will apply to Alexandria Town Centre. Is this appropriate? 17 0 - Is the application of NPF4 policy 27 part C clear? 15 1 1 Have the existing clusters of pay day lending and betting shops within town centres been correctly identified? 15 2 - Is the application of LDP2 policy SC2 Criteria and SC3 clear? 16 1 - Is the approach to applying policy SC4 (Local Centres) in relation to pay day lending and betting offices appropriate 15 2 - Is the application of LDP2 policy SC4 clear? 16 1 - The majority of respondents agreed that the summary of evidence was appropriate, that applying a cap within town centres is appropriate, clusters of pay day lending and betting shops have been correctly identified and that the application of policy is clear. Page 131
Page 132
Respondents were given the opportunity to provide additional information to support their answers. The main criticisms of the guidance include: The evidence does not include information on pay day lending and betting shops outside of the town centre and so does not provide the full context. The guidance should apply to the whole of West Dunbartonshire. Limiting application of the policy to town centres means these uses could be pushed out into local centres, or other locations. As drafted the guidance allows for zero pay day lenders in Alexandria, which is not overprovision. Application of Local Development Plan 2 Policies does not align with National Planning Framework 4 (NPF4). The guidance demonstrates prejudice against these uses by the council. Summary of Changes As a result of the consultation responses the following changes have been made to the background information and guidance document. The Following changes have been made to the background information document: Additional information has been added on the number of pay day lending and betting shops in Local Centres (Dalmuir, Hardgate, and Glasgow Road in Dumbarton) and in other locations outside of designated centres. Maps for Dumbarton and Clydebank updated to reflect most up to date town centre surveys. The number of betting shops in Clydebank has been updated following up to date town centre surveys. An amusement arcade, categorised as a betting office in error, has been removed from the count. The following changes have been made to the guidance Information on pay day lending and betting shops within local centres has been added. The number of betting offices in Clydebank in table 1 has been updated to reflect the number in the background information. Greater emphasis has been placed on National Planning Framework 4 as the most up to date part of the development plan in West Dunbartonshire. Amended the application of NPF4 Policy 27 to clarify that the cap on pay day lending and betting uses is a cap on both uses in combination. College Way has been removed from the description of the cluster in Dumbarton Town Centre, as one premises was moved from College Way to High Street. Application of Policy SC4 from Local Development Plan 2, relating to Local Centres, has been changed to place a cap on the number of pay day lending and betting shops that will be supported by the Council in Local Centres. Detailed Views and Council Responses Question 1: Is the summary of the evidence and local context within the guidance clear and appropriate? In response to this question 16 said “yes”, agreeing that the evidence and local context in the guidance was clear and appropriate and with one response stating no. Page 132
Page 133
Is there other evidence we should consider? Five respondents provided additional comments on the evidence: 1. The document reads as if the council has already made up its mind. 2. The guidance should address pay day lending and betting shops in West Dunbartonshire as a whole, not just within town centres, including Dalmuir and North Kilbowie. The guidance should consider these premises within walking distance of people’s homes and Policy 15 (Local Living and 20-minute neighbourhoods) of NPF4. 3. Addressing issues with gambling and pay day lending goes beyond the remit of planning. There is a need to identify all types of gambling in the area, such as fruit machines in pubs and restaurants and consider factors such as the age of users and cost, profit and winnings ratios. 4. The Council could limit the proportion of commercial units that are pay day lending and betting uses for example, one in 50 premises. 5. Money spent at these premises leaves the local economy 6. Gambling can cause extreme distress to families. The Council’s responses to comments 1. To ensure support for this type of planning control still exists, the council asked its Citizens Panel and found there is still support for controlling them as they are not good for community wellbeing and town centres have a high number of them. The results of the Citizen Panel surveys can be seen in the Background Information supporting the guidance. 2. The guidance targeted town centres as these locations are where the issues of number and clustering of these premises are most acute. We accept that premises in local centres may be the most accessible form of gambling and pay day lending in some neighbourhoods. We have updated the guidance and Background Information to include the level of provision in local centres to support decision making. The Council has not yet finalised an approach towards Local Living in West Dunbartonshire and will do so through the preparation of the new Local Development Plan, however the Background Information has been updated to note the locations of premises outside designated town and local centres. We also note that other policies will apply regarding planning applications for these, not just those within this guidance. 3. The Council agree that problem gambling cannot be fully addressed through planning controls as there are many different factors at play. However, the evidence suggests that easier access to gambling leads to more gambling, and that when people moved further away from opportunities to gamble, they gambled less. The guidance aims to limit the prevalence of gambling in certain locations. Licensing of betting shops is another function of the Council, under the Gambling Act 2005, and the planning team has been keeping licensing colleagues informed throughout the process of updating the guidance. Licensing does not seek to restrict gambling, instead it regulates it and indeed, permits it so far as it complies with the Gambling Act 2005. Gaming machines in pubs are authorised by virtue of a concept called Page 133
Page 134
"automatic entitlement". If a premises with an alcohol licence under the Licensing (Scotland) Act 2005 meets certain requirements, for example, it has a bar, then it can have up to two gaming machines provided it notifies the Licensing Board. It can request more, however the Licensing Board's power to refuse the additional machines is limited. 4. Restricting the proportion of pay day lending and betting shops relative to other uses was an option considered by the Council and similar approaches have been taken elsewhere. Given that town centres are currently going through a change of the types of uses within it and proposals may change the number of units (for example changes to Mitchell Way in Alexandria, and proposals for the Artizan Centre in Dumbarton) this does not necessarily provide a clear limit to the number of pay day lending and betting uses. 5. We acknowledge that betting shops are typically national chains, and that means some of the money spent there is removed from the local economy. 6. We acknowledge the distress caused by problem gambling to individuals and their families. It forms part of the rationale for the guidance. Question 2: Do you consider a cap on the number of pay day lending and betting shops within town centres to be appropriate? In response to this question 15 said “yes” agreeing that the evidence and local context in the guidance was clear and appropriate and with two responses stating no. If no, why not? Two respondents, who answered no to the question above, made the following comments: 1. Agree with the pay day lending cap, however consumers should have the freedom to choose and there is online ability of gambling irrespective of physical shops. 2. Alexandria is set at zero payday lenders. Adding one more, for a total of one, wouldn’t be overprovision. Setting it at zero highlights WDC's prejudice. The Council’s responses to comments 1. The benefits of competition are recognised, and we acknowledge the prevalence of online gambling will not be affected by this guidance. 2. The guidance is intended to address Pay Day Lending and Betting Shops in combination. The citizens panel evidence suggests both of these uses harm the character and amenity, and town centre surveys show they cluster in the same locations. It has been clarified within the finalised version that the cap applies to the combined total of these uses. Question 3: The current version of this guidance only applies to core retail areas of Clydebank and Dumbarton Town centres. This updated guidance will apply to whole town centre areas. Is this appropriate? In response to this question 16 said “yes” agreeing that the evidence and local context in the guidance was clear and appropriate and with one response stating no. If no, why not? One respondent, who answered no to the question above, made the following comments: Page 134
Page 135
1. Agree that the scope should be wider than the current guidance, however, should be widened further to include all settlements with small centres, otherwise betting shops will relocate to these locations, where the guidance has less influence. The Council’s responses to comments 1. The guidance has been revised to provide additional information on prevalence of betting shops in local centres to aid decision making. The revision also states a level of provision for these uses in local centres, beyond which applications for further provision of these uses will not be supported. It should be noted that under NPF4 Policy 27, restrictions of these uses can only be applied where “further provision of these uses undermine the character and amenity of the area or the health and wellbeing of communities”. This means guidance cannot apply a blanket restriction of these uses in all locations in West Dunbartonshire. Question 4: The current version of this guidance does not apply to Alexandria Town Centre. This updated guidance will apply to Alexandria Town Centre. Is this appropriate? All respondents answered “yes” to this question. If no, why not? There were no further comments on this question. Question 5: Is the application of NPF4 policy 27-part C clear? In response to this question 15 said “yes” agreeing application of NPF4 policy is clear, with one response stating “no”, and one respondent providing no answer to this question. If no, why not? One respondent, who answered no to the question above, made the following comment: 1. Policy 27 applies to City, town, local and commercial centres while application of this policy in the guidance narrows the focus of the policy on town centres. The Council’s responses to comments 1. The focus of the guidance is on town centres as this is where numbers of pay day lending and betting shops are highest and clustering is most acute. However, additional information has been added to the Background Information document to include the number of premises within Local Centres and a cap has also been provided on the number of these premises in local centres to provide clarity and address the concern of these uses being “pushed out” from town centres and concentrating in smaller centres, as has been raised in the answers to other consultation questions. Question 6: Have the existing clusters of pay day lending and betting shops within town centres been correctly identified? In response to this question 15 said “yes” agreeing clusters have been properly identified with two responses stating “no”. If not, can you identify other clusters that should have been included? Two respondents, who answered no to the question above, made the following comments: 1. All town, local, and commercial centres in the whole authority should be considered within the guidance, or there is risk these uses will be pushed out to smaller local and commercial centres. Page 135
Page 136
2. The number of betting shops within the wider Clydebank area has been underrepresented, with shops in Dalmuir, North Kilbowie, Yoker, and Hardgate. 3. One shop in Dumbarton has been moved. The Council’s responses to comments 1. The guidance has been updated to include further information on the prevalence of premises in local centres and elsewhere. A cap has also been provided on the number of these premises in local centres to provide clarity and address the concern of these uses being “pushed out” from town centres and concentrating in smaller centres. 2. Betting shops within the listed locations are noted and further information has been added to the guidance and background information. 3. Locations of betting shops have been reviewed to check for correct locations. The maps in the background information have been updated. Question 7: Is the application of LDP2 policy SC2 Criteria and SC3 clear? In response to this question 16 said “yes” agreeing LDP2 policies have been clearly applied with one response stating “no”. If not, how can it be made clearer? Respondents who answered no to the question above, made the following comments: 1. The terminology of these policies does not align with NPF4, making it difficult to understand. The Council’s responses to comments 1. While the policies in NPF4 and LDP2 use different language the council is not of the view that they are incompatible. LDP2 is still a material consideration, so despite the differences in terminology, the council considers it should still form part of the guidance. This section identifies where existing clusters of these uses exist, and also that additional footfall and filling a vacant unit will be lesser considerations, compared to amenity, character and health and wellbeing. In the council’s view this aligns with the policy intent of NPF4. Question 8: Is the approach to applying policy SC4 (Local Centres) in relation to pay day lending and betting offices appropriate? In response to this question 15 said “yes” agreeing clusters have been properly identified with two responses stating “no”. If no, why not? Respondents who answered no to the question above made the following comments: 1. Application of the policy in the guidance appears to be prejudiced. 2. This section of the guidance is very unclear. It needs to be made more accessible and described in plain English. The Council’s responses to comments 1. As mentioned previously, the Background information contains the views of residents of West Dunbartonshire which the Council believes justifies the restriction of Pay Day Lending and Betting Shops. 2. To provide additional clarity the guidance has been amended to place a firm cap on the number of these uses on local centres. Page 136
Page 137
Question 9: Is the application of LDP2 policy SC4 clear? In response to this question 16 said “yes” agreeing LDP2 policy SC4 have been clearly applied with one response stating “no”. If no, why not Respondents who answered no to the question above made the following comments: 1. Policy appears to promote that betting shops may be acceptable in areas outside of town centres. 2. The guidance lacks clarity, meaning it will be open to interpretation and dispute in decision making. 3. The guidance highlights that LDP2 is the council’s most up to date spatial strategy, but not that NPF4 is the national strategy. 4. NPF4 needs to be read as a whole, policies should not be isolated from one another. The Council’s responses to comments 1. NPF4 Policy 27 states that development of these premises is not supported where they undermine the character, amenity, and health and wellbeing of the area because of further provision. Currently evidence suggests that the overprovision is taking place in town centres. The section on local centres has been amended to prevent the overprovision in these locations as a result of restrictions in the town centres. It should be noted however that Pay day lending and betting shops may be acceptable in locations where there is not overprovision. 2. Majority of respondents agreed that the guidance was clear, however changes have been made for clarity, in particular to the section on local centres, where a cap has been placed on the acceptable number of these uses. 3. The section on NPF4 in the guidance has been amended to emphasize that it is the national strategy and the most up to date part of the development plan. LDP2 is still a material consideration in planning decisions, however as previously stated, the Council does not view it as incompatible with NPF4 with regard to non-retail uses. 4. The council agrees that NPF4 needs to be read as a whole in any planning decision, however the purpose of the guidance is to provide greater detail on a specific issue at a local level. Other policies and guidance will still be considered where relevant to the application in question. Question 10: Additional Comments The following additional comments were made in relation to the guidance 1. The guidance does not tackle the root cause of addiction and problem gambling. 2. Information on the usage of payday loans in the area would be interesting. 3. The claim that betting shops are not footfall generators is anecdotal and not evidenced. 4. The guidance is not based on robust evidence. 5. The cap on pay day lending and betting shops in the town centre should be more restrictive. 6. William Hill has two shops in Dumbarton. One should be made to close. If replaced by another bookmaker, it would increase competition. 7. Shops should have signs outside to provide advice to gamblers. The Council’s responses to comments 1. The council acknowledges that the guidance will not tackle all issues surrounding gambling, however the evidence suggests that greater access to gambling increases occurrence of gambling. The guidance aims to address this issue by limiting the Page 137
Page 138
number of betting offices in places where these are overprovided, and to address of the effects on character and amenity of the area. 2. The Council is not aware of the use of any data showing the use of pay day loans at a local level. 3. The Background Information document include the results of a footfall survey which took place in Clydebank and Dumbarton in 2016. These counted footfall during a weekday and a Saturday. The survey showed that betting shops offered similar footfall to retail uses. Pay day lending shops attracted very low footfall. Counts also took place in the evening to ascertain if the later opening hours of betting shops attracted significant footfall in the evening. The Council does not consider that the level of footfall attracted by these uses outweighs the impact on health, wellbeing, amenity and character of the area. 4. The Background information document contains evidence on higher numbers of betting shops within West Dunbartonshire, deprivation within the area, and the impacts these uses have on health and wellbeing. The citizens panel survey provides evidence from users of the town centres that the number and clustering of them have a negative effect on vitality of the town centre. Footfall surveys undertaken in Dumbarton and Clydebank demonstrate that betting shops do not attract significantly greater footfall than other town centre uses, and that footfall generated by pay day lenders is low. The Council considers this evidence to be sufficient in justifying restrictions on these uses. 5. The proposed cap is based on the current level of provision. The council considers this to be justified by the available evidence, mainly the views of the Citizens Panel. We do not currently believe that our evidence can robustly support a lower cap. 6. The Council is not able to use the planning system to force specific operators to close, nor could it refuse an applicant on the basis it already operates in a specific area. The planning system regulates the use of land and buildings, not the individuals or companies involved in the use. With regards to regulation through the Gambling Act 2005, any complaint around premises already operating would require to be underpinned by evidence that demonstrate that the premise is no longer operating in a manner consistent with the Gambling Act 2005. 7. Gambling premises licence holders are required to provide information through leaflets and signage on help with gambling and how to exclude yourself by the Gambling Commission's Licence Conditions and Codes of Practice. It also requires licence holders to have policies around “interactions”, where staff in gambling premises should interact with customers to identify if that customer is gambling responsibly. Page 138
Page 139
AssessmentNo 715 Owner cameron.clow Resource Regeneration, Environment and Growth Service/Establishment Regeneration First Name Surname Job title Head Officer Cameron Clow Development Planning and Place Office (include job titles/organisation) Members Cameron Clow Alan Williamson (Please note: the word 'policy' is used as shorthand for stategy policy function or financial decision) Policy Title Revision of planning guidance for Pay Day Lending and Betting Shops The aim, objective,purpose and intended out come of policy The guidance places planning controls on applications for the stated uses, due to the correlation of these uses with deprivation and problem gambling, and debt and negative health outcomes. The update to the guidance is expected to reflect National Planning Framework 4, which restricts payday lending and betting shops Service/Partners/Stakeholders/service users involved in the development and/or implementation of policy. Licensing, environmental health, and communities. Does the proposals involve the procurement of any goods or services? No If yes please confirm that you have contacted our procurement services to discuss your requirements. No SCREENING You must indicate if there is any relevance to the four areas Duty to eliminate discrimination (E), advance equal opportunities (A) or foster good relations (F) No Relevance to Human Rights (HR) No Relevance to Health Impacts (H) Yes Relevance to Social Economic Impacts (SE) Yes Who will be affected by this policy? Users of pay day lending and betting offices on high streets. Potential economic impacts on town center areas due to restrictions of uses. Who will be/has been involved in the consultation process? Questions on the above uses and their impacts (positive or negative) has been put to the citizen’s panel. A draft of the guidance will be consulted on with the wider public. Please outline any particular need/barriers which equality groups may have in relation to this policy list evidence you are using to support this and whether there is any negative impact on particular groups. Needs Evidence Impact Age Males between 16 and 24 are more likely to be problem gamblers. Literature indicates that this group is more likely to have a gambling problem and that opportunities for Restricting betting shops in town centres will reduce the opportunities to gamble. ITEM 7 - APPENDIX 4 Page 139
Page 140
gambling (accessibility) increases gambling problems. Cross Cutting Disability Social & Economic Impact Short term loans are often used to bridge the gap to the next pay-check. Gambling premises concentrate in more deprived areas. Impacts on economy of town centres due to restricted uses. Typical user of payday loans earns less than £20k a year. Lower income households are less likely to hold debt, but are more likely to have debt problems. Concentration of gambling premises and machines are disproportionately in deprived areas. Problem gambling can have an effect on household finances Cross cutting with health, due to health inequalities. Sex Males between 16 and 24 are more likely to be problem gamblers. Literature indicates that this group is more likely to have a gambling problem and that opportunities for gambling (accessibility) increases gambling problems. Restricting betting shops in town centres will reduce the opportunities to gamble. Gender Reassign Health Mental and physical wellbeing. Problem debt impacts mental wellbeing, with relationship between debts and negative health outcomes including mental disorder, suicide attempts, problem drinking, drug dependence, depression, OCD, panic disorder, anxiety. Debt results in poor health outcomes, but also Restricting payday lending and betting shops potentially reduces access and therefor use of these premises. Page 140
Page 141
people with poor health are more likely to be in debt. Problem gambling can strain household finances and relationships, so can impact mental health. Human Rights Marriage & Civil Partnership Pregnancy & Maternity Race Religion and Belief Sexual Orientation Actions Policy has a negative impact on an equality group,but is still to be implemented, please provide justification for this. Policy is expected to have a positive effect on groups effected by the proliferation of these use types. There is expected to be some economic impacts resulted from restricting the uses allowable in town centres, however it is expected to make the overall town centre areas more attractive, by avoiding concentrations of these uses. Betting shops have declined nationally anyway as a result of changes in regulations to the gambling industry and the movement to online gambling, however the concentration of them is still higher in West Dunbartonshire than in comparable areas. Payday lending shops have also declined nationally due to other forms of regulation. Will the impact of the policy be monitored and reported on an ongoing bases? The prevalence of these uses in town centers will be monitored via the annual town center outlet survey. Q7 What is you recommendation for this policy? Intoduce Please provide a meaningful summary of how you have reached the recommendation West Dunbartonshire has a socio-economic profile which is vulnerable to problem gambling and high interest lending and the corresponding impacts this has on health and wellbeing. Despite the reduction in pay day lenders and betting shops nationally, due to changes in regulation and access to online services, the number within the districts town centers has remained similar. The results of a citizen panel survey show that more of these uses in town centers is undesirable users of the town center. Restrictions of these uses will prevent further proliferation and access to them. Page 141