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Item 7 - Pay Day Lending and Betting Shop Guidance

West Dunbartonshire Council · 11 September 2024
Back to Planning Committee — 11 September 2024 and its agenda

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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.
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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
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 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.
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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
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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
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