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. Page 1 ITEM 7
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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 Page 2
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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. Page 3
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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 Page 4
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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 Page 5