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West Dunbartonshire Council · 14 February 2024
Back to Planning Committee — 14 February 2024 and its agenda

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Agenda
Planning Committee
Date:  Wednesday, 14 February 2024
___________________________________________________________________
Time:  10.00 
___________________________________________________________________
Venue:  Civic Space, Council Offices, 16 Church Street, Dumbarton, G82 1QL.
___________________________________________________________________
Contact:   Email: 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
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Distribution:-
Councillor Lawrence O’Neill (Chair)
Councillor Gurpreet Singh Johal (Vice Chair)
Councillor Ian Dickson
Councillor Daniel Lennie
Provost Douglas McAllister
Councillor June McKay
Councillor Karen Murray Conaghan
Councillor Chris Pollock
Councillor Hazel Sorrell
Councillor Sophie Traynor
All other Councillors for information
Date of Issue: 1 February 2024
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PLANNING COMMITTEE
WEDNESDAY, 14 FEBRUARY 2024
AGENDA
1 APOLOGIES
2 DECLARATIONS OF INTEREST
Members are invited to declare if they have any interests in 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 MEETINGS     5 - 23
Submit for approval, as correct records, the following Minutes of Meetings of
the Planning Committee: 
(a) Ordinary meeting – 6 December 2023; and
(b) Special meeting – 17 January 2024.
5 NOTE OF VISITATIONS  25 
Submit, for information, Note of Site Visitations carried out on 15
January 2024.
6 PLANNING APPLICATIONS
Submit reports by the Planning, Building Standards and Environmental Health
Manager, in respect of the following Planning applications:-
(a) DC23/210/PPP: Erection of three dwelling houses 27 - 47
(in principle) at Old Carman Water Works Site,
Cardross Road, Renton, Dumbarton by Mr J McDougal.
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(b) DC23/177/FUL: Erection of single wind turbine, 30m hub 49 - 78
and 43m tip, access track, substation and associated
works at land to East of Broomhill Wood, Bonhill, Alexandria
by Mr Harris Smith.
(c) DC23/202/FUL: Application under Section 42 of the 79 - 96
Town and Country Planning (Scotland) Act 1997, as Amended,
in relation to Condition 17 (approach to risk assessment and any
associated required remediation strategy/plan) attached
to Planning Permission, in Principle, reference DC20/088 at
Land At Former Dunglass Oil Terminal Dumbarton Road, Bowling
by West Dunbartonshire Council.
(d) DC23/205/FUL: Application under section 42 of the 97 - 109
Town and Country Planning (Scotland) Act 1997 to
vary Condition 7, relating to the timing of footpath delivery
at Farm Road, Duntocher, Clydebank by Barratt Homes
West Scotland.
(e) DC22/185/FUL: Change of use of ground for the siting 111 - 130
of three holiday lodges including a waste water treatment
plant and ancillary car parking (being a revised design
from that approved under Planning Permission ref:
DC21/096/FUL) at Former Maryland Water Pumping Station,
Garshake Road, Dumbarton by Mrs Mary Gillies.
(f) DC22/072/FUL: Residential development, landscaping 131 - 153
and associated infrastructure at Hawthornhill Road,
Dumbarton by Persimmon Homes.
7 CLYDEBANK BUSINESS PARK PLANNING GUIDANCE 155 - 192 
Submit report by the Planning, Building Standards and Environmental Health
Manager, seeking approval of the finalised version of Planning Guidance
relating to Clydebank Business Park for use in making planning decisions.
8 DRAFT PAY DAY LENDING AND BETTING SHOP 193 - 287
PLANNING GUIDANCE
Submit report by the Planning, Building Standards and Environmental Health
Manager, seeking approval to consult on draft Planning Guidance relating to
Pay Day Lending and Betting Offices.
__________________________________________________________________
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PLANNING COMMITTEE
At a Meeting of the Planning Committee held in the Council Chambers, Clydebank
Town Hall, 5 Hall Street, Clydebank on Wednesday 6 December 2023 at 10.00 a.m.
Present: Councillors Karen Murray Conaghan, Ian Dickson*, Gurpreet
Singh Johal*, June McKay, Lawrence O’Neill, Chris Pollock, and
Sophie Traynor.
* Arrived later in the meeting.
Attending: Pamela Clifford, Planning, Building Standards and
Environmental Health Manager; Alan Williamson, Development
Planning and Place Team Leader; Nigel Ettles, Section Head –
Litigation (Legal Officer) and Nicola Moorcroft, Committee
Officer. 
Apologies: Apologies for absence were intimated on behalf of Provost
Douglas McAllister and Councillors Daniel Lennie and Hazel
Sorrell.
Councillor Lawrence O’Neill in the Chair
DECLARATIONS OF INTEREST
It was noted that there were no declarations of interest in any of the items of
business on the agenda.
OPEN FORUM
The Committee noted that no open forum questions had been submitted by
members of the public.
MINUTES OF PREVIOUS MEETING
The Minutes of Meeting of the Planning Committee held on 15 November 2023 were
submitted and approved as a correct record.
NOTE OF SITE VISITATIONS
A Note of Visitations carried out on 13 November 2023, a copy of which forms
Appendix 1 hereto, was submitted and noted.
ITEM 4a
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LOCAL DEVELOPMENT PLAN AND LOCAL PLACE PLAN UPDATE
A report was submitted by the Planning, Building Standards and Environmental
Health Manager, seeking approval of the 2023 Development Plan Scheme and
Participation Statement in relation to a new Local Development Plan (LDP3).
After discussion and having heard the Development Planning and Place Team
Leader in further explanation, the Committee approved the Development Plan
Scheme and Participation Statement set out in Appendix 1 of the report and noted
that once approved it would be submitted to the Scottish Ministers.
PLANNING PERFORMANCE FRAMEWORK 2022-23
A report was submitted by the Planning, Building Standards and Environmental
Health Manager, advising of the comments recently received from the Scottish
Government regarding the Planning Performance Framework submitted by this
Council for reporting year 2022-23.
After discussion and having heard the Planning, Building Standards and
Environmental Health Manager and the Development Planning and Place Team
Leader in further explanation and in answer to Members’ questions, the Committee
noted the content of this report and the comments received from the Scottish
Government.
The meeting closed at 10.22 a.m.
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APPENDIX 1 
PLANNING COMMITTEE
NOTE OF VISITATIONS – 13 NOVEMBER 2023
Present: Councillors Chris Pollock and Sophie Traynor
Attending: James McColl - Development Management Team Leader
SITE VISITS
Site visits were undertaken in connection with the undernoted planning applications:-
Lawmuir Farm, Glasgow Road, Hardgate, Clydebank G81 5QT
DC23/012/FUL: Change of use from agricultural land to 3 dog exercise fields,
erection of boundary fencing and erection of 3 shelters (Retrospective)
Former Site of Dunclutha, Parkhall Road, Clydebank
DC22/216/FUL: Erection of three dwelling houses and associated works.
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PLANNING COMMITTEE
At a Special Meeting of the Planning Committee held in the Council Chambers,
Clydebank Town Hall, 5 Hall Street, Clydebank on Wednesday 17 January 2024 at
10.00 a.m.
Present: Councillors Ian Dickson, Gurpreet Singh Johal, Daniel Lennie,
June McKay, Karen Murray Conaghan*, Chris Pollock, Hazel
Sorrell and Sophie Traynor.
*Arrived later in the meeting
Attending: Pamela Clifford, Planning, Building Standards and
Environmental Health Manager; James McColl, Development
Management Team Leader; Amy Melkevik, Lead Planning
Officer; Gail MacFarlane, Chief Officer – Roads and
Neighbourhoods; Nigel Ettles, Section Head – Litigation (Legal
Officer) and Nicola Moorcroft, Committee Officer.
Apologies: Apologies for absence were intimated on behalf of Provost
Douglas McAllister and Councillor Lawrence O’Neill.
Councillor Gurpreet Singh Johal in the Chair
DECLARATIONS OF INTEREST
It was noted that there were no declarations of interest in any of the items of
business on the agenda.
OPEN FORUM
The Committee noted that no open forum questions had been submitted by
members of the public.
PLANNING APPLICATIONS
A report was submitted by the Planning, Building Standards and Environmental
Health Manager in respect of the following Planning applications:-
ITEM 4b
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(a) DC23/113/MSC: Details relating to the first Approval of Matters Specified
by Condition (AMSC) application (Phase 1 and 2 works only) for
conditions 1(a), 1(d), 12, 23, 24 and 30 at Exxon, Bowling.
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 Graham Parton (objector) to address the Committee. Mr
Parton was heard in respect of the application and in answer to Members’
questions.
The Chair invited Ms Susan Dick (objector) to address the Committee. Ms
Dick was heard in respect of the application and in answer to Members’
questions.
The Chair invited Gail MacFarlane and Patricia Rowley (applicant - on behalf
of West Dunbartonshire Council) to address the Committee. Ms MacFarlane
and Ms Rowley were heard in respect of the application and in answer to
Members’ questions.
After discussion and having heard the Development Management Team Leader in
further explanation, and in answer to Members’ questions, the Committee agreed
to grant planning permission subject to the conditions set out in Section 9 of the
report, as detailed within Appendix 1 hereto.
ADJOURNMENT
The Chair adjourned the meeting for a short recess. The meeting reconvened at
11.07 a.m. with the Elected Members listed in the sederunt present.
(b) DC23/149/FUL: Erection of 128 residential homes, associated roads,
infrastructure and open space on existing brownfield site, (former
Playdrome site) Residential Development Site, Abbotsford Road,
Clydebank by Miller Homes.
A copy of a letter (tabled) by Chief Executive Officer, Clydebank Co-operative
Society, setting out objections to this planning application, was circulated for
consideration to the Committee members and the applicant – Miller Homes
The Committee agreed to accept the tabled letter noted above.
Reference was made to a site visit, which had been undertaken in respect of the
above application. The Planning and Building Standards and Environmental
Health Manager, was heard in further explanation, and in answer to Members’
questions.
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The Chair invited Ms Marie McNair MSP (objector) to address the Committee.
Ms McNair was heard in respect of the application and in answer to Members’
questions.
The Chair invited Ms Fiona McInnes, on behalf of Clydebank Co-operative
Society (objector), to address the Committee. Ms McInnes was heard in
respect of the application and in answer to Members’ questions.
The Chair invited Mr Robert McKinnon and Mr Tom Cahill (on behalf of Miller
Homes Ltd.) to address the Committee. Mr McKinnon and Mr Cahill were
heard in respect of the application and in answer to Members’ questions.
After discussion and having heard the Planning and Building Standards and
Environmental Health Manager and the Chief Officer – Roads and
Neighbourhoods, in further explanation, and in answer to Members’ questions,
Councillor Johal Singh moved that the Committee:-
(1) refer the application to full Council for determination, with a preliminary
recommendation, based on the information considered to date, that it be
approved, subject to the conditions in Section 9 of the report, as detailed
within Appendix 2 hereto; and
(2) include the following additional condition:-
That at all times, during the construction of the development, vehicular and
pedestrian access shall remain available via Abbotsford Road, or any other
equivalent access road, to all existing properties which were, at the time of
granting planning permission, accessed via Abbotsford Road.
As an amendment, Councillor Ian Dickson, seconded by Councillor Chris Pollock,
moved:-
That an additional condition be attached to any planning consent, requiring the
applicant, one year after completion of the development, to undertake a traffic
survey to assess the adequacy of parking on the site and to provide additional
parking if the survey suggests that parking facilities are inadequate.
As a second amendment, Councillor Murray Conaghan, seconded by Councillor Sophie
Traynor, moved:-
That the planning application be refused due to the concerns raised as to the loss
of car parking and the adequacy of parking provided on the development site.
On a vote being taken between the first amendment (Councillor Dickson) and the
second amendment (Councillor Murray Conaghan), 1 Member voted for the first
amendment and 2 Members, voted for the second amendment, which was
accordingly declared carried.
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On a further vote being taken, between the amendment (Councillor Murray
Conaghan) and the motion (Councillor Johal Singh), 3 Members voted for the
amendment and 5 Members voted for the motion, which was accordingly declared
carried.
The meeting closed at 12.46 p.m.
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APPENDIX 1
(a) DC23/113/MSC: Details relating to the first Approval of Matters Specified
by Condition (AMSC) application (Phase 1 and 2 works only) for
conditions 1(a), 1(d), 12, 23, 24 and 30 at Exxon, Bowling.
GRANT full planning permission subject to the following conditions:-
1. Other than the details approved for Phase 1 and 2 in terms of this permission,
no approval is given in respect of the position of all buildings, footpaths,
waterfront walkway, green corridors, open space, boundary treatments and
drainage infrastructure in respect of the requirements of Condition 1(a) of
planning permission in principle DC20/088 and the approval of these details
shall be sought via further applications for matters specified by conditions in
connection with the further requirements of Condition 1(a) of planning
permission in principle DC20/088.
2. That prior to the commencement of development works with the exception of
those in connection with site set-up and creation of development compounds
on site, a full planting schedule for all landscaping and new tree planting
hereby approved in connection with the Phase 1 works together with the
timescale for implementation shall be submitted to and approved in writing by
the Planning Authority.  The schedule will set out how tree planting is
maximised in compensation for those lost.  The landscaping shall then be
implemented as approved unless otherwise first agreed in writing by the
Planning Authority.
3. That any trees, shrubs or areas of grass which die, are removed, damaged or
become diseased within five years of completion of the landscaping in
connection with the phase 1 works shall be replaced within the next planting
season with others of a similar size and species.
4. That prior to the commencement of development works on site, full details of
maintenance and management for the landscaping approved in connection
with the Phase 1 works shall be submitted to and approved in writing by the
Planning Authority, unless otherwise first agreed in writing by the Planning
Authority.  Management and maintenance shall commence within a timescale
agreed with the Planning Authority.
5. Prior to the felling of any trees within the site a scheme for the use of felled
timbers for structures within the site including (but not limited to) benches,
sculptures and wildlife features shall be submitted to and approved in writing.
The scheme shall then be implemented as approved unless otherwise agreed
in writing by the Planning Authority.
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6. All recommendations within the Ecology Survey Report dated November 2023
and associated 2023 Ecology Technical Report date October 2023 shall be
followed.  This shall include all required mitigation during the works on site.
All further survey work undertaken shall be submitted to and approved in
writing by the Planning Authority prior to the commencement of development
works on site with no works including vegetation clearance within the vicinity
of SPA/SSSI.  Any mitigation measures arising from the further survey work
shall be implemented as approved.
7. Notwithstanding condition 6 above, no tree works, removal or scrub clearance
shall occur on site from March through to August (inclusive) each year unless
otherwise agreed in writing with the Planning Authority prior to clearance
works commencing.  In the event that clearance is proposed between March
to August (inclusive), a suitable bird nesting survey shall be carried out by a
suitably qualified ecologist covering the proposed clearance area and shall be
submitted to and approved in writing by the Planning Authority before those
clearance works commence.  Once written approval has been given, the
works themselves should be carried out within a specified and agreed
timescale.
8. Notwithstanding condition 6 above, no development works shall be
undertaken on site with no works including vegetation clearance within the
vicinity of the SPA/SSSI during the period September to March inclusive until
a further full winter survey is undertaken in respect of wintering birds within
the SPA / SSSI with the survey results and recommendations submitted to
and agreed in writing by the Planning Authority in consultation with
NatureScot.
9. Prior to any development works on site with no works within the vicinity of
SPA/SSSI during the period September to March inclusive, the survey results
and recommendations that require to be submitted in connection with
condition 8 above shall be used to formulate a detailed mitigation strategy in
respect of the impact of any construction works within the site on the wintering
bird population of the SPA / SSSI.  This mitigation strategy shall be submitted
either as part of an updated Construction Environmental Management Plan
(CEMP) focusing on the Phase 1 and 2 works or as a standalone document
accompanying the updated CEMP and approved in writing by the Planning
Authority in consultation with NatureScot.  All mitigation shall then be
implemented as approved unless otherwise first agreed in writing by the
Planning Authority.
10. Prior to the commencement of development works on site, full details of how
toolbox talks to ensure all site personnel involved in Phase 1 and 2 of the
development are aware of matters relating to ecology and protected species
will be delivered to ensure that all personnel are aware of what to do should
evidence of species be discovered during construction shall be submitted to
and approved in writing by the Planning Authority.  The agreed approach shall
then be implemented unless otherwise first agreed in writing by the Planning
Authority.
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11. That prior to the commencement of development works on site in connection
with Phases 1 and 2, an updated Construction Environmental Plan (CEMP)
specifically addressing the Phase 1 and 2 works shall be submitted to and
agreed in writing by the Planning Authority. For the avoidance of doubt, the
CEMP will consider (but not be limited to) the impact from noise, dust and air
quality and construction activities for Phases 1 and 2.  The CEMP for Phases
1 and 2 of the development shall thereafter be implemented on site as
approved unless otherwise first agreed in writing with the Planning Authority.
12. That prior to the commencement of development works on site in connection
with phases 1 and 2, an updated Construction Traffic Management Plan
(CTMP), specifically addressing the Phase 1 and 2 works shall be submitted
to and agreed in writing by the Planning Authority.  The CTMP for Phases 1
and 2 of the development shall thereafter be implemented on site as approved
unless otherwise first agreed in writing with the Planning Authority.
13. Notwithstanding condition 12 above, all vehicles transporting construction
material to and from the proposed development shall be sheeted, unless
otherwise first agreed in writing with the Planning Authority.
14. Notwithstanding condition 12 above and prior to the commencement of any
works on site in connection with Phases 1 and 2, vehicle wheel cleaning
facilities shall be installed and brought into operation on the site, unless
otherwise first agreed in writing with the Planning Authority.
15. The Materials Management Strategy previously submitted and approved in
connection with condition 6 of Planning permission in principle DC20/088 shall
be fully followed at all times during the Phase 1 and 2 works hereby permitted
unless a modification is first agreed in writing by the Planning Authority.
16. All material to be used in the top 300mm of the development platforms shall
be free from deleterious materials such as metals, plastic, wood, glass,
tarmac, paper and odours.  On completion of the works in respect of each of
the two phases hereby permitted the developer shall submit for approval to
the Planning Authority a verification report containing details of the source of
the material and associated test results to demonstrate its suitability for use.
17. That unless otherwise agreed in writing by the Planning Authority, prior to
service buses commencing use of the relocated eastbound bus stop on the
A82 at Dumbuck, the existing bus shelter shall be relocated to the new
stopping position.  The final position of the shelter shall first be submitted to
and agreed in writing by the Planning Authority.
18. That prior to any alterations or works commencing affecting the A814, the
traffic modelling data to support the position of the westbound A814 bus stop
and demonstrate that westbound traffic flow will not be impacted by a bus
using the stop and vehicles waiting to turn left shall be submitted to and
approved in writing by the Planning Authority.
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19. That prior to the commencement of development works on site, a
communications strategy designed to make road users, local residents, local
business owners and the public in general aware of the proposed works, the
likely impact upon the locality and updates of progress in respect of the Phase
1 and 2 works hereby permitted shall be submitted to and approved in writing
by the Planning Authority.  The strategy shall then be implemented as
approved unless otherwise first agreed in writing by the Planning Authority.
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APPENDIX 2
(b) DC23/149/FUL: Erection of 128 residential homes, associated roads,
infrastructure and open space on existing brownfield site, (former
Playdrome site) Residential Development Site, Abbotsford Road,
Clydebank by Miller Homes.
GRANT full planning permission subject to the following conditions:-
1. Prior to the commencement of development on site, exact details,
specifications and samples of all proposed external materials to be used
within the development site shall be submitted to and approved in writing by
the Planning Authority.  For the avoidance of doubt, all facing bricks to be
used shall be good quality clay bricks.  Thereafter, unless otherwise first
agreed in writing with the Planning Authority, the development shall be
completed in strict accordance with the approved material details and palette.
2. Further to Condition 1 above, prior to the approved brickwork associated with
any house being constructed on site, a sample panel of the brickwork shall be
constructed on site in order for it and the associated mortar to be reviewed,
inspected and approved in writing by the Planning Authority.  Thereafter,
unless otherwise first agreed in writing with the Planning Authority, the
development shall be completed in strict accordance with the approved brick
details.
3. Prior to the commencement of development on site, full details of the
timescale/phasing for the build-out of the development shall be submitted to
and approved in writing by the Planning Authority.  Works shall then proceed
as approved unless an alternative timescale is first agreed in writing by the
Planning Authority.
4. 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 be proceed in accordance with
the approved details.
5. Prior to commencement of development on site, a 'Play Equipment Strategy'
for the site shall be submitted to and approved in writing by the Planning
Authority.  This shall include (but not be limited to) the following:
• Details and specifications of forms of play equipment and structures to
be provided within the site.
• Provide full details regarding the maintenance arrangements for all play
equipment and associated features within the site.
• Provide timescales for implementation of the play equipment.
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Thereafter, the approved play equipment strategy and all associated features
and specifications shall be installed within the development in accordance
with the strategy unless otherwise first agreed in writing by the Planning
Authority and maintained in accordance with the approved details for the
lifetime of the development.
6 Notwithstanding the approved plans, all recommendations within the
Ecological Constraints Survey dated 23rd August 2022 shall be followed. 
This shall include all required further survey work identified as being required
for otters.  Further survey work undertaken shall be submitted to and
approved in writing by the Planning Authority prior to the commencement of
development on site and implemented as approved.
7. Notwithstanding the approved plans and condition 6 above, and prior to the
commencement of development on site, the recommendations in paragraph
4.2.12 of the Ecological Constraints Survey dated 23rd August 2022, in
respect of re-establishing the ecological baseline shall be followed and the
approach to this submitted to and approved in writing by the Planning
Authority.
8. Notwithstanding the approved plans and condition 6 above, and prior to the
commencement of development on site, a further submission which
demonstrates an understanding on how the proposal enhances biodiversity
beyond the current baseline including any adjustments to the approved
landscaping proposals together with the implementation details on site shall
be submitted to and approved in writing by the Planning Authority.  All
measures shall then be implemented as approved.
9. Prior to commencement of development on site, a full planting schedule shall
be submitted for the further written approval of the Planning Authority.
Thereafter, 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.
10. 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.
11. Prior to commencement of development on site, a site management scheme
for construction traffic, shall be submitted to, and approved in writing by the
Planning Authority and thereafter shall be implemented in accordance with the
approved scheme.  For the avoidance of doubt, construction access shall only
be taken via Abbotsford Road and at no time will any vehicular access be
taken to or from Argyll Road, unless otherwise agreed in writing with the
Planning Authority.
12. That prior to each house hereby permitted being occupied, all new roads and
footways leading to it shall be surfaced to a sealed base course.
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13. That within 4 weeks of the last of the houses hereby permitted being
completed, all roads and footways within the application site shall be
completed to a final wearing course.
14. Prior to the occupation of any house, the on-street parking provision
associated to that house shall be completed and be available for use by
residents of the associated house.  The on-street parking provision shall then
remain unobstructed and available for use by residents of the associated
house at all times thereafter
.
15. The additional parking provided on Abbotsford Road, as identified on drawing
ARC/SITE001 Rev Q – Site Layout shall be constructed and made available
for use prior to the removal of the existing parking area.
16. That prior to the commencement of development 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 thereafter.  For
the avoidance of doubt, the drainage regime shall be implemented
commensurately with the construction of the houses it serves.
17. 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 by the Planning Authority prior to the
commencement of development on site.  The measures shall be implemented
and maintained as approved.
18. The approved car charging points/units/ducting and associated infrastructure
shall be installed in accordance with the approved details in a timescale
agreed by the Planning Authority and maintained at all times thereafter.
19 .Prior to the occupation of the first house within the site, the developer shall
install the necessary infrastructure to enable the full development and all
associated properties to be connected to the existing fibre optic network,
where available in West Dunbartonshire, and in accordance with the relevant
telecommunications provider’s standards.
20. Prior to the commencement of development on site, details of any street
furniture inclusive of grit bins and telecommunications cabinets as well as
lighting and bins adjacent to the canal, shall be submitted to and approved in
writing by the Planning Authority and within a timescale agreed with the
Planning Authority.
21. The Residential Travel Plan as approved as part of this application shall be
provided on occupation of each dwelling to new residents.
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22. No development (other than investigative works) shall commence on site until
such time as a revised report on the nature and extent of any contamination of
the site has been submitted to and approved in writing by the Planning
Authority.  The report shall be prepared by a suitably qualified person and
shall include the following:
a) A detailed site investigation identifying the extent, scale and nature of
contamination on the site (irrespective of whether this contamination
originates on the site)
b) An assessment of the potential risks (where applicable) to:
• human health
• property (existing and proposed), including buildings, crops,
livestock, pets, woodland and service lines and pipes
• groundwater and surface waters
• ecological systems
• archaeological sites and ancient monuments
c) An appraisal of remedial options, including a detailed remediation
strategy based on the preferred option.
23. No development (other than 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.
24. The approved remediation scheme shall be carried out in accordance with its
terms prior to the commencement of development other than that required to
carry out remediation, unless otherwise agreed in writing by the Planning
Authority.  The Planning Authority shall be notified in writing of the intended
commencement of remediation works not less than 14 days before these
works commence on site.  Upon completion of the remediation works and
prior to the site being occupied, a verification report which demonstrates the
effectiveness of the completed remediation works shall be submitted to and
approved in writing by the Planning Authority.
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25. The presence of any previously unencountered 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.
26. If the remediation plan requires it then a monitoring and maintenance scheme
(including the monitoring of the long-term effectiveness of the proposed
remediation) shall be submitted to and approved by the Planning Authority.
Any actions/measures ongoing shall be implemented within an agreed
timescale with the Planning Authority.  Following completion of the
actions/measures identified in the approved remediation scheme a further
report which demonstrates the effectiveness of the monitoring and
maintenance measures shall be submitted to and approved by the Planning
Authority.
27. 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.
28. Prior to commencement of development on site, an updated noise
assessment shall be submitted to, and approved in writing by the Planning
Authority, to determine the impact of noise on the proposed development.
The noise impact assessment and any recommendations in respect of
mitigation measures shall be implemented as agreed prior to the development
being brought into use and where appropriate shall be retained in accordance
with approved details.  The noise assessment shall include an assessment of
aircraft noise taking into account the structure of the roof design as a possible
pathway for noise transmission.
29. Prior to occupation of any house, the applicant shall have a third party
independent verifier submit a verification report which shall provide verification
of the installed noise mitigation measures demonstrating that the projections
as detailed within the approved noise impact assessment are reliable and
meet with the relevant conditions.
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30. Prior to the commencement of development on site, a noise control method
statement for the construction period shall be submitted to and approved in
writing by the Planning Authority.  This statement shall identify likely sources
of noise (including specific noisy operations and items of plant/machinery), the
anticipated duration of any particularly noisy phases of the construction works,
and details of the proposed means of limiting the impact of these noise-
sensitive properties.  The construction works shall thereafter be carried out in
accordance with the approved method statement unless otherwise approved
in writing by the Planning Authority.
31. 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 first agreed in writing by the Planning
Authority:
• Mondays to Fridays: 0800 – 1800
• Saturdays: 0800 – 1300
• Sundays and public holidays:  No Working
32. 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, unless otherwise first agreed in writing by the Planning Authority.
33. 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.
34. Prior to the commencement of development on site a scheme for the control
and mitigation of dust shall be submitted to and approved in writing by the
Planning Authority.  The scheme shall identify likely sources of dust arising
from the development or its construction, and shall identify measures to
prevent or limit the occurrence 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 first agreed by the Planning Authority.
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35. Prior to the commencement of development on site, an air quality impact
assessment shall be submitted to and approved by the Planning Authority.
The report should use a method based on the principles set out in the
Environmental Protection UK document Development Control: Planning for Air
Quality (2010 Update), Scottish Government publication “Local Air Quality
Management Technical Guidance LAQM.TG(09)”, and “Delivering Cleaner Air
for Scotland - Guidance from Environmental Protection Scotland and the
Royal Town Planning Institute Scotland, January 2017”.  The
recommendations of the assessment shall be implemented prior to the
development commencing on site or within a timescale agreed by the
Planning Authority.
36. Prior to the commencement of development on site, details (including specific
luminaire and lamp type; beam control; wattage; the use of reflectors; baffles;
louvers; cowling; lux contours/distribution diagrams and columns
types/colours) of the lights /floodlights have been submitted to and approved
in writing by the Planning Authority.  The floodlights shall then be
implemented in accordance with the approved details and shall be maintained
in this condition.  Any subsequent changes to their position or specification
shall be subject to the prior written approval of the Planning Authority.  The
applicant should also take cognisance of the nearby commercial premises
and any associated floodlights.  The potential for obtrusive light affecting the
properties must be assessed and appropriate mitigation measures put in
place to negate any nuisance from any lights on the commercial premises.
37. Prior to the commencement of development on site, details for the storage
and the collection of waste arising from the development shall be submitted to
and approved in writing by the Planning Authority.  The agreed details shall be
in place prior the occupation of the first house within the site and thereafter
maintained for the lifetime of the development.
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PLANNING COMMITTEE
NOTE OF VISITATIONS – 15 JANUARY 2024
Present:
Attending:
Councillors Gurpreet Singh Johal, June McKay, John Millar,
Chris Pollock and Clare Steel.
Pamela Clifford, Planning, Building Standards and Environmental
Health Manager and James McColl, Development Management
Team Leader. 
SITE VISITS
Site visits were undertaken in connection with the undernoted planning applications:-
Former Playdrome site, Abbotsford Road, Clydebank 
DC23/149/FUL: Erection of 128 residential homes, associated roads, infrastructure and
open space on existing brownfield site, (former Playdrome site) by Miller Homes
EXXON Site - Land at Former Dunglass Oil Terminal, Bowling and Dunglass
roundabout and areas of the site at Dumbuck.
DC23/113/MSC: Details relating to the first Approval of Matters Specified by Condition
(AMSC) application  (Phase 1 and 2 works only) for conditions 1(a), 1(d), 12, 23, 24 and
30.
ITEM 5
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager
Planning Committee: 14th February 2024
_____________________________________________________________
DC22/210/PPP: Erection of three dwellinghouses (in principle) at Old
Carman Water Works Site, Cardross Road, Renton by Mr
J McDougal
1. REASON FOR REPORT
1.1 The planning application proposal is a departure from the adopted
development plan. 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 in principle subject to the conditions set out in
Section 9.  
3. DEVELOPMENT DETAILS
3.1 The site comprises the former Carman waterworks site which is located on
Cardross Rd near Renton. To reach the site from Renton, it is necessary to
take an unclassified, mostly single track road which connects the B857 Main
Street in Renton with the A814 Main Rd in Cardross. The site is
approximately 0.4 mile from the junction with the B857 and is located on a
hairpin turn. Due to this, the site is triangular in shape and features a
noticeable change in elevation between its lower and its upper parts. To the
west of the site, on the other side of the road, is a forested area adjacent to
Carman Hill House and Carman Reservoir.  To the east, also across the
road, and to the north, there are agricultural areas typically used for grazing.
The site is partially overgrown and features disused water supply
infrastructure in the form of three tanks and possible further associated
underground facilities. There is boundary treatment present in the form of a
historic stone wall; access is from the western side of the site via an iron
gate. 
3.2 The application seeks planning permission in principle for the erection of
three dwellinghouses. The existing water supply infrastructure will be
removed from the site to facilitate development. An indicative layout with
three detached dwellinghouses, two of which would face west with the third
facing east. Off street parking would be provided within driveway parking.
ITEM 6a
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As the application is considered in principle, any design and layout details
of the site and proposed houses provided in the submitted drawings are
indicative and would be submitted at the detailed stage. 
3.3 Improvements are proposed to the road surrounding the eastern and the
southern perimeter of the site as part of this application.  The existing hairpin
corner at the southernmost tip of the site would be altered, widened and
improved with asphalt finish to an adoptable standard. As a result, the
sightlines of the sharp corner and the dimensions of the carriageway would
be improved. The submission also indicates that the ownership of the corner
of the site where the widened carriageway and road verge would be
provided
3.4 In terms of planning history, the site was previously subject to a permission
(DC02-332) for the formation of specialist market garden, including erection
of two growing buildings and erection of dwellinghouse. Permission was
later approved (DC10/025/FUL) for variation of condition 1 of permission
DC02-332 to extend the time period for the commencement of development
of market garden and dwellinghouse. Both of the applications have since
lapsed and no development of the site has taken place. 
4. CONSULTATIONS
4.1 West Dunbartonshire Council Biodiversity Officer has no objection subject
to conditions relating to all recommendations within the Preliminary
Ecological Appraisal being followed, including the protection for nesting
birds. Furthermore, conditions to address biodiversity enhancement and
Black Grouse mitigation are required. 
4.2 West Dunbartonshire Council Environmental Health have no objection
subject to conditions relating to construction noise, contaminated land,
importation and reuse of soils, lighting, Noise Impact Assessment, as well
as noise control, hours of work, piling method statement, waste storage and
dust control during construction.
4.3 West Dunbartonshire Council Roads have no objection to the proposal in
respect of roads and parking together with flooding matters.
4.4 Scottish Water and West of Scotland Archaeological Service have no
objection to the proposed development. .
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5. REPRESENTATIONS
5.1 One objection was received from a neighbouring resident. The full details
are contained within the planning file and are available for public viewing.
However, the key points of objection can be summarised as follows:
• Neighbour notification was not issued to neighbouring property.
• The site is within the Green Belt.
• More than one house on site would be out of step with how other sites
within the Green Belt were redeveloped.
• The site is in close proximity to a Local Nature Conservation Site and
may impact upon this designation, other locally sensitive areas and local
wildlife.
• The development may result in more people seeking to gain access to
the area.
• Road realignment may encourage unsuitably sized vehicles to attempt
to use the road, resulting in accidents.
• Road safety concerns in relation to Cardross Road, which is narrow,
steep and used by notable levels of vehicle traffic, walkers and cyclists,
heavy goods vehicles.
• There is a history of road accidents in winter conditions and speeding in
all conditions.
• Access to the site may potentially be affected in the winter during
icy/snowy conditions.
• Concern over insufficient turning space in the proposed western plots
within the site, as shown in the proposed site drawing.
• Noise from traffic may disturb neighbouring properties.
• Inaccurate site boundary in the submitted drawings.
• Access and servicing and neighbouring property may be impacted upon.
• Concerns regarding sightlines for the new access to the proposed
development.
• Concern regarding the height and finish of the boundary treatment for
the site in relation to sightlines for vehicles exiting the site and privacy of
the future inhabitants.
• No information is provided on bin storage and refuse collection.
• Concern over the impact of refuse collection method on the amenity of
the site and its surroundings.
• Insufficient parking indicated in the drawings.
• Scale and design of the proposed dwellinghouses and utilisation of the
footprint of the site and its topography.
• The scale and design of the new houses is inappropriate and
overdevelopment would occur.
• It is incorrect to suggest flooding does not occur at this location.
• The position of neighbouring properties is not shown in the application
submission.
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• The construction of the development may impact upon access on
Cardross Road and to neighbouring property.
• The site could be confused with another site of a similar name.
• It has been difficult to view the application online.
The concerns raised are considered in Section 7 below.
6. ASSESSMENT AGAINST THE DEVELOPMENT PLAN
National Planning Framework 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. It requires that local development will include appropriate
measures to conserve, restore and enhance biodiversity. It is noted that
measures should be proportionate to the nature and scale of development.
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 8 supports development within the green belt in a limited number of    
circumstances. These include:
• development associated with agriculture, woodland creation, forestry
and existing woodland (including community woodlands);
• residential accommodation required for key workers in a primary
industry in the vicinity of the site;
• horticulture, including market gardening and directly connected retailing,
as well as community growing;
• essential infrastructure or new cemetery provision;
• minerals operations and renewable energy developments;
• intensification of established uses, including extensions to an existing
building where that is ancillary to the main use.
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Additional requirements include justification is provided for the green belt
location; the purpose of the green belt is not undermined by the
development; the development is compatible with the surrounding
countryside and landscape character; the development is of an appropriate
scale, massing and external appearance and minimises visual impact; and
there will be no long-term impacts on the environmental quality of the green
belt.
6.5  As the site has been previously developed, Policy 9 addressing brownfield,
vacant and derelict land applies. Development proposals that will result in
the sustainable reuse of brownfield land including vacant and derelict land
and buildings, whether permanent or temporary, will be supported.
6.6 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.
Development proposal will contribute to local living including, where
relevant, 20 minute neighbourhoods. Consideration will be given to existing
settlement pattern, and the level and quality of interconnectivity of the
proposed development with the surrounding area, including local access to
affordable and accessible housing options, ability to age in place and
housing diversity.
6.7 Policy 16 relates to quality homes with part a) supporting proposals for new
homes on sites allocated for housing in Local Development Plans. The
application site is allocated in the proposed Local Development Plan 2 as a
residential development opportunity. 
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 the proposal 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 22 - Flood risk and water management states 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.
Policy 23 does not support proposals which are likely to raise unacceptable
noise issues. Policy 24 supports proposals that incorporate appropriate,
universal, and future-proofed digital infrastructure.
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West Dunbartonshire Adopted Local Plan 2010
6.11 The site lies within the Green Belt and Policy GB1 states that within the
areas of Green Belt shown on the Proposals Map there will be a general
presumption against development other than:
• agriculture and forestry, including community woodlands; or
• the appropriate re-use of vacant buildings which would be desirable to
retain; or
• for their local significance, historic or architectural character; or
• outdoor recreation, leisure or tourist proposals which are appropriate for
the countryside, contribute to the social and economic development of
the Plan area and are not contrary to other policies and proposals
contained within the Local Plan; or
• where there is a specific locational requirement and established need
for the development and it cannot be accommodated on an alternative
site; or
• where there is a necessity for additional land for development purposes,
having regard to the requirements of the approved Structure Plan.
Development will not be permitted which would have an adverse effect on
the landscape character of the local area. Proposals for new buildings,
extensions or the change of use of existing buildings within the Green Belt
will have to pay particular regard to design, siting, landscaping, nature
conservation and protection of habitats.
6.12  Policy H1 of the adopted Local Plan highlights that the sites identified in
Schedules H1 and H2 represent the main opportunities for private sector
housing development. The site is not allocated for residential development
in Schedule H2. Policy UR1 further encourages the redevelopment and re-
use of underused, vacant and/or derelict land and buildings for appropriate
uses such as housing. Policy RD1 which sets out a preference for
residential development on brownfield sites.
6.13 Policy H4 sets out standards expected of all residential development,
requiring high quality design in the range of house types and sizes and in
terms of form, layout and materials. Policy H5 safeguards and where
possible enhances the character and amenity of existing residential area.
Policy GD1 seeks to ensure that all new development is of a high quality of
design and respects the character and amenity of the area. 
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6.14 Policy E1 relates to the Council’s biodiversity duty with Policy E4 specifically
focusing on the protection and retention of trees subject to a Tree
Preservation Order (TPO). Policy E5 goes on to set out an expectation for
development proposals on sites with or adjacent to, existing trees or
woodlands to take account of trees at the beginning of the design process
and includes a requirement for a tree survey. Policy R2 specifies the open
space provision required for all developments. Assessment of open space
requirements has been undertaken against the updated position set out in
in Section 7 below.
6.15 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. 
Development Plan Conclusions
6.16 The site lies within the Green Belt and the construction of three
dwellinghouses, not designed to accommodate key workers in a local
primary industry such as agriculture, is not a form of development supported
by Policy 8 of NPF4 or Policy GB1 of the adopted Local Plan. However, the
site is an allocated residential development opportunity in proposed Local
Development Plan 2 which reflects the Council’s most up to date spatial
strategy. Based on the proposed Local Development 2 site allocation, the
proposed residential development would in turn be supported by Policy 16
and the Green Belt policies would not be applicable in the assessment of
the application. In light of the residential development allocation within
proposed Local Development Plan 2 which carries significant weight in the
assessment and determination of planning applications, it is considered that
the material considerations are such that a departure from Policy 8 of NPF4
and Policy GB1 of the adopted Local Plan can be justified in this instance.
Subject to the full assessment set out 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.
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7.2 Policy H2 supports new housing development on sites in Schedules 2 and
3. This site is an allocated residential development opportunity included in
Schedule 2. Policy CP1 of proposed LDP2 seeks to ensure that all
development the layout and form of the development, including the
relationship between the buildings, streets and spaces, protect and
enhance the amenity of existing communities, future occupiers and
neighbouring development sites. 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. Policy H4 sets out that that
the Council will protect, preserve and enhance the residential character and
amenity of existing residential areas at all time.
7.3 Policies GI2 and GI4 relate to green infrastructure. Policy GI2 requires new
development to meet with the open space standards set out within the
policy. Where a development has difficulty providing these standards on
site, or where a relaxation of the standards can be justified, developers will
require to accord with Policy GI4 and provide a contribution towards the
types of projects outlined within the policy and detailed in the Green
Network and Green Infrastructure Planning Guidance. GI4 sets out the
requirements for Developer Contributions.
7.4 Policy CON1 requires that significant travel generating uses are designed
to encourage sustainable transport. CON3 encourages improvements to
core paths and the development of new core paths and Policy CON4 sets
out a need for all developments to install sufficient broadband provisions. 
7.5 Policy ENV8 requires developments to address air quality, lighting and
noise as part of the planning process, whilst policy ENV9 requires all
potentially contaminated sites to be remediated where necessary to ensure
that the site is suitable for the intended use. 
7.6 RE4 encourages micro-generation and heat recovery technologies within or
associated with individual properties and Policy RE5 relates to low and zero
carbon buildings and states that new buildings should conform to the
sustainability standards. 
7.7 Policies ENV1, ENV4, and ENV6 are all similar to the ecology and tree,
water environment and flooding policies of the adopted Local Plan. 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. 
7.8 It is considered that the application proposal complies with the relevant
policies above as set out in the following assessment below.
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Creating Places Guidance and Green Network and Green Infrastructure
Guidance
7.9 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. It is considered that the
development responds to the local context and accords with the approach
set out in the Guidance at this Planning in Principle stage.  
7.10 The Green Network and Green Infrastructure Guidance – November 2022
seeks to ensure that the proposal also 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. The on-site
provision follows the Guidance in respect of residential development
proposals. The proposal accords with the approach set out in the Guidance.
Principle of Development
7.11 Within the adopted Local Plan, the site is situated within the Green Belt. The
erection of three dwellinghouses would not be a development supported
within a Green Belt location by either Policy 8 of NPF4 or Policy GB1 of the
adopted Local Plan. However, proposed Local Development Plan 2,
incorporating the recommended modifications of the Examination Report
received on 22 April 2020, forms the Council’s most up to date spatial
strategy and can therefore be afforded significant weight in the assessment
and determination of planning applications, subject to compatibility with
NPF4. The site is identified as a residential development opportunity within
proposed Local Development Plan 2 and this allocation was supported by
the Reporter in the Examination Report, and not subject to any
recommended modifications. 
7.12    Notwithstanding the position of proposed Local Development Plan 2 as the
Council’s most up to date spatial strategy, it remains that the adopted Local
Plan does not identify the site as a development opportunity but rather a
site within the Green Belt.  Accordingly, Policy GB1 of the adopted Local
Plan and Policy 8 of NPF4 are relevant as set out in paragraphs 6.4 and
6.11 above. In assessing whether there are any material considerations
which would justify a departure from the adopted development plan, it is
recognised that whilst the Council took the decision not to adopt proposed
Local Development Plan 2, it remains a significant material planning
consideration in the assessment of planning applications. If proposed Local
Development Plan 2 had been adopted, the residential development
allocation would have changed its status of the site in respect of the policy
assessment within NPF4. Policy 8 would not be applicable and Policy 16
would support the development of the allocated site. Furthermore, Policy 9
of NPF4 also supports the sustainable redevelopment of brownfield sites.
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7.13 In further considering the proposal, the indicative capacity set out in
proposed Local Development Plan 2 is for three houses. Based on the
indicative layout submitted, it is considered that a development of three
units could be suitably accommodated on site, including accommodating
the topography of the site, in a way which balances the development of an
allocated site with the character of the wider Green Belt. 
7.14 The proposal would require demolition of the existing disused water supply
infrastructure within the site, predominantly in the form of underground
water tanks, which has been redundant for a significant period of time. The
existing site does not feature any buildings but it is noted that there are
detached dwellinghouses within the locality along Carman Road. As the site
has not performed its infrastructural function for some time, it remains shut
off with the access gate closed and parts of the site overgrown and subject
to spontaneous rewilding, all contained within the area bounded by the
historic wall demarcating its limits. The redevelopment of the site would
remove a disused brownfield site and, subject to the final design and layout
of any new development, result in a positive impact on the visual amenity
of the area. As it is understood that the water supply needs have since been
superseded by other infrastructure serving the area, it is not considered that
the loss of the site to a housing development would raise concerns.  
7.15 It is considered that in this instance a departure in respect of Policy 8 of
NPF4 and from Policy GB1 of the adopted Local Plan can be justified and
the principle of residential development accepted on site. 
Indicative design, layout and visual impact within the landscape 
7.16 No detailed information has been submitted, however an indicative layout
has been proposed. The number and size of the properties proposed is
considered acceptable in this context. The setback from the road level and
the screening afforded by the remaining boundary wall around the perimeter
of the site, also manages the visual impact and prominence of the new
development in the immediate vicinity. The properties would benefit from
open outlook overlooking the Vale of Leven and the surrounding Kilpatrick
Hills. This section of Carman Road, while predominantly rural in character,
does feature several residential properties, with some located a distance
away from the road level.  The proposal is considered to be consistent with
the development pattern of the area and a suitable reuse of the vacant
derelict site. 
7.17   Whilst recognising that the application is considered in principle only, it must
be assessed whether a suitable development could be achieved on site. In
this instance, such an assessment can be guided by the indicative layout
and details submitted.  The indicative details suggests the proposed houses
are of one-and-a-half-storey in height. 
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Houses of this size would be acceptable, given the semi-open nature of the
site and this is the predominant height of other houses along Carman Road
outwith the urban settlement. The suggested ratio of plot size to house is
considered acceptable and the properties would have an acceptable
amount of private garden ground at the rear providing outdoor amenity
space for the occupants. The houses would be set back from Carman Road
by a reasonable distance, with sizable front curtilages fronting each of the
three houses. The design indicates render houses incorporate details as
timber cladding and such an approach would be considered appropriate for
the Green Belt location.
7.18 Overall, it is considered that an appropriate, attractive outward facing
development could be achieved on site that does not result in
overdevelopment nor any adverse impacts on the wider landscape within
this Green Belt location. Whilst the lack of detail on a variety of aspects of
the development is highlighted in the objection received, this application is
in principle only and does not consider the final detail of the development of
the site. Conditions can guide the detailed design of the houses which will
be subject of a further detailed application.   
Residential amenity 
7.19 Potential impact on neighbouring properties has been considered in relation
to privacy and overshadowing. As the current application is for planning
permission in principle it is not possible to assess specific details. However,
based on the suggested indicative details which indicate one-and-a-half-
storey houses and taking into account their position relative to neighbouring
properties and within the application plot, it is considered that the site could
be developed without any unacceptable overshadowing or loss of privacy
would occur. This will be fully assessed at the detailed stage.  Any noise
and activity generated by the new houses would be typical of that emanating
from a domestic setting and it is not considered that any undue noise
disturbance would occur. 
7.20    Whilst the Council’s Environmental Health Service advice on the need for a
noise impact assessment is noted. This will determine suitable mitigation
measures are incorporated within the development to minimise noise
sources that are likely to impact upon new residents. This matter can
therefore be addressed by condition.  
Roads and parking 
7.21 The application site is accessed via Cardross Road, which is a single track
road with some steep inclines. A variety of concerns are raised in the
objection in respect of roads and access matters. The Council’s Roads
Service has no objections to the principle of three houses on the site,
subject to the applicant providing relevant dimensioned sightline splays
(noting that the national speed limit applies). 
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The ability for the final development detail to achieve the required sightlines
is indicated in the indicative layout provided. The proposed site plan
indicates that there is sufficient space for off-road parking and it therefore
can be concluded the final development detail can provide adequate off-
street parking. Based on the indicative layout, access to the driveways
would be from Cardross Road approximately where the current gate is
(upper plots) and through a new road opening (lower plot). 
7.22    There is an opportunity for improvements to the tight hairpin bend adjacent
to the site as a result of the development.  The indicative layout indicates
how this will be achieved as part of the development and the Council’s
Roads Service raise no additional requirements in this respect. Full details
of the delivery of this improvement can be addressed by condition. 
Accessibility
7.23    The site is outwith the build settlement and thus doesn’t specifically promote
20 minute neighbourhoods. However, it is a development opportunity within
the proposed Local Development Plan 2 and is only of a small scale. None-
the-less, the settlement of Renton lies in reasonably close proximity with a
range of local facilities including public transport links within a typically 20
minute walk from the site. Despite the out-of-settlement location, the site is
reasonable accessible to local facilities.
Ecology, Biodiversity and Impact on Existing Vegetation.
7.24 There are no environmental designations covering any part of the site and
also no buildings to be demolished. It does, however, lie opposite the
Carman Muir Local Nature Conservation Site (LNCS) and ecology and
biodiversity considerations arise as a result of this together with the re-
wilding and re-naturalisation of the site and the rural location in the Green
Belt. The application assessment is informed by a preliminary ecological
appraisal. This identifies a variety of habitats within the site, but that these
are in poor condition. No field signs of protected species were identified,
Opportunities for foraging and commuting bats were highlighted, as were
limited opportunities for foraging badger. Opportunities for nesting birds
were also highlighted with recommendations in respect of nesting bird
surveys. The opportunity for biodiversity enhancement is highlighted. 
7.25    The Council’s Biodiversity Officer raises no concerns regarding the findings
or methodology used. However, highlight survey information from the Black
Grouse RSPB monitoring scheme which confirms that there are records of
black grouse within 1.5 km of the proposed development site. The
Biodiversity Officer highlights the requirement for mitigation in this respect.
Conditions can ensure that all recommendations within the Appraisal are
followed including the protection for nesting birds, biodiversity enhancement
and Black Grouse mitigation. 
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7.26   Whilst the site has re-naturalised with vegetation and scrub there are no
significant trees on site and no concerns arise in respect of the impact upon
existing vegetation. 
Flooding Matters
7.27 Concerns regarding flooding are raised in the objections received. Whilst
proposed Local Development Plan 2 identifies the requirement for any
proposals for residential development on this site to be informed by a flood
risk assessment, the site is not shown on SEPA’s flood maps at being at
risk of either river or surface water flooding. The Council’s Roads Service
has considered the proposal and advises that the site is not within an area
at flood risk. They do not identify any requirement for a flood risk
assessment and offer no objections on flood risk grounds. Drainage
arrangements can be addressed by condition. 
Open space provision
7.28 In terms of open space provision for residential developments, this is set out
within Policy GI2 of proposed Local Development Plan 2 together with the
Our Green Network guidance. For small developments of less than 10
houses, a developer contribution is generally considered appropriate rather
than the provision of open space within the development site itself. Open
space calculations together with the level of any contribution are based on
the number of bedrooms provided. As this application is considered in
principle, open space requirements and developer contributions will be
addressed at the detailed stage of the development. 
Other Technical Matters
7.29 The Council’s Environmental Health Service raise no concerns and
conditions are recommended to address the presence of any unexpected
contamination and in respect ensuring the suitability of either re-using site
won material or importing material to the site,  construction hours inclusive
of site deliveries together with dust control.  Scottish Water offer no
objection noting current capacity within the existing network. West of
Scotland Archaeological Service offer no objections and, in noting the
previous development of the site, do not consider any archaeological work
necessary.  
7.30 The requirement to incorporate zero carbon generating technologies and
make provision for the connection of the development to available
broadband networks can be addressed by condition. 
Outstanding points of objection
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7.31 In considering the outstanding points raised in the objection, neighbour
notification is issued to any premises within 20 metres of the application
site. Where there is neighbouring land with no premises, inclusive of private
roads, a press advertisement is placed in accordance with the Town and
Country Planning (Development Management Procedure) Regulations
2013 and this occurred in this instance. Whilst concern is raised that a
neighbouring property did not receive a notification, the curtilage of this
neighbouring property is around 100 metres from the application site and
therefore no neighbour notification was required in terms of the regulations.
The application site, inclusive of sightlines, is clearly defined in red in the
submitted plans. Whilst concern is raised regarding possible confusion with
a nearby premises with a similar name, the correct application site has been
assessed. The submitted plans and drawings clearly indicate the position of
the site within the local context and the relationship of neighbouring
properties is fully understood. The online Portal has been checked and the
application is available for viewing. 
8. CONCLUSION
8.1 The site lies within the Green Belt and the construction of three
dwellinghouses are not designed to accommodate key workers in a local
primary industry such as agriculture, is not a form of development supported
by Policy 8 of NPF4 or Policy GB1 of the adopted Local Plan.
Notwithstanding this, within proposed Local Development Plan 2 that
reflects the Council’s most up-to-date planning policy position, it is identified
as a residential development opportunity. The principle of the residential
development on the site is therefore supported by proposed Local
Development Plan 2, and that three houses could be accommodated within
an appropriate arrangement. It is considered that significant weight can be
attached to the proposed Local Development 2 site allocation in the
determination of this application and that the material considerations are
such that a departure from Policy 8 of NPF4 and Policy GB1 of the adopted
Local Plan can be justified in this instance.
8.2   Overall, the proposal would allow the development of an unmanaged,
previously developed site subject to a suitable design and layout which
responds to the site and is appropriate for the rural landscape. An additional
and welcome benefit of the development would be the improvements to the
tight hairpin bend on Cardross Road adjacent to the site. 
9. CONDITIONS
1. No development shall commence until such time as approval of the detailed
design, layout and other matters associated with the development
(hereinafter called "the matters specified in conditions") has been granted
by the Planning Authority. Any application(s) for approval of matters
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specified in conditions shall be submitted before the expiration of three
years from the date of this planning permission in principle and shall include:
a) the siting, design, external appearance and external materials of all
buildings and other structures;
b) the means of access to the site;
c) the layout of the site, including all car and cycle parking areas;
d) the details of and timetable for the implementation of the hard and soft
landscaping for the site;
e) details of the management and maintenance of the areas identified in
(d) above;
f) full details of the design and location of all boundary walls and fences;
g) the provision of surface water drainage works incorporating Sustainable
Drainage Systems (SuDS). For the avoidance of doubt, the submitted
details shall be in accordance with CIRIA C753, the SUDS Manual and
Sewers for Scotland;
h) the disposal of sewerage;
i) details of existing and proposed site levels;
j) details of the storage and collection of waste and recycling from the new
dwellinghouses;
k) details of required sightlines and visibility splays;
l) biodiversity enhancement measures to be incorporated into the
development;
m) full details of the incorporation of low and zero carbon infrastructure into
the development;
n) details of the provision for electric vehicle charging
2. Notwithstanding condition 1 above, prior to the commencement of
development on site, exact details, specifications and samples of all
proposed external materials to be used within the development site
inclusive of hard surfaces 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 material details and palette.
3. Notwithstanding conditions 1 and 2 above and unless otherwise first agreed
in writing by the Planning Authority, the design and layout of the
development shall generally follow the indicative details submitted and
approved inclusive of siting of the dwellinghouses, one and a half storey
design, pitched roof, light coloured render and use of timber cladding.
4. That with the first application for matters specified by condition application,
full details of the design and implementation of the works to the hairpin bend
in Cardross Road shall be submitted for the written approval of the Planning
Authority. Works shall then proceed as approved.
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5. Notwithstanding the approved plans, all recommendations within the
Preliminary Ecological Appraisal dated 24 March 2023 shall be followed.
6. Notwithstanding condition 5 above, no removal of and vegetation shall take
place during the bird nesting season March to September inclusive unless
first agreed in writing by the Planning Authority and nesting bird survey
undertaken not more than 48 hours prior to the commencement of site
clearance works, the findings of which shall be submitted to the Planning
Authority.
7. Notwithstanding condition 3 above and prior to the commencement of works
on site, full details of mitigation in respect of Black Grouse  shall be
submitted to and approved in writing by the Planning Authority and the
agreed mitigation measures implemented as approved.  The development
shall then proceed as approved.
8. That prior to the occupation of any house, the off-street parking provision
shall be completed and be available for use by residents of the associated
house. The off-street parking provision shall then remain unobstructed and
available for use by residents of the associated house 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 by 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 occupation of the first house within the site, the developer shall
install the necessary infrastructure to enable the full development and all
associated properties 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. No development (other than investigative works) shall commence on site
until such time as a detailed report on the nature and extent of any
contamination of the site has been submitted to and approved in writing by
the Planning Authority. The report shall be prepared by a suitably qualified
person and shall include the following:
a) A detailed site investigation identifying the extent, scale and nature of
contamination on the site (irrespective of whether this contamination
originates on the site)
b) An assessment of the potential risks (where applicable) to:
• human health
• property (existing and proposed), including buildings, crops,
livestock, pets, woodland and service lines and pipes
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• groundwater and surface waters
• ecological systems
• archaeological sites and ancient monuments
c) An appraisal of remedial options, including a detailed remediation
strategy based on the preferred option.
12. No development (other than 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.
13. The approved remediation scheme shall be carried out in accordance with
its terms prior to the commencement of development other than that
required to carry out remediation, unless otherwise agreed in writing by the
Planning Authority. The Planning Authority shall be notified in writing of the
intended commencement of remediation works not less than 14 days before
these works commence on site. Upon completion of the remediation works
and prior to the site being occupied, a verification report which
demonstrates the effectiveness of the completed remediation works shall
be submitted to and approved in writing by the Planning Authority.
14. The presence of any previously unencountered 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 affected area
shall cease. At this stage, if requested by the Planning Authority, an
investigation and risk assessment shall be undertaken and an amended
remediation scheme shall be submitted to and approved by the Planning
Authority prior to the recommencement of works in the affected area. The
approved details shall be implemented as approved.
15. If the remediation plan requires it then a monitoring and maintenance
scheme (including the monitoring of the long-term effectiveness of the
proposed remediation) shall be submitted to and approved by the Planning
Authority. Any actions/measures ongoing shall be implemented within an
agreed timescale with the Planning Authority. Following completion of the
actions/measures identified in the approved remediation scheme a further
report which demonstrates the effectiveness of the monitoring and
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maintenance measures shall be submitted to and approved by the Planning
Authority.
16. 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 used. In
addition to this and in accordance with BS3882:2015 and BS8601:2013,
material to be used in the top 300mm shall also be free from metals, plastic,
wood, glass, tarmac, paper and odours. On completion of the works and at
a time and or phasing agreed by the Planning Authority, the developer shall
submit a verification report containing details of the source of the material
and appropriate test results to demonstrate its suitability for use.
17. Prior to the commencement of development on the site, full details of any
external lighting within the site shall be submitted to and approved in writing
by the Planning Authority. The lighting shall thereafter be installed as
approved.
18. The applicant shall undertake a noise assessment to determine the impact
of noise from nearby noise sources on the proposed development using the
principles set out in British Standard BS 4142:2014 – “Methods for rating
and assessing industrial and commercial sound”, or a method agreed by
the Planning Authority. Where the Level of Significance as described within
the Scottish Government Document: “Technical Advice Note Assessment
of Noise”, identifies changes in noise as moderate or greater (assessed with
windows open), a scheme for protecting the proposed dwelling(s) from
industrial/stationary noise shall be submitted to, and approved by, the
Planning Authority.
The approved scheme for the mitigation of noise shall be implemented prior
to the occupation of the houses and shall be retained in accordance with
the approved scheme. The noise impact assessment and any
recommendations in respect of mitigation measures shall be prepared by a
suitably qualified person.
19. No development shall commence on site until such time as a noise control
method statement for the construction period has been submitted to and
approved in writing by the Planning Authority. This statement shall identify
likely sources of noise (including specific noisy operations and items of
plant/machinery), the anticipated duration of any particularly noisy phases
of the construction works, and details of the proposed means of limiting the
impact of these noise sources upon nearby residential properties and other
noise-sensitive properties. The construction works shall thereafter be
carried out in accordance with the approved method statement unless
otherwise approved in writing by the Planning Authority.
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20. 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
21. 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
BS6472 ‘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.
22. During the period of construction no commercial vehicle making deliveries
to or collecting material from the development shall enter or leave the site
before 08:00 or after 18:00.
23. Unless otherwise approved in writing by the Planning Authority, no
development shall commence on site until such time as a scheme for the
control and mitigation of dust has been submitted to and approved in writing
by the Planning Authority. The scheme shall identify likely sources of dust
arising from the development or its construction, and shall identify measures
to prevent or limit the occurrence and impact of such dust. The approved
scheme shall thereafter be implemented fully prior to any of the identified
dust generating activities commencing on site and shall be maintained
thereafter, unless otherwise approved by the Planning Authority.
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Pamela Clifford 
Planning, Building Standards and Environmental Health Manager
Date: 14th February 2024
Person to Contact: Pamela Clifford, Planning & Building Standards
Manager  
Pamela.Clifford@west-dunbarton.gov.uk
James McColl, Development Management Team
Leader
James.Mccoll@west-dunbarton.gov.uk
Appendix:  Location Plan
Background Papers:
1. Application form, plans and supporting documents;
2. National Planning Framework 4;
3. West Dunbartonshire Local Plan 2010;
4. West Dunbartonshire Local Development Plan 2
Proposed Plan 2020;
5. Consultation responses;
6. Objection received;
7. Application nos: DC02-332, DC10/025/FUL.
Wards affected: Ward 2 (Leven)
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¯
Reproduced by permission of Ordnance Survey on behalf of HMSO. (C) Crown copyright and database right 01/02/2024.
All rights reserved. West Dunbartonshire OS Licence Number 100020790.
Scale: 1:1,250@A401/02/2024
DC22/210/PPP - MapWest Dunbartonshire
Council
16 Church Street
Dumbarton
G82 1QL
ITEM 6a - APPENDIX 1
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager
Planning Committee: 14th February 2024
DC23/177/FUL: Erection of single wind turbine, 30m hub and 43m tip,
access track, substation and associated works at Land to
East of Broomhill Wood, Bonhill, Alexandria by Mr Harris
Smith.
1. REASON FOR REPORT
1.1 The planning application is subject to a substantial body of objection.
Under the terms of the approved Scheme of Delegation, it therefore
requires to be determined by the Planning Committee.
2. RECOMMENDATION
2.1 Grant planning permission and delegate authority to the Planning &
Building Standards Manager to issue the decision subject to the conditions
set out in Section 9 and subject to the conclusion of a legal agreement to
ensure that a suitable financial bond is put in place to cover restoration
liabilities for the site and the community benefit contribution.
3. DEVELOPMENT DETAILS
3.1 The application site is located to the east of Bonhill, Alexandria. The
nearest residential areas are Beechwood and Wheatcroft Estate, Bonhill
located approximately 440m to the west and Bellsmyre which is just over
1km to the south, though there is intervening woodland between the site
and both residential areas. The site is to the north of the Murroch Glen (a
steep wooded valley containing the Murroch Burn), on land which rises to
the northeast into the Kilpatrick Hills. It forms part of an area of plantation
woodland, bordered by the Murroch Glen and areas of grazing land. The
application site boundary extends to 0.89 hectares, but is within a much
larger area of land controlled by the applicant.
ITEM 6b
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3.2 The proposal would involve the following works:
• Installation of a single wind turbine;
• Construction of a 550m access track;
• Construction of an electrical substation and underground cabling;
• Construction infrastructure (e.g. crane hardstanding area);
• Construction of 6 vehicle parking spaces;
3.3 The turbine would be a three-bladed, horizontal axis turbine, with a
nominal rated capacity of 250kW. It would have a hub height of 30m and a
maximum height to the blade tip of 43m. The turbine would be of the
conventional design for such pieces of equipment, featuring a tubular
tower and blades finished in a non-reflective pale grey colour consistent
with the industry standard used in most UK wind turbines. 
3.4 The turbine would sit on a concrete base measuring roughly 7.5m x 7.5m,
with an expected depth of 3m, although the exact design of the foundation
would depend upon which specific manufacturer’s turbine was used
(which is not known at this stage). In addition to the foundation, an area of
hardstanding would be required adjacent to the turbine as a crane platform
for construction and ongoing maintenance. Adjacent to the base of the
turbine would be an external substation measuring approximately 7.5m x
4m, and 2.8m in height. The colour of the substation is currently
unspecified, however the supporting statement suggests it will be either
green or pale grey. Due to the relatively small generator size of the
proposed turbine, a local connection to the distribution network is
anticipated and without the need for more extensive reinforcement or
upgrade works.
3.5 Access to the site would be by way of the existing private access track
leading to Highdykes Farm, which is, itself, accessed from Broomhill
Crescent. A new 550m access track would be created between the farm
track and the proposed turbine. The new track would be 4.5m wide and
surfaced in hardcore, with a passing place and areas to permit the turning
of long vehicles. The road is likely to sit above the existing ground by
approximately 300mm with banking at either side. No borrow pits are
proposed as part of the development and material would be imported to
construct the access track. The level of material required to be imported is
not, however, specified in the application submission. The access track
crosses a drainage ditch around 330 metres from the junction with the
existing farm track, which a short section of pipe being installed below the
hardcore.
3.6 In terms of the planning history of the site, there have been two previous
applications for the erection of a wind turbine of the same size, as well as
the associated access track on this site. 
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The Planning Committee considered the first application (DC14/210) on 29
April 2015 and were minded to grant planning permission subject to the
conclusion of a legal agreement to ensure that a suitable financial bond is
put in place to cover restoration liabilities for the site and the community
benefit contribution. The financial bond was never concluded and with a
lack of any progress over an extended period, the application was
considered withdrawn in March 2021. 
3.7 The second application (DC22/190/FUL) was submitted in 2022. In addition
to the wind turbine and associated works, an agricultural storage shed was
also proposed as part of this application. All planning application proposals
require to be considered as a whole and in assessing the application it was
concluded that the proposed shed was not a form of development which
could be supported in this Green Belt location and would result in an
unjustified sporadic development within the Green Belt. The application was
refused by Planning Committee on 2nd August 2023 for the following reason:
1. It has not been demonstrated that the proposed agricultural shed is
being provided in association with an agricultural land holding, nor has
the nature of any farming operation at this location been quantified.
Therefore it cannot be concluded that the proposed shed is specifically
required to support agriculture at this green belt and the shed would
result in unjustified sporadic development within the green belt
location. It is thus not a form of development that is supported in the
green belt by Policy 8 – Green Belts of the National Planning
Framework 4, Policy GB1 – Green Belt of the adopted West
Dunbartonshire Local Development Plan, Policy GB1 – Greenbelt and
Countryside of the proposed West Dunbartonshire Local Development
Plan 2.
This refusal of planning permission was not appealed to the Scottish
Government Planning and Environmental Appeals Division.
3.8 Works to create the access track associated with the wind turbine
commenced on site prior to this application being determined. The
applicant was advised that the works were being undertaken without
planning permission. The applicant was requested on a number of
occasions to stop works until such time that planning permission was
granted. The applicant continued works on the access track and a
Temporary Stop Notice was subsequently issued. Works initially continued
after the Notice was issued and then halted. At the expiry of the
Temporary Stop Notice works commenced again, despite it remaining that
no planning permission was in place. 
3.9 Further to the refusal of application DC22/190/FUL, an Enforcement Notice
was issued requiring the removal of the partially constructed access track.
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The applicant appealed this Enforcement Notice which was dismissed by
the Reporter of the Planning and Environmental Appeals Division of the
Scottish Government. Reports from residents within the area suggested that
works were ongoing to further develop the track. However a site visit on 30th
January 2024 has confirmed that the works are ongoing to remove the track
in accordance with the requirements of the Enforcement Notice.
4. CONSULTATIONS
4.1 West Dunbartonshire Council Environmental Health Service have no
objections to the proposal and recommends the following conditions
regarding noise in relation to the turbine, noise complaints, wind data,
point of contact, hours of work, delivery vehicles during construction,
construction noise, and noise attenuation.  
4.2 West Dunbartonshire Council Roads Service have no objections in relation
to flooding matters. A Traffic Management Plan was submitted and the
Roads Service confirmed that the clarifications and qualifications
contained within the plan made the proposal acceptable to the Roads
Service. 
4.3 West of Scotland Archaeological Service (WoSAS) have no objection
subject to a condition requiring the implementation of an archaeological
watching brief.
4.4 West Dunbartonshire Council Biodiversity Officer has no further comments
to make on the current proposal. Comments from the previous application
note that the Preliminary Ecological Assessment submitted offers
mitigation in section 7 of the document and should be conditioned if the
development is to proceed. The proposed mitigation includes following
national guidelines and standards for any tree/hedgerow retention, that
best working practice measures are adhered to safeguard otters and
badgers, and a walkover survey prior to works commencing within bird
breeding season. If any otter or badger resting place is found then an
ecologist should produce an otter protection plan. Should the development
proceed there should be a clear intention provided of the biodiversity
enhancement works that will be included to meet the requirements of
NPF4 Policy 3. It should be specifically noted what is being regarded as
mitigation and enhancement so that a clear picture of the ‘positive effect
on biodiversity’ can be determined.
4.5 Glasgow Airport and National Air Traffic Services have no objections to the
proposal.
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4.6 RSPB Scotland note that the previous ecological report appears to be
based on site visit(s) during December 2022 (so outside the
recommended dates for protected species surveys) and the conclusion
that there would be no impact on birds was based on a desktop study
using only freely available data rather than survey visits – and so no actual
survey work had taken place. The updated application mentions NPF4
policies, but again says that based on an assessment in support of the
application, it concludes there will be no material impact on biodiversity,
including birds. It is unclear how this can be assessed from the data
provided. There is also no mention of proposed biodiversity
enhancements.
4.7 Stirling Council and Inverclyde Council have no objections to the proposal.
4.8 Loch Lomond & The Trossachs National Park Authority and Argyll and
Bute Council have not provided a response at the time of writing this
report.
5. REPRESENTATIONS
5.1 Fifty eight representations from fifty seven representees have been
received in connection with the proposal including from Beechwood &
Wheatcroft Residents Association. All are in objection. The full details are
contained within the planning file and are available for public viewing.
However, the points raised can be summarised as follows:
Roads and traffic
• The estate roads are not suitable for heavy vehicles.
• There will be a noise impact from the HGV traffic.
• Concern for children and elderly in relation to the increase in traffic.
• There was never a road in this location before.
Location and visual impact of the development
• Concern for the visual impact on Dumbarton Rock, cluttering the
backdrop to & from the Kilpatrick and Lang Craig Hills & the Pappert
Well.
• No access track previously existed at this location previously.
• There are industrial estates within Dumbarton and Vale of Leven which
are more suited to a development of this nature.
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Residential amenity
• Nearby residents would be adversely affected by noise disturbance.
• There are potential health side effects from living beside a wind
turbine, including from vibration, shadow flicker and ice throw.
• The area is a residential area and is too close to residents/houses.
• Scottish Government guidelines state that wind turbines should be no
closer than 2km away from residential properties.
Environmental matters
• Air pollution may result from the development, particularly during
construction.
• The development would adversely impact upon wildlife, trees, and
hedgerows.
Procedural concerns
• The applicant has not attended the resident’s association meetings to
discuss their plans.
• The applicant has not met his legal obligation to the residents to provide
compensation for previous work.
• There is no stated business aim and no community benefit.
• There is no stated life of the turbine and no bond for restoration on
decommissioning.
Other matters
• What is the energy to be used for?
• The applicant intends to produce bio fuel which is not on the application.
• No connection to the grid has been indicated.
• The turbine name no longer seems to be in production.
• Property prices will be affected.
• Approval would set a precedent and open the area to further large scale
turbines.
• West Dunbartonshire Council’s Open Space Strategy 2011 states that
planning authorities are expected to support, protect and enhance open
space and opportunities for sport & recreation.
5.2 The matters of concern raised above are addressed in Sections 6 and 7
below.
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. 
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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 states that development proposals will contribute to the
enhancement of biodiversity and should integrate nature-based solutions
where possible. Proposals for local development will include appropriate
measures to conserve, restore and enhance biodiversity, in accordance
with national and local guidance. Policy 4 requires that development
proposals do not have an unacceptable impact on the natural environment
inclusive of environmental designations and protected species. Policy 5
states that development proposals will only be supported if they are
designed and constructed in accordance with the mitigation hierarchy by
first avoiding and then minimising the amount of disturbance to soils on
undeveloped land and in a manner that protects soil from damage
including from compaction and erosion that minimises soil sealing. 
6.3 Where there is potential for non-designated buried archaeological remains
to exist below a site, developers will provide an evaluation of the
archaeological resource at an early stage so that planning authorities can
assess impacts in accordance with Policy 7.
6.4 Policy 8 supports development within the green belt in a limited number of
circumstances. These include: 
• development associated with agriculture, woodland creation,
forestry and existing woodland (including community woodlands);
• horticulture, including market gardening and directly connected
retailing, as well as community growing;
• essential infrastructure or new cemetery provision;
• minerals operations and renewable energy developments;
• intensification of established uses, including extensions to an
existing building where that is ancillary to the main use.
Additional requirements include justification is provided for the green belt
location; the purpose of the green belt is not undermined by the
development; the development is compatible with the surrounding
countryside and landscape character; the development is of an
appropriate scale, massing and external appearance and minimises visual
impact; and there will be no long-term impacts on the environmental
quality of the green belt.
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6.5 Policy 11 supports proposals for all forms of renewable, low-carbon and
zero emissions technologies. Policy 11 also states that development
proposals will only be supported where they maximise net economic
impact, including local and community socio-economic benefits such as
employment, associated business and supply chain opportunities. The
policy also lists impacts which must be addressed including residential
amenity, visual impact, noise and shadow flicker, impacts on road traffic
and on adjacent trunk roads, including during construction; and the quality
of site restoration plans including the measures in place to safeguard or
guarantee availability of finances to effectively implement those plans.
6.6 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 20 states that development proposals that result in
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. The planning
authority’s Open Space Strategy should inform this. Green infrastructure is
defined as features or spaces within the natural and built environments
that provide a range of ecosystem services. An ecosystem services is the
benefits people obtain from ecosystems.
6.7 Policy 23 relates to health and safety and states that development proposals
that are likely to raise unacceptable noise issues will not be supported. A
Noise Impact Assessment may be required where the nature of the proposal
or its location suggests that significant effects are likely.
6.8 The matters relevant to the assessment against the above policies are
addressed in detail in Section 7 below. Based on that assessment, it is
concluded that the proposal is in accordance with NPF4.
West Dunbartonshire Adopted Local Plan 2010 
6.9 The site of the proposed turbine is identified as Green Belt. Policy GB1
indicates a general presumption against development within the Green
Belt, other than in certain circumstances, including where there is a
specific locational requirement and established need for the development
and it cannot be accommodated on an alternative site. Development in the
Green Belt will not be permitted if it would have an adverse effect on the
landscape character of the area.
6.10 All development is expected to be of a high quality of design and to respect
the character and amenity of the area in which it is located in accordance
with policy GD1. 
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6.11 Policy E5 relates to development affecting trees. There are trees on site
which line the proposed access route. In accordance with policy E5 new
development proposed on sites with, or adjacent to, existing trees will be
assessed in accordance with best practice. Policy BE5 states that where
the presence of archaeology becomes apparent once development has
commenced, adequate opportunity must be afforded by the developer for
an archaeological investigation. 
6.12 The development takes access via a designated core path and as such
policy R5 applies. Policy R5 states that the Council will undertake to protect
Core Paths using the Council’s statutory powers.
6.13 Policy DC6 states that renewable energy proposals will be permitted
where these would not give rise to unacceptable detriment to the
landscape, natural or build heritage, sport or recreation interests or local
amenity. Development proposals are to be considered against the
following criteria:
• visual impact and effect on landscape character, including the
landscape character of the Kilpatrick Hills RSA;
• nature conservation interests;
• historic environment and its setting, including scheduled ancient
monuments;
• local amenity, including noise, traffic and broadcast interference;
• any cumulative impacts.
6.14 Policy DC3 states that within the Glasgow Airport Safeguarding Zone,
development which adversely affects the operational integrity or safety of
the airport will not normally be permitted.
6.15 Policy GN1 seeks to promote, protect and improve the Green Network. It
states that development which is detrimental to the green network will be
considered contrary to the Plan, and that new development should
contribute positively to the protection and improvement of the green
network. The Kilpatrick Hills are recognised as an important green network
resource in West Dunbartonshire owing to their landscape value, the
habitats and species found there and the outdoor recreation opportunities
they offer. Policy SUS1 states that all development should seek to
conserve and enhance environmental resources and ensure
environmental impact is minimised.
6.16 Policy E3A states that the Council will seek to maintain and enhance the
environmental resources of the Plan area by protection of habitats,
species and natural features which are vulnerable and/or specifically
protected, including Local Nature Conservation Sites. It also states that
proposals should not have an adverse effect on the integrity or character
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of Local Nature Conservation Sites and that satisfactory arrangement for
habitat creation/site enhancement elsewhere should be made to
compensate where development would cause the total or partial loss of a
Local Nature Conservation Site. The application is in close proximity to
Murroch Burn but is located outwith the Local Nature Conservation Site. 
6.17 The matters relevant to the assessment against the above policies are
addressed in detail in Section 7 below. It is concluded that the proposal is
in accordance with the Local Plan.
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.
7.2 The proposed turbine does not trigger Policy RE2: Spatial Framework for
Wind Energy, and therefore requires to be assessed against Policy RE3,
which is supportive of wind energy proposals where it can be
demonstrated that there will be no unacceptable significant adverse
impacts on the local area and the wider landscape and where they avoid
unacceptable landscape, visual, aviation, infrastructure, cumulative and
residential impacts and unacceptable impacts on the built and natural
environment and do not have an adverse effect on a Natura 2000 site. 
7.3 Policy GB1 restricts development in the green belt to a limited number of
circumstances. These include development associated with agriculture,
horticulture and forestry, rural economic development and infrastructure
with a specific locational need. 
7.4 Any development proposed within the Kilpatrick Hills Local Landscape Area
must; protect and enhance the landscape character; protect and enhance
the integrated network of habitats and important geological features; and
protect and enhance the Hills as an accessible recreation resource in
accordance with policy KH1. 
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7.5 Policy H4 of the LDP2 relates to residential amenity. The policy states that
the Council will protect, preserve and enhance the residential character
and amenity of existing residential areas at all times In this regard, there
will be a general presumption against the establishment of non-residential
uses within, or in close proximity to, residential areas which potentially
have detrimental effects on local amenity or which cause unacceptable
disturbance to local residents.
7.6 Policy ENV2 relates to landscape character. Development proposals should
be sited and designed to relate to the local landscape character of the area
and ensure that the integrity of this landscape character is maintained and,
where appropriate, enhanced. Policy ENV4 relates to forestry, trees and
woodland. The loss or fragmentation of long established woodland, high
conservation value or areas covered by tree preservation orders will only be
supported where any significant adverse effects are clearly outweighed by
significant social or economic benefits. Policy ENV8 relates to air, light and
noise pollution. All new development must ensure that significant adverse
noise impacts on surrounding properties and uses are avoided. 
7.7 Policy CON3 is not supportive of development which disrupts or adversely
impacts on any existing or potential core path, right of way, bridle path, or
footpath, including off-path access rights, used by the general public for
recreational or other purposes. 
7.8 Policy BE1 states that unscheduled archaeological sites should be
preserved insitu where possible. Where not possible, provision should be
made by the developer to undertake the excavation, recording analysis,
publication and archiving of the archaeological remains. Development that
would adversely impact on the operations of Glasgow Airport or would be
adversely affected by aircraft noise will not be permitted in accordance with
Policy E7. 
7.9 Policy CP1 requires new development to take a design led approach to
creating sustainable places which puts the needs of people first and
demonstrate the six qualities of successful places. Policy CP2 requires all
development to demonstrate that green infrastructure has been integrated
into the design approach from the outset.
7.10 The matters relevant to the assessment against the above policies are
addressed in detail below. It is concluded that the proposal is in accordance
with proposed Local Development Plan 2. 
Kilpatrick Hills Local Landscape Area – Statement of Importance
7.11 This Statement of Importance explains the reasons why the Kilpatrick Hills
have been selected for the designation. The special qualities of the
Kilpatrick Hills are identified as being:
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• Strong sense of remoteness, wildness and open horizons;
• Distinctive geomorphology and topographical features; and
• A unique diversity of views.
The impact of the proposed development on these special landscape
qualities of the Kilpatrick Hills is assessed below, and it is concluded that
the proposal would not significantly detract from the special qualities of the
Local Landscape Area.
Renewable Energy Local Development Plan (Proposed Plan) Planning
Guidance November 2016
7.12 Whilst written in the context of proposed Local Development Plan 1
together with Scottish Planning Policy (SPP), both of which no longer form
a material consideration in the assessment of planning applications, much
of the general advice and guidance set out remains relevant in assessing
wind energy proposals. 
This document provides guidance on planning for wind energy including a
Spatial Framework and guidance on the factors that will be considered in
assessing wind energy proposals. The spatial framework applies to “wind
farms” which are defined by the Council as:
• Any development containing a turbine of 50m and above to tip
height; or
• Any development of 3 or more turbines, containing a turbine of
30m above to tip height.
As this turbine is a single turbine and 43m to blade tip it falls under the
threshold for assessment under the spatial framework. 
7.13  It remains, however, that the document provides guidance on the
assessment of all proposals for wind energy. This includes considering
matters pertaining to landscape character, forestry and woodland, the
water environment, the path network, built heritage, aviation, residential
amenity in respect of noise, shadow flicker and visual intrusion, economic
benefit, contribution towards renewable energy targets, effect on soils,
impact on the road network and decommissioning. These matters are fully
assessed in detail below where it is concluded that, in taking into account
all material planning considerations, the wind turbine proposal is
acceptable. 
7.14 The guidance also highlights the expectation for all wind energy
applications to provide a community benefit. In this case, the proposed
turbine is indicated to have generating capacity of 250kw so any financial
amount will be small. 
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However, the guidance does not have a minimum threshold and therefore
this is aspect is applicable and a financial contribution would be required if
the proposal is approved. 
Overall, it is considered that the proposal presents no conflict with the aims
of the guidance. 
Site Selection and Design
7.15 The application site was selected by the applicant as it was established to
benefit from an above average windspeed. Further operational
advantages include its proximity to a grid connection point and the
proximity off the A82 being relatively short without requiring extensive
works impacting the local road network. In terms of impacts on the
surrounding area, although the nearest settlement to the site (Bonhill) is
located only 440m away, the site is well screened from it by high ground
and trees. The 440m distance from residential properties is noted in
multiple objections as being too close due to Scottish Government
Guidance. However the guidance which notes 2km as being the
separation distance relates to wind farms and is also contained within
Scottish Planning Policy, which has been superseded by National
Planning Framework 4. 
7.16 The wind turbine is located in the green belt and requires to be justified
against Policy 8 of NPF4 and GB1 of both the adopted Plan and Proposed
Plan. Essential infrastructure is acceptable within the green belt with
reference to the above policies. Essential infrastructure includes all forms
of renewable energy generation. Therefore the wind turbine itself together
with the associated access, crane pad and sub-station would in principle
be acceptable. The design and height of the turbine would follow current
wind energy industry practice, and the turbine would be of the type widely
used elsewhere. The location of the proposed turbine has also been
selected in order to minimise its prominence. Due to the height of the
turbine, some views from sensitive locations such as the Loch Lomond
and the Trossachs National Park and Kilpatrick Hills are unavoidable but
not significant enough to be unacceptable. It is acknowledged that an
effort has been made by the applicant to minimise the impact of the
development on the landscape.
Impact on Landscape Character
7.17 The proposed turbine would be located on the edge of the Kilpatrick Hills
which are designated as “Rugged Moorland Hill” Landscape Character
Type (LCT). The actual application site is on the boundary of the urban
area and the Rugged Moorland Hill LCT of the Kilpatrick Hills. The
Kilpatrick Hills have a distinctive upland character created by the
combination of elevation, exposure, rugged landform, moorland vegetation
and the predominant lack of modern development. 
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These areas share a sense of apparent naturalness and remoteness
which contrasts strongly with the farmed and developed lowland areas.
The general aim should be to conserve the upland character of the
Rugged Moorland Hills and where possible, the visual influence of existing
developments should be reduced. New developments which would
introduce modern elements or which would undermine the sense of
`wildness' and remoteness should be resisted even though it is accepted
that these areas already contain tall structures such as pylons and
communications masts. Although this landscape can provide an essential
location for this type of infrastructure, the erection of certain structures can
lead to disproportionate levels of landscape impact, affecting the remote
character of the moorland hills. Additional masts and other tall structures
should be discouraged within the hills, with particular concerns relating to
wind development. It is therefore vital that developments which could have
a significant and adverse effect on the landscape character are resisted. 
7.18 In general, there is limited capacity to accommodate wind turbines within or
adjacent to the Rugged Moorland Hill LCT of the Kilpatrick Hills, particularly
in areas which are identified as Green Belt and which form part of the
landscape and recreational setting for the settlements which they surround.
In this instance however, the sloping ground and established tree coverage
would help to screen the site from surrounding areas. This tree cover would
also limit the visibility of the proposed access track. The proposed turbine
would be viewed from certain positions in the context of an urban area,
backclothed by the hills and woodland and importantly, it would not impact
upon the skyline or detract from the remoteness of the Kilpatrick Hills. On
this basis, it is considered that the wind turbine would not have a significant
impact on the landscape quality or the character of the Kilpatrick Hills and
surrounding area. This is a similar opinion taken when 2014 previous
application was assessed and approved.
Designated Landscapes
7.19 Regional Scenic Areas/Local Landscape Areas are landscapes which
have been designated as of local importance by the relevant local
planning authority. Such designations seek to preserve a high quality
landscape and its natural character. The Regional Scenic Area/Local
Landscape Area most affected by this proposal is the Kilpatrick Hills
Regional Scenic Area/Local Landscape Area, which covers the area of the
Kilpatrick Hills located within the West Dunbartonshire Council area. The
wind turbine would be located in close proximity to the Kilpatrick Hills
Regional Scenic Area but within the more recently designated Local
Landscape Area. Whilst the site is readily visible from a wide area within
the Regional Scenic Area/Local Landscape Area the turbine would be
close to the urban edge where it would be seen against the backdrop of
other man-made development. 
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When viewed from outwith the Regional Scenic Area/Local Landscape
Area it would normally be seen against a backdrop of rising land and it
would not break the skyline. Although it would introduce a large man-
made structure into the environment, the turbine would not be visually
dominant or would detract from the sense of remoteness and wildness
provided by the Kilpatrick Hills. The overall impact upon the Regional
Scenic Area/Local Landscape Area is therefore considered to be
acceptable. The turbine would be 4km from the southern boundary of
Loch Lomond and Trossachs National Park. Whilst it would be visible from
some places within the National Park, it would be seen in the context of an
urban area, backclothed by the hills and woodland and would not impact
on the skyline of the Kilpatrick Hills which forms part of the setting of the
National Park. This was previously confirmed as part of the response to
the last planning application by the Loch Lomond and Trossachs National
Park Planning Authority in their consultation response. Since then, nothing
significant has changed in terms of changes to the landscape character to
arrive at a different opinion. There is also no change in the proposed
access track and this, together with the other infrastructure proposed
raises no concerns.
Visual Impact
7.20 The information accompanying the application demonstrates that the wind
turbine would not be visible from most of the closest built up area (Bonhill)
because of the intervening high ground, but that it would be visible from
much of Dumbarton and from areas further afield such as Port Glasgow, at
distances of up to 10km. However, when viewed from distance, it would be
difficult to differentiate the turbine from the overall urban context due to the
proximity of the turbine to the built up area of Bonhill. Consequently, the
visual impact would be less significant from greater distance. Outwith
settlements, the wind turbine would be visible from much of the western
shore of Loch Lomond, the River Clyde and areas within the Kilpatrick Hills.
However, due to the distances involved and the size of the turbine, it will not
have a significant impact on the landscape from distance and therefore will
have an acceptable visual impact. 
7.21 The applicant has provided photomontages and wireframe drawings for
each of 20 previously agreed viewpoints, in accordance with the national
methodology for such visual modeling exercises. These photomontages
provide a representation of how the turbine might typically appear in clear
weather from representative and sensitive locations, although obviously
the appearance would vary according to weather conditions. The majority
of the viewpoints demonstrate that the turbine would not be visible or that
it would be seen at sufficient distance to have little impact on the
landscape. From the viewpoints at Auchiewannie Wood and Cardross
Road, the turbine would be visible to the rear/side of the settlement of
Bonhill. 
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Further viewpoints at Auchenreoch Muir and the core path at Highdykes
Farm show the turbine appearing more dominant in views looking
south/south west. It is accepted that turbine development cannot take
place on this site without being visible from a large area, however the size
of turbine proposed is suitable for the location and will minimise any visual
impacts beyond 5km and the proposal is therefore acceptable.
7.22 The landform behind the turbine provides a backdrop setting which would
ensure that from most viewpoints, the turbine would not breach the skyline
of the Kilpatrick Hills. Although the turbine is a total height of 43 m, the
location, size and setting of the turbine are such that it will not have a
detrimental visual impact on the Kilpatrick Hills regional scenic area or
significantly alter the local landscape. It is further considered, the access
track would not result in an adverse visual impact within the landscape. 
Residential Amenity
7.23 The proposed turbine would be located 440m from the edge of Bonhill, but
its impact would be minimal as between the proposed turbine and the
settlement is an area of plantation woodland and a further area of
woodland adjacent to the houses. This would provide adequate separation
in terms of both amenity and visual impact, ensuring that the turbine would
be adequately screened from the nearest residential properties. Whilst the
wind turbine may be visible from some urban areas further from the site,
such as Dumbarton and parts of Alexandria, it would be sufficiently distant
to avoid being visually dominant and therefore it would have an
acceptable impact. The proposed access track takes access from an
existing track which serves Highdykes Farm. It is visually separated from
the nearest residential neighbours by trees. As part of the operation of the
turbine there are minimal traffic movements proposed. As such the
proposed access road will not have an unacceptable impact to residential
amenity. 
Shadow Flicker
7.24 Shadow flicker is the flickering effect caused when rotating wind turbine
blade periodically cast shadows through constrained openings such as the
windows of neighboring properties. The distance at which shadow flicker
is created is accepted to be 10 times the rotor diameter. In this case the
rotor diameter is 26m and as such the distance would be 260m. The
closest property to the proposed wind turbine is 65B Broomhill Crescent,
notes at 447m away from the proposed turbine. The application also gives
scope for a 25m buffer for micro siting. This could mean the turbine could
be 422m away from 65B Broomhill Crescent, however this is still outwith
the 260m distance at which shadow flicker could be created. 
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The Council’s Environmental Health Service have raised no objection in
this regard, although they nonetheless recommend a condition for any
granting of permission, requiring the site operator to investigate any
complaints and instigate appropriate mitigation measures in the event of
shadow flicker occurring.
Noise & Air Quality
7.25 Turbines produce two distinct types of noise – the mechanical noise
produced by the machine and the aerodynamic noise produced by the
passage of the blades through the air. The “Assessment and Rating of
Noise from Wind Farms” (Final Report, Sept 1996, DTI), (ETSU-R-97)
provides a UK framework for the measurement of wind turbine noise,
including indicative noise levels deemed to be appropriate. Subsequent
UK government reports have concluded that there is no evidence of health
affects arising from infrasound or low frequency noise generated by
turbines.
7.26 The supporting information predicts that the operation of the wind turbine is
capable of meeting ETSU-R-97 standards at the nearest properties, the
closest of which is 440m from the proposed turbine location. Hours of work
could be limited by condition to avoid disturbance during the construction
phase to nearby residential properties. The Council’s Environmental Health
Service has no objection to the proposal on noise grounds subject to
appropriate conditions. No issues have been raised in terms of air quality.
Road Traffic Impact
7.27 As part of the proposal, an access track is proposed which joins the
existing farm track leading from Broomhill Crescent at the point before the
entrance to Highdykes Farm. As noted above, the construction of this
track has already commenced. The applicant has stated that this was
done as the access track was existing and was being upgraded. The
Traffic Management Plan submitted as part of the application states that
where practicable, material for the access track and hard standings will be
recycled material that is available on-site. Any additional material that is
required shall be sourced from a local quarry. As part of the “proposed”
access track already constructed on site, it is clear that recycled materials
have not been used. Deliveries have occurred from local quarries,
however, there appears to have been no co-ordination of or a structured
approach to deliveries which the objections highlight has caused
congestion on the residential roads with large delivery vehicles being
unable to pass on both the residential roads and the farm track. If the
application is approved, a robust condition regarding a delivery
management strategy for materials delivered on site would be required to
ensure that the further importation of material would be carefully managed
and to minimise the disruption to adjacent residential properties. 
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The Council’s Roads Service have no objections to the proposal subject to
the implementation of the Traffic Management Plan. Comments raised in
objections regarding continuous traffic from a wood mill/sawmill/bio fuel
facility cannot be considered at this time due to the application not
including such details. The wind turbine and its construction is not
considered to be a large traffic generating use. Whilst concerns are raised
in respect of potential to damage to road surfaces, any damage that did
occur would be a matter to be addressed in conjunction with the Council’s
Roads Service. 
7.28 Once operational a wind turbine would generate negligible traffic, but the
size of the turbine components is such that delivery of the turbine to the
site can cause disruption due to oversized loads. Deliveries would be from
the south, off the A82, onto Stirling Road (A813) heading northbound and
then towards the Nobleston roundabout. From there any deliveries would
traverse onto residential roads to the south of the Bonhill area via
Beechwood Drive, Murroch Crescent and Broomhill Crescent before
moving onto the access track and onto the “proposed” access into the site.
The Traffic Management Plan states that from point 6
Redburn/Beechwood Drive measures would be required in order to
facilitate the deliveries of the wind turbine. For the duration of the journey
a support vehicle is recommended. At point 6, the open verges would
need to be used and a banksman and support vehicle. The same applies
for point 7 Beechwood Drive / Murroch Crescent. Once the turbine
delivery would reach point 8 Murroch Crescent/Broomhill Crescent the
previous measures as well as the clearing of parked cars is
recommended. At point 10, the alignment of the track is noted to be a
“concern”. It is indicated that the track would be required to be widened to
support load-bearing surface to the western edge. This track is not,
however, included within the applicant’s ownership or within the red line
boundary of the site. Accordingly, any works required to this track would
be a civil matter between the parties involved and if the works are to an
extent that planning permission is required, a separate application would
require to be brought forward in this circumstance. Point 11 is from the
“proposed” new access track which has been designed for the proposed
use.
Impact on recreation, open space and the core path network
7.29 The development will not result in the loss of open space that has been
laid out with the purpose of providing amenity, an area of public access or
an area for countryside recreation. There is also no impact on any areas
of open space specifically identified on the Proposals Maps of the adopted
local plan or proposed local development plan. Consequently, it is not
considered that the proposal will adversely impact on open space or
countryside recreation or the sustainable access to such.
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7.30 The existing access track to Highdykes Farm which will provide access to
the application site is designated as a core path. Whilst this track will be
used to access the site and for deliveries during construction, overall the
impact on users of the core path will be minimal during construction and
following completion it is not considered there will be any discernible
impact.
Cumulative Impacts
7.31 The proposal would be the first significant wind turbine to be located within
the West Dunbartonshire area, so there would be no localised cumulative
impacts. The proposed wind turbine is well separated from other wind
turbine development in neighbouring Council areas.
Natural Heritage – Designated Sites/Peat and Soils/Habitats/Protected
Species/Ornithology
7.32 There are no site-specific statutory nature conservation designations
within the site and it is not considered that the proposal would have any
detrimental impact on any other designated sites. A Preliminary Ecological
Assessment (PEA) was submitted in support of the application. The
surveys included an extended Phase 1 habitat survey with protected
species walkover survey, which considered not only habitats and species
of plant present but also the potential presence of relevant European
Protected Species (Bats and Otters, Badgers, Water Voles and breeding
birds). It was concluded that in general, habitats and plant species were
common and typical of former agricultural land that has been planted up
with young deciduous woodland, with no notable species found. Habitats
and plant species are therefore not considered ecological constraints for
the proposed development. Bats, badgers, otters, water voles and
breeding birds were also considered not to be an ecological constraint in
the PEA. 
7.33 The consultation response from the RSPB notes that the site visit for the
PEA was carried out in mid-December 2022 (which is now outside the
recommended dates for protected species surveys). The conclusion that
there would be no impact on birds was based on a desktop study using
only freely available data rather than survey visits – and so no actual
survey work has taken place. The PEA states that if site preparation work
is to be undertaken between March and September that the presence of
breeding birds should be assessed by an ecologist prior to work
commencing on site. As it is an offence to disturb any active bird nest, any
granting of permission would require a condition relating to acceptable
months for working or further survey work to establish that there are no
breeding birds. The RSPB also note that the updated application mentions
NPF4 policies and concludes there will be no material impact on
biodiversity, including birds. 
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Whilst the RSPB state that it is unclear how this can be assessed from the
data provided, they raise no specific concerns regarding potential impact
on any particular bird species, migratory routes, the general commuting
and foraging of birds within the locality or a concern regarding bird
collisions. No information is highlighted in respect of a need for specific
avoidance or mitigation in respect of birds. 
7.34 The Council’s Biodiversity Officer previously noted that no additional
species protection plans or follow up surveys were identified in the PEA.
The proposed mitigation includes following national guidelines and
standards for any tree/hedgerow retention, that best working practice
measures are adhered to safeguard otters and badgers, and a walkover
survey prior to works commencing within bird breeding season. If any otter
or badger-resting place is found then an ecologist will produce an otter
protection plan. It can therefore be concluded that the proposal will not
adversely impact upon protected species and it is appropriate that the pre-
start surveys and any required protection plans identified at this stage are
conditioned should the development proceed. Special Protection Area
(SPA) connectivity is not mentioned as an issue in the PEA. Annex 1 of
Nature Scot’s “Assessing the impact of small-scale wind energy proposals
on the natural heritage” guidance document considers SPA’s within a
20km connectivity zone to be relevant. Therefore, both Inner Clyde SPA
and Loch Lomond SPA should be considered. Greenland White - Fronted
Goose is the relevant species to be considered and has a core foraging
range of 5-8km. The Loch Lomond SPA is around 10km from the
proposed development site and therefore falls out with requirement for
further assessment. The Carbon and Peatland 2016 map shows the site
area to not be within an area of peatland. Whilst acknowledging the points
highlighted in the consultation response from the RSPB, having fully
considered the impact upon ecology, and informed by the consultation
response from the Council’s Biodiversity Officer, subject to condition, the
impacts of the development upon designated sites, peat and soils,
habitats, protected species and ornithology are all considered acceptable.
Hydrological & Hydrogeological Impact
7.35 The Supporting Statement provided as part of the application states that
the site has no watercourses within it, and it is not anticipated that the
development would impact significantly upon any water course or local
groundwater. During site visits, it was noted that the access road (being
constructed without the benefit of planning permission) crossed a small
drainage ditch and the road thus included a small section of pipe at this
location. No concerns arise from this arrangement and no wider issues are
considered to arise in this respect. 
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Historic Environment Impacts
7.36 No historic buildings or monuments are located within the site. There are a
number of monuments in the vicinity of the site, although there would be
no direct impact on these from construction or operation of the wind
turbine. In regard to archaeology, WoSAS have no objection however the
implementation of an archaeological watching brief would be required prior
to the commencement of any development on site.
Renewable Energy Targets
7.37 Scotland’s long-term climate change targets will require the near-complete
decarbonisation of the energy system by 2050, with renewable energy
meeting a significant share of the need. The Scottish energy strategy sets
a 2030 target for the equivalent of 50% of the energy for Scotland’s heat,
transport and electricity consumption to be supplied by renewable
sources. This approach is supported via NPF4’s just transition spatial
principle that seeks to empower people to shape their places and ensure
the transition to net zero is fair and inclusive.
Economic Impact
7.38 The proposed development would have minimal impact on the potential
use of the wider area for grazing or forestry whilst the construction of the
wind turbine would provide some short-term employment during
construction. In the longer term, once completed and operational, there
would be a requirement for site maintenance, although it is acknowledged
this would likely be minimal. It is not considered that the proposed wind
turbine would have any impact on tourism within West Dunbartonshire or
neighbouring areas. It is therefore considered that whilst any development
of this nature will have a positive impact, the scale of the development
would result in the long-term economic benefits being negligible. 
Community Benefit
7.39 The Council’s Renewable Energy Planning Guidance (2016) states that in
line with Scottish Government guidance, the Council expects all wind
energy applicants to provide a community benefit of a minimum £5,000
per MW of installed capacity. This would be payable annually and would
increase relative to the Retail Price Index. The contribution is expected
from all wind energy developments. As such it is recommended that
should the application be granted, a legal agreement should be put in
place to address the community benefit contribution. 
Aviation Safety
7.40 NATS and Glasgow Airport have no objections in terms of airport
safeguarding.
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Decommissioning
7.41 Should permission be granted, there would be a requirement for
decommissioning and site restoration. A legal agreement to ensure that a
suitable financial bond is put in place to cover restoration liabilities for the
site would be required. Site restoration would be triggered by either the
expiry of any permission or if the project ceased to operate for a specific
period of time.
Matters raised in objections
7.42 A wide range of matters were raised in the objections received, many of
which are already addressed as part of the main assessment set out above.
Multiple objections question what the energy is to be used for and that no
grid connection has been shown. A lack of grid connection, however, can
be done via a separate consenting process where required. 
7.43 The availability of the turbine type which has been applied for has been
brought into question. However, the application notes that the final choice
of the wind turbine will be dependent upon availability. Conditions
associated to any granting of permission would ensure that the impact of
any turbine would remain the same. 
7.44  Alternative locations for the proposal have been suggested, however the
applicant has stated that this is a good site for wind energy creation due to
wind speeds and the application requires to be assessed on its own merits.
It is contended that the applicant has indicated to residents that he intends
to produce bio fuel. The application form and supporting documents do not
indicate this and the Planning Authority can only assess the submitted
proposal. Matters relating to traffic and the road have been assessed above.
7.45 Whilst there has been some removal or trees and hedgerows these are not
protected and the extent of the removal undertaken is in any case limited.
Matters raised in respect of the Council objective for Natural & Semi Natural
Green Space and the impact on the green belt are assessed above.
7.46  One objector states that West Dunbartonshire Council’s Open Space
Strategy 2011 states that planning authorities are expected to support,
protect and enhance open space and opportunities for sport and
recreation. As set out in the assessment above, the development proposal
will not impact upon or result in the loss of open space that has been laid
out with the purpose of providing amenity, an area of public access or an
area for countryside recreation.
7.47 Any perceived impact upon property values is not a material planning
consideration. Finally, the applicant non-attendance at the local residents
meeting has been brought into question. As this is not a procedural
requirement for the application, it is not a material planning consideration.
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8. CONCLUSION
8.1 The proposed wind turbine complies with both the adopted and proposed
local plans as well as NPF4. The sloping landscape and urban character
in the vicinity of the site mitigates against the visual impact of the turbine
on the Kilpatrick Hills or the Loch Lomond and the Trossachs National
Park and there would be no adverse cumulative impacts. The distance
from the nearest residential property and intervening tree coverage is
sufficient to ensure that there would be no unacceptable impact on
residential properties. A legal agreement would ensure that a suitable
financial bond is put in place to cover future restoration liabilities for the
site and community benefit would also require to be addressed in a similar
way. Previously planning permission was granted for the erection of a
wind turbine of the same size, as well as the associated access track on
this site in 2015, although the decision notice was never issued and the
application subsequently withdrawn.
8.2 Planning application DC22/190/FUL was refused due to the concern
regarding the proposed agricultural shed. By removing the proposed
agricultural shed, this current proposal addresses the concerns raised in
2023 refusal. 
8.3 Overall, the proposed development would allow the erection of a wind
turbine which would be appropriately sited, have no unacceptable impacts
and would contribute to renewable energy targets. 
9. CONDITIONS
1. The planning permission for the wind turbine hereby granted shall be for a
maximum period of 25 years and 6 months from the date of the
permission. This period consists of a 25 year period of operation of the
turbine followed by a 6 month period for removal of the turbine, ancillary
equipment, associated hard standing and access track and restoration of
the site to its former condition, or other such condition as agreed in writing
as acceptable to the Planning Authority in accordance with the terms of
Condition 6 below.
2. Unless otherwise agreed in writing by the Planning Authority, should the
turbine cease to generate electricity for a continuous period of 6 months,
the turbine, ancillary equipment, associated hard standing and access track
shall be removed. Restoration of the site to its former condition, or other
such condition as agreed in writing as acceptable to the Planning Authority
in accordance with the terms of Condition 6 below, shall thereafter take
place within 6 months.
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3. All external colours of the turbine and associated equipment cabinet shall
be agreed with the Planning Authority prior to the commencement of works
and shall be implemented as approved.
4. No turbine, transformer building or any other above ground infrastructure
shall be illuminated or display any name, logo, sign or advertisement (other
than health and safety signage) unless and until otherwise approved in
writing by the Planning Authority.
5. Within one year of the date of this consent, the turbine operator shall
submit an Outline Decommissioning, Restoration and Aftercare Scheme
(the Outline Decommissioning Scheme) for the Turbine development, for
the written approval of Planning Authority. The Outline Decommissioning
Scheme shall include (but not necessarily be limited to) details of:
a) Works for the decommissioning and removal of the turbine (together
with the foundations to a depth of at least one meter) and all above
ground ancillary infrastructure and equipment;
b) The treatment of any ground surfaces including access tracks, hard-
standing areas and any sub-surface elements including cabling to
restore the site to its former condition, or other such condition as is
agreed in writing by the Planning Authority;
c) Environmental management provisions, including waste management;
d) A decommissioning timetable;
e) Appropriate aftercare following site restoration; and
f) How and when the Outline Decommissioning Scheme will be reviewed
during the operational life of the development.
The approved Outline Decommissioning Scheme shall be implemented as
approved, unless otherwise agreed in writing by the Planning Authority. 
6. No later than 12 months prior to the decommissioning of the development,
or the expiration of the 25 year period of operation (whichever is earlier), a
detailed Decommissioning, Restoration and Aftercare Scheme, which
takes account of the latest version of the Outline Decommissioning
Scheme (approved under Condition 5) and which also takes into account
of the current best environmental practice, shall be submitted to and
approved in writing by the Planning Authority.
The development shall be decommission, the site restored and aftercare
thereafter in accordance with the scheme approved as part of this
condition, unless otherwise agreed in writing in advance by the Planning
Authority. 
7. Unless otherwise agreed in writing by the Planning Authority, if the wind
turbine fails to generate electricity for a continuous period of 12 months,
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the turbine shall be deemed to have ceased to be required, and a scheme
that takes cognizance of Condition 6, setting out how the wind turbine and
associated infrastructure will be removed from the site, the ground
restored and aftercare carried out, shall be submitted for the written
approval of the Planning Authority no later than one month after the date
of the expiry of the 6 months. 
The scheme approved shall be implemented within 12 months of the date
of its approval. 
8. In order to ensure compliance with Condition 7, the wind turbine operator
shall submit 12 monthly generation and output figures to the Planning
Authority to evidence that the turbine is continuing to generate electricity
and the 12 monthly reporting cycle shall commence from the date the
turbine is commissioned (turned on).
9. Notwithstanding the approved plans, all recommendations within the
Preliminary Ecological Appraisal dated December 2022 shall be followed
to the satisfaction of the Planning Authority.
10. That prior to works commencing on site a traffic management plan
indicating the proposals for the construction and delivery of the turbine and
all associated construction material shall be submitted to the Planning
Authority for their written approval, and shall thereafter be implemented as
approved. The statement shall include the following information:
a) The intended turbine transportation route including swept path
analysis, timings and methodology.
b) All temporary works including relocation of signs, guardrails,
bollards, street furniture and all temporary measures.
c) Any alteration to the public road network.
d) Details of the construction compound including staff car parking.
e) Details of proposed signage during the delivery and construction
period.
f) Any necessary mitigation.
g) Details of the type, weight, frequency and number of delivery and
construction vehicles inclusive of those delivering all associated
construction materials, for example, hardcore and associated
tonnage.
h) Details of wheel washing facilities.
i) A condition report based on a joint survey of the proposed route to
ensure that all temporary alterations and any damage to the road
network are made good.
11. No development shall take place within the development site until the
developer has secured the implementation of an archaeological watching
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brief, to be carried out by an archaeological organisation acceptable to the
Planning Authority, during all ground disturbance. The retained
archaeological organisation shall be afforded access at all reasonable
times and allowed to record, recover and report items or interest and finds.
A method statement for the watching brief shall be submitted by the
applicant and agreed in writing with the Planning Authority in consultation
with the West of Scotland Archology Service prior to the commencement
of the watching brief. 
The name of the archaeological organisation retained by the developer
shall be given the Planning Authority in writing prior to any works on site.
12. Prior to the commencement of development full details of the surface
water drainage system shall be submitted for the written approval of the
Planning Authority and shall be implemented as approved prior to the
occupation of the building. The drainage system shall incorporate the
principles of Sustainable Drainage Systems within its design, and shall
thereafter be implemented as approved.
13. In accordance with ETSU- R- 97 (Simplified Method) the noise from the
wind turbine shall not exceed an LA90(10min) of 35dB at the boundary of
the curtilage of any noise sensitive premises at all times at wind speeds of
up to 10 metres per second at 10m height as measured within the site.
14. Prior to the installation of the turbine, the developer shall submit a report
for approval by the Planning Authority which demonstrates compliance
with the noise limits in Condition 13 above. The report shall be prepared in
accordance with reference to the Institute of Acoustics Good Practice
Guide to the Application of ETSU-R-97 and associated supplementary
guidance notes.
15. Prior to the installation of the turbine, the applicant shall provide written
confirmation to the Planning Authority that the noise from turbine operation
will be broad-band with no discernible tonal characteristics.
16. Within 14 days from the receipt of a written request from the Planning
Authority or following a complaint to the Planning Authority from the
occupant of a dwelling regarding noise from the wind turbine operation,
the wind turbine operator shall, at the wind turbine operator’s expense,
employ an independent consultant approved by the Planning Authority to
assess the level of noise emissions from the wind turbine at the
complainant’s property following procedures to be agreed with the
Planning Authority. The wind turbine operator shall provide to the Planning
Authority the independent consultant’s assessment and conclusions
regarding the said noise complaint, including all calculations, audio
recordings and the raw data upon which those assessments and
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conclusions are based. Such information shall be provided within 28 days
of the date of the written request of the Planning Authority unless
otherwise extended in writing by the Planning Authority. The wind turbine
operator shall take such remedial action as required by the Planning
Authority. 
17. Wind speed, wind direction and power generation data shall be
continuously logged and provided to the Planning Authority in a format to
be agreed at its request and within 28 days of such a request. Such data
shall be retained by the operator for a period of not less than 12 months.
18. No development shall commence  on site until details of a nominated
person have been submitted in writing to the Planning Authority for the
development who will act as a point of contact for local residents (in
connection with conditions 13 - 17), together with the arrangements for
notifying and approving any subsequent change in the nominated
representative. The nominated representative shall have responsibility for
liaison with the Planning Authority in connection with any noise complaints
made during the construction, operation and decommissioning of the wind
turbines.
19. During the period of construction, all works and ancillary operations
(including piling) 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 
Saturday: 0800-1300 
Sundays and public holidays: No working
20. During the period of construction no delivery or removal of material from
the site shall take place outwith the hours of 8am to 6pm Mondays to
Fridays and 8am to 1pm on Saturdays, and not at all on Sundays or Public
Holidays unless otherwise approved in writing by the Planning Authority.
21. The applicant shall ensure that all works carried out on site are carried out
in accordance with the current BS5228, 'Noise control on construction and
open sites'. No further development shall commence on site until such
time as a noise control method statement for the construction period has
been submitted to and approved in writing by the Planning Authority. This
statement shall identify likely sources of noise (including specific noisy
operations and items of plant/machinery), the anticipated duration of any
particularly noisy phases of the construction works, and details of the
proposed means of limiting the impact of these noise sources upon nearby
residential properties and other noise-sensitive properties. The
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construction works shall thereafter be carried out in accordance with the
approved method statement unless otherwise approved in writing by the
Planning Authority.
22. Before any further plant and machinery is used on the premises it shall be
enclosed with sound insulating material in accordance with a scheme
which shall first be approved in writing by the Planning Authority. The
sound insulation measures shall thereafter be retained.
23. Within 14 days from the receipt of a written request from the Planning
Authority or following a complaint to the Planning Authority following a
complaint alleging shadow flicker nuisance, the wind turbine operator shall
at the wind turbine operator’s expense:
a) Employ an independent consultant approved by the Planning Authority
to assess the conditions likely to be causing the incidences of shadow
flicker to which the complaint relates.
b) Within 28 days of receipt of the written request from the Planning
Authority, the wind turbine operator shall submit to the Planning
Authority, the independent consultant’s report on shadow flicker,
detailing any amendments to the operation of the wind turbine
necessary to mitigate any further incidences of shadow flicker, for the
written approval of the Planning Authority. The turbine shall thereafter
operate in accordance with the amendments to operation as approved.
24. Notwithstanding the approved plans, and prior to any works on site, a
further submission which demonstrates an understanding on how the
proposal enhances biodiversity beyond the current baseline shall be
submitted to and approved in writing by the Planning Authority. All
measures shall then be implemented as approved.
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Pamela Clifford 
Planning, Building Standards and Environmental Health Manager
Date: 14th February 2024 
Person to Contact: Pamela Clifford, Planning & Building Standards
Manager
Email: Pamela.Clifford@west-dunbarton.gov.uk
James McColl, Development Management Team
Leader
Email: James.McColl@west-dunbarton.gov.uk
Appendix: Location Plan
Background Papers: 1. Application forms and plans
2. Consultation responses
3. Representations
4. National Planning Framework 4
5. West Dunbartonshire Local Plan 2010
6. Proposed West Dunbartonshire Local
Development Plan 2 2020, as amended
7. Kilpatrick Hills Local Landscape Area Statement
of Importance
8. Renewable Energy Local Development Plan
(Proposed Plan) Planning Guidance November
2016
Wards affected: Ward 3 (Dumbarton)
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¯
Reproduced by permission of Ordnance Survey on behalf of HMSO. (C) Crown copyright and database right 01/02/2024.
All rights reserved. West Dunbartonshire OS Licence Number 100020790.
Scale: 1:2,500@A401/02/2024
DC23/177/FUL - MapWest Dunbartonshire
Council
16 Church Street
Dumbarton
G82 1QL
ITEM 6b - APPENDIX 1
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager
Planning Committee: 14th February 2024
DC23/202/FUL:       Application under Section 42 of the Town and
Country Planning (Scotland) Act 1997 (as amended)
in relation to Condition 17 (approach to risk
assessment and any associated required remediation
strategy/plan) attached to Planning Permission in
Principle reference DC20/088 at land at the former
Dunglass Oil Terminal, Dumbarton Road, Bowling by
West Dunbartonshire Council. 
1. REASON FOR REPORT
1.1 This application seeks to vary a condition previously agreed by the Planning
Committee as part of the approval of an earlier planning permission in
principle (ref: DC20/088). 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 extends to approximately 56 hectares and is located on the
northern bank of the River Clyde. It is bounded by the River Clyde, the Glasgow
to Dumbarton and Helensburgh railway line and the A82 Trunk Road. The
national cycle route - NCN7 runs along the northern boundary of the site and
cuts across the western part of the site. The cyclepath provides a local route to
Bowling and Dumbarton as well as onto Glasgow and Balloch beyond. 
3.2  Two Category B listed buildings comprising Dunglass Castle and Obelisk
Memorial to Henry Bell are also found within the site. The Inner Clyde Special
Protection Area (SPA), Ramsar Site (Wetlands of international important) and
the Milton Burn Sites of Special Scientific Interest (SSSI) overlap and border
the site to the south, along the River Clyde foreshore.  
3.3 The majority of the site comprises land of the former Dunglass Oil Terminal
which was previously occupied by and currently remains under the ownership
of Exxon Mobil and Esso Petroleum Company Limited. This was historically
used as a fuel distribution terminal from the 1920s until the 1990’s. While the
majority of the site comprises the former oil terminal, there are other sections
of land within the application site under separate ownership. 
ITEM 6c
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The application site also extends beyond the former oil terminal to include
surrounding, existing road infrastructure. The former terminal has been vacant
and unused since decommission and clearance was completed in 2001. Other
land subject to the application includes fields and strips of land under private
ownership and the Council is progressing the purchase of the whole application
site. An extensive programme of remediation of parts of the former oil terminal
site was granted planning permission in 2019 (ref: DC18/013). This comprises
of works for areas known as Centerfield, Garden, Northfield and Westfield. A
further planning permission was granted in December 2020 (ref: DC20/182) for
an alternative revetment solution along the Centrefield frontage. The Eastfield
area of the site has previously been remediated in 2014 under planning
permission DC11/218. Esso and EXXON Mobil are currently undertaking the
remediation works granted under the DC18/013 permission. It is currently
expected that this work will be concluded by March 2024 although there is a
subsequent monitoring period thereafter. 
3.4 In December 2020, planning permission in principle was approved (ref:
DC20/088) for the re-development of the site comprising a mixed use
development through a masterplan approach consisting of: 
• Up to 44,450m2 of commercial and industrial development comprising a
mix of storage, distribution, industrial, business and office space; 
• a new spine road with associated drainage and lighting infrastructure;
• Upgrades to the public road network;
• A new junction on the A82 at Dumbuck with closure of the existing
junction; 
• A remodelled junction on A82 at Dunglass;
• An enhanced routing of a section of the National Cycle Network Route
7; 
• A new underbridge of the Glasgow-Dumbarton Railway at the western
access to the site; 
• A new railway overbridge at the eastern access to the site; 
• Flood mitigation works; 
• Site drainage works;
• Landscaping, green corridors and green open space;
• Environmental mitigation works;
• Establishment of platforms for development across the site. 
3.5  In January 2024, a Matters Specified in Conditions application (ref:
DC23/113/MSC) for conditions 1(a & d), 12, 23, 24 and 30 of the above
Planning Permission in Principle Permission (ref: DC20/088) was approved by
Planning Committee. This addresses the details relating to the road
infrastructure, development platforms and associated works and details.   
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3.6 The redevelopment of the site forms part of the Council’s City Deal project. The
development will provide a platform for major industrial and commercial
development whilst, at the same time, providing road and infrastructure
improvements to relieve pressure and provide an alternative route to the A82
through Milton. The development of the site will be progressed through 4
phases as follows: 
• Phase 1 – road infrastructure work covering the eastern junction works at
Dunglass, western junction works at Dumbuck, the eastern railway
overbridge, western railway underbridge and the new spine road through
the site.
• Phase 2 - creation of three development platforms (East, Central and
West).
• Phase 3 – landscaping, utilities and energy infrastructure facilities. 
• Phase 4 - on-site buildings, Dunglass Castle and Henry Bell Obelisk
works. 
3.7 Condition 17 of the Planning Permission in Principle (ref: DC20/088/FUL) states
that: 
“No development (other than investigative works) shall commence on site until
such time as an assessment of the risks to all new receptors, such as people
and buildings, that this development will introduce has been undertaken. If the
risk assessment identifies any unacceptable risks, a remediation strategy/plan
will be submitted to and approved in writing by the Council as Planning Authority
prior to development works commencing. The report shall be prepared by a
suitably qualified person”.   
3.8 The applicant seeks to vary Condition 17 to allow Phases 1 and 2 of the
development to commence without first having to submit and receive approval
of an assessment of the risk to all new receptors across the whole site. The
proposed variation to Condition 17 seeks to instead require the submission of
a document outlining the approach to undertaking a new receptor risk
assessment prior to the commencement of development on site. The risk
assessment would then to be undertaken in accordance with the approved
approach. The proposed variation to Condition 17 as suggested by the
applicant reads as follows: 
“No development (other than investigative works) shall commence on site until
an approach to undertaking a new receptor (e.g. people and buildings) risk
assessment has been submitted to and approved in writing by the Planning
Authority. The approach must be prepared by a suitably qualified
professional(s). Any new receptors risk assessment shall then be undertaken
in accordance with the approved approach unless otherwise agreed in writing
by the Planning Authority. For the avoidance of doubt, should any risk
assessment identify unacceptable risks, a remediation strategy shall be
submitted to and approved in writing by the Planning Authority prior to the
commencement of development on the affected part of the site”. 
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4. CONSULTATIONS 
4.1 West Dunbartonshire Council Environmental Health’s Contaminated Land
Officer have no objections but request some changes to the wording of the
proposed variation to Condition 17.     
5. REPRESENTATIONS 
5.1 No representations received. 
6. ASSESSMENT AGAINST THE DEVELOPMENT PLAN 
6.1 As the principle of development has already been established through the
earlier planning permission in principle (ref: DC20/088), the policies referenced
below only relate to those works which are within the scope of works and
development associated with Condition 17. 
National Planning Policy 4 (NPF4)
6.2 National Planning Framework 4 (NPF4) did not form part of the adopted
development plan at the time the application for Planning permission in principle
was determined. Whilst the granting of planning permission in principle is not
revisited in the context of NPF4, it is now part of the adopted development plan
against which the current, and any future applications for the site, are required
to be assessed against. 
6.3  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. 
6.4  Policy 4 sets out requirements to be met when development affects Special
Protection Areas/Sites of Special Scientific Interest (in this case the Inner Clyde
SPA). Policy 7 addresses the historic environment and requires development
proposals to fully assess the impact on historic assets or places, including listed
buildings. This is relevant to Dunglass Castle and Henry Bell Obelisk which are
listed buildings within the site.  
6.5 Policy 9 aims to encourage, promote and facilitate the reuse of brownfield,
vacant and derelict land and empty buildings. Criterion (c) requires that where
land is known or suspected to be unstable or contaminated, development
proposals will demonstrate that the land is, or can be made, safe and suitable
for the proposed new use. 
6.6 Policy 14 seeks to encourage, promote and facilitate well designed
development that makes successful places by taking a design-led approach
and applying the Place Principle. Criterion (b) advises that development
proposals will be supported where they are consistent with the six qualities of
successful places, which includes ‘Healthy. 
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6.7 Policy 23 seeks to protect people and places from environmental harm, mitigate
risks arising from safety hazards and encourage and promote and facilitate
development that improves health and wellbeing. Criterion (b) states that
development proposals which are likely to have a significant adverse effect on
health will not be supported. A Health Impact Assessment may be required. 
6.8 It is considered that the application proposal being assessed complies with the
relevant policies of NPF4 and is assessed fully in Section 7 below. 
West Dunbartonshire Adopted Local Plan 2010 
6.9 Policy GD 1 advises that new development is expected to be of a high quality
of design and to respect the character and amenity of the area in which it is
located. Development proposals are required to assess and address
environmental pollution and ensure that suitable remediation measures are
undertaken on contaminated sites. 
6.10 Policy BE2 relates to protection of Listed Buildings and seeks to ensure that
there are no adverse impact on their character, appearance and setting. Policy
BE4(5) specifically encourages the rejuvenation and restoration of Dunglass
Castle and improvements to the setting of the castle will aid in this regard. 
6.11 Policies E1, E2A and E2B relate to the Council’s biodiversity duty and nature
conservation matters. 
6.12 It is considered that the application proposal being assessed complies with the
relevant 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, although it does not directly
affect the development proposal under consideration. 
7.2  Policy CP1 seeks to ensure that new development takes a design led approach
to creating sustainable places which put the needs of people first and
demonstrates that they 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). 
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7.3 Policy ENV1 relates to nature conservation. Similar to the other plans, this
policy stipulates that development with potential to have an impact upon on
ecological designations like a SPA or SSSI will only be allowed if there would
be no adverse impacts on the nature conservation interest, or where there are
imperative reasons of overriding public interest. 
7.4 Policies ENV5, which relates to the water environment, advises that the quality
and enjoyment of the water environment will be protected and improved
minimising pollution of all waterbodies and ground water resources. 
7.5 Policy ENV9 requires developers to establish the nature of any contamination
on any potential development site. Where contamination is present and risks to
key receptors are identified, then remediation will be required to ensure the site
can be made suitable for its future use. 
7.6 It is considered that the application proposal being assessed complies with the
relevant policies above as set out in the following assessment below. 
Principle of Development and Section 42 applications
7.7 The principle of development on this site has already been established through
the granting of planning permission in principle (ref: DC20/088) and is not being
revisited as part of this application. Detailed permission (AMSC) was also
recently granted for the road infrastructure, development platforms and
associated works. 
7.8 The advice from the Scottish Government (contained in Annex H of Circular
3/2022 – Development Management Procedures) is that in determining Section
42 applications, planning authorities may only consider the issue of the
conditions to be attached to any resulting permission. As such, this application
considers only the proposed variation to Condition 17 of the planning
permission in principle in terms of the approach to risk assessment and any
associated required remediation strategy/plan. 
Ground Contamination/Remediation - Condition 17
7.9 Contaminants from the former oil storage facility are being addressed via the
remediation undertaken by Esso and EXXON Mobil prior to the site being taken
over by the Council. The Eastfield area of the site, which extends to
approximately 5 hectares, was remediated in 2014 by permission DC11/218. In
assessing the application for planning permission in principle (ref: DC20/088),
both SEPA and the Council’s Environmental Health Service were content that
the remediation strategy would successfully mitigate the contamination on site
from the oil terminal use and enable its re-development. 
7.10 As part of the planning permission in principle (ref: DC20/088), Condition 17
was attached to ensure that an assessment of the risks to all new receptors,
such as people and buildings, was carried out and a remediation strategy
submitted. 
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7.11 While it is noted that no new receptors are applicable to Phases 1 and 2, the
condition does not allow for these Phases to progress until an assessment of
the risks to all new receptors, which only apply to Phases 3 and 4, has been
undertaken. Some initial assessment works may, however, be required prior to
the creation of the development platforms. 
7.12 Further to the approval of Matters Specified in Conditions (ref: DC23/113/MSC),
which relates to Phases 1 and 2 of the development, the applicant is keen to
commence development works on site. This application aims to enable works
to progress by varying Condition 17 so that the submission and approval of an
assessment of the risks to all new receptors is not required prior the
commencement of development on site. The proposed variation, set out below,
requires the submission of a document outlining the approach to undertaking a
new receptor risk assessment prior to the commencement of development. This
approach will be expected to address the requirements for any initial
assessment works prior to the commencement of the development platforms
together with the risk assessment is to be undertaken in relation to Phases 3
and 4 where new receptors will occur. The risk assessment is then to be
undertaken in accordance with the approved approach. The Council’s
Contaminated Land Officer has no concerns regarding the amendment to the
condition to allow the alternative approach as the same requirements and
commitments in terms of assessing risks and identifying any remediation
requirements will still apply and ensure any requirements are fully addressed.
The revised approach allows for greater flexibility in allowing the site to progress
in a way which satisfies all parties.  The Council’s Contaminated Land Officer,
however, sets out an alternative wording for an amended condition that they
consider is required to ensure that the matter is satisfactorily addressed. It is
considered that this wording, whilst very similar to the applicant’s suggested
approach, ensures the condition is enforceable whilst allowing flexibility for all
parties. This wording of the proposed variation to Condition 17 is: 
“Unless otherwise agreed in writing by the Planning Authority, no development
shall commence on site until the approach to undertaking an assessment of the
risks to all new receptors, such as people and buildings, that this development
will introduce has been submitted to and agreed in writing by the Planning
Authority. The assessment of the risks to all new receptors shall then be
undertaken in accordance with the approved approach unless otherwise
agreed in writing by the Planning Authority. If the risk assessment identifies any
unacceptable risks on any part of the site then a remediation strategy will be
submitted to and approved in writing by the Council as Planning Authority prior
to development works commencing on that part of the site. The report shall be
prepared by a suitably qualitied person”.  
7.13 The proposed variation to Condition 17 raises no concerns with respect to
human health, climate change, the natural environment or listed buildings within
the site. While the variation would allow Phases 1 and 2 to progress without a
site wide assessment of the risks to all new receptors, this would have a neutral
effect in practice as no new receptors are identified for these phases. 
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The variation, by requiring that the approach to undertaking a new receptor (e.g.
people and buildings) risk assessment be submitted to and approved in writing
by the Planning Authority prior to the commencement of works, would still
ensure that an assessment of the risk to all new receptors at Phases 3 and 4 is
undertaken. Furthermore, the variation would ensure that should any risk
assessment identify unacceptable risks, a remediation strategy shall be
submitted to and approved in writing by the Planning Authority prior to the
commencement of development on the affected part of the site. 
7.14 In light of the above, it is considered that the proposed variation to Condition
17, subject to some minor wording changes beyond the applicant’s suggestion,
is acceptable as it would enable Phases 1 and 2 of the development to progress
while ensuring that an assessment of risks to all new receptors is undertaken
and appropriate remediation carried out, where required. The applicant is aware
of the wording changes suggested by Environmental Health and raises no
concerns. 
8. CONCLUSION 
8.1 The acceptability of the re-development of the site is already established, with
the granting of planning permission in principle (ref: DC20/088). This Section
42 application considers the proposed variation to Condition 17 of the planning
permission in principle. The proposed variation, subject to some minor wording
changes, is acceptable as it would enable Phases 1 and 2 of the development
to progress while ensuring that an assessment of risks to all new receptors is
undertaken and remediation carried out, where required. The Council’s Land
Contamination Officer has raised no concerns to this approach. 
8.2 As the effect of granting planning permission for a Section 42 application is
such that a new and separate standalone permission exists for the
development, all other conditions associated with the planning permission in
principle (DC20/088) are re-imposed to this permission, including Condition 17,
as varied.   
9. CONDITIONS 
1. Prior to the commencement of works associated with any part of the development
(apart from remediation works), an application(s) for approval of detailed design
matters shall be submitted for the written approval of the Planning Authority.
Unless otherwise agreed in writing by the Planning Authority, all applications for
the approval of matters specified in conditions shall be accompanied by:  
a) Development platforms and site layout plans showing the position of all
buildings, roads, access arrangements, parking areas, footpaths, waterfront
walkway, green corridors, open space, boundary treatments and drainage
infrastructure. 
b) Block and layout plans showing existing, proposed and finished floor levels
and elevations of each building, showing dimensions, and palettes of external
materials.  
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c) Applications that include proposals for buildings, will provide details of cycle
parking, shelter and storage provision, electric car charging points, shower,
changing and drying facilities and any other facilities and measures which
promote and support active and sustainable travel. 
d) Landscape and streetscape plans showing the locations and species of all
proposed trees, shrubs, hedges, palettes of hard landscaping materials and
street furniture. Where applicable, all trees and planting shall be sited at least
10 metres in distance from the railway boundary located within the application
site. Where it is agreed for trees, shrubs are to be planted adjacent to the
railway boundary located within the application site, these shall be positioned
at a minimum distance from the boundary which is greater than their predicted
mature height.   
2. Any applications(s) for approval of matters specified in conditions for any phase
or part of the development submitted under Condition 1 shall also accord with
the elements of approved 'design and construction' and 'operational phase'
management plans and strategies associated with Conditions 3, 4, 6, 7, 8, 10,
11, 13, 14, 15, 16 that are relevant to the development being proposed. 
3. Prior to the submission of the first application for the approval of matters specified
in conditions, a Phasing Plan including details for the subsequent delivery for
each phase of the development alongside timescales for implementation of the
various phases shall be submitted to and approved in writing by the Planning
Authority.  The Phasing Plan shall contain a strategy for the submission of a
series of future detailed applications as under Condition 1 above including the
delivery and implementation of the approved zones (including the waterfront
walkway, green spaces and green network corridors). The approved Phasing
Plan including any measures therewithin shall be implemented on site and unless
otherwise agreed in writing by the Planning Authority. Any modifications or
updates of the approved phasing plan shall be subject to the written approval of
the Planning Authority and implemented thereafter as approved. 
4. Prior to the submission of any application for matters specified in Condition 1
(parts B, C or D), a design strategy to establish the principles for the design and
locations of street furniture, railings, bollards, signage, bins, substations,
generators and cycle parking shall be submitted to and approved in writing by
the Planning Authority. Unless otherwise agreed in writing by the Planning
Authority, each application for approval of matters specified in conditions
submitted shall adhere to the principles and requirements approved through the
design strategy. 
5. Unless otherwise agreed in writing by the Planning Authority, prior to the
submission of any application for matters specified in Condition 1 (A, B, C or D),
a Preliminary Options Appraisal Report including a condition survey and scheme
of repairs for the conservation, repair and reuse of Dunglass Castle (including
the house, garden, walls) and the Henry Bell Obelisk in both in the short term
and long term shall be submitted to and approved in writing by the Planning
Authority. Prior to the occupation of any  buildings to be located within Zones A
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and B as identified on Parameters Plan (Drawing No. 30953/4504/002 Rev F),
details of the final chosen option for Dunglass Castle (including the house,
garden and castle walls) and the Henry Bell Obelisk shall be submitted to and
agreed in writing Planning Authority. These details shall include a programme of
works including timescales for obtaining relevant permissions alongside
timelines for the delivery and completion of the works for the Dunglass Castle
(including the house, garden, walls) and the Henry Bell Obelisk. Thereafter this
shall be implemented as approved in accordance with the approved final
strategy. 
6. Prior to the submission of the first application for the approval of matters specified
in conditions, a Soil Management Plan and Earthworks and Materials Movement
Strategy shall be submitted to and approved in writing by the Planning Authority.
Beyond the details set out in in Chapter 15 (Schedule of Mitigation and
Monitoring) of the approved 'Environmental Statement Volume 1 Main Text
(Dated: September 2019), these submissions shall include:   
• Details of the assessment criteria and sampling frequency that would
adequately demonstrate suitability for use. 
• A Waste Management and Recycling Strategy to address on-site waste
and materials.     
The approved plans and strategies shall be implemented on site and unless
otherwise agreed in writing by the Planning Authority. These shall remain in place
for the duration of the construction phase of the full re-development of the site.
Any modifications or updates required shall first be subject to the written approval
of the Planning Authority and implemented thereafter as approved. 
7. Prior to the submission of the first application for the approval of matters specified
in conditions, a Construction Traffic Management Plan (CTMP) shall be
submitted to and approved in writing by the Planning Authority. Beyond the
details and scope set out in in Chapter 15 (Schedule of Mitigation and Monitoring)
of the approved 'Environmental Statement Volume 1 Main Text (Dated:
September 2019), the CTMP shall include details of measures for minimising the
disruption of the construction works on existing local bus services along the A82
and A814. As part of such details it shall also demonstrate continuity of access
along the A82 and A814 at all times, to allow for the continued operation of local
bus services, except where otherwise agreed by the Planning Authority. The
approved CTMP including any measures therewithin shall be implemented on
site and unless otherwise agreed in writing by the Planning Authority and shall
remain in place for the duration of the construction phase of the full re-
development of the site. Any modifications or updates required for the approved
CTMP shall first be subject to the written approval of the Planning Authority and
implemented thereafter as approved.   
8. Prior to the submission of the first application for the approval of matters specified
in conditions, a Flood Risk Management Plan, a Construction Flood Response
Plan and a Construction Drainage Plan shall be submitted to and approved in
writing by the Planning Authority. Beyond the details and scope set out in in
Chapter 15 (Schedule of Mitigation and Monitoring) of the approved
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'Environmental Statement Volume 1 Main Text (Dated: September 2019), the
Construction Drainage Plan shall include confirmation that all foul drainage
installed within the application site shall discharge into the public sewer network
at all times. The approved plans including any measures therewithin shall be
implemented on site and shall remain in place for the duration of the construction
phase of the full re-development of the site, unless otherwise agreed in writing
by the Planning Authority.  Any modifications or updates required for these
approved plans shall first be subject to the written approval of the Planning
Authority and implemented thereafter as approved. 
9. Prior to the occupation of any part of the site, all measures agreed in accordance
with Condition 8 above which are associated with addressing flood risk shall be
implemented.  This shall also include those measures set out in Section 5.3.5 of
the approved 'Environmental Statement Non-technical Summary (September
2019)' and Chapter 7 and figure 7.2 'Conceptual Flood Mitigation Strategy' of the
approved 'Environmental Statement Volume 1 Main Text (Dated: September
2019)' .Once implemented, all of these measures shall be maintained thereafter
unless otherwise agreed in writing by the Planning Authority. 
10. Prior to the submission of the first application for the approval of matters specified
in conditions, a Lighting Strategy and an Otter Mitigation Strategy shall be
submitted to and approved in writing by the Planning Authority. Beyond the
details and scope set out in in Chapter 15 (Schedule of Mitigation and Monitoring)
of the approved 'Environmental Statement Volume 1 Main Text (Dated:
September 2019), the Lighting Strategy shall provide specific confirmation that
night lighting will be avoided during the months of September to  March inclusive
where such lighting would illuminate areas of inter-tidal habitat of the Inner Clyde
Special Protection Area (SPA) to levels in excess of 1 Lux (i.e. the maximum
natural night-time background light level). The approved strategies, including any
measures therewithin shall be implemented on site and shall remain in place for
the duration of the construction phase of the full re-development of the site, and
unless otherwise agreed in writing by the Planning Authority.  Any modifications
or updates required for these approved strategies shall first be subject to the
written approval of the Planning Authority and implemented thereafter as
approved. 
11. Prior to the submission of the first application for the approval of matters specified
in conditions, a Landscape Framework and Strategy shall be submitted to and
approved in writing by the Planning Authority. Beyond the details and scope set
out in in Chapter 15 (Schedule of Mitigation and Monitoring) of the approved
'Environmental Statement Volume 1 Main Text (Dated: September 2019), the
Landscape Framework and Strategy  shall be prepared in accordance with the
approved 'Landscape Framework Objectives' document (Dated October 2020)
and shall  update the  approved masterplan and parameters plan for the site. The
approved Landscape Framework and Strategy including any measures
therewithin shall be implemented on site and unless otherwise agreed in writing
by the Planning Authority. Any modifications or updates required for this
approved strategy shall first be subject to the written approval of the Planning
Authority and implemented thereafter as approved. 
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12. Unless otherwise agreed in writing by the Planning Authority, as part of any
applications for approval of matters specified in conditions, and with regard to
the requirements of condition 1 above, a supporting report which evidences how
the relevant development proposals complies with and delivers the requirements
and aims of the 'Landscape Framework and Strategy' approved under Condition
11 above. 
13. Prior to the submission of the first application for the approval of matters specified
in conditions, a Construction Environmental Management Plan (CEMP) shall be
submitted to and approved in writing by the Planning Authority. Beyond the
details and scope set out in in Chapter 15 (Schedule of Mitigation and Monitoring)
of the approved 'Environmental Statement Volume 1 Main Text (Dated:
September 2019), the CEMP shall also include a timetable and programme for
all noise and vibration generating works associated with the construction of the
development including the use of plant and machinery and vehicle movements.
The timetable shall set out how the construction works will be programmed to
minimise noise and vibration generation during the months of September to
March inclusive and associated disturbance on wintering redshank and other
qualifying features of the Inner Clyde Special Protection Area. Any noise
generating works and/or operations agreed in consultation with the Planning
Authority as being unavoidable during the period specified shall be accompanied
by a schedule of mitigation detailing the measures that will be put in place to
mitigate those impacts that will be caused by noise generating works and
operations. The approved CEMP including any measures there within shall be
implemented on site and shall remain in place for the duration of the construction
phase of the full re-development of the site, unless otherwise agreed in writing
by the Planning Authority. Any modifications or updates required for the
approved CEMP shall first be subject to the written approval of the Planning
Authority and implemented thereafter as approved. 
14. Prior to the submission of the first application for the approval of matters specified
in conditions, a Written Scheme of Archaeological Investigation and Programme
of Archaeological Works shall be submitted to and approved in writing by the
Planning Authority. Notwithstanding the details and scope set out in in Chapter
15 (Schedule of Mitigation and Monitoring) of the approved 'Environmental
Statement Volume 1 Main Text (Dated: September 2019), this investigation shall
be subject to a full Risk Assessment considering all areas of the site not
previously covered by permission DC18/013 for  the Remediation Strategy for
the site. If required by the Risk Assessment, the scope for the Written Scheme
of Archaeological Investigation shall be extended beyond the boundary of Zone
F of the site and may include other areas. The approved written investigation and
programme of works including any measures there within shall be implemented
on site and shall remain in place for the duration of the construction phase of the
areas subject to the investigation, unless otherwise agreed in writing by the
Planning Authority. Any modifications or updates required for the approved
written investigation and programme of works shall first be subject to the written
approval of the Planning Authority and implemented thereafter as approved. 
15. Prior to the submission of the first application for the approval of matters specified
in conditions, an Energy Strategy shall be submitted to and approved in writing
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by the Planning Authority. Further to the approach and overarching aims set out
in the approved 'Energy Masterplan' (Dated, May 2020) document, the Energy
Strategy shall include details for the delivery and implementation of on-site low
carbon and renewable energy solutions, building specific technologies and
features alongside any other measures aimed at increasing energy efficiency on
the site. The approved strategy including any measures there within shall be
implemented on site and unless otherwise agreed in writing by the Planning
Authority and shall remain in place for the lifetime of the development. Any
modifications or updates required for the approved strategy shall first be subject
to the written approval of the Planning Authority and implemented thereafter as
approved. 
16. Prior to the occupation of any part of the site, a Travel Plan including measures
to minimise the impact of traffic and to promote sustainable and active travel
choices for staff and visitors shall be submitted to and approved in writing by the
Planning Authority. The Travel Plan shall include the details and requirements
as set out in Section 7 of the approved 'Transport Assessment (Dated April
2019). The approved Travel Plan including any measures there within shall be
implemented on site and unless otherwise agreed in writing by the Planning
Authority and shall remain in place for the lifetime of the development. Any
modifications or updates required for the approved Travel Plan shall first be
subject to the written approval of the Planning Authority and implemented
thereafter as approved. 
17. Unless otherwise agreed in writing by the Planning Authority, no development
shall commence on site until the approach to undertaking an assessment of the
risks to all new receptors, such as people and buildings, that this development
will introduce has been submitted to and agreed in writing by the Planning
Authority. The assessment of the risks to all new receptors shall then be
undertaken in accordance with the approved approach unless otherwise agreed
in writing by the Planning Authority. If the risk assessment identifies any
unacceptable risks on any part of the site then a remediation strategy will be
submitted to and approved in writing by the Council as Planning Authority prior
to development works commencing on that part of the site. The report shall be
prepared by a suitably qualitied person. 
18. Unless otherwise agreed in writing by the Planning Authority, prior to the
submission of any approval of matters specified in conditions applications
(AMSC), a full Site Investigation and Risk Assessment for areas of the AMSC
site not previously covered by the Remediation Strategy to be undertaken in
accordance with permission DC18/013 shall require to be submitted to and
approved in writing by the Planning Authority. The approved details shall be
implemented as approved. 
19. In the event that contamination, which has not previously been identified and
assessed, becomes evident at any time during the development of the site, it
shall be reported in writing to the Planning Authority within 1 week. If such
contamination can be dealt with without departing from the principles and
outcome of an already approved remediation strategy then works can continue
on the affected part of the site.  If the contamination would result in a departure
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from the principles and outcome of the approved remediation strategy and if
requested by the Planning Authority, works shall cease and/or an investigation
and risk assessment shall be undertaken and an amended remediation strategy
shall be submitted to the Planning Authority for approval. The amended
remediation strategy, once approved in writing by the Planning Authority, shall
be implemented as approved prior to the recommencement of works in the
affected area. 
20. Prior to the occupation of any part of the site and unless otherwise agreed in
writing by the Planning Authority, the proposed upgrade of Dunglass Roundabout
Junction of the A82 (T) with the A814 to traffic signal control shall be constructed
in accordance with approved plan 'Eastern Access' (Drawing No. 30953-STN-
00-XX-DR-D-0021 Rev P01). 
21. Prior to the occupation of any part of the site and unless otherwise agreed in
writing by the Planning Authority, the proposed upgrade of the Dumbuck
signalised junction of the A82 (T) with the A814 shall be constructed in
accordance with approved plan 'Western Access' (Drawing No. 30953-STN-00-
XX-DR-D-0020 Rev P01). 
22. Development proposals affecting the route of NCN7, shall include arrangements
for the temporary diversion of the NCN7. Such details shall be accompanied by
measures which seek to mitigate the impact of the diversion such as the provision
for wayfinding signage and the use of distinctive materials alongside other
measures of route design required to ensure that the diverted route remains
clear, attractive and intuitive to users. Thereafter the approved temporary
diversion and associated mitigation measures shall be undertaken in a timescale
agreed in writing by the Planning Authority. The mitigation measures shall be
maintained on site for as long as the temporary diversion of the NCN7 remain in
place. 
23. Development proposals that propose to alter the route of NCN7 shall include
details for the final arrangement of post-development reconfiguration of NCN7 at
the western end of the site. These details shall include the final route and
positioning of NCN7. Thereafter, the approved details shall be implemented as
approved in a timescale agreed in writing by the Planning Authority. 
24. Any development proposals that will permanently affect the route and function of
existing bus stops shall be accompanied by a report assessing and reviewing the
impact of the proposed road layout upon existing bus stop locations (including
those stops situated along the A82 and A814). If required, the report shall include
details for any new bus stops required or details for relocation of existing bus
routes. The approved report, including any identified findings and measures shall
be implemented in a timescale agreed in writing by the Planning Authority. 
25. Prior to the commencement of any development on site, a trespass proof fence
of minimum 1.8 metres in height shall be installed along the boundary of the
railway line within the application site. Prior to its installation, details of the
proposed trespass fencing including its location and design shall be submitted
to, and approved in writing by the Planning Authority. The approved trespass
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fence shall thereafter be implemented as approved in a timescale agreed in
writing by the Planning Authority. Unless otherwise agreed in writing by the
Planning Authority, the approved trespass fence shall remain in place for the
duration of when construction works are taking place on the part of the site
impacting the railway. 
26. No development shall take place, between the months of September to March
inclusive, until an independent Ecological Clerk of Works (ECoW) or on-site
Ecologist (with ornithological experience) has been appointed by the
developer/applicant to oversee, monitor and ensure the effectiveness of all
ecological mitigation measures to protect the integrity of the Inner Clyde Special
Protection Area and other ecological designations. The Planning Authority shall
be notified in writing once this person has been appointed. Thereafter, the ECoW
shall remain in place for the duration of the construction works associated with
that part of the development, unless otherwise agreed with the Planning
Authority. 
27. Further to Condition 26, prior to appointing the ECoW, a 'scope of works' and
'terms of reference' for that person shall be submitted to and approved in writing
by, the Planning Authority. This specifically shall detail the role and remit of the
ECoW and the circumstances and timescales during the construction phase
whereby they will require to be present within the application site.  As a minimum,
this shall detail that the ECoW shall:   
• Be kept adequately informed of and ensure compliance with the construction
timetable and  programming (including any variations to such details) to be
agreed under the terms of approved CEMP alongside all other ecological
mitigation measures and proposals which are to be in place for the lifetime of
the construction work associated with the redevelopment of the site.   
• Have the capacity and authority to halt/postpone any construction works
taking place during the sensitive over-wintering months (i.e. from September
to March inclusive) and until such time as they believe the operations
concerned will not result in any redshank, cormorants, goldeneye,
oystercatchers, red-breasted merganser (or any other notified bird species)
being displaced from feeding or roosting within the identified Inner Clyde
Special Protection Area or within the designated Site of Special Scientific
Interest (SSSI). 
28. No development shall commence, between the months of September to March
inclusive until a screening and protective barrier has been installed along the
boundary between the Inner Clyde Special Protection Area (SPA) and the area
proposed for development works within the application site (southern boundary
of the water/foreshore edge boundary of the works area).  Prior to its erection,
details of the proposed screening barrier including its location, extent, design and
level of obscurity shall be submitted to, and approved in writing by the Planning
Authority. The approved screening barrier shall thereafter be implemented as
approved in a timescale agreed in writing by the Planning Authority. Unless
otherwise agreed in writing by the Planning Authority, the approved screening
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barrier shall remain in place for when construction works are taking place within
the part of the site impacting the SPA.
29. Further to Condition 28 above, in the event that any such screening barrier is to
be replaced by more permanent screen planting, details of such proposals shall
be submitted to and approved in writing by the Planning Authority prior to the
removal of the screening barrier (between the months of September to March
inclusive). Such proposals shall include details for planting along the edge of the
development site area (referred to as the 'Green Corridor' on  the approved
Masterplan and Parameters Plan) combined with tree/scrub retention and
appropriate reinforcement planting along the route of the new/upgraded road and
along the edge of the existing railway line. The approved screen planting details
shall thereafter be implemented as approved in a timescale agreed in writing by
the Planning Authority.
30. As part of any applications for approval of matters specified in conditions, and
with regard to the requirements of condition 1 above, up-to-date protected
species surveys insofar as required in relation to the area of proposed
development and associated ecological features shall accompany development
proposals within the site. These surveys shall be carried out by a suitable
qualified ecologist at the appropriate time of year and will be provided to update
the baseline information provided through the Environmental Statement and
ecological surveys provided as part of this application. Furthermore, should the
results of such surveys show them to be necessary, any such applications shall
also be accompanied by the relevant species protection plans to identify any
license requirements.
31. Prior to the commencement on any development on site, details of measures to
protect retained trees and areas of woodland on the site during construction shall
be submitted to and approved in writing by the Planning Authority. The details
shall include specific details for the establishment of buffer zones for the
protection of trees and area of woodland along and within the site boundary.
Thereafter, unless otherwise agreed in writing by the Planning Authority, the
approved measures shall be implemented and shall remain in place for the
duration when construction works are taking place on site.
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Pamela Clifford 
Planning, Building Standards and Environmental Health Manager
Date: 14th February 2024
Person to Contact: Pamela Clifford, Planning, Building Standards and
Environmental Health Manager
Pamela.Clifford@west-dunbarton.gov.uk
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.
7.
8.
Planning applications DC11/218, DC18/013,
DC20/182, DC23/113/MSC
Planning permission in principle DC20/088
Application for matters specified by condition
DC23/113/MSC
Wards affected: Ward 3 (Dumbarton)
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¯
Reproduced by permission of Ordnance Survey on behalf of HMSO. (C) Crown copyright and database right 01/02/2024.
All rights reserved. West Dunbartonshire OS Licence Number 100020790.
Scale: 1:12,000@A401/02/2024
DC23/202/FUL - MapWest Dunbartonshire
Council
16 Church Street
Dumbarton
G82 1QL
ITEM 6c - APPENDIX 1
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WEST DUNBARTONSHIRE COUNCIL 
Report by Planning, Building Standards and Environmental Health
Manager 
Planning Committee: 14th February 2024
_____________________________________________________________
DC23/205/FUL: Application under Section 42 of the Town and Country
Planning (Scotland) Act 1997 to vary Condition 7 of
permission DC19/203 relating to the timing of footpath
delivery for residential development site at Farm Road,
Duntocher, Clydebank by Barratt Homes West Scotland.
1. REASON FOR REPORT
1.1 This application seeks to vary a condition attached to a planning
permission in principle granted on appeal for an application proposal
previously considered by the Planning 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 relates to approximately 8.8 hectares of agricultural land
on the northern edge of Duntocher. The site comprises two fields roughly
similar in size, which are connected to each other by a narrow corridor.
The north-eastern field lies on the west side of Farm Road, bounded by
the back gardens of houses on Mirren Drive to the south and by the
houses in the former Duntiglennan Farm buildings to the north.  At its
south-western corner is a connection into the south-western field, which is
bordered by back gardens in Mirren Drive and Craigielea Road to the east
and south. Both fields border farmland to the north and west. There are
significant level changes across both parts of the site, with the land
generally rising to the north. The land was previously used for agricultural
grazing but is currently unused, and consists mainly of overgrown
grassland. The south western field contains mature trees around its
perimeter, and these are covered by a Tree Preservation Order.
ITEM 6d
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3.2 Planning Permission in Principle application (ref:DC19/203) for the
erection of 99 dwellinghouses, formation of access, landscaping, open
space, SuDS and associated infrastructure was granted on appeal in
September 2020, subject to seven conditions (ref: PPA 160-2030). 
3.3 In March 2022, Matters Specified in Conditions application
(DC22/049/MSC) was submitted for conditions 1, 3, 5 and 7 of the
planning permission in principle. Conditions 1, 3 and 5 related to the
layout, siting and design of the proposed houses, access arrangements,
car parking, levels, landscaping, garden space and provisions for waste,
habitat survey, flooding and drainage. Condition 7 related to the provision
of bus stops on Craigielea Road and associated footpath link. This
application was refused by the Planning Committee in November 2022,
but granted on appeal (PPA-160-2039) in January 2023. 
3.4 The current application relates to Condition 7 of the planning permission in
principle, which states that:
“Unless otherwise agreed in writing by the Planning Authority, none of the
houses within the development shall be occupied until bus stops and
shelters have been provided on Craigielea Road, in locations to be agreed
with the Council, as Roads Authority, and Strathclyde Partnership for
Transport together with a footpath linking these stops with the
development”.
3.5 The current application seeks to vary the terms of Condition 7 under
Section 42 of the Town and Country Planning (Scotland) Act 1997, as
amended.  The proposed variation would delay delivery of the footpath
linking the bus stops to the housing development until occupation of the
64th house. The applicant has justified the variation on the basis that
delivery of the footpath prior to the occupation of the 64th house would
result in health and safety risks to users of the path. The variation sought
only relates to the delivery of the footpath. No variation is sought to amend
the requirement to provide the new bus stops on Craigielea Road prior to
the occupation of the first house. 
4. CONSULTATIONS
4.1 West Dunbartonshire Council Roads Service offer no objections to the
proposed variation of the condition.
5. REPRESENTATIONS
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5.1 Thirteen objections have been received in connection with the proposed
development. The full details are contained within the planning file and are
available for public viewing. However, the points raised can be summarised
as follows:
Residential Amenity
• Adverse noise effects.
• Adverse impacts on privacy.
• Development will result in air pollution from additional car travel from
its greenbelt location.
Access and Parking
• Will result in additional traffic congestion and endanger the safety of
pedestrians, mainly children.
• Could potentially restrict emergency vehicle access to Farm Road
and adjacent streets.
• Insufficient road and pedestrian access has been provided.
• Will cause parking on pavements.
• Concern that additional bus stops will change the bus route along
Craigielea Road with knock on adverse effects on traffic congestion.
Landscape and Visual Impact
• Will change the character and appearance of the local landscape.
Flood Risk and Drainage
• Flood risk.
• No information provided on how the existing drainage on the hill will
be affected and any effects mitigated.
Other Issues
• Adverse effects on water pressure to existing properties.
• Adverse effects on food production from loss of agricultural land.
• Adverse impact on wildlife and eco structure.
• Condition 7 should be implemented as originally written.
• Concern that the applicant does not own all the land required for the
footpath link.
• ‘Off Site Bus Stops Plan’ does not show existing paths.
• Bus stop on north side of Craigielea Road not required.
6. ASSESSMENT AGAINST THE DEVELOPMENT PLAN
6.1 As the principle of development has already been established through the
earlier planning permission in principle (ref: PPA 160-2030), the policies
referenced below only relate to those works within the scope of works and
development associated with Condition 7.
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National Planning Framework 4
6.2 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.
6.3 Policy 13 supports proposals to improve, enhance or provide active travel
infrastructure, public transport infrastructure or multi-modal hubs. 
6.4 Policy 14 requires that proposals be designed to improve the quality of an
area whether in urban or rural locations and regardless of scale. In
addition, proposals are supported where they are consistent with the six
qualities of successful places, including ‘Connected’, which promotes well
connected networks that make moving around easy and reduce car
dependency.  
6.5 Policy 15 relates to local living and 20 minute neighbourhoods.
Development proposals will contribute to local living including, where
relevant, 20 minute neighbourhoods. Consideration will be given to
existing settlement pattern, and the level and quality of interconnectivity of
the proposed development with the surrounding area, including access to
sustainable modes of transport and high quality walking, wheeling and
cycling networks. 
6.6 It is considered that the application proposal being assessed complies
with the relevant policies of NPF4 and is assessed fully in Section 7
below.
West Dunbartonshire Local Plan 2010 
6.7 Policy SUS1 advises that the Council will pursue a sustainable approach
to development and transportation issues by seeking to maintain and
enhance the quality of the environment within the Plan area and
integrating transportation and land-use planning matters. 
6.8 Policy H5 safeguards and where possible seeks to enhances the
character and amenity of existing residential area. Development within
existing residential areas will be considered against the following criteria;
the requirement to avoid over development which would have an adverse
effect on local amenity, access and parking
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6.9 Policy GD1 seeks to ensure that all new development is of a high quality
of design, respects the character and amenity of the area and that
increases in traffic volumes and adverse impacts on air quality are
avoided or minimised by including provision for public transport,
pedestrian and cycling access. 
6.10  Policy T1 states that the Council supports measures to provide
sustainable transport modes including footpaths, cycle routes and
improved access to public transport. The Council will give favourable
consideration to proposals which increase access to public transport
services and path networks, particularly in respect of employment areas,
provided there are no adverse impacts on the amenity of the surrounding
area. 
6.11 Policy T4 states that developers should ensure that sites are well
integrated into walking, cycling and public transport routes, and should
give priority to the positioning of footpaths, cycleways and bus stops at the
main entrances to developments or within residential areas. Significant
new development will be expected to be sited so as to be accessible to
public transport networks and developer contributions will be required
where such development is shown to impact on the public transport
infrastructure, including railways, in Transport Assessments.
6.12 It is considered that the application proposal being assessed complies
with the relevant 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.
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7.2 Policy CP1 seeks to ensure that housing is of a high quality, adaptable
and is 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). Criterion (b) states that all
new development is required to ensure that streets are safe, comfortable
and attractive for all users; creating an accessible, inclusive and walkable
network of streets and paths which consider the role of streets as places
for people first.
7.3 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. Criterion (b) states that
applicants should demonstrate how the design and layout of development
prioritises active travel modes (linking work places, schools, community
facilities and public transport hubs) and recreation routes, as well as
maintains and enhances the quality and connectivity of the active travel
network. 
7.4 Policy CON1 requires that significant travel generating uses are designed
to encourage sustainable transport. All new development will require to
prioritise active travel, by incorporating new, and providing links to,
existing footpaths, cycle routes and public transport routes.  
7.5 It is considered that the application proposal being assessed complies with
the relevant policies above as set out in the following assessment below.
Principle of Development and Section 42 applications
7.6  The principle of development on this site has already been established
through the granting of planning permission in principle (ref: PPA 160-
2030) and is not being revisited as part of this application. The advice from
the Scottish Government (contained in Annex H of Circular 3/2022 –
Development Management Procedures) is that in determining Section 42
applications, planning authorities may only consider the issue of the
conditions to be attached to any resulting permission. As such, this
application considers only the proposed variation to Condition 7 of the
planning permission in principle in terms of the delivery timescale for the
footpath link.
Public Transport Footpath Link – Condition 7
7.7 Condition 7, which seeks to facilitate the use of public transport by
residents of the development, was attached to the planning permission in
principle as detailed in paragraph 3.4 above.  The locations of the bus
stops and shelters have been agreed with the Council and were approved
as part of the Matter Specified in Conditions permission. 
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The applicant has justified the footpath link being provided prior to the
occupation of 64th house on the basis of health and safety considerations
during construction.  
7.8 Phase 1 of the development is located in the northern part of the site and it
is accepted that the provision of a path linking the Phase 1 properties to
the bus stops on Craigielea Road would bring pedestrians into closer
contact with construction vehicles, plant and machinery which require to
use an adjacent route to access the southern part of the development,
which would still be under construction. It is noted that linking new houses
within Phase 1 to the bus stops would require approximately 600m of unlit
footpath to be formed through an active construction site, which could
potentially pose health and safety risks for users of the path. The concerns
raised by the applicant are accepted. In further assessing the proposed
variation to the condition, a key consideration is the extent to which
delaying delivery of the footpath would restrict pedestrian access from the
Phase 1 properties to the agreed bus stops. As there is an existing
asphalt, street lit and overlooked footpath available through the existing
street network, via the main site access at Farm Road southwards along
Craigielea Road and westwards to the agreed bus stops, it is considered
that delaying delivery of the footpath would not significantly restrict
pedestrian access for residents from Phase 1. The Council’s Roads
Service offers no objections to the proposed variation of the condition in
terms of delaying the provision of the footpath link. 
7.9 With respect to when it would be appropriate to deliver the footpath, the
variation seeks to delay delivery until occupation of the 64th house, which
is the first house in Phase 2. While the southern part of the site would still
be under construction at this point, it is considered appropriate that the
footpath should be delivered at the start of Phase 2 as this part of the site
is significantly further from Farm Road than the Phase 1 part of the
development. In light of the above, it is considered that the proposed
variation is acceptable, as it would reduce health and safety risks to
pedestrians while still ensuring that the footpath is delivered in time to
promote pedestrian access between the development, particularly Phase
2, and the agreed bus stops. A condition is proposed that the development
is completed through a continuous programme of construction and this will
ensure that it remains that the delivery of the footpath link forms part of
any development of the site.  
7.10 The delivery of the footpath linking the development with public transport
nodes contributes to the promotion of sustainable transport and the
creation of a successful place. As such, it is supported by NPF4, the
adopted Local Plan and proposed LDP2 policies set out in sections 6 and
7 of this report. 
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While the proposal seeks to vary the timescale for delivery of the footpath,
it does not seek to completely remove the requirement, thereby meeting
the terms of the above policies in terms of accessibility, permeability and
promoting sustainable travel.   
Access and Parking 
7.11 It is noted that the objections raised a number of concerns related to
access and parking. There is concern that the proposal would not provide
sufficient road and pedestrian access and would adversely affect existing
access by increasing traffic congestion, which could potentially endanger
pedestrian safety and restrict emergency vehicle access to Farm Road. In
addition, concerns are raised that the bus stop on the north side of
Craigielea Road is not required and that the additional bus stops proposed
will change the bus route along Craigielea Road. As the current
application seeks only to vary the timescale for delivery of the footpath
link, matters relating to parking, road access, additional bus stops and the
level of pedestrian access are not material to the assessment of the
application. These matters were fully addressed as part of the Planning
Permission in Principle and the Matters Specified in Conditions
permissions. 
Other Matters Raised in Representations
7.12 A range of other issues have been raised in the objections received, which
have not already been assessed above. It is noted that the applicant does
not own all the land required to deliver the footpath link. While the council
is aware that the applicant does not control all the relevant land and
acknowledges that this could potentially affect delivery, it is understood
that discussions are ongoing between the applicant and the land owner.
Should no agreement be reached then the applicant may require to revisit
the matter and any additional amendments to the requirements to provide
the footpath link will require a further application to be submitted for
consideration. The outstanding ownership issues does not impact on the
determination of this application.   
7.13 The other issues raised include adverse impacts on residential amenity
(i.e. noise disturbance, privacy and air pollution), landscape character,
wildlife and eco structure, food production, flood risk, drainage and water
pressure to existing properties. These matters are not considered material
to the assessment of this application, which relates solely to the delivery
timescale of the footpath link. It is also considered that such matters were
fully addressed as part of the Planning Permission in Principle and the
Matters Specified in Conditions approvals 
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8. CONCLUSION
8.1 The acceptability of the principle of residential development on the site is
already established, with the granting of planning permission in principle at
appeal.  The proposed variation is acceptable as it would reduce health
and safety risks to residents pedestrians while still ensuring that the
footpath is delivered to promote pedestrian access between two phases of
the development. .  
8.2 As the effect of granting planning permission for a Section 42 application
is that a new and separate standalone permission exists for the
development, those conditions which were attached to the Planning
Permission in Principle are re-imposed to this permission, including
Condition 7, as varied by this permission if approved together with an
additional condition regarding the continuous implementation of both
phases of the development. 
9. CONDITIONS
1. No development shall commence on site until such time as approval of the
detailed design and layout of the residential development (hereinafter
called “the matters specified in conditions”) has been granted by the
planning authority. Any application for approval of matters specified in
conditions shall be submitted before the expiration of three years from the
date of this planning permission in principle and shall include:
a) the overall site layout;
b) the orientation, size, height, design and external appearance of the
proposed houses;
c) the means of drainage and sewage (including perimeter drainage)
which shall incorporate the principles of Sustainable Drainage Systems
(SuDS);
d) details of the full access arrangements (including a swept path analysis
to demonstrate the suitability of the road layout within the site for
refuse vehicles) ;
e) provisions for car parking;
f) boundary walls/fences to be erected and/or retained;
g) existing and proposed site levels and floor levels;
h) hard and soft landscaping for the site;
i) the provision of private open space within each house plot to West
Dunbartonshire Council’s Residential Design Guidance Standards; and
j) provisions for the storage and collection of waste arising from the
development.
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2. Prior to the commencement of development on site, details of the
measures to be taken to protect the existing trees on the site, as identified
in the Tree Survey and Arboricultural Report, dated September 2019, shall
be submitted to and approved in writing by the planning authority. The
approved measures shall thereafter be fully implemented during the
course of all construction works on the site. None of these trees shall be
felled, lopped or topped except as otherwise approved by the authority.
3. Further to Section 4.2 of the approved Extended Phase 1 Habitat Survey
(dated 15 August 2019) the further badger, otter, water vole and bat
surveys and assessments shall be carried out and submitted for approval
by the planning authority as part of the detailed application(s) for the
matters specified in conditions. If no works have commenced on site by 1
August 2021, a new habitat survey shall be undertaken and submitted as
part of the detailed application(s). This shall either confirm that the findings
and recommendations of the original survey remain valid or alternatively
outline further recommendations as required based on current
circumstances.
4. No development shall take place within the development site until the
developer has secured the implementation of a programme of
archaeological works in accordance with a written scheme of investigation
which has been submitted to and approved in writing by the planning
authority. Thereafter the developer shall ensure that the programme of
archaeological works is fully implemented and that all recording and
recovery of archaeological resources within the development site is
undertaken to the satisfaction of the Planning Authority in agreement with
the West of Scotland Archaeological Service.
5. Further to Appendix 4: ‘Flood Risk Assessment’ of the approved
Engineering Assessment and Drainage Report (dated September 2019),
any modification or alterations to the indicative masterplan layout of the
proposed residential development (as shown on approved plan
‘Masterplan’ (Drawing No. 5914(2) S005 Rev E) shall be subject to a
further Flood Risk Assessment. This shall be submitted as part of the
application(s) for the approval of matters specified in conditions.
6. No development shall commence on site until a site-specific Construction
Environmental Management Plan (CEMP) has been submitted to and
approved in writing by the planning authority. The CEMP shall include the
following information:
a) a site management plan including details of the management/storage
of soil and construction materials, of the storage of all waste materials,
and for the parking of all vehicles associated with the construction
operations;
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b) a construction method statement, detailing the hours of construction
operations and deliveries, measures to prevent the transmission of
noise to adjoining residents, and measures to control the spread of
dust from the site;
c) details of wheel-washing arrangements;
d) a construction traffic management plan; and
e) details of construction stage sustainable drainage measures, including
provision for
f) the prevention of pollution of groundwater or surface watercourses.
7. Unless otherwise agreed in writing by the Planning Authority, none of the
houses within the development shall be occupied until bus stops and
shelters have been provided on Craigielea Road, in locations to be agreed
with the Council, as Roads Authority, and Strathclyde Partnership for
Transport. Furthermore a footpath linking these stops with the
development shall be provided prior to the occupation of the 64th
dwellinghouse in the development site.
8. That the development shall be implemented in a continuous programme of
construction commencing with the northern field as Phase 1 and
concluding with the southwestern field as Phase 2.
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Pamela Clifford 
Planning, Building Standards and Environmental Health Manager
Date: 14th February 2024
Person to Contact: Pamela Clifford, Planning, Building Standards and
Environmental Health Manager
Pamela.Clifford@west-dunbarton.gov.uk
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
7.
8.
Representations
Planning Appeal Decisions PPA-160-2030 and
PPA-160-2039
Wards affected: Ward 4 (Kilpartick)
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¯
Reproduced by permission of Ordnance Survey on behalf of HMSO. (C) Crown copyright and database right 01/02/2024.
All rights reserved. West Dunbartonshire OS Licence Number 100020790.
Scale: 1:3,500@A401/02/2024
DC23/205/FUL - MapWest Dunbartonshire
Council
16 Church Street
Dumbarton
G82 1QL
ITEM 6d - APPENDIX 1
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager      
Planning Committee: 14th February 2024
_____________________________________________________________
DC22/185/FUL: Change of ground for the siting of three holiday lodges,
associated waste water treatment plant and ancillary car
parking at Former Maryland Water Pumping Station,
Garshake Road, Dumbarton by Mrs Mary Gillies
1. Purpose
1.1 To provide the Committee with additional information following continuation of
the above planning application and to seek the Committee’s decision on the
application.
2. Recommendations
2.1 Grant planning permission subject to the revised conditions set out in
Appendix 2 of the report.
3. Background
3.1  The above planning application was presented to Planning Committee on 13th
April 2023. Appendix 1 contains a copy of the report previously considered by
Planning Committee. It was determined by Committee to continue the
application to allow officers to seek further detailed information on drainage and
parking, which were proposed to be secured through condition, prior to the
application being determined. The Planning Committee also requested that the
applicant address concerns raised about the visual impact and safety of the
stepped access to the lodges and the lack of disabled access.
3.2 The applicant subsequently submitted an updated layout with the following
changes:
• The stepped access from the car park to the central courtyard and
lodges at upper level has been removed and the resulting opening in the
1.1m high wall closed off with timber cladding consistent with the rest of
the wall.
• A new, more gradually sloping stepped access is proposed adjacent to
the western elevation of Unit 1.
• Addition of a second 1.2m wide hard surfaced footpath which takes a
wider sweep around the western side of Unit 1, with a lesser gradient (1
in 12) enabling wheelchair access.
ITEM 6e
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• Two car parking bays at the western end of the parking area have been
re-positioned to enhance the overall area for turning/reversing.
• One car park space has been designated for disabled drivers.
3.3 In addition to the proposed changes, further information on drainage has been
provided, which advises that waste water will be discharged via a soakaway to
an on-site Sewage Treatment Plant, with surface water drainage collected and
discharged via soakaways. A Phase 1 Desk Top Study on the historical usage,
geology and potential contamination has also been submitted.   
3.4 In addition to the further details requested by Planning Committee, the applicant
has also indicated that they are agreeable to the attachment of an additional
Planning Condition restricting occupancy of the lodges to a maximum of 4
people per unit.  
4. Main Issues
4.1 There are no material changes to either the development plan position or the
circumstances of the site since Committee previously considered the
application. 
Parking
4.2 With respect to the requirement for a turning area that facilitates cars to enter
and exit in a forward gear, which was highlighted in the original consultation
response from the Roads Service, two car parking bays at the western end of
the parking area have been re-positioned to enhance the overall area for
turning/reversing. Disabled parking provision has also now been added.  An
updated consultation response from the Roads Service advises that the revised
parking layout raises no concerns. It is therefore considered that the revised
parking layout is acceptable. 
Water Supply and Drainage Arrangements
4.3 With regard to foul and surface drainage, the applicant has submitted further
information which advises that waste water will be discharged via a soakaway
to an on-site Sewage Treatment Plant, with surface water drainage collected
and discharged via soakaways. It is noted that the drainage arrangements will
meet current standards and SEPA Guidelines. In support of the proposed
drainage arrangements, a Phase 1 Desktop Study on the historical usage,
geology and potential contamination has been submitted. This study identified
no potential contaminative uses of the site and concluded that the proposed
holiday lodges would have a very low impact on the site and that there is a very
low risk to current and future users. The drainage proposals have been
considered by the Roads Service, who raised no objection in their consultation
response. In light of this, it can be concluded that the proposed drainage
arrangements are acceptable.  
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Design and Appearance of the development
4.4 In response to concerns about the safety and visual impact of the stepped
access from the centre of the car park to the courtyard and lodges at the upper
level, this access has been relocated to be adjacent to the western elevation of
Unit 1. The gradient of the access has also been significantly reduced. It is
considered that locating the stepped access to the side of the existing structure
and Unit 1 will significantly reduce the visual impact, with the more gradual
gradient also reducing safety concerns. As such, the new stepped access is
acceptable.
4.5 Further to concerns about the lack of disabled access to the lodges, the revised
layout includes a second 1.2m wide hard surfaced footpath which takes a wider
sweep around the western side of Unit 1, with a lesser gradient (1 in 12). It is
considered that this path will enable wheelchair access and is therefore
acceptable. 
Other matters
4.6 Whilst not an issue that the Committee sought additional or revised details in
respect of, the applicant has provided updated details on the occupancy of the
holiday lodges. The applicant has indicated that they are agreeable to the
attachment of a planning condition restricting occupancy of the lodges to a
maximum of 4 people per unit. It is considered that this will additionally allow
further control over the occupation and use of the site, further reducing any
potential impacts. 
Conclusion
4.7 It is considered that the revised layout and details has addressed the
requirements for further information on drainage and parking, which were
identified in the April 2023 Committee Report (see Appendix 1). Additional
changes to the stepped access and the provision of wheelchair access are also
welcome and acceptable. Overall, the amendments to the detail and design
beyond that previously granted planning permission in 2021, will have no
significant or adverse effects on the physical appearance of the overall
development or significant impacts on the surrounding landscape and visual
amenity. The proposed changes are considered acceptable.  It remains the
case that the revised proposal accords with NPF4, the adopted West
Dunbartonshire Local Plan and the proposed West Dunbartonshire Local
Development Plan 2. The recommendation in 2.1 of this report is to grant the
application subject to the revised conditions detailed in 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.
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7. Risk Analysis
7.1 No risks have been identified.
8. Equalities Impact Assessment (EIA)
8.1 Not required.
9. Environmental Sustainability
9.1 Matters relating to environmental sustainability have been fully considered via
the planning application assessment.
10. Consultation
10.1 Consultation was undertaken as part of planning processes associated with the
planning application. The proposed amendments and additional details
provided do not result in any significant change to the proposal that requires
the application publicity to be re-issued. 
10.2 An updated consultation response was received from the Council’s Roads
Service who raise no objections on parking the drainage matters.
11. Strategic Assessment
11.1 There are no strategic issues.
Pamela Clifford 
Planning, Building Standards and Environmental Health Manager
Date: 14th February 2024 
Person to Contact: Pamela Clifford, Planning, Building Standards and
Environmental Health Manager
Pamela.Clifford@west-dunbarton.gov.uk
James McColl, Development Management Team
Leader
james.mccoll@west-dunbarton.gov.uk
DC22/185/FUL Committee Report (19/4/2023)
Updated conditions
Location Plan
Appendix1:
Appendix2:
Appendix3:
Wards affected: Ward 3 (Dumbarton)
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ITEM 6e - APPENDIX 1
WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager
Planning Committee: 19th April 2023
_____________________________________________________________
DC22/185/FUL: Change of ground for the siting of three holiday lodges,
associated waste water treatment plant and ancillary car
parking at Former Maryland Water Pumping Station,
Garshake Road, Dumbarton by Mrs Mary Gillies
1. REASON FOR REPORT
1.1 The application has been subject of a number of objections, including one from the
Silverton and Overtoun Community Council. 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. 
3. DEVELOPMENT DETAILS
3.1 The application relates to a former Scottish Water site located adjacent to a private
road approximately 380m northwest of the fork at the top of Garshake Road
Dumbarton. The site is 0.2ha in size and spilt across two distinct levels, with the
upper level created by a former water storage tank, which measures approximately
20.4m x 15m. In addition to the storage tank, the site also includes a lower section
which provides level access to the private road. The site is bounded by the private
road to the east, mature woodland to the west and north, and a narrower strip of
trees to the south.
3.2    In 2021, planning permission was granted for a change of use of the site for the
siting of three holiday lodges, including a waste water treatment area and ancillary
car parking (DC21/096/FUL). It was subsequently brought to the Council’s
attention that the applicant had undertaken works on site which did not follow the
planning permission granted. Following discussions with the applicant, an
application was submitted in respect of the changes undertaken on site which did
not accord with the planning permission granted. 
3.3       The main amendments to the proposal are as follows:
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• The dimensions of all proposed units has been altered, with each unit having
a footprint of 55sqm, being 11m L x 5m W, 2.5m to eaves height and 3.2m to
the highest point of the roof.
• In relation to the units previously approved, the proposed footprint of Units 1
and 3 have been reduced by a total of approximately 32.8sqm (16.4sm each),
with the highest point of the proposed roof reduced by 0.2m. The proposed
footprint of Unit 2 has increased by 7.7sqm, with the highest point of the
proposed roof reduced by 0.7m. Overall, the total footprint proposed
represents a decrease of 25.1sqm.
• Number and placement of windows and doors has been altered, with each unit
having three double windows on the front elevation, a set of double doors on
the gable elevation and one double window on the rear elevation. Previously,
Units 1 and 3 had two double windows and a front door on the front elevation,
two double windows on Gable 1, two windows on Gable 2 and a double window
and set of French doors on the rear elevation. Unit 2 differed in having three
windows on Gable 1, one window on Gable 2, with the rear elevation having
one window at upper level.
• Unit 2 re-ordinated through 90 degrees.
• Units 1 and 3 moved forward by approximately 3 metres.
• Profile of external staircase between the upper and lower sections, which
previously comprised a half-landing before turning and continuing upwards,
has been straightened as one.
• Demolition of single storey former valve house, which was previously retained
• Opening of the front elevation of former water tank to allow installation of new
double doors measuring 2.1 W x 2.3 H.
• Alterations to the parking layout and associated works, with two car parking
spaces to the west of the external staircase removed and two new spaces
created to the east of the staircase.
• Timber cladding added to the front elevation of the former water tank, including
new door opening.
• Addition of a new 1.6m high timber screen fencing along the gable ends of unit
2, a 1.6m high wall to the north of the gable end of unit 1 and a 1.1m high wall
along the front edge of the former water tank
4. CONSULTATIONS
4.1 West Dunbartonshire Council Roads Service have no objections on roads and
parking grounds subject to the applicant addressing the requirement for turning
space within the site. No objection on flooding grounds.  
4.2 West Dunbartonshire Council Environmental Health Service have no objection,
subject to two conditions relating to re-use of site material and unexpected
contamination being attached. 
4.3  Scottish Water have no objection to the proposed alterations.
5. REPRESENTATIONS
5.1 Nine objections from local residents (some of whom have forwarded multiple
submissions), the Woodland Trust, and the Silverton and Overtourn Community
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Council were received. The detail of each representation is available in the
electronic planning file for the application and available for public viewing. The
material concerns raised in the objections can be summarised as follows:
Layout and Design
• Concern that U-shaped layout lends itself to group bookings.
• Lodges have changed significantly in size, design and positioning.
• Design of lodges is cramped to achieve maximum occupancy.
• New 1 metre wall on top of former water tank is obtrusive and dominant.
• External staircase now has a straight profile, with concrete finish not in keeping
with rest of the development and surrounding rural area.
• Removal of original valve house has altered front façade.
• Lodges 1 and 3 previously had an outlook to the River Clyde, which has been
removed.
• No landscape plan provided.
• Entrance gates not in keeping with surrounding landscape.
• No disabled access.
• Proposal constitutes overdevelopment.
Landscape and Visual Impact
• Adverse effects on local character and visual amenity.
• Trees removed outwith site, but close to boundary.
Residential Amenity
• Proposal would result in anti-social behaviour.
• Disturbance to residential amenity, including sheltered housing on Baxter
View.
• Believe a hot tub will be built on the terrace area.
Access and Parking
• Adverse impacts on road safety due to increased traffic generated.
• Lack of adequate parking provision.
• Lack of turning head space within parking area.
• Location of two new car parking spaces will create congestion at entrance and
result in cars reversing onto farm track.
• Straightened external staircase will make turning more difficult in the site.
• Adverse safety impacts on use of Core Path no.56.
Drainage
• No details provided on surface water or foul drainage.
• Concern that a soakaway cannot be supported on the site.
• No servitude rights to access mains water or discharge wastewater to adjacent
land.
Procedure
• Private access should be included in the application site boundary.
• Application DC21/096/FUL not properly assessed.
• Planning conditions attached to DC21/096/FUL disregarded.
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• Planning permission for DC21/096/FUL should be invalidated.
• No Building Warrant for the development.
• Site description is inaccurate.
• General lack of detail in application.
Other Issues
• Contrary to Green Belt Policy.
• Applicant does not own or have full permission to use the private road to
access the application site.
• Development will result in adverse impacts on the ancient woodland within Barr
Wood.
• Site not suitable for development due to its location between two high voltage
pylons.
• Unauthorised works undertaken.
• Opening of the former water tank is a change of use.
• Concern about future use of former water tank and its structural integrity
• Engineer’s Report on former water tank not submitted.
• No net environmental gain identified.
• No carbon reduction plan or inclusion of any renewable energy technology.
6. ASSESSMENT AGAINST THE DEVELOPMENT PLAN
National Planning Framework 4 (NPF4)
6.1     National Planning Framework 4 (NPF4) was adopted by the Scottish Ministers on
13th of February 2023 and now forms part of the Development Plan.
6.2   Policy 1 relates to tackling the climate and nature crises. 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. Policy 3 seeks to protect biodiversity, reverse biodiversity loss,
and deliver positive effects from development and strengthen nature networks.
Criterion (c) states that proposals for local development will include appropriate
measures to conserve, restore and enhance biodiversity, in accordance with
national and local guidance. Measures should be proportionate to the nature and
scale of development. Overall, the proposal re-uses an existing structure as part
of the development and as such the embodied energy of the structure remains. It
is considered that the nature and small scale changes proposed to the design and
layout would have a neutral effect in respect of Policies 1, 2 and 3.
6.3 Policy 8 seeks to promote and facilitate compact urban growth and only supports
development in the Green Belt in certain circumstances. Proposals are also
required to meet additional criteria, including the need for development to be
compatible with the surrounding established countryside and landscape character;
be designed to an appropriate scale, massing and external appearance; use
materials that minimise visual impact on the green belt as far as possible; and have
no significant long-term impacts on the environmental quality of the Green Belt. 
6.4 Following the grant of planning permission for DC21/096/FUL, the principle of
development in a Green Belt location is established. Following an assessment of
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the proposed layout, design, impacts on landscape character and visual amenity,
set out in section 7 below, it is considered that the proposal, specifically the
proposed changes to DC21/096/FUL, complies with the Policy 8.   
6.5     Policy 14 aims to promote and facilitate well designed development that makes
successful places by taking a design-led approach and applying the place
principle. The policy supports proposals which are consistent with the six qualities
of successful places; healthy, pleasant, connected, distinctive, sustainable and
adaptable. It is considered that the small scale nature of the proposed changes to
the layout and design do not raise any concerns with regard to six qualities of
successful places. 
6.6 Flood risk and water management is covered in Policy 22. The proposal is not at
risk of flooding or considered to add to flood risk. The policy goes on to require
proposals to manage all rain and surface water through sustainable drainage
systems (SuDS). A SuDS / soakaway arrangement is proposed and final details
can be addressed by condition.
6.7     Development proposals that are likely to raise unacceptable noise issues will not
be supported, in accordance with Policy 23. The site is located some 300 metres
from the nearest adjacent properties and in any case, the amendments being
considered would not result in any noise concerns beyond the consented position.
6.8 Tourism proposals are addressed by Policy 30, which sets out a range of criteria
to be taken into account. In this case, the acceptability of the use of the site is
already established by the extant planning permission and the amendments under
consideration raise no issues that require assessment in respect of this policy. 
6.9 Overall, it is considered that the proposal is supported by and presents no conflict
with the policies set out within NPF4 and is assessed fully in Section 7 below.
West Dunbartonshire Adopted Local Plan 2010 
6.10 Policy GB1 aims to restrict the types of green belt development which could be
accommodated within the urban area by defining the uses and types of
development that are acceptable in the green belt. It notes that development which
would have an adverse effect on the landscape character of the local area is not
supported. The principle of development is established by the previous permission.
It is considered that the proposal would not have any significant adverse effects
on landscape character, with further assessment set out in section 7 below.
6.11 Policy GD1 of the Local Plan seeks to ensure that all new development enhances
the Plan area and environmental quality in general through an emphasis on high
quality design. Proposals are required to meet a number of criteria, including the
need to be appropriate to the local area in terms of land use and layout and design;
be energy efficient and meet the roads, parking and access requirements of the
Council. 
6.12 The proposed changes to the layout and design are assessed in section 7 below,
which concludes that they are appropriate and do not raise any concerns with
respect to the six qualities of successful places. Further to the assessment of
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parking below, it is considered that the proposal meets the Council’s parking
standards. 
6.13 Policy F2 requires proposals to satisfy the principles of Sustainable Drainage
Systems (SuDS) and identify maintenance arrangements, where appropriate. The
policy also requires Drainage Impact Assessments (DIA) to be submitted for any
proposals which requires waste or surface water to be drained. The principle of
private waste water treatment on the site was established through DC21/096/FUL
and, subject to the final details being agreed, there is no conflict with this policy.
6.14 Policy LE8 supports applications for tourist industry development, subject to there
being no adverse environmental, landscape, infrastructure and transport
implications; a clear locational need and significant economic benefit. As noted
above, the acceptability of the use of the site is already established by the extant
planning permission and the amendments under consideration raise no issues that
require assessment in respect of this policy.
6.15 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 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.
7.2 Policy GB1 seeks to direct new development towards the urban area in order to
support regeneration and maintain the attractiveness and character of the Green
Belt, whilst also supporting economic development and diversification in the green
belt, under certain circumstances. This support is subject to a number of additional
requirements being met, including the need for proposals to be fully compatible
with surrounding established countryside character, and avoid unacceptable
impacts on the environmental quality and landscape character of the Green Belt.
In addition to the principle of development having already been established, it is
considered that the small scale and type of changes proposed to the layout and
design would be compatible with the surrounding landscape character and would
avoid any significant adverse effects on the landscape and surrounding
environmental quality.
7.3 Policy CP1 requires new development to take a design-led approach to creating
sustainable places, which put the needs of people first and demonstrate the six
qualities of successful places.  Further to the assessment of changes proposed to
the layout and design, set out in Section 7 below, it is considered that the proposal
complies with the policy.   
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7.4    Policy CP2 seeks to promote the role of green infrastructure in creating high quality
places. The policy requires proposals to integrate Sustainable Drainage Systems
(SuDS) features in line with the current Sewers for Scotland Guidance (i.e. v 4.0),
with applicants required to demonstrate how the design and layout of SuDS
reflects and responds to the site circumstance and local landscape character. 
7.5 Policy E6 supports tourist facilities where there would be no adverse effect on the
integrity of a Natura 2000 site and they avoid adverse impacts on the green
network and built heritage. With the acceptability of the use of the site already
established by the extant planning permission and the amendments under
consideration raising no issues, further assessment in respect of this policy is not
required. 
7.6   It is considered that the proposal being assessed presents no conflict with the
relevant policies of the proposed LDP2.
Principle of Development
7.7  The principle of development for the proposed use of the site and erection of three
holiday lodges is already established through the grant of planning permission for
DC21/096/FUL, which remains extant for the development of the site. The principle
of the development does not therefore require to be further assessed as part of
this application as this has been agreed by the previous permission.     
Design and Appearance of the development
7.8 The proposed site is located in a rural area adjacent to a private road
approximately 380m northwest of the fork at the top of Garshake Road in
Dumbarton. The site is well screened by mature woodland to the west and north,
and a narrower strip of trees to the south. As such, the site is only visible when in
close proximity to it. The revised design of each lodge does not raise any concerns
with regard to their external appearance, outlook or impacts on the wider site.
Indeed, each lodge having the same design and dimension delivers a higher level
of uniformity and coherence than that previously approved. It is also noted that
revised design will result in the lodges having a smaller overall footprint than that
originally approved. With regard to layout, it is considered that the re-orientation of
Unit 2 by 90 degrees would have a positive effect by creating a more enclosed and
defined space that contributes to a greater sense of place within the wider site.
Moving Units 1 and 3 forward by approximately 3 metres to be adjacent to the front
edge of the former water tank is considered to have a neutral effect. The provision
of appropriate landscaping can be addressed through condition. Overall, the
design, appearance and visual arrangement of the lodges situated on the former
water storage tank is considered acceptable and also improves the overall
arrangement on site beyond the consented position.
7.9 The amended design to the stairway within the site giving access between the
lower and upper sections results in a straight stairway rather than the previous
half-landing before turning and continuing upwards arrangement.  Whilst this
marginally increases the visual impact of the staircase when viewed from outwith
the site, the arrangement is considered acceptable as the overall site is well
screened and not visually prominent. However, notwithstanding the straightened
profile of the external staircase being acceptable, the concrete finish proposed
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raises concerns visually and is not considered to be compatible with the more
natural timber material finishes across the wider site. In light of this, and following
discussions with the applicant, it was agreed that either side of the staircase would
be clad in timber to match that of the wider site. The removal of the valve house to
allow for a better car parking arrangement does not have any adverse visual
impact and in any case, a non–residential building could be demolished without
requiring planning permission.
7.10 Turning to the amended walling and fencing arrangement within the site, the
introduction of 1.6m high timber screen fencing along the gable ends of unit 2, a
1.6m high wall to the north of the gable end of Unit 1 and a 1.1m high wall along
the front edge of the former water tank is considered to be proportionate in scale
to the wider development, with the timber fencing in keeping with the timber
finishes of the lodges. To soften the effect of the proposed walls, a condition
requiring a timber clad finish is recommended. The amendment to the entrance
gate does not raise any concerns and is acceptable. The opening formed within
the front wall of the former water storage tank, which will be fitted with steel double
doors with a timber clad finish, is considered compatible with the other parts of the
development. The use of gabion baskets along the northern boundary of the
parking spaces south of Unit 1, and the timber fencing proposed at the entrance
would not have a significant adverse effect on the overall appearance of the wider
site. Overall, it is considered that the proposed development is appropriate in terms
of the layout and design and that these matters are satisfactorily addressed. 
Impacts on Landscape Character and Visual Amenity
7.11  The siting of three holiday lodges would not have any significant effects on local
landscape character or visual amenity due to the site being well screened by
landscaping and not visually prominent. Therefore the nature and small scale
changes proposed would have limited visual effect beyond the site. In light of this,
it is considered that the proposed changes will not have any significant impacts on
the character and visual amenity of the surrounding area.  
Flood Risk and Drainage Arrangements
7.12  There is no objection to the proposal from the Councils Roads Service in their
capacity as local flooding authority on flood risk grounds. The principle of a private
waste water drainage system on the site was established through DC21/096/FUL
and the final detail can be addressed by condition together with the final drainage
arrangements. The proposal is therefore acceptable and Scottish Water have not
raised any concerns.  
Roads, access and parking
7.13   The location of the site and access from the private road was accepted in the
originally granted planning permission. Whilst finished with a loose surface and
being single track, the traffic associated with three small holiday lodges will be
minimal and does not raise concern. The use of a private road to access this type
of development is a common situation. It remains the case that the Council’s
Roads Service raises no objections to the access arrangements.  
7.14    While the proposal does not alter the number of parking spaces with the site, it
does seek to change the parking layout from that previously permitted, specifically
the removal of two car parking spaces to the west of the external staircase and the
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creation of two new spaces to the east of the staircase. The Roads Service have
indicated that a turning space within the parking area should be provided. There is
sufficient space within the site to provide a suitable turning arrangement and the
final detail of this can be addressed by condition. Subject to the agreement of these
final details, the proposed parking arrangement is acceptable. 
7.15     While it is acknowledged that the private access road is a core path, no changes
are proposed to the core path. The core path is currently not exclusively used by
walkers nor is it a grass track in which it is proposed to be surfaced in a way that
will completely change its character and use. It is an existing loose surfaced private
road designed for use by vehicles. As noted above, the traffic associated with three
small holiday lodges will be minimal and the proposed development does not
adversely impact upon users of the core path. In fact people using the holiday
lodges are likely to use the core path to gain access to the Kilpatrick Hills and the
wider area. The Council’s Access Officer also offered no objections to the original
planning application. In any case, this application assesses the design changes
beyond the original proposal and the proposed changes have no impact upon the
core path. 
Residential Amenity
7.16    Whilst concerns are raised in respect of possible noise disturbance from the use
of the site, particularly given the lack of management on site or adjacent to the site,
the site is not located near any neighbouring residential properties. It is some 300
metres from the nearest houses in Bellsmyre, 360 metres from Baxter View and
400 metres from Maryland Farm. The amended proposal being considered does
not increase the number of lodges nor the potential duration of occupation. The
changes being assessed therefore have no impact on residential amenity.
Notwithstanding this, the requirement to submit a management plan for the
operation of the site is addressed by condition. 
Other Matters raised in representations
7.17 A wide range of other issues have been raised in the objections received which
have not already been assessed above. Concern is raised regarding the
processing and assessment of the original planning application previously granted
for the site (ref: DC21/096/FUL). It is accepted that the report of handling
references a site adjacent to the fork at the top of Garshake Road and not the
correct application site. However, following a review of the planning decision, it is
clear that the submitted application and all associated documentation related to
the correct site. The consultation process was also undertaken on the correct site
and submitted application proposal. In respect of the planning policy situation, both
sites are located within the Green Belt and the policy position is consistent across
both sites. The development complied with all relevant policies, nothing arose in
the consultation responses which suggested the proposal was unacceptable and
there are no material considerations which suggested that the application should
not have been granted. Whilst the situation is unfortunate, any concerns require to
be considered separately to this application submission and the Council has
responded to the submitted complaints via the Council’s complaints process. 
7.18 The retrospective nature of the application is highlighted. Whilst these concerns
are shared, this can have no bearing on the assessment of the submitted
application. An application being retrospective is not grounds for a decision of
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refusal. Further concerns were raised about the failure to comply with the
conditions attached to planning permission DC21/096/FUL. Whilst this was raised
with the applicant, the submission of this application allows a review of all condition
requirements and addresses any breaches of planning conditions. It is noted that
those conditions previously attached to the permission for DC21/096/FUL, which
remain relevant and appropriate to this proposal, will be attached to a permission,
if granted. Issues relating to the requirement for, or absence of, a Building Warrant
are not a material planning matter and are addressed through the Building
(Scotland) Act and not the Planning Acts.      
7.19 Concerns relating to the right of access and use of the private road are civil matters
that can have no bearing on the assessment of a planning application. Damage to
neighbouring land including any tree removal on neighbouring land are also civil
matters. The design amendments being considered will not impact on adjacent
land or woodland. The right to connect to any water supply is not a matter to be
determined via the planning process. 
7.20 In further considering procedural matters, concern is raised that the application
should not have been validated due to the omission of the private road from the
application site. The means of access to an application site requires to be clear. In
this case the means of access is via the existing, long established road adjacent
to the site. It does not follow that because this road is private and unadopted that
it requires to be included within the application site. A road outwith the
development site itself would only be included if a proposal requires works to be
undertaken to the road. This is not the case here. Concern that the application
lacks detail is also highlighted. It is considered that the level of detail required to
enable a full assessment is provided in the application submission. Noting concern
regarding the lack of a business plan and carbon reduction plan, sufficient
supporting documentation was considered to have been submitted with the original
application for a proposal of this nature within a Green Belt location, and it is not
appropriate to revisit this conclusion as part of this application assessment. The
concern regarding the site description on the submitted application form is noted.
The application site does not have a postal address and in such cases, it is
commonplace to find a range of site descriptions used in identifying a site. It is a
requirement of any planning application to submit a location plan with the
application site clearly outlined in red to ensure an application site is clearly
identified. This has been submitted as required and is available on the electronic
planning application file. There is no doubt on the site to which this application
relates.  
7.21 In relation to concerns about the opening of the former water tank, specifically its
structural integrity and use, while a Site Investigation Report submitted with
DC21/096/FUL recommended that the condition of the water tank and supporting
columns be assessed by a structural engineer, the structural integrity of buildings
is a matter for the building warrant process and not a material planning
consideration. In relation to use, the opening of the former tank is not itself a
change of use. The applicant has also confirmed there are no proposals to use the
void of the former tank. It is noted that a planning application would be required if
it is proposed to change the use of the former tank in the future. 
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7.22 With regard to concern raised about a lack of biodiversity gain, no such
requirements were considered necessary in originally granting planning
permission. This application is considering the design amendments which do not,
on their own, justify biodiversity enhancements.  
7.23 The proximity of the above ground high voltage electricity transmission lines has
no bearing on the acceptability of the proposal and while concern is raised about
the possible installation and use of a hot tub, this does not form part of the
proposal.
8. CONCLUSION
8.1 It is considered that the amendments to the detail and design, beyond that
previously granted planning permission, will have no significant or adverse effects
on the physical appearance of the overall development or significant impacts on
the surrounding landscape and visual amenity. The proposed changes are
considered acceptable.  The revised proposal accords with reference to NPF4, the
adopted West Dunbartonshire Local Plan and the proposed West Dunbartonshire
Local Development Plan 2. Whilst the submitted objections are acknowledged,
there are no material planning considerations that suggest that planning
permission should not be granted subject to the conditions below. 
9. CONDITIONS
1. No individual shall reside in the tourist accommodation for more than 28
consecutive days. In addition, no individuals shall reside in the tourist
accommodation for more than 60 days in the calendar year. To this effect, a
permanent log book shall be kept of all visitors who stay at the tourist
accommodation for the lifetime of the development. This shall note the names
and addresses of all visitors. The log book shall be made available for the
inspection of the Council as Planning Authority, if requested.
2. Prior to the commencement of development, full details of the parking
arrangement will be provided to the Planning Authority for written approval.
Thereafter, the approved parking arrangement shall be formed and available
prior to the lodges hereby approved being first brought into use. The spaces
and access arrangements shall thereafter be kept available for the lifetime of
the development.
3. Prior to the commencement of development, full details of the surface and foul
drainage shall be provided to the Planning Authority for written approval.
Thereafter, the approved arrangements shall be implemented prior to the
lodges hereby approved being brought into use. The drainage arrangements
shall thereafter be maintained for the lifetime of the development.  For the
avoidance of doubt, the arrangement will incorporate sustainable drainage
arrangements (SuDS).
4. Prior to the lodges hereby approved being first brought into use, the lodges
operator shall submit a Management Plan to the Planning Authority for their
written approval. The Management Plan shall include details of day to day site
management and maintenance and how potential noise and guest behaviour
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issues are to be dealt with, should they arise. Thereafter, the site will operate
in accordance with the approved Management Plan for the lifetime of the
development unless otherwise agreed by the Planning Authority. 
5. Prior to the commencement of works, full details of both hard and soft
landscaping works shall be submitted to and approved in writing by the
Planning Authority. Where appropriate, these details shall include proposed
finished and existing grounds levels and contours, hard surfacing materials and
lighting. Thereafter, the approved details shall be fully implemented in
accordance with the approved details prior to the lodges being brought into
use, unless otherwise agreed by the Planning Authority.  Any trees, shrubs, or
hedges planted in accordance with this condition which are removed, die,
become severely damaged or become seriously diseased within five years if
planting shall be replaced within the next planting season by trees, shrubs or
hedging plants of similar size and species to those originally required to be
planted.
6. The 1.6m high wall to the north of the gable end of unit 1 and the 1.1m high
wall along the front edge of the former water tank shall be finished in timber
cladding to match that across the wider site.
7. Prior to the commencement of development on site, the finishing materials to
be used shall be submitted to the Planning Authority for written approval.
Thereafter, the approved materials shall be implemented as approved.
8. If there is a requirement to either re-use site one 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 used. 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 and odours.
On completion of the works and at a time and/or phasing agreed by the
Planning Authority, the developer shall submit a verification report containing
details of the source of the material and appropriate test results to demonstrate
its suitability for use.
9. 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 works. The approved details shall be implemented as
approved.
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Pamela Clifford 
Planning, Building Standards and Environmental Health Manager
Date: 19th April 2023
Person to Contact: Pamela Clifford, Planning & Building Standards
Manager  
Email: Pamela.Clifford@west-dunbarton.gov.uk
Appendix:  Location Plan
Background Papers:
1. Application form and plans
2. National Planning Framework 4
3. West Dunbartonshire Local Plan 2010
4. Proposed West Dunbartonshire Local Development Plan
2 2020, as amended
5. Planning decision DC21/096/FUL
6. Consultation responses
7. Representations
Wards affected: Ward 3 - Dumbarton
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ITEM 6e - APPENDIX 2
CONDITIONS
1. No individuals shall reside in the tourist accommodation for more than 28
consecutive days or for more than 60 days in the calendar year.  To this effect,
a permanent log book shall be kept of all visitors who stay at the tourist
accommodation for the lifetime of the development. This shall note the names
and addresses of all visitors. The log book shall be made available for the
inspection of the Council as Planning Authority, if requested.
2. The occupation of each of the three lodges forming the tourist accommodation
hereby permitted shall not exceed four people at any one time, with a maximum
occupancy of the site as a whole not exceeding 12 people at any one time
3. The approved parking arrangement shall be formed and available prior to the
lodges hereby approved being first brought into use. The spaces and access
arrangements shall thereafter be kept available for the lifetime of the
development.
4. The approved arrangements shall be implemented prior to the lodges hereby
approved being brought into use. The drainage arrangements shall thereafter
be maintained for the lifetime of the development.  For the avoidance of doubt,
the arrangement will incorporate sustainable drainage arrangements (SuDS).
5. Prior to the lodges hereby approved being first brought into use, the lodges
operator shall submit a Management Plan to the Planning Authority for their
written approval. The Management Plan shall include details of day to day site
management and maintenance and how potential noise and guest behaviour
issues are to be dealt with, should they arise. Thereafter, the site will operate
in accordance with the approved Management Plan for the lifetime of the
development unless otherwise agreed by the Planning Authority.
6. Prior to the commencement of works, full details of both hard and soft
landscaping works shall be submitted to and approved in writing by the
Planning Authority. Where appropriate, these details shall include proposed
finished and existing grounds levels and contours, hard surfacing materials and
lighting. Thereafter, the approved details shall be fully implemented in
accordance with the approved details prior to the lodges being brought into use,
unless otherwise agreed by the Planning Authority.  Any trees, shrubs, or
hedges planted in accordance with this condition which are removed, die,
become severely damaged or become seriously diseased within five years if
planting shall be replaced within the next planting season by trees, shrubs or
hedging plants of similar size and species to those originally required to be
planted.
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7. The 1.6m high wall to the north of the gable end of unit 1 and the 1.1m high wall
along the front edge of the former water tank shall be finished in timber cladding
to match that across the wider site.
8. Prior to the commencement of development on site, the finishing materials to
be used shall be submitted to the Planning Authority for written approval.
Thereafter, the approved materials shall be implemented as approved.
9. If there is a requirement to either re-use site one 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 used. 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 and odours.
10. On completion of the works and at a time and/or phasing agreed by the
Planning Authority, the developer shall submit a verification report containing
details of the source of the material and appropriate test results to demonstrate
its suitability for use.
11. 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 works. The approved details shall be implemented as
approved.
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¯
Reproduced by permission of Ordnance Survey on behalf of HMSO. (C) Crown copyright and database right 01/02/2024.
All rights reserved. West Dunbartonshire OS Licence Number 100020790.
Scale: 1:1,250@A401/02/2024
DC22/185/FUL - MapWest Dunbartonshire
Council
16 Church Street
Dumbarton
G82 1QL
ITEM 6e - APPENDIX 3
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager 
Planning Committee: 14th February 2024
___________________________________________________________________ 
Subject:  DC22/072/FUL: Residential development, landscaping and
associated infrastructure at the former Our Lady and St
Patrick’s High School site, Hawthornhill Road, Dumbarton by
Persimmon Homes
1. Purpose
1.1 To provide the Committee with an update on the above planning application
and to seek the Committee’s updated decision on the application.
2. Recommendations
2.1 That the Committee indicate that it remains Minded to Grant planning
permission and delegate authority to the Planning, Building Standards and
Environmental Health Manager to issue the decision conditions set out in
Section 9 of Appendix 1 of the report and to the satisfactory conclusion of a
legal agreement or other suitable mechanism to secure a financial payment
towards open space provision/ green infrastructure improvements in the local
area.
3. Background
3.1  The above planning application was presented to Planning Committee on 12th
October 2022. Appendix 1 contains a copy of the report previously presented
to Planning Committee. It was agreed to grant planning permission subject to
the conditions set out in Section 9 of Appendix 1 of the report and to the
satisfactory conclusion of a legal agreement or other suitable mechanism to
secure a financial payment towards open space provision/ green infrastructure
improvements in the local area.
3.2 The applicant is now seeking to conclude the legal agreement in respect of
securing the financial payment towards open space provision/green
infrastructure improvements in the local area.  However, since the Committee
previously considered the application, a material change in circumstances has
occurred with the adoption of National Planning Framework on 13th February
2023 by the Scottish Government, with this document now forming part of the
adopted Development Plan. On 15th March 2023, the Planning Committee
also took a decision that the Council would not adopt Local Development Plan
2.
ITEM 6f
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Additionally since the Committee previously consider the application, the
Committee approved the adoption of the Creating Places Guidance and
Green Network and Green Infrastructure Guidance in November 2022 and
these documents have become material considerations. 
4. Main Issues
4.1 As the legal agreement in respect of securing the financial payment towards
open space provision/ green infrastructure improvements in the local area has
not yet been concluded and a decision on the application issued to the
applicant, the proposal requires to be further assessed in the context of any
new material planning considerations. 
National Planning Policy 4
4.2 Since the Committee previously considered the application, National Planning
Framework 4 (NPF4) has been adopted by the Scottish Ministers and now
forms part of the Development Plan. It now forms a key material consideration
in the assessment of all planning applications. 
4.3 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. Policy 3 requires development
proposals to contribute to the enhancement of biodiversity. The policy goes on
to set out the requirement for proposals for national and major development to
demonstrate that it will conserve, restore and enhance biodiversity.
4.4 As the site has been previously developed, Policy 9 addressing brownfield,
vacant and derelict land applies. Development proposals that will result in the
sustainable reuse of brownfield land including vacant and derelict land and
buildings, whether permanent or temporary, will be supported.
4.5 Policy 13 supports proposals to improve, enhance or provide active travel
infrastructure, public transport infrastructure or multi-modal hubs. This includes
proposals for electric vehicle charging infrastructure.
4.6 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. Development
proposal will contribute to local living including, where relevant, 20 minute
neighbourhoods. Consideration will be given to existing settlement pattern,
and the level and quality of interconnectivity of the proposed development with
the surrounding area, including local access to affordable and accessible
housing options, ability to age in place and housing diversity. 
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4.7 Policy 16 relates to quality homes. Development proposals for new homes on
land allocated for housing in LDPs will be supported. Part (c) supports
proposals for new homes that improve affordability and choice. This includes
a range of size of homes. 
4.8 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.
4.9 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 the proposal would not result in or
exacerbate a deficit in green infrastructure provision, and the overall integrity of
the network will be maintained. 
4.10 Policy 21 relates to play, recreation and sport and requires development
proposals that are likely to be occupied or used by children and young people
to be incorporate well designed, good quality provision for play at an appropriate
scale. New streets should be inclusive and enable children and young people
to play in the neighbourhood. New play provision will as far incorporate a range
of requirements including being accessible. 
4.11  Policy 22 - Flood risk and water management states 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. Policy 23 does not
support proposals which are likely to raise unacceptable noise issues. Policy
24 supports proposals that incorporate appropriate, universal, and future-
proofed digital infrastructure.
4.12 It can be concluded that the application proposal is supported by NPF4. The
site is identified as a residential development opportunity within proposed Local
Development Plan 2 and the proposal can therefore be considered to be
supported by Policy 16 of NPF4. The sustainable re-use of brownfield land is
supported through Policy 9 of NPF4. In respect of 20 minute neighbourhoods,
the proposal is within the existing urban area, is near to a variety of local
facilities and the wider connectivity of the site to public transport was assessed
in the original Committee Report. Matters including those relating to design and
layout, placemaking, biodiversity and flooding are also fully assessed in the
original Committee Report attached as Appendix 1 and meet the requirements
of NPF4. 
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West Dunbartonshire Local Development Plan (LDP2) Proposed Plan
4.13 On 15th 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 22nd April 2020, which were accepted by
the Planning Committee of 19th 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 18th December 2020, is also a material
consideration. 
4.14   The proposal was fully assessed against the polices of the proposed Local
Development Plan 2 in the original Committee Report as the Council’s most
up to date spatial strategy. There has been no material changes in the
development. 
Creating Places Guidance and Green Network and Green Infrastructure
Guidance
4.15 The Creating Places Guidance and Green Network and Green Infrastructure
Guidance have also been adopted by the Council since the application was
previously considered by the Committee.  These documents replace the
Residential Development Design Guidance and Our Green Network Planning
Guidance in place at the time the application was originally assessed.  
4.16   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 what is
expected for all development proposals. The proposal was originally informed
by pre-application discussions as encourage by the Guidance. This resulted in
a development proposal that achieves a high quality design that responds to
the local context as set out in the assessment within the original Committee
report. Overall, the proposal accords with the updated approach set out in the
Guidance.
4.17 The Green Network and Green Infrastructure Supplementary Guidance –
November 2022 seeks to ensure that the proposal also 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. As set
out in the original Committee report, this development requires 4,830 square
metres of open space. The proposed on-site provision sees a total area of open
space and landscaping of 3,918 square metres provided. It remains that the
Guidance allows for a relaxation in the open space standards where deemed
appropriate and in this circumstance developers will require to provide a
contribution towards open space and green network provision and
enhancement. This follows the position set out in the original Committee report
and the required contribution remains as per that set out in the original report.
The open space also integrates with the wider green network adjacent inclusive
of pathway connections. The proposal accords with the updated approach set
out in the Guidance.
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Conclusion
4.18 The proposed redevelopment of this former school site for 66 houses of 2 and
3 bedroom accommodation continues to be welcomed and is supported by
NPF4 which has been adopted since the original consideration of the planning
application by Committee in October 2022. The proposal is also supported by
the Creating Places Guidance and Green Network and Green Infrastructure
Guidance. The site is within an existing residential area and, subject to the
appropriate use of conditions, the proposed development is acceptable. The
layout and design of the development has been developed to ensure that it
integrates with the existing residential form. A high quality development will be
created which enhances the local residential area as well as improvements to
the footpath and greenspace networks. The development will provide high
quality housing with good connections to the surrounding area and wider green
network. 
4.19 This new housing development will transform the immediate surroundings and
contribute to the longer term redevelopment/regeneration of the area and
providing quality housing. It will result in a high quality residential development
and it remains that there are no material considerations which suggest that
planning permission should not be granted. 
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 Matters relating to environmental sustainability have been fully considered via
the planning application assessment.
10. Consultation
10.1 Consultation was undertaken as part of planning processes associated with the
planning application. No further consultation was required.  
11. Strategic Assessment
11.1 There are no strategic issues.
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Pamela Clifford 
Planning, Building Standards and Environmental Health Manager
Date: 14th February 2024 
Persons to Contact: Pamela Clifford, Planning, Building Standards and
Environmental Health Manager
Pamela.Clifford@west-dunbarton.gov.uk
James McColl, Development Management Team
Leader
james.mccoll@west-dunbarton.gov.uk
Appendix 1: Planning Committee Report: Ref: DC22/072/FUL –
12th October 2023
Wards affected: Ward 3 (Dumbarton)
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager
Planning Committee: 12th October 2022
_____________________________________________________________
DC22/072/FUL: Residential development, landscaping and associated
infrastructure at the former Our Lady and St Patrick’s
High School site, Hawthornhill Road, Dumbarton by
Persimmon Homes
1. REASON FOR REPORT
1.1 The application proposal comprises a major development as defined by The Town
and Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009.
Under the terms of the approved Scheme of Delegation, it therefore requires to be
determined by the Planning Committee. 
2. RECOMMENDATION
2.1 That the Committee indicate that it is Minded to Grant planning permission and
delegate authority to the Planning, Building Standards and Environmental Health
Manager to issue the decision subject to the conditions set out in Section 9 and to
the satisfactory conclusion of a legal agreement or other suitable mechanism to
secure a financial payment towards open space provision/ green infrastructure
improvements in the local area.  
3. DEVELOPMENT DETAILS
3.1  The site is located within the Castlehill area of Dumbarton and extends to 2.28
hectares. The site’s northern boundary is Hawthornhill Road, while the southern
boundary is along the A814 Cardross Road and adjoins the rear curtilages of nos
67 to 77 Cardross Road. The eastern boundary is partly adjacent to existing
houses in Sunderland Avenue and partly adjoins the boundary of Cunninghame
Graham Memorial Park, which comprises of Arthur’s Seat (directly adjacent to the
application site) and Castle Hill. The westernmost part of the site runs along the
boundary of a sports pitch which used to form a part of the former high school
complex but has been retained. A recent planning permission (ref DC21/243/FUL)
granted consent for the development of a pavilion to serve the aforementioned
sports pitch with an access linking through the new development. 
The site has been cleared following the demolition of the school complex circa
October 2018. Areas of hardsurface which formed part of the car park together
with a vacant former janitor’s house fronting Cardross Road remain within the site.
The application site also includes a section of Cardross Road which is associated
with the new access arrangements to the site.  
ITEM 6f - APPENDIX 1
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3.2 There is a gentle gradient across the site with a drop of approximately 5 metres
from north to the south, with the lowest point of the site being in the centre. The
site is bounded by a variety of fences. A variety of grassed areas interspersed by
occasional tree planting which remain from the former use. An existing electrical
sub-station is located next to the south-eastern corner of the site albeit out with the
application site. Public transport links in the form of bus stops are available in
Hawthornhill Road and Cardross Road with the site being a 10-minute walk from
Dalreoch train station and about a 20-minute walk away from Dumbarton Town
Centre. West of the adjacent sports pitch lies Dumbarton Joint Hospital.
3.3  Planning permission is sought for the construction of 68 no. houses and associated
works. 15 of the houses will be two bedroom and 53 will have three bedrooms. The
development comprises of a range of dwelling sizes as detailed below: 
• 15 no. x 2-bedroom mid-terrace houses
• 8 no. x 3-bedroom end-terrace houses
• 18 no. x 3-bedroom semi-detached houses
• 27 no. x 3-bedroom detached houses
3.4   The redevelopment of the site will consist of the demolition of the last remaining
structure that formed a part of the old school complex, namely the vacant janitor’s
house in Cardross Road at the southern boundary of the application site. Its
removal will enable the formation of the new vehicular access to the site. The
current vehicular access from Hawthornhill Road will not be retained as part of the
development although pedestrian connections are proposed to Hawthornhill Road.
The formation of access in Cardross Road will also require the relocation of the
existing signalised pedestrian crossing approximately 200m east to a
accommodate a new right-turn lane to serve the development. 
3.5  The development will comprise thirteen different house types all of which will be
two storey. External materials will comprise concrete roof tiles, a combination of
facing brick and render together with uPVC windows.   Each property will feature
in curtilage driveway parking constructed in blockwork and a private front and rear
garden area. Rear gardens will be defined by 1800mm high timber slatted fencing
with a feature wall and fence combination to prominent corner plots. Side
boundaries will be delineated by a 450mm high timber rail. In terms of the road
layout within the development, this will take the form of a large square-shaped two-
way loop accessed from Cardross Road with additional pedestrian connections to
Hawthornhill Road, Sunderland Avenue and the adjacent park. Parking will be
provided with a combination of in curtilage driveways and parking courts. A SuDS
pond would be located in the eastern part of the site directly adjacent to the
Cunninghame Graham Memorial Park. 
3.6 A landscape strategy is proposed and the landscaping will ensure an attractive
setting for the development that creates a ‘safe and pleasant space’ and aims to
be visually appealing. At the same time, the proposed landscaping will enhance
the square that will be created with Sunderland Ave where the use of variegated
sycamore along the western edge of the site to match those already within that
street will create an off-set avenue of trees. The fence boundary with
Cunninghame Graham Memorial Park will be removed. This will be done to allow
for the site to connect with the established park and connect with its surroundings
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naturally. This would be particularly accentuated by the location of the SuDS pond,
located at the low point of the site adjacent to the park. 
3.7 In support of the proposal the applicant has submitted a range of supporting
documentation and information including a Supporting Planning Statement,
Design and Access Statement, Pre-application Consultation Report, Open Space
Allocation, Obtrusive Light Compliance Report with Luminaire Schedule, Transport
Assessment, Flood Risk Assessment, Tree Report, Ecology Report, and Noise
Report.
4. CONSULTATIONS
4.1 West Dunbartonshire Council Roads Service and Environmental Health Service
have no objection to the proposals. A variety of points are highlighted and these
are considered within the assessment below.
4.2 West Dunbartonshire Council Biodiversity Officer highlights a range of points
including where value could be added to the landscaping. 
4.3 Scottish Water have not provided a response.
4.4 SP Energy Networks have no objection to the development, but advise of the
presence of HV/LV underground cables in the vicinity of the site and reserve the
right to protect and/or deviate this infrastructure at the applicant’s cost.
4.5 West of Scotland Archaeological Service have no objection.
4.6 Strathclyde Partnership for Transport (SPT) have not provided any response at the
time of writing the report.
5. REPRESENTATIONS
5.1 Four objections from three parties were received in connection with the application.
The detail of each submitted representation is available in the electronic planning
file for the application and available for public viewing. The concerns raised can,
however, be summarised as follows:
• Location of new access to the site in Cardross Road will lead to increase in
traffic congestion on this road, with the suggestion of vehicular access being
relocated to Hawthornhill Road.
• Impact of the new vehicular access and resulting traffic in the context of the
nearby proposed development of the Notre Dame Convent site.
• Concern over the possible removal of the existing signalised pedestrian
crossing in Cardross Road and impact on pedestrian safety, including children
accessing local schools.
• Impact on traffic and pedestrian safety.
• The new site access is too close to neighbouring property.
• There is insufficient room on the carriageway for the new right turn lane
• The development resulting in the removal of trees.
• Concerns regarding loss of privacy.
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• Neighbouring gardens may become waterlogged.
• Footpaths connecting the site with the adjacent park should not be allowed.
5.2 Two further representations have been received in support of the proposal
although these also highlight concerns including access and traffic together with
overlooking.
5.3 The concerns raised will be considered in Section 7 below.
6. ASSESSMENT AGAINST THE DEVELOPMENT PLAN
Clydeplan Strategic Development Plan 2017
6.1 The 2017 Clydeplan Strategic Development Plan (Clydeplan) sets out a strategic
vision to be implemented through a spatial development strategy and sets targets
for the provision of new housing within the component parts of the Plan area. This
provides that most development is to be focused on existing settlements, with
much of the intervening land being designated as Green Belt. Clydeplan is clear in
supporting housing growth that creates high quality places which delivers not only
the right type of homes but in the right locations. Clydeplan Policy 8 on Housing
Land Requirement is the most relevant policy in the context of this proposal. It
requires local authorities to make provisions in Local Development Plans for all
tenures and allocate sites which are effective or likely to be effective within the plan
periods to meet the housing land requirements for each housing sub-market area.
Policies 1 and 16 covering Placemaking and Managing Flood Risk and Drainage
are also of relevance.
6.2 The proposed development presents no conflict with Clydeplan and accordingly is
subject to an assessment against the Local Development Plan.
West Dunbartonshire Adopted Local Plan 2010 
6.3  Policy PS1 seeks to protect established public utility, social and community
facilities as identified on the Proposals Map. The high school that previously
occupied the site was identified on the Proposals Map under this policy. Prior to
closure the policy seeks that it is demonstrated that the facility is no longer
required. Any redevelopment will require to have regard to the surrounding area
together with other Local Plan policies. The school was replaced with a new facility
at Bellsmyre and the buildings have since been demolished. Policy UR1
encourages the redevelopment and re-use of underused, vacant and/or derelict
land and buildings for appropriate uses such as housing. Policy H4 sets out
standards expected of residential development, requiring high quality design in the
range of house types and sizes and in terms of form, layout and materials. Policy
GD1 seeks to ensure that all new development is of a high quality of design and
respects the character and amenity of the area. 
6.4 Policy R2 specifies the open space provision required for all developments.
Assessment of open space requirements has been undertaken against the more
updated “Our Green Network” Planning Guidance (2015) in Section 7 below.  
6.5  Policy T1 and T4 requires sites to be integrated with sustainable travel. 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
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not at risk from, and does not increase the risk of flooding, and has suitable SUDS
drainage infrastructure.
6.6  The proposal complies with the policies of the adopted local plan and is assessed
fully in Section 7 below.
7. ASSESSMENT AGAINST MATERIAL CONSIDERATIONS
National Policy
7.1 Scottish Planning Policy (SPP) introduces a presumption in favour of sustainable
development and indicates that the planning system should support economically,
environmentally and socially sustainable places by enabling development that
balances the costs and benefits of a proposal over the longer term. The aim is to
achieve the right development in the right place but not allow a development at
any cost. Design and Placemaking are key principles with SPP setting out that
planning requires to create better places through a design-led approach. Designing
Streets seeks to promote a clear hierarchy of streets with the creation of a sense
of place. The proposed development is considered consistent with national policy.
West Dunbartonshire Local Development Plan (LDP2) Proposed Plan
7.2 The modified Plan and associated documents was approved by the Council on 19
August 2020. The Council has advised the Scottish Ministers of its intention to
adopt the Plan. On 18 December 2020, the Scottish Ministers issued a Direction
in relation to the housing land chapter of the Plan. None of the policies considered
in the determination of this application are affected by that Direction. Therefore,
Local Development Plan 2 is the Council’s most up to date policy position and is
afforded significant weight in the assessment and determination of planning
applications. 
7.3 Policy H1 identifies that the Council will maintain a five-year effective supply of
housing land and Policy H2 supports the development of sites within Schedules 2
and 3 for new housing development where they accord with other relevant policies
of the Plan and associated supplementary guidance. This site is identified in
Schedule 2 a residential development opportunity for private housing (site ref
H2(23)) with an indicative capacity of 100 units. However, the wider allocation
includes the site of the adjacent sports pitch, a facility which is now being retained
by the Council.  Policy CP1 seeks to ensure that housing is of a high quality,
adaptable and is 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). 
7.4  Policy GI2, BE1, ENV1, ENV4, ENV5 and ENV6 are similar to the green network,
built heritage, tree, water environment and flooding policies of the adopted Local
Plan, albeit that Policy GI2 sets a higher open space standard to that of the
adopted Local Plan. 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. 
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7.5 Policy CON1 requires that significant travel generating uses are designed to
encourage sustainable transport and Policy CON4 sets out a need for all
developments to install sufficient broadband provisions. Policy ENV8 requires
developments to address air quality, lighting and noise as part of the planning
process, whilst policy ENV9 requires all potentially contaminated sites to be
remediated where necessary to ensure that the site is suitable for the intended
use. Policy RE5 sets out the requirements in respect of low and zero carbon
buildings. It is considered that the application proposal being assessed comply
with the relevant policies above as set out in the following assessment. 
Principle of Development
7.6   The site is a brownfield site within a well-established residential area and is
identified in the proposed LDP2 as a residential development opportunity for
private housing. The principle of the development of the site for new housing is
considered to be fully compatible with the surrounding locality and accordingly it
rests to consider whether there are any material planning considerations which
suggest that planning permission should not be granted for this residential
development on an identified residential development opportunity in proposed
LDP2. 
Site Layout, Design and Appearance
7.7 New residential layouts require to be well designed, take cognisance of the setting
into which they are introduced and provide a high quality environment of well-
designed buildings in a setting of gardens and open space whilst recognising the
impact on existing neighbouring properties. The surrounding locality is based on a
low density approach with a variety of detached, semi-detached and terraced
houses together with flatted houses situated within individual curtilages in a setting
which includes open space. Flatted blocks also feature within the locality and form
part of the wider low density arrangement. The proposed development follows the
overall theme and pattern of development in the locality and it is considered that
the density of development is compatible with the character and amenity of the
wider adjacent residential area.  
7.8 The development is designed to be outward looking providing a strong frontage to
both Cardross Road and Hawthornhill Road together with and the small square to
the front of the adjacent flats. The new dwellings within the central part of the site
ensure a strong street frontage is also provided within the central part of the
development. Considering design and the proposed materials, the proposed
houses are all two storeys with a variety of different house types which will assist
in creating visual interest within the development. This visual interest is enhanced
by the use of a range of roof shapes. Furthermore, the house designs feature
active gables at key locations and at spaces overlooking green spaces. The
proposed houses will be of a modern design and utilise high quality external
materials such as a good quality clay multi–red facing brick. The quality of the
layout and materials will enhance and contribute positively to the aesthetic of the
area. The houses will also feature porch canopies and solar panels incorporated
into the roof covers. The proposed layout has made the most of the site layout and
levels and its topographical character and what is proposed successfully integrates
into the wider residential area. The built ratio of each plot accords with the
requirements of the Council’s Residential Development Design Guidance and this
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ensures a suitable level of garden ground and associated private amenity space
is provided for new residents. 
7.9 Overall, it is considered that the proposal will create a well-designed and integrated
development which will address the six qualities of successful places by having a
distinctive identity, forming safe streets, having quality green infrastructure, using
high quality materials and being sustainable, all complying with policies GD1, DS1
and CP1 of the adopted and proposed Plans alongside the Residential
Development Design Guidance.  
Residential Amenity
7.10 Until demolition, the high school building was a significant and dominant feature
adjacent to the residential properties that surround the site. Whilst the new
development may introduce new houses in closer proximity to existing properties
than the previous buildings on site, these new buildings do not have the scale and
massing of that which existed previously. The concerns raised in the
representations in respect of privacy are noted. Whilst a number of plots adjoin the
existing garden boundaries of houses on Cardross Road and face towards the flats
at Sutherland Avenue, they will not be dominant or elevated and a window to
window distance in excess of 18 metres is achieved in all cases. It is further
considered that there is no adverse impact on daylight or sunlight to the nearest
houses. Window to window relationships within the development itself are also
acceptable. Whilst the development will undoubtedly bring additional activity to the
area, the occupation of new dwellings is not expected to cause any noise or activity
beyond that typically found in a residential area. Daytime activity will also likely be
significantly less than the previous high school use. Whilst it is accepted that any
construction site will produce an element of noise and disruption, the Council’s
Environmental Health Service highlight the requirement to require that the
construction of the development is undertaken in a way that ensures that adjacent
residential amenity is not adversely affected. A range of conditions are
recommended and it is considered appropriate to attach these. 
7.11 The consultation response from Environmental Health identifies the need for noise
to be fully assessed. A Noise Impact Assessment has been submitted in support
of the application. This considers how noise sources including road traffic noise
and the use of the adjacent sports pitch would impact upon the new dwellings. It
is concluded that with appropriate mitigation, noise would not adversely affect the
new residents. The requirement to follow the recommendations can be addressed
by condition. This includes the installation of a 2.2 metre high acoustic barrier
adjacent to the sports pitch. The potential for obtrusive lighting from the sports
pitch floodlighting to adversely affect the new houses has also been fully explored
and Environmental Health are content that the new houses will not be adversely
affected. 
Trees, open space and landscaping 
7.12 A variety of trees exist within the site. The function of these trees was to provide
part of the landscape setting of the school that formerly occupied the site. They
are not protected. Some of the trees are Ash trees affected by die back and the
appropriate course of action is to remove them. It is accepted that other trees are
removed to accommodate the development. It is not considered that they are
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significant specimens and new tree planting is provided as part of the new
development. 
7.13   In respect of open space, this predominantly takes the form of a grassed area; a
part of it is taken up by the proposed SuDS pond, which forms a focal point of the
development, located in the vicinity of the existing adjacent park. It is noted that
the Cunninghame Graham Memorial Park would be clearly and closely connected
with the planned development, thus compensating for the limited amount
greenspace within it and ensuring appropriate opportunities for outdoor recreation
and play provision for residents. Whilst the concern in the objections is noted, it
would be inappropriate not to maximise connections to the park. The level of open
space within the development is below that expected for such a development.
Policy GI2 of proposed LDP2 sets out the up to date position on open space
provision with this development requiring 4830 square metres of open space. The
development provides for a total area of open space and landscaping of 3918
square metres. The Policy goes on to highlight that where a relaxation in the open
space standards is deemed appropriate, developers will require to provide a
contribution in accordance with policy GI4. The required contribution in this
instance is £27360 and, this can be addressed by the conclusion of a legal
agreement. .
7.14 The landscaping strategy includes a variety of plants, flowers and trees to
encourage wildlife and biodiversity to the site. In terms of hard landscaping, variety
is also proposed to the hard landscaped areas with a mix of materials. New tree
planting is also proposed throughout the development. In respect of the planting
strategy, the Council’s Biodiversity Officer highlights that it is unclear from the
drawings what the SuDS feature is as the drawing shows a large retention style
basin but also has a wetland flower mix shown on the same area.  It is highlighted
that species would require to withstand both drought and submerged conditions.  A
recommendation from the Biodiversity Officer for Hawthorn specimens to be
included in the overall design which would be in keeping with the wider landscape
is also set out. The overall approach to open space provision and planting is
considered appropriate and the implementation and maintenance can be
addressed by condition together with the recommendations of the Council’s
Biodiversity Officer in respect of the planting schedule.  
7.15 Overall, the quality and range of open spaces will likely all contribute to the overall
success of the transformation of the now derelict site.
Traffic, parking and road safety
7.16 The applicant has submitted a Transport Statement in support of the proposal
which concludes that the development will integrate well with the surrounding
transport network and that resultant traffic impacts will not be significant. The
Transport Statement also includes a swept path analysis for the new development.
The Council’s Roads Service have no objections t with the conclusions.
7.17 In terms of pedestrian movements, the proposed layout and footpath connectivity
ensures that excellent pedestrian links are provided throughout the site and
beyond. Where pedestrian routes meet roads within the development, speed
tables are proposed at all internal junctions, street corners and central parts of the
longer North -South streets. The speed tables will act as a traffic calming measure
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to allow the continuous and uninterrupted movement for pedestrians traveling
through the site. The development also includes wider public footpaths connecting
it with Hawthornhill Road and Sunderland Avenue to allow these spaces to be
shared by pedestrians and cyclists.
7.18 In the consultation response, the Roads Service highlights the requirement for a
right turn lane to Cardross Road and this is now included in the proposal. The
response goes on to conclude that the development is well serviced by pedestrian
links and that the parking provision is appropriate. It is highlighted that the final
surfacing will be agreed with the Roads Service during the Roads Construction
Consent process. The existing pedestrian crossing will be relocated by
approximately 200 metres to accommodate the new access. This in turn will
require the relocation of the existing bus stop. These matters can be addressed by
condition. Whist the concerns raised in the objections are noted, the assessment
is guided by the advice in the consultation response from the Council’s Roads
Service. 
Transport, connectivity and permeability
7.19  The site is well served by public transport with bus stops adjacent to the site on
Cardross Road and Hawthornhill Avenue which provide for services to local
destinations, Helensburgh and Glasgow. Dalreoch railway station is also
accessible by foot, approximately a 10 minute walk from the site. Dumbarton Town
Centre is around a 20 minute walk from the site. 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. It is considered
appropriate for a travel information pack which encourages reduced dependency
on the private car by highlighting the location of local amenities, public transport
services and active travel routes to be provided to the residents of the new
dwellings. This can be addressed by condition. 
Flooding and drainage
7.20 With respect to flooding and drainage, the applicant has submitted a flood risk
assessment in support of the application. The application is below the threshold
for SEPA to be consulted and accordingly the assessment is guided by the advice
of the Council’s Roads Service. Following clarification from the applicant, the
Roads Service is content that there is no flood risk to the development or resulting
from the development and that drainage inclusive of SuDS can be satisfactorily
addressed. Maintenance of the SuDS can be addressed by condition. The
concerns raised in the representations regarding surface water are also noted and
a condition can also ensure surface water is intercepted within the site. 
Ecology
7.21 The ecological appraisal assists in proposing biodiversity friendly designs such as
use of native species and rich mixes thereof, protection of any bird nesting
activities during construction, welcome packs for new homeowners instructing how
they can increase biodiversity within the curtilage of their dwellings, hedgehog
holes in fencing, use of bat friendly lighting throughout the development, bat and
bird boxes that can be incorporated throughout the development as well as
demonstrating that all protected species specific concerns have been addressed
and that good practice with positive effects for biodiversity have been considered
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throughout the development. This will be addressed by condition. The Council’s
Biodiversity Officer also offers no objections to the proposal. 
Local service capacity and infrastructure provision 
7.22 Scottish Water were consulted but have not responded to indicate any objection
to the proposal. In terms of education provision the site is allocated within proposed
LDP2 as a residential development opportunity with an indicative capacity of 100
units.
Other matters raised in the consultation responses
7.23 The Council’s Environmental Health Service does not highlight any concerns over
and above the standard need for site investigation associated with any brownfield
site. This includes the requirement for a site investigation report inclusive of
remediation and mitigation measures. These matters alongside other matters
regarding dust mitigation and construction activity can be addressed as planning
conditions. 
Pre-application Consultation and Elected Member Briefing 
7.24 As the proposal constitutes a major development, statutory pre-application
consultation was carried out prior to the submission of the application. The
applicant has submitted a Pre-application Consultation Report setting out the
public engagement undertaken. The local Community Councils, MSPs and MPs
and Councillors were contacted about the proposal. A statutory notice was
published in the local press advertising the public event and submission of the
Proposal of Application Notice and additional consultation was undertaken by the
applicant.
8. CONCLUSION
8.1 The proposed redevelopment of this former school site   for 66 houses of 2 and 3
bedroom accommodation for sale is welcomed. The site is within an existing
residential area and, subject to the appropriate use of conditions, the proposed
development is acceptable.  The layout and design of the development has been
developed to ensure that it integrates with the existing residential form as well as
creating a high quality development which enhances the local residential area as
well as improvements to the footpath and greenspace networks. The development
will provide high quality housing with good connections to the surrounding area
and wider green network.
8.2 New housing developments within the immediate surroundings are transforming
the area and contributing to the longer term redevelopment/ regeneration of the
area and providing quality housing
8.3 The proposal will result in a high quality residential development and there are no
material considerations which suggest that planning permission should not be
granted.
9. CONDITIONS
1. Prior to the commencement of development on site, exact details, specifications
and samples of all proposed external materials to be used for the houses within
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the development 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 strict accordance with the
approved material details and palette.  
2. Further to condition 1 above, unless otherwise agreed in writing with the Planning
Authority, the brick type to be used for the elevation treatment of all houses within
the development site shall be of the ‘Forterra Victorian Mixture’ specification and
variety.
3. Further to Conditions 1 and 2 above, prior to the approved brickwork associated
with any house being constructed or installed on site, a sample panel of this
brickwork shall be constructed on site in order for it and the associated mortar to
be reviewed, inspected 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 brick
details.
4. The approved hard and soft landscaping and all associated approved planting
details shall be implemented within a timescale to be agreed prior to the
commencement of works on site with the Planning Authority.
5. Notwithstanding the approved  plans , an updated planting schedule to incorporate
Hawthorn planting and clarify the suitability of the planting within the SuDS area
shall be submitted to and approved in writing by the Planning Authority prior to the
commencement of  any works on site and shall be implemented with a timescale
to be agreed with the Planning Authority.
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. That full details of maintenance and management for the landscaping approved
shall be submitted to and approved in writing by the Planning Authority prior to the
start of construction of the development hereby permitted. Management and
maintenance shall commence upon completion of the landscaping.
8. That prior to each house hereby permitted being occupied, all new roads and
footways leading to it shall be surfaced to a sealed base course.
9. That within 4 weeks of the last of the houses hereby permitted being completed,
all roads and footways within the application site shall be completed to a final
wearing course.
10. That prior to the occupation of any house, the off-street parking provision shall be
completed and be available for use by residents of the associated house. The off-
street parking provision inclusive of garages where they part of this parking
provision shall be shall then remain unobstructed and available for use by
residents of the associated house at all times thereafter.
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11. No construction works except ground investigation works shall commence on site
until the existing pedestrian crossing on Cardross Road shall be relocated and be
fully operational in the new position.
12. No construction works shall commence on site until full details of the new position
of the existing bus stop on Cardross Road currently in the position of the relocated
pedestrian crossing shall be submitted to and approved in writing by the Planning
Authority in consultation with SPT with the relocation taking place and the bus stop
being available for use by services
13. That the approved drainage regime inclusive of the SuDS pond shall be fully
implemented. For the avoidance of doubt, the drainage regime shall be
implemented commensurately with the construction of the houses it serves.
14. 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 ty the Planning Authority prior to the commencement of any
works on site. The measures shall be implemented and maintained as approved.
15. No site clearance works shall be undertaken during the bird nesting season March
to September inclusive unless first agreed in writing by the Planning Authority. For
the avoidance of doubt, any such agreement will require a full nesting bird survey
prior to the commencement of works on site, the methodology and findings of
which shall be submitted to the Planning Authority
16. That prior to the commencement of any works on site, full details of the
incorporation of low or zero carbon generating 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.
17. Prior to the commencement of development with the site, details of the location
and design of  electric charging points/units and associated infrastructure and
ducting  to serve the development shall be submitted to and approved in writing by
the Planning Authority. The approved car charging points/units/ducting and
associated infrastructure shall thereafter be installed in accordance with the
approved details at a timescale agreed by the Planning Authority and maintained
at all times thereafter.
18. Prior to the occupation of the first house within the site, the developer shall install
the necessary infrastructure to enable the full development and all associated
properties to be connected to the existing fibre optic network, where available in
West Dunbartonshire, and in accordance with the relevant telecommunications
provider’s standards.
19. Details of the provision of grit bins for the development shall be submitted to and
approved in writing by the Planning Authority. The agreed details shall be in place
prior the occupation of the first house within the site and thereafter maintained for
the lifetime of the development.
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20. Prior to the commencement of works on site, details of any street furniture shall be
submitted to and approved in writing by the Planning Authority and shall be
implemented within an agreed timescale.
21. No house shall be occupied until the contents of a Travel Information Pack which
encourages reduced dependency on the private car by highlighting the location of
local amenities, public transport services and active travel routes is submitted to
and approved in writing by the Planning Authority. Thereafter, on the occupation
of each dwelling, the approved Travel Information Pack shall be provided to new
residents.
22. No development (other than investigative work) can take place until such time as
a comprehensive site investigation has been carried out to the appropriate Phase
level and submitted to and approved in writing by the Planning Authority. The
investigation shall be completed by a suitably qualified and competent person and
completed in accordance with advice given in the following:
• Planning Advice Note 33 (2000) and Part IIA of the Environmental
Protection
• Act 1990 (as inserted by section 57 of the Environment Act 1995)
• BS 10175:2011+A1:2013 – British Standards institution ‘The Investigation
of Potentially Contaminated Sites – Code of Practice’.
• Land Contamination and Development Management -Guidance.
https://www.epscotland.org.uk/wp[1]content/uploads/2019/09/ConLanDev
Guide_12-Aug19-FINAL.pdf
23. If the Phase 1 investigation indicates any potential pollution linkages, a Conceptual
Site Model must be formulated and these linkages must be subjected to risk
assessment. If a Phase 2 investigation is required, then a risk assessment of all
relevant pollution linkages will require to be submitted.
24. If the risk assessment identifies any unacceptable risks then an appraisal of
remedial options followed by a detailed remediation scheme will be submitted to
and approved in writing by the Planning Authority. No works other than
investigative works shall be carried out on site prior to receipt of the Planning
Authority’s written approval of the remediation scheme.
25. 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.
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26. The approved remediation scheme shall be carried out in accordance with its terms
prior to the commencement of development other than that required to carry out
remediation, unless otherwise agreed in writing by the Planning Authority. The
Planning Authority shall be notified in writing of the intended commencement of
remediation works not less than 14 days before these works commence on site.
27. Upon completion of the remediation works and prior to the site being occupied, a
verification report which demonstrates the effectiveness of the completed
remediation works shall be submitted to and approved in writing by the Local
Planning Authority.
28. 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.
29. 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.
30. 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.
31. No development shall commence on site until such time as a noise control method
statement for the construction period has been submitted to and approved in
writing by the Planning Authority. This statement shall identify likely sources of
noise (including specific noisy operations and items of plant/machinery), the
anticipated duration of any particularly noisy phases of the construction works, and
details of the proposed means of limiting the impact of these noise-sensitive
properties. The construction works shall thereafter be carried out in accordance
with the approved method statement unless otherwise approved in writing by the
Planning Authority.
32. 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
33. 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
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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.
34. No commercial vehicle making deliveries to or collecting material from the
development shall enter or leave the site before 0800 or after 1800.
35. 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.
36. Notwithstanding condition 36 above, full details of the design, height and location
of an acoustic fence adjacent the sports pitch shall be submitted to and approved
in writing by the Planning Authority. The fence shall then be erected prior to the
occupation of any dwellinghouse on plots 32 to 44 inclusive.
37. No development shall commence on site until details for the storage and the
collection of waste arising from the development and the location of grit bins shall
be submitted to and approved in writing by the Planning Authority. The agreed
details shall be in place prior the occupation of the first housing unit/property within
the site and thereafter maintained for the lifetime of the development.
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Pamela Clifford 
Planning, Building Standards and Environmental Health Manager 
Date: 12th October 2022  
______________________________________________________________
Person to Contact: Pamela Clifford, Planning, Building Standards and
Environmental Health Manager  
Email: Pamela.Clifford@west-dunbarton.gov.uk
Appendix: Location Plan
Background Papers: 1. Application documents and plans
2. Clydeplan Strategic Development Plan 2017
3. West Dunbartonshire Local Plan 2010
4. West Dunbartonshire LDP - Proposed Plan 2
5. ‘Our Green Network’ Guidance
6. Residential Development Design Guidance
7. Scottish Planning Policy 2014
8. Designing Streets
9. Consultation responses
10. Representations
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¯
Reproduced by permission of Ordnance Survey on behalf of HMSO. (C) Crown copyright and database right 01/02/2024.
All rights reserved. West Dunbartonshire OS Licence Number 100020790.
Scale: 1:2,500@A401/02/2024
DC22/072/FUL - MapWest Dunbartonshire
Council
16 Church Street
Dumbarton
G82 1QL
ITEM 6f - APPENDIX  2
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager
Planning Committee: 14th February 2024
Subject: Clydebank Business Park Planning Guidance
1 Purpose
1.1 The purpose of the report is to seek approval of the finalised version of Planning
Guidance relating to Clydebank Business Park for use in making planning
decisions.
2. Recommendations
2.1 It is recommended that the Committee approves the finalised version of
Clydebank Business Park Planning Guidance contained in Appendix 1.
3. Background
3.1 The purpose of planning guidance is to add more detail to the content of policies
in the Local Development Plan. While primarily a location for business,
industrial, and storage and distribution uses, there is interest from a diverse
range of business types to locate within the Clydebank Business Park. Planning
applications and enquiries have been received for the change of use of existing
premises to uses such as nurseries, soft play, gymnasiums, and dog grooming
and training premises. The guidance aims to strike a balance between allowing
a diverse range of business within the business park, while ensuring these
alternative uses do not interfere with the operation of existing businesses and
that the area remains primarily a location for industry, business, and storage
and distribution.
4. Main Issues
4.1 The Planning Committee approved a draft of the guidance for consultation at
the meeting on 2nd August 2023. Consultation took place from 22nd September
to 22nd December 2023.
A final version of the guidance, with changes reflecting the comments received
in Appendix 1.
4.2 The guidance details the criteria to be used in assessing planning applications
for alternative uses, as well as informing businesses considering locating within
Clydebank Business Park.
4.3 The consultation received seven representations, all from owners, managers or
representatives of businesses within the business park. These representations
ITEM 7
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and the council response to these questions are set out in Appendix 2.
4.4 All representations agreed with the definition for alternative uses set out in the
guidance. One respondent was concerned that introducing uses that would lead
to more people in the business park in the evening may affect security. Two
responses queried the need for a specific area for alternative uses for the
following reasons: a business may want to locate within the business park for
their specific needs; businesses outside the area would be denied “drop by
visitors”; it is important to full vacant units and provide employment; and the
business park has good access to public transport. 
4.5 One respondent stated the criteria for deciding applications was much improved
since they went through the planning process. One respondent suggested that
increased footfall should be included in the criteria for deciding planning
applications and whether the business has parking needs. One respondent was
concerned about the proliferation of “motor trade” uses, particularly impact on
the appearance of the business park from visible scrap and cars.
4.6 Changes made to the draft guidance are shown as italicised and underlined text
Appendix 1. The text of the guidance has been amended to clarify that
businesses outside of the defined area for alternative uses can still have other
ancillary uses for “drop by” visitors, provided their primary activity falls into
business, industrial, or storage and distribution uses and that the ancillary use
will not attract significant footfall.
4.7 It is still considered appropriate for the guidance to define an area for alternative
uses in order to direct uses that attract footfall to locations adjacent to the town
centre, closest to public transport, and ensure that the business park remains
primarily for business, industry, and storage and distribution. 
4.8 Some issues raised in representations are already covered by the guidance.
The guidance acknowledges that some alternative uses have specific needs,
making the business park the most appropriate location for them. Parking needs
are acknowledged by the guidance.
Next steps
4.9 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 Clydebank Business Park Guidance (2017).
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
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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 the guidance
sets out the Councils approach to balancing the operations of, and need for
available space for business, industry, and storage and distribution uses, while
allowing for flexibility and maintaining a well occupied business park.
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 3.
8.2 As part of managing different types of uses in Clydebank Business Park, child
oriented uses have been restricted. The effect of this will be the reduced conflict
with these uses and the primary users of Clydebank Business Park. The
guidance strikes a balance between the enabling some child oriented uses
within the business park and preventing conflict with existing business and
industrial uses. The guidance will note that accessibility for those with
disabilities is important thus helping to ensure a shared understanding of
considerations.
8.3 The guidance does not support any kind of residential or accommodation use
within the business park. This should have a positive impact on health, as the
business and industrial nature of the main occupiers of the business park could
harm the amenity of residents.
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 Consultation has been undertaken on the draft Planning  Guidance documents
as set out in paragraph 4.1.
11. Strategic Assessment
11.1 The Clydebank Business Park Planning Guidance will support the
Council’s strategic priorities of ‘Our Economy – Strong and Flourishing’.
Pamela Clifford
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Planning, Building Standards and Environmental Health Manager 
14th February 2024
________________________________________________________________
Person to Contact:    
Pamela Clifford, Planning, Building
Standards and Environmental Health Manager
Pamela.Clifford@west-dunbarton.gov.uk
Cameron Clow, Development Planning & Place Officer
cameron.clow@west-dunbarton.gov.uk
Appendices:
Background Papers:
Wards Affected:
Appendix 1 – Draft Clydebank Business Park Planning
Guidance
Appendix 2 - Consultation Results
Appendix 3 – Equalities Impact Assessment
None
Ward 5: Clydebank Central
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Clydebank Business Park Planning Guidance
1
1. Introduction
Clydebank Business Park is an area designated primarily for business, general
industry, and storage and distribution uses, however the Council has and continues
to receive interest from more diverse range of uses to locate within Clydebank
Business Park. Planning applications and enquiries have been received for the
change of use of existing premises to uses such as nurseries, soft play,
gymnasiums, and dog grooming and training premises. This has raised issues about
whether these are suitable uses to locate within a business/industrial area in terms of
their impact on existing uses and the impact on the availability of property for
industrial and business uses.
This document offers additional guidance on how the Council’s Local Development
Plan (LDP2, as modified 2020) should be applied when considering proposals for
such uses. It will assist the Council in determining applications and will also provide
greater certainty to potential applicants. It also takes account of the Fourth National
Planning Framework (NPF4).
2. Alternative Uses: Defining the Issue
This Guidance uses the term ‘industrial/business uses’ to refer to the following uses
from the Town and Country Planning (Use Classes) (Scotland) Order 1997:
Use Class 4 – Business
Use Class 5 – General Industry
Use Class 6 – Storage and Distribution
This guidance uses the term ‘residential/accommodation uses’ to refer to:
Use Class 7- Hotels and Hostels
Use Class 8 & 8A - Residential Institutions and Secure Residential Institutions, e.g.
nursing home, hospital, prison
Use Class 9 – Houses
Sui Generis flats and student accommodation
All other uses will be referred to as ‘alternative employment uses’.
3. Clydebank Business Park
Clydebank Business Park was built on part of the site of the former Singer Sewing
Machine factory which closed in 1980. The site was identified as an Enterprise Zone
in 1981 and the Business Park developed to provide industrial and business
accommodation.
It is located centrally within Clydebank, adjacent to the town centre and Clyde
Shopping Centre. It is easily accessible by public transport with Singer rail station
sitting immediately adjacent to the north, and Clydebank rail station within walking
distance to the south. A frequent bus service runs along Kilbowie Road at the
ITEM 7 - APPENDIX 1
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Clydebank Business Park Planning Guidance
2
eastern entrance to the Business Park, with more services available within walking
distance from locations within the town centre.
Road access is also good with Kilbowie Road linking to the A82 and A814 which
provide access to the rest of Clydebank and the West Dunbartonshire area, Glasgow
City Centre and via the Erskine Bridge and Clyde Tunnel to the wider trunk road
network. 
Map 1 Clydebank Business Park location and transport links
The Business Park is predominantly occupied by Business (Use Class 4), General
Industry (Use Class 5) and Storage and Distribution (Use Class 6) uses. Business
types range from small local businesses to national and international organisations
such as the Clydesdale Bank and Northern Marine. Business units range in size from
under 100sq.m up to 8,000 sq.m.
The Business Park is in multiple ownership, with business units and common areas
in different private ownerships. The Council does not own or manage property within
the Business Park.
4. Policy context
Policy 26 of NPF4 describes the type of development that is acceptable in on land
allocated for business and industry uses. Part c) of the policy states: “Development
proposals for business and industry uses will be supported where they are
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compatible with the primary business function of the area. Other employment uses
will be supported where they will not prejudice the primary function of the area and
are compatible with the business/industrial character of the area.” 
Policy E1 of LDP2 designates the Business Park as an existing business and
industrial area and directs development in Use Class 4, 5 and 6 to these areas.
Policy E2 is intended to manage the level and type of alternative employment uses
within business and industrial areas. Proposals for alternative uses will be assessed
with regard to the following criteria in E2:
a) There is no adverse impact on the operation of existing uses or the
potential for future business, industrial or employment use within the area;
b) The proposal protects and enhances the attractiveness of the area as an
industrial and business location;
c) The proposal is ancillary to the industrial and business uses;
d) There is no unacceptable detrimental impact on the availability of
employment land; and
e) The economic benefit that the proposal can bring to the area is
demonstrated.
Policy 27 of NPF4 also identifies town centres as the preferred location for uses
attracting significant number of people including retail and commercial leisure,
offices, and community, sport, cultural facilities and public buildings. 
Policy SC1 of LDP2 (and the accompanying Table 4) states that town centres are
the preferred location for new leisure uses. The Plan’s strategy for Clydebank town
centre includes support for strengthening and diversifying the town centres role as a
hub for retail, leisure, cultural, civic, and office uses.
5. Current situation
Alternative uses
The predominant existing uses within the Business Park are industrial and business
(Use Classes 4/5/6). However a number of non-industrial/business uses have been
established including a café, dog care/training service, sport/fitness uses, children’s
nursery and a soft play centre.  Table 1 and Map 2 show the number and spread of
these non-industrial uses.
Table 1 Breakdown of alternative uses
Use Count of
Premises
Percentage
of
premises
1A – Shops and
professional services 5 4%
3 - Food and Drink 1 1%
4 - Business 70 59%
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Use Count of
Premises
Percentage
of
premises
5 - General Industry 9 8%
6 - Storage and
Distribution 2 2%
8 - Residential
Institutions 1 1%
10 - Non-residential
Institutions 1 1%
11 - Assembly and
Leisure 7 6%
Sui Generis 9 8%
Vacant 14 12%
Total 118
Of the nine sui generis uses, four are dog grooming or dog day care businesses, two
are vehicle hire, one is a taxi office, one is the ambulance depot, and one is a car
storage and appointment only showroom. 
Map 2 Use Classes in Clydebank Business Park
Unit sizes and vacancies
There are a range of different unit types and sizes in the Business Park. Table 2
identifies the number of units available within different size bands. Vacancies exist in
greatest number and at the highest rate in the 150-250 sq.m size band and the
highest vacancy rate is within the 250 – 800sq.m size band. Vacancies exist in all
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the other size bands but in less number and not as high a rate. Vacancies are
spread throughout the business park
Table 2 Breakdown of unit sizes (February 2023)
Size band
(sq.m)
No of
units
Vacant
unit
Vacancy
rate
<150 22 3 14%
150 - 250 42 5 12%
250 - 800 18 4 22%
800 - 1500 16 1 6%
>1500 20 1 5%
Total 118 14 12%
Floorspace information was unavailable for four units. When compared to the floor
space of similar size, three of these buildings likely exceed 1000 square meters and
one most likely falls within the 100 – 499 square meter size bracket. Additionally,
office buildings that are subdivided into different floor space areas which are then let
are counted as one premises. They are counted as occupied here, but there was
some vacant floor space during the survey, evidenced by advertisements for office
space available to let.
Overall there is a higher level of occupancy in the business park in 2023 than the
previous survey in 2016. 
6. Research
Survey of Business Park businesses
The Council undertook a survey of Clydebank Business Park businesses in April
2023, to update the previous survey undertaken in September 2016. This involved
an online questionnaire, with a letter delivered to all businesses in the business park
advising of its availability and purpose. Responses were received from seven
businesses and four employees. The survey results provide information on the
attitude of existing Clydebank Business Park businesses towards alternative uses
and vacancies within the Business Park. Full details of the survey and the results are
set out in Appendix 1 – Online Questionnaire for Clydebank Business Park. Some
headline findings are included below. These results were also compared to previous
survey results to indicate any changes in attitude towards alternative employment
uses.
Alternative uses
• Overall, alternative uses were generally seen to provide convenient services for
businesses and employees, with the exception of residential, which was not
seen to provide useful services to the business park. Hotels had a mixed
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response to this question, with most respondents being neutral on them, and
roughly even positive and negative responses.
• Alternative uses were generally not seen to detract from the character of the
business park. Residential and hotels received a more mixed response to this
question, with responses to residential uses leaning towards that they would
detract from the character.
• There was general agreement that alternative uses helped fill vacant units.
• There were some mixed views on whether alternative uses caused traffic
conflicts, but generally that they did not was the most common response. The
exceptions to this were hotels, retail and residential, where more respondents
strongly agreed that they did cause traffic conflicts with existing businesses.
• There were mixed views as to whether there were other operational conflicts
cause by alternative uses. Overall it was generally considered that child related
uses did not cause conflict, but this was not unanimous. Opinions on hotels, pet
grooming and day care, and residential were split roughly evenly, both in favour
and against.
• It was generally agreed that alternative uses contributed to a lively and active
business park, with the exception of hotels and residential which received more
mixed views.
Vacancies
• The majority of respondents agreed or strongly agreed that vacant units detract
from the character of the business park, attract anti-social behaviour and
vandalism and present a negative image to customers and clients.
Other Issues
• On street parking is causing difficulty for other road traffic.
• There was a request for businesses to have industrial bins
Conclusions from survey
The survey indicates a majority opinion within existing businesses in favour of
alternative employment uses within the Business Park and support for vacancies to
be addressed. There are concerns around on-road parking within the Business Park,
although this is not specifically connected to alternative uses.
Accessibility
NPF4 and LDP2 require development proposals to demonstrate they are accessible
by active travel and public transport. Map 3 shows the majority of the Business Park
is within 800 metres (approximately 10 minutes walk) of nearby train stations
(Singer, which is immediately adjacent, Clydebank, and Dalmuir stations) and that
there are numerous bus stops on the surrounding roads and streets, including at the
main entrance on Kilbowie Road.  
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Map 3 Accessibility to public transport
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7. Application of NPF4 Policies and Local Development Plan Policy
E2 criteria
Alternative employment uses will be supported in the area from the eastern entrance
to the business park up to Symington Drive, as shown on Map 4. The reasons for
this are: 
• to ensure the business park is primarily for meeting the demand for use
classes 4, 5, and 6, aligning with NPF4 Policy 26 and LDP2 Policy E2;
• the area is adjacent to the Town Centre and so the next sequentially preferred
location if there are not suitable premises in the Town Centre or Commercial
Centres for the proposed use, following NPF4 Policy 27;
• the area is within easy walking distance of public transport, encouraging
sustainable access, following NPF4 Policy 13;
Further details on application of each of these policies, and possible exceptions are
described below. Figure 1 contains a flow chart to provide an overview of how the
council will assess if an alternative use may or may not be supported, but other
considerations may be material. 
Map 4 Area identified for the location of non-industrial/business uses
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NPF4 Policy 26
The primary use of Clydebank Business Park is industry and business. Alternative
uses will need to demonstrate that they are compatible with existing business and
industrial uses in the business park. The council will use the criteria in Policy E2 of
LDP2 in order to determine compatibility.
NPF4 Policy 27
Taking the town centre first approach, Clydebank town centre is the preferred
location for town centre uses (as defined in the development plan) that attract
significant footfall, followed by Clyde Retail Park and Kilbowie Retail Park. Where
relevant, applicants for alternative employment uses within the Business Park should
demonstrate through a Town Centre First Assessment that they have considered
available premises within Clydebank town centre and retail parks. 
In some circumstances it is accepted that premises within Clydebank town centre
and its commercial centres may not be suitable for alternative uses, and cognisance
will be given to the operational requirements of the proposed use with regard to
physical requirements and hours of operation that may not make it suitable for a
town/commercial centre location.
LDP2 Policy E2
a. Will there be adverse impacts on the operation of existing uses or the
potential for future business, industrial or employment use within the area?
The Council shares the view of the majority of respondents that alternative
employment uses have limited impact on the operations of existing businesses. 
Therefore, where an application is within the area outlined in map 4, and meets the
other considerations set out in this guidance, only where there is clear evidence that
there would be an adverse impact on an existing industrial/business use, would an
alternative use be refused. However, the Council does have concerns about the
safety of users of alternative employment uses within industrial/business areas,
particularly of child-focused uses, and survey evidence suggests that there is a
general concern with regards to parking in the Business Park, particularly on-road
parking. Therefore the safety of the staff and customers of proposed alternative uses
will be a consideration, as will the impact on the operations and safety of staff and
customers of adjacent businesses.
Proposals should prioritise, sustainable travel, with suitable, safe walking route to the
unit from public transport stops demonstrated. This includes ensuring accessibility
for people with disabilities.
Any traffic impacts and parking requirements should be discussed and agreed with
the Council. Consideration will be given to the need for parking in close proximity to
the unit to avoid traffic conflict. Where parking areas are shared with other uses,
different hours of operation will be a consideration.
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The survey showed the number of dog care, grooming, and training premises within
the park has increased. Further proposals for these or similar uses will be required to
demonstrate how animals will be kept securely and that any outdoor space
dedicated to animals will adjoined and accessed through the unit occupied by the
business.
The impact from the overall level of alternative employment uses within the business
park on the operation, suitability of existing industrial and business uses will be a
consideration. The primary purpose of this Business Park for industrial/business use
will remain
The council will not support residential/accommodation uses in the business park as
this would not conform to the character of the business park.  The operation of
existing buildings would likely conflict with residential/accommodation amenity.
b. will the proposal protect and enhance the attractiveness of the area as an
industrial or business location?
The evidence does not suggest alternative employment uses have a detrimental
impact on the suitability of an area’s future for industrial/business development and
that filling vacant units has a positive effect on the attractiveness of the business
park. However, a consideration will be the impact of any particular alternative use, or
cluster of alternative uses on the quality and character of the Business Park.
c. Is the proposal ancillary to the industrial and business use of the area?
Alternative employment uses that are primarily aimed at servicing businesses or
employees operating and working within the business park will be considered
favourably.  In particular, retail (and other class 1A uses) and food and drink uses
should not exceed 250sq.m.
Uses ancillary to a business that is primarily use class 4, 5, or 6 outside of the area
defined on Map 4 may be acceptable, provided that the main activity of the business
falls within use classes 4, 5, or 6. The applicant must demonstrate that this ancillary
uses will not attract a significant level of footfall.
d. Will there be a detrimental impact on the availability of employment land?
The Council will seek to retain a supply of units for Use Class 4, 5 and 6 uses in
preference to other uses. Therefore, the Council will not support an alternative use in
any unit that would result in there being no vacant units remaining in any of the size
bands identified in Table 2.
e. Is the economic benefit the proposal will bring to the area demonstrable?
There is a strong preference for vacant units to be occupied as they detract from the
character of the Business Park. Therefore the occupation of a vacant unit by an
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alternative employment use will be viewed positively within the area defined in Map 4
for these uses and where they meet other relevant policy criteria.
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Figure 1 Flow chart indicating if a proposed alternative use may be appropriate.
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Appendix 1 – Online Questionnaire for Clydebank Business Park 
The purpose of this survey was to gain the views of business managers, owners and
employees within the business park regarding non-business, industry, and storage
and distribution uses within the business park.
The survey was distributed in April 2023 with respondents given a month to reply to
each business in the park. Letters explaining the purpose of the survey, with a link
and QR code to the survey were delivered to businesses. Where possible they were
handed directly to a manager or employee of the business. Where this was not
possible it was posted through the door or into a mail box. 
Where applicable responses were compared to the previous survey, which was part
of preparing the original 2017 guidance. It should be noted that the previous survey
did not ask questions on pet grooming and day care services, retail uses, or
residential uses, so any comparison does not refer to these uses.
Definitions
• Adults Sports/ fitness – Use class 11 premises focussed adult fitness, such as
gyms and personal training
• Child fitness/sports – Use class 11 premises focussed on activities and fitness
for children, such as dance studios, and gymnastics
• Child focused leisure – Use class 11 premises focussed on leisure for
children, such as soft play.
• Child care/education – Use class 10 for child care, such as crèche and
nurseries.
• Food and Drink – Use class 3 and Sui Generis hot food takeaways.
• Hotels – Use class 7.
• Retail – Use class 1
• Pet grooming/ day care Residential – premises for pet grooming and day
care services
• Residential – residential uses, including institutions such as care homes and
student accommodation.
Number and Type of Respondents
There were a total of 11 respondents to the survey. Respondents were asked if they
were responding on behalf of a business or as an employee. Seven responses were
on behalf of a business as the manager or owner which represents a 4% response
rate from businesses. The remaining four responses were from people who identified
as employees.
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Alternative uses provide convenient services for businesses and employees
The majority of respondents either agreed or strongly agreed that sports and fitness
(for adults and children), child focussed leisure, child care and education, and food
and drink provided convenient services to the businesses and employees. For hotels
the largest response was neutral, and overall there was slightly more disagreement
than agreement that they provided a convenient service. Retail was generally
considered to provide a convenient service, as was pet grooming and day care.
Residential had the strongest negative response of all the listed uses, with only one
respondent strongly agreeing they provide a convenient service and four giving a
neutral response.
When compared to the previous survey results were similar for adult fitness, child
care and food and drink, however there were more neutral or negative responses to
these uses in this survey. Responses were more mixed towards hotels in this survey
than the previous survey were responses were in agreement or neutral.
0
1
2
3
4
5
6
7
Do you Agree or disagree that the following uses provide
convenient services for business and employees
Strongly agree Agree Neutral Disagree Strongly disagree
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Alternative uses affect the character of the business park
Adult fitness, child fitness, child leisure, child care, and food and drink all had the
same responses to this question. More respondents disagreed or strongly disagreed
that these uses detracted from the character of the business park than agreed or
strongly agreed. Hotels received a mixed response to this question; the largest
number of responses were neutral, and slightly more agreed or strongly agreed that
hotels detract from the character of the park than agreed or disagreed. Retail
received a mixed response, with only one more responded disagreeing or strongly
disagreeing that retail detracts from the character of the business park than agreeing
or strongly agreeing. The response to pet grooming and day care was generally
more positive than negative. 
Overall the results of this and the previous survey disagreed that adult fitness, child
fitness, child leisure, child care and food and drink detracted from the character of
the business park. However there was more, responses in agreement that they did
detract than the previous survey. In this survey more respondents strongly disagreed
than in the previous. The view on hotels is more mixed than in the previous survey,
with more agreement or strong agreement that they detracted from the character of
the business park.
0
1
2
3
4
5
Do you agree or disagee that the following businesses
detract from the character of the business park
Strongly agree Agree Neutral Disagree Strongly disagree
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Alternative Uses and Vacancies
There was general agreement that alternative uses helped to fill vacancies within the
business park, with a small number of answers being neutral, disagreeing, or
strongly disagreeing. The exception to this was residential which had a more mixed
response, but was slightly weighted towards agreement. 
The previous survey was also in agreement that alternative uses help fill vacancies.
0
1
2
3
4
5
6
7
8
Do you agree or disagree that the following uses help to
fill vacancies
Strongly agree Agree Neutral Disagree Strongly disagree
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Alternative uses and traffic conflicts
Adult fitness, child fitness, child leisure, child care, and food and drink all had similar
responses to this question; “disagree” was the most common answer among all
these uses, however some responses did agree or strongly agree that these uses
created traffic conflict. Residential and Hotels had the largest “strongly agree”
responses, respectively, and this was the most common response for these uses,
however this was followed by “disagree” in most cases. Retail had a mixed
response, however more respondents agreed or strongly agreed than disagreed or
agreed. Pet grooming and day care had a very mixed response, but the most
common response was “disagree”.
Where applicable, responses from the previous survey are comparable to responses
to this survey. Hotels are an exception to this, which received more responses in
strong agreement than previously.
0
1
2
3
4
5
6
Do you agree or disagree that the following uses create
traffic conflicts with the operations of existing businesses
Strongly agree Agree Neutral Disagree Strongly disagree
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Alternative uses and operational conflicts
Overall, respondents disagreed, strongly disagreed, or were neutral that child fitness,
child leisure, child care, and retail uses did not create operational conflicts or
responded neutrally for these uses. Other uses received more mixed results. Adult
sports and fitness, and food and drink were considered by more respondents to
cause operational conflicts than those uses listed above, but more views stated they
disagreed or strongly disagreed they created conflict than did agree or strongly
agree. Opinions on hotels, pet grooming and day care, and residential were split
roughly evenly.
In the previous survey there was general disagreement that alternative uses cause
other operational conflicts with existing businesses. Disagree was still the most
common response in this survey, the response overall was more mixed, particularly
with adult fitness and food and drink.
0
1
2
3
4
5
6
Do you agree or disagree that the following uses may
create other conflicts with the operation of existing uses.
Strongly agree Agree Neutral Disagree Strongly disagree
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Alternative uses and contributing to a lively business park
The majority of responses either agreed or strongly agreed that other uses
contributed to a lively and active business park. The exceptions to this was hotels
and residential. For hotels more respondents had a neutral response or disagreed,
though there was still some agreement that hotels contributed to an active and lively
business park. Residential received a mixed response, with the most common
response being neutral and an equal number of responses that agreed, strongly
agreed, disagreed or strongly disagreed.
This generally aligns with responses from the previous survey, however there was
some more disagree or strongly disagree responses than in the previous surveys.
0
1
2
3
4
5
6
7
8
Do you agree or disagree that the following uses contribute
to an active and lively business park
Strongly agree Agree Neutral Disagree Strongly disagree
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Vacant Units
Respondents generally agreed that vacant units detracted from the character of the
business park, vacant units attract anti-social behaviour and vandalism, and present
a negative image to customers and clients. Respondents generally disagreed that
they make no difference to the operations of the business park. There were mixed
views, but general disagreement that vacant units always ensure there are units
available for new businesses to locate.
This survey generally aligns with the previous survey.
0
1
2
3
4
5
6
They detract
from the
character of the
business park
They ensure that
there are always
units available for
new businesses
to locate
They attract anti-
social behaviour
and vandalism
They present a
negative image to
customers and
clients
They make no
difference to
operations of
existing
businesses
Do you agree or disagree with the following
statements about vacant units
Strongly agree Agree Neutral Disagree Strongly disagree
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Concern about non-industrial business uses
Most respondents were not very concerned about non-industrial uses in the business
park. Two respondents were quite concerned and three were not at all concerned. 
A larger proportion of respondents selected “not very concerned” compared to the
previous survey, with a small proportion of respondents being quite concerned or not
at all concerned. 
Other uses in the business park you would like to see
Respondents were asked if there are any other uses in the business park they would
like to see. There were three responses suggesting the following uses:
• Trade stores, e.g. Screwfix
• More food uses
• Hair dresser or nail technician
Other Comments
When asked if they had any other comments on non-industrial uses in the business
park the following responses were received:
• Could we have industrial bins
• I think any business that attract people into the Business Park is good and
also feel landlords should be doing all they can to ensure units remain in use
and that might mean assistance from the Council to keep rent and service
charges affordable while ensuring all roads are in a satisfactory condition
which is not the case withing the Business Park at the moment.
• In 2016 we moved into the business park by the skin of our teeth after very
strong opposition from some councillors. 7 years later (even after the
pandemic and being forced to close for 15 months) we are still here
welcoming families,  Employing 23 members of staff and contributing to the
local community/economy in many small ways. I don’t see any reason to
0
1
2
3
4
5
6
7
Quite Concerned Not Very Concerned Not concerned at all
To what extent are you concerned about the
existing level of non-industrial business uses in
Clydebank Business Park
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leave units empty when they could be filled with thriving business’s? I’d like to
thank those councillors who had the foresight to have faith in us. 
• We (UK) are moving to, or have moved to years ago, service led businesses.
Manufacturing et al is no longer congruent or pivotal with a modern growing
economy..
• You just have to look outside any school / nursery or even local activities
centres at start finish times to see the chaos brought to any area by
inconsiderate and often dangerous parking and blocking of lanes, Some of the
parking at weekends with the 1 current play centre is bad enough
• Parking  lighting and safety are concerns.
• Traffic and parking is ready a nightmare
Key Points from Survey
• Overall, alternative uses were generally seen to provide convenient services
for businesses and employees, with the exception of residential, which was
not seen to. Hotels had a mixed response to this question.
• Alternative uses were generally not seen to detract from the character of the
business park. Residential and hotels received a more mixed response to this
question, with responses to residential uses leaning towards that they would
detract from the character.
• There was general agreement that alternative uses helped fill vacant units.
• There were some mixed views on whether alternative uses caused traffic
conflicts, but generally that they did not was the most common response. The
exceptions to this were hotels, retail and residential, where more respondents
strongly agreed that they did cause traffic conflicts with existing businesses.
• There were also mixed views as to whether there were other operational
conflicts cause by alternative uses. Overall it was generally considered that
child related uses did not cause conflict, but this was not unanimous. Opinions
on hotels, pet grooming and day care, and residential were split roughly
evenly.
• It was generally agreed that alternative uses contributed to a lively and active
business park, with the exception of hotels and residential which received
more mixed views.
• Overall it was felt that the presence of vacant units had a detrimental effect on
the business park.
• There is some concern as to the number of alternative uses within the
business park.
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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
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Clydebank Business Park Draft Guidance Consultation Results
Consultation on the draft planning guidance took place over 12 weeks between the 22nd 
September and 22nd  December 2023. The consultation was undertaken through the online
platform Survey 123 and was mainly targeted at businesses within the business park area.
Businesses within the park were contacted by letter that the consultation was taking place,
and the consultation was also promoted using the council’s social media. Letters were sent
to 161 addresses in the park.
The consultation received a total of seven responses. The survey consisted of four yes or no
questions, asking respondents whether they agree with specific elements of the guidance.
Respondents were also asked to provide comments should they wish to provide additional
detail. The council has responded to each of these comments.
Which category applies to you?
Six of the seven respondents were a
business manager or owner, with one
representing a business or other
organisation.
6
1
A business owner or manager
Representing a business or other organisation
ITEM 7 - APPENDIX 2
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Appendix 2
Are the definitions of different uses in section two of the guidance
appropriate?
The guidance uses the term
‘industrial/business uses’ to refer to the
following uses from the Town and
Country Planning (Use Classes)
(Scotland) Order 1997:
• Use Class 4 – Business
• Use Class 5 – General Industry
• Use Class 6 – Storage and
Distribution
The guidance uses the term ‘residential/accommodation uses’ to refer to:
• Use Class 7- Hotels and Hostels
• Use Class 8 & 8A - Residential Institutions and Secure Residential Institutions, e.g.
nursing home, hospital, prison
• Use Class 9 – Houses
• Sui Generis flats and student accommodation
All other uses will be referred to as ‘alternative employment uses’.
All respondents agreed with the definitions given in section two of the guidance.
Proposed changes as a result of responses to this question
No proposed changes to this section of the guidance as a result of responses to this
question.
7
0
Yes No
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Appendix 2
Is the area identified in Map 4 the appropriate location for non-business,
industrial and storage and distribution uses within the business park?
Four respondents considered that the
area defined on Map 4 was the
appropriate area to locate non-
business, industrial, and storage and
distribution uses. 
Three respondents said the area was
not appropriate.
If no, where is it appropriate for non-business, industrial, and storage and distribution
to be located? 
Of the three respondents that said no, two considered that there should be no such
restriction on the location of businesses and prioritise filling vacant premises and providing
employment opportunities. One respondent said that changing the planning status of the
park would not bring a positive impact, in particular highlighting concerns around safety and
security that increased footfall may bring to the area.
There is a conflict within these responses, between respondents wanting to attract visitors
into the park and respondents cautious about doing so for reasons of security. 
Respondent 1
“The key element for us locating our business in the located was largely in part due
to the current planning status of this area, we do no think that any change to that will
bring postive benefits and may become a factor in us looking to relocate away. 
Also this area is relatively secure for businesses you would be looking to introduce a
transient population to an area that in the evening is sparsely populated and can
impact on the security of these businesses.”
West Dunbartonshire Council response
The council intends for the main uses of the business park to be business, industrial, and
storage and distribution and the criteria for determining planning applications has been
designed with this in mind. It is not intended that the guidance would encourage increased
activity in the evening. Issues of safety and security can be considered when deciding if an
application is compatible with the industrial and business use of the area. 
Respondent 4
“There should be no defined area for this.  Businesses within the Business Park are
denied the opportunity to have 'drop by' visitors if only one part is used for non-
business activities.  People not familiar with the Business Park may not be aware (I
work in the Business Park and I am not aware) of all the businesses within the Park
4
3
Yes No
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Appendix 2
and what services I could use locally.  Empty space should be utilised by all types of
companies especially if they contribute to employment of local people.”
West Dunbartonshire Council response
One purpose of the defined area is to ensure businesses that may generate higher levels of
footfall are within close proximity of Clydebank Town Centre, however it does not necessarily
prohibit businesses from accepting ‘drop by’ visitors, provided this is ancillary to the main
business (e.g. not the main purpose of the business or premises). For example some
businesses within the business park are primarily sales or manufacturing, but have a
showroom element. Ancillary uses such as this that enable visitors to business, industry, and
storage and distribution may still be acceptable. The guidance can be amended to clarify
this.
Respondent 7
“With the accessibility to local bus stops and train and location to shopping centre
any units should be available for mixed use. Employment and provision of facilities is
more important than units sitting empty, not every business fits in a “box” “
West Dunbartonshire Council Response
The area for alternative uses was chosen in part because of its proximity to public transport
and Clydebank Town Centre. National Planning Policy and West Dunbartonshire Council
aim to support town centres through an approach which intends to direct uses that generate
significant footfall towards the town centre. Town centres are the preferred location for such
uses, however the guidance does recognise this is not always feasible, allowing for these
uses within the business park. 
However this needs to be balanced against the need to ensure that there is sufficient land
and premises available for business and industry use. The council’s intention is that
Clydebank Business Park remains primarily for business, industry, and storage and
distribution and so considers that restricting the area that alternative uses are permitted is
necessary. 
Proposed changes as a result of responses to this question
Amend guidance to clarify that uses ancillary to a business in use class 4, 5, or 6 outside of
the zone in map 4 may be acceptable, provided that the primary activity on the site still falls
under use class 4, 5, and 6. For example a business which is primarily manufacturing or
sales, could have a small show room. Applicants for proposals outside of zone for must
demonstrate that this will not attract a significant amount of footfall. 
It is not considered appropriate for the guidance to enable alternative uses in all areas of the
business park, due to the need to ensure that there is available land and premises for
business, industrial, and storage uses.
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Appendix 2
Are the criteria for deciding planning applications on ’alternative uses’
clear?
Five respondents considered that the
criteria for deciding applications for
‘alternative uses’ were clear, with two
stating that they were not.
If no, what is unclear? How could the clarity be improved?
One of the respondents who said the criteria were not clear did not know what the criteria
were. One respondent to this question stated that the criteria in the draft guidance was much
clearer than when they had been through the planning process.
Respondent 3
“What are they?”
West Dunbartonshire Council response
The criteria were detailed in section 7 of the consultation draft guidance.
Respondent 7
“So much better than when we had to go through planning process.”
West Dunbartonshire Council response
This comment is noted.
Proposed changes as a result of responses to this question
No proposed changes to this section of the guidance as a result of responses to this
question.
5
2
Yes No
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Appendix 2
Do you agree with the criteria the guidance applies to determining
planning applications for 'alternative employment uses'.
Six of seven respondents answered this
question. Four respondents agreed with
the criteria and two did not agree. 
Please provide additional detail on what criteria you think should applied when
determining planning applications within the business park?
Three respondents provided additional detail. One respondent suggested the council should
long term help to the businesses to boost local employment. One respondent suggested if
consideration should be given to increased footfall (and therefor custom) to the business
park and provision of parking near to the businesses.
Respondent 1
“I understand the planners desire to look at alternatives for this area but this is a well
established industrial area and maybe providing some long term support to the
businesses located here can help to increase local employment.”
West Dunbartonshire Council response
This comment is noted, however this is not an issue that can be addressed through planning
guidance.
Respondent 4
“Will it provide a wider variety of people travelling through the Business Park?  Would
the business asking for change of use within the Business Park benefit from having
parking close - not a car park at one or other side of the Shopping Mall (or more
importantly would their customer benefit and in turn would this mean more people
within the Business Park).”
West Dunbartonshire Council response
Uses that generate significant amounts of footfall (e.g. retail, food, leisure) are generally
preferred in in town centre locations or retail parks. The Council will continue to promote
footfall in town centre locations where possible, but allow these uses in the business park
when there are not appropriate premises in the town centre for particular business needs.
This is addressed in section 7 under “NPF4 Policy 27”.
4
2
Yes No
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Appendix 2
Parking is addressed within the guidance, including the need to have parking close by to the
businesses, in section 7 under “LDP Policy E2”, part “a”.
Respondent 7
“Common sense”
West Dunbartonshire Council response
This comment is noted.
Proposed changes as a result of responses to this question
No proposed changes to this section of the guidance as a result of responses to this
question. 
The suggestion that the Council provide additional support to businesses within the business
park is beyond the scope of this guidance and is a wider economic development issue. 
The suggestion that the council should consider whether a planning application will lead to
greater footfall in the area is not considered appropriate in this situation. Directing footfall
towards the towards town centres is the preference in both local and national planning
policy. The business park is designated primarily for business and industry and the council is
seeking to ensure that proposals that may bring more footfall are in still compatible with this
and are in close proximity to the town centre.
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Appendix 2
Do you have any other comments on the draft guidance you would like
the council to consider?
Respondent 2
“The business park was previously zoned as not suitable for Motor Trade.  Has this
been changed officially or just by non enforcement? The motor trade activities are a
blight on the whole park.  Scrap and untaxed cars are left in north avenue almost
permanently. This will be the thin edge of the wedge that will see this high quality
park ruined. You should halt any further motor trade activities in the business park.“
West Dunbartonshire Council response
Existing Planning policy and guidance for the Clydebank Business Park does not explicitly
exclude “Motor Trade” uses. Mechanic garages would be considered either class 4
(business) or class 5 (industrial) uses depending on the nature of the business and therefore
acceptable in the business park in principle. However other motor uses (including sale or
display of vehicles, taxi/vehicle hire, or a scrap yard/ yard for breaking motor vehicles) would
be considered sui generis (not falling into a specific use class). Application for these uses
would need to be considered on their own merits against policy and guidance. 
Respondent 4
“For me if a business is considering the Business Park over other areas it is because
there is an advantage to that business such as the Unit being considered being the
correct size or able to be extended etc.  All applications should be considered on
merit and not just if they tick a certain amount of boxes on a pre-determined list.”
West Dunbartonshire Council response
We accept some businesses do have specific needs and may find it difficult to locate their
businesses elsewhere, such as the town. This is addressed within the draft guidance in
section 7 under “NPF4 Policy 27”.
Proposed changes as a result of responses to this question
No proposed changes to this section of the guidance as a result of responses to this
question. 
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AssessmentNo 744 Owner cameron.clow
Resource Transformation Service/Establishment Regulatory
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 Clydebank Business Park
The aim, objective,purpose and intended out come of policy
The aim is to control the types of land use within Clydebank Business
park to ensure they are compatible or complimentary to the business
parks primary use for industrial and business uses.
Service/Partners/Stakeholders/service users involved in the
development and/or implementation of policy.
Planning
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) Yes
Relevance to Human Rights (HR) No
Relevance to Health Impacts (H) Yes
Relevance to Social Economic Impacts (SE) No
Who will be affected by this policy?
Businesses seeking to establish themselves in Clydebank Business park and the users
of those businesses. There is specific mention of child oriented uses in the business
park, including childcare and leisure uses, such as soft play.
Who will be/has been involved in the consultation process?
Business owners/ managers and employees of the business park have been surveyed
with an online questionnaire.
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
Child oriented uses,
including childcare
and soft play are
present in the
business park and
the guidance seeks
to further control
these uses to ensure
Online consultation
of business owners/
managers and
employees. Survey
of business park
premises and uses
maps these uses
throughout the park.
The guidance will
limit the area where
child oriented uses
will occur and
guides these uses to
an area of the
business park that is
accessible by public
ITEM 7 - APPENDIX 3
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that they do not
impact the operation
of existing
businesses and to
enable safer access
of this group to the
business park.
transport and states
development should
ensure there are safe
walking routes.
Cross Cutting
Disability
The Council needs to
have due regard to
the Public Sector
Equality Duty, in
terms of planning
matters. This
includes around
accessibility for
disabled people.
National Planning
Policy sets it out the
needs of people with
disabilities needs to
be met regarding
transport and access
There is a range of
evidence on the
importance of
consideration of the
PSED in planning
matters
The guidance will
note that
accessibility is an
important thus
helping to ensure
that a shared under
standing of
considerations.
Social & Economic
Impact
Sex
Gender Reassign
Health
The guidance
highlights that
residential uses are
not acceptable in the
business park, as the
business and
industrial nature
would likely impact
the amenity of
residents and
impinge on the
ability of businesses
to operate.
Online consultation
of business owners/
managers and
employees indicates
that residential uses
in the park would
likely cause conflicts
with the operation of
existing businesses.
Planning permission
would not be
granted for
residences within
the business park,
which will avoid
conflicts with
business uses.
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.
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Will the impact of the policy be monitored and reported on an ongoing bases?
The guidance will likely be reviewed as part of the preparation of a new Local
development Plan.
Q7 What is you recommendation for this policy?
Intoduce
Please provide a meaningful summary of how you have reached the
recommendation
As part of managing different types of uses in Clydebank Business Park, child oriented
uses have been restricted. The effect of this will be the reduced conflict with these uses
and the primary users of Clydebank Business Park. The guidance strikes a balance
between the enabling some child oriented uses within the business park and
preventing conflict with existing business and industrial uses. The guidance will note
that accessibility is an important thus helping to ensure that a shared under standing
of considerations. The guidance does not support any kind of residential or
accommodation use within the business park. This should have a positive impact on
health, as the business and industrial nature of the main occupiers of the business park
could harm the amenity of residents.
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WEST DUNBARTONSHIRE COUNCIL
Report by Planning, Building Standards and Environmental Health Manager
Planning Committee: 14th February 2024
Subject: Pay Day Lending and Betting Shop Planning Guidance
1 Purpose
1.1 The purpose of the report is to seek approval to consult on draft Planning
Guidance relating to Pay Day Lending and Betting Offices.
2. Recommendations
2.1 It is recommended that the Committee approves the publication of the draft Pay
Day Lending and Betting Shops Guidance in Appendix 1 for consultation.
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 involving surveys and in depth focus groups identified
Clydebank and Dumbarton Town Centre in particular were considered to have
an undesirable number of these premises. The research showed a majority of
people 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. NPF4 has taken onboard much of the Council’s approved guidance on
Pay Day Lending and Betting Offices and 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.
3.3 The updated draft guidance reflects changes to planning policy, up to date town
centre surveys identifying the number and location of pay day lending and
betting shops, and updated research. The evidence supporting this guidance is
compiled in a separate background information document in Appendix 2.
4. Main Issues
ITEM 8
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4.1 Updated Pay Day Lending and Betting Shop Guidance and Background
Information have been prepared and draft versions for consultation purposes
are attached for approval in Appendix 1 and 2 respectively. 
4.2 The Planning Guidance is intended to address the over-concentration of pay
day lending and betting shops and potential negative effects on the vibrancy of
town centres and wellbeing. The guidance and accompanying background
information sets out the socio economic background of West Dunbartonshire,
which is arguably one of the more deprived areas in Scotland according to the
Scottish Index of Multiple Deprivation and employment, benefits and earnings
data. When compared to the rest of Scotland, the area has lower weekly wages
per resident, higher proportion of people economically inactive due to long term
illness, and a higher proportion of benefit claimants. 
4.3 Literature indicates that higher deprivation is correlated to a higher density of
gambling machines and that easier access to gambling means individuals are
more likely to gamble. West Dunbartonshire, when compared to other
authorities of a similar population size was found to have a significantly higher
number of betting shop licenses. Regarding pay day lending, research
indicates that typical borrowers earn less than £20,000 per year and that there
is a relationship between debt and many negative health outcomes, including
mental health and addiction. Pay day lending debt was found to have the
greatest effect on people’s wellbeing of all other types of debt.
4.4 The number of pay day lending shops has significantly decreased across the
UK due to additional regulation. There has been a decline in the number of
betting shop licenses in the council area and across comparable authorities in
recent years. However West Dunbartonshire is still arguably more vulnerable
to gambling and high interest lending due to its socio-economics. It also still has
higher betting shop licenses per person than local authorities of a similar size. 
4.5  Surveys undertaken through the Citizens Panel in 2015 and 2023 provide
evidence that, overall, people consider that there are too many pay day lending
and betting shops in Clydebank, Dumbarton, and Alexandria town centres and
that they do not contribute positively to the town centres. Town centre surveys
undertaken in 2023 show that numbers of these premises remain similar to
when the guidance was introduced, and that clusters of these uses are still
present in Clydebank (South Sylvania Way) and Dumbarton (High Street,
College Way and Riverside Lane). Therefore a refresh of the approved
Guidance is appropriate given the policy position of NPF4. 
4.6 The Guidance would restrict these uses by:
• not supporting applications that would increase the number of these
uses to above their current level;
• by not supporting applications for these uses within identified clusters in
Clydebank, Dumbarton and Alexandria Town Centres;
• not supporting applications on the basis they will contribute to the footfall
or vitality of the town centre.
• in relation to vacant units, the council accepts that it is generally
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preferable to have an occupied unit, however due to the socio-economic,
health effects and local concerns regarding these types of businesses,
unit vacancy will be a lesser consideration in planning decisions. 
While it does not introduce a limit or identify clusters in local neighbourhood
centres, the guidance also introduces the number and clustering of these uses
in local centres as a consideration in planning applications.
4.5 The guidance now also applies to Alexandria Town Centre. Previously, the
guidance only applied to Core Town Centre Areas, through policy SC2 Core
Town Center Areas of LDP2, which only identified in core areas within
Dumbarton and Clydebank. However Policy 27 of NPF4 applies to whole town
centre areas. The 2023 citizens panel survey results 71% of respondents
identified Alexandria as their town centre felt that there were too many betting
shops in the town centre and a majority agreed that pay day lending and betting
shops had a negative impact on community wellbeing.
Next steps
4.6 The Draft Planning Guidance will be published for a minimum 8 week
consultation period, the outcome of which, and any subsequent proposed
changes to the guidance, will be reported to a future Planning Committee. 
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 An Equalities Impact Assessment is attached in Appendix 3. Access to
gambling opportunities increase the likelihood of problem gambling and males
between the ages of 16 and 20 are more likely to be problem gamblers.
8.2 Betting shops tend to concentrate in more deprived areas and pay day loans
are often used to bridge gaps between pay-checks. This means that the
negative effects on household finances wellbeing of debt and problem gambling
disproportionately affect people in deprived areas.
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8.3 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 the town centre.
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 The draft Planning Guidance document in Appendix 1 and the background
information in Appendix 2 will be published for a minimum 8 week consultation
period. The draft documents will be made available online with publicity via
social media and local development plan participants.
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.
Pamela Clifford
Planning, Building Standards and Environmental Health Manager 
14 February 2023 
________________________________________________________________
Person to Contact:
Pamela Clifford, Planning, Building Standards and Environmental Health
Manager
Pamela.Clifford@west-dunbarton.gov.uk
Cameron Clow, Development Planning & Place Officer
cameron.clow@west-dunbarton.gov.uk 
Appendices: Appendix 1 – Draft Clydebank Business Park Planning
Guidance
Appendix 2 – Background information
Appendix 3 – Equalities Impact Assessment
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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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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. [INSERT LINK WHEN AVAILABLE]
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,
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 authorities
ITEM 8 - APPENDIX 1
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• 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.
Error! Reference source not found. 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 3 3
Total 5 6 3
Planning Policy Context
National Planning Framework 4
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)
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.
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  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.
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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 Lending 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 recorded in the Error! Reference source not found. 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 the Error!
Reference source not found. 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.   
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
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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
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 Error! Reference source not found..
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 would 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
consideration 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
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impact the character and amenity of the centre, no further uses of this type will 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.
Therefore 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.
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Pay day lending and betting shops:
Planning Guidance
Background
Information
I T E M  8  -  A P P E N D I  X  2
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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%) werewithin
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/
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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 thanscotland
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 
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. 
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which do not have as high a proportion of data zones within the 20% most deprived 
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 
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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 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 
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. 
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Table 3: Betting shop and high interest lending premises in Clydebank town centre
Clydebank town centre 2023 2015
Betting shop premises 3 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
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
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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 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
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 has 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.
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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 check,
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
persons 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)
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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 effected; 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 
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2023 Survey
The council repeated Citizens Panel  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  “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  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  they are not goof for community wellbeing.   There is some difference to the degree
of agreement or disagreement with the questions between the two  surveys , the same
conclusions can be drawn from both. 
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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 
Dumbarton results 
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Evening results
Clydebank Evening Count Dumbarton evening count
Time Unit Tally
17.30 - 18.00 Ladbrokes 9
18.00 - 18.30 Paddy Power 10
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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
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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.
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Appendix 1: Citizens Panel
Research Report 2015 
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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 
Citizen Panel Research Report by Hexagon Research and Consulting 1
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises   
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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 being. 
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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 
are: 
a) Whether the change would significantly reduce the retail offer of the core retail area,
or parts of 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;
c) The contribution the proposed use would make to the vibrancy of the town centre by
increasing 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. 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 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 24th July 2015. 
Location Number of respondents Breakdown of respondents
Garshake, Dumbarton 7 4 male, 3 female
Town Hall, Clydebank 8 4 male, 4 female 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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. 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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  than  once  a
month 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 being of the local community, as a base for community activity and an important
centre of employment. 
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Of 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. 
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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% 
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‘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 has 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 that but the parking is rarely
policed and you get people parking on both sides of the road. So, when a bus 
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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  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%) 
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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% 
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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 
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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 purpose 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 
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5. Pay day lenders
To help the Council develop its evidence base to  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  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 being 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. 
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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% 
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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. 
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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 thing 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 to 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 
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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 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 more 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 
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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 being of the community (66%)
The majority of respondents also disagreed that betting offices:
• Added  vitality  and  vibrancy  to  their  town  centre  (85%  disagreed,  with  41%
‘strongly disagreeing’)
• Were important because they help to fill vacant premises (81% disagreed) 
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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% 
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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’s 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 me but he enjoyed it and it got him out of the house every day.
Dumbarton respondent 
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I’ve got a neighbour and he likes to have a wee bet now and then. I’m not opposed
to that but surely 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 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 
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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” 
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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 places 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 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 
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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 being 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 being 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. 
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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 competition 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 being 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 like 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
Street 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 
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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’. 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’s 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 centres 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  this proposal,
with more than two thirds (68%) saying they would ‘strongly support’ it. Only 2% said
they opposed it. 
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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 being 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 nation 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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 being and cohesion 
Major concerns about the number and  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 being. 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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises   
Appendix 1
West Dunbartonshire Citizens’ Panel 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 
the 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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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) 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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). 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises   
Appendix 2 
Focus group discussion guide 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 being 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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 being 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 being of local communities 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises   
Appendix 3
Survey Questions 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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) 
Clydebank (the Clyde Shopping Centre, Sylvania Way South and  
Alexandria (Main Street, Bank Street and Mitchell Way) 
Q8. How often would you visit your local town centre?
Daily
2-3 times a week
Once a week 
2-3 times a month 
Once a month 
Less than once a month 
Never 
Q9. How important do you think it is to have a vibrant town centre?
Very important
Quite important 
Not very important 
Not important at all 
Don’t know 
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Q10. How important are the following in a vibrant town centre?
Ver
imp
Wide range of shops Fast
food outlets
Pharmacy/health facilities
Pubs
Charity shops
Cafes and restaurants
Betting offices
Libraries/museums/art galleries
Banks
Good quality shops
Pay day lenders/pawn brokers
Green/open spaces
‘Pound’ shops
Leisure facilities (cinema etc)
Local Government/civic uses
Supplementary Guidance on Pay Day Lending and Betting Offices Premises
y Quite Not very Not Don’t
ortant important important important know
at all
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
0 1 0 2 0 3 0 4 0 5
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Q11. Thinking of your own town centre, how satisfied or dissatisfied are you with the following?
Green/open spaces      
‘Pound’ shops 
Leisure facilities
(cinema etc) 
Local
Government/civic
uses       
Supplementary Guidance on Pay Day Lending and Betting Offices Premises   
The range of shops
Fast food outlets
Pharmacy/health
facilities 
Pubs 
Charity shops 
Cafes and restaurants
Betting offices
Libraries/museums/art
galleries 
Banks
Very
satisfied
Quite
satisfied
Neither
satisfied
nor
Quite
dissatisfied
Very
dissatisfied
Don’t
know  
dissatisfied   
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6
The quality of the      
shops    0 1 0 2 0 3 0 4 0 5 0 6 
Pay day lenders/pawn 
brokers 0 1 0 2 0 3 0 4 0 5 0 6 
0 1 0 2 0 3 0 4 0 5 0 6
0 1 0 2 0 3 0 4 0 5 0 6 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
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? 
They are important
because  they  help  to  fill
Strongly
agree
Agree Disagree Strongly
disagree
Don’t
know
vacant premises 0 1 0 2 0 3 0 4 0 5
They charge very high
interest rates 0 1 0 2 0 3 0 4 0 5
They  make  an  important contribution
to the area by
paying business rates 0 1 0 2 0 3 0 4 0 5
They make it too easy for vulnerable
people to get a
loan 0 1 0 2 0 3 0 4 0 5
They add to the
vitality/vibrancy of the town
centre 0 1 0 2 0 3 0 4 0 5 
There are too many of
them  0 1  0 2  0 3  0 4  0 5
They provide an important
service for those who can’t
access mainstream  0 1  0 2  0 3  0 4  0 5
financial institutions 
They attract the wrong type
of people into the town/put
others off 0 1 0 2 0 3 0 4 0 5
They are  a  valuable
employer in  the town
centre 0 1 0 2 0 3 0 4 0 5
They are not good for the well
being of the
community 0 1 0 2 0 3 0 4 0 5 
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Supplementary Guidance on Pay Day Lending and Betting Offices Premises  
Betting Offices 
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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     
They  make  it  too  easy  to
gamble     
They  make  an  important
contribution to the area by
paying business rates     
There
them
are too many of     
They add to the
vitality/vibrancy of the town
centre     
They attract the wrong type
of people into the town/put
others off     
They provide an important
service  for  those  who  like
to gamble     
They are not good for the
well being of the
community     
They are a valuable
employer
centre
in the town     
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Q14. To what extent are you concerned about the number and clustering of pay day lenders
and betting offices in your town centre?
Very Quite Not very
concerned concerned concerned
Not
concerned
at all
Don’t
know
The   overall   number   of
pay day lenders and
betting offices in the town
centre     
The clustering of pay day
of the town centre
pay day lending and betting shops
appendix 1 
Supplementary Guidance on Pay Day Lending and Betting Offices Premises   
Clustering of Pay Day Lenders and Betting Offices 
lenders and betting 
offices in particular parts 0 1 0 2 0 3 0 4 0 5 
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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
Strongly
agree
Agree Disagree Strongly
disagree
Don’t
know
It would have a detrimental
effect  on  the  vitality  and
vibrancy of the town centre     
It would improve the vitality
and  vibrancy  of  the  town
centre by increasing footfall     
It  would  be  bad  for  the
health and well being of the
community     
6
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Q16. 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? 
Supplementary Guidance on Pay Day Lending and Betting Offices Premises 
Strongly agree Agree Disagree Strongly disagree Don’t know 
0 1  0 2  0 3  0 4  0 5 
Q17. The Council has limited powers to address the number and clustering of pay day lenders and
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     
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Appendix 2: Citizens Panel
Results 2023 
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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.. 
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 citizens 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)% 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 said “don’t know”.
“Very important” aspects of a town centre 
Dumbarton Clydebank Alexandria
Hot food takeaways  11% 7% 8%
Betting offices 3% 1% 0%
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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  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  with this statement in 2015 and
69% in 2023);
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• There are too many of them (71% agreed  with this statement in 2015 and
66% in 2023);
• They are not good for the well being 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
they help to fill vacant
16% 3% 36% 38% 7%
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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  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
paying business rates
35% 31% 42%
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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
respondents in Dumbarton
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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 
on  the  vitality 
and vibrancy of
the town centre
45% 38% 2% 1% 13%
Would improve
the vitality and 
vibrancy  of  the 
town centre by
increasing footfall
3% 4% 43% 38% 12%
Would  be  bad 
for  the health
and well being 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  on  the 
vitality  and vibrancy of the town centre
83% 81% 89%
Would improve the vitality and  vibrancy 
of  the  town centre by increasing footfall
9% 8% 3%
Would  be  bad  for  the health and well
being 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.
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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  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 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
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noted that the bank on both days closed earlier than the other stores (4.30pm on Thursday and
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) 
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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. 
2Figure 3 
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Figure 4 
Figure 5 
Evening count
This provided evidence of the footfall attracted into the centres during evening hours, after the
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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  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.
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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 
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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   
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Customer count -
actual recorded results
Dumbarton: Saturday 19th September Weather 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   
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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 count Weather conditions: Good, light 
Time
17.30 - 18.00
Unit
William Hill 
Tally 
10 
18.00 - 18.30 William Hill  10 
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18.00 - 18.30 William Hill 9
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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 8 - APPENDIX 3
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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.
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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.
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