Craig McLaren, Director of RTPI Scotland, on planning, betting and pay day loans
I attended the recent Scottish Government summit on Betting and Payday Loans on Scotland’s High Streets. The summit was hosted by Derek Mackay MSP, Minister for Local Government and Planning, given his responsibility for town centres and it was very much pitched as something to be looked at in that context, especially given ‘issues’ with clustering of these types of premises. The summit brought together financial advisors, bookmakers, credit unions, planners, politicians, debt advisors and users.
A couple of things struck me about the summit. Firstly, a number of people and organisations saw the planning system as the key means of solving the issue. As much as I am always keen for planners to attempt to provide solutions to issues in our town centres, this is an unrealistic expectation and I’ll explain why later.
Secondly, many of those at the summit talked about bookmakers and pay day loan shops in the same breath, as if they provided the same services and had the same impacts. From a planning perspective, they are quite different functions, with betting shops being easier to distinguish from other financial services but pay day loan shops less so.
The key discussion points centred around the Use Classes Order with calls for both betting shops and pay day loan shops to be taken out of Class 2 (Financial, Professional and Other Services) and made Sui Generis. This would mean that new pay day loan shops or bookies would need to apply for planning permission if the premises they wished to use weren’t already in that use. However, this would not be retrospective and so wouldn’t impact on any existing premises. Also, I think it would be very difficult to establish a clear difference between pay day loan shops and other financial services such as banks as they carry out very similar functions, with the key difference being the product and interest rate charged. Does that really make a difference in planning terms?
It would be easier to re-classify betting shops as Sui Generis – indeed they have been classed as this previously. But again this couldn’t be applied retrospectively to existing premises.
There were also pleas for Councils to use Article 4 Directions to restrict permitted development rights, though as far as I understand this would only restrict existing changes of use from Class 3 (Food and Drink) to Class 2 and wouldn’t therefore have a major impact.
And we have to remember that both bookies and pay day loan shops generate footfall in town centres at a time when they are crying out for it.
For me there were other interesting points put forward which should be explored as part of the broad front needed to tackle the issues: using licensing law more effectively and linking these more effectively with other regulations, including planning; using broader powers on wellbeing to bring together a range of solutions; perhaps using need and demand assessments as part of developing a more effective and openly accessible evidence base.
So, as much as the planning system could be part of the response, it certainly does not provide the entire solution. And it has to be remembered that it is only dealing with demand that is generated for these uses. Tackling that is a much bigger issue entirely.