From: e-mail
Sent: 29 October 2020 12:17
To: Brighton Licensing <>
Importance: High

Dear Sirs,

Many thanks for your representation of my Premises Licence Variation application.

I understand as a Licensing officer of Sussex Police, you have concerns over the grounds of the Prevention of Crime and Disorder and Prevention of Public Nuisance and that this application falls within your Cumulative Impact Area.

In your representation, you mentioned that I did not reach out to Sussex Police before submitting my application and therefore you assumed that I did not consider the negative impact my application might have. To be honest, there is no indication at any point during submitting the application that one has to reach out to the Police prior if there were I defiantly would have.

I have been trading from this location since 2006 with my late night refreshment licence. 14 years of experience as a shop owner in this area does give me some idea. You might know that my current licence does not have any conditions attached to it. But, as a responsible licenced premises owner, I took upon my self to employ SIA doormen at my premises during 23:00hrs to 04:00hrs Friday and Saturday as well as during bank holiday weekends, to help disburse people away from the area quietly and quickly. Also, I am fully aware that the Police can be overstretched during the summertime especially during weekends in June, July and August, therefore my premises have also signed up to BCRP radio to assist the Police in any way possible. During these 14 years, my premises have never violated it's licencing objectives, we have never had any bad behavioural reports from the Police or any other responsible authorities,  I have done all this from my own initiative and I believe this morethan proves that I am a responsible premise and personal licence holder. 

To address the Cumulative Impact Area issue, I am prepared to reduce my ‘ON’ the premises alcohol sale as a cafe from 11am until 10pm every day. I am already a Fish and Chips cafe, therefore I just want to add a small drinks menu for my ‘eating in’ customers and allow them an option to add alcohol to their food order. This will be a table service only and drinks will only be served in disposable plastic cups. I believe this is permissible under the Statement of Licensing Policy. So, to address your concern, I am proposing the above conditions to restrict the sale of alcohol to just-food orders after 10pm every night. 

As for the ‘OFF’ license element of my application, it will be purely ‘sale of alcohol by retail for the consumption of OFF the premises between the hours of 11:00hrs to 03:00hrs every day. Thereby reducing my hours for Friday and Saturday from 04:00hrs to 03:00hrs. I believe these measures I have put forward will mitigate and reduce the negative cumulative impact of my application. I also feel that my application should be considered as an exceptional circumstance, because I realize the ongoing redevelopment work in my area specially the promenade and the shelter hall redevelopment, will boost the city’s image as a top UK tourist attraction. Only recently alcohol license was issued to the bars located in the shelter hall development. Even though, they are located on the beachfront. My shop, on the other hand, is located on the busy main road, so there will be no increasing the risk of alcohol being consumed on the streets. Besides, you can not stop people from buying alcohol from elsewhere and consume it on the beach, it's just not physically possible to police. This behaviour only happens during the three weeks in August during the summer night. I feel my premises have enough conditions in place to tackle these three weeks. At least, we as a licenced premise can have measures in place such as Challenge 21 and be able to refuse anyone who is too drunk, thereby upholding the Licencing Objective. Otherwise, people will simply buy from elsewhere and consume it without any control what so ever.

I would also like to point out since my application has been put in, I have had NO objections from residents/businesses above my shop or surrounding buildings.

Like to point out, that at no time, the back of my shop will be reserved for the display of alcohol. As mentioned in my application, alcohol will only be kept behind the serving counter. 

If I am granted this license variation, I confirm that I will change the shop into more of an OFF Licence/Convenience store operation after 10pm every day. By ONLY serving late-night refreshment, will be available after 10pm. More emphases will be put on the ‘Off Licence/Convenience store element, throughout the year, where I will also stock beachwear and all related tourist gifts items such as Brighton rocks, souvenirs, etc. The cafe elements will only take priority during the summer season ie; during the months of June to August.

I believe my proposition is a positive proposal; will provide a unique store in this tourist area of our city. My current license has no condition attached to it. However, I am prepared to the employment of an SIA security doorman between the hours of 23:00hrs to 03:00hrs Friday and Saturday to oversee the sale of Alcohol and to encourage customers to leave the area quietly and quickly, so there is no gathering of too many people outside the store thereby reducing any potential risks.

With all the above conditions attached, I believe I have demonstrated that my application has exceptional circumstances to justify departing from the policy. I will be grateful if you would withdraw your representation and allow the License variation. If you are still unclear about anything I have stated so far, please contact me so we can try to resolve it. I am a small business who has been trading in the city since 2000. Due to the current Covid-19 situation, times are extremely hard for small businesses, and the high street future is not looking bright. The government is trying to allow various initiatives to allow small business to survive, the changes I am seeking in my application will allow me just that.

Kind Regards,

Mr Ali Akbar.