Appendix C
Alcohol licensing Cumulative Impact Assessment (CIA) Consultation July – September 2023
1. Respondents
How are you responding to this survey? |
||
|
n |
% |
Business operator |
28 |
37% |
Brighton & Hove resident |
20 |
27% |
Premises licence representative |
13 |
17% |
Responsible authority |
2 |
3% |
Other (details below) |
11 |
15% |
Not answered |
1 |
1% |
Total |
75 |
|
Other respondents
· Chair of BHCC Safety Advisory Group
· Brighton marina estates management
· Methodist Church
· Councillor
· Technically we are a business with a premises licence. We are a community benefit society that owns and runs a community hall just north of Seven Dials
· North Laine Community Association
· Chairman of a tennis club
· I live close and spend a lot of my time in Brighton and Hove
· We are acting on behalf of our client Abrdn, who have a significant interest in Brighton City Centre given their ownership of Churchill Square Shopping Centre. Please note that the responses provided to this survey should be read in conjunction with the representations submitted directly to Jim Whitlegg.
· Brunswick Town Association - we represent all the residents associations within the Brunswick Town conservation area.
· We are acting on behalf of our client Abrdn, who have a significant interest in Brighton City Centre given their ownership of Churchill Square Shopping Centre.
2. The proposals
Do you agree or disagree with the proposal to maintain the special policy on cumulative impact and to maintain the current cumulative impact zone as set out in the draft cumulative impact assessment? |
|||||||||||||||
|
All respondents |
Local resident |
Business operator |
Premises licence rep |
Responsible authority |
Other |
Not answered |
||||||||
Strongly agree |
34 |
45% |
13 |
65% |
6 |
21% |
8 |
62% |
1 |
50% |
5 |
45% |
1 |
100% |
|
Tend to agree |
12 |
16% |
1 |
5% |
6 |
21% |
2 |
15% |
|
|
3 |
27% |
|
|
|
Neither agree nor disagree |
8 |
11% |
1 |
5% |
7 |
25% |
|
|
|
|
|
|
|
|
|
Tend to disagree |
9 |
12% |
2 |
10% |
4 |
14% |
2 |
15% |
1 |
50% |
|
|
|
|
|
Strongly disagree |
12 |
16% |
3 |
15% |
5 |
18% |
1 |
8% |
|
|
3 |
27% |
|
|
|
Total |
75 |
|
20 |
|
28 |
|
13 |
|
2 |
|
11 |
|
1 |
|
|
How are you responding to this survey? As a… |
Do you agree or disagree with the proposal to maintain the special policy on cumulative impact and to maintain the current cumulative impact zone as set out in the draft cumulative impact assessment? |
Why do you agree or disagree with the proposal? |
Brighton & Hove resident |
Strongly agree |
Having worked for over a decade in a red zone area, the effects that spread into the community are sadly clear to see. I fully support the tackling of anti-social behaviour and a reduction in crime related to all forms of substance and alcohol misuse that propel this type of behaviour. |
Brighton & Hove resident |
Strongly agree |
i agree, i do not feel safe walking in parts of Brighton because of drinkers and aggressive begging, and my family who would be tourists now after living in Hove for most of their lives also would not go into Brighton for the same reason. |
Brighton & Hove resident |
Strongly agree |
Living in North Laine the alcohol- and drug consumption concentrated to this area has increased noticeably during this year resulting in increased crime, disorder and public nuisance. Having four pubs/alcohol premises on either end of the street naturally increase constant drunken through-traffic of people and attracts non-social behaviour. This proposal is very much needed if central Brighton wants to stay as living residential area and not seasonal outdoor nightclub. It is a grave concern for both visitors and residents. |
Brighton & Hove resident |
Strongly agree |
Quality of life concerns |
Brighton & Hove resident |
Strongly agree |
The cumulative impact zone comprises areas where large numbers of people live. Problems of noise and anti-social behaviour are not confined to the licensed premises themselves, they spill out into the streets, making parts of the town hazardous and threatening for residents and for people coming into town for a meal or cultural event. Neighbourhoods become blighted because of the drunkenness, noise, fighting and urinating. People coming into town for the evening are more likely to want to drive than use public tranpsort, so as to minimise the time they have to spend walking through the streets. |
Brighton & Hove resident |
Strongly agree |
To help towards Brighton & Hove being a safe place for all, help regarding the anti social behaviour and crime in these areas. I believe we should go further and some areas should be designated No Alcohol licence areas. |
Brighton & Hove resident |
Tend to agree |
As a resident it is apparent which premises have old licence agreements and in some cases apply too much flexibility to the interpretation of them, staffing ages, id checks and general venue / operations management. A higher level scrutiny of the city licensed venues , off-licences in the zone in particular ( selling cheap high volume alcohol). NO additional pure off licence venues should be accepted. |
Brighton & Hove resident |
Tend to disagree |
It comes across as lazy. It’s not really fixing a problem. It’s not really addressing existing bad users of alcohol licences and it’s also limiting open trade. It’s trying to fix a symptom and not a cause. |
Brighton & Hove resident |
Strongly disagree |
Scrap it and come up with something better. While i generally agree with the proposal, the fact that CIA is not enforced and alcohol licences continue to be granted within the area means that there is no point to the CIA. |
Brighton & Hove resident |
Strongly disagree |
The lack of organised policing is the problem. |
Brighton & Hove resident |
Strongly disagree |
You need to be more targeted with business applications as this policy could hold back small business and the development and regeneration of the cities economy. |
Business operator |
Strongly agree |
As a small independent business, anti-social behaviour in the Preston Road area is at an unacceptable level. I feel restricting additional alcohol licences will be useful in helping curb the increase of this issue. |
Business operator |
Strongly agree |
B&H does not need any more new venues, as this dilutes the quality of what we already have |
Business operator |
Strongly agree |
To reduce anti social behaviour. |
Business operator |
Strongly agree |
Too many uncontrollable factors. Consumption is excessive and irresponsible |
Business operator |
Tend to agree |
Based on current analysis and levels of crime / nuisance activity it seems prudent to maintain the current policy and CIZ |
Business operator |
Tend to agree |
I absolutly agree with having controls in place but do not agree with how difficult for instance new premises would find it to gain a licence. They may well offer something great to the zone and promote tourism. |
Business operator |
Tend to agree |
The proposal does go one way to minimise crime and other we complaints, however it is a bit of a blunt tool and does not discriminate between types of licensed premises ie small venues and mass clubs or venues with responsible management. |
Business operator |
Tend to agree |
Working in the area for over 20 years it is apparent that businesses that engage in a considered licence management strategy are a benefit to the city whereas those who are idle with their responsibility contribute to criminal activity and are beacons for bad behaviour. Any model that allows for higher level scrutiny ( within measures ) should be supported and all businesses requested to engage. Historical relaxed licences should be looked into and routinely scrutinised |
Business operator |
Neither agree nor disagree |
Our business is solely a convenience store, part of which sells alcohol for consumption off the premises. We already have store(s) within the zone and do not think the CIA is aimed at such premises. We feel our impact on the issue is minimal, though appreciate some people may purchase alcohol for excessive consumption or "pre-drink" before going out for a late evening |
Business operator |
Neither agree nor disagree |
While I very much agree with the principal of the CIZ and the need for extra care with licensing in these areas, I would like to raise some issues for consideration with the implementation of the policy when it comes to the use/abuse of the system by a highly vocal but very small minority of local stakeholders to air grievances unrelated to the licensing objectives, or that are highly speculative, and/or that pertain to represent local opinions and interests without the mandate of said locals. This especially appears to be the case with the North Laine Community Association, where 2 or 3 members of long standing have taken it upon themselves to object to every licensing application or variation without consulting either their own membership or the local residents that they claim to represent. Their representations therefore appear to command far more weight than maybe they should do. |
Business operator |
Tend to disagree |
An increasing number of nightlife venues are closing and not being replaced. Onerous licensing terms is putting off new nightlife businesses launching. Brighton's nightlife offering is much weaker now than it was pre-pandemic, which affects the appeal of visiting Brighton for this purpose. |
Business operator |
Tend to disagree |
Because a well run licensed establishments are a huge benefit to the City Centre. The CIZ needs to be looked at differently. Plus many licenses have been granted within the CIZ so it seems to depend who you are. |
Business operator |
Tend to disagree |
I believe businesses like Shelter Hall have proved that if responsibly run, companies can improve the area, rather than purely being the domain of the Police. |
Business operator |
Tend to disagree |
While
I understand the aim of this policy, I feel it misses addressing
the crux of the issue at hand - the pervasive antisocial behaviour
manifested through alcohol and drug misuse during the day. The
assumption that licensed premises are predominantly to blame, in my
observation, is misguided. The root of the problem, as I encounter
daily, is the consumption of alcohol in public spaces, often
directly from cans. |
Business operator |
Strongly disagree |
I believe all new premises licenses should be given to individuals for the duration of their occupancy and not attached to the building. A fit and proper person check should also be carried out. |
Business operator |
Strongly disagree |
The
restrictions placed on business means creating a viable business
difficult . |
Business operator |
Strongly disagree |
This is absolutely a disgraceful way of handling the situation by punishing new businesses if you thing there is a business who contributes this negative impact you should locate the premise and tackle the specific location you cannot just stop new business while they are paying their rent and rates and contributing the community while i do not believe these business especially with food have anything to do with this problem |
Business operator |
Strongly disagree |
You are stifling new enterprise and business which is at the heart of what our wonderful city is famous for and what brings people to us. You are destroying the community, new upstarts, and all around have made Brighton and Hove a worse place to be. |
Premises Licence Representative |
Strongly agree |
cause get better managing alcool means safer and enjoyble road for everyone, too many drunk people and under age causing noice and trouble on the streets. |
Premises Licence Rep |
Strongly agree |
There clearly are issues and ongoing attention is required. |
Premises Licence Rep |
Strongly agree |
In principal a good thing |
Premises Licence Rep |
Strongly agree |
There clearly are issues and ongoing attention is required. |
Premises Licence Rep |
Strongly agree |
It is important not in risk increasing crime and nuisance levels. |
Premises Licence Rep |
Strongly agree |
The City Centre on weekends and special event days see huge crime levels and a no go area for many. Important for this to be controlled. |
Premises Licence Rep |
Tend to agree |
Agree it may help to limit antisocial behaviour |
Premises Licence Rep |
Tend to disagree |
Whilst there is a need to be vigilant on all applications and potential effect, a blanket policy on refusing to grant licences within the CIZ stifles innovation and investment especially in a touristic destination city such as Brighton. Alcohol consumption is dynamic, tastes, styles, fashion are constantly changing and we need the ability for our centre to showcase that with so many craft and micro breweries and Sussex being the centre of the English sparkling wine industry. Ultimately it is the individuals responsible and education on sensible consumption constantly reiterated, but the policy due to the city's magnet for stag, hen and attracting a younger inexperienced drinker within a concentrated area (and hence absorbing resources) fails to take into account that there may be opportunities for quality niche premises which could enhance the experience of local and tourists alike and should treat each application on its merit. |
Premises Licence Rep |
Strongly disagree |
The individual operators of licenced premises should be responsible and not black mark the area for new responsible operators |
Responsible Authority |
Strongly agree |
Appears to be a common sense approach to achieving the licensing objectives, with the benefit of precedent and supporting empirical data. |
Responsible Authority |
Tend to disagree |
I get that a lot of the issues relate to hospitality and in particular late night bars and clubs, however I feel the onus more is on the Government to properly find the police to be Abel to have the resources it needs on the street. From working in the industry for over 15 years, I have noticed that the more police that are about, being proactive, the less issues are faced on the streets. Unfortunately, there will always be idiots who will want to cause trouble or who will get drunk to excess and want to cause issues, however a proactive approach in being able to deal with them and move them on is more contortive to a safer and better nighttime economy. |
Other |
Strongly agree |
Because the constraints set up within the CIZ are based upon extensive, accumulative knowledge and there is evidence that it is helping to mitigate unruly and anti-social behaviour. |
Other |
Strongly agree |
there are more than enough venues in Brighton |
Other |
Strongly agree |
We agree that the concentration of business dispensing alcohol contributes to a well dodgy atmosphere in the city centre at weekends. |
Other |
Tend to agree |
I
tend to agree, although the policy is deliberately noncommittal in
parts. |
Other |
Tend to agree |
I think it's a good idea to restrict licensable premises - provided there's evidence said premises are directly or indirectly encouraging alcohol related anti social behaviour. |
Other |
Tend to agree |
I've put 'tend to agree' because, although we are outside the cumulative impact zone and so not directly affected, the policy sounds sensible. As long as it is possible to make an exception for an application that makes a good case for opening a new premises then the policy is not unfair and should be workable. The main difficulty probably lies in the Council's ability to resist pressure from a well-funded, expensively-represented commercial company or group, which could bias the policy against smaller applicants. |
Other |
Strongly disagree |
The
matrix approach categorises premises types, which when first
conceived, reflected relevant types of uses and occupiers. However,
an increasing number of premises, particularly those considered to
be more premium offers are providing an experience-based offer that
does not neatly fit into the categories listed in the matrix. In
our view, the uses set out in the matrix do not suitability define
premises that provide high-end experience destinations in heavily
managed locations that do not focus on consuming large quantities
of alcohol. |
Other |
Strongly disagree |
The
matrix approach categorises premises types, which when first
conceived, reflected relevant types of uses and occupiers. However,
an increasing number of premises, particularly those considered to
be more premium offers are providing an experience-based offer that
does not neatly fit into the categories listed in the matrix. In
our view, the uses set out in the matrix do not suitability define
premises that provide high-end experience destinations in heavily
managed locations that do not focus on consuming large quantities
of alcohol. |
Other |
Strongly disagree |
It's is blindly discriminatory and will lead to the potential of monopolies on the type of entertainment and clubs as the larger developers and businesses use their clout to muscle out the smaller more fringe venues. |
Not Answered |
Strongly agree |
Lansdowne Area Residents Association, LARA strongly supports the proposal but suggests the area is extended to, thus including palmyra Square and Adelaide crescent which has problems of asb with which the police are dealing. This would be a policy reflecting joined up thinking. |
3. General comments
How are you responding to this survey? As a... |
Do you have any comments to make about the draft Cumulative Impact Assessment and supporting evidence? |
Brighton & Hove resident |
It is deflecting from the actual cause and problems of those abusing alcohol often in broad daylight but definitely in known places. |
Brighton & Hove resident |
Scrap it and come up with something better and enforce it. |
Brighton & Hove resident |
The number of problems arising from drunkenness, noise, fighting and urinating are likely to be much more nmerous than shown in the complaints made to police, because residents feel it's a waste of time repeatedly reporting the same problems. |
Brighton & Hove resident |
The supporting evidence is a reflection of the daily life trading environment that businesses operate within. |
Brighton & Hove resident |
You may need to think about revoking current alcohol licenses to stop the impact business that are currently an issue and a risk to continue trading. |
Brighton & Hove resident |
A higher concentration of licensing will probably not increase the reports of antisocial behaviour and crime. Blanket rules never work. An in depth case by case attitude to licensing would be better. Maybe look at what each establishment sells. If they sell three shots for a fiver then they’re probably gonna have more crime than a place that sells a cocktail for twenty quid. |
Brighton & Hove resident |
Although North Laine have several alcohol premises, high spot for complaints due to crime, disorder and public nuisance, recently yet another premise (on Trafalgar Street) was granted alcohol licence, so unfortunately I think this CIA will be toothless. |
Business Operator |
I do not agree that this information really supports the CIA - in some areas it actually states that crime has diminished over the stated timescale. |
Business Operator |
I have a big issue with the extent of 'off licences only' in the area and question the understanding and delivery of legal checks within these. Businesses who have teams trained and educated in Licensing, abiding by the rules and regulations with extra security measures for peak / high volume periods are delivering a far better experience for the city and economic strategy, i would question the contribution pure off licenses make or the responsibility they take. |
Business Operator |
I would want to look at problem premises specifically and not an overall as that seems counter intuitive. |
Business Operator |
Please see answer above |
Business Operator |
The
combined financial pressures on hospitality business means a
flexible approach to licensing will allow business to survive
. |
Business Operator |
The current policy has not been supported by the councillors sitting on the licensing committee. They recently approved a licence for a huge new pub in Churchill Square. The CIZ policy specifically refers to 'exceptional circumstances', for example a new theatre that would need a licence for limited alcohol sales. The large capacity venue in Churchill Square simply stated that selling cocktails was 'exceptional'. This was a total disregard of the existing policies and make a mockery of the whole process, the councillors in question were taken in by the applicants persuasive barrister, and said that they would enjoy visiting the new bar themselves, which is not a reason to grant a new premises licence to a venue for hundreds of people in the CIZ area. |
Business Operator |
You can control crime and nuisance without destroying new business and night life. No one we talk feels the city is what it was, and it’s harder than ever for young business people to do great things that have made the city so vibrant for years. |
Business Operator |
You should tackle the drugs and late time operating clubs and pubs which creates the problem you cannot just come up with a solution of not allowing new premises with licence its utter disgrace and cheap way of tackling the problem |
Not Answered |
See above. We welcome the evidence. |
Other, please give details below |
Is there a plan to further increase the CIZ, and incorporate other areas of Brighton & Hove? |
Other, please give details below |
Please extend the zone on the western boundary to St Johns Road, Hove. The western boundary is currently Holland Road and an extension to St Johns Road will include the shops between Holland Road and St Johns Road. That should help to reduce alcohol related anti-social behaviour in the gardens of Palmeira and Adelaide. |
Other, please give details below |
The draft is a sledgehammer policy that would not dare be used on say a number of places of worship placing undue stress on the local area because of parking etc |
Other, please give details below |
We believe the evidence base has evolved positively since the last consultation, incorporating a greater range of data sets obtained from a more granular level. We consider each of the data sets to be useful in isolation however would encourage further analysis to cross-reference the distribution of premises against occurrences of crime and disturbances to understand any connection that may exist. We feel this exercise would be useful to identify less vulnerable areas across the Cumulative Impact Zone where restrictions imposed by policy could be relaxed to promote opportunities to introduce more diverse uses. Following this consultation, we would welcome a publication from the Council that sets out how the data has been interrogated and how analysis has fed into any amendments to the cumulative impact policy. We feel that it is important for any changes to the policy position to be informed by a combination of consultation responses and clear trends in empirical data. |
Other, please give details below |
We believe the evidence base has evolved positively since the last consultation, incorporating a greater range of data sets obtained from a more granular level. We consider each of the data sets to be useful in isolation however would encourage further analysis to cross-reference the distribution of premises against occurrences of crime and disturbances to understand any connection that may exist. We feel this exercise would be useful to identify less vulnerable areas across the Cumulative Impact Zone where restrictions imposed by policy could be relaxed to promote opportunities to introduce more diverse uses. Following this consultation, we would welcome a publication from the Council that sets out how the data has been interrogated and how analysis has fed into any amendments to the cumulative impact policy. We feel that it is important for any changes to the policy position to be informed by a combination of consultation responses and clear trends in empirical data. |
Other, please give details below |
When looking at applications, and attending Hearings, an applicant has never been able to show that their applications will have no negative Cumulative Impact. It's subjective, isn't it? Also, what are 'Exceptional Circumstances'? What is listed is very weak. For instance, a plate of olives and a few crisps now amount to what is a 'substantial meal' waited at tables to obtain a Licence. Every applicant can say they are 'exceptional' and it is never questioned simply because it cannot be equated. |
Premises Licence Representative |
Happy with current CIA in place. |
Premises Licence Representative |
It’s commendably thorough. |
Premises Licence Representative |
Some shops such as my own have the license mainly to sell cooking wine which doesn’t impact on the community |
Premises Licence Representative |
The CIA /Z has good ideologies and principles in theory and the evidence the work and operations of the police seem to have a positive impact on antisocial behaviour related to alcohol misuse. |
Responsible Authority |
The evidence is clear that there is a lot happening within the Cumulative Impact Zone. I believe it to be unfair to in a way hold premises to account when licences have been granted over and over again. There are many pubs, bars and clubs who have restrictions on their licences to which others, like off licences etc don't have. Maybe they should have resources as part of there agreements like SIA registered staff working or closing later. I also believe some of the issues have stemmed from pubs being allowed to open later and have later licences. I do not know the data from before the late licences for pubs was introduced, however if pubs had to close earlier then there would be more people in smaller areas, which I believe in turn would help reduce the areas where resources would be needed as it would be more contained and then teams of say police could work in smaller areas and be more of a presence when necessary. |
4. Profile of Brighton & Hove residents who responded.
Postcode |
||
BN2 3HT |
||
BN1 4AR |
||
BN3 7FR |
||
BN1 2FJ |
||
BN1 4AB |
||
BN1 6PE |
||
BN1 7HB |
||
BN1 8NA |
||
BN2 0EJ |
||
BN2 1HP |
||
BN2 1QE |
||
BN2 3PJ |
||
BN2 4TP |
||
BN2 5JS |
||
BN2 5YU |
||
BN3 1NJ (x2) |
||
BN3 5HJ |
||
BN3 6FT |
||
No response (x1) |
||
How old are you? |
||
25 to 44 years old |
4 |
20% |
45 to 64 years old |
9 |
45% |
65 or older |
3 |
15% |
No response |
4 |
20% |
Total |
20 |
100% |
What gender are you? |
||
Female |
7 |
35% |
Male |
8 |
40% |
Other |
1 |
5% |
Prefer not to say |
4 |
20% |
Total |
20 |
100% |
Do you identify as the sex you were assigned at birth? |
||
Yes |
13 |
65% |
No |
1 |
5% |
Not Answered |
2 |
10% |
Prefer not to say |
4 |
20% |
Total |
20 |
100% |
How would you describe your ethnic origin? |
||
Asian or Asian British: Indian |
1 |
5% |
Mixed: Black Caribbean & White |
1 |
5% |
White: Any other White background |
1 |
5% |
White: UK/British |
11 |
55% |
White: Irish |
1 |
5% |
Not Answered |
1 |
5% |
Prefer not to say |
4 |
20% |
Total |
20 |
100% |
Which of the following best describes your sexual orientation? |
||
Bisexual |
2 |
10% |
Gay |
3 |
15% |
Heterosexual/'Straight' |
9 |
45% |
Not Answered |
1 |
5% |
Prefer not to say |
5 |
25% |
Total |
20 |
100% |
What is your religion or belief? |
||
Agnostic |
1 |
5% |
Atheist |
1 |
5% |
Christian |
5 |
25% |
I have no particular religion |
8 |
40% |
Not Answered |
2 |
10% |
Prefer not to say |
3 |
15% |
Total |
20 |
100% |
Are your day-to-day activities limited because of a health problem or disability which has lasted, or is expected to last, at least 12 months? |
||
Yes a little |
2 |
10% |
No |
13 |
65% |
Not Answered |
1 |
5% |
Prefer not to say |
4 |
20% |
Total |
20 |
100% |
Are you a carer? |
||
No |
14 |
70% |
Not Answered |
2 |
10% |
Prefer not to say |
4 |
20% |
Total |
20 |
100% |
|
||
Are you currently serving in the UK Armed Forces? |
||
No |
14 |
70% |
Prefer not to say |
4 |
20% |
No response |
2 |
10% |
Total |
20 |
100% |
Have you ever served in the UK Armed Forces? |
||
No |
14 |
70% |
Prefer not to say |
4 |
20% |
No response |
2 |
10% |
Total |
20 |
100% |
Are you a member of a current or former serviceman or woman's immediate family/household? |
||
No |
14 |
70% |
Prefer not to say |
4 |
20% |
No response |
2 |
10% |
Total |
20 |
100% |