Appendix C




DL CON ENDS 11.03.2024 VALID PCD & PPN & (A)

Dear Sir/Madam

1445/3/2024/00503/LAPREN  Beak Social Club Ltd (Trading name: BEAK MRKT)  47 Trafalgar Street (previously Thrifty Car Rentals)

Opening hours: 9am – 11.30 every day

Sale of alcohol: 9m – 10pm every day – On and Off the Premises

The premises, 47 Trafalgar St, lies within the Cumulative Impact Zone, the North Laine Conservation Area and is in a largely residential area with Frederick Place, Over St and Kemp St close by. The proposed venue is also next to a large public House, the Albert (Grade II), and close to a night club, the Green Door. Trafalgar St has 15 licensed premises already, in a street just one hundred and fifty metres long, a street which suffers more than any other street in the area from anti-social behaviour and crime and disorder. West Hill and North Laine is the ward with the highest rate of anti-social behaviour in the city and there was recently a serious stabbing just fifty metres down Trafalgar St from the premises. None of this is mentioned by the applicant in the application.

This application is contrary to the SoLP objectives of preventing crime and disorder, and the prevention of public nuisance and I ask that it should be rejected. Rather than preventing these licensing objectives, this application, if granted, will have the potential to greatly increase crime and disorder, and public nuisance in the area.

I have lived in North Laine for over 35 years and in that time, I have seen it change from being a relatively quiet and peaceful area with a strong community association to having the worst crime statistics relating to alcohol in the city. The exchange of drugs, incidents of violent behaviour, and late night noise are now commonplace and as a consequence residents are leaving the area, often with their houses then becoming short-term lets. The link between the number of licensed premises and the level of crime in an area is well established, yet licences continue to be granted to premises in North Laine which now has 90 licensed premises, three times the number it had in 2005. The Licensing Policy is quite clear on applications that will have a negative impact on crime, but the Licensing Policy does not seem to apply in North Laine. I hope that this policy is judged against the Licensing Policy. If so, it has to be refused.

I was for many years the chair of the local community Association, the North Laine Community Association and also sat on the Licensing Strategy Group. I also spoke on behalf of residents at many Licensing Panels. What was then apparent was that the default position was to grant licence applications and ignore the policy, especially paragraph 3.1.6 which states that applications for new premises licences or club premises which are likely to add to the existing Cumulative Impact will be refused following relevant representations. This presumption can be rebutted by the applicant if they can show that their application will have no negative Cumulative Impact.


In all the time I spoke to Licensing Panels I never witnessed any applicant attempting to show how their premises would not produce any negative cumulative impact. This application is for 250 drinkers. How can an additional 250 drinkers moving through North Laine fail to have a negative impact, yet the application does not mention this at all. The problem of the arrival and dispersal of drinkers moving to and from the intended venue in the numbers envisaged in this application will clearly have a negative impact on the residential streets of North Laine, particularly when The Albion are playing at home.


This application is contrary to the SoLP for the following reasons:

Section 1.9.1 refers to promoting community well-being. This application will further erode community cohesion as it will increase anti-social behaviour and particularly late-night noise.


1.11.1 The Human Rights Act 1998 in Article 1 of the First Protocol states that everyone is entitled to the peaceful enjoyment of their possessions. I assume this includes the right to enjoy their home peacefully without having to suffer the late night noise that North Laine residents have had to put up with since the advent of 24 hour drinking.

2.1.5 The data available in the Public Health Framework is a valuable tool to assess the impact of potential licences. The latest report from 2019 has St Peter’s and North Laine as the worst ward in Brighton and Hove for alcohol related violence, criminal damage, increasing risk or higher risk drinking and alcohol suspected ambulance call outs. A more recent report, Community Insight Brighton and Hove (May 2023) puts the North Laine and West Hill ward as the worst ward in the city for anti-social behaviour. This application will not do anything to reduce these figures.

3.1.3 and 3.1.6 North Laine is now in the Cumulative Impact Zone (CIZ), an area where the concentrated number of premises is causing problems of crime and disorder and public nuisance. The policy states that applications for new premises licences or club premises certificates within the area, or variations which are likely to add to the existing Cumulative Impact, will be refused following relevant representations. This presumption can be rebutted by the applicant if they can show that their application will have no negative Cumulative Impact.

The problem of the dispersal of drinkers in the City centre is recognised in the SoLP and it is clear that premises for 250 drinkers will cause additional noise and disturbance as they go to and from the premises (through North Laine). There cannot be any doubt about this. Movement to the venue and dispersal from it by this number of people going through the narrow North Laine streets will cause extra noise that will be heard from within the small, terraced houses that front the streets of North Laine. It states in paragraph 3.1.9 that if an application is unlikely to add to the cumulative impact of the area, it may be granted. However there is absolutely no doubt that this application would cause additional noise and disturbance at the very least and likely to cause additional crime and disorder. North Laine already suffers severely from the movement of drinkers through the area and this application must be refused given the impact it would certainly have on the area.

In section 3.1.9 it even states that a high capacity public house might add to problems of cumulative impact

This venue would be a perfect venue for stag and hen parties and especially one for football supporters as it is so close to the station. What arrangements have been planned for dealing with sets of football fans on Brighton and Hove FC match days?

The Matrix This application contravenes the matrix which should be strictly adhered to. This application is for a pub and the matrix says No to pubs within the CIZ, in fact it says Departure from the matrix policy is expected only in exceptional circumstances. I can see no exceptional circumstances which might apply in this application. If it is exceptional, it is because of the size of the premises in an area where homes and business premises are small scale to fit in with the character of the area.

The SoLP states that consideration will be given to the nature of the area and location in relation to any application. In a residential area for example the concerns of local residents will be relevant when considering applications for off-licences, pubs or cafes, especially if there is evidence of anti-social behaviour, street drinking or underage drinking. Earlier closing times may be appropriate. Regard will be had to the Public Health Framework for assessing alcohol licensing on our website

I ask that the interests of the local residents of North Laine be taken into account, and this application be judged against the Licensing Policy. In which case the Licensing Panel will have no alternative but to reject this application for the reasons given above.

I attach below a list of Licensed premises in North Laine already, and highlight those in Trafalgar St.


Kind regards



I attach below a list of licensed premises in North Laine

Licensed Premises in the North Laine as at February 2024

1.          Moccata House, Trafalgar Place, Trafalgar St

2.          The Albert, 48 Trafalgar St

3.          St Noha News, 41 Trafalgar St (24 hrs)

4.          Easy News, 30 Trafalgar St (24 hrs)

5.          Oliver’s 45 Trafalgar Street (shop closed Jan 2023, but sells ‘Wizards Gold’ alcohol)

6.          The Laine Deli, 31 Trafalgar Street/Corner of Kensington Place

7.          Lord Nelson Inn, 34 – 36 Trafalgar St

8.          Cut Your Wolf Loose, 23 Trafalgar Street (Pub by stealth. No substantial food. Variation for On

   Sales granted May 2020. A bar, when no bars or pubs allowed under SoLP Matrix.)

9.          Toyito (was O’Shio) restaurant, 87 Trafalgar St/corner of Whitecross St

10.      Mange Tout, 81 Trafalgar St

11.      Bread and Milk, 82 Trafalgar St

12.      Piccolo (previously Breeze, followed by Ciao Bella), Trafalgar St (Closed end ’19)

13.      Le Baobab Cuisine, Trafalgar St

14.      Prince George, 5 Trafalgar St

15.      Great Eastern, 103 Trafalgar St

16.      Blueberry’s, 1 Trafalgar St

17.      Grind and Slice, 15 Trafalgar Street

18.      Lucky Star Chinese Restaurant, 101 Trafalgar St

19.      Trafalgar News, 95 Trafalgar St (Off Sales to 11pm)

20.      The Green Dragon (was The Office), 8 – 9 Sydney St

21.      Café 16, 16 Sydney Street

22.      Yum Yums, 22-23 Sydney Street

23.      The Roastery, By Trading Post 13-14 Sydney Street

24.      Si Signore, 12 Sydney St includes Off Sales

25.      Good News, 33 Sydney Street (Off Sales)

26.      Cala Arboras, Sydney St

27.      The Eagle, 125 Gloucester Rd

28.       Basketmakers Arms, 12 Gloucester Rd/corner of Cheltenham Place

29.       Brighton Tavern, 99 – 100 Gloucester Rd

30.      Trawlerman (Fish n’ Chip shop) 106 Gloucester Rd

31.      The Pond, 49 Gloucester Rd

32.      Gloucester Newsagents, 107 Gloucester Rd

33.      Pinot & Picasso, 127 Gloucester Rd

34.      La Choza, 36 Gloucester Rd/corner of Queens Gardens (includes Off Sales)

35.      The Blue Man (previously Neighbourhood) 95 Gloucester Rd/corner of Kensington Place

36.      Fatto a Mano, 25 Gloucester Rd/corner of Kensington Gardens

37.      Meat Bread Wine (was Isaac @) 2 Gloucester St

38.      Foundry/Pedestrian Arms, 13 – 14 Foundry St

39.      Three Jolly Butchers, 59 North Rd

40.      Oseta Cafe, 34 North Rd

41.      Barbers (was Spirit Hunter), 32 North Rd (Off Sales)

42.      The Heart and Hand, 75 North Rd/corner of Gardner St

43.      Dorset Arms, North Rd

44.      Infinity Foods, 25 – 27 North Rd (Off Sales)

45.      Wagamamas, North Rd

46.      Helm Gallery Ltd (was Burgers and Cocktails) 15 North Rd

47.      Bills, 100 North Rd (On and Off Sales)

48.      Bus Stop, North Rd (Closed end of 2019)

49.      Fountain Head, 101 – 103 North Rd

50.     Bison Beer, 103 North Rd (closed Jan ’24, building still has alcohol licence)

51.     Wai kika moakau, Kensington Gdns

52.     White Rabbit, 13 – 14 Kensington Gdns

53.     Trading Post Coffee Roasters (was Grow 40) Kensington Gdns/North Rd (includes Off sales)

54.     Barneys Delicatessen,39 Kensington Gdns (Off Sales granted 20 Oct 2020) (Closed Jan   2023 –

  building still has alcohol licence)

55.     The Basement, 24 Kensington St

56.     Lighthouse Arts, 28 Kensington St

57.     Dead Wax Social (was Riki Tiki), 18A Bond St (often causes late night asb)

58.     Taylors Tobacconists, 19 Bond Street (Off Sales)

59.     Komedia, 44 – 47 Gardner St

60.     Gourmet Burger Kitchen, 44 – 47 Gardner St (includes Off Sales)

61.     Lavash (The Manor), 52 Gardner St

62.     Café Laziz, 48 Gardner St

63.     Goemon Ramen Bar, 50 Gardner St

64.     North Laine Newsagent, 55 Gardner St

65.     North Laine Deli (ex Poutine City (ex Hell’s Kitchen), 4 Gardner Street (includes Off Sales)

66.     Wolfox Health Café, 47 Gardner Street

67.     640 East (was Silo), 39 Upper Gardner St 

68.     Ten Green Bottles, 9 Jubilee Street (includes Off Sales)

69.     Iguanas, 7 – 8 Jubilee St

70.     More than Sushi, Jubilee St

71.     Pizza Express, Jubilee Sq, New Road

72.     Chilli Pickle, Jubilee St/Jubilee Sq

73.     My Hotel, Jubilee St

74.     Tesco, 5 Jubilee St

75.     The Captain Pig, 10 Church St (Off Licence granted 22 Aug ’19) contravening CIZ, SoLP, and

   ignoring EHL’s objection)

76.     Five Guys Ltd (was Carluccio’s), 6 Jubilee St/Church St

77.     William IV, 4 Church St/corner of Bond St

78.     Wagon and Horses, 109 Church St/corner of Jubilee St

79.     Brunswick Fine Wines and Spirits, 15 New Road (On and Off Sales)

80.     Bodega & Tapa, New Rd

81.     Tonkotsu (Polpo) (The Courtyard), 20 New Road

82.     Red Roaster, New Rd (On and Off Sales)

83.     Longrain Theatre – café/bar, (Sumatra Ltd) 31-32 New Rd (open till 2am; incudes Off sales)

84.     Black Horse Inn, 112 Church St

85.     2 Church Street, café/wine bar

86.     Earth and Stars, 46 Windsor St/corner of Church St

87.     Tesco, 104-106 Queens Road/rear of Frederick St

88.     The Green Door Store, Undercroft Brighton Station, top of Trafalgar St (24 hrs)

89.     Cotes, The Old Music Library, Church St

90.     Wetherspoons, corner Bond St/North Rd

91.     CIN CIN, 15 Vine Street

92.     Vine Street Tap, 15-16 Vine Street Tap, Unit 3

93.     The Ironworks, Cheapside

94.     The Wine Cellar, 17 Marlborough Place

95.     Tutto, 20-22 Marlborough Place (Grade II listed building)




































                                                                                                                Brighton & Hove Licensing Unit


Police Station

John Street




Tel: 01273 404535 ext 550809



8th March 2024

The Licensing Technical Support Officers
Environmental Health, Brighton & Hove City Council
Bartholomew House, Bartholomew Square
Brighton, East Sussex


Dear Donna Lynsdale,




I write on behalf of the Chief Officer of Police for Sussex to raise a representation against the application for a premises licence for the above address on the grounds that it will undermine the Licensing Objective of the prevention of crime and disorder. We also make reference to the Brighton & Hove City Council (BHCC) Statement of Licensing Policy (revised January 2021) and and the Public Health Framework for Assessing Alcohol Licensing.


This is a proposed variation licence application in an area of the City which is subject to a Special Policy adopted by Brighton & Hove City Council. The premises lies in the Cumulative Impact Area (CIA) (as defined in the BHCC Statement of Licensing Policy) and seeks the following hours and licensable activities:


Supply of Alcohol (on and off the premises)


                Every Day:        09:00 – 23:00


Opening hours


Every Day:        09:00 – 23:30




Within the 2021 Brighton & Hove City Council (BHCC) Statement of Licensing Policy, this premises is within the Cumulative Impact Area. The policy which is generated using data from various agencies including Police and is one we fully support, and it recognises that the location has a significant number of licensed premises concentrated in one area.

When considering any application, we refer to the matrix within the Statement of Licensing Policy which sets out the expectations for new and varied applications for the City. Within the Cumulative Impact Area – a Pub is a “No”


The application itself has not mentioned the Cumulative Impact area and no specific reference to potential cumulative impact issues has been made. Local concerns that the area faces have not been addressed.

A number of conditions have been offered in the application, but they do not go far enough to mitigate the concerns of Sussex Police or offer exceptional circumstances for a new pub, hosting over 200 customers to be granted in the Cumulative Impact Area.


The night-time economy within Brighton & Hove can at times be challenging for all the emergency services. Within Brighton & Hove we are unique in that we have a high number of licensed venues all of which are in very close proximity to each other and is inclusive of licensed premises around the Train Station.


Due to the risks associated with intoxication, the city has several initiatives that support Police and other emergency services in safeguarding the public. These include Beach Patrol and Safe Space. More recently alongside the Council, Police have jointly assisted in funding Night Safety Marshalls who are SIA registered security staff with numerous training sessions completed to be able to deal with the challenges they might come across patrolling on foot within the night-time economy at the weekends between 8pm and 4am with the focus on vulnerability. Additionally taxi marshals have also been employed to assist with reducing issues occurring at taxi ranks in the early hours. Many of these organisations and persons involved are volunteers and operate in their spare time. The fact these safeguarding services are needed and exist goes a long way to prove the negative impact alcohol has within the night-time economy.

With high numbers of persons descending on the city especially at the weekends Sussex Police operate a standalone night-time operation each weekend and at other various peak times throughout the year. This involves dedicated Police resources patrolling the main night-time economy area to free up our night duty officers so they can manage the rest of the city and the demands it has on our service. Having a visible police presence in the area goes some way to assist in reducing criminal incidents occurring, but unfortunately does not stop them in their entirety. Most incidents dealt with have an element of alcohol and drugs linked to them. This is a mix of persons becoming drunk and disorderly, violent and a high number of incidents involve persons who have become a victim of crime such as sexual assaults and robberies due to their own vulnerability after consuming alcohol. Staff at venues and emergency services are also far too often at the end of a drunk person’s aggression.


Looking at incidents which Sussex Police have dealt with within a 1 mile radius of the venue between the 8th March 2024 and 8th March 2024 we have dealt with a huge number of incidents including 146 for violent crime, 210 thefts and 54 Crime Public order. Sussex Police would like to highlight that these crimes have occurred throughout the daytime as well as the Nighttime Economy with 37 Crimes occurring at 10:00, 38 crimes occurring at 15:00, 44 crimes occurring at 18:00.  Therefore, there are concerns that a new and additional licenced premises in this location could have a negative impact and cause these numbers to increase.


Sussex Police are aware of the local ward changes, however within the Public Health Framework, this premises is in the St. Peter’s and North Laine Ward, which is the worst for Police recorded alcohol related incidents and Criminal Damage. Second Worse for All Injury Violence, All violence against the person and sexual offences


Applications for new or varied premises licenses within this area which are likely to add to existing cumulative impact will be refused following relevant representations. This can be rebutted by the applicant if they can show that their application will have no negative cumulative impact. On reading the application we do not feel exceptional circumstances have been put forward by the applicant to justify departing from the policy or to offer any reassurance that consideration has been given to the licensing objectives to operate into the CIZ. Therefore, Sussex Police invite the Licensing Authority to seriously consider refusing this application.



Yours sincerely,






A/Inspector Mark Redbourn

Licensing – Brighton & Hove Division

Sussex Police


Please address all future correspondence to Brighton & Hove Licensing Unit, Police Station, John Street, Brighton, BN2 0LA.





































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Description automatically generated
Regulatory Services
Bartholomew House
Bartholomew Square








Licensing Authority

Brighton & Hove City Council

Bartholomew House

Bartholomew Square





Our Ref:



11 March 2024

ELG/ 2024/00472/LICREP




Dear Donna


Licensing Act 2003 

Beak MRKT, 47, Trafalgar Street, Brighton.


I wish to make a representation against a new application for Beak MRKT, 47, Trafalgar Street, Brighton. The application is for a premises licence for the sale of alcohol from 09:00 until 23:00 Monday to Sunday on and off the premises.


The grounds for the representation are that it is contrary to the Council’s Statement of Licensing Policy (SoLP) as the premises falls within the cumulative impact area and may undermine the Licensing objectives Prevention of Crime and Disorder and Prevention of Public Nuisance.


The SoLP recognises the importance and value of the night-time economy as part of the city’s cultural and tourism offer, which is crucial in the ongoing economic success of the city, as well as providing a safe and diverse environment for both residents and visitors to enjoy. However, the Council also recognises the impact the night-time economy can have on people’s safety, health and wellbeing. The Council’s licensing authority has created special policies, including Cumulative Impact and the Matrix Approach and Night-time Economy Safeguarding Initiatives, designed to restrict the amount of licensable premises in the city centre and promote good practices to minimise the adverse impact of alcohol-use.


The Licensing Authority’s Cumulative Impact area (CIZ) was adopted to give greater power to control the number of licensed premises within the city centre. The special policy was set up because the Licensing Authority determined that the concentration of licensed premises and the subsequent numbers of people drawn into the city centre is causing exceptional problems of crime and disorder and public nuisance. The effect of this special policy is that applications for new premises licences or club premises certificates within the area, or variations which are likely to add to the existing Cumulative Impact, will be refused following relevant representations. This presumption can be rebutted by the applicant if they can show that their application will have no negative Cumulative Impact.


The Council’s SoLP includes a Matrix approach for licensing decisions with provisions for a terminal hour for all classes of licensed premises in a particular area. The Matrix Model recognises the diverse operation and different risks presented by different classes of licensed premises.  It provides a vision of what the Licensing Authority would like to see within its area and gives an indication of likelihood of success or otherwise to investors and local businesses making applications. 


This application describes the proposal as a welcoming, vibrant and easily accessible street food market showcasing food from independent businesses, along with locally produced ales and low intervention wine. This does not fall within the categories identified in the matrix. The matrix states that applications for restaurants will be considered favourably until midnight and cafes until 10:00pm for premises in the CIZ. Off sales are not permitted in the CIZ in the matrix. However each application must be considered on it’s own merits.


Guidance issued under S182 of the Licensing Act 2003 states that in completing an operating schedule, applicants are expected to have regard to the statement of licensing policy for their area. The guidance goes on to say that applicants are expected to include positive proposals in their application on how they will manage any potential risks.  Where specific policies apply in the area (for example, CIZ), applicants are also expected to demonstrate an understanding of how the policy impacts on their application, any measures they will take to mitigate the impact, and why they consider the application should be an exception to the policy. 


The policy does state that each application is still considered on its individual merit and there is discretion to depart from the policy where justified. However, departure from the Matrix Model is only expected in exceptional circumstances.


When considering whether representations should be submitted, the Licensing Team have regard to the ‘Public Health Framework for assessing Alcohol Licensing’ – (accessed at  Public Health Framework for Assessing Alcohol Licensing | Tableau Public) document. The premises sits within the newly named electoral ward of West Hill & North Laine, which in the Framework document is under the old Ward name of St Peter’s & North Laine.  Under ‘Crime and Disorder data’ it is second worst out of 21 wards for all violence against the person, all injury violence, non-injury assault and sexual offences. It is also worst for police recorded alcohol related incidents and criminal damage. Within the recorded ‘Health data’, the premises sits in the second worst ward for alcohol suspected ambulance call outs.


The Licensing Team therefore makes this representation to uphold our Statement of Licensing policy. The Policy is predicated on too much alcohol being available and applications for new premises licences will be refused unless the applicant can demonstrate exceptional circumstances. It is up to the applicant to demonstrate this and satisfy a Licensing Panel that they will not impact negatively on the CIZ.  As the application stands at the moment, I feel that this application should be considered and determined by a Panel.



Yours sincerely,



Emma Grant, 

Licensing Officer













DL CON ENDS 11.03.2024 VALID PPN (D)

Sent: Monday, March 11, 2024 3:51 PM
To: EHL Licensing <>
Subject: Re: Licence - 1445/3/2024/00503/LAPREN


Hi Donna

I confirm that I am making a formal representation because of public nuisance on the following -

Can there are no tv screens and no music (taped or live) allowed on the premises. This would ensure that this is not a destination for football fans and also hen and stag nights.

I would also ask that if Beak vacate the premises, the licence is surrendered. This will make sure that a craft beer bar does not become a beer warehouse.

I think that the closing time should be earlier as there will be 250 people dispersing through North Laine at 23.30. I live in REDACTED which will be a route that they will use. I would prefer that the closing time is 2130 so that everyone is dispersed by 2200.

Finally, can there be a time limit on off sales so that there are none allowed after 20.00. This will mean that people who are leaving do not have lots of beer to drink on their way through the area and then throw the litter into the area


























DL CON ENDS 11.03.2024 VALID PCD & PPN (E)

Sent: Monday, March 11, 2024 5:51 PM
To: EHL Licensing <>
Subject: 1445/3/2024/00503/LAPREN



Dear Licensing Team,


I’m writing to object to the alcohol licensing application being made for 47 Trafalgar Street. 


We live on REDACTED and are neighbours to this property. We have concerns about the development and its proposed licensing hours:  9:00am-10:00pm, with a venue close time of 11:30pm, 7 days a week. 


Our home REDACTED. We have bedrooms and our only (small) area of outside space just a few metres away from the site. We are really worried about the impact of having a venue that can sell alcohol for 13+ hours a day, every day of the week. The noise nuisance, as well as potential anti-social behaviours of people coming to the venue, is a significant concern. 


We would also like to better understand the plans for managing security at the venue. In addition, the application has a capacity of up to 250 people. With a new licence granted for access to alcohol in the area all day, 7 days a week, then there is further potential for negative impact on public order and anti-social behaviours. 


If the Council are minded to grant this new licensing application, then we would very strongly request for limitations to be made on operating hours and serving times e.g. not 7 days a week, consideration of an earlier closing time in the evening. 


We are supportive of developments to the site that will help restore and regenerate North Laine. 


We would welcome further consultation with the applicant about their proposal and to provide further information/ details that will help. The noise report and acoustics survey that has been submitted as part of the planning application appears to focus on The Prince Albert but does not address other residents including neighbours on REDACTED.