APPENDIX C

REP A

Police Station

John Street

Brighton

BN2 0LA

Email: brighton.licensing@sussex.police.uk

18^th July 2025

The Licensing Technical Support Officers
Environmental Health, Brighton & Hove City Council
Bartholomew House, Bartholomew Square
Brighton, East Sussex
BN1 1JP

SC CON END 25.07.2025 VALID PCD, PPN & CIZ (A)

Dear Sarah Cornell,

RE: APPLICATION FOR A NEW PREMISES LICENCE FOR STATION GRILL, 62 QUEENS ROAD, BRIGHTON, BN13XD UNDER THE LICENSING ACT 2003.

I write on behalf of the Chief Officer of Police for Sussex to raise a representation against the grant of the above application on the grounds that it will undermine the Licensing Objectives of the prevention of crime and disorder and public nuisance. We also make reference to the Brighton & Hove City Council (BHCC) Statement of Licensing Policy.

This is a proposed new 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 (CIZ) (as defined in the BHCC Statement of Licensing Policy) and seeks the following hours and licensable activities:

Late Night Refreshment (Both)

Every Day 23:00 – 05:00

Opening hours

Every Day: 23:00 – 05:00

Paragraph 3.1.2 of the Brighton and Hove City Council 2021 Statement of Licensing Policy states:

“The licensing authority, after careful consideration, has determined that the concentration of licensed premises in an area of the city centre is causing problems of crime and disorder.”

In accordance with the Statement of licensing policy this application would be a “NO”

This premises lies within what was the Regency Ward which within the Brighton & Hove Public Health Framework for Assessing Alcohol Licensing and is ranked number 1 for All injury Violence, All violence against the person and Sexual Offences. Additionally, it’s ranked number 2 for Police recorded alcohol related incidents, demonstrating the higher risk to the Licensing Objective of the Prevention of Crime and Disorder in this area.

Recent incident & crime statistics indicate that during the period of 18^th July 2024and 18^th July 2025 there were 297 crimes linked to Queens Road and surrounding side roads. The majority of these incidents were recorded as Violence against the person, anti-social behaviour and thefts.

This shows a slight increase in crimes from the previous searches which was run between October 2023 – October 2024 where there were 271 crimes recorded and May 2024 – May 2025 where there were 283 crimes linked to Queens Road.

There was also 11 Sexual Assaults reported along Queens Road in this 12-month period which again is an increase from the statistics provided between May 2024 and May 2025.

To assist with the history, I have attached the two previous Sussex Police Representation letters to assist with evidencing the crime and disorder statistics in this area that has been recorded.

With the area already experiencing high number of incidents which occur throughout the day and night, permitting a premises to be open throughout the entire night time economy is likely to increase incidents in the locality, which is already a busy thoroughfare road to and from the city centre and the train station and is populated with many Licensed premises all varying from Pubs, off licences and Late Night Refreshment venues.

While Sussex Police acknowledge that the premises application is not asking for the sale of alcohol, offering food and drink into the early hours encourages persons who may be under the influence of alcohol or drugs to remain in the area, which has a number of residential flats and properties. This increases the risk of crime and disorder, anti-social behaviour and public nuisance in an area that is already evidenced to be problematic.

Sussex Police are aware that the applicant has previously submitted two applications for a premises licence at this address, both have been previously refused and Sussex Police are concerned how this application has been submitted so quickly, less than 24 hours following the last Panel decision.

The applicant has asked in the application for the 2 previous applications not to be linked, as all the circumstances have changed. However, Sussex Police are unsure of this as there was only 20 hours between the panel decision and this application being submitted.

A large number of emails have been received from the applicant with supporting evidence, these have been acknowledged as received by the Police Licensing team.

The applicant was advised in the second panel hearing to consider pre consulting with Sussex Police and advised to have a meeting with the licensing team to discuss concerns. The Applicant has not pre consulted with the police before this application was submitted.

In the application, the applicant states this premises is a restaurant. However, again the confusion remains that from Midnight the applicant has offered no dining in facility and from Midnight until 05:00 will be operating as a deliveries and collection services throughout the majority of the licensable hours.

If no dining facility is offered, Sussex Police believe this premises will be trading as a takeaway as all of the food ordered will be collected and eaten away from the premises, which is likely to see persons collecting and eating their food in public spaces again leading to congregation along Queens Road.

Sussex Police have little confidence in the applicant and fear should a licence be granted until 05:00 every day, which is now a later time again than previously applied for in the previous applications.

Sussex Police could see an increase in crime and disorder as the applicant would not be able to operate knowledgably.

Sussex Police have noted that the applicant has asked for this application not to be linked to the previous applications in their operating schedule, however, point 43 in the operating schedule links to concerns raised by police over the congregation of persons along Queens Road in application 2, please see attached the Representation letter.

The point evidenced by the police in this letter, is the fact that this premises closes at 23:00 dispersed persons along Queens Road back up to the train station.

Sussex Police would also like to note that this premises is not the only premises who provide Egyptian and Turkish food, there are other premises across Brighton and Hove who offer Middle Eastern food and have late licences.

Although we are unable to support this application and are now seeking refusal for the third time, if the Licensing Panel are minded to grant this application at the hearing, Sussex Police have attached conditions and ask that these conditions are added to the Premises Licence, taking into account the request that the premises trades only for deliveries from Midnight until 2am. The conditions being offered unfortunately do not mitigate fully the risks should this premises trade until 05:00am. They go some way to reduce incidents occurring within the premises itself but there are no conditions that can address the risks once customers have departed. The risks of them becoming a victim of crime or them partaking in criminal activity is one that will need to be dealt with by the emergency services. Or if public nuisance issues occur, then this will be for the environmental officers to pick up.

Therefore, Sussex Police invite the Licensing Authority to seriously consider refusing this application.

Attached proposed conditions.

Yours sincerely,

REDACTED

Insp Ben Morrison

Ops Planning and Events (inc. Licensing) Inspector

Brighton & Hove Division

Sussex Police

Police Licensing Representation Letter 19^th May 2025

Police Station

John Street

Brighton

BN2 0LA

Email: brighton.licensing@sussex.police.uk

19^th May 2025

The Licensing Technical Support Officers
Environmental Health, Brighton & Hove City Council
Bartholomew House, Bartholomew Square
Brighton, East Sussex
BN1 1JP

Dear Emily Fountain,

RE: APPLICATION FOR A NEW PREMISES LICENCE FOR STATION GRILL, 62 QUEENS ROAD, BRIGHTON, BN13XD UNDER THE LICENSING ACT 2003.

Late Night Refreshment (Both)

Every Day 23:00 – 03:00

Opening hours

Every Day: 23:00 – 03:00

Paragraph 3.1.2 of the Brighton and Hove City Council 2021 Statement of Licensing Policy states:

“The licensing authority, after careful consideration, has determined that the concentration of licensed premises in an area of the city centre is causing problems of crime and disorder.”

In accordance with the Statement of licensing policy this application would be a “NO”

Recent incident & crime statistics indicate that during the period of 18^th May 2024and 16^th May 2025 there were 283 crimes linked to Queens Road and surrounding side roads. The majority of these incidents were recorded as violent crime in a public place and thefts.

This shows a slight increase in crimes from the previous search which was run between October 2023 – October 2024 where there were 271 crimes recorded.

There was also 9 Sexual Assaults reported along Queens Road in this 12-month period.

With the area already experiencing high number of incidents which occur throughout the day and night, permitting a premises to be open into the night time economy is likely to increase incidents in the locality, which is already a busy thoroughfare road to and from the city centre and the train station and is populated with many Licensed premises all varying from Pubs, off licences and Late Night Refreshment venues.

PC Wade and Licensing officer Hannah Staplehurst worked a night shift on Saturday 10^th May 2025. At 23:05 they travelled along Queens Road and witnessed large groups of people congregating at a Late Night Refreshment (LNR) premise. We were unable to access this premises due to the crowd growing along the pavement, however at this time Station Grill 62 Queens Road was closing and this dispersed some of the groups and encouraged them to continue towards the train station.

At 23:45 we visited Queens Road again to visit the LNR premises and crowds were less busy and manageable inside the premises however we were unable to stop due to a few arrests that were taking place on the opposite side of the road, because Police Constables had been assaulted and Queens Road was busy with a number of police vehicles and Police Constables.

I have previously worked with the applicant throughout the consultation period for their first application which was submitted in 2024 and after a licensing hearing this application was refused. Sussex Police are aware the applicant has appealed this decision and are concerned that should be this second application be granted while the first application is in the appeal process, this would encourage a Judge to grant a second licence at appeal as the police concerns and crime data would be dismissed.

The applicant may have been trading during a day for a few months now, but they haven’t traded along Queens Road, nor in Brighton during the Night time economy and seemed to have little understanding of the crime and disorder associated with this area. Security has since been offered when requested by the police, the applicant has not offered specific days and times themselves.

Sussex Police are also confused over what the applicant is applying for. I note on this application they are now applying for 03:00 every day which is an hour longer on a Sunday – Thursday than the first application.

The application also says they are a restaurant offering delivery services, but in Subsection A under section 18 of the application it states “Also, will offer collection services for customers already exciting in the city centre”

During this Consultation period, Licensing Officer Hannah Staplehurst asked for clarification for what the applicant was applying for, and asked for clarity why this application had been submitted while an appeal is progressing with the first court hearing imminent.

Please find below part of the reply that was received

“My first application was not for take away. I confirmed many times that my shop is a restaurant and not a take away shop.

serving dine in , delivery and collection DOES NOT mean that it is a take away. all restaurants including Macdonalds and KFC are restaurants and they offer delivery and food collection services.”

Sussex Police would disagree that during the first hearing the applicant stated he was applying for a restaurant as the applicant offered to have a hatch cut in the window at the front in order to pass food to customers waiting on the pavement. Which would possibly mean the tables and chair would have to be removed for this area.

Sussex Police would also disagree and would state that deliveries and collections are in fact take aways as the definition of a take away is where a customer buys food from a premises to be eaten elsewhere.

Sussex Police have little confidence in the applicant and fear should a licence be granted until 03:00 every day, Sussex Police could see an increase in crime and disorder as the applicant would not be able to operate knowledgably.

Lastly there was issues raised around the Blue notice the applicant had to display as part of this application process. Licensing officer Hannah Staplehurst and PC Wade drove past on the 24^th April 2025 and they are able to confirm that there was no Blue Notice on display and spent photos to the BHCC Licensing team. This further raise concerns in the confidence of the applicant to complete licensing conditions.

Although we are unable to support this application and are now seeking refusal for the second time, if the Licensing Panel are minded to grant this application at the hearing, Sussex Police have attached conditions and ask that these conditions are added to the Premises Licence, taking into account the request that the premises trades only for deliveries from Midnight. The conditions being offered unfortunately do not mitigate fully the risks should this premises trade until 03:00am. They go some way to reduce incidents occurring within the premises itself but there are no conditions that can address the risks once customers have departed. The risks of them becoming a victim of crime or them partaking in criminal activity is one that will need to be dealt with by the emergency services. Or if public nuisance issues occur, then this will be for the environmental officers to pick up.

Therefore, Sussex Police invite the Licensing Authority to seriously consider refusing this application.

Attached proposed conditions.

Yours sincerely,

REDACTED

Insp Ben Morrison

Ops Planning and Events (inc. Licensing) Inspector

Brighton & Hove Division

Sussex Police

Police Licensing Representation Letter 23^rd October 2024

Police Station

John Street

Brighton

BN2 0LA

Email: brighton.licensing@sussex.police.uk

23^rd October 2024

The Licensing Technical Support Officers
Environmental Health, Brighton & Hove City Council
Bartholomew House, Bartholomew Square
Brighton, East Sussex
BN1 1JP

Dear Emily Fountain,

RE: APPLICATION FOR A NEW PREMISES LICENCE FOR STATION GRILL, 62 QUEENS ROAD, BRIGHTON, BN13XD UNDER THE LICENSING ACT 2003.

Late Night Refreshment (Both)

Sunday – Thursday: 23:00 – 02:00

Friday – Saturday: 23:00 – 03:00

Opening hours

Sunday – Thursday: 23:00 – 02:00

Friday – Saturday: 23:00 – 03:00

Paragraph 3.1.2 of the Brighton and Hove City Council 2021 Statement of Licensing Policy states:

“The licensing authority, after careful consideration, has determined that the concentration of licensed premises in an area of the city centre is causing problems of crime and disorder.”

In accordance with the Statement of licensing policy this application would be a “NO”

Recent incident & crime states indicate that during the period of 23^rd October 2023 and 23^rd October 2024 there were 271 incidents linked to Queens Road and surrounding close by side roads. The majority of these incidents were recorded as violent crime in a public place and thefts.

There is also 11 Sexual Assaults reported along Queens Road in this 12 month period.

I have attempted to work with the applicant throughout the consultation period. Please find attached to this letter the proposed conditions that were sent to the applicant.

Sussex Police offered a condition that would allow the applicant to trade as a restaurant until Midnight but then lock their door and trade for deliveries only.

Unfortunately, this condition has not been agreed, along with Conditions 5, 6, 7.

Conditions number 1, 3, 4, 8, 9 and 10have been agreed.

However, a further concern which was highlighted following a phone conservation with Police Licensing Office Hannah Staplehurst is, the applicant had no knowledge of the BHCC Statement of licensing policy and wasn’t aware the premises is located in the CIZ.

They haven’t traded along Queens Road, nor in Brighton and seemed to have little understanding of the crime and disorder associated with this area.

Although we are unable to support this application and are now seeking refusal, if the Licensing Panel are minded to grant this application at the hearing, Sussex Police have attached the conditions proposed to the applicant and ask that these conditions are added to the Premises Licence, taking into account the request that the premises trades only for deliveries from Midnight. The conditions being offered unfortunately do not mitigate fully the risks should this premises trade until 02:00/03:00am. They go some way to reduce incidents occurring within the premises itself but there are no conditions that can address the risks once customers have departed. The risks of them becoming a victim of crime or them partaking in criminal activity is one that will need to be dealt with by the emergency services. Or if public nuisance issues occur, then this will be for the environmental officers to pick up.

Therefore, Sussex Police invite the Licensing Authority to seriously consider refusing this application.

Attached proposed conditions.

Yours sincerely,

REDACTED

Insp Daniel Eagle

Ops Planning and Events (inc. Licensing) Inspector

Brighton & Hove Division

Sussex Police

Police Licensing Proposed Conditions

Station Grill, 62 Queens Road, Brighton Proposed Conditions

Timings

Restaurant until Midnight

Deliveries – until 02:00

Conditions

General

Authorised staff employed by Sussex Police in the role of licensing officer shall have the right of access to the licensed premises during hours of operation for the purpose of inspection of the premises and premises records in order to ensure the promotion of the licensing objectives.
The premises will operate as a restaurant until 23:59pm. From Midnight (00:00) until close the premises will be closed to customers (there will be no takeaways or eating in after that time), The premises door will be locked during these times and opened only to allow delivery persons to collect orders. and only deliveries will take place. Clear signage will be placed on the door to advising potential passing customers that the premises is closed.
All delivery orders shall be to a registered residential or business address. There shall be no deliveries to public/communal areas or open spaces.

Prevention of crime & disorder

Subject to GDPR guidance and legislation:

(a) Digital CCTV and appropriate recording equipment to be installed in accordance with Home Office Guidelines relating to UK Police Requirements for Digital CCTV System (PSDB Publication Number 09/05), operated and maintained throughout the premises internally and externally to cover all public areas, including the entrances/exits to the premises as well as any outside space. The system shall be on and recording at all times the premises licence is in operation.

(b) The CCTV cameras and recording equipment must be of sufficient quality to work in all lighting levels inside the premises at all times.

(d) The management will give full and immediate cooperation and technical assistance to the Police in the event that CCTV footage is required for the prevention and detection of suspected or alleged crime.

(e) The CCTV images will record and display dates and times, and these times will be checked regularly to ensure their accuracy.

(f) The management of the premises will ensure that key staff are fully trained in the operation of the CCTV, and will be able to download selected footage onto a disk (or other electronic portable device acceptable to Police e.g. USB) or provide footage via an online link as initiated by Police, without difficulty or delay and without charge.

(g) Any breakdown or system failure will be notified to the police immediately & remedied as soon as practicable - brighton.licensing@sussex.police.uk.

(h) In the event of the CCTV system hard drive being seized as evidence as part of a criminal investigation by Police or for any other reason, the premises will be expected to install a replacement hard drive, or a temporary replacement drive as soon as practicable.

SIA licensed door supervisors shall be employed on any other occasions when a requirement is identified by the licence holder's written risk assessment or requested by Sussex Police in writing at least 48 hours in advance. The written risk assessment will be reviewed at least once every calendar year. The written risk assessment will take into account information or guidance offered by the police, and also taking into account busy periods such as Bank Holidays, Season Variations and other City Events e.g. Football, Pride, Music Events. The written risk assessment will be available on the premises for inspection by police and authorised officers of the Licensing Authority.

At all times the premises is open to the public, the management will contract the back up services of an approved mobile support unit (MSU) that operates at all times the premises is open to the public, with a minimum of 2 SIA registered Door Supervisors operating from it. A copy of the MSU contract will be retained at the premises and made available for immediate inspection upon request by Sussex Police or Council Officials. The MSU will be accredited by the Brighton Crime Reduction Partnership (BCRP) or other similar organisation approved by Sussex Police should the BCRP not be in existence.

The premises will become a member of the Brighton Crime Reduction Partnership or similar scheme approved by the Licensing Authority. The scheme must operate, subject to local coverage, radios and additionally an exclusion/banning scheme of named individuals within both the day and nighttime economy.

(a) An incident log will be maintained by the premises showing a detailed note of incidents that occur in the premises. The log will be inspected and signed off by a manager at least once a month.

(b) The logbook should be kept on the premises and be available for inspection at all times the premises are open by authorised officers of the Licensing Authority or the police. An incident will be defined as being one which involves an allegation of a criminal offence.

Any additional conditions offered up within the original application or agreed with any other responsible authority.

Public safety

Any additional conditions offered up within the original application or agreed with any other responsible authority.

Prevention of public nuisance

The management will ensure that delivery vehicles waiting or arriving to collect orders will be parked/waiting legally and not causing a public nuisance by way of obstructing the highway or footpaths.

Any additional conditions offered up within the original application or agreed with any other responsible authority.

Protection of children from harm

All staff will be trained in:

· Identifying persons who are vulnerable which could include but not limited to, their age or due to intoxication and or drugs as well as identifying potential perpetrators.

· Conflict management.

The operator will have a policy in place assisting staff in how to deal with such situations.

All training undertaken by staff members shall be fully documented and recorded. All training records shall be made available to Sussex Police, officers of the local authority and officers from the Trading Standards team upon request.

Further verbal reinforcement/refresher training covering the above will be carried out thereafter at intervals not to exceed 8 weeks, with the date and time of the verbal reinforcement/refresher training documented.

Any additional conditions offered up within the original application or agreed with any other responsible authority.

REP B

Licensing Team

Brighton & Hove City Council

Bartholomew House

Bartholomew Square

Brighton

BN1 1JP

Date:

Our Ref:

Email:

21 July 2025

2024/02430/LICREP/EH

emilyfountain@brighton-hove.gov.uk

Dear Sarah Cornell,

SC CON END 25.07.2025 VALID PCD, PPN & CIZ (B)

RE: Licensing Act 2003 - Representation against the application for a new Premises Licence application for Station Grill, 62 Queens Road, Brighton, BN1 3XD

I refer to the application made by London Export and Import Ltd, for a new Premises Licence at Station Grill, 62 Queens Road, Brighton. The proposed hours are for Late Night Refreshment, every day 23:00 to 05:00 with opening hours of 24 hours a day every day.

I have concerns about this application and make a representation on the grounds of the prevention of crime and disorder and the prevention of public nuisance and that this application is contrary to our Statement of Licensing Policy (SoLP).

The council has a special policy to address cumulative impact, 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 special policy will only be overridden in exceptional circumstances. New applications and variations to existing licences should normally be refused following relevant representations. This presumption of refusal can be rebutted by the applicant if they can show that their application will have no negative cumulative impact on licensing objectives including the prevention of crime and disorder and public nuisance. The Licensing Authority will always consider the circumstances of each case and whether there are exceptional circumstances to justify departing from its special policy in the light of the individual circumstances of the case.

Station Grill 62 Queens Road falls within the cumulative impact area (CIZ). The Council’s Statement of Licensing Policy (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. Each application is still considered on its individual merit and there is discretion to depart from the Matrix approach policy in exceptional circumstances. The Matrix table clearly shows that late night takeaways in the CIZ should not be granted.

I acknowledge that the applicant has submitted extensive documentation as to why they consider their application to be exceptional. In addition that the applicant has offered some positive conditions to mitigate risk including BCRP membership, staff training and SIA risk assessment.

I also acknowledge that each application is to be considered on it’s own merits, however as this is the third time the applicant has applied for a late night take away in the CIZ in under a year, having had the previous two applications refused with one currently being appealed, the following are a real cause for concern:

This application is for a considerably later time than previous ones 23.00 to 05.00 everyday with 24 hour opening times.

It’s still unclear that the applicant properly appreciates what the policy means in terms of cumulative impact.

That not selling alcohol is not an exceptional circumstance in the context of applying for a late night refreshment licence.

The application is still unclear as to how members of the public for example passing by the premises will be able to place orders for takeaway/collection.

I believe that granting this application will likely add to additional burdens and problems to the already challenging area, especially if customers are collecting orders from the premises and deliveries are taking place between midnight and 05.00. I therefore wish to bring the application to the attention of the panel so that they can question the applicant further and decide whether this application constitutes exceptional circumstances to depart from the policy.

Yours sincerely

REDACTED

Emily Fountain

Licensing Officer

Licensing Team

Regulatory Services