Appendix C
REP A
EF CON ENDS 15.08.2025 VALID
PCD, PPN and CI (A)
The Licensing Technical Support Officers Environmental Health, Brighton & Hove City Council Bartholomew House, Bartholomew Square Brighton,
East Sussex, BN1 1JP
12/08/2025
Email: brighton.licensing@sussex.police.uk
Dear Emily Fountain,
RE: APPLICATION FOR A VARIATION OF THE PREMISES LICENCE FOR REVOLUTION, 77 WEST STREET, BRIGHTON, EAST SUSSEX, BN1 2RA UNDER THE LICENSING ACT 2003. 1445/3/2025/05850/LAPREV
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 (revised January 2021) and the Revised Guidance issued under section 182 of the Licensing Act 2003 (February 2025).
This is a proposed licence variation 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 Zone (CIZ) (as defined in the BHCC Statement of Licensing Policy) and seeks to extend the licensable hours for alcohol, regulated entertainment and late night refreshment and opening hours on a Friday & Saturday night and the day before any bank holiday.
The premises is currently licensed as follows:
Sale by Retail of Alcohol (On & Off the premises)
Everyday: 10:00 – 02:30
Late Night Refreshment (Indoors)
Everyday: 23:00 – 03:00
Regulated Entertainment (Live Music, Recorded Music, Performance of Dance, Entertainment of a similar description – All Indoors)
Everyday: 10:00 – 03:00
Opening hours
Everyday: 10:00 – 03:00
They have applied to vary the licence to the following hours:
Sale by Retail of Alcohol (On & Off the premises)
Sunday - Thursday: 10:00 – 02:30
Friday – Saturday: 10:00 – 03:30 (1 hour extra)
(and the day before any Bank Holiday)
Late Night Refreshment (Indoors)
Sunday - Thursday: 23:00 – 03:00
Friday – Saturday: 23:00 – 04:00 (1 hour extra)
(and the day before any Bank Holiday)
Regulated Entertainment (Live Music, Recorded Music, Performance of Dance, Entertainment of a similar description – All Indoors)
Sunday - Thursday: 10:00 – 03:00
Friday - Saturday: 10:00 – 04:00 (1 hour extra)
(and the day before any Bank Holiday)
Opening hours
Sunday - Thursday: 10:00 – 03:00
Friday - Saturday: 10:00 – 04:00 (1 hour extra)
(and the day before any Bank Holiday)
Paragraph 3.1.3 of the Brighton and Hove City Council 2021 Statement of Licensing Policy states that:
‘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 and public nuisance, and that therefore an approach to ‘Cumulative Impact’ is necessary as part of its statement of licensing policy.’
While Sussex Police acknowledge that the variation application has limited the extension asked for to just Friday and Saturday nights, this is arguably the busiest time in the night-time economy and so requires special scrutiny and discussion. Offering additional licensable activity into the early hours encourages persons who may be already under the influence of alcohol or drugs to remain in the area, which is at the heart of the night-time economy in Brighton (West Street). This increases the risk of crime and disorder, anti-social behaviour and public nuisance.
The licensing decision matrix on page 18 of
the Council Statement of Licensing Policy (SoLP) suggests that new
premises or premises licence variations asking for sale of alcohol
(both on & off the premises), regulated entertainment and late
night refreshment are a ‘No’ in West Street (CIZ).
Applications of this nature, which are highly likely to add to
existing cumulative impact, should be refused following relevant
representations.
The ‘Cumulative Impact Zone’ is covered by special
policy and paragraph 3.1.6 provides that:
‘The special policy will only be overridden in exceptional circumstances. 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 applicant did pre consult with Sussex Police and has offered a comprehensive list of conditions as part of their application. They do make mention of the BHCC Special Policy and Statement of Licensing Policy (SoLP) within their application and have shown consideration towards this. However, West Street is a key crime hotspot in Police data and while the conditions currently offered can go some way to reduce incidents occurring and being managed within the premises itself, there are no conditions that can address the risks around what happens once customers leave the premises in the later hours of the morning.
Therefore, it is not felt that anything provided could fully address the local concerns or show the application will have no negative cumulative impact. Therefore, Police question whether this application can provide evidence to rebut the presumption of refusal in the CIZ and believe it should be heard by a Panel to be able to explore this.
Paragraph 14.40 of the Secretary of State’s Guidance to the Licensing Act 2003 (February 2025) provides:
‘In publishing a CIA a licensing authority is setting down a strong statement of intent about its approach to considering applications for the grant or variation of premises licences or club premises certificates in the area described.…Applications in areas covered by a CIA should therefore give consideration to potential cumulative impact issues when setting out the steps that will be taken to promote the licensing objectives.’
As mentioned previously, there is a
presumption of refusal in this area, so it is for the applicant to
show what their exceptional circumstances are and to evidence that
their application will have no negative cumulative impact. Sussex
Police contend that the carrying on of additional licensable
activity by extending the hours at this premises has the potential
to add to existing cumulative impact issues in this area and
therefore, the application is at risk of undermining the prevention
of crime & disorder and public nuisance Licensing Objectives.
Therefore, we invite the Licensing Authority to seriously consider
refusing this application in light of the Police concerns, local
issues and Local Authority special policy
Yours sincerely,
REDACTED
Insp Ben Morrison Operations, Planning & Events (inc. Licensing) Inspector
Brighton & Hove Division
Sussex Police
REP B
Emily Fountain
Licensing Officer
Brighton & Hove City Council
Bartholomew House
Bartholomew Square
Brighton
BN1 1JP
EF CON ENDS 15.08.2025 VALID
PCD, PPN and CI (B)
Dear Ms Fountain,
Re: Licensing Act 2003 - Representation regarding the application for a Variation of Premises Licence for: Revolution, 77 West Street, Brighton, BN1 2RA
I write to make a representation on behalf of the Council's Licensing Team, in their capacity as a responsible authority, in relation to the above application for a variation of Premises Licence submitted by Inventive Service Company Limited to extend the closing time and currently authorised regulated entertainment and late-night refreshment on Fridays and Saturdays (and the day before any bank holiday) from 03.00am until 4.00am and to extend the terminal hour for the sale of alcohol by retail (on / off sales) from 02:30 to 03:30.
This representation is made as the Licensing Team has concerns that the application could have a negative impact on the licensing objectives of Prevention of Crime and Disorder and Public Nuisance. I also refer to the Special Policy on Cumulative Impact (SPCI) contained within the Council's Statement of Licensing Policy (SoLP).
This premises falls within the Licensing Authority's Cumulative Impact Zone (CIZ), which was adopted to give greater power to control the number of licensed premises within the city's centre. The SPCI was introduced 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 the SPCI is that applications for new or varied premises licences, which are likely to add to the existing Cumulative Impact, will be refused following relevant representations. The applicant can rebut this presumption of refusal if they can show that their application will have no negative cumulative impact on licensing objectives, including prevention of crime and disorder and public nuisance.
The Council's Statement of Licensing Policy also 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. Regarding the Matrix policy,
it indicates that a ‘nightclub’ in the CIZ is a “No”.
When considering whether representations should be submitted, the Licensing Team also
have regard to the ‘Public Health Framework for assessing Alcohol Licensing’ – https://public.tableau.com/app/profile/brightonhovepublichealthintelligence/viz/PublicHealthFr ameworkforAssessingAlcoholLicensing/NavigationPage
The premises sits within the electoral ward of Regency. Under ‘Crime and Disorder data’ it is the worst out of 23 wards for sexual offences and violence with injury and second worst for all violence against the person and non-injury assault.
The applicant has addressed that the premises are situated in the CIZ and provided an operating schedule with proposed conditions, but the Licensing Team make this representation to uphold our Statement of Licensing Policy. The SPCI is predicated on too much alcohol being available and, as previously stated, applications for new and varied premises licences will be refused unless the applicant can demonstrate exceptional circumstances. The onus is on the applicant to demonstrate this, and we would invite them to explain their exceptional circumstance to the Panel, so that the Panel can decided whether they are satisfied that this application will not impact negatively on the CIZ.
Yours sincerely
REDACTED
Corinne
Hardcastle Licensing Officer, Licensing Team, Regulatory
Services.
REP C
From: Chinwe Ihemefor REDACTED
Sent: 06 August 2025 08:37
To: REDACTED
Cc: EHL Licensing <EHL.Licensing@brighton-hove.gov.uk>;
Emily Fountain
REDACTED
Subject: Re: Application to Vary Premises License
Application, 77 West Street Brighton BN1 2RA
Dear Kuit Steinart Levy,
Thanks for your Premises Variation Application on behalf of your client to extend your hours for carrying out licensable activities to 0400 hours.
Unfortunately, the Environmental Protection Team would like to raise objections to this application because we are concerned that granting the proposal will mean neighbouring residents will have to bear an additional hour of disturbance from loud music/karaoke from your premises.
Based on noise complaints we have received in the past and the most recent ones, it does not appear that you are currently managing the sound levels coming from your premises even with the existing conditions for the Prevention of Public Nuisance on your current premises licence.
If you would like us to reconsider our stance on this matter, could you tell us how you intend to resolve the noise problem and what additional measures you propose to uphold the Prevention of Public Nuisance licensing objective?
Yours sincerely
Chinwe Ihemefor (she/her) |Environmental Health Officer – Environmental Protection
Safer Communities
Brighton & Hove City Council
2nd Floor, Barts House, Barts Square, BN1 1JP