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The National Organisation of Residents Associations has member organisations representing nearly two million people resident in England and Wales.
It was initially formed as a result of a licensing problem, so members are familiar with the consequences of the liberalisation of the licensing legislation
following the 2003 Licensing Act.
The Consultation Paper on EMROs and the Late Night Levy was drawn to the attention of its members, and this response was produced by including all the comments
received from its members. Accordingly this response can be regarded as expressing a view representative of a large number of residents,
many of whom are exposed to the serious problems of the night economy.
RESPONSES to QUESTIONNAIRE
CONSULTATION QUESTION 1:
Do you think that the proposed processes for Early Morning Restriction Orders include sufficient consultation with those likely to be affected by an EMRO?
No. It is important to include associations representing residents and businesses in the list of those involved in the process both in
advertising the order, receiving representations and organising the hearing.
CONSULTATION QUESTION 2:
The government proposes that EMROs will not apply (i.e. will not restrict alcohol sales) between midnight on 31st December and 6am on 1st January of each year.
Do you think that EMROs should apply on New Year’s Eve?
No.
CONSULTATION QUESTION 3:
Do you agree or disagree that the categories of premises above should be exempt from EMROs?
Agree.
CONSULTATION QUESTION 4:
Do you have any other suggestions on the types of premises that should be considered for an exemption from EMROs?
No.
CONSULTATION QUESTION 5:
Do you think that there should be an option for local residents/ community groups to recommend the implementation of the levy in their area?
Yes. If one or more relevant local residents associations have sufficient concerns about problems caused by the night-time economy, their request for
implementation of an EMRO should be considered by the Local Authority.
CONSULTATION QUESTION 6:
Do you agree or disagree that licensing authorities should be able to exempt these premises from the levy?
Yes.
CONSULTATION QUESTION 7:
Do you agree or disagree that licensing authorities should be able to exempt Business Improvement Districts from the late night levy?
Yes.
CONSULTATION QUESTION 8:
Do you think that premises operating under a club premises certificate should be exempt from the late night levy?
No. The behaviour of club members leaving premises may be no different from those leaving other types of licensed venues.
Were Club premises exempt from the Late Night Levy, licensed venues may decide to become Clubs just to avoid paying the levy but with no change in the
behaviour of their patrons on leaving the premises.
CONSULTATION QUESTION 9:
What are your views on affording a reduction from the late night levy to businesses that receive small business rate relief?
No comment.
CONSULTATION QUESTION 10:
Do you agree or disagree that there should be an exemption for New Year’s Eve?
No. The burden on the community associated with New Year’s Eve celebrations is no different from other nights and may even be worse,
so the funds will still be needed for police involvement and local authority cleansing, etc.
CONSULTATION QUESTION 11:
Do you agree or disagree that licensing authorities should be able to ask for a reduced levy payment from these businesses?
Agree.
CONSULTATION QUESTION 12:
Do you have any suggestions for benchmarks that can be applied to grassroots schemes to ensure members are actively working to reduce crime and disorder?
No.
CONSULTATION QUESTION 13:
Do you agree or disagree with this set-up of cumulative discounts?
No comment.
CONSULTATION QUESTION 14:
Should there be scope for further exemptions and reductions from the late night levy?
No.
CONSULTATION QUESTION 15:
What activities do you think licensing authorities should be able to fund with their retained proportion?
The list proposed - taxi marshalling, cleaning the after-effects of crime, disorder, anti-social behaviour consequent on alcohol consumption,
booze buses - is acceptable.
CONSULTATION QUESTION 16:
What restrictions do you think there should be on the types of services that licensing authorities will be able to fund?
Cleaning streets from refuse related to Late Night Refreshment and Fast Food takeaways should not be funded by this Levy.
Preventive measures to meet the four licensing objectives are the duty of the licensees. The funds from the levy should be spent on services to the area directly attributable to the behaviour of the patrons of the licensed premises paying the levy,
and not used for services in other parts of the district.
CONSULTATION QUESTION 17:
If you have any comments on the Impact Assessment, please detail them here?
No comment.
CONSULTATION QUESTION 18:
If you are responding on behalf of a licensing authority, how many premises do you expect will be affected by EMROs in your area
Not applicable.
April 2012
Alan B Shrank - NORA chairman
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