Memorandum from the British Institute
of Innkeeping (BII) (RL 08)
The BII, the professional body for the licensed
retail sector, welcomes the opportunity to comment on the way
in which the re-licensing process under the Licensing Act 2003
has been implemented. We would like to be considered as a witness
for this hearing on 31 October.
BACKGROUND TO
THE BII
The BII is the professional body for the whole
of the licensed retail sector and currently has a membership of
17,400 individual members made up of managers, staff, licensees
and tenants from both the on and off sectors. We are also supported
by 50 Corporate Patrons and Members who contribute to furthering
our main mission which is to:
"Promote high standards of professionalism
throughout the licensed retail sector, to encourage new entrants
into the industry and to help them develop their long-term careers.
To provide all our members with high quality information, skills
and qualifications to help them succeed in their business activities."
As a professional body therefore we are fully
committed to maintaining the highest possible standards throughout
our industry. We set and maintain standards through our wholly
owned Awarding Body, the BIIAB. All individual members sign up
to our Code of Conduct, which reinforces the professional message
that we deliver.
Our qualifications cover a wide range of areas
specifically for licensed retail, including full regulatory qualifications
such as the National Certificate for Licensees (now replaced by
the National Certificate for Personal Licence Holders), the National
Certificate for Door Supervisors and the Barperson's National
Certificate. We also deliver a wide range of business competence
qualifications to assist our members in developing and improving
their business performance.
In 2004 we processed 134,745 individual qualifications
and since 1992 we have awarded over 600,000 qualifications.
COMMENTS ON
THE RE
-LICENSING PROCESS
UNDER THE LICENSING
ACT 2003
1. The transition phase has prompted an
increase in work for local authorities including setting up new
departments but this will not continue at this level into future
years. Therefore we believe that the first year's fees should
cover the initial work but will become a revenue raising exercise
in subsequent years.
2. In this transition year, there has been
a huge increase in monetary and time costs associated with the
system to licensees. These costs are incurred through advertising,
legal fees for a solicitor used to make the application, cost
of preparation of plans as well as the licence fee itself. It
should be borne in mind that historically, licensees without a
Public Entertainment Licence (PEL) were liable to pay £30
for a three year justices' licence. Whilst some of the extra burden
is limited to transition, we still believe that the new fees scale
for the average pub is still too high, whilst those for more complex,
larger entertainment premises are too low.
3. One of the causes for late submission
was the lack of financial incentive. There was no discount for
early payment in transition—so what about offering a discount
for early payment in 2006 and beyond?
4. The licensed trade is unique as its rateable
value is based on turnover rather than square footage of the outlet,
like other retail businesses. If levels were set by square footage
then the bigger premises would pay more than smaller premises.
The introduction of more bands would help especially with more
complex premises. For example a nightclub in Westminster paid
£20k for a Public Entertainment Licence under the old regime
will now be paying the same as a much smaller venue. In our view
the top bands are too low and the lower bands too high.
5. The BII believes that the best way for
a uniform system is for it to be set by central Government and
not devolved to local authorities. A standard application process
should be applied across the country to avoid local authorities
complicating the process by applying their own interpretation
and stipulations. The application form needs to be in plain English
to accommodate those people for whom English is not their first
language or whose literacy levels are not high.
6. In conclusion, the licensed trade was
assured by the Government that the new fees structure would be
no more expensive under local authorities than under magistrates
and that over the next 10 years the new system would save the
licensed trade £2 billion. In the face of the evidence above
we do not believe this assertion to be true. The new system has
been both more time consuming and more costly to an industry that
already contributes 5% of the country's GDP and pays £22
billion pa to the Exchequer.
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