Written evidence from the British Beer
& Pub Association (DDD 15)
The British Beer & Pub Association is the
trade body representing brewing companies and their pub interests,
and pub owning companies, accounting for 98% of beer production
and just over half of the UK's 52,500 pubs. Over 80% of pubs are
small businesses that are either leased/tenanted, or owned and
run directly by their owners.
INTRODUCTION
1. The beer and pub sector is committed
to helping to combat drink driving and is proud of the part that
it has played over many years in helping to increase public awareness
about the dangers of drink driving through its many initiatives
and campaigns. The industry continues to support the Department
for Transport's THINK campaign.
2. Pubs are now firmly part of the broader
leisure and hospitality sector and food is as important an offer
(if not more so) than the drinks offer. Food is consistently the
top reason why people choose to visit the pub with over 1.1 billion
meals served every year compared with 771 million in restaurants.
Today's pub culture has become more family friendly, more focused
on food and alternatives to alcoholic drinks, offering entertainment
accompanied by drinks rather than the old-style drinks orientated
public houses.
3. The value of the pub to the local economy
should not be underestimated. Pubs are a major source of local
jobs. The industry provides over half a million positions for
management, bar and catering staff, and chefs, 60% of which offer
part time or flexible patterns of working that enable people to
juggle their home and work commitments. For every one job in hospitality,
it is estimated that an additional 1.3 jobs are created in the
wider economy. Through their support of local businesses and local
sourcing of goods and services, pubs also help to ensure that
other small businesses thrive, securing more local employment.
Pubs are a mainstay of rural community life, and play a crucial
part in the sustainability of the rural economy.
4. There are an estimated 8,000 pubs in
rural locations and a further 10,000 pubs in suburban or semi-rural
locations which are vehicle-dependent. In villages and smaller
towns there is often no public transport at all or a very restricted
service in the evenings. Many pubs with large restaurant areas
would not be sustainable if they relied on community trade alone.
In total 18,000 pubs could therefore be particularly affected
by a reduction in the current BAC limit.
Should the permitted blood alcohol limit be reduced
as proposed?
5. Over the past two decades a mixture of
improved enforcement, tougher penalties and a programme of publicity
campaigns have significantly reduced the number of drink drive
accidents. All the evidence gathered over many years indicates
that drink/drive offenders have blood alcohol levels far in excess
of the legal limit. The latest drink/drive figures[1]
confirm this trend despite an ever increasing number of cars on
the road and the number of miles driven. Britain's roads are already
the safest of almost any developed country.
6. We believe that the current BAC limit
of 80mg has the respect of the overwhelming majority of people
in this country who believe the current limit to be fair. People
are well aware of the consequences of exceeding the limit and
have no sympathy for those that do. There is a real risk that
lowering the limit would see a loss of that respect with a return
to the "unlucky" tag resulting in more people taking
the chance and not limiting their drinking at all. The current
limit of 80mg has taken a long time to become established as the
social norm. There is a danger that the message will lose credibility
and cause confusion if it is changed after so many years of success.
7. A reduction in the current limit would
also lead to more people being caught (this is likely to include
more people who considered themselves responsible by drinking
at home, or at a friend's house, but whose chances of being over
the limit the next morning would be greatly increased). This would
divert resource away from catching dangerous drivers who far exceed
the current limit. The public may not look favourably either at
the prospect of losing their licences as a result of a stricter
limit being imposed after such a long period of time.
8. We do not believe that lowering the current
limit will address the hard-core repeat offenders but will penalise
the responsible majority. The industry supports the efforts of
the authorities to enforce the law regarding drivers over the
limit and, indeed, has long advocated the introduction of greater
enforcement and random breath testing. We believe that these measures
represent the best way of making further progress and should be
allowed time to take effect before any consideration is given
to lowering the BAC limit.
9. The North Report cites research contained
in the "review of effectiveness of laws limiting blood alcohol
concentration levels to reduce alcohol-related road injuries and
deaths", March 2010 (produced by the Centre for Public Health
Excellence NICE). It should be noted that the evidence base for
this report is derived mainly from the USA, Australia, New Zealand
and other European countries where public attitudes, driving habits
and drinking culture are all very different to that prevalent
in the UK. We question the supposition that the benefits claimed
in the report would be delivered by lowering the limit in the
UK, where levels of enforcement, degrees of punishment and respect
for the current limit are not compatible.
If so, is the mandatory one year driving ban appropriate
for less severe offenders, at the new (lower) level?
10. We believe that public opinion would
rise against a reduction in the BAC limit if it were to carry
the same penalties as currently exist for exceeding the 80mg limit.
However, a two-tier penalty system would create enormous uncertainty
and confusion and would give the wrong message about the consequences
of drink/driving. We believe that retention of the existing 80mg
limit, together with the associated severe penalties, would be
the most sensible option.
11. A lower drink/drive limit with a more
lenient penalty regime will not have any impact whatsoever on
persistent core offenders.
How severe is the problem of drug driving and
what should be done to address it?
12. The industry fully supports any measures
taken by the Government to combat drug/driving. We are very concerned
that the "the cocktail effect" of drug taking and drinking
has the potential to be explosive. Drugs are frequently quoted
as being a significant factor in other crimes and driving is no
exception. The North Report acknowledges that where the Police
suspect drugs have been involved, and evidence is found that the
offender is over the drink driver limit, then a prosecution for
drink/driving will be pursued and the drug issue ignored.
13. We believe this problem is becoming
more and more prevalent and we fully support further Government
action, including the creation of a new offence for driving whilst
under the influence of illegal drugs and the development of new
"drugalyser" equipment.
What wider costs and benefits are likely to result
from changes to drink and drug driving law?
14. We do not believe that a stricter regime
will do anything to reduce drink driving by hard-core offenders
but will introduce the element of chance. Much greater enforcement
of current laws is what is required.
15. Lowering the current BAC limit will
have a significant impact on the viability of many rural and destination
pubs. There will be a perception amongst law-abiding pub customers
(and a fear-factor) that they cannot safely have even one drink.
Despite the wide availability of alcohol-free drinks, customers
will feel their dining experience is diminished if they can't
have a good pint of beer or a nice glass of wine with their meal.
16. While we need to make it clear we would
not wish to hinder any measure that would make a real improvement
to road safety, we have a real concern that lowering the limit
would not make a significant difference but it would most certainly
have an undesirable effect on the hospitality and tourism industry
throughout the country. Pubs operate from doing business themselves
and are an important and integral part of the tourism industry.
Many associated businesses, such as holiday home rentals, B&B's,
historic sites and leisure facilities, rely on the location of
a pub close to their business to attract visitors also looking
for food and entertainment.
17. The tourism and hospitality industry
has had to manage many legislative changes in recent years, much
of which has added direct costs to business, and others which
have had the effect of driving customers away from pubs. Notably,
the smoking ban implemented on 1 July 2007 in England (earlier
in other parts of the United Kingdom) resulted in reduced footfall
affecting many pubs, particularly small community pubs and those
which were constrained from adapting to the new situation. It
is estimated that the industry invested around £100 million
in outdoor areas but the loss of trade caused by the smoking ban
has not been fully quantified. However the Valuation Office recently
recognised the ban as a material factor in a number of successful
rating appeals. (If a pub loses 10-20% of its trade, its viability
is at risk). This is a prime example of the consequences that
can arise as a result of legislative change. With 39 pubs closing
each week any further economic damage will accelerate closures
resulting in local unemployment. With each pub on average supporting
six jobs another 1,500 pubs could be lost together with 9,000
jobs.
18. Having considered the likely impact
of consumer behaviour we have made the following basic calculation
of the effects a lowering of the BAC limit might have on the pub
sector:
— Approximately 15 million people visit
the pub each week.
— We estimate 1.5 million drivers make
their journey to the pub in a vehicle (with passengers this number
could potentially increase to 2.5 million pub visits each week).
— Estimated spend £20/person/visit
= £50m/week.
— If one third of pub customers arriving
by car no longer visited the pub there could potentially be a
loss of £16.6 million each week (or approx £863 million
per annum).
— The greater proportion of this loss will
be from reduced food sales. This is approximately 4.5% of pub
turnover.
19. The above estimate does not include
other parts of the hospitality sector such as hotels and restaurants.
We understand from the British Hospitality Association that the
impact of a lower drink/drive limit is likely to reduce turnover
in hotel and restaurants by £350 million a year and cost
some 8,500 jobs.
What would be the implications of such changes
for enforcement?
20. It could be argued that more police
resource will be required to enforce a lower drink drive limit,
and this may even be counter-productive as resources will be stretched
more thinly than at present. With more people being caught exceeding
a lower limit there could be considerable costs for the police
and courts in dealing with such a big increase in offenders.
21. Those continuing to drink and drive
way above the limit will continue to ignore the law and take the
risk of evading detection.
SUMMARY
22. We believe that the existing drink/drive
limit of 80mg/100ml of blood should be retained. It is tried and
tested and has the respect of the vast majority of the population.
23. The Police should be given greater powers
of enforcement including the introduction of random breath testing
to enforce the existing limit. Sufficient time should be allowed
for these measures to take effect before any further consideration
is given to lowering the current limit.
24. The Government should target its resource
at tackling the increasing problem of drug driving through improved
detection and punishment.
August 2010
1 Department for Transport Reported Road Casualties
in Great Britain: 2009 estimates for accidents involving illegal
alcohol levels. Fatalities resulting from drink and drive accidents
fell by 5% from 400 in 2008 to 380 in 2009, whilst seriously injured
casualties fell by 9% from 1, 620 to 1,480. Slight casualties
resulting from drink drive accidents fell by 8% from 10,960 to
10,130. Total casualties fell by 8% from 12,990 to 11,990.
Fatal accidents remained unchanged from 2008, remaining at 350
for the second year in a row. Overall drink and drive accidents
fell by 7% from 8,620 to 8,050. Back
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