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New Title

A review of Westminster City Council’s Statement of
Licensing Policy

10August 2007




                                                  1
P2

In 2005, the new Licensing Act came into effect and we took over responsibility for
issuing licences for the sale of alcohol from the Magistrates. After asking residents,
businesses and visitors what they thought about what we planned to do, we issued a
Statement of Licensing Policy, which can be found on our website
http://www.westminster.gov.uk/licensing/policy.cfm

We think this policy has worked really well so far, but we are obliged to review it and
update it by January 2008.

This document tells you why we think the existing policy is working and tells you what
we are planning to update. We want to hear your view on our proposals, and on any
other aspect of the policy.

The rest is up to you – if you support or object to what we are proposing then it
couldn’t be easier to let us know..


P3
Westminster City Council‟s Statement of Licensing Policy was approved by council meeting
on 17 December 2004 and was published on 7 January 2005.

By law we must review it to see if it is working and, if necessary, update it by January 7 2008.

We believe the policy is working as it has proven to be a robust tool for the consideration and
determination of licences. We don‟t intend to change it substantially, but it is up to you to tell
us if you think otherwise.

Hearings before the Licensing Sub Committee started on 28 April 2005 and the policy has
been used to determine 1043 applications to vary licences or for new premises so far.

Almost all applications were granted with some conditions, and only 63 applications were
refused outright. Although 568 “new premises licences” were granted, only some of these
were truly new. Most were as a result of structural change to premises.


P4
No one has challenged the policy‟s legality. It has been applied by the Magistrates Court on
many occasions when the Council‟s decision have been appealed. There have only been a
handful of successful appeals (out of several hundred submitted). Most appeals have been
dealt with by agreement or withdrawn. Only two appeals relating to premises in the West
End Stress Area have been successful.

Westminster City Council has generally only granted later hours to pubs and bars under its
core hours policy. Core hours shift the time after which customers have to be off the
premises, from 23:20 under the previous Licensing Act 1964 regime, to 23:30 in the week
and to midnight on Friday and Saturday nights.

Around 250 pubs have been granted the core hours. Many pubs already had later hours for
the alcohol with food. Very few premises were not granted core hours. This was due to the
adverse impact they were already having on the licensing objectives, which are

Prevention of crime and disorder
Public safety
Prevention of public nuisance
Protection of children from harm

Across the city there are 1064 premises that still sell alcohol no later than 23:00.
                                                                                                2
A number of restaurants with bars for customers waiting to dine have been granted later
licences. Casinos have been granted very late hours for the sale of alcohol during gaming
hours. Hotels have variations to sell alcohol at large functions and changes to licences to
recognise that those staying at hotels can be sold alcohol at any time. There have been
some new licences granted for firms, institutes and exhibitions with very much earlier hours
than were permitted under the previous regime.

Westminster City Council has granted premises licences for major parks and public places in
the centre of the city for a limited number of days so that events can take place.


P5
There are two main parts to the review:

     1) A review of the overall effect of the operation of the Statement of Licensing Policy and
        the licences granted under it, and

     2) Lessons learnt from the experience of operating the policies and considering detailed
        changes and additions to the policies to address problems that have been identified
        and to codify the Licensing Sub Committee‟s emerging practice.


P6

PART ONE: A review of the overall effect of the operation of the Statement of
Licensing Policy and the licences granted under it.

This includes:
    the effect of the operation of the policy to date
    a review of the overall effect of decisions
    a review of the approach of distinguishing between types of premises and their effect
        on the promotion of the licensing objectives.
    In particular the effect of the Stress Area policies have been examined, their
        appropriateness and whether the boundaries of the Stress Areas or the polices
        applied within them or need to be revised.

P7

One City

The One City White Paper for the period 2006-2010 identifies as an action that the
Statement of Licensing Policy would need to be reviewed in the light of experience.

It identified as a possibility that, subject to consultation, the council might adopt an explicit
policy to reduce the concentration of licensed premises in current or emerging areas of
saturation where that would help achieve the licensing objectives.

In addition, the review would consider whether the boundaries of the existing stress areas
should be adjusted and whether additional areas should be designated.

The review has also explored whether it is appropriate to adopt policies for areas adjoining
Stress Areas which, whilst not currently subject to similar levels of cumulative impact, may be
at risk of becoming so if preventative policies are not adopted and implemented.




                                                                                                    3
The City Survey

The City Survey revealed that residents were overwhelmingly more often satisfied than
dissatisfied about licensing issues. In the more central part of the city, which has more
licensed premises, higher proportions of residents were more generally satisfied
(around10%). However a higher proportion was also dissatisfied. They had more definite
views on licensing matters than those in other parts of the city and smaller proportions of
them stated they did not know.

         Findings on Licensing from the City Survey 2007 from City Survey

                                     Satisfaction with licensing of premises

             Stress Area and
                boundaries                    46%                10%                    44%
             (sample size 60)




           W1,W2,WC2, SW1                     46%                8%                    46%




          Rest of Westminster              35%            5%                     60%




                                0%               25%             50%                75%             100%

                       Satisfied                  Dissatisfied               Neither / Don't Know



                                        Satisfaction with licensing hours


             Stress Area and
                boundaries                        51%                  10%               39%
             (sample size 60)




           W1,W2,WC2, SW1                        48%              10%                   42%




          Rest of Westminster               39%             5%                    56%




                                0%               25%             50%                75%             100%

                       Satisfied                  Dissatisfied               Neither / Don't Know




                                                                                                           4
                                      Problems of drunk or rowdy people

              Stress Area and
                 boundaries            22%                38%                  39%              1%
              (sample size 60)




            W1,W2,WC2, SW1            19%                 46%                     33%           2%




           Rest of Westminster          26%                 41%                   29%           4%




                                 0%             25%             50%         75%             100%

                A big problem         Not a big problem   No problem   None of these / Don't Know



P8

Working together

The policy recognises that licensing operates together with the police and the council‟s other
strategic partners in furthering the quality of life for those who live, work and do business in
the City of Westminster.

Since the Statement of Licensing Policy was published we have been working with all our
partners to reduce late night crime and disorder. Initiatives include:

        Home Office extra funding at Christmas
        the introduction of City Guardians and Safer Neighbourhood Teams
        changing shift patterns of the police and City Guardians
        systematic identification of „problem premises‟ and work with them to reduce crime
         and disorder and public nuisance

The number of late night violent crime reports in the period from 24:00 to 04:00 has fallen by
11% since 2004/5


P9
Reviews of premises licences

Residents have called for fewer reviews than anticipated. We think this is due to continued
heavy involvement of the police and other responsible authorities in dealing with problem
premises and because the steps taken by the premises concerned have reduced the
problems which would have merited review of the licence.

To date there have been some thirteen reviews completed Three of these (all in the West
End Stress Area) were the result of closures by the police which were confirmed by the
Magistrates. Three more were called for by the police and further conditions were imposed
by the authority and in one case the Designated Premises Supervisor was replaced.
Environmental Health has called for five reviews. One was in parallel with the police. As can
be expected, issues of noise featured highly. Recorded music was removed from three
licences; one had its hours reduced to 11:00 p.m. and conditions were imposed on sound
limiters and closure of windows. In addition, issues of public safety were raised and
conditions on CCTV and capacity limits were introduced. There have been three reviews
brought by residents. One was about a supermarket‟s hours of servicing; a condition on
                                                                                                     5
servicing was added; one was on noise from a club and a range of conditions on noise
prevention measures were added, and the other review was about nuisance from outdoor
drinking. Extensive conditions restricting outside drinking were agreed at the hearing in that
case.


Relationship with Planning and the Local Development Framework Core Strategy

The revised Statement of Licensing Policy will explain the differences between
planning and licensing regimes in the scope of powers and concerns and the way in
which the council‟s licensing and planning responsibilities are exercised.

The local planning authority is a responsible authority and can make representations
on applications. However it can only make representations related to the licensing
objectives. Nuisance and crime and disorder are shared concerns of planning and
licensing, however the environmental health authority and the police are the primary
responsible authorities for these aspects pf the licensing objectives. Planning
concerns relating to the character and function of an area and aspects of amenity
that would fall short of being a public nuisance are outside the scope of the licensing
regime. For example, a large restaurant might be unacceptable in a conservation
area characterised by small retail units on planning grounds of character and function
where licensing grounds of public nuisance might not apply.

The operation of a restaurant or cafe only becomes licensable if it includes the sale
of alcohol or the provision of regulated entertainment licensable or if it sells hot food
or hot drink after 23:00. However, the setting up of premises as a café or restaurant
requires planning permission unless is already in bar or take away use. The
introduction of alcohol sales into a café or off sales into a food shop will not require
planning permission. Thus if a daytime unlicensed café gets a licence to sell alcohol
and trades later into the night it will not be subject to the need for planning
permission unless it has previously been subject to specific conditions on its hours.

The introduction of regulated entertainment such as music and dancing will not
require planning permission unless they are carried on to the extent that they
constitute a change of use. Thus, if a restaurant introduces music and dancing as
part of its operation as long as this is ancillary to its operation as a restaurant then it
will not need planning permission. However, it would need to include regulated
entertainment on its premises licence.

Not having lawful planning use for an activity is of itself not a matter for licensing. The
Planning Department informs the Licensing Sub Committee and the applicants of the
planning status of premises where licences are sought by providing this information
for inclusion in reports Only in exceptional cases would the planning authority make
representations as a responsible authority. Whether the premises have planning
permission or whether a lawful use exists is are matters that will be taken up by the
planning authority.

The city council as a planning authority has planning policies which apply differently
in the Stress Areas and other areas. These are policies which relate to planning
concerns and are related to development, including the use of buildings and land.
They contain criteria related to sizes of premises and the use of premises rather than
to individual licensable activities.

Planning remains the regime that is directed at the development of premises and
their overall use. Licensing is the regime that is directed at individual licensable
                                                                                                 6
activities and their management. The granting of a planning permission for premises,
or finding that that a premises enjoy a lawful use, does nor constrain the city council
as licensing authority from considering in detail the licensable activities, their
management and conditions appropriate to them.


The City Council‟s Unitary Development Plan (adopted January 2007) contains
planning policies which control the location, size and activities of entertainment uses
to in order to safeguard residential amenity, local environmental quality and the
established character and function of the various parts of the City. These policies will
be supported by Supplementary Planning Guidance on Entertainment Uses, currently
being developed by the City Council.

As part of the new planning system, introduced by the Planning & Compulsory
Purchase Act (2004), the City Council is developing its „Core Strategy‟ - the principal
document of its new Local Development Framework (LDF), which will replace the
UDP. The Core Strategy will set a clear vision for the pattern and location of
development in Westminster.

The City Council is undertaking a consultation exercise on the Core Strategy „Issues
and Options‟ from mid May until the end of July 2007. The Core Strategy paper
included issues and options for the night time economy and specifically, options in
relation to the stress areas, low impact entertainment uses, and the reduction of high
impact entertainment uses in defined areas.

Under the LDF, the City Council will also be producing a Development Plan
Document containing more detailed spatial policies for the delivery of the vision set
out in the Core Strategy. It is intended that both the Core Strategy and the more
detailed policies in the Development Plan Document will complement the Statement
of Licensing Policy.

Responses received from the Core Strategy Issues and Options consultation and
from the review of the Statement of Licensing Policy will be used to inform the next
stage of the Core Strategy - „Preferred Options‟ - and the Issues and Options stage
of the Development Plan Document – both are due for further consultation in October
2007. They therefore will unlikely to be completed in time be to be able to inform this
review of the Statement of Licensing Policy.



P10

Stress Areas
In defining areas for special policies on cumulative impact (stress areas) for licensing
purposes the city council as licensing authority must carry out its functions with a
view to promoting the licensing objectives. These are the prevention of crime and
disorder, public safety, the prevention of public nuisance, and the protection of
children from harm. Revised Guidance Paragraph 13.25 refers specifically to “serious
problems of nuisance and disorder”. Paragraph 13.28 to “whether there is good
evidence that crime and disorder or nuisance are happening and are caused by
customers of licensed premises or that risk of cumulative impact is imminent.” There
may be issues in terms of amenity or problems from the conduct of individual
premises in an area which would not of themselves represent sufficient evidence for


                                                                                        7
the creation or extension of a an area where special policies of cumulative impact will
apply.

The review has examined whether the existing Stress Area policies can be strengthened by
more policies to reduce cumulative impact in those areas already suffering from the effects of
an over-saturation of licensed premise.

We think that the contribution to cumulative impact of premises licences that are having a
negative impact on the licensing objectives may in some circumstances be reduced if
responsible authorities or interested parties (residents) apply for reviews of licences that are
creating particular problems.

The Government‟s Revised Guidance on reviews (Paragraph 11.6) differs slightly from that in
the original Guidance. It now states that:
    “After a licence or certificate has been granted or varied, a complaint relating to
    a general (crime and disorder) situation in a town centre should generally not be
    regarded as a relevant representation unless it can be positively tied or linked by
    a causal connection to a particular premises which would allow for a proper
    review of its licence or certificate”. (Underlining added)

Taking revised guidance into account, and also the continued existence of some serious
problems of nuisance, it is proposed that the Statement of Licensing Policy is revised to
make it clear that if and when applications to review premises licences in a Stress Area are
made, we will take into account when considering the application the fact that the premises
are in an area suffering from cumulative impact when considering what steps to take to
promote the licensing objectives.

Proposed Policy for Reviews

When considering applications for the review of a premises licence the fact that
premises are in a Stress Area, and the need to reduce the cumulative impact of
premises within the Stress Area, will be taken into account in deciding what steps are
necessary to promote the licensing objectives.

QUESTION

Stress areas and reviews

Do you agree that we should take into account the fact that there are already
problems arising from the number of licensed premises in a Stress Area when
we consider complaints and problems related to premises in Stress Areas,
compared to other parts of the City where there are fewer problems?


 Exceptions to stress area policies

 The impact of some types of premises and licensable activities are such that they have a
 particularly marked effect on the licensing objectives. These have been identified as the
 operation of a pub or bar (sale of alcohol for consumption on the premises which is not
 ancillary to another activity) , the operation of premises for music and dancing (provision of
 facilities for dancing ) and the sale of hot food or hot drink to take away (provision of late
 night refreshment off the premises). Any increase in the number of these premises or their
 capacity would add to cumulative impact and is contrary to the Stress area policy; this is
 regardless of the hours sought.

 We consider that exceptions to the Stress Area policies to refuse applications must be
 genuine exceptions. Thus any list of circumstances where exceptions may be granted is not

                                                                                               8
 definitive. However we now have experience of some propositions put forward as to
 exceptional circumstances during the operation of the Policy. It is proposed to give
 examples in the revised Statement of Licensing Policy of the kind of considerations that
 address the reasons underlying the special policies on cumulative impact.

 Proximity to residential accommodation is a general consideration with regard to the
 prevention of public nuisance. However the absence of residential accommodation in the
 vicinity of premises in an area of cumulative impact is not a reason for exception. The
 nature of cumulative impact is that it is cumulative; the numbers of people visiting the
 premises the nature of licensable activities and the lateness operation have an impact on
 the area as a whole.

Revised Guidance Paragraph 13.36 specifically recognises that applications to vary
capacities are directly relevant to special policies of cumulative impact. This accords with the
city council‟s view and practice in considering applications to vary premises licences in the
Stress areas. Revised Guidance Paragraph 13.34 continues to recognise that different types
of premises have different impacts and contrasts large night clubs and high capacity public
houses with a small restaurant. This continues to give support for policies directed at
different types of premises and licensable activities in the stress area and treating
restaurants differently from pubs and premises with music and dancing.

Revised Guidance Paragraph 10.43 recognises that capacity conditions can be attached for
the promotion of the prevention of crime and disorder and refer to appropriate ratios of tables
and chairs based on the capacity and door supervision to control numbers on entry and
exclude drunk or disorderly individuals The city council further consider that prescribed
capacity and the provision of minimum levels of seating and tables can also promote the
licensing objective of the prevention of public nuisance. Customers who have been seated in
premises which are not crowded are less likely to have been talking at high volume and will
leave the premises more quietly than the greater number of customers in equivalently sized
premises without capacity limits with more vertical drinking.

The Statement of Licensing Policy refers to the substitution of licensable activities with less
impact. In addition the introduction of measures to reduce the extent of or remove
opportunities for vertical drinking can address the underlying reasons for the special policies
for cumulative impact. This can be by introducing fixed seating and the conditions to provide
a minimum number of seats at all times and limiting sales to be by waiter or waitress service.

The extension of hours beyond the core hours is of concern as there are greater problems of
late night transport and disturbance. Late at night there is less masking background noise
and disturbance is greater if people are trying to sleep or are woken up. Police resources
are more stretched later at night.

The City Council will consider whether offers to set capacities (maximum numbers of people
to be within the premises) for the first time in premises which have not previously had set
capacities (generally pubs and bars and restaurants) and offers to reduce capacities actually
do effectively address the underlying reasons for a policy on cumulative impact. There would
have to be substantial reductions in relation to the capacity at which premises had actually
been operating. Any proposals for later hours which offer reducing the capacity will have to
represent genuine reductions in the actual number of people using the premises at its peak
times and late at night and not on days or times when the premises are less busy. The later
the hours sought the more significant the reduction in capacity would have to be.

The Statement of Licensing Policy refers to exceptions to policy being granted to “transfer
operations” from one premises to another which will promote the licensing objectives and
where the impact will be no greater. In order for this to be treated as a consideration
justifying an exception to policy the city council will need to be satisfied that the necessary
legal mechanisms are in place to ensure that the original premises licence will cease to be
operable.

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QUESTION

Do you agree that we should say more about how we will treat applications which may
be exceptions to our policy as set out above?


P11

Areas Adjoining the West End Stress Area
There have been several representations from residents that the West End Stress Area
Boundary should be extended. Some of these were made at the time of the Publication of the
Statement of Licensing Policy but others have been made since.

An analysis of the changes in hours the licences granted under the Licensing Act 2003 and
the changes to the latest hours at which alcohol is sold has been undertaken. This involves
matching the magistrates‟ records of licences to current premises licences. The common
factor of the latest hour that alcohol could be sold on a Friday night has been used to as a
comparator. Many premises held multiple justices licences. The assumption has been made
that the licences with the longest hours would be compared unless it was known for certain
that they had been superseded. The 443 licences in areas adjoining the West End Stress
Area have been analysed as a priority as it was from these areas that concerns were being
expressed as to whether these areas were coming under pressure and the effect of the grant
of licences within these areas.

The licences that have been granted for later hours after midnight on Friday nights are listed
for each of these areas in Appendix 1. This shows that a number of very late licences have
been granted for casinos to match the hours when they are open for gambling. Hotels have
always been able to sell alcohol to residents at any time. This has been explicitly recognised
in the terms of varied licences and in the terms of new hotel licences that have been granted.
However there have always been conditions imposed that members of the public are not
able to enter hotels after a set time; frequently midnight, unless attending a pre-booked
function or as a guest of someone staying at the hotel. A number of previously existing
restaurants have been granted substantially later hours.

P12

Distribution of licences and late licences
The numbers of licences and the density of licences were re-examined based on the
information on their licences held under the Licensing Act 2003. This allowed the pattern of
late night licences to be discerned .and also to distinguish between licences for different
types of premises. Some areas with substantial numbers of licences have few licences
operating after midnight.




                                                                                           10
The analyses of distribution of licences show concentrations of licensed premises outside the
Stress Areas in:

          The Villiers St. area south of the Strand
          The Duke St/James St. St. Christopher‟s Place area North of Oxford St.
          The Shepherd‟s Market area in Mayfair
          The Dover St./ Albemarle St. area in Mayfair
          The St James‟s St. area in St. James‟s
          The area between Praed St. and Sussex Gardens in Paddington
          The area around Victoria St. and Wilton Road.

Looking at only those licensed premise that operate after midnight these concentrations of
licensed premises outside the Stress Areas persist in the following areas:

          The Villiers Street area south of the Strand
          The Duke St James St, St. Christopher‟s Place area North of Oxford St.
          The Shepherd‟s Market area in Mayfair
          The Dover St/Albemarle Street area in Mayfair
          The area around Victoria Station.

The St James‟s Street Area, the area between Praed Street and Sussex Gardens and in the
Wilton Road area no longer shows up as areas of concentration of licences operating after
midnight.

P13
Evidence of Crime and Disorder
The concentration of numbers of licensed premises is not enough in itself to indicate that a
special policy on cumulative impact is called for. It is essential to show that this concentration
is associated with evidence of adverse impact on the licensing objectives.

In the policy the Stress Area boundaries, which had already been delineated on the basis of
incorporating coherent areas of concentrations of late night licences, were shown mapped
                                                                                               11
together with Crime Reporting Information System (CRIS) data for 2003-2004 on violent
crime (defined as offences of Grievous Bodily Harm, Actual Bodily Harm, and Common
Assault). These offences were considered to be most related to licensed premises. The data
showed that these types of offences were concentrated in the West End Stress area but
occurred in spots across the City, often strung out along main roads.

Data on the location of crime reports for violent crime for the year April 2006- March 2007
been analysed. This is the first set of data that covers a period when the Licensing Act 2003
has been fully in operation. Analysis has been focussed on violent crime, between midnight
and 3:59 a.m. This is the period when these types of crime are most often are committed.
Midnight is the latest time that pubs can be open under the core hours and the next four
hours is the key time for the operation of the night-time economy.

These analyses show that the overall numbers of reports of these crimes at later hours that
can be mapped have been dropping over the four years
           Violent Crimes Reports where locations have been mapped
          Years                             Night        Late Night
                                            20:00-      00:00- 03:59
                                            23:59
          2004/05                            1329           1492
          2005/06                            1127           1469
          2006/7                             1104           1331
          Overall Change Numbers             -225            -161
          Overall Change %                  -17%            -11%

  P14

  The geographical pattern of these violent crimes late at night has altered little over the
  four years. While the West End Stress Area successfully encapsulates the areas of the
  highest concentrations of these types of crimes at these hours, they do not include them
  all. The area around Charing Cross station and south of it show high levels of crime
  reports. There was on this basis a case for examining proposals that this area be included
  in an extension to the West End Stress Area. There are other areas where lower levels of
  concentrations of reports of violent crime persist. This is not to suggest that any level of
  violent crime is inherently acceptable. These areas are along the western stretch of
  Oxford Street, along Piccadilly, and around the Embankment Temple area and around
  Victoria station.

  Concentrations of Late Night Crimes of Violence against the Person




                                                                                           12
The nature of the crime reports has been considered in discussion with the police. The
conclusion was that the level of crime was generally lower than the Stress Area and was in
many cases attributable to individual premises. It is considered that the existing problems in
these areas should be addressed by interventions from the police and other responsible
authorities directed to problem premises to ensure compliance with licensing conditions,
taking up crime prevention and nuisance reduction initiatives and recognising that if
necessary responsible authorities will call for reviews of individual premises licences. The
inclusion of these areas in the Stress Area is not considered appropriate. However the
contribution to cumulative impact of additional premises and of variations of premises
licences premises in these areas will continue to be assessed on a case by case basis.

Further studies and advice have been commissioned from a consultant who has
considerable experience of conditions in various parts of Westminster from the collection of
evidence in relation to appeals. He also has a wide knowledge of the night time economy
and its relationship to crime and disorder. The conclusion of his study of areas of Mayfair and
St James‟s where there had been particular concerns expressed by residents was that the
“problems of environmental stress encountered were qualitatively and quantitatively different
from those I would expect to find in the WESA and Edgware Road Stress area. Isolated
pockets of „stress‟ were encountered in each area. These could be clearly identified as
relating to particular premises”.

Revised guidance Paragraph 13.25 continues to recognise that even outside an area
of special policies of cumulative impact representations to can be made to specific
applications that they will have a negative cumulative impact on the licensing
objectives.

Our conclusions from this data and from our experience, taking into account the fact
that the role of the licensing authority is limited to the promotion of the licensing
objectives, recognising the effect that our existing policies have had to date,
recognising that where necessary problems arising from individual premises can be
dealt with by enforcement action, taking into account the role of other plans and
                                                                                            13
policies (particularly planning policy), and finally having regard to the policies with
respect to specific types of premises, particularly restaurants, that we propose below,
are

That there should be NO CHANGE to the existing Stress Area boundaries

That the Stress Areas should not be extended to include the areas referred to above

That it is not necessary to introduce special geographically based policies to protect
any specific areas outside the existing Stress Areas.

QUESTION

Stress Area boundaries

The City Council has not found evidence that areas around the West End
Stress Area have started to experience the same levels of problems that are
found in the Stress Areas. It has found that there are particular premises in
these surrounding areas that are associated with crime and disorder. Do you
agree that these problems should be addressed by targeted enforcement or by
other means rather than by extending the Stress Areas?




P15

PART TWO: Lessons learnt from the experience of operating the policies and
proposed changes and additions to address the problems identified to date.

The second major aspect of our review has looked at policies in relation to specific types of
premises.

We have considered the revision of policies arising from our experience of the application of
the policies in practice and what we would need to do to codify formally as policy the
approaches that we have developed to particular issues.


P16

Hotels
Hotels are currently covered under Policy COM1 which relates to premises that have a range
of activities which are licensable under the Licensing Act 2003. There are common features
of hotels which merit a specific policy that codifies the City Council‟s policy approach.

Sub Committees have generally granted later hours for events for pre-invited guests and
allowed sales of alcohol to non-residents provided they have entered the premises prior to
the end of alcohol sales to the public.

Proposed Policy on Hotels

Subject to the effect on the promotion of the licensing objectives and other relevant
policies the Statement, premises licences for hotels will generally be granted so that:

 (a) Alcohol is permitted to be sold at any time to people staying in hotel rooms and
       to their bona fide invited guests
                                                                                             14
 (b) The hours of serving alcohol to the general public will be subject to conditions
       limiting the sale of alcohol after a specified time to those attending pre-booked
       events held at the hotel,
 (c) The exhibition of film, in the form of recordings or non-broadcast television
       programmes to be viewed in hotel bedrooms, will generally be granted

 QUESTION

Hotels

It is proposed that hotels should be able to sell alcohol at any time to people
staying overnight and to their invited guests but other sales will be restricted
to earlier hours and to pre booked events. Do you agree with this approach on
hotels?


p17

   Restaurants
   The current policies on restaurants are:

   Outside the Stress Areas applications for new or varied premises licences for restaurants
   will generally be granted, provided they are considered satisfactory in relation to the
   criteria set out in each of the policies specifically related to the licensing objectives.

   Inside the Stress Areas applications would be expected to be granted subject to other
   policies providing it can be demonstrated that grant will not add to cumulative impact.

   Cafes and restaurants that serve hot food or drink after 23:00 hours but do not serve
   alcohol are treated in the same way as restaurants that serve alcohol provided that hot of
   food and drink is only served to customers seated at tables. i.e. not take away or service
   at a counter and self seating.

   It is a feature of the Statement of Licensing Policy that its policies are intended to allow
   for change in the composition of its night-time economy so it is more widely based and
   less dominated by alcohol led premises and thus promote the licensing objectives.

   Although the policy approach to restaurants is not restrictive, the definition of a restaurant
   in the Statement of Licensing Policy is a very tight one. It is that, in order to qualify for
   consideration under the policy for restaurants, the alcohol is only to be served to seated
   customers who are dining (and this would include those including waiting to dine and
   having dined) and that any bar is only for customers waiting to dine. Customers leaving
   the dining table to drink alcohol in a bar area would take a premises out of the category
   of a restaurant The condition now attached to many premises licence is:
      "The Sale of Alcohol on the premises shall only be to persons taking a table meal
      there and for consumption by such a person as ancillary to their meal."
   This allows the service of drinks as “aperitifs” and the consumption of drinks afterwards
   but drinks after the meal would have to be served at the table rather than at the bar if the
   premises are to be considered under policies which apply to restaurants rather than
   under those applying to mixed use premises that include bars.

   The inclusion of a bar which is open to those who are not dining in a restaurant or the
   inclusion of facilities for music and dancing by the public will be taken under the
   Statement of Licensing Policy COM1 as creating respectively; a bar or/and a music and
   dance premises to which specific policies apply of not granting licences in the Stress
   Areas.

                                                                                                  15
   The Statement of Licensing Policy recognises that the wide variety of restaurants is a
   feature of Westminster and contributes to its status as a world class city. Restaurants
   attract people over a wide range of age.

   It recognised in the Statement of Licensing Policy that restaurants providing table service
   have little association with crime and disorder. This is supported by a recent study of
   crime reports in licensed premises in Westminster over April 2006 to March 2007, which
   indicates that for every 10 restaurants there were just over 3 violent incidents in the year.
   This compares to 6 for every 10 pub/restaurants and 42 for every 10 nightclubs.
   Restaurants that stay open later than 1:00 a.m have a rate of violent incidents over three
   times that of those that close earlier, Pub/restaurants that open after 1:00 a.m have nearly
   three times the rates of violent crime compared to those that close earlier.
P18



                       Violence by Premises Type, FY0607 All Premises

                                    Violence by Premises Type, FY0607
    400     42                                                                                   45
    350                                             344                                          40
    300                                                                                          35
                 282
    250                       253                                                                30
                                                                                                 25   Incidents per 10
    200
                                                                                                 20   premises
    150                                                                                          15
                                                                  128          118
    100                                                   7                             7             No. of incidents
                          6                                                                      10
     50                                 3                               3
                                                                                                 5
      0                                                                                     11   0
                                                                        Shop


                                                                                     Casino or
           clubs and




                                                          Hotel
          restaurant

                                       Restaurant




                                                                                     gambling
           house or
             discos
             Public
              Night




                                                                                       club
              pub




  Violence by Premises Type, last serving time on a Friday between 01:00 and
                                06:00, FY0607




                                                                                                                         16
                                     Violence by Premises Type, FY0607

      300       47                                                                             50
                     275                                                                       45
      250                                                                                      40
                                                     228
      200                  29                                                                  35   Incidents per 10
                                                                                               30   premises
      150                                                                                      25
                                                           15                                  20   No. of incidents
      100                       85     12                          88                          15
                                                                        9             7
      50                                                                                       10
                                                                                               5
       0                                                                       6          11   0




                                                                        Shop


                                                                                   Casino or
            clubs and




                                                           Hotel
            restaurant

                                        Restaurant




                                                                                   gambling
             house or
              discos
              Public
               Night




                                                                                     club
               pub




p19

  There has been concern expressed on the policies in the Statement of Licensing Policy
  on restaurants. Two concerns broadly expressed by residents are

                    That additional restaurants or existing restaurants trading late into the night
                     will adversely affect the licensing objectives and will add cumulative impact.

                    That premises styling themselves as restaurants serve alcohol to people not
                     taking table meals.

  The concerns partially arise because many premises which converted their full on
  licences are still able to sell alcohol without the sale of table meals up to 23:00. The
  provisions of the previous licensing regime were continued by the conversion of “full on
  licences” held by restaurants that allowed them to operate as a bar up until 23:00 (22: 30
  on Sundays ) but which held “supper hour certificates” which allow the sale of alcohol up
  to midnight (23:30 on Sundays) as part of a table meal. Some pubs held supper hours'
  certificate to serve alcohol later with food. It is estimated that around 60% of restaurants
  only held “restaurant licences” where all sale of alcohol was ancillary to a table meal but
  they enjoyed the automatic grant of supper hours on application to the justices.


  The Statement of Licensing Policy only applies to those seeking new premises licences
  or variations (and where representations are made). New applications or variations for
  premises licences seeking to sell alcohol for consumption on the premises without a meal
  will be considered under the policies for pubs and bars. The operation of premises with a
  new premises licence granted as a restaurant solely under restaurant policies RLN 1 or
  RLN2 could not include independent use of the bar or entertainment. Bar use and
  entertainment would have to be specifically sought and considered under policies
  appropriate to these activities. (PB1 or PB2 and MD1 or MD2) Conditions may be
  attached to ensure that sale of alcohol is not only ancillary to the taking of a table meal
  but that all sale of alcohol after the meal is served at the same table as the meal.

  It is proposed to include the foregoing explanation of the way that policies apply to
  restaurants in the text supporting the Policies RLN1 and RLN2.

  An area of concern raised by the police is over the granting licences for the sale of
  alcohol at very late hours to premises that in effect serve snacks and very cheap meals.
  They consider that this will add to problems the police have encountered in these types
  of premises, such as drunkenness and disputes over bills and will, in effect, be creating
  late night drink led premises. This is of concern especially in the Stress Areas

                                                                                                                       17
  In order to limit the extent to which there is a proliferation of very late night restaurant
  premises in areas of cumulative impact restaurants, it is proposed that the lighter touch
  policies for restaurants apply only to premises that are open for customers up to 1:00 am.
  This will allow the sale of alcohol to continue to midnight as in the previous regime for
  restaurants and give time to consume a meal and leave the premises. It takes into
  account that more time needs to allowed for restaurants for food to be consumed
  compared to other premises.

  There are specific and stricter policies on premises serving hot food to take away (TAW 1
  and TAW2) than apply to restaurants. The policy is not to grant applications for takeaway
  hot food sales in the Stress Areas. There have been a number of applications for
  premises which have hitherto been serving hot food to take away food or serving
  customers from behind a counter for extended hours for the provision of late night
  refreshment on the basis that they will operate as a restaurant. In determining
  applications for the provision of late night refreshment consideration will be given to the
  size and suitability of the premises for providing meals by waiter or waitress service.
  Conditions may be imposed that there will be waiter or waitress service and no takeaway
  hot food sales,

P20
  Proposed draft revised policies on restaurants

      Restaurants and Late Night Refreshment Premises                Policy RLN1
      outside the Stress Areas

  Applications will generally be granted and reviews determined subject to the
  relevant criteria in Policies CD1, PS1, PN1and CH1.
  Applications to serve alcohol after midnight will only be granted if the service of
  alcohol is by waiter or waitress service and forms part of the continuing service
  and consumption of a table meal while seated at the same table and it can be
  demonstrated that the proposal meets the relevant criteria in Policies CD1, PS1,
  PN1and CH1.



      Restaurants and Late Night Refreshment Premises                Policy RLN2
      within the Stress Areas

  Applications will granted subject to other policies in this Statement and subject to
  the relevant criteria in Policies CD1, PS1, PN1and CH1 provided it can be
  demonstrated they will not add to cumulative impact in the Stress Areas.
  Applications to serve alcohol after midnight will only be granted if the service of
  alcohol is by waiter or waitress service and forms part of the continuing service
  and consumption of a table meal while seated at the same table and it can be
  demonstrated that the proposal meets the relevant criteria in Policies CD1, PS1,
  PN1and CH1.


  P21

  Hours for restaurants
  The “core hours” in the policy indicate that applications to serve alcohol for consumption
  on the premises where ancillary to the consumption of food will generally be granted to
  allow them to have customers on the premises until 23:30 in the week and up to midnight
  on Friday and Saturday. These hours are less than the supper hour certificates that the
  magistrates granted with restaurant licences and as a matter of course. Newly
  established bona fide restaurants should generally be able to trade on a comparable
  basis with other established restaurants. This approach has been commonly adopted by
                                                                                           18
   the responsible authorities. It is proposed to create a further category within the core
   hours for customers to be on the premises for restaurants supplying alcohol ancillary to
   the consumption of table meals. It needs to be noted that the core hours refer to times
   when customers are on the premises and that Policy HRS 1 refers to “core hours as “will
   generally be granted” .Licensing Sub Committees have not always granted core hours if
   there were good reasons related to the licensing objectives not to do so.

   The creation of Core Hours for restaurants that are later for premises which sell alcohol
   without it being ancillary to a meal provides the opportunity for alcohol led premises to
   gain additional hours of trading if they are prepared to vary their operation and licences
   to become food led premises.

   It is proposed that the core hours policy for restaurants serving alcohol ancillary
   to table meals be amended.

   Proposed Core Hours for restaurants serving alcohol ancillary to table meals
   Monday to Saturday                                              10:00 - 01:00
   Sundays immediately prior to Bank Holidays                      12:00 - 01:00
   Other Sundays                                                   12:00 - 24:00

   QUESTION

Restaurants

It is proposed that restaurants will generally be able to stay open to 1:00 a.m.
but will only be only permitted to serve alcohol after midnight if it is by table
service as part of a meal. Drinks at the bar may only be served prior to the meal.
If premises serve alcohol that is not part of a meal they will be considered as
pubs or bars, those offering dancing as nightclubs.
Do you agree that genuine restaurants should be allowed stay open longer than
pubs and bars and to serve alcohol with meals later?


P22

Casinos
When the Gambling Act 2005 is fully implemented in September 2007, the membership
requirement for all casinos will disappear and any entertainment will be public. The hours for
gambling will be set in the operating licence and the default condition proposed by the
Government will apply. The City Council will continue to licence the sale of alcohol and
entertainment. The Licensing Sub Committee has granted licences to casinos generally that
take into account the hours when they are open for gambling.

Proposed Policy on Casinos

The granting of licences for regulated entertainment and extension of the hours for
the sale of alcohol in casinos will be considered in relation to the likely effect on the
licensing objectives. Account will be taken of the hours that the premises will be open
for gambling.

Conditions will be imposed on licences so that that the provision of licensed activities
is ancillary to the operation as a casino including the playing of casino table games.

QUESTION

Casinos


                                                                                            19
Do you agree that casinos, which will be able to stay open for gambling until at
least 6:00 a.m. under the Gambling Act 2005, should be able to sell alcohol and
provide entertainment to similar hours to those when gambling is provided?



Combined Use Premises
The policy on combined use policies will be revised to reflect that new specific policies are
proposed for hotels and casinos. It will be made clearer that the approach to combined uses
applies equally within and outside the stress areas and that the inclusion of a bar area in a
restaurant provided it is exclusively for intending diners with be considered under the policy
related to restaurants. The provision of any facilities for music and dancing or entertainment
of a like kind will always be considered in relation to policies MD1 and MD2.

QUESTION

Do you agree with this approach?


P23

Children
Unaccompanied children under 16 are not permitted to be on “premises being used
exclusively or primarily for the supply of alcohol” (i.e. alcohol led premises: pubs, bars and
nightclubs). In addition, it is an offence to allow unaccompanied children under 16 on
premises licensed to sell alcohol for consumption on the premises after midnight but before
5:00 am. The provisions of the previous regime that children under 14 should not be allowed
in a “bar area” have been often converted into conditions attached to premises licences
under the new regime.

It has been accepted that it is difficult to define a bar area as premises trade longer and
change in character over the day. On many licences for alcohol led premises, the applicants
have accepted a condition that children under 16 should not be on the premises or only be
on the premises if they are accompanied by an adult and eating a table meal and off the
premises by 21:30. In general the concerns over the protection of children from harm arise in
relation to premises after 18:00.

Proposed policy on children

Conditions on children will refer to children younger than 16 years old. It is proposed
that a condition that any children on the premises after 18:00 must be accompanied by
an adult and partaking of a table meal and that children should be off the premises by
21:30 will normally be imposed on the following types of premises:

 (a) premises licences for premises “primarily or exclusively for the sale of alcohol
     for consumption on the premises”
 (b) premises with facilities for music and dancing that also sell alcohol.

QUESTION

Children
By law, under the Licensing Act 2003, children under 16 must be accompanied
by an adult on premises that are being used primarily for the sale of alcohol and
are must be off premises after midnight if they are selling alcohol. Many
premises still have the old rule that children under 14 should not be in bar.

Do you agree with the proposed approach that children under 16 should only be
in pubs, bars and nightclubs after 18:00 if they are accompanied by an adult and
                                                                              20
eating a meal and they should be off the premises by 21:30? Are these the
appropriate times?


Corporate Facilities and Canteens
There have been a number of applications from companies and other organisations and
institutions which have facilities such as canteens and bars for their employees or members.
In some cases these involve a bar use without the consumption or provision of meals, at
least for part of the time. If these premises are in the Stress Area the provision of a bar is
contrary to policy. In many cases those using the facility would be in the area in any event
as they have come to work there that day and might otherwise have used some other bar
near at hand in the Stress Area. Sub-committees have granted a number of such licences.

Proposed policy on Corporate Facilities and Canteens

The impact of canteens and other similar private facilities for employees will be
considered in the context of their effect on the licensing objectives. They will not be
subject to the provisions of Policy PB2. The provision of facilities for students will
receive separate consideration in light of the numbers and the age of the students.

QUESTION

Do you agree with this approach?

P24

Off-Sales of Alcohol
The Statement of Licensing Policy does not follow Government Guidance which
recommends that shops selling alcohol should generally be permitted to match the hours
during which they may sell alcohol with their normal trading hours. There are problems of
street drinking found across the City. While there are some areas with recurring problems of
street drinking „schools‟ they also crop up in different areas at different times and seasons.
Shops selling alcohol can be a source of for anti-social behaviour, disorder and disturbance.
These include the day long consumption of alcohol on the street and in open spaces by
groups of drinkers who cause various types of public nuisance and engage in antisocial
behaviour; the sale of alcohol to underage young people who which apart from being a
criminal offence gives rise to disorder, public nuisance and concerns over public safety and
harm to children; the sale of alcohol to both adult and underage young people who consume
it on the way to other premises and giving rise to problems of drunkenness.

The City Council has introduced a controlled drinking zone across the City by making orders
to give police powers to stop street drinking and seize alcohol and receptacles under the
powers of the Criminal Justice and Police Act 2001. Short term Dispersal Zones have also
been used in various parts of the City to break-up street drinking “schools” and disrupt
patterns of street drinking.

In locations where the police report problems of street drinking, and late night disorder
specific consideration will be given to restricting the number, type, and the hours of premises
selling alcohol exclusively for consumption off the premises. This is to hinder both underage
drinkers and problematic street drinkers masking their consumption by purchasing from a
series of premises and using a number of other premises to try if they are refused sale in
one. The City Council will want to be assured that the operating schedule of premises and
their overall management and staffing are appropriate to ensure that the licensing objectives
are promoted in what may be challenging circumstances. The earliest hours of opening will
not generally be before 8:00 am. This is because problematic street drinkers and other
people who are seriously addicted to alcohol may be drawn to shops that sell alcohol earlier
in the morning than other premises and create public nuisance. It is already noted in the
Statement of Licensing Policy where there are problems of late night disorder ( these are

                                                                                            21
generally the Stress Areas) the hours when alcohol may be sold for consumption off the
premises hours may be restricted to be less than the generally granted core hours.

Proposed Policy on Off-Sales of Alcohol

In areas experiencing problematic street drinking or disorder, specific consideration
will be given to the number of premises selling alcohol exclusively for consumption
off the premises and the grant of new licences for off-sales may be restricted.
Conditions may be imposed to restrict sales to start later and finish earlier than the
hours that it will generally grant under policy HRS1.

When requested by the Police, the Licensing Authority will impose conditions that
there should be no sale of beers, lagers and ciders and other specified types of
alcoholic beverages with alcoholic contents of over a specified limit of alcohol by
volume. Other conditions may be imposed directed at reducing problematic street
drinking.

QUESTION

Sale of alcohol for consumption off the premises

Do you agree that, in areas of the City where there are street drinking problems
of any type the number of new licences for the sale of alcohol for consumption
off the premises should be restricted? Should their opening hours be more
limited in these areas? Should there be restrictions on the types and quantities
of alcoholic drink sold in these areas? E.g. no super-strength beers, lagers and
ciders; only full sized bottles of spirits.


P25

Other issues

Non standard hours for events
There have been numerous instances when non standard hours have been sought for
events additional to, or offered substitution for, Temporary Event Notices. The vast majority
of such applications were from existing premises, seeking to retain similar rights to those
they enjoyed under the old regime with the use of occasional licences.

In order to have conditions that are clear and enforceable the circumstances in which the
non-standard hours will apply must be identifiable This is so there is an opportunity for
representations to be made to the particular events and in order to provide predictability as to
when non-standard hours will apply for the benefit of those who may be affected. The
inclusion of particular national saints‟ days will have to be considered in relation to the overall
number of events. The particular clientele of premises may be a reason to seek non-standard
hours for other national days. The there should be no expectation of specific non-standard
hours for any particular day. Premises not benefiting from exceptions for New Year‟s Eve
must seek it specifically or use a Temporary Event Notice.

Proposed Policy on non standard hours

In general, the need for non-standard hours should be met by Temporary Event
Notices. Specific non-standard hours should be identified and justified as part of the
application. Bank Holiday Mondays will not generally be late hours as the next day is a
working day.

In the Stress Areas there are policies to refuse applications for pubs and bars , music
and dance premises and takeaway hot food premises other than to vary hours to
                                                                                                22
within the core hours. These policies apply to the granting of applications for non
standard hours. The consideration of applications for non standard hours for other
types of premises and licensable activities will have regard to the effect on cumulative
impact.
QUESTION

Do you agree with this approach?


“No nudity” condition
Many converted licences have a condition that ran with the Justices licence that all persons
are to be to be decently attired. In addition, Public Entertainment Licences when they were
converted incorporated the previous Rules of Management including Rule 4 on “no nudity”.
Such conditions are most obviously called for where the regulated entertainment includes the
performance of dance. To avoid creating opportunities to set up, for example “topless”
premises of various types without the opportunity for proper consultation or consideration by
the Licensing Authority and the attachment of appropriate conditions, premises licences for
regulated entertainment and late night refreshment should have a no nudity condition
imposed. There will obviously be some late night refreshment premises such as small
takeaway hot food premises where such a condition will be unnecessary.

Proposals for an addition to policy NS1 on nudity and striptease
When there is no answer in Section N, a “no nudity” condition will normally be
imposed on premises licences for regulated entertainment and late night refreshment.

QUESTION

Do you agree with this approach?.

P26

Smoke Free Premises
The implementation the smoke free regulations under the Health Bill on 1st July 2007, will
probably result in customers who wish to smoke frequenting premises with gardens, or other
outside areas. This will also lead to more people congregating and drinking outside premises
on private forecourts and on pavements which are part of the highway. The smoking ban will
add to the problems that already can arise from drinking and eating outside premises. The
Statement of Licensing Policy contains a policy on the prevention of public nuisance and this
has the scope for proper consideration of any public nuisance that arises from licensed
premises.

The smoking ban is likely to have particular effects on premises that change for admission
and those that have close door supervision to prevent illegal drugs and weapons being
brought onto the premises. These important crime prevention measures need to continue to
be operated in full on all readmissions so that they are not circumvented and the crime
prevention licensing objective is not undermined. This has the potential to lead to more
queuing outside these types of premises. This could give rise to public nuisance especially
as these types of premises operate late at night.

Premises with conditions on “no readmission” will need to seek variations if they intend to
allow smokers to be readmitted after leaving the premises. The intention behind the “no
readmissions” condition is both to deter people from moving from bar to bar and to prevent
the circumvention of admission charges which were applied after a specified time.

Proposed changes to Policy PN1arising from the smoking ban in enclosed spaces

The Statement of Licensing Policy contains a policy on the prevention of public
nuisance (PN1) which lists environmental impacts other than noise. This has a
                                                                                              23
section on measures to prevent smells, fumes and dust arising from the licensable
activity causing disturbance to people in the vicinity. This will be amended to
specifically mention tobacco and other smoke creating public nuisance.

The specific set of criteria to be considered in relation to outside eating and drinking
under Policy PN1 will be adapted to refer to smoking as well as eating and drinking.
The specific references to measures to prevent queuing and prevent disturbance and
obstruction under Policy PN1 will include references to the management of people
leaving premises to smoke and their readmission.

QUESTION

Smoking outside

There are amendments proposed to the policy specifically to address the
potential problems of people going outside premises to smoke. These cover
nuisance from smoke and noise and the likelihood of extra queuing to re-enter
premises. Do you agree with these proposals? Are there other aspects that need
to be addressed?



Conditions
The section on conditions will be amended to include the recognition that in appropriate
cases the City Council has granted and will continue to be prepared to grant premises
licences with conditions that the licence will have no effect until certain works are completed
or measures put in place to the satisfaction of a nominated responsible authority. This is an
expedient way to resolve technical matters that cannot be readily be resolved during the
course of hearing.

QUESTION

Do you agree with this approach?


Hearings
The city council exercised a good deal of flexibility at its hearings under the
Licensing Act to allow applicants and responsible authorities and interested parties to
present amend applications to reduce the extent of what was sought and to consider
new conditions put forward. It was necessary to proceed to determine applications at
hearings and not adjourn them during the period of transition. Licensing sub
committees may adjourn hearings to be heard another day if sets of conditions that
have not been provided in time for the reports to be circulated to members,
applicants responsible authorities and interested parties. This is generally seven
days before the hearings.

In line with Revised Guidance Paragraph 9.14 and its previous practice on occasion
previously the city council may withhold disclosing the personal details of an
interested partly after satisfying itself that the representation is from an interested
party in the vicinity. This will only be done at the request of the interested party.
In doing this the city council is not accepting that any claims or fears of intimidation
are well based. The City Council urges interested parties to convey their concerns to
responsible authorities at an early stage so that these can be logged, investigated
and collected together as a source of evidence. When interested parties make
representations they are put before the Licensing Sub Committee in advance and
they are considered in full whether or not the parties attend the hearing. It can be
                                                                                             24
helpful to the Licensing Sub committee if interested parties can attend to take part in
the hearings. Their direct experience is of value to the hearing in finding suitable
solutions and determining the applications. Some hearings are held in the evenings
to assist those who cannot attend in the day. It assists hearings if interested parties
can agree to present points that they share in common and add those points that
apply only to them individually.
QUESTION

Do you agree with this approach?

QUESTION?

Are there any other changes you think we should make to our policy, or any
other points you believe should be addressed by the policy?




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