Transcript

Thanks everyone for coming for the statement of licensing policy 2025 to 2030. I'm now going to introduce Edward who's going to start the ball rolling on this quick answer session. Thank you. Thank you very much. about what we've received and how obviously you will have the full agenda facts with everything in including our response to consultation but really I just wanted to take the time and for you to spend some time with the policy and to ask any questions to me as an officer or to Paddy and Heidi from elsewhere who have assumed we write in the see so really we're at your disposal as long as you need us to take any questions and to talk through the policy and in its draft form ahead of committee next week okay so let's start are there any questions on right so we'll start with so I think we'll just work through it as per the agenda on the screen if you find that easier yeah speak free and you can read it up there well okay so the first one comes in the agenda is responsibility of the authorities and other persons and representation so I've looked through and I've seen the various authorities I've met police and fire brigade and planning services now what I found before in the old policy was we had things like planning services who never never seem to put in representations or come but we had a lot of discussions in those committee meetings with regards to why planning isn't here and how can we enforce certain conditions based on how far a shop can come out onto the the highways or what have you but yet they don't come and also another question I wanted to ask you on responsible authorities is can you give us a more updated version on HMRC them coming as a responsible author for the first time since I think it's the home immigration so if I can leave you with those questions thanks yeah cool so when we set out the um the policy we want firstly to be more accessible and clearer and break it down in a manner that was more um constructive so one of the parts is introducing the authorities and other persons so people have an idea about the breadth of responsible authority the up-to-date list of responsible authorities on the council website the reason we haven't embedded that in the policy is quite frequently they change um so we keep that as your wet as a rule of thumb we have the same priorities time after time that are more engaged with the lifestyle process the metropolitan police um commercial environmental health deal with noise trading standards underage sales and children and underage showers principally and there's other responsible priorities that under the act are a responsible authority don't routinely have um engaging with process so planning is is a good example um planning and licensing are separate statutory functions they're separate remits and they will engage um especially during enforcement but it's rare for them to come to committee um I don't think that's going to change and immigration um in enforcement and they are responsible for it and I've never known them to call in a review in my time in Newham and I'm here five years now and prior to that as well and recently we've had a flurry of reviews called in vibrations there's three coming to committee within the coming month and I think that the rationale behind that is nationally immigration policy is changing I read something today I think um it's like being a 30 percent or so increase in immigration activity across the UK and government changes its policy to migration and because of that interaction with licensing and as a rule of thumb I think immigration will be putting in more reviews as and when they do their enforcement and I think that's something that's going to become more more regular and part of parcel of Newham um so we have the um reviews called in what I would say is the reviews are very different um in terms of um the individual premises and I think the sexual minority guidance is quite specific on immigration and how immigration cases should be severity that they should be dealt with so obviously it's linked to the objective of crime and disorder and it's quite interwoven in the section 102 guidance that's where I'm a little bit confused yeah ASB right so so um the way I think about it is the home office and are the government department responsible for the Licensing Act and they're responsible for the Statute 102 and Section 102 guidance um obviously the home office are also responsible for immigration enforcement so I think um the role of immigration as a responsible authority is quite woven into the Section 102 guidance and it's linked to the objective of crime and disorder so immigration offences are criminal offences so when immigration do their visits to premises in the borough and they find undocumented migrants working they have their own enforcement regime in pain slash arrest they can do civil penalties quite often they'll put in civil penalties quite substantial civil penalties yeah so I heard they were quite substantial but in the thousands tens of thousands of panels so this is one of the cases is 40 000 pounds parallel to that if they go to a licensed premises and they undertake enforcement action they have because they're responsible they can call in a license for review because the um the objective of crime and disorder has been undermined now looking at the three cases coming to committee and the cases are quite different there's been some premises that have been repeat offenders there's been some cases where um it's their first interaction with immigration the enhanced role that they're playing currently in national politics it's something that's going to become more common in terms of them as a responsible authority bringing um bringing cases to committee and so as you can see they're mentioned in the list of full yeah authorities section six um i'll just introduce i walked in hi thank you this is a really informal session um it's literally just a few minutes session your your colleagues in southern kept me a longer than i am this is our time okay that answers the question and this is just an introduction about the breath responsible authorities yeah people people are like that but they're all just actually responsible under the axis and there's nothing new here no just be laid out in clearer clear at four yeah just had a quick question before um i was going to ask like um in terms of consultation who was the consultation i'm looking for what their license residents or that you mentioned it was consulted but who did you mean the consultation for the review the policy so um if you look at the agenda um bundle so i'm not sure how much you've got you've just got the policy on you um but the consultation process is set out in statute so it's set out in the licensing act so there's a minimum we have to do for it to be the legal process so we we did that and beyonds i've got the list here um so most of them are directly from the the legislation so the chief of police for the local local property area fire and rescue council's director of public health and a long list of staffing bodies and so how we do consultation is we um so we embedded it on the council's web page and had an ongoing effort to us by our email and we published it twice in the by month after the eu letter that's issued on you and business and enterprise that goes to quite a few businesses in the borough and pubwatch stratford bid business improvement district um safer business networks all these organizations embedded with local businesses um shared to be then a further sharer curiosity how many people responded back so um all in all so i would say um it's quite rare for us to get responses back in in this type of policy um this time we've got seven responses back yeah yeah so one was from community safety internally uh one was for the safer business network um one was from excel london this is license holder uh one was from our own scrutiny internally so scrutiny for crime environment and transport one was from a former licensee in newham one was from um a group called action newham represented by a license holder and one was from the uh an organization for the black equity organization so to be fair the responses we had were quite long a lot of them were quite constructive it was i think it was quite a good response to consultation um we struggled to get residents engaged in any consultation around policy um it went out on the council website it went out on a number of different manners going back to businesses and we went to all of the legal firms that represent businesses we'd never operate within newham um we went out to the institute of licensing um internally to different departments and we have to go statutory to neighboring boroughs as well um so it did go go far and wide um but it's not uncommon to have a relatively small um consultation um is we did think about taking it to libraries and libraries and we weren't able to do that that was more of a resourcing issue internally um but having looked into it we won't look so the opinion that we were going to get much from the libraries so from the times we were going to be put on we didn't feel like we were going to get much back from the consultation process because obviously we have like few libraries and if we had someone because obviously every policy and we do it affects the residents so it's kind of helpful but having that discussion with them in terms of what they would like to see and what why we have certain policies and the impact of it so i would presume i mean seven i would have presumed would have been a bigger number so sorry so i've been in newham for five five years in this role now so i've brought the gambling policy um before seven is the most i've ever got to a response to policy consultation um there's a number i can't i can't tell you how representative it is i think it also is worth saying that this way it's all ward councils try heavily to engage with ward councillors into the specific wards relationship with residents um i would say that we went very hard to ensure that businesses license holder and applicants were were particularly consulted um what i would say is the policy balances the need to be um constructive and support businesses with the need to safeguard communities and uphold the licensing objectives and i think we do that very well as well as the policy change the way of working we have pre-application mediation with businesses we support license holders um if any resident reaches out we directly liaise with them as well as officers um we do provide a very localized responsive service and so the policy itself may not necessarily reflect the nature of of of that level of work but um yeah councilor i would say as well as looking after a lot of your work we represent people all over london and all over the country and i would say that the vast majority of consultations get no responses at all yeah i was so i think to be fair maybe that's the the sorry state that policy is in you know we try really hard to engage with with residents um and so a good example is whenever we undertake work enforcement action visits what heavily pushed social media now um and we really try to get out there um and and liaise with with residents i think you know we could have taken it to to libraries etc so i for instance i was going to be booked into stratford library for 6 31 evening and to give you an example i was told that they had a zumba class in that evening i saw it i took it i took the call about how far we go to engage engagement yeah but what i would say as well as a policy yeah you get a zumba class no no a serious point and everything we do in our work we try to engage constructively um with with um with everybody i think maybe the proper route is ward councilors to get into the ward at that granular level um hopefully that would also fit back you know what i found though um and and all my colleagues that have been in committee is that they are not residents specifically not even businesses are not interested in the licensing policy until it affects them 100 back then you get all the hands up in the air and the the shouting and why didn't you and you said well we've had this we put out consultation you wasn't interested then so we can only only continue from where they've made their complaints so it's it's it's a egg and a chicken kind of situation i agree and i think you know i think it's very important for me that we reach applicants and license holders directly impacted by the policy yeah residents are obviously affected and as and when a resident comes to us whether it's a complaint or anything i know that they get a fantastic level of personal service yeah and quite often education because there is a kind of an unknown element to licensing until they're directly affected like you say um but yeah i think it's it's very hard on a big policy to meaningfully engage a resident level especially with something that's so chunky on that note so was there any questions no whilst we've we've got legal in in the room um you've written we've written this this statement in conjunction with each other and and it's fantastic i'd have to say really fantastic but just so that we are clear why is it um residents find it very difficult to understand how we make the decisions we make and a lot of it is is written in the policies it's great but still that legal aspect of it not being a political committee but a legal this is a legal governed entity all by itself so just for us here which i don't think it's really sharp in in this as to why we make decisions and what laws are we held by why this has to be done the way it's done i mean my personal view is that's that's a very hard question to listen to the policy the relevant section for me particularly to residents is there's a section specifically on the role of ward councillors i would expect the ward councillors about residents linking to the system that's the councillor um representing them at their level of their household nice and i think the reason that we have a section on the role of ward councillors is make them aware of the role of their who can support them explain the system to them even when representation i think as a resident that is the routine if a resident interacts with licensing presumably because they have an issue one of the one of the areas of licensing is being undermined take it as public uses for instance the second they interact they get a response from a licensing officer who give a very very good response to to residents and also at the same time educate residents in the process it'll be then written to with the whole process um how hearings work whether they attend whether they don't attend that gets them the decision letter back to them so i think when residents do engage they get a very good service from the case officer and and the process of licensing it's very well explained to them and then how they can interact with it should they as you know residents actually turning up to committee hearings is pretty rare it peaks slightly during the pandemic with remote access and dialing um but i do think the relevant thing linking them into this process would be the section on on the role of board councilor section seven um i'm not sure how else we could effectively write it explain the system more i do think you're you're right i think sometimes things are seen as political decisions or regeneration decisions or and it's not it's a statutory process maybe that's a broader education and i'm not sure how we can embed that further in the policy but i've looked at patio hiding to maybe expand on that yeah i think so excuse me so i've got a cold man but i think there are other sections in in the policy which touch on that so i think the licensing hierarchy in progress 1.9 to 1.11 pages sorry that's on page five yeah that's true it goes into a little bit about what's relevant what's not relevant and that there are the fact that there are other um mechanisms that deal with its planning controls and other aspects that deal with how premises might impact on them as well so i think there is there's an element there trying to set it out that licensing legislation is not like a universal panacea for everything that is considered yeah and then the other thing as well that i thought was um i think it's section four on page 10 in real terms if there's no reps then we get to the policy and if not and even licensing supremacy but it's an interesting point that having you know you having read it as the chair it might not be as as punchy as it could be on that but yeah because i do tend people do get very confused and it's um when when we have when we have the meetings and that they're saying well we don't understand and then i have to get legal to explain it um to them but they still don't seem to grasp the concept of of it being a legal entity and we are governed by the section 182 the guys here yeah i think those points you made actually really fundamental the sections that you picked out clearly explain and very very i think quite specifically firms that the role of hierarchy in the decision-making process and the delegation of functions um the problem is i think that's pretty well set out but even then a resident's going to want to go to this policy to click on that link to read that section i think it's covered quite well and the other reason that we made the policy as you mentioned it looks attractive as a policy yeah we wanted to make it more accessible to residents so when you click on this policy you go to the contents you know you can for instance see the role of council as you click it it takes you straight to that section whereas the old policy you were lumbered with the whole policy in this entity to read through so i think it was more user-friendly it is more user-friendly the other thing i would say is we've paid for a translation panel to be put in there for the lifelong policy yeah which translates the whole policy to the major languages spoken into newham so we've tried to make it interact to be more accessible yeah so you're not lumbered with a big document which is you open in words you click and you take to the area try to make it clear and we've tried to make it more palatable in terms of access i think that is an issue with licensing quite often with residents you'll find that they're complaining about parking um why the asb noise nuisance we've got a commercial environmental health team there might be a better place to suit them i think with the best in the world you're never going to clarify that level of clarity in this document but a lot of it is down to the officers um taking that initial empowering quite often we would actually refer a resident to other areas like parking enforcement or the commercial noise team even back to the award council advice um but like you say how we communicate that at a granular level to an individual is is difficult yes i had a quick question it's on i know you've got you we talk about immigration and um children and young people services just a question um if there was any safeguarding issue or anything else like that we will do something that picks it up is there any reason why we don't have or is that covered somewhere else in terms of representation like if there's something to do with immigration if there was a child involved the first people to pick it up would be school yeah there may be why we don't have representation from school so so we do so if it's a responsible authority um so the protection of uh children from harm is one of the four licensing objectives granted it's not the most common one that we normally climate disorder and nuisance um but actually one of the responsible authorities is um is the council's children young people service so if there was a safeguarding issue that was um associated with licensing premises and they would be the appropriate body to put in a representation around safeguarding and protection children issues now in my time in newham i have known them once do that okay using a strong representation around an issue where children um had access to a licensed premises where they shouldn't do and there were safeguarding issues and on that specific case and we had the children young people services put in a formal representation as a responsible authority and attendance which added weighting to peace's concern around vulnerability um the same thing with enforcement of immigration is concerns around modern day slavery and vulnerability um you'd expect that to be drawn out in immigration's representation or or like we've had reviews recently for immigration um so the different responsible authorities would that's like if anyone picks it up you'll be the school first because they're probably the kind of authority spends a lot of time with individual which are so if something happens i'll pick it up if so if there was supposed to be a representation wouldn't school be one of those bodies that we approach so no because they're so so they're so technically they're not a responsible authority under the act so they don't have a statutory function under the act so we do interact with schools and a good example would be underage sales now go on and vape so schools have embedded police officers but there's been a change in newham how that's delivered um but so for instance we're quite often um and actually we pioneered an intelligence sharing resource with schools in newham and which london trading standards took on as a model of practice so the trading standards team reach out to schools and we provide a business card and qr code and for teachers parents um anyone to report issues of vulnerability around underage sales could be alcohol can be cigarettes or vaping and that's part of intelligence that we perceive which drives our underage sales test purchase program um so that's the appropriate link so if that came from reporting that would drive the intelligence that visit that might uncover licensing issues which then responsible authorities could deal with um via review etc um so that that mechanism does link in with schools but then that wouldn't that just come under other persons as if they're caught in a representation independently yeah yeah there's nothing stopping that no yeah absolutely right um i've never known the case of that would happen the most common way schools report intelligence under itself to us and that prompts a visit which then leads to outcomes um but i have known children services to put in a formal rep before around safeguarding and that was a very effective um intervention from them thank you simon thank you that's an observation reason really as a board council i've only agreed approach twice re-licensing and on both occasions one occasion i think i wrote to the chairs some time ago now somebody this is i can call it bribie where it was trying to do something like you're on that panel so i just distanced me didn't turn up i didn't do that panel and another one the game which i didn't report you came to me twice two different people with different surgeries to try and you're on a licensing panel so can you do this i just seen you didn't do anything it's when i saw it come up another just one attempt yeah it's keeping it simple but i do wonder if there's something we can do when we because we listed us counselors that are on the panel should perhaps we shouldn't have it listed on their bio on the on the long line site so if they're targeting a particular account world counter because they were nice and single because they're trying to push something yeah that way they don't know who we are i mean what what i would say is um there's a thought as a ward counselor you can obviously put in your own rep or you you can put in if they'd ask me to do it the correct way i've been a different band a resident but you that was very miserable you'd need you'd need to see from them that one of the four licenses they targeted because we're on that panel and not as a ward counselor if i do wonder if we should say if we were to take that off our bios they're not going to target particular counselors who may not be as honest as i am yeah you see me point of making i mean i can't then then they can't then target particular individuals i think that's down to not policy i think that would be down to so the important safeguard is obviously if a ward council was to put in a rep or have an issue that they wouldn't be sitting determining the decision yeah so they don't have the idea as officers if with ward councils have issues quite often they'll ring us direct and they'll ask us to directly look at something on their behalf or in it or interact i think you actually advised me to write so so if you're ever unsure i'd say to all counselors just just reach out to licensing officers the majority of the time we pick up stuff on on ward counselors behalf and contact the resident etc etc and but the distinction is if a wall counselor does put in a rep and obviously you can be in the committee but you're not in a decision-making function so there's that there's that level of separation there yeah very interesting point we've we've just relatively recently settled a case at the high court where a london borough councilor did accept a significant uh bribe in relation to a certain premises and it's not reached the public domain property yet because we're just settling damages and costs and so it's really interesting from hearing from hope he's not in any spot right no it's one of those but it's um you know it's really interesting to hear yeah yeah good for you but yeah that's really interesting it's life isn't it yeah that's why i just wondered if if it wasn't on the bio then it takes the temptation away so we should no i think it's is it i don't know because i've just always accepted it as as red but is it is it not on duty to put which committees your honor it is you have to publish that because accountability but i would say there's a factor of interest at the beginning of the hearing maybe you have a bullet point at the bottom bribes accepted do not template that again seriously so what was she saying i mean there's a declaration beginning of all hearings isn't there yes of course and at the same time there's a code of conduct for counselors it's separate mechanisms um if ever a council is uncomfortable an issue i'd say just point it to an officer and officers can pick it up on your behalf um and even have the correspondence so you've done that oh yeah yeah i'll be keeping for a bit i would imagine it's probably gone by now but can i just what's the only other questions ladies um just going back to page 16 um i want to know applications for personal licenses interim authority notices what is that what is this interim authority notice intriguing them it's not my expertise or priority notice i think that's the that's kind of a partial agreement to give a business a steer on on on a potential outcome is it not paddy um it's not something i've ever ever experienced in you know let me have a look at it for a long while i think it is um it let me google it so that i'm not saying i i my understanding was that it was let me just look my understanding was it was not an application for like a premises license it was a toe in the water on how would the application be be dealt with to give someone authority they were like investing in a business like what chance they're going to get a license from i thought that was the principle of it it's not something i've ever known well i've done it to do with a license like yeah it is transfer it back over right so an interim authority notice allows the person giving the notice to act as license holder and continue to carry out the license activities at the premises for up to three months all right and there's a period of change yeah yeah yeah but there are i i mean this is all i do for a living and i've never seen i've never seen it in here and i've just saw in five years we do have we do have licenses licenses lapses to hide in front and i i think that well you wouldn't it's it's a procedural application so it would never be something that you'd hear in a committee to offices says yeah so an office would process it we've had a lot with our license lapse all the time but we've never had an issue where someone's putting a notice of that nature i've never seen one come across our desk notes i haven't have you ever dealt with no i've never okay um i think you're reading it yeah i was like boss i just did just like oh god i can't read no more um um right so um i'm looking at page 20 moving on premises license now um you've mentioned in like so right 20 more 21 um where it um nine two so variation to an existing premises license and i just wanted to just be clear you've got four variation you've got minor variation why would someone do a full variation and not just take out a new license so i mean it's down to that it's it's down to to them if if you need to make changes to a premises that by their nature are minor then you have to do a major variation or you could buy for a new license so it can work either way there's nothing stopping africans from doing it we would advise to it 90 percent of the time to apply for a new premises license and surrender the other one yeah because if you apply for a variation and this happened to a colleague of mine she made an application for a variation to a hotel license in kensington and chelsea and got representations to it went to a hearing she ended up in a worse position than she before she started the variation so what i would also advise a client is you've got you've got your license you want to change it that can sit on the shelf and be our fallback position we do a new license application explaining what we want to do spend a deal yeah and and tell the licensing subcommittee if you grant us this we'll surrender the other one i'm a huge believer that multiple licenses in licensed places should be avoided where that's my next question in this policy i noticed that i mean because we have it all the time don't we um but uh we had one premises that had six licenses in stratford and uh it just all our um officers were just running like headless chickens so i know that a lot of this is governed by law but is there nothing that we can put in there to stipulate that i mean apart from shadow license which i can understand because it's the license holder protecting his premises but but if you have a license why can't you surrender yeah i don't think we can prescribe it because they're legally entitled to it but what we do do is through our pre-application vice service of which we cover um variations officers would steer an applicant in just like a representative in terms of what the best process would be and it would be our preference to have a cleaner process it's not duplicate licenses if they did put in a fresh application to voluntary um put forward the surrendering as a clean outcome worst example that i can think is is serene entertainments yes the junk house that's the one i was talking about it had something like six and that that that was a bit of naughty lawyering the lawyer that was representing and unfortunately the the act doesn't stop them from doing that it doesn't have the gambling acts and the gambling act you can only have one premises license existence yeah same space but under the licensing act it doesn't yeah now every enforcement agency licensing authority police anybody doesn't want more than one license yeah because it's it's a way to try and be mischievous yes and hoodwink that's a hoodwink yeah so um it's something certainly if you if you've got if your responsible authority's got a sniff that somebody was trying to do something for those reasons i'm pretty sure they come in front of you as a licensed subcommittee they wouldn't just let each go through on the nodding it would get representations and then you can assess it and you and you can you know if i was advising you as a committee that there so you're entirely entitled to work out why they're trying to do this what's the reason that they need to have um another license you could only refuse it if you felt that that was potentially going to compromise one or more of the license yeah you still have to tie it back into the licensing objectives you have the ability to um you know to dig into what's going on it's not as frequent as it used to be and i would say that you as a borough because of a certain person who was we laugh and busy yes yes and i did more than most boroughs that i know you know i mean i had not seen the problem exist i mean i did your all of your appeals on yes entertainment's case and it was it was it was a nonsense really and and they just got away with cheating for a while eventually it was unpicked and and went away but it was labor intensive about your officers and but there's nothing in law to stop it from happening but you're right what we would do is through pre-application advice would give people a proper steer yeah and if offices did have concern and we could we would bring it to committee yeah and also we've doubled down on the fact that in this policy we specifically make reference to shadow licenses and the responsibility of landlines section 22.5 on page 46 so we actually vocalize the facts that it's an area we take seriously and we lay down our expectations for people who hold a shadow license and again that's a lesson learned which is why we specifically reference it in this policy so um but yeah we looked at that specifically didn't we 100% oh that's finesse it's obvious and i think we've got the wording right on there which pretty much says the council remains concerned that the holding of additional licenses has the potential undermine the sanctions available to it um in response to review application um and so i think the wording there is actually good um and also mentions potentially undermining the objective calmness order because i think it gives community more power and decision making because you're it's rooted in the policy as a potential issue i think if you if you we if if you've got an application for a state school license to go on and you have those concerns triggered by representations i'm pretty sure that your legal advisor would make sure that you you've weaved in this section to your decision this precisely hence it being there because it's a decision letter because what the primary legislation says is if that policy has become your policy you have to have regard to it same as the section 182 guidance so you can hang your hat on these sections to refuse things so which is why do we have a limit of how many license one premises could have no it's the whole better does it be any number i'm guessing you'll know who you're talking about yes you know who we're talking about yes lovely man um yes okay thank you for clarity on that um um now you guys are not here all the time so have you been working with the likes of mandy ken and umair um like particular situations we wouldn't always remember as committee members but they are up to date with everything in this and as you say have it as a steer for us when making our decisions then so specifically mandy is extremely busy but so we've been principally dealing with umar um who sits on a lot of committees yes and his specific um feedback was that the policy was much more friendly for him's legal advisor to utilize more yes as is the section 102 guidance as opposed to our old policy which we found it difficult to link to justify decision making yeah and he's also fed in from previous cases in terms of what he would like to see in there um as a legal advisor and issues and hurdles that we've faced hence the doubling down on the shadow licenses and specifically referencing it yeah so we wanted this policy to you know to not be a policy that sits on a shelf because we have to have one yeah we want it to be an operationally useful policy whether that's for applicants offices um or legal team you're in your decision making you can actually make reference to it in your decision making which then makes decisions more robust less likely to to be open to appeal um so yeah they are abreast of it they've had copies of it and they're both quite instructive in their feedback of it and he gets it yes umair is it good yes he needed he gets it yep okay um any other questions there um right page 23 um and it's third paragraph down an exhibition or film that is that is incidental to another activity where an other activity in so it is not itself a description or entertainment set out in the paragraph two of schedule one uh to the 2003 act is exempt now from licensing can you give me an example because i didn't understand what that actually meant all right let me just so this this this this part of the policy is all around the live music yes 2012 um which basically deregulated a lot of regulated entertainment um so the thing you were specifically referring to was that the unity premise yes i'm sorry it's uh page 23 the third paragraph down on the left of the exception of film when it was incidental to another so we've had that in westfield so projects yeah um where they've used um film as part of their product launch say in westfield and they've come to us and said oh this is a film we need licensing you don't because the film's incidental to your product launch um whole part of licensing um exhibitions of films is is taking that incidental element out of it there would be no point in licensing something it was incidental basically promotional materials primary purpose of why people are going is not to watch the film it's incidental it's like incidental music um yeah the same thing yeah i mean the deregulation order which is detailed i think really clearly in these paragraphs which is good because a lot of people still struggle with how to interpret this yeah though it's good that it's there i think so yeah because it all it's in the section 182 guidance badly yeah yeah this is i think this is much needed yeah so we notice there's been a lot of deregulation so from 253 people to 500 people in different for instance there's different um from so whether it's a casino or a pub or whether it's a so like a thousand people now for the concerts up to a thousand people and so it's as you said it's clearer for me um and i'm sure my my colleagues um so it's more like on a 500 basis now for everything am i correct so the deregulation number that always sticks to mind for me is is 100 is it yeah um so as officers we often give advice to applicants on deregulation and what they need a license for and what they don't and there's a massive misunderstanding um we we're off we often give advice 500 is normally the number um whether it's a workplace exemption or another exemption i don't know why that is presumably it's just a threshold um a risk base based on capacity and the officers are very very used to giving advice um you shouldn't have something coming to your committee wrong because officers should have given advice prior to that coming right and they're very used to especially around music yeah events as well through the safety group particularly around what they need to license and what they don't and quite often you'll find that a lot does fall out licensing but we'll mop it up in our safety advisory group function where we also focus on public safety and other elements that comes into play yeah previously yeah um the other thing i wanted to ask and i know this wouldn't really come to us but you've got on page 24 with vessel and ships and I did i did like that one it was support it was of course so basically just so unclear when the ship is on water it doesn't need a license but if it's on port side it does and the same with an airplane if it's in the air it doesn't license but uh if it's on the runway it does so i mean the good example for me relevant to us was was ocean beaver yes that's why i want to take lots of activities along the Thames the reason they came to us for a license because their place of birthing their usual place on this board borough yeah so if they want to do lots of activity and they're not doing a transit from a to b or international voyage so if they're in uk waters they need lots of activity they'll be licensed at the place of their mooring slash berth yeah so it may be in the future we see more of those it may be that you know another ocean even might come back and it was a very good example of the licensing act maybe having some quirks in yeah so um yeah you know that one made me laugh when i looked at that there are several vessels that are permanently moored not in newton no now um but that that you know if there's a license for activity on the premises it's a oiler barge yes stocks number example so it's permanently moored it's in the boroughs doing license for activities um yeah all right um we do get a lot well not a lot lot but we do get hotels so uh just a little bit feedback on the mini bus um the mini bars in the rooms um and i was asking do they actually need a license because it's alcohol but then children in rooms there was something else i read it's a lot of reading yesterday um so for a mini bar a hotel needs a license so it's my understanding partly quoting me from off here is that if there's a retail sale of alcohol they need a license so if you pay for that room you pay for the mini bar tab that it captures a license of activity does it not you don't need to have the mini bar license no because the the contract concludes where the license will be which will be either in reception or or in the bar area so the actual under the old act we used to redline all of the bedrooms and things like that nowadays you don't have to do that it's a case that the the alcohol sale concludes at the point where the alcohol is appropriated to the contract and the sale concludes at that point where the money in effect exchanges hands at the reception or yeah or ever and it's pretty rare to have hotels that have many bars that don't actually have some sort of bar and again trading standards as part of an application would work with the client to work out the different controls and different under sales chinese 25 etc it may be that we've got model which is a cover element but can i just ask a quick question on the section where we've got sexual entertainment venue it says it will result case by case obviously we've got a big campaigning and issues around sex workers in the borough so if something like that came up how would we kind of deal with it kind of like yeah because it because it's such a big thing that happening with policies and campaigns and everything that's happened locally in the borough so we used to have a small number of um edu venues don't think we realized we need to amend this yeah that should say the local government miscellaneous provisions are not licensing out well no i think i think the rationale for this and quote me if i'm wrong is the sevs you've had in the past so jankos is a good example the license for activity i think so the way that we've regulated in the past is newham never adopted specific legislation so so as a borrower um there's this specific um act brought in to deal with sexual entertainment venues when it's probably more of a pressing problem in the past than it is now yeah now boroughs didn't have to adopt and you're wronging and you've never adopted it you know way back when was the illustration born in paddy goddess roughly 14 years ago yeah so it's quite a while back so any venue that was licensed was licensed for license collecting gender licensing acts for instance dancing or similar activities if that was of a sexual nature and there was concern around safety or children the license would have been properly conditioned to reflect that um in terms of children accessing times yeah and protection for yeah because i remember that one one particular point it was about the premises license holder he had children underage and they lived kind of upstairs where they would have to go through that stuff yeah to again so that case was was dealt with and you know undermining some objectives order potential from harm the license would expect to be properly conditioned on a case-by-case basis to that business yeah um so we don't have we haven't adopted wider um sev legislation and when do you think we last had anybody to satisfy that they wanted to offer in the last in the last five years i've been here we've never had an application once yeah multiple reasons they've all dropped off thank god so yeah i would say is depending on where you are some boroughs it might be more relevant if you have a so if there was a if we saw an uptake or an uptick in applications it might be that we'd reflect our policy and and what we needed to do but at this point i don't see any evidence saying that we should adopt any legislation that we could have done in the past and so we would deal with any applicant on its own merits and we would ensure it's properly conditioned under the right objective all right uh i'm going to club premises certificates and i've always been a little bit aware but this has been made quite clear but just under 10.2 where in order for um qualifying clubs to supply alcohol and provide other last premises so when you say club right so when i think of not a club i go into like i pay at the door go and pay at the bar but am i taking that you're talking like a private club where you have membership right historically it's been members a member's club right a rugby club where you've got where members that you have membership so you use that premises and the alcohol was bought by the organization and it's just distributed by members yeah no retail sale but they they don't need a dps um it's but it has to be a club and it has to meet the threshold of being a club right which we have less and less and less in new i don't i actually don't think we have more than what 10th i wouldn't know i would make i would say between six maybe maybe half maybe a dozen max but no okay any three other benefits from having running as a club than operating as a traditional allow the public in and sell alcohol and those benefits have gradually been eroding so people who ran clubs most of them have transferred to having a premises license now so that they can allow members of the public in because members clubs were only allowed to allow members members and they had to have prescriptive rules so it's quite onerous and there's not the benefits that there used to be now to do that if they wanted to say sublet to bring in revenue they have to have a premises license anyway so there's i think there used to be some tax exemptions there were taxes not anymore yes that's right yeah there's no there's no real unless genuine club yeah clubs that have got both yeah so i act for the irish centre in leeds which is huge it's a live music venue and they got into trouble because they'd got a member's um member's certificate and not an on license and they were allowing people to turn up and buy tickets to come and see like it was quite a good little live music venue so in the end we the live music room we'd put a premises license on so that members of the public can come yeah retain their premises certificate for some of the other rooms so that they could maintain the members and yeah so there are quite a few hybrids but maybe not on the other side not on you i mean there are some genuine clubs left and they are dwindling probably yeah you find the times yeah less relevant now than they were once were i just had one clarity what's the difference between provisional statements and premises licensing but this is what i was talking about before when i waffled on the wrong tangent even though statement is um is what you're um what you're planning on doing and to gauge from responsible authorities how it's going to be receptive before you put in your full application and again i've never done very very very we've come outside of the gambling a similar thing yeah but you you will get maybe not so much here but there are some lawyers who advise their clients to put them in and my view is is they get double feet because i don't see the relevance of applying for a provisional stain because there's nothing in the gambling in the licensing act to stop you from putting your premises license in when it's a building that's right yeah so by doing this all you're doing in real terms is you are putting your marker down with the provisional statement but if new people come into the area um so for example if there's a new housing development near where you've got your provisional statement when you then apply for your premises license they can still object to that so i personally don't see the benefit in it other than getting to say something but yeah it says it can be used for license for activity so it pretty much gives the indication that it will do the similar kind of job yeah but you're paying twice yeah yeah so so if someone got a provisional statement they wouldn't need to get the you've still got to get your premises license they have to it doesn't collaborate right no so and we would steer people to a pre-application box service because i think yes that's the mediation because i want the x y and z actually fantastic have you thought about doing this this is around the borough this is the context um i would be very surprised if you ever sit on a committee that's got provision statements but at least we now know what it is yeah uh uh guys no good hi um right so white so i've looked at the hours of license and activities the only something that was in my mind other noise and vibration um i was thinking along the lines of where we now have uber age delivery and loads of others delivering food all over the place is that does any of that come under there if the riders yeah who are congregating you know that the stuff the company won't allow them inside that's in the conditions which and it's now pulling them i am pulling up yeah i'm sure if your operation which is delivery or whatever whatever taking food from your premises has an impact then that is relevant to the license and public nuisance so you put in here is some suggested conditions which are i just asked because i don't see that from here but i can see on my booklet was it was it would it sound like delivery services yeah so i'm sure we had some other ones under noise separates that i may be right um well this yeah so i mean it's certainly funny enough to hear it out of them this morning it didn't come up in my case it came up in the case that was on before me um which was going to be a jerk chicken um premises in peckham one of the main concerns by the residents was are you going to be using the delivery services that's what causes us the biggest nuisance because of the noise they make most banks the engine's ticking out common cars so yeah the impact of of those services you can take into consideration and you would expect operators that are going down the route of having those services to work out systems in place that and so so um you know the noise team um do pick up on that but yes it's an issue under noise ao what page is that and this page 98 at the top of 98 is necessary um that's a broader control um but when ian and colleagues would always look at an application they would be commenting on delivery from a public nuisance perspective and ensuring there's adequate controls um so we have semi-addressed it in the model conditions i think we do actually address it under the public nuisance section yeah but it is something that do do look up almost a reasonable time like they manage noise from opeds etc etc and that's becoming a much like more frequent yeah it's such a big i just wonder because as um i declare what i do with i'm a rather drivers professional drivers union right and i look at it the simple way of dealing with it is that the guys doing deliveries for living they should be allowed access and somewhere inside the premises then they're not creating outside but that's where you need some perspective yeah but that would do with itself as a layout but there is nothing to stop you from probing into that in any contested application which we do which we do bring it up he's on that one which we do so um it was a separate um this was off the back of the pandemic when this really exploded around welfare delivery drivers and also we have a statutory duty and the health and safety work act so if you had a complaint about working conditions work you know workplace regulations i mean in the past we've looked at provision for for them under that um but from a noise perspective we definitely pick up at an application stage yeah 100 thank you is that also you also included basically like using basic toilets and slippers and everything yep you know i have this thing about toilets as well so under sticking on to the model conditions while we're here have you made i mean i've whizzed through it but have you made any major changes yeah we have yeah right would you just like to run us through that we took the old conditions and x so all the responsible laboratories got together and we took out the ones we just no longer use them there's ones we haven't used for years and years and years so we we kept the ones that are our bread and butter conditions so be careful because every application is like saying that we don't pose conditions on um but the conditions are here as a helpful guide really for to to kind of sense expectations what we've tried to do to make it more usable which i prefer is you've broken them down into the four objectives and then specifically also into the different types of business that we regularly deal with so one of the pet peeves for me late night refreshments um so actually we've got sections specifically late night refreshment um on kind of the conditions we'd expect an operator to put in and there's one noise you know for for obvious reasons this one mentions all third-party delivery drivers riders should be instructed to wait inside the premises and not to leave their engines running close car doors and not to play loud music while outside so going back to our previous point yeah we've tried to put conditions not only in the different objectives under this relevant heading but to also capture the relevant business day-by-day basis so late night refreshments probably a good example alcohol delivery service is another good example expansion post pandemic warehouses and we want to ensure delivery takes place to homes properly so trading standards sales and how they check id um off sales we've done a lot of work on off sales and you saw the piece you wrote in iol on that um we have some really robust off sales conditions that we try to offer up um when with classes is not properly conditioned so we've clubbed that together um with the conditions that we know work and that we know um prevent street drinking food led premises we've got conditions specifically more relevant to them um so we've tried to make the conditions usable but we don't want to prescribe one-size-fits-all conditions but these are to pick up and really to set a steer we've done the same for event management plans for large venues and events for expectation um around a risk-based approach to licensing and management plan how we expect that to be dealt with in parallel to a license so i would say that the conditions they're slightly less but i think they're more user-friendly more to the point they're very focused and they're focused and what i would expect to see as applicants take this as steer but to deliver stuff that's right for them their business information yeah if we're not here to tell them no no no i'm a huge fan of these by the way uh you know i mean i i as a as an applicant solicitor will always go to the local policy and you've got us there on this i was drafting an application yesterday for a food led place in leeds please for a similar system to this and it's fantastic when you can drill down to what your authority wants yeah and then i can say to my client you know this is what the authority is looking for is anything here that you don't want to live with and we won't offer everything and then gives the responsible authorities there's so much work goes on in the background before it gets to committee stage where they'll be able to think look at an application well you know actually looking at what they're trying to do and in this locality clearly sees what they're offering from our standard conferences a model a really good example of what we're talking about licensing objectives or they might say well actually we want the following conditions and talk to the agent or to the the applicant and then there's a good bit of communication it gives a really good sort of like rules of engagement as to what's expected for me that's the most important thing for me like our approach is mediation but we want successful businesses we want responsible businesses and everyone's different no one size fits all we want principally its policy to set a tone of what we expect and so it's a foster dialogue and so food lead premise is a good example there's some really robust simple conditions i would imagine pretty much any applicant doing food lead would be pretty happy to take we've had many premises that have gone down that route and then ended up being a club and the the polar opposite of food their premises yeah so we want this to be user-friendly for applicants because the defining if we get it right first time you know we're saving time money resources we're building most importantly relationships at the onset which really sets the tone from the beginning i think the model poorly conditions again for me it's all about this document is engaging with people to give them a fighting chance of doing it right and again it goes back to people we mentioned before sme businesses small businesses and businesses maybe they don't have deep pockets they can't afford legal representation again um with our pre-application service being affordable plus this document i really believe plus the translational element of it we're giving applicants across the breadth of fighting chance of putting in a better quality application but this also highlights the fact that um a lot of people don't actually read stuff you'd be surprised literally risking it out to say look this could be your next application and they'll read the operating schedule and they would have nothing from the module conditions or nothing i mean that's nothing that we can do but what you've done you've really tidied this up and you've made it very tight and it's exactly what they need but then it's down to them whether or not yeah they read it my absolute passion is to make it accessible for me that's a number one thing yeah and newham's a challenging bar at the best of times we have many small businesses where english is not necessarily a first language yeah aren't deep um you didn't want this to get successful as possible to allow businesses to do well right first time because if we set these relationships at the beginning we're not coming down afterwards and forcing and being in fact you're not getting inundated with yeah stuff going to where it should be sorted in the mediation stage so the model conditions are a good example of this breaking down the objective clearly in the policy is trying to give people as much as they can to to set it up okay it's a big question around the cctv it might not be relevant or it might be something that we don't we can't do but if someone wanted to do cctv because obviously at the moment with the face recognition it has caused the public outright because of the way it's been used i was someone who cctv there is the two argument around women's safety at some point women don't feel safe is someone watching them so if someone would came to a licensing committee with these kind of reasoning like they felt like the shop next door has a cctv but i felt i've been watched that's all they do with it is that something that we could bring up in the licensing committee or how would that how would you deal with something like that it's kind of it's a difficult one because sometimes i've been in cases where someone had a cctv help find who is a culprit but there are times where i've had women come up to me and say we feel uncomfortable we feel watched by the shopkeeper so something like that how do you deal with it so i think i would park facial recognition as something very different from cctv and cctv my experience hand on heart is it is absolutely essential to safeguard everyone whether it's the shop owner the individual using it um the detection um and and bringing to justice of crime is fundamentally um you know at the end of the day there's no nothing forces someone to put forward this cctv um condition on their license it may be cases that it's onerous and unnecessary ending on the application and an application stage we would work with the responsible authorities principally the police around cctv because it's linked to objective crime disorder and to mediate with the applicant as to why it's necessary and have those discussions early on if someone was an allegation of someone misusing their cctv to cause harassment or whatever and i can't think of how why that would happen but if it did happen that's something that could be can be dealt with um in in the relevant way but cctv for me is is principally a tool for um for safeguarding yes um what i would say in this policy as well um we really have tried to make women's safety um absolutely forefront of this policy and dedicated a whole section to it consultation that we had some comments around maybe um vulnerability was wider than being a women-only issue not a humble feeling this statistically vulnerability to women is it dwarfs most other groups and that's why we wanted to on its own to really highlight how seriously we take it but we have taken on feedback to to broaden it to wider vulnerability and and i think we give a very good steer again and towing as to what we expect from license holders specifically around um people feeling safer and and the steps they can put effective steps they can put in around women's safety and it might be that you want to have a look at i think section 28 have a look at this suggested measures quickly something like because obviously i've had both incidents come to me so if something like that comes i could say it's not something that the licensing committee deals with it's more of a police matter yeah if someone felt like cctv was being misused and they felt like harassed or stressed by that then that would be a matter that we'd get them to take up principally with the police as a police matter if that ended up being something that um interacts with the licensing objectives as license premises it may be that the police would would deal with that under licensing powers but principally i think that'd be a matter um to take to the police first unless you disagree i agree thank you yes sign go back to delivery services the thing about yes delivery um where it's an alcohol delivery service yes yes yes yes premises which is obviously licensed and then there's a thing in here that says hackney or private hire should not be used for deliveries under any circumstances that's true yeah yeah i just wondered where the reasoning was for that because sometimes if it's a delivery service and it's to say i don't know a small house party somewhere going on around the corner as long as the alcohol is secure in a boot and unopened same as in u.s law isn't it you can carry alcohol providing it's not opened don't you i think i can't see what the issue is this is so first of all that these these are suggestive conditions so what i would say is so we we don't license hackney carriage some some you know we don't see the various lives so i don't know there's there's strict safeguarding that for obvious reasons uh so it's unfavorable for hackney carriages to be involved in the delivery of licensing i think that's just a general approach to safeguarding it's not things that are great mixing from where i live i know for a fact that premises you get a takeaway it's delivered by yeah happy carriage of course you know yeah delivering your takeaway yeah i don't know paddy if you've got anything you know i think as you said it's a condition people might not offer it or might want to argue it if it goes to a live hearing but it's not something we would absolutely mandate again everything's case by case basis obviously you wouldn't be actually you wouldn't be doing your happy carriage service at the same time as delivering license no i think it's probably but it's more pretty private in the business we carry side of things but yeah sort of thing you must live in a very posh place they come around with bikes around our way no it's the public transport's too bad so yes it's not by full distances okay um so what's homie how is your non-timing okay so i'm looking at backing up by about five o'clock so um and i'm not gonna strings up so very quickly uh back to the eastham communicative impact area now that has been very contentious took a long time to come through the processes cabinets through full council then it didn't have it has there been any changes any updates um it is as it was when it was passed at full council so we are completely there's been some changes so i'm gonna put it out there i'm not like okay um cumulative impact assessments particularly yeah um having said that the challenges of working in the london borough i appreciate that we still are in a position where i think it adds more than it takes away um that we reduced our cumulative impact assessment yes but we retained it we focused it and all those particular hot spots yeah more valuable at the same time for me there's a cumulative impact of the assessment we're not saying to people no we're saying to people there's a higher threshold yeah but we counterbalance that with our pre-application advice and mediation service so what i would say is nothing has changed so appendix four of the report you'll find the data review from which i did page um i haven't got the oh don't know so if you go to to the public so it won't be in here if your policy if you go to the published agenda pack this one the published agenda pack that was put out okay for the next all right yeah yeah you go to appendix four um you'll find the cumulative impact assessment data report which i did in november 2024 so we redid the policy we fought it prudent to relook at our cia even though we signed it off relatively not long ago i think from memory april 2024 yeah uh yes so what what we found is crunching the data and it's really worthwhile reading this appendix because it is all the data from london ambulance service and the police internally from the council and it shows that there's no particularly broad change um in in anything and it's still just the most accumulative impact assessment personally being kept as it is um there were some ever so slight differences from memory there was a small section of catherine road and something further up high street north but they were deemed two isolated cases of street drinking to be taken by seriously in terms of the data so we're broadly happy that the cia should remain the same particularly um the cannytown star lane yes which is for me fundamentally important for obvious reasons having said that we decided um looking at the data the data was showing us that there was no need for chlorosis or regulated entertainment on its own to be within the scope of the cia what was driving the alcohol related harms data was linked to the retail sale of alcohol and late night refreshment either through asb or through alcohol so we've refined areas to only capture the retail sale of alcohol and or late night refreshment so you've just taken some activities outside the scope of the cia but we've kept it as is covering the same areas and the data the data shows exactly um so i would i would look at um appendix for the published committee report to have yourselves the data from memory i think the alcohol harms data is pretty much the same as as was the crime data and we've plotted it all um on the borough so you can see how it lines up with the cia all right yeah it's no material changes other than other than that going back to that we know that we have certain establishments that fall outside of the c z scope they do late night refreshments because they close at four or five o'clock in the morning still selling alcohol at that time but you didn't see that as being prudent to add but you've kept them on the outskirts so we know what you're saying expand it because for me cumulative impact the the principal thing is not about specific premises being it's about the saturation within an area offering the same service causing a problem whether that be littering or noise or crime um if if we did that we felt we'd be going back down the avenue of missions further and further and then we might as well capture the whole borough so at the end of the day every application would be on the same merits every complaint or issue we investigate and take appropriate action the cia as is captures our most challenging areas principally our high streets strapped with an east ham for different various reasons for now until anything massively changes we thought it prudent as is but i wanted to move away from the um the necessity to creep further out again because i think it takes away from the argument of it being more refined all right uh just very quickly for me uh with regards to the police um and them come to committee and so i've seen eventually crime disorder um what we found in committee a lot of the times was the wording of asb and connor would always say it covers a multitude of sense right but when we use right but when we use it we're usually talking about um uh knife offenses or shootings or throwing acid in people's faces and i was just wondering has it stayed the same in this policy um with regards to using those three letters and it being explained correctly in in the policy i i i don't know to be honest with you so the provincial crime disorder um section covers the main issues that we would would would would expect um applicants to be aware of so behavior of customers outside premises door supervisors the use of glass instant reporting books cctv all the you know high volume vertical drinking all of the areas that we would advise applicants to anyway when considering our application i don't think we've gone down to specifically say what is crime disorder what is that merge of asb what is that then virgin to nuisance from crime risk order i think for me the section 182 guidance is is the principal place for i'm just looking at um the general bit that we've put in um so and again i think that's i personally think the tone is cool people need to be aware of how they're going to promote the prevention of climate disorder yes um what options are appropriate um the different factors that will you know impact that the nature of style of the venue the activities conducted the location the clientele um about appropriate conditions being in place um i think it sets the correct tone asp is going to always be on technically the local authority leads on asp the majority of it it's going to potentially fall within prevention of crime disorder or prevention of nuisance or both i think it's going to be a kind of case-by-case um focus more on section one at two guidance to go back to our positions that's a general principle position which the home office covers in the section 182 guidance your local policies about local issues so yeah i think it needs to be directed to the section 182 local policy and also like it's very important in this policy that you know the license is responsible for their premises the red line and specifically like you know if you look at the biden scenario either side of the premises externally we have linked in our public space protection order and stuff controls we have as a council it's not down necessarily to the licensing ourselves um so i think in this policy we do mention the pspo um and how licensing interacts with the pspo how we combat street drinking and broader street-based asp which might not necessarily be interlinked with licensing and again for me it's down to a case-by-case basis about where it's appropriate to draw the line and i think the section 102 guidance is the appropriate place to take us there um but within our local policy thank you right are there any questions or anything that you're not sure of you think you want to go over say we've we've brought in something around martin's law yeah i saw that and terrorism yeah and obviously it's still working its way through the legal process and this it hasn't been finalized yet the reason we put it in is to give a broad steer around our expectations and the importance um of of the subject um it's an area where communities will make you push us to be more prescriptive yeah until the legislation is kind of finalized we didn't want to go above and beyond what we've put in is a reasonable steer for applicants yeah great question um i feel it's under public safety actually but um public safety is um hey it's page 57 so what we've done we've just formally recognized that the fillers worked because the reality is that currently licensed premises will have duty of care and responsibility especially when you deal with events through safety advisory we already advise people strongly to undertake active learning relevant training and to link up with the police but we decided as this is still going through that we'll make reference to it but not be too prescriptive i think that's it i i addition to the policy it was section on women's safety which i'm particularly passionate about section 28 i think that's been a really strong addition around drink spiking and what we expect from behavior ability and it's just given i think um license holders especially ones like the excel and all the bigger places where we have a lot of people um a little bit of not a better idea of how they could protect their premises and keep keep our customers you'll find that all of the bigger capacity venues like excel like stadium like yeah so whatever my guys who they've got the licenses will already be doing this yeah you know i think martin's law is going to be on the venues that are just underneath yeah people haven't really paid a great deal of attention but certainly the bigger venues that i act for will have as part of their emps their inbound management they will have terrorism section and they will employ consultants to do it so yeah um um other other than that i think that's the that's the that's the main points um that i'd like to draw out well if there's nothing else um culture thanks i was looking at the special effects kind of stuff on page 56 so yeah like in lots of different events smoke machines get away else kind of are used how would you monitor what is what you can what you can't kind of license because obviously firearms obviously you you know you can't but there are lots of things that people use at an event in the event how would you monitor or is it monitoring or would it be where would you find information in the actual policy itself have you covered that certainly special effects themselves aren't licensable so um so with special effects really it falls under other legislation the proper safety work act principally um with events certain events come across our desk that we actively look at special effects so for instance when we license the stadium and give their um special safety certificates we look at um anything around lasers and pyrotechnics etc we physically look at controls in place we physically look at risk assessments we actually go for pre-event checks etc if a if a smaller premises is used like a smoke machine or hired and stuff for specific um events if it's mismanaged it can be a risk to public safety um we we would expect it to be risk assessed etc we would always give support to venues if we had complaints we'd investigate it when we do our proactive visits we came across it with advice it's not as self-licensible it's the management of health and safety which kind of falls parallel to other powers we've got if we ever had an issue we we've got broad powers we can prohibit stuff we can see stuff we can serve improvement notices and we can do all sorts there has been horrific stories of special effects gone wrong yeah um but cannons like confetti cannons where they've swept up stuff and put in shrapnel and bits of metal back in and or you know what was the famous one with dry ice and um but again this is an educational piece like this isn't something an application stage necessarily but it is covered but it's covered because it's a public sector yeah you come across okay there are certain types of venues where this will be a consideration okay um i'm happy is there anything else you'd like to share with us before you go because we dragged you away from south london no yeah i would i just wanted to i mean i've i've thoroughly enjoyed being involved in the process i think ed's taken massive ownership of this yes really enjoyed working on it and i think it was amazing and heidi as well heidi used to be a licensing officer at camden and she was also westminster and we got to steer away from westminster and borrow a bit from camden we think we've created a really user-friendly document i just wanted to be here to answer any questions you may have i think it's really good and do you think it's the future yes absolutely reinvented in five years time it can be tinkered with yeah so do you have the same policy documents for five years i think so unless there's i mean we can review whenever we like okay i see i it's been that process tend to be reviewed much more frequently yeah five years it used to be every three years and the law changed to allow it to be every five years so quite a lot of authorities were saying we're reviewing it's costing us a lot of consultation nothing's really changing yeah actually there's some really important points because of the cia policy is linked as an appendix to the main document so i have the ability to review it without reviewing the whole policy so and does that would that have again to go back to cabinet just committee so under the constitution so i would like to annually keep the accumulative impact area under review and look at the data it's good practice yeah um the policy itself stands the test of time which is why the cia is an appendix to the policy itself because i didn't think it makes sense bringing the whole thing through cabinet council yeah and it could yeah oh yeah there was ever a massive change then obviously yeah something that we felt the need to review the policy we could do it at our discretion yeah and it's refreshing to see an authority that's trying to do this document is really good well done to everyone like it's probably the most easiest policy document that was easy to digest understand and thank you so much because i think this is probably the most easiest thing i've read yeah in terms of policy honestly i think because for me this is the driving thing my passion is to make it it is by clientele and for our residents and as you keep saying it's useless friendly it's easy on the eye it's you know it's quite dynamic it's a really good reference point like you're doing something and you could secretly like just go through and go this is what you say it's kind of stuff so searchability well done searchability is really important that's the best that's the main thing for me because like it truly is interactive you know you want to know about now it's not still you go straight there yeah and for me the more user friendly is the better is yeah yeah we'll embed the translation panel i think it's more than that in the attendance again we've paid for that since at the language shop and it covers a whole lot of units like i don't know of any other policies that are that very true granular in the way that they reach different people yeah and it's important and interactive yeah it does because you know it's just thank you thank you for making it yeah no people it's so easy to interact with it do you know what we'll have more people another note so the consultation you're you're aware that we had some yeah yes out of the seven three so out of the seven we had um three responses that weren't favorable around the policy yeah um unfortunately historically um two of them were license holders or ex-license holders that faced some action specifically and i think there's a confusion between if i'm honest personal responsibility enforcement individual case outcome and the purpose of policy so this consultation is to steer policy on cases specific areas where the policy is lacking and resulting in maybe outcomes or disproportionality absolute um so i've responded in depth to really of those consultations specifically and it is worth looking at the appendix i think seven um former yeah where we formally respond to those out of the constantly responses that only tweaks this policy have been because of the sacred business network to make the section on women's safety more inclusive in its language which is um no other um comments have been taken on board in terms of changing the draft policy i think it's very important to look at the last three and to look specifically at our public response to those um to understand how we've interacted as reasonably as we can if there's anything around it's difficult discussion what's going to be the the area to focus on okay and uh just so that we're clear on the 20th will be the um committee review on on this policy which will be open to the public um and we have an idea they may or may not attend its particular three groups that may not attend or attend on that day so i know that uh so who's sitting on the committee my name so i don't know if any like to come and see how it's how it's all quite it's going to be my first as well so um i can't make it that day but if you're the mother that i would have loved to it starts at 10 starts so yeah if you would like to just pop your heads in and just see how the actual process works you'll be here as well loop has it all it'll be it'll be myself yeah and there won't be any other offices but there will be um mandy and this will be legal so um i don't know whether we'll have people turn up again today it's a public meeting um but it is a public meeting it's it's it's not it's not a chance to scrutinize that question i think that's quite important in that respect it's a meeting held in public it's not a public meeting for different things okay so um so that probably be a couple of hours it shouldn't be in anything too extensive should it so for me um i i envisage a similar process today going through the going through looking at the cia looking at the um annex four yeah interrogating the policy asking questions that have been asked today which is the important important process to take place um all right um okay so we'll see you on the 20th thank you patty thank you very much ellie for coming thanks for all your hard work we really appreciate it thanks guys