Last week the short consultation period on the raft of forms, regulations and statutory instruments that provide the basis for the new licensing system ended.
I, along with many others, made a response to the Department for Culture Media and Sport (DCMS), with a number of criticisms and observations. The department is now meant to sift through these and come up with an accurate, clear and workable system in a matter of a few weeks.
What puzzles me considerably is how, after nearly two years of deliberation and consultation, including large groups and sub-groups representing the licensed trade (all of whom seemed terribly proud to be sitting on a real Government committee), we can have arrived at this mess.
What were they consulting on? Who designed the forms without argument the worst I have ever seen in 30 years? Why didn't the licensed trade fight for clarity, simplicity and accuracy during the months of consultation? Or was it, as I have heard, that they weren't really consulted at all?
If it is the latter, then the working groups were a sham and the trade leaders ought to have recognised it much earlier. If today, looking at the draft regulations and the pronouncements of some local authorities, they are proud of their participation, then I for one am very sorry for them.
The problem now is the pressure that has been applied because of the lack of time. Talking to participants on all sides, I am convinced that everyone wants a workable licensing system, but they have grave fears that the lack of proper consideration of the technicalities of the licensing process and its inherent delays have presented a situation in which Corporal Jones would feel very much at home!
This is to some extent borne out by the document on fees to which I referred last week. One section actually calculates in minutes how long the local authority administration process for various applications should take. In minutes! As one local council official wryly commented to me: "It takes me that long to walk to the photocopier on the third floor".
To suggest that a temporary event notice application, for example, actually takes 45 minutes to process, while an application for a copy of a licence which has been lost takes 15 minutes (plus copy production time) just does not take into account the way local authorities work, or the problems which can arise. One lost piece of paper, or an unreadable address and you are over time and the whole timing process goes out of the window.
In any event, get real. Local authorities simply do not work to this sort of timing. It once took me eight months to get a variation of a special hours certificate for Sundays in Westminster. Others tell of weeks or months of delay. This is all going to change overnight?
Of course not. It has come about because of the pressure put on themselves by the Government to live up to their highfalutin' promises in the White Paper, coupled with a blind adherence to principle rather than practicality by the officials charged with putting the package together.
Now we are up against it, and this complicated scheme is due to go live next February, with neither the regulations nor the fees in their final form and just 11 weeks to go. For once, "meltdown" might be an appropriate, if scary, word to use.
But one crumb of comfort. Those application forms will be improved. They've got to be. But why, oh why, didn't the DCMS get them properly drafted in the first place and have them checked over by people who know about these things? Sheer cussedness, I think.