"It's like walking over hot coals!" That's what one licensee said to me this week as she related the problems over putting in her application for a premises licence, complete with a variation. She was referring to the amazing number of things she had to get right, and the seemingly endless comments and objections from officials and neighbours on what she proposed to do.
It is no wonder that a growing number of people have decided merely to go for grandfather rights and not bother with variation at this stage. Although it may cost extra, it may well prove to be an easier journey than the one that my licensee friend has embarked upon.
Why is it so difficult? Well, I have tried to answer that question several times on this page. It is a combination of an untried system, in which everyone is starting from scratch, together with a cumbersome and bureaucratic application process that presents a stumbling block every step of the way.
I am tending to sound like a broken record on this, but every week we are reporting in this newspaper on some other difficulty arising from the change-over. Surely even the DCMS cannot ignore the statistics if Westminster City Council has actually rejected 69 applications as invalid out of 159 received, then something is going seriously wrong.
Here are a few pointers to the issues that seem to have caused major problems:
l Who are you? At the beginning of the form you have to state in what capacity you are applying as an individual, a company, a registered charity, a club or some other form of applicant. Some people are getting this wrong, or filling in individual names when they do not need to.
l Rateable value You have to fill this in, so you must know it. If you leave the space blank because you do not know, then the form is invalid. Remember that if you have no separate rateable value, it is the RV for the whole building.
l Existing licences Have you sent the proper copies of current licences (including entertainment)? If you ticked the entertainment box and do not provide a PEL, you have slipped up.
l Premises supervisor You cannot leave this blank because no-one has yet got a personal licence. You must put a name and address in here, even if the personal licence has not yet been processed.
l Licence conditions All justices' licences are granted subject to the conditions laid out in the Licensing Act 1964; some special ones may have been added to your licence, in which case they will be noted on it. Public entertainment licences are granted subject to standard conditions, which the local authority already knows. Check that you have completed these boxes properly.
l Fee The fee must be sent with the application or it will not be processed. The fee must relate to the band of the correct rateable value.
l Plans There have been major problems here concerning compliance with the instructions. People are leaving off relevant information (such as fire safety equipment or the height of the stage). Check exactly what is required to be shown.
l Consent forms Even if you are signing the application personally, you must still consent to being the designated premises supervisor on a separate form. Failure to produce the consent form can also invalidate the application.
Now these are issues concerning the grandfather rights section only, before we even get on to the question of a variation, correct advertising, sending copies to all the responsible authorities and other technical details.
In spite of my plea to local councils, they are still taking a very hard line on accuracy, it seems. Treading on hot coals is probably easier!