I have been reading with some interest the recently published Interim Report of the Licensing Fees Review Panel which was set up principally to look at the level of fees that licensees now pay for the privilege of having a licence.
They have not yet reached any conclusions. That is understandable. But they have highlighted matters of concern throughout the whole transition and application process which bring a wry smile to my lips.
I was particularly interested in the 'justifications' which the panel chairman, Sir Les Elton, has presumably obtained from the Department for Culture Media and Sport (DCMS) for their action or inaction over the past couple of years. He does not at this stage pass any judgements. I have no such qualms.
For example, the DCMS admits that the late laying of regulations prior to transition 'was not helpful'. That is an understatement. But they then go on to claim that the 'significant publicity campaign' in May would eliminate the problem.
Four months after transition starts is a great time to have a publicity campaign! Would it not have been helpful to do it before the transition? But they couldn't, because they had not yet published the vital information on the draft application forms and procedures.
Remember that they actually changed the forms at 4pm on the Friday before the first appointed day! If that is not brinkmanship, I don't know what is.
The review is full of such empty justifications. The complexity of the application forms is justified by the fact that it is less paperwork than the six separate regimes. That sounds good, until you realise that virtually no-one had to comply with all six regimes previously. In the case of small pubs and off-licences, for example, it meant a simple payment of £30 every three years and forget about it. One piece of A4 paper.
The hidden costs of transition were never properly spelled out. The review team highlight the enormous payments made for newspaper advertisements and for professional plans to be drawn up. In one of their immediate recommendations, they want the DCMS to make it clear that professional plans are not required. I think they should also tell a number of licensing authorities and fire authorities exactly what the minimum requirements should be, so that they do not reject hundreds of applications as they did during transition.
Reading this fairly short report, one is struck mainly by the utter failure of a 'one-size fits-all regime' in so many aspects. Rateable value is 'the least unfair' system for gauging licence fees, it seems Sir Les is saying. But it is blatantly unfair on those for whom alcohol sales are a small part of their business, or who occupy a tiny part of a big building.
The applications forms for everything are too long and do not allow for minorities or voluntary organisations. The Temporary Event Notice system is an appalling compromise, removing that vital element both of instant approval in a hurry and the longevity of the occasional licence (up to three weeks, and extendable).
And for most of the licensed trade, the cost has risen dramatically. An annual fee of more than £100 for the same level of permission that previously cost just £10 a year seems disproportionate for many. But when you try and cram everyone into the same barrel, that's what you get.
In spite of the pleas from the DCMS, I am left with the impression that the whole affair has been thoroughly botched, and Sir Les is merely picking up the pieces. We shall now have to wait for another year before we hear what his team thinks about the fees themselves - that is, if they can get the information they need, which currently seems in short supply.