Cumulative impact puzzle

MA legal editor Peter Coulson considers the impact of cumulative impact zones.

I was slightly perplexed by the purported "news" that Southwark was embarking on a consultation for its third cumulative impact area, as if more than one is a matter for surprise.

In fact, multiple cumulative impact areas have been a feature of the statistics published by the Department for Culture, Media & Sport (DCMS) and show even more interesting developments.

Top of the pile is not, as might have been expected, Westminster. It appears at present to be shared between Doncaster, Leeds and the London Borough of Greenwich, with no less than five each. Westminster joins Bournemouth in second spot with four such areas, and then Bexley, Birmingham, Hastings and Newcastle follow up with three each.

Now, admittedly, these figures date from March 2008 and there may well have been some changes since then — especially as Southwark was listed at that stage as having no cumulative impact areas at all.

But what strikes me about the list is the varying nature of the licensing authorities concerned. They are not just the major conurbations, because a number of notable large cities are missing from the list. But why is Hastings rubbings shoulders with Newcastle, and what is Greenwich doing at the head of the queue?

These smaller boroughs have not been making the headlines as places where there have been considerable disorder problems or antisocial behaviour, although many years ago Hastings was known as a venue for battles in the streets! What it appears to demonstrate is the attitude of certain councils and councillors to the question of what constitutes disorderly conduct warranting a cumulative impact policy.

Then there is another thought. If you have five such areas on your books, the next step seems to me to be the declaration of an alcohol disorder zone (ADZ), so that you can claw back some of the expenditure from the licensed trade. But as far as I am aware — with the exception of Bournemouth — none of the top contenders has even contemplated going down that route, and the number of ADZs remains firmly fixed at zero.

Brighton had the bright idea of making most of the city centre into one huge cumulative impact area, stretching for miles from the sea-front. It then took advice and thought better of it. We are now presumably reaching the stage where those authorities with multiple designations have to start reassessing what has happened, as they are obliged to do under the Guidance, and ought to withdraw this status if there are currently no perceived problems. I look forward to announcing the first borough to do this!