Believe it or not, but three years have passed since the then licensing minister Sean Woodward announced changes to the licensing system in respect of village halls and community centres, setting them apart in a minor way from the rest of the licensed trade.
But I commented at the time that this proposal tended to mask an underlying problem: temporary event notices, that most widely criticised amalgamation of three different permissions under the old 1964 Act, need to apply in a variety of circumstances and to a variety of requirements, but are not really flexible enough to do so.
The problem with village halls and the like is that there was a distinct reluctance to get embroiled in the full-scale licensing system, because of the responsibilities that would fall to a local individual with perhaps little interest in running a bar. Every premises licence where alcohol sales are made requires a designated premises supervisor and that individual has to hold a personal licence. Off to your local training centre, then, and do the exam? Not likely.
So village halls had to fall back on TENs, as they are called, or at least the users did. This in itself created problems early on: only 12 events a year involving "licensable activities", which could be a dramatic society production or wedding with a bar. There are 52 weekends in a year. It just doesn't make sense.
The losers in all this were those section of the licensed trade who used to employ occasional licences on a regular basis to cater for their roving business — event caterers, for example, and those selling their specialist drinks from market stalls. They are now placed in a very difficult position, because the limit of 12 per year for one location creates problems for a regular stall operated in the same position once a week. I even fielded a question recently on whether a market stall can in fact constitute "premises" for the purposes of the Act.
So one part of the problem is to be resolved, but the other will not. Although the village halls will get their administrative relaxation, on the question of TENs, the Government continues to bow to pressure from outside the trade and has decided that the balance is more hostile to relaxation of the TENs limits than for it. I am not sure that the Department for Culture, Media and Sport has taken account of the whole picture here, and certainly not the problems it creates for honest traders. This is a problem of the rigid system, not of the majority of those who want to use this temporary permission.
I repeat my challenge: if the DCMS can create a different regime for the halls, why can't it create two types of TEN — one for professional licensees and the other for amateurs. The limit of 12 for some premises is ludicrously low. The "generous" allowance of 50 notices a year for a personal licence holder is not much use if your regular venue shuts up shop before the 13th event.
It is claimed that there was not much lobbying on this issue from trade organisations. Well, there continues to be considerable criticism from certain sectors of the trade who may be under-represented in organisations, but still have a valid point.
And there are a lot of licensees who have received a steady income from outside events, and who now find themselves in more difficulty than before — even though what they did was of benefit to the community and was far from causing a nuisance or disturbance.
This system has clearly not been abused. It is time for some further relaxation of the rules.