The Government's plans to overhaul licensing are a "baleful attack" on the licensed trade that is "calculated to appease the bigotry" of health campaigners.
So says CPL Training director Paul Chase, in a forceful attack on the Coalition's plans for major reform to licensing.
The proposed late-night levy is dismissed as an "act of collective punishment" that "doesn't distinguish between well-run and badly-run premises".
He was cool on plans for reductions for venues with Best Bar None status or pubwatch members - licensees would essentially be "press ganged" into joining these organisations.
On the plan to make relevant licensing authorities responsible authorities, Chase said it would let licensing authorities become "judge and jury" over their own representations.
"Impartiality goes, and licence holders will lose confidence in the system."
Reducing the burden of proof on licensing authorities will "further dilutes due process, fairness and objectivity."
Under the plan, licensing authorities must accept representations from police unless there's clear evidence these aren't relevant.
Chase said this "effectively makes the licensing authority a creature of the police; merely a rubber stamp".
"Combined with the proposal to limit rights of appeal, this proposal effectively gives a police area commander the right to determine commercial life or death for any premises whose licence is being reviewed.
"The rationale for taking licensing away from magistrates and giving it to local councils was to increase democratic accountability.
"How is democratic accountability increased when democratically elected councilors will be required to accept police recommendations, even if they don't agree with them?"
Chase goes further, saying plans to limit appeals "is an attack on the principle of liberty itself" and arguably goes against the right to a fair trial.
On the plan for automatic licence reviews, Chase said a consequence will be "more licences lost because of an obsession with offences that are always detected by trading standards or police on fishing expeditions".
Other criticisms concern the plan to add a fifth licensing objective, prevention of harm.
This has caused "much mischief" where it's used in Scotland, said Chase. For example, by Glasgow's insistence that pubs have an alcohol-free "winding down hour" in their last hour of trading.
Chase said CPL doesn't support minimum pricing and the proposed below-cost ban is the "lesser of two evils".
But he questioned whether the effort of policing the ban would be justified by its effect on alcohol-related harm.
Chase also slammed the consultation itself, saying it "appears to many to be a sham" and "the Government has already decided what it wants to do".
It's "shameful" to put out a consultation during Parliament's recess and "bulldoze it through in just six weeks".
He concluded: "With a few minor exceptions this package of reforms is a baleful attack on the licensed retail sector that is calculated to appease the bigotry of a resurgent temperance movement in, and outside of Parliament.
"Curiously, for a coalition government of Conservatives and Liberal Democrats, the reforms are both anti-business and illiberal.
"CPL urges the government to consult more widely and reconsider this lamentable package of measures before it inflicts even more harm on a vibrant, employment creating sector that has been unjustifiably pilloried for a variety of intractable social ills that are outside of its control."
The consultation ends on 8 September.