We have all seen caps set under other legislation, gambling and universities come to mind, where a large number of authorities and organisations have charged the cap itself.
The Home Office will tell you that the cap is a maximum and authorities should only charge ‘cost recovery’, but with authorities strapped for cash we can all guess where the majority of fees might end up at.
At a Home Office consultation event I attended in London, I came away with the feeling that most authorities actually preferred having set fees rather than setting their own. For an authority to set their own fees is only going to take time and therefore costs, with these costs having to be added into the ‘cost recovery’ calculation.
Fees
There are a number of points in consultation that give me some concern but especially the following.
The proposed cap for a personal licence fee is £114 (currently £37). My argument against this is that we should be encouraging training and qualifications and a personal licence is an excellent way of demonstrating that a person not only has a qualification but also has no unspent relevant convictions.
The Government has recently confirmed the personal licence is not going to be scrapped so must see some importance in having this.
The whole process of getting a personal licence with obtaining the qualification, basic disclosure, photographs, etc currently costs an applicant around £300. If a fee of £144 is brought in by some authorities then the total cost will rise to almost £400.
Should we not be encouraging training and not increasing the financial barrier?
One thing I have thought about is that what if the authority the applicant lives in charges £144 and the neighbouring authority charges £30. Surely the applicant will get a temporary address in his neighbouring authority and obtain a personal licence where it is cheaper?
Another thing to look out for here though is the proposed cap on changing your address on a personal licence; currently £10.50, with the proposed cap at £59!
The biggest concern is the premises licence cap proposed at £2,400. This cap is for all premises across the board and removing the rateable value banding! Think £180 for Band B is too much now? How about facing £2,400?
If you have not yet responded to the consultation - I urge you to do so as it closes on 10 April.