APPENDIX C
Police Station
John Street
Brighton
BN2 0LA
REDACTED
19th March 2021
The Licensing Technical Support
Officers
Environmental Health, Brighton & Hove City Council
Bartholomew House, Bartholomew Square
Brighton, East Sussex
BN1 1JP
EG CON ENDS 26.03.21 VALID PCD & PCH (A)
Dear REDACTED
RE: APPLICATION FOR A NEW PREMISES LICENCE FOR WEEZY FULFILMENT CENTRE, 8&9 LOWER GOODS YARD, TRAFALGAR STREET, BRIGHTON, BN1 4FQ UNDER THE LICENSING ACT 2003.
I write on behalf of the Chief Officer of Police for Sussex to raise a representation against the grant of the above application on the grounds of the Prevention of Crime and Disorder and for the Protection of Children from Harm. We also make reference to the Brighton & Hove City Council (BHCC) Statement of Licensing Policy.
This is a proposed new licence application is in the City’s Special Stress Area (SSA), however it is noted the location is in very close boundary with the Cumulative Impact Area (CIZ) which seeks the following hours and licensable activities:
Supply of Alcohol (Of the Premises)
Every Day: 07:00 – 23:00
In the Brighton and Hove statement of licensing policy, under paragraph 3.2
3.2.2 This Special Stress Area (SSA) is of concern to the licensing authority because of the relatively high levels of crime and disorder and nuisance experienced within it. The area will be kept under review.
3.2.3 New and varied applications for premises and club premises certificates within the SSA will not be subject to the presumption of refusal, but operators will be expected to pay special attention when drawing up their operating schedules and to make positive proposals to ensure that their operation will not add to the problems faced in these areas. Appendix A of the SoLP sets out a list of potential measures the licensing authority considers may be appropriate. These may be more or less appropriate depending upon the style of operation applied for.
3.2.4 On receipt of any application in the SSA, where a relevant representation has been made, the licensing authority will scrutinise the application carefully and will look at the measures proposed in the operating schedules and compare them to the measures set out in Appendix A, Licensing Best Practice Measures. Where discretion has been engaged, those applications which fall short may be refused or conditions applied to comply with policy measures.
As this premises is in the SSA and operating a delivery service of groceries and alcohol there are concerns that alcohol will be delivered into the Cumulative Impact Area (CIZ), which is currently saturated with licensed premises, high levels of crime and disorder and Anti-Social Behaviour.
Due to the 15 minute turnaround time from order to delivery, Sussex Police have concerns that alcohol can be ordered without a grocery/ food shop to assist with pre-loading, extension to house party drinking (especially within student houses, Air B+B’s, or party houses within the city centre).
The data shows high levels of crime and disorder in the city centre, varying from ASB to serious public order and violent crimes. Please find attached the crime statistic heat maps. The areas marked in red highlights the high numbers of crime committed in the city centre during 2020, which must be noted experienced a number of Government restrictions and 2 lockdowns periods due to the Covid19 pandemic.
A large percentage of these crimes were also affected by alcohol (either victim, offender or both).
Sussex Police also have concerns over the operation and the high possibility of proxy sales. This style of operation would allow for under age persons to use another person’s credit card or debit card to purchase alcohol for delivery or allow a person who is alcohol dependent to purchase alcohol.
Sussex Police have concerns over delivery drivers having the confidence to refuse a delivery at the customer’s house, especially if they are heavily intoxicated and become threatening or abusive.
Lastly Sussex Police have concerns over the increased number of 2 wheeled delivery vehicles on the road. Sussex Police have a current operation called Op Mainstay, which focusses on reducing the numbers of road collisions resulting in killed or seriously injured persons who are on powered two wheeled vehicles. Our concerns are that this business operation will add more vehicles on the road and possibly increase the number of people killed or seriously injured, as well as vehicle document related offences (No Insurance, MOT, Driving Licence…).
The applicant has made specific reference to the Special Stress Area in their application and offered some reasoning how the offered conditions will ensure that the operation of these premises will not undermine any of the licensing objectives following a pre-consult with Sussex Police Licensing. In the circumstances, Sussex Police are making a representation as there are high levels of crime and disorder and even though the applicant has offered some enforceable conditions; this will enable a Council Licensing Sub Committee to properly scrutinise the application as described in 3.2.4 above.
We now invite the Licensing Sub Committee to consider the application, along with any other representations that may be submitted, and to make a decision.
Yours sincerely,
REDACTED
|
REDACTED Licensing Officer Licensing Team BHCC Bartholomew House Bartholomew Square Brighton BN1 1JP |
Date: Our Ref: Phone: Email: |
REDACTED |
EG CON ENDS 26.03.21 VALID PCD, PPN & SSA (B)
Dear REDACTED
Re: Licensing Act 2003 - Representation regarding the application for a New Application for a Premise Licence for: Weezy Fulfilment Centre, 8 & 9 Lower Goods Yard, Trafalgar Street, Brighton, BN1 4FQ
I refer to the application made by Weezy Group Ltd, for a new Premises Licence to be issued for the above premises. The Licensing Team, in its role as a Responsible Authority, has concerns about this application and therefore I am submitting this representation on the grounds of the prevention of crime & disorder and public nuisance and to uphold our Statement of Licensing Policy (SoLP).
The applicant has applied for a Premises Licence for alcohol for consumption off the premises every day 7am – 11pm for a locally based home delivery grocery centre that is not open to the public.
This representation is submitted as there are concerns that the application does not meet the requirements of the Council’s SoLP, with regard to applications made within the Special Stress Area of the city. The Special Stress Area is of concern to the Licensing Authority because of the relatively high levels of crime and disorder and nuisance experienced within it and we believe that the granting of this application could lead to increased associated issues with regard to crime & disorder and public nuisance in the nearby surrounding area.
The Council’s SoLP includes a Matrix Model approach for licensing decisions, which recognises the diverse operation and different risks presented by different classes of licensed premises. It provides a vision of what the licensing authority would like to see within its area and gives an indication of likelihood of success or otherwise to investors and local businesses making applications.
The Matrix Model, on page 18 of the Council’s SoLP, states that in the Special Stress Area, there should be no new off-licence Premises Licence applications granted. The policy does state that each application is still considered on its individual merit and there is discretion to depart from the policy where justified. However, departure from the Matrix Model is only expected in exceptional circumstances.
The premises is in the Special Stress Area and is located in the electoral ward of St Peter’s and North Laine, which according to our Public Health Framework for Assessing Alcohol Licensing (5th edition- January 2019) is ranked the worst out of 21 wards under Crime and Disorder data for Police Recorded Alcohol related incidents and Criminal Damage and second worst for Sexual Offences, Non-injury assault, All injury violence and All violence against the person. On the Health data St Peter’s and North Laine ward ranks the worst for Increasing risk or higher risk drinking and Alcohol suspected ambulance call outs. Third worst for A&E attendances with a record of alcohol and Alcohol specific admissions 2017/18. It ranks 4th worst out of 21 wards for Clients in alcohol treatment.
We maintain that the Matrix Model states that no new off-licence applications should be granted in the Special Stress Area and therefore invite a Sub-Committee Panel to decide the outcome of this application on behalf of the Licensing Authority and whether the applicant has demonstrated whether there are exceptional circumstances to depart from our policy.
Yours sincerely
REDACTED
Licensing Department
Brighton & Hove City Council
Bartholomew House
Bartholomew Square
Brighton BN1 1JP 25 March 2021
March 2020
EG CON ENDS 26.03.21 VALID PCD & PPN (C)
Dear Sir/Madam
1445/3/2021/00468/LAPREN Weezy Fulfilment Centre, Units 8 & 9 Trafalgar Arches
Sale of alcohol Off Premises between 7am and 11pm, every day
We write on behalf of the North Laine Community Association in respect of the above application to sell alcoholic drinks Off Premises. We object to this application on the grounds of Prevention of crime and disorder, Public safety, and Prevention of public nuisance.
6.1.1 of the SoLP states: In determining applications for new and varied licences, regard will be had to the location of premises, the type and construction of the building and the likelihood of nuisance and disturbance to the amenity of nearby residents.
The premises lies close to the top of Trafalgar Street, which connects to the link to the Arches, and a couple of doors away from a 24-hour night club. This is an area noted for anti-social behaviour linked mostly to drug dealing and metres away from North Laine CIZ. We are also concerned that this outlet will appeal to hen and stag parties who use the Airbnbs in and around the North Laine area.
Although it is intended that the premises will not be open to the public, we are concerned about the possibility of unruly crowds nearby from the night club and surrounding area, particularly late evening. There could be safety issues here, as delivery bikes will certainly have to travel through our narrow roads and streets . We already have problems with Deliveroo etc, ignoring all road signs and illegally riding against one-way streets.
North Laine Conservation Area is within the Cumulative Impact Zone. Since the introduction of flexible opening hours in 2003 residents have had to put up with increased levels of noise from drinkers during the day and night, leading to increased levels of anti-social behaviour and vandalism. We believe that by granting this application it would add to the cumulative impact.
As you are aware, North Laine is saturated with licensed premises. There are 80 licensed premises within a small, tight-knit residential area of c600m x 600m. We believe that due to this saturation, the cumulative effect is undermining the licensing objectives.
Yours faithfully
REDACTED