It is difficult to know where to start with the latest consultation paper on fees, issued by the Department for Culture, Media & Sport (DCMS) last week. It is almost as if I live in a different country.
Page after page of the document makes what are called "assumptions" about the number of actions likely to arise from the new Licensing Act. Some of these are just plain wrong. Others are based on misunderstood or misinterpreted data. But the main problem is that the cumulative effect of all of this is to create a false image of costs and therefore to base fees and expenditure on entirely the wrong data.
It was way back at the time of the White Paper that the Government first ventured into the dizzy world of "cost-saving" when it claimed that £1.9bn would be saved by the industry in 10 years. It is now claiming that this will rise to £2bn, with an additional administrative saving of almost £150m for the police.
This is based on the assumption that 16.6 million "licensing processes" will reduce to just 2 million, and 2.4 million hearings will come down to a mere 40,000. On the face of it, extremely good news. Old Cassandra here, he just don't believe a word of it!
I just want to pick up two "assumptions" from the huge list, just to see if they make sense. The first concerns applications for personal licences during the transition period.
The consultation document (para. 3.15) gives an estimate of the number of applications which will be made for personal licences next year. The figure given is 155,000.
However, the previous week, the Government issued its latest licensing statistics on the number of licensed premises in England and Wales. You will be intrigued to discover that, excluding registered clubs which do not have a licensee, the total number currently stands at 159,952.
On this basis, there are nearly 5,000 licensed premises that do not have a licensee at all, or are going to disappear before transition. That leaves 155,000 premises which all have a single named licensee no joint licensees exist, according to these figures.
This is palpable nonsense. Applications for the new-style personal licence will exceed 200,000 and may even be as high as 250,000, based on the most conservative realistic estimates.
The second assumption is that only 65% of licensees will seek any sort of variation of hours or operation during transition. Seeing as it appears that the fee will be the same, whether a variation is sought or not, I think that figure. too. is an underestimate.
My final comment concerns timing. Consultation until 23 December means that the final fees order will not reach Parliament until the middle of January, just three weeks or so before transition starts. I cannot comprehend why the DCMS cuts everything so fine unless the rumour is true and it just doesn't care.