Sloppy DCMS persists in showing poor form

Regular readers will be aware that I have consistently berated the Department for Culture Media and Sport (DCMS) for the appalling state of the application forms used in licensing. I have been joined - perhaps not in such trenchant terms - by Sir Les Elton of the Independent Fees Review Panel, who has commented that the forms and accompanying guidance leave much to be desired.

Now two other events have occurred which bring this issue into sharp perspective. The first is the story in last week's MA about a Pembrokeshire licensee refused a Temporary Event Notice (TEN) for failing to give his home address on the first page of the form. The second is that the DCMS has devised another set of forms, this time relating to gambling, which are also of rather dubious quality.

I have every sympathy with the landlord because I think Pembrokeshire county council's decision is wrong. The TEN form does not require the applicant to state his or her home address in section 6: it asks, effectively, for a contact address, stating: "we will use this address to correspond with you unless you complete the separate correspondence box below."

This is given added weight by the heading of section 7: "Other contact details." In other words, it is not a legal requirement to give a home address for checking purposes and the application should not have been rejected.

I suspect that hundreds of other applications for TENS have listed the contact address as a business address for the applicant, which is logical and sensible. The box does not say "home address" or "residential address" and I fully support the licensee in this instance.

I have been unable to ascertain the definitive DCMS policy on form-compiling: some allege that it is done by junior civil servants, while others maintain that lawyers at the DCMS put them together. What is clear is that there is apparently no desire or budget to employ a proper form-compiling organisation, such as that used by the Inland Revenue and other departments, to ensure that fundamental aspects such as grammar and spelling are correct and, vitally, that no part of the form is ambiguous or misleading.

There also seems to be no senior person in the Department who takes any responsibility for this shabby state of affairs. They are presumably quite happy to be classified as bottom of the class in English. Given that you can even gain admission to university these days by borrowing your CV from a website, you don't seem to have to learn to spell at all!

This question of compilation is, however, no laughing matter when it comes to people's livelihoods. It would be expensive for the rejected licensee to try and claim compensation for his lost profits, but how is the council "accountable" - to use the White Paper concept - for this over-bureaucratic decision?

The answer is that they are not - therefore they can claim that the form is ambiguous and they are entitled to interpret it as they see fit.

You may remember that we were promised a simplified licensing system which would do away with a great deal of form-filling.

Forgive me, but I cannot remember any technical problem with the forms we used to complete under the old regime.

Now, it seems, any number of people are contacting me about the way they have to fill in the licensing variation form, and the great deal of head-scratching that goes with it.

Local authorities, too, are attributing different interpretations from what is written down by applicants.

This is just not good enough. The DCMS should be prepared to shell out for expert compilers to ensure that all their statutory forms are fit for purpose. They clearly aren't bothering to do so at the moment.