The Association of Convenience Stores (ACS) has raised concerns about proposed changes to the alcohol licensing regime.

ACS was responding to the Public Bill Committee’s call for evidence on the Policing and Crime Bill.

It warned that a proposal to no longer require alcohol licensing guidance to be scrutinised by Parliament could mean significant changes could be made to the guidance without any accountability.

The Bill proposes to remove the requirement to lay section 182 guidance in Parliament for approval. Section 182 guidance is a key document which informs licensing officers and licensees on how to interpret the Licensing Act including how to uphold Licensing Objectives.

In recent years, the Home Office has failed to hold formal consultation with industry representatives which has led to a number of significant changes including:

• the addition of the Portman Group Code as a licensing condition;

• changing the requirement to establish the primary use of a forecourt to acquire an alcohol licence from just the point of application to at any point in time;

• the addition of sections to help local authorities determine how to use alcohol-related health data in relation to licensing decisions and reviews.

In the ACS submission, it called on the Home Office to commit to formal consultation with representatives of the on and off trade on any changes to the guidance.

ACS chief executive James Lowman commented: “If changes to section 182 guidance are to be made without reference to parliament, then the Home Office must commit to consulting extensively with both the on-trade and the off trade to ensure that any changes do not have an adverse impact on licence holders.”

ACS also raised concerns in their submission on any Government plans to use the Policing and Crime Bill to put Cumulative Impact Policies on a statutory footing, after they announced the plans in the Modern Crime Prevention Strategy earlier this year.

Lowman said: “We continue to oppose the use of CIPs to reduce alcohol-related harm. Limiting the number of licensed premises in an area only deters new stores from opening instead of dealing with the existing problems. Local authorities should focus on the quality and compliance levels of the retailers in the market, not just the number of licensed premises.”