Cumulative Impact Policies
Cumulative impact policies
Draft Statement of Licensing Policy 2017-2022
Cumulative impact policies
This chapter explains cumulative impact and sets out the policies in respect of Camden Town and the Seven Dials area of Holborn and Covent Garden.
6.1 Cumulative impact is the potential negative effect on the promotion of the licensing objectives of a significant number of licensed premises concentrated in one area.
6.2 A cumulative impact policy creates a rebuttable presumption that we will normally refuse an application for a new premises licence or a variation of an existing premises licence, which is likely to add to the existing cumulative impact.
6.3 We acknowledge that cumulative impact can apply at all times not just at night, and can apply to any licensed premises not just those that supply alcohol. The cumulative impact of licensed premises on the promotion of the licensing objectives is a proper matter for us to consider in our Statement.
6.4 We have agreed the following policies based on current and recent historical evidence of licensing related activities in the borough. We acknowledge that Transport for London (TfL) is introducing a night tube service, which is likely to impact on a number of areas of Camden at night and we will keep these policies under review.
6.5 We will work with our partners to agree a common approach on measuring and analysing changes following the introduction of the night tube. We will agree baselining information based on existing data sets including but not restricted to:
- crime statistics on the street
- crime statistics at stations and on the network
- noise complaints at licensed premises
- noise complaints at stations and surrounding area
- other incident reports at licensed premises
- other incident reports noise at stations and surrounding area
- ASB data
- ambulance call out data
- behaviour audits
- customer usage data at stations
6.6 After we have obtained the baselining data, we will monitor the activities in the borough associated with the night-time economy, before evaluating the evidence of change against the baselining data. At that time, we will decide whether to review our existing policies and consult further.
6.7 In 2005, we introduced two cumulative impact policies to address concerns about large numbers of people leaving an area at night and the resulting pressure on transport infrastructure, street cleaning services and police resources, combined with an increase in public nuisance and crime and disorder.
Seven Dials cumulative impact policy area
6.8 The Seven Dials CIP area applies to the whole area within the following outer boundary:
a) From the centre of New Oxford Street at its junction with Charing Cross Road along the centre of Charing Cross Road to its junction with Shaftesbury Avenue
b) From this junction along the centre of West Street to St Martin’s Lane at its junction with Shelton Street
c) From this junction along the centre of Shelton Street to its junction with Drury Lane
d) From this junction along the centre of Drury lane to its junction with Wild Street and Long Acre
e) From this junction along the centre of Wild Street to its junction with Kingsway
f) From this junction across to the Eastern side of Kingsway and along the eastern flank of Kingsway (including all buildings on the eastern side Kingsway) to its junction with Holborn
g) From this junction to the eastern side of the junction with Proctor Street (including all buildings on the North and South of Holborn) and back to Kingsway
h) From the Kingsway at its junction with Holborn, along the centre of Kingsway and into Southampton Row as far as the junction with Great Russell Street
i) From this junction along the centre of Great Russell Street to its junction with Bloomsbury Street
j) From this junction along the centre of Bloomsbury Street to its junction with New Oxford Street
k) From this junction along the northern flank of New Oxford Street (including all buildings on that northern flank) to the point in the centre of New Oxford Street at its junction with Charing Cross Road
Camden Town cumulative impact policy area
6.9 The Camden Town cumulative impact policy area applies to the whole area within the following outer boundary:
a) From Hampstead Road at its junction with Lidlington Place along the centre of Hampstead Road to its junction with Granby Terrace
b) From this junction along the centre of Granby Terrace onto the railway bridge and then in a line behind the houses in Mornington Crescent and along the edge of the railway track northwards at the western side of Clarkson Row, to the centre of Morning Street to the west of its junction with Mornington Terrace
c) From this point, along the centre of Mornington Terrace to its junction with Park Village East
d) From this point, along the western edge of the railway track to the south side of Gloucester Gate
e) From this point, across Gloucester Avenue to the western edge of the railway track and then northwards until adjacent to Sunny Mews at which point the boundary moves to the centre of the railway track to the centre of the bridge with Gloucester Road to the West and Regents Park Road to the East
f) From this point at the centre of the bridge, along the centre of Bridge Approach, across the junction with Adelaide Road to the northern side of Eton College Road and north west passed Eton Place
g) From this point, the boundary passes between Eton Place and Eton Hall to the centre of Haverstock Hill and then passes to the South of 50 Haverstock Hill to the rear of the premises situated on Prince of Wales Road, past Craddock Street, Truro Street and into Croglands Road
h) From this point, along the centre of Croglands Road and the boundary then passes north of the Charlie Ratchford Centre, crosses over Belmont Street, Hadington and back into Belmont Street and then eastwards past Mead Close to the north, across Ferdinand Street and into Harmood Place and along the centre of the road to its junction with Harmood Street
i) From this point to the junction with ClarenceWay and along the centre of Clarence Way, across Castlehaven Road in a straight line as far as the rear gardens to the premises on Kentish Town Road
j) From this point, along the rear of those premises to Hawley Road, across Kentish Town Road in a straight line to the centre of Camden Street at its junction with Kentish Town Road
k) From this junction, along the centre of Camden Street over the junction with Crowndale Road and into the South side of Oakley Square
l) Along the centre of the South side of Oakley Square, across the junction with Eversholt Street and into Lidlington Place as far as the junction with Hampstead Road
6.10 Maps showing the cumulative impact areas are contained in Appendix Three and Appendix Four.
6.11 We have concluded from the most recent research, that we will maintain the cumulative impact policy for Camden Town and extend the Seven Dials cumulative impact policy area to include the following areas:
a) the eastern side of Kingsway extending from its junction with Sardinia Street to its junctions with High Holborn and Southampton Row.
b) both sides of High Holborn to the East of Kingsway as far as the junction with Proctor Street
c) the northern side of New Oxford Street extending from its junction with Charing Cross Road to its junction with Bloomsbury Street
Reasons for the policy approach
6.12 We have undertaken research since 2004 to identify and review areas within the borough where high concentrations of licensed premises are undermining the promotion of the licensing objectives. This research has included:
- crime statistics for specific offence groups that, according to the police, are associated with the night-time economy, alcohol and licensed premises
- information from Public Health in relation to alcohol related ambulance call-outs
- observational studies, including studies of anti-social behaviour, criminal activity, and difficulties getting people away from the area at night
- interviews with local stakeholders
6.13 Following research in 2004, we identified two areas within the borough where the number, type and density of premises selling alcohol for consumption on the premises were having a serious negative impact on the local community and local amenities. These areas are Camden Town and the Seven Dials area of Covent Garden and we made both areas subject of cumulative impact policies.
6.14 We have reviewed the policies for these areas regularly to assess whether they are still relevant or whether we should amend them. In 2009, we extended the Seven Dials cumulative impact area, and we retained both cumulative impact areas following research to support this Statement.
6.15 In 2015, we commissioned a review of areas in Camden, where there appeared to be emerging problems of alcohol related crime, disorder and emergency health demand at night. The independent review was carried out over six months from February to July 2015. The report did not recommend creating any new policy areas in Camden but did recommend that two sections adjoining the existing Seven Dials cumulative impact policy area should be included within that policy area. We have considered the reasoning behind this recommendation and we are satisfied that granting or varying licences for premises within these areas could lead to a negative cumulative impact on the licensing objectives.
6.16 We have carefully considered the valued contribution of local residents in formulating these policies, including interviews and their deputations to our Licensing Committee, and have consulted widely on the implementation of these policies with all relevant stakeholders
6.17 We are satisfied that the two cumulative impact policy areas contain a high number, type and density of premises selling alcohol or providing late night refreshment and that serious problems of nuisance and disorder arise outside or some distance from those premises. It is our view that the impact on surrounding areas of the premises taken together has a negative impact on the promotion of the licensing objectives, and it is necessary to restrict the number of premises and extensions to the licensable activities at premises in those areas in order to manage that cumulative impact.
6.18 A summary of the evidence for these cumulative impact policies is available on our website
6.19 The cumulative impact policies set out in this chapter apply to the following types of application in both of the cumulative impact policy areas :
- all applications for new premises licences and club premises certificates
- all applications to vary existing premises licences and club premises certificates
- all applications for provisional statements
6.20 We expect applicants to demonstrate an understanding of how the policy affects their application and identify the measures they will take to mitigate any negative impact on any of the licensing objectives. Applicants should also state why they consider the application should be an exception to the policy.
6.21 Where we receive an application, the licensing authority in its role as a responsible authority will normally make a representation on how the policy affects the application.
6.22 We will consider each case on its merits, though applicants should be aware that we would only depart from the policy in respect of cumulative impact in exceptional circumstances.
6.23 The absence of a cumulative impact policy for an area does not prevent a responsible authority or any other persons making representations on the ground that the premises may give rise to a negative cumulative impact on the area in question.
6.24 Where we receive relevant representations, we will in almost all cases, refuse applications for licences within the two cumulative impact policy areas.
6.25 If we do not receive any relevant representations against the proposed application, the law requires us to grant the application as requested by the applicant.
Public Health and cumulative impact
6.26 We recognise that it will not always be possible for Public Health to have venue specific information and the majority of health data will generally relate to geographical areas. The use of this type of data is most suitable where a licence application relates to premises situated in a cumulative impact area, and areas where there is a high level of alcohol related ambulance activity in conjunction with alcohol related crime and violent crime.
6.27 Public Health acknowledges that the impacts of alcohol related harm in terms of ambulance call-outs and crime are not felt evenly across the borough. In particular:
- areas of Camden with high numbers of licensed premises generally have a higher number of alcohol related ambulance call-outs
- areas with higher ambulance activity are mainly in the south of the borough and Camden Town
- large clusters of licensed premises coincide with the areas of higher related ambulance call-outs and alcohol related crime
- Exceptions to cumulative impact policies
6.28 We acknowledge that some premises may be able to demonstrate that they will not or do not contribute to cumulative impact due to the nature of the premises or the activities they provide. However, as mentioned above, we expect applicants to explain why they consider that the application should be an exception to the policy.
6.29 Examples of factors that we may consider as exceptional include, though are not limited to one or more of the following:
- small premises with a capacity of fifty persons or less who only intend to operate during framework hours
- premises which are not alcohol led and operate only within framework hours, such as coffee shops
- instances where the applicant has recently surrendered a licence for another premises of a similar size and providing similar licensable activities in the same cumulative impact policy area
6.30 Examples of factors we will not consider as exceptional include but are not limited to:
- that the premises will be well managed and run
- that the premises will be constructed to a high standard
- that the applicant operates similar premises elsewhere without
6.31 The examples given in 6.29 above do not infer that an exception will automatically be applicable. Consequently, we will always consider each case on the individual merits of the application before deciding whether an exception is appropriate.
Map of Camden Town cumulative impact policy area
Reproduced by permission of Ordnance Survey on behalf of HMSO © Crown copyright and database right 2015. Ordnance Survey Licence number 100019726
Camden Statement of Licensing Policy 2017-2022 Page 92 of 102