Client: London Borough of Hounslow

Project: Cumulative Impact Assessment 2023

What were MAKE asked to do?

Hounslow Council needed know whether evidence pointed towards retaining, changing or removing its existing Cumulative Impact Assessment (CIA) areas, and whether there was evidence supporting community calls for a new CIA area in the borough.

In simple terms, Cumulative Impact Assessments are an optional policy tool within the Licensing Act 2003 (formalised in the Police and Crime Act 2017) to help boroughs resist the granting of new or extended licences to premises. However, the borough must show that one or more of the four licensing objectives under the Act, most usually crime and disorder and public nuisance, are being negatively affected by the ‘cumulative impact’ of too many existing licensed premises in a given area.

To introduce, retain, change or remove a Cumulative Impact Assessment area or areas, there is a legal requirement for a solid evidence base of the problems.

How did MAKE do it?

  • Hounslow has a significant street drinking challenge. MAKE undertook observational research to visit over 120 existing and new street drinking sites to verify the extent of the problems reported anecdotally by residents, the police and parks team

  • Working with the community safety team, we undertook a comprehensive audit of crime and antisocial behaviour, both temporally and spatially

  • We used CCTV evidence logs to understand more about the detailed nature of the types of crime and nuisance that are linked to the sale and consumption of alcohol in the borough

  • We reviewed the evidence for the council’s two existing CIA areas and examined the evidence from a community group for an ‘area of interest’ where the community claimed there were problems linked to off-licences. MAKE were able to assess the veracity of this evidence

  • We spent time meeting councillors and explaining the Licensing Act 2003, ‘cumulative impact’ and the benefits and downsides of any retaining, changing, removing or introducing any new Cumulative Impact Assessment areas

  • We brought all the elements together in a CIA report that was based purely on the evidence rather than any policy recommendation so that councillors could decide themselves whether to retain, modify, or remove existing CIA areas or introduce any new areas

  • The council also asked us to handle the consultation responses to ensure the process remains impartial and independent.

What happened next?

A comprehensive consultation was carried out. This involved an online survey for residents and businesses alongside writing directly to approximately 1,000 licensed premises and 6,000 personal licence holders. All the relevant responsibility authorities and other stakeholders, such as schools, business organisations and community groups, were also engaged with.

What unique value did MAKE bring to this project?

This was the first time we worked with a greenspaces department to understand the negative impact of clusters of off-licences, alcohol sales and street drinking on local public spaces and the resulting demands on the parks team’s time and council resources.