Client: Private Client

Project: Appraisal of Westminster Licensing Policy

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What were MAKE asked to do?

We were asked to examine Westminster City Council’s Licensing Policy by a well-respected operator to examine the efficacy of WCC’s cumulative impact area (or West End Stress Area). As an operator they felt that, despite being inside the council’s CIP area, that one of their venues was actually located in an area of very low crime and public nuisance and thus it was unfair that they were prevented from opening later at night. Our view was that this would be hard to convince Westminster City Council that even if this was the case that they were an exception, despite being a venue with no current problems. But we like a challenge!

How did MAKE do it?

  • We reviewed the council’s licensing evidence base as well as crime data and the council’s own vision, planning documents and corporate plan. 

  • We used data from our own NightMix economic metrics modelling tool to demonstrate the nature of Westminster’s changing evening and night-time economy and its value to the City of Westminster as well as to London 

  • We used crime data for the area in which this client’s venue was located to map hotspots and identify temporal and spatial trends. As it turned out they were right, this area was entirely free of problems, yet they were being treated as if they were in the same part of the West End as Old Compton Street, Charing Cross Road or Piccadilly Circus, where there are serious crime and disorder issues.  

What happened next?

We wrote a report that identified, perhaps for the first time, that there were some significant ‘holes’ and important ‘quiet zones’ within the overall West End Stress Area where there may be room for certain amounts of policy flexibility for the right type of venue. The operator applied for a licence variation and, with conditions, was granted this variation. They continue to trade, to our knowledge, with an unblemished record.

What unique value did MAKE bring to this project?

Because we have a unique understanding of cumulative impact policies in general, the West End Stress Area in particular and access to London-wide crime data, whilst we remain objective, we were able to demonstrate that cumulative impact areas are often drawn for broader convenience rather than based on absolute specificity and that this can lead to streets being caught up in them where there is little evidence for their inclusion.