Cumulative Impact Assessment - Licensing Act 2003

1. Cumulative Impact Areas - background

The concept of Cumulative Impact has been described within the Secretary of State's guidance since the commencement of the Licensing Act 2003.

Section 4 of the Licensing Act 2003 (the Act) requires that local authorities must carry out their functions under the Act with a view to upholding these objectives:

the prevention of crime and disorder
public safety (i.e. ensuring it)
the prevention of public nuisance
the protection of children from harm

The Act requires that the way in which the objectives are to be upheld should be included in a statement of licensing policy. This document must be reviewed every 5 years to ensure it remains fit for purpose. As part of this process, local authorities can consider the potential cumulative impact of a large number of premises operating in a small area and, if warranted, publish a Cumulative Impact Assessment as part of the policy.

Section 5A of the Licensing Act 2003 delegates to the Licensing Authority the power to implement a Cumulative Impact Assessment.

Great Yarmouth Borough Council (the Licensing Authority) include the steps they would consider when deciding on a special policy for cumulative impact in their statement of Licensing policy.

This includes taking the following steps:

identification of serious and persistent concern from a responsible authority or representatives of residents about nuisance and disorder
where it can be demonstrated that disorder and nuisance is arising as a result of customers from licensed premises, identifying the area from which problems are arising and the boundaries of that area
assessing causes
adopting a policy about future licence applications from that area

Great Yarmouth Borough Council is of the opinion that there is a cumulative impact regarding certain types of premises, and this is resulting in significant crime and disorder, anti-social behaviour and public nuisance issue.

2. Consultation

As per section 5A of the Act, in preparing the Cumulative Impact Assessment, the Licensing Authority will consult with the persons mentioned in section 5(3) of the Act, namely:

Norfolk police
Norfolk Fire and Rescue Service
Environmental Health
Health and Safety Executive
Local Planning Authority
the authority responsible for the protection of children from harm
the Director of Public Health at the Norfolk Health Authority
representatives of licence holders
local businesses and their representatives
local residents and their representatives

The Licensing Authority will consider the views of all those consulted prior to determining this policy.

3. The cumulative impact of a concentration of licensed premises

Cumulative impact is the potential impact on the promotion of the licensing objectives of a significant number of licensed premises concentrated in one area, for example the potential impact on crime and disorder or public nuisance.

The cumulative impact of licensed premises on the promotion of the licensing objectives is a matter that the Licensing Authority can take into account, this should not, however, be confused with 'need' which concerns the commercial demand for a particular type of premises such as a pub, restaurant, or hotel. The issue of 'need' is therefore primarily a matter for the market to decide and does not form part of this policy.

The Licensing Authority can publish a Cumulative Impact Assessment if there is evidence that a significant number of licensed premises concentrated in one area is causing a cumulative impact on one or more of the licensing objectives.

The absence of a policy does not prevent any responsible authority or other person making representations on a new application for the grant or variation of a licence on the grounds that the premises will give rise to a detrimental cumulative impact on one or more of the licensing objectives in a particular area.

In response to ongoing concerns, the Licensing Authority has undertaken the following steps when considering whether to adopt a Cumulative Impact Assessment:

identified serious and persistent concern about crime and disorder and public nuisance
considered whether there is good evidence that crime and disorder is happening and is arising as a result of customers from licensed premises
identified the boundaries of the areas where problems are occurring
consulted with those specified in section 5(3) of the Licensing Act 2003, on the proposal for a Cumulative Impact Assessment in relation to new applications and variations to existing premises licences and club premises certificates and considered the outcome of the consultation

Having considered the available evidence and undertaken consultation, the Licensing Authority considers that it is appropriate and necessary to control cumulative impact as detailed in Section 4.

4. Cumulative Impact Assessment

This assessment is being published because the Licensing Authority considers that the number of licensed premises and club premises certificates within the area specified in Appendix 1 is such that it is likely that granting further licences or variations to licences would be inconsistent with the authority's duty to promote the licensing objectives.

The Police, together with the Council, have raised significant concerns regarding crime, disorder, and incidents of public nuisance. A recent survey of borough residents also identified anti-social behaviour and perceptions of safety in the Town Centre as key issues requiring attention. This assessment draws on various sources of evidence for data analysis, including police records, Public Health statistics, and data from the Town Centre BID.

This assessment will apply to all applications for the grant or variation of a premises licence or club premises certificate within the cumulative impact area.

This will relate to premises carrying on or proposing to carry on the following licensable activities:

the sale or supply of alcohol on or off the premises
the provision of late-night refreshment
the provision of any regulated entertainment

The aim is to limit the growth of licensed premises where the promotion of the licensing objectives is being compromised.

The Authority seeks to prevent any rise in crime, disorder, and anti-social behaviour, particularly those linked to late-night licensed premises within the designated area. There is also concern regarding the sale of single-use cans, which may contribute to street drinking.

Cumulative Impact Assessments strengthen the ability of Local Authorities to control the availability of alcohol and to reduce alcohol-related crime and disorder.

By publishing a Cumulative Impact Assessment, the council is setting down a strong statement of intent about its approach to considering applications for grant and variations of premises licences or club premises certificates in the area's set out.

The contents of the Cumulative Impact Assessment do not change the fundamental ways that decisions are made under the Licensing Act 2003. The Licensing Authority will make all decisions on applications within the cumulative impact area on a case-by-case basis with a view on how best to promote the licensing objectives. Each application will be considered on its own merits.

The Licensing Authority may grant an application where it is considered appropriate and where the applicant can demonstrate on the operating schedule that they would not be adding to the cumulative impact.

Applicants are therefore expected to clearly outline in their operating schedules how they will address and mitigate these issues.

Applications in the area should therefore give consideration to potential cumulative impact issues when setting out the steps that will be taken to promote the licensing objectives.

The Cumulative Impact Assessment does not remove the requirement for a relevant representation to be submitted against an application for it to be considered by the Licensing Committee. An application that does not receive relevant representations is deemed granted under the Licensing Act 2003 (subject to such conditions as are consistent with the operating schedule and any mandatory conditions required by the Licensing Act 2003).

Whilst this Cumulative Impact Assessment does not apply directly to Temporary Event Notices, the guidance issued under section 182 the Licensing Act 2003 states that it is open to the Police and Environmental Health Officers to refer to this assessment and the evidence contained within it when objecting to a TEN. The Licensing Authority believes this is a right and proper approach as extension of hours within the Cumulative Impact Area can have a direct impact on the promotion of the licensing objectives.

This Cumulative Impact Assessment will be subject to regular review and formal reconsideration every three years or more frequently, if required.

5. Streets in Cumulative Impact Area

This map shows the proposed cumulative impact area.

The area encompasses the following roads:

Albion Road
Brittania Road
Euston road
Lancaster Road
Market Place
North Market Road
Princes Road
Rodney Road
Saxon Road
St Nichols Road
Suffolk Place
Union Road
Alexandra Road
The Conge (part)
Fullers Hill
Manby Road
Middle Market Road
Oliver Mews
Priory Plain
Roman Palace
Southampton Place
St Peters Plain
Temple Road
Yarmouth Way
Apsley Road
Crown Road
Kent Square
Marine Parade
Napoleon Place
Oxborough Walk
Regent Road
Russell Road
South Market Road
St Peters Road
Theatre Plain
York Road
Bermondsey Place South
Dene Side
King Street
Market Gates
Nelson Road Central
Paget Road
Regent Street
St Georges Road
Standard Road
Trafalgar Road

6. Police data

Police data is in relation to alcohol related events in Great Yarmouth from 19 August 2020 to 19 August 2025 and has been provided by the Operational Analysis and Research Team for Norfolk and Suffolk Police.

View police data on alcohol related events

7. Public health data

Public Health England produces alcohol profiles for local areas which look at a range of key indicators for the impact of alcohol on heath. The dashboard for Great Yarmouth is outlined below.

In most of the areas Great Yarmouth has a higher mortality rate from alcohol than the England average and significantly higher than the average for Norfolk.

View alcohol statistics

Alcohol related admissions to hospital in the UK are on the increase, with the Nelson ward being the highest ward within Great Yarmouth

View alcohol hospital admission statistics

The NHS spends an estimated £4.91 billion annually on alcohol-related harm in England, according to a recent analysis by the Institute of Alcohol Studies (IAS). This includes costs associated with hospital admissions, A&E visits, and ambulance call-outs. Overall, the total cost of alcohol harm to society in England is estimated at £27.4 billion per year.

Here's a breakdown of the costs: