Clause 112 takes us to temporary event notices, by extending the right to comment on them to the environmental health officer. Currently, the chief officer of police may object, given various time frames and time limits. A hearing is required if the police object, which they may only do on the grounds of the crime objective set out in the Licensing Act 2003. The clause extends the right to make objections to the environmental health officer, and it offers the police and the environmental health officer the right to object over all four licensing objectives.
I want to make some points about the clause because, first, my understanding was that the rationale for the temporary event notices was to have something quick, effective and flexible. With an environmental health officer being involved and able to object, we are moving more towards temporary event notices becoming similar to mini-licences. I want the Minister to reflect on that and on the additional bureaucracy attached to the clause.
Also, why can environmental health officers comment? Clearly they have a specific role in and knowledge of environmental health issues, but they will be able to object on all four licensing grounds. The original intention of the police being able to object was restricted to what they know best about, which is crime and public order. They had to keep to that objective as their key reason for objecting. Now, however, the provision has been widened and all four licensing objectives can be considered by the police and the environmental health officer.
The submissions express concern about environmental health raising the bar for what is expected with temporary event notices. The notices are often used by small community groups for one-off events, so the people involved are not generally that experienced in licensing conditions. A concern is that we will see standards imposed, which was not the original intention for the temporary event notices.
Another concern is that we may see great disparity around the country. What one environmental health officer might require, another one would not. Also, if there are problems with temporary event notices, conditions might be attached in the future—if there was a problem—rather than attaching them with the original application.
Will the Minister respond to those specific points?