Cumulative impact assessment consultation


We are undertaking a four week consultation exercise to determine whether a Cumulative Impact Assessment (CIA) should be published to help it limit the number or types of licence applications granted in areas where there is evidence to show that the number or density of licensed premises in the area is having a cumulative impact and leading to problems which are undermining the licensing objectives:

  • The prevention of crime and disorder;
  • The prevention of public nuisance;
  • Public safety; and
  • The protection of children from harm.

Through this consultation we are seeking to identify whether there is a sufficient evidential basis to publish a CIA and if so the area and types of applications that should be included. In particular we are seeking information, and supporting evidence, in respect of:

  • Crime and Anti-social behaviour (ASB) statistics;
  • Health related statistics, such as alcohol related hospital attendances and admissions;
  • Complaints that relation to nuisance, such as litter and noise;
  • Complaints raised by local residents or residents’ associations;
  • Resident feedback;
  • Elected Member (local or parish) feedback;
  • Other evidence that could be attributed to the Cumulative Impact of Licensed premises.


Cumulative Impact Assessments were introduced to the Licensing Act 2003 by the Policing and Crime Act 2017. In general terms they replaced Cumulative Impact Policies (CIP).

Before adopting a CIA the authority must establish the evidential basis that one is required, and consult upon its scope and extent with the same persons that must be consulted over the Statement of Licensing Policy (SLP).

Since July 2013 we have had a CIP detailed within our SLP. The CIP was originally requested by Staffordshire Police and has been renewed annually until 2021 when the current CIA was introduced. The CIP covered an area known as the ‘Town Centre’ and which overlapped two distinct police reporting areas, but did not incorporate all of the two areas. The current CIA was based upon the same area and a plan can be downloaded.

Our Licensing Committee last reviewed the evidence and determined that there was an evidential basis in March 2021. The current CIA was published on 14th July 2021 and must be reviewed within a 3 year period from its inception.

The provisions of publishing a CIA state that a CIA may relate to all premises licences (PL) and club premises certificates (CPC), or only those described within the assessment. For example a CIA could apply only to all PLs and not to CPCs. Or it could apply to both PLs and CPCs but not to specific types of business e.g. a CIA could be published that does not include a PL that is for a cinema, or late night takeaway business but does relate to pubs, restaurants and nightclubs. The current CIA relates to all premises applications, new and variations, that authorise or propose to authorise the sale or supply of alcohol for consumption on or off the premises. It does not relate to premises applications that only authorise, or propose to authorise, the provision of late night refreshment and/or regulated entertainment.

Further information can be found at Chapter 14 of the Licensing Act 2003 Statutory Guidance.


We are requesting views and evidence from any person, body or party that may have an interest in the matter of whether we should publish a new CIA. Points that you may wish to consider include:

  1. Whether there remains an evidential basis to retain the CIA as it is;
  2. If so, then on what basis;
  3. If not, then whether there a basis to publish a CIA with a different scope;
  4. If the area needs amending then propose a new area or the removal of the existing area with evidential basis for doing so;
  5. If the type of activities need amending then provide an evidential basis as to the licensable activities to be added or removed;
  6. If the nature of the businesses or type of premises that should be included, or excluded from any CIA if published.

The above points are not exhaustive and we welcome any comments with supporting evidence regardless of view point. However it should be noted that we cannot accept and consider comments on whether there is a ‘need’ for more/less premises.


The consultation period ran from Friday 15 March 2024 to Thursday 11 April 2024.