PAPER B

 

 

Committee :   LICENSING (DETERMINATIONS) SUB COMMITTEE

 

Date :              11 JUNE 2007

 

Title :               TO CONSIDER AN APPLICATION FOR A STREET TRADING CONSENT FOR ‘SNACK ATTACK’ COWES, ISLE OF WIGHT

 

                        REPORT OF THE HEAD OF CONSUMER PROTECTION


 

SUMMARY/PURPOSE

 

1.                                       To invite the Licensing Committee to consider an application for a street trading consent for a mobile ‘tuck-shop’ to sell a variety of snack foods in the Cowes area.

 

DETAILS OF THE APPLICATION

 

2.                                       An application (Appendix 1) for the grant of a street trading consent has been received from:

 

Miss Nina Elphick

11 Love Lane

Cowes

Isle of Wight

PO31 7ES

 

3.             The application was received on 25/04/07.

 

4.             The proposed dates of trading are Monday - Sunday for a three month period from date of grant.

 

5.             The proposed operating times are:

 

Setting up from:                     08:30 hours

To start trading from:            09:30 hours

End of trading:                       16:30 hours

Cleared up by:                       17:30 hours

 

This trader shall sell a range of chocolate bars, crisps, carbonated cans, ice pops and penny sweets.  Copies of photographs of the Snack Attack Vehicle are attached (Appendix 2).

 

6.                 The requested roads in Cowes are as follows:

 

           Love Lane, Ash Grove, Elm Grove, Arnold Road, Shamblers Road, St. Faiths Road, Maxted Road, Seaview Road, Park Road Recreation ground, Baring Road, Egypt Esplanade and Ward Avenue.

          

           Venner Avenue, Northwood.

          

           Hogan Road, Rooke Street and Partridge Road, Parkhurst.

 


BACKGROUND

 

7.                 This is an application for a new street trading consent.

 

STRATEGIC CONTEXT

 

8.                 The decision to grant a street trading consent accords with the Corporate Plan and the Environmental Health Service Plan 2007-2008.

 

CONSULTATION

 

9.                 The Isle of Wight Council Street Trading Policy (The Policy) outlines the groups of people who should be consulted in respect of an application for a street trading consent. (Appendix 3)

 

10.             The policy allows fourteen days from the date of application in which comments may be received.

 

11.             The consultation period commenced on 1ST May 2007 and concluded on 15th May 2007

 

12.             A consultation letter was sent to the following:

 

(a)               Police: Sergeant Mudge;

(b)               Local Councillor: Cllr. Lora Peacey-Wilcox

(c)               Cowes Town Council; Mr R H Hendey

(d)               Cowes Business Association; Mrs L Murford

(e)               Highways: Kevin Burton

(f)                 Cultural & Leisure: Sean Newton

(g)               Revenues: Nikki Sampson

(h)               Fire: Trevor Moyce

(i)                 Environmental Health

(j)                  Property owners within 100 metres of the proposed site

 

13.             No adverse comments were received from the consultees as detailed above (a), (b), (f) and (i). No responses have been received from (d), (e), (g) and (h).

 

Three adverse comments were received as detailed in (14) below.

 

14.             Objections have been received from the following:

 

(a)               Objection - Cowes Town Council, Mr R H Hendey (c)

The Town Council are no longer prepared to support ventures which encourage children to buy food and drinks which are high in fats and additives and low in nutritional value. (Appendix 4)


(b)       Objection - Thelma Howland, Northwood Primary Headteacher (j)

Northwood Primary holds the National Health Schools Aware, which places emphasis on Healthy eating. The availability and promotion of unhealthy choices would send out the wrong message to children, and add extra pressure to parents who are wishing to maintain a healthy balance of only 20% treats. (Appendix 5)

 

(c)        Objection - Northwood Village Management Committee (j)

This application would be inconsistent with the local ethos promoting healthy living.  Concerns over childhood obesity, tooth decay and infant diabetes.

The objector also has concerns that the van would be directly targeting children, operating adjacent to children’s park and sale of pocket money sweets. (Appendix 6)

 

The objections are not specifically listed in section 8 of the policy (Appendix 3) but may be described in section 8 (3). ‘Any other valid reason that would affect the occupier of a property as a result of the application made.’

 

FINANCIAL/BUDGET IMPLICATIONS

 

15.             Broadly, Council expenditure on Licensing matters and specifically those matters administered and enforced through Consumer Protection, balances income generated from fees.  This arrangement is not expected to change by virtue of the grant of a street trading consent. From the information received, it does appear public safety/public order nuisance issues are a likely outcome from this application.

 

LEGAL IMPLICATIONS

 

16.             An application for the grant of a street trading consent is made under Schedule 4 of the Local Government (Miscellaneous Provisions) Act 1982 (The Act).

 

17.             Paragraph 1 of Schedule 4 defines a “consent street” as a street in which street trading is prohibited without the consent of the district council.

 

18.             On 20 April 2004 Isle of Wight Council resolved that for the purposes of street trading all current and future streets, council car parks, recreation grounds and open spaces along with public parks, gardens, amenity areas, sports areas, play areas and parking bays adopted by the council in the Isle of Wight be adopted as “consent streets” with effect from 28 May 2004.

 

19.             Paragraph 7 of schedule 4 to the Local Government (Miscellaneous Provisions) Act 1982 sets out the requirements in respect of street trading consents.

 

20.             Paragraph 7(1): An application for a street trading consent or the renewal of such a consent shall be made in writing to the district council

 

21.             Paragraph 7(2) Subject to paragraph (3) below, the council may grant a consent if they see fit

 

22.             Paragraph 7(3) A street trading consent shall not be granted

 

(a)               To a person under the age of 17 years of age; or

 

(b)               For any trading in a highway to which a control order under section 7 of the Local Government (Miscellaneous Provisions) Act 1976 is in force, other than trading to which the control order does not apply.

 

23.             Paragraph 7(4) when granting or renewing a street trading consent, the council may attach such conditions to it as they consider reasonably necessary.

 

24.             Paragraph 7(5) Without prejudice to the generality of sub paragraph (4) above, the conditions that may be attached to a street trading consent by virtue of that sub-paragraph include conditions to prevent

 

(a)               Obstruction of the street or danger to persons using it; or

(b)               Nuisance or annoyance (whether to persons using the street or otherwise).

 

25.             Paragraph 7(6) the council may at any time vary the conditions of a street trading consent.

 

26.             Paragraph 7(7) Subject to sub-paragraph (8) below, the holder of a street trading consent shall not trade in a consent street from a van or other vehicle or from a stall, barrow or cart.

 

27.             Paragraph 7(8) The council may include in a street trading consent permission for its holder to trade in a consent street

 

(a)               From a stationary van, cart, barrow or other vehicle, or

(b)               From a portable stall

 

28.             Paragraph 7(9) If they include such a permission, they may make the consent subject to conditions

 

(a)               As to where the holder of a street trading consent may trade by virtue of the permission; and

(b)               As to the times between which or periods for which he may so trade.

 

29.             Paragraph 7(10) A street trading consent may be granted for any period not exceeding 12 months but may be revoked at any time

 

30.             Local opposition or support (in whatever form) for a proposal is not in itself grounds for refusing or granting a licensing permission, unless that opposition or support is based upon valid reasons and concerns, which can be sustained.

 

31.             There is no right of appeal against the refusal to grant or refuse consent or against the revocation or variation of consent.

 

IMPLICATIONS UNDER THE CRIME AND DISORDER ACT 1998

 

 

32.             Members are advised that without prejudice to any other obligation imposed on it, it shall be the duty of each authority to which this section applies to exercise its functions with due regard to the likely effect of the exercise of those functions on, and the need to do all that it reasonably can to prevent crime and disorder in its area.

 

IMPLICATIONS UNDER THE HUMAN RIGHTS ACT 1998

 

33.             Members are advised that this application must be considered against a background of the implications of the Human Rights Act 1998.

 

There are three convention rights, which need to be considered in this context:

 

(a)                 Article 6 – Right to a fair trial

In the determination of his civil rights and obligations or of any criminal charge against him, everyone is entitled to a fair and public hearing within a reasonable time by an independent and impartial tribunal established by law.

 

(b)                 Article 8 – Right to respect for private and family life

Everyone has the right to respect for his private and family life, his home and his correspondence. In the case of article 8 there shall be no interference by a public authority with the exercise of this right except as such in accordance with the law and is necessary in a democratic society in the interests of national security, public safety or the economic well-being of the country, for the prevention of disorder and crime, for the protection of health or morals or for the protection of the rights and freedoms of others.

 

(c)                 Article 1 of the first protocol – protection of property

Every natural or legal person is entitled to peaceful enjoyment of his possessions. In the case of article 1 of the first protocol it states that “no one shall be deprived of his possessions except in the public interest and subject to the conditions provided for by the law and the general principles of international law. The preceding provisions (of which articles 6 and 8 are but 2) shall not however in any way impair the right of the state to enforce such laws as it deems necessary to control the use of the property in accordance with general interest or to secure the payment of taxes or other contributions or penalties.

 

(d)                 The Licensing Authority acknowledges the right of business in its area to operate, but equally acknowledges the fact that this must be balanced against the rights of residents not to be disturbed by unreasonable noise and nuisance caused by licensed premises.  The committee needs to be clear as to the rights granted and the need to ensure that the reasons given for any interference are proportionate and in accordance with the council’s legitimate aim.

 

34.             It has to be appreciated that there is a difference between licences and consents; however the members may wish to err on the side of caution and accept that the committee should consider Article 1 because a licence is normally deemed to be a possession.

 

35.             The Freedom of Information Act 2000 requires public authorities to disclose certain information they hold if it is requested subject to specified exemptions. This includes information contained in responses to consultations.

 

 OPTIONS

 

36.             Option 1: The Licensing (Determinations) Sub Committee may grant the street trading consent as requested by the applicant.

 

37.             Option 2: The Licensing (Determinations) Sub Committee may grant the street trading consent subject to conditions and/or amendments.

 

38.             Option 3: The Licensing (Determinations) Sub Committee may refuse to grant the street trading consent.

 

EVALUATION/RISK MANAGEMENT

 

39.       The Licensing (Determinations) Sub Committee should have regard to paragraph 9 of The Policy when considering the application.  In particular members’ attention should be drawn to sub paragraph 9(d). The general objections are about the need for ‘snack attack’ which would make it more convenient for children to source snack foods and sweets.

 

The Licensing (Determinations) Sub Committee may wish to distinguish between this application which has provoked objections and similar applications from ‘ice cream vans’ whose goods have equally poor nutritional value. Snack Attack wishes to serve the young people using the recreation ground with snacks, sweets and drinks at low prices affordable from their pocket money. This also includes ‘penny sweets’. Members may wish to consider whether this changes the van from providing an occasional ‘treat’ to providing a source of daily snack food. The applicant has made no mention of healthy alternatives.

 

The objector highlights the balance required in a child’s diet, 80% healthy and only 20% treats.  Councillors may wish to consider whether this application provides children with a treat or promotes an everyday food, and whether that is relevant to the decision to grant a street trading consent.

 

APPENDICES ATTACHED

 

Appendix 1    Application form

Appendix 2    Copies of photographs of the Snack Attack Vehicle.

Appendix 3    Isle of Wight Council Street Trading Policy

Appendix 4    Objection Letter – Mr. R Hendey, Cowes Town Council

Appendix 5    Objection Letter – Thelma Howland (Head teacher Northwood Primary)

Appendix 6    Objection Letter – Northwood Village Management Committee

Appendix 7    Isle of Wight Council Standard Street Trading Conditions          

 

BACKGROUND PAPERS

 

47.       Minutes of a meeting of the Licensing Panel held at County Hall, Newport, Isle of Wight on 20 April 2004 commencing at 10.00am.

 

48.       Agenda and papers for a meeting of the Licensing Panel held at County Hall, Newport, Isle of Wight on 20 April 2004 commencing at 10.00am.

 

49.       Isle of Wight Fire & Rescue Service – Fire Safety Guidance for Food/Concession Holders at Outside Events

 

ADDITIONAL INFORMATION

 

50.       A copy of the Isle of Wight Council Standard Street Trading Consent Conditions is attached (Appendix 7)

 

 

Contact Point:            Claire Van Heerden

Licensing Officer Ext 5120

 

 

ROB OWEN

Head of Consumer Protection