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The BBPA has submitted its own response, in which it labels the proposed Code as "untargeted" and "ill conceived" and has asked the Government to think again about the need for the measure, which will result in more bureaucracy and costs for the trade during acutely challenging times, with 52 pubs now closing every week.
There has also been near blanket opposition to the Code during the Government's series of consultation 'workshops' being held across the country. Audiences of police, council officials and licensees have voted strongly against the Code measures in electronic polls taken at the meetings.
In Birmingham, 93% were opposed or strongly opposed. At the Nottingham meeting, the figure was 80%, and in Cambridge, 77%.
Martin Rawlings, BBPA director of pubs, said: "At a time when 52 pubs are now closing every week, the last thing publicans need is this huge bill looming over their heads. It will be a body blow to many struggling pubs. And it is clear that there is little support for this unnecessary legislation, not just among the trade, but also amongst the police and local authorities.
"With pubs struggling and the country in recession, it is hard to accept that the Home Office seems determined to bury the industry in yet more red tape. All the powers needed to deal with the small minority of problem premises are already there. Better enforcement the only sensible way forward, and the Government need to rethink this entire measure."
"With public and political concern centred mainly on irresponsible promotions, the Government could quite easily focus on legislating to ban these through a simple amendment to the Licensing Act and would have the full support from the industry, police, local authorities and the public were it to do so. However, the rest of these proposals should be ditched as being unnecessary, excessive and disproportionate."
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