I completely agree with you Kevin. While it has been useful having an analysis of the guidance document, I think that too much discussion on the detailed legal details and how they might/could/should be interpreted is not necessarily very constructive, and indeed may distract us from the more inportant issue of making sure that as many pubs (and other venues) as possible do apply for entertainmant licenses when they first have to fill in the new application form.

I think it is also most important to look and see if any councils are trying to find loopholes in the system so that they can continue to make money out of granting entertainments licenses. As noted elsewhere, Greenwich council have closed down a session within the last couple of months insisting that "The Star & Garter" obtain a PEL - which I'm sure the council expect to make some cash on.

No-one seems to have answered my question about what happens when a pub has already paid for a PEL under the old system - I can't see the council being very happy to say "OK now you've ticked the box, you don't have to pay anymore and here's a refund on the six months that your old PEL still had to run". Yet having granted a PEL in the past, it would be rather difficult for them to refuse a new entertainments license or to insist on new conditions. Councils like Greenwich, definitely saw PELs as a way of raising revenue and somehow, I don't think they're going to give up so easily. The fact that they are still being quite draconic in this interim period seems to support this.