· A poll of council licensing officers carried out by the LGA Group found that 9 out of 10 think the exemption would lead to an increase in complaints about noise and nuisance. More than half said they expected the increase to be considerable. As such, we believe the proposed exemption is contentious.

If the proposed exemption is at all contentious, it is important to note the direction of that contention and establish if it is at all valid. What is reported is here is what some licensing officers may think. And even if there were to be an actual increase in complaints about noise and nuisance - so what? Again what some people who complain may think, is just that and beyond any control.

The only complaints that should be concerning the LGA Group, are those that are proved to be valid on investigation. The licensing objectives do not currently include reducing the number of complaints. There is no onus on the LGA Group to reduce the number of complaints. The quantity of complaints being made may not reflect any corresponding increase in noise or nuisance but could be reflecting many other factors, such as the attitudes of Licensing Authorities actually encouraging complaints to be made by scare-mongering tactics, such as the type of objections being made in this submission.

Again it is not as if the concept of a de minimis exemption is new and the world did not end for all the years that the two-in-a-bar rule was in place. No corresponding reduction in the quantity of complaints seems to have been reported since the abolition of the two-in-a-bar rule, so there would seem to be little real concern for a resulting increase caused by this proposal. This suggest that the LGA Group's opposition here is not based on any real concern for the public's well-being. This stance alone is enough to alarm the public and as it is not a stance based on evidence, it is not one the LGA Group, as a responsible body should be expressing?

The same concern about anticipating the level of and urgently addressing potential and actual complaints, is not one shown when the complaint or concern is from members of the public and is about the local interpretations and resulting enforcement actions taken by licensing officers and the adverse effect of these on live music. Obtaining any satisfaction in these circumstances is unlikely and considered to be outside of the process described by the LGA Group as the democratically accountable licensing regime.