I have responded online to the questions but this is only half the story and I would like to add the following, for your consideration.
The whole package is flawed as it is based on a concern over alcohol and rather overlooks the fact that there is no longer an alcohol licence and that the document does not refer to any attempt to create one. There remains but one licence with one level of fees - The Premises Licence.
As a result, the measures proposed in this document to address alcohol-related problems will apply equally to premises which may not in fact serve any alcohol.
To take but one example: The proposal to increase licensing fees - due to some perceived problem with alcohol-related issues at some premises - will result in a school, hospital, cafe or coffee bar (which requires a Premises Licence to provide live music or the facilties to enable them) also having to pay any increase in fees.
It is quite unfair to proceed with any of these proposals until an alcohol only licence is re-introduced. The existing over-regulation needs to be addressed and the split of responsibilities between the Home Office and DCMS needs to be detailed and an full explanation needs to be agreed and suppled so that all proposals by this LibCon Govt to deal with areas currently covered by the Premises Licence are dealt with openly and at the same time.
To the disgrace of the previous Govt, the current expensive shambles which is the additional entertainment permission aspect of the Licensing Act 2003 has always suffered because the alcohol aspects were judged to be more important. One can only hope and trust that the current Govt will not make the same mistake - but in rushing through this consultation and these proposals, it would appear that they already have.