Tuesday 22 January 2013

Drafting An Alcohol Strategy Consultation Response

Last year, I posted a guide to questions contained in the plain packaging consultation along with some suggested responses.

This was partly because some fellow jewel thieves had mentioned that they found such procedures daunting or unfamiliar, but also due to others sharing their submitted responses with me prior to my writing it. The article encouraged more to send their personal efforts my way, all of which were very welcome and now reside in a folder set up specifically for the purpose on the Puddlecote Towers IT system.

So let's repeat the process, shall we, with the Home Office's alcohol strategy consultation which contains the daft proposal to install a minimum unit price for alcohol. I do hope you can set aside some time to respond - if you don't try, they will just do it anyway as you will note from the way the questions are posed. You have until Wednesday 6th of February to do so if you choose.

You can access it at this page, where you should scroll to the link for the online form unless you'd prefer to fire off a stiffly-worded e-mail to public.enquiries@homeoffice.gsi.gov.uk or make them open a letter addressed thus:

Home Office
Direct Communications Unit
2 Marsham Street

Now, it's important to point out some stark differences between this consultation and the plain packs one. Firstly, this is far more wide-ranging than the single issue plain packaging effort. You may wish to respond to the whole thing, or just select the issues of minimum pricing and the equally silly proposed ban on multi-buy discounts. You are able to pick and choose the elements you wish to comment on - small mercies, and all that - but for this guide we'll just run through the questions for minimum pricing and multi-buy promotions (there are actually some decent suggestions for reducing licensing red tape in later sections)

Secondly, it's not being handled by the Department of Health, which you'd assume would be the case. Instead, the Home Office has bagged the gig for reasons which become obvious when the slippery nature of government is taken into account.

You see, the Scottish parliament has already been rapped on the knuckles by the EU for pursuing the absurd idea of minimum alcohol pricing as a health issue, and is currently being challenged in court by the Scotch Whisky Association. It's pretty clear that if minimum pricing for tobacco can be rejected as illegal, then the same for alcohol has no chance whatso-pigging-ever on health grounds.

Hence the decision that the Home Office are to lead on it based on the dodgy premise that it will deter or prevent public order offences. Yes, that's right, the government is trying to say that increasing the price of supermarket brand cheap fizz will stop late-night brawls outside town centre pubs serving a bottle of Bud for £4 and shots for £3 a pop.

The shift from the DoH to the Home Office also proves that minimum alcohol pricing is a policy which the coalition is deadly determined to drive through on the say-so of, err, Cameron and Cameron alone (actually, he will no doubt enjoy some backing from Sarah "one trick pony" Wollaston and her made-up stats).

The questions, and available answers, in the consultation only emphasise that further. All of which makes it even more important that you stick your oar into their puritan outboard motor if you can possibly do so.

So here is a plan on how I intend to respond before the closing date of 6th February, two short weeks away.
The impact of minimum unit pricing will depend on the price per unit of alcohol. The government wants to ensure that the chosen price level is targeted and proportionate, whilst achieving a significant reduction of harm. The government is therefore consulting on the introduction of a recommended minimum unit price of 45p. 
The government estimates a reduction in consumption across all product types of 3.3 per cent, a reduction in crime of 5,240 per year, a reduction in 24,600 alcohol-related hospital admissions and 714 fewer deaths per year after ten years. 
Do you agree that this minimum unit price level would achieve these aims? 
Don't know
Well, that's a slam dunk no, isn't it?

The question contains the answer in quoting figures advanced by the appalling 'evidence' from Sheffield University. Their 'research' is deliberately flawed and is advanced by a team who are so lax that they didn't bother checking their figures before the BBC's Panorama was forced to apologise for their shortcomings.

There is a text box beneath that question ... you might want to remind the Home Office that their source is quite pathetic and funded to come to a pre-determined conclusion.
Should other factors or evidence be considered when setting a minimum unit price for alcohol? 
Please select one option. 
Don't know
Note the absence of an option saying that minimum pricing should be rejected entirely? I suggest answering no and using the explanation box to say that it shouldn't be considered at all. As evidence, just reiterate that Sheffield's analysis is bollocks (but in finer vernacular, perhaps).

Hey, it gets worse, believe me! Question 3.
The government wishes to maintain the effectiveness of minimum unit pricing and is therefore proposing to adjust the minimum unit price level over time. 
How do you think the level of minimum unit price set by the government should be adjusted over time? 
Please select one option. 
 Do nothing - the minimum unit price should not be adjusted 
The minimum unit price should automatically be updated in line with inflation each year 
The minimum unit price should be reviewed after a set period Don't know
"Select one option"? None apply, since they all accept that minimum pricing is a given. There is no box allowing the option to object to the policy.

It is now becoming clear that this is designed exclusively to invite miserable scaremongery from state-funded finger-waggers.

I suggest selecting "don't know" and using the text box to explain that the proposal shouldn't even be on the table, let alone ramped up every time the Chancellor stands up to deliver his bloody budget (alcohol free these days, you may have noticed). 

The aim of minimum unit pricing is to reduce the consumption of harmful and hazardous drinkers, while minimising the impact on responsible drinkers. 
Do you think that there are any other people, organisations or groups that could be particularly affected by a minimum unit price for alcohol? 
Please select one option. 
Don't know
Well, of course yes.

It is a policy deliberately designed to punish the poor, from a Prime Minister who is pretty confident that none of his millionaire mates will ever have to fork out an extra penny. It is deeply regressive - the Institute of Fiscal Studies has estimated that it will remove £700million from the pockets of the less well off and deliver it straight into bank accounts of already wealthy corporations - and the policy should have no place in a society claiming to be fair, which is supposed to be a buzzword with modern political rank and file.

Now for multi-buy promotions.
Do you think there should be a ban on multi-buy promotions involving alcohol in the off-trade? 
Please select one option. 
Don't know
Err, emphatically no. Why? Because it has been widely reported to have failed dramatically in Scotland, in fact it may may have even increased sales, and its unintended consequences have led to prohibitionists to call for even more intrusions on the law-abiding, non-problem drinker.
Should other factors or evidence be taken into account when considering a ban on multi-buy promotions? 
Please select one option. 
Don't know
Apart from it not working, d'you mean? Well, how about 650 in parliament having a fucking cheek placing themselves between businesses who want to sell legal products at market rates and around 44 million potential customers who are quite happy to buy (or not) at those rates?
The aim of a ban on multi-buy promotions is to stop promotions that encourage people to buy more than they otherwise would, helping people to be aware of how much they drink, and to tackle irresponsible alcohol sales. 
Do you think that there are any other groups that could be particularly affected by a ban on multi-buy promotions? 
Please select one option. 
Don't know
Difficult one, this. It is tempting to say no, but yes is the answer.

We are constantly told that 'pocket money prices' are a problem with alcohol sales, yet banning multi-buy promotions - as proven in Scotland - will merely bring the cost of single units down. And how is this supposed to help people "be aware of how much they drink"? If they buy slabs of Carling, they will continue to do so. If they buy single units, they'll carry on doing that too, but for less money. Politicians are so wrapped up in their own procedures and self-importance that it seems they never really think anything through before wasting our taxes on twaddle.

That is about it for minimum pricing and multi-buys, though the rest is quite funny too, in places, if you intend to respond further than the above.

I found it particularly amusing, for example, that Westminster is wasting its time suggesting mandatory licence conditions such as providing "free water on request to customers" and banning "dispensing alcohol by one person directly into the mouth of another". It's hard to decide if they belong in the script of an inept minister in The Thick Of It or a Monty Python satire.

And as for putting public health in charge of deciding new licence applications (yes, that's there too), they may as well ask vegans how many butchers are allowed on the High Street.

Do go have a look around and have your say. You don't have to give your name and you may qualify for a community action reward ... or a slim chance of not being treated forever like a child by dull-minded, shitstick politicians, anyway. 


Steve Brown said...

I had a great deal of fun filling in that load of tripe!

If an undergraduate had presented that questionnaire as being appropriate for discerning opinions then he/she would have been shot down in flames in seconds! It presumes acceptance of the imposition of minimum pricing, the questions are more loaded than a primed cannon and the restricted responses restrict replies to unintended positives.
What a farce!

I'm buying my home-brewing kit tomorrow!

Dick_Puddlecote said...

They're asking the general public as well as businesses, public sector organisations and even - as we saw with the plain packs consultation - citizens and governments of other countries.

As for why it is not publicised more, we'll that's just how government likes to work. Squirrel it away on an obscure page of some boring civil service website and they can say the public has had their chance to respond without the danger of many actually doing so. Of course, anti-alcohol groups who are paid out of your taxes will be acutely aware of the process because it's their job to know. They'll have received many a reminder from central government too just in case they forgot to add it to their Outlook calendar.

You won't receive an e-mail announcing the start of the consultation - nor would private businesses in the drinks or hospitality industry - but Alcohol Concern, for example, would have been sent a personal invite to respond.

It's just how the modern, shifty, mendacious politician and his greaseball civil facilitators have chosen to {cough} serve the public these days.

Dick_Puddlecote said...

Great to hear you took time to make the effort, Steve. :)

Questions more one-sided than Pavarotti on a see-saw, weren't they?

Steve Wintersgill said...

I did mine a while ago, but have just shared this post to FB 'pour encourager les autres' :-)

Simon Cooke said...

Although the changes allowing for a more free occasional licencing system are welcome, there is a proposal to allow health authorities the same rights as the police in objecting to new licences and licence renewal. This is on the rather dubious grounds that a concentration of licences increases the harm to health (there is at least a modicum of logic to the police powers and anti-social behaviour argument). In understanding this, we should appreciate that you and I don't have the right to support or object - unless we are close neighbours to the licenced premises. Indeed, I cannot object or support as a local councillor unless I do so on behalf of residents close to the licenced premises in question.
The result of these changes will undoubtedly be - in some places - a host of licence objections from local health authorities claiming that another pub or off licence will reuslt in most "alcohol-related harm".

Sam Duncan said...

It's hardly new. I've been re-watching the first series of Yes, Minister (now more than thirty years old) on DVD lately. This is straight out of the Sir Humphrey Appleby playbook. Douglas Adams had a pop at local authorities doing much the same thing in the first episode of Hitchhiker's around the same time.

Beware of the leopard.

tiredofcameronsbs said...

This was very helpful, thank you - I hadn't even see the consultation mentioned anywhere before. I made sure to mention that minimum pricing will lead to more offshore duty free buying, leading to less tax/profits overall. Denmark had to repeal its 'fat tax' recently because people were going to neighbouring countries to do all their shopping, hitting the government in their wallets where it hurt!