Client: City of Westminster Council

Project: Licensing CUMULATIVE Impact ASSESSMENT Review

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What were MAKE asked to do?

In licensing terms, Westminster is the most watched, most contested and most influential borough in the country. It has 3,700+ licenses, huge ongoing demand for new venues, cutting edge innovation and vast footfall, all of which are allied to a series of strong residents’ associations and significant challenges with crime and disorder. There are more licence applications, reviews and appeals in Westminster than anywhere else in the country.

In developing the council’s 2020-25 Statement of Licensing Policy there was a need to update its Cumulative Impact Assessment (CIA), to see if there was still a need for a Cumulative Impact Policy (CIP), and if so, what geographical boundaries or other parameters that should apply. Given that Westminster’s licensing policy is scrutinised more closely than any other, the council asked MAKE to review the analysis contained within the 150-page Cumulative Impact Assessment and the conclusions drawn from the data.

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How did MAKE do it?

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  • Reviewed the overall document for missing sources of data that could be harnessed and analysed.

  • Examined the interpretations of the statistical modelling and regression analyses and in terms of conclusions drawn from them – were they reasonable and defensible?

  • Scrutinised the mapping to see how the data had been geographically represented and if this was a reasonable spatial realisation of the data. 

  • Identified if any geographical areas had been included in the mapping without sufficient evidence and likewise if locations that had been excluded from the CIP areas where the evidence was overwhelming for their inclusion. 

  • Comparative analysis of the existing cumulative impact areas and new hotspots to assess whether they may warrant inclusion in any new CIP area/s. 

  • A view on the veracity of overall conclusions that had been drawn.

What happened next?

The Council took the MAKE findings and changed the Cumulative Impact Assessment geographically and as well as re-wording certain sections to make it more robust. The CIA is the most statistically rigorous and comprehensive yet produced by a licensing authority. 

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Westminster published the Cumulative Impact Assessment and its draft Statement of Licensing Policy in November 2020 for public consultation. A key facet of this consultation was the council requesting specific input, in the midst of the pandemic, into the formulation of a licensing policy that addressed Covid and achieved a balance between supporting recovery of the licensed economy whilst protecting the four licensing objectives.

What unique value did MAKE bring to this project?

We have an in-depth knowledge of both the Westminster geography, as well as cumulative impact assessments, statistical modelling and GIS systems. This allowed us to advise on how to refine an already hugely comprehensive CIA into an even more rigorous document.