Dear Sir,

Further to our meeting with Dermot Ahern, TD, Minister for Justice, Equality & Law Reform on Friday, 20 June last and to our subsequent meeting with you on Wednesday, 25 June, we would like to draw your attention to the following points:

• The introduction of the 10pm closing without the implementation of Section 8 or the proposed Code of Practice will lead to alcohol being openly on display in mixed trading / convenience outlets for a lot longer during non licensing hours (2.5 hours longer between 10pm and 12:30pm at weekends). This will more than likely result in sales of alcoholic product outside of licensing hours.

• By requiring specialist off-licences to close at 10pm without the presence of Section 8 you are further opening up the retailing of alcohol to untrained personnel in mixed trading environments, who in many cases have no knowledge of the responsibility social or judicial obtaining to the sale of alcohol. Till operators will be put under undue pressure from customers arriving at the counter with alcohol, late in the evening, unaware that it is not available for purchase because of the repeal of the licensing hours back to 10pm.

• By closing earlier the specialist off-licence sector was prepared to forgo up to 20% of its daily turnover in support of the legislation, the purpose of which is to tackle alcohol abuse. This was in recognition of the fact that mixed traders would also be impacted upon due to segregation. Loss of sales will have serious economic implications for our members and they now perceive that the powerful mixed trading groups have somehow managed, yet again, to evade their responsibilities in regard to alcohol legislation.

As stated above we are prepared to do what is necessary, however, in the interests of equity and responsibility the repeal of off-licence hours to 10pm closing should be introduced in conjunction with and not prior to the full ratification of Section 8 or the Code of Practice.

Joint introduction would ensure that the Code of Practice is developed in a timely manner therefore preventing protracted discussions amongst what are very disparate strands of the alcohol retailing industry.

I would ask you to bring these matters to the urgent attention of the Minister for Justice.

Yours sincerely

JIM MC CABE
Chairman