The Foundation for Alcohol Research and Education (FARE) welcomes the opportunity to provide comments to the Northern Territory Government on its draft Community impact assessment guidelines (the guidelines). Governments have a duty of care to protect the health and wellbeing of the community and the liquor licensing process should not be excluded from this responsibility. Determining the impact of a liquor licence on the community is critical and should sit within a frame that puts the onus of proof on the applicant that they will not contribute further to levels of harm.
In its submission to the NT’s Alcohol Review Implementation Team, FARE stated that the guidelines provide a good foundation for the assessment of the impact of liquor licence applications in the Northern Territory, and that they should be strengthened and adopt a principles based approach to ensure the guidelines are consistently applied and provide confidence in the integrity of the assessment process. Importantly, these guidelines should reflect and support the Northern Territory Government’s alcohol policy and legislation reform agenda to prevent and reduce alcohol harm.
FARE identified the following principles to underpin the assessment of the impact on the community and the development of these guidelines:
1. Assessments of the impact of liquor licences on the community apply to all licence types and include new applications and variations to existing licences.
2. The assessment of the impact of licences on the community prioritises harm minimisation over liquor sales and requires applicants to clearly demonstrate that their proposed venues will not contribute to further harm in the community.
3. Assessments of the impact of liquor licences on the community are supported by evidence to demonstrate the validity of claims made by applicants.
4. The community has a legitimate role in the development of impact statements and are consulted as part of this process.
5. Consideration of the impact of a licence application on the community is guided by a risk model to support decision-making and provide fairness and consistency.
6. The assessment process is transparent and fosters accountability by making information publicly available.
7. The guidelines are reviewed on a regular basis to ensure that they continue to meet the objective of preventing and reducing harm.