Consultation open

A Local Alcohol Policy sets out how alcohol should be sold and supplied in Christchurch and Banks Peninsula.

Any council can develop its own Local Alcohol Policy, in consultation with the local community. A Local Alcohol Policy can set rules around the number, location, and opening hours of licensed premises, such as bars, cafes and restaurants, supermarkets and bottle stores. These rules can apply across either the whole city and district or only in identified local areas.

What can be included in a council’s Local Alcohol Policy is outlined in the Sale and Supply of Alcohol Act (the Act). The objectives of the the Act are to ensure “the sale, supply and consumption of alcohol should be undertaken safely and responsibly”, and that “harm caused by the excessive or inappropriate consumption of alcohol should be minimised”.

The policies in a Local Alcohol Policy can apply across either the whole city and district or only in identified local areas.

Any council wishing to have one must follow a process set out in the Act, which includes considering local data and producing a draft policy to formally consult on.

Over the last year we have gathered feedback from our communities and data from a range of sources including the Police, Health New Zealand Te Whatu Ora, Salvation Army, St Johns and licensing data, and completed research, to understand what conditions could be included in a Local Alcohol Policy. You can find out more by reading the Research Report, Issues and Options Paper and Engagement Analysis Report.

We have developed a Draft Local Alcohol Policy and now is the time to tell us if you support each of the proposed individual policies within the Policy before Council decides whether to adopt it later this year.


Our proposed policies

Click on each of the individual policies below to find out more.

Policy 1. Reduce trading hours for all off licences to 9pm daily

  • What we propose and why?

    We propose that all off-licence retailers across the district would only be able to sell alcohol until 9pm at the latest each day. This includes all bottle stores, supermarkets, small grocery and convenience stores, wineries and other venues that hold an off licence.

Our research tells us the most alcohol harm occurs at night and in the early hours of the morning. Restricting hours of operation could help reduce this. Currently, the latest closing time for these retailers can be 11pm.

Earlier this year we tested reducing the trading hours at night with the community and 53% agreed we should. The majority thought a closing time of 10pm or earlier would be appropriate for off-licence retailers, as many viewed reducing the availability of alcohol, particularly late at night, would lead to a reduction in alcohol-related disturbances and anti-social behaviour, including crime, noise, violence and social harm. They also viewed it as helping to protect vulnerable groups and communities, and being an effective way to limit the ability for people who have already been drinking to ‘top up’. You can read more about community views in the Engagement Analysis Report.

Taking into consideration community and stakeholder views, recent research and the purpose of a Local Alcohol Policy to minimise alcohol-related harm, we propose to reduce the maximum trading time to 9pm daily.

How it would work

All off-licence retailers across the district would only be able to sell alcohol up until 9pm at the latest. This includes bottle stores and supermarkets, and would impact 201 current off-licence retailers across the district (currently there are already 53 off-licence retailers that are required to close by 9pm or earlier).

This policy would also apply to all Working Men’s Clubs and other on-licensed venues that also hold off-licences. They would not be able to sell alcohol to take off the premise after 9pm but could continue to sell alcohol to be consumed on the premise until the maximum trading time within their on-licence.

Remote sellers would be exempt

This option would not apply to premises which hold an off-licence under section 40 of the Act (remote sellers). Remote sellers can sell alcohol online, by phone or by mail order, but not to customers who are physically at their premises. Remote sellers are exempt from trading hours restrictions under the Act. However, they are bound by the restrictions in the Act regarding the hours they can deliver alcohol.

It would be operative no earlier than 3 months after the Council notifies they have adopted the policy.

Advantages and disadvantages of reducing trading hours for off-licences:
Advantages
  • Possible reduction of alcohol-related harm.
  • Addresses concerns that trading hours for off-licence premises are too long.
  • The greatest impact is likely to be felt in areas with higher deprivation, which tend to have more off-licence premises with longer trading hours.
  • Generally supported by the community, and supported by NZ Police, Health New Zealand - Te Whatu Ora and licensing inspectors.
  • Simple to understand. The rule is clear and implementing it should be straightforward.
Disadvantages
  • May drive people to purchase alcohol earlier in the day.
  • Some impact on business, such as possible reduced revenue for off-licence premises who are currently open after 9pm, and a cost for supermarkets e.g cordoning off alcohol for sale after 9pm.
Other restrictions considered
  • The Council did not consider other restrictions or exemptions for this policy.


More information on community views from testing this policy is available in the Engagement Analysis Report.

Policy 2. Place a freeze on new off-licences in high deprivation areas

  • What we propose and why?

    We place a freeze on granting new alcohol licences for off-licence premises in high deprivation areas to address the disproportionate level of alcohol-related harm experienced by higher-deprivation communities by preventing further concentration of licensed premises in these areas.

Our research indicates availability of alcohol in areas of high deprivation is a concern for our communities, and residents in these areas are more likely to experience alcohol-related harm. We tested placing a temporary freeze on new licence applications for any new venues and outlets in high-deprivation areas for three years.

Of the 3478 people and organisations who provided feedback, 61% agreed we should apply it to some licensed retailers and venues. Those with the strongest community support to apply it to were bottle stores (68%), small grocery stores (52%) specialty stores (47%) .

Feedback showed concern for the proliferation of off-licence retailers rather than many on-licence venues like cafes, restaurants and bars. Cafes, restaurants and bars were viewed as less of a risk, because they serve more purposes than just selling alcohol such as providing entertainment, selling food, creating a platform for socialising, as well as adding a sense of vibrancy and life to the area.

Some also felt that supermarkets are more of a grey and complicated area because while they do sell alcohol for off-premise use, they also serve the purpose of selling essential groceries.

How it would work

A freeze would be placed on granting alcohol licences for new off-licence premises within high deprivation areas. The freeze would apply to areas across the district that score decile 8 -10 on the New Zealand Index of Deprivation SA2 Map (2023) and reviewed within six years when the Local Alcohol Policy is reviewed.

The New Zealand Index of Socioeconomic Deprivation (NZDep) uses a scale between 1 (low deprivation) and 10 (high deprivation) and measures deprivation based on census data across eight dimensions: communication, income, employment, qualifications, home ownership, support, living space, and dwelling condition.

Existing premises and exemptions

An exemption is possible for licence applicants who can show their primary purpose is not the sale and supply of alcohol.

Existing off-licence premises could renew their alcohol licence and an existing off-licence premises could change ownership and continue operating.

Advantages and disadvantages
Advantages
  • Has strong general support in the community.
  • Addresses community concerns about the proliferation of off-licence premises in high-deprivation areas.
  • Acknowledges community views about on-licences, such as cafés and restaurants.
  • Reduces the risk that concentrations of off-licence premises encourage lower prices, and consequently greater alcohol consumption.
  • Can act as a temporary “sinking lid” – in other words, it may prevent further alcohol-related harm in these areas, and possibly reduce it over time, if off-licence premises close and are not replaced.
Disadvantages
  • Restricts the ability for off-licence operators to invest in new business endeavours in these areas and gives a competitive advantage to retailers who are already operating.
  • People can still purchase alcohol from on-licence premises, existing off-licence premises or premises that are granted an exemption.
  • As the policy applies to only some areas, it inherently has some complexity to it.
Other restrictions considered
  • The Council considered not including an exemption for premises which can show the primary purpose of their business is not the sale and supply of alcohol.

Applying the freeze geographically

Council has considered how to apply the freeze to high deprivation areas geographically. We propose to apply the freeze to areas that score 8, 9 and 10 on the New Zealand Index of Deprivation SA2 map (marked in red). The boundaries within the map would become the geographical boundaries the freeze would apply to. These maps show the high deprivation areas the freeze would be applied to. Note: there are no high deprivation areas within Banks Peninsula when SA2 mapping is used.

More information on community views from testing this policy is available in the Engagement Analysis Report.

Policy 3: Restrict new bottle stores near sensitive sites

  • What we propose and why?

    We propose that all new bottle stores, in suburban areas across Christchurch can not open within 200 metres of an addiction treatment/rehabilitation site, secondary school or primary school in Christchurch suburbs, within 50 metres of an addiction treatment/rehabilitation site and secondary school or primary school in Banks Peninsula and, within 100 metres of an addiction/ rehabilitation site and 50 metres of a secondary school or primary school in the central city, .

More than 70% of survey respondents in the 2024 Life in Christchurch survey told us they thought restrictions should apply on how close a licensed venue or outlet is located to community facilities they considered sensitive, so we tested this further.

We asked the community whether we should restrict how close off- and on-licence retailers and venues were to a number of educational, health and religious community facilities.

Of the 3478 participants, 68% agreed the Council should restrict how close some new licensed venues and retailers can be located to some community facilities. The most common licence types the community wanted restricted were bottle stores, taverns (pubs and bars) and night clubs.

The community facilities that had the most support for applying this policy to were addiction treatment/rehabilitation sites, secondary and primary schools and early childhood learning centres. A 200 metre distance restriction was also preferred for those community facilities.

When asked why we should restrict off or on-licence retailers and venues from being close to community facilities, a number shared views about normalisation of alcohol consumption and the impact of alcohol-related harm on children and young people, highlighting the importance of a proximity restriction to reduce the exposure young and vulnerable people had to the advertising and availability of alcohol.

Some also identified the importance of maintaining safe environments and reducing anti-social behaviour around schools, addiction centres and other sensitive sites.

How it would work

We restrict new bottle stores in suburban areas from opening within

  • 200 metres of an addiction treatment/rehabilitation site, a secondary school or a primary school in all areas outside of the central city four avenues (of Bealey, Moorhouse, Fitzgerald and Deans).
  • 100 metres of an addiction treatment/rehabilitation site and 50 metres of a secondary school or a primary school within the central city four avenues (of Bealey, Moorhouse, Fitzgerald and Deans).
  • 50 metres of an addiction treatment/rehabilitation site, a secondary school or a primary school in Banks Peninsula (including but not limited to Akaroa, Lyttleton, Diamond Harbour, Little River, and Duvauchelle).

The policy would not apply to sites located within the City Centre Zone (as shown in the map below).

Existing premises and exemptions

Existing bottle stores could renew their alcohol licence, and an existing bottle store could change ownership and continue operating.

Exemptions are possible if the applicant can show they have engaged with the community and can demonstrate that they can manage the store in a way that addresses any concerns.

Within the Central City there is also an exemption for the City Centre Zone (CCZ), as defined by the District Plan. The CCZ is recognised as the primary destination for activities including dining, night life and entertainment activities. The exemption of this policy for the CCZ recognises the role that this area plays in the city.


Advantages and disadvantages
Advantages
  • Has strong general support in the community.
  • Potential for reducing harm to vulnerable populations by reducing the establishment of new bottle stores to purchase alcohol.
  • Reduces the burden on the community to object new bottle stores being located near sensitive sites, effectively shifting the burden to the applicant who would have to demonstrate that harm can be mitigated.
Disadvantages
  • Impact on reducing alcohol-related harm is unclear.
  • The exemption process could be onerous for applicants or communities if there are frequent exemption requests.
  • Restricts the availability of bottle stores in some communities.
  • As the policy applies to only some areas, it inherently has some complexity to it.
Other restrictions considered
  • The Council considered applying this policy to taverns and night clubs.
  • The Council also considered treating Banks Peninsula the same as the rest of the district (excluding the Central City).


Sensitive sites

We chose to focus on addiction treatment/rehabilitation sites, secondary schools and primary schools because they were the most supported sites that the community told us they wanted the policy applied to. We also considered the practicality and simplicity of applying this policy across the district to ensure we take a proportionate and reasonable approach. For example, for this reason, we did not include Early Childhood Education (ECE) centres within the policy. There are far more ECE centres across Christchurch compared to other types of schools and we consider that the coverage of the policy across this city if we applied it to ECEs would be impractical and disproportionate. This is also why we didn’t apply the policy to places like neighbourhood parks and reserves.

Applying the proposed policy geographically

These maps illustrate the areas that the proximity restriction would be applied to across the district. They are not within the policy itself. Click on each map to open a larger view.

More information on community views from testing this policy is available in the Engagement Analysis Report.

Impact of policy 2 and 3 across the district

This map shows the extent of areas that will have restrictions applied if both policies two and three were approved within the Draft Local Alcohol Policy.

Pull the arrow across the image to see the policies overlaid.

Policy 2: Freeze on granting an off-licence to new premises in high deprivation areas Policy 3: Proximity restriction applied to sensitive sites overlaid on to

Options considered and not carried forward

Reducing trading hours for on-licences in suburban areas

Early engagement included a possible policy option to reduce trading hours for on-licences in suburban areas. We opted not to proceed because it was the least supported option, and because responding to the community’s general preferences – treating different types of on-licence venues differently, rather than having a blanket rule – would create some complexity and risk. The District Licensing Committee can already apply different times to different licence applications on a case by case basis so the status quo remains appropriate.

One-way-door restriction

Early engagement included a possible policy option to introduce a one-way-door restriction. There was a small majority of support for this option, and among those who did support it, their clear preference was for a 1am one-way-door policy. However, we consider that a 1am one-way-door policy would have a negative impact on the hospitality industry and the city’s nightlife, and could lead to unintended consequences like people leaving supervised venues early and continuing to drink unsupervised. Other possible cut-off times did not receive strong support, with a range of opinions on whether the impact would be positive or negative. The District Licensing Committee can already apply a one-way-door restriction on a case by case basis without a Local Alcohol Policy so the status quo remains appropriate.

Other restrictions proposed by stakeholders

We received a number of other suggested options for a Local Alcohol Policy from the community and stakeholders. As part of our process of analysing the possible options, we have been careful to ensure that all the options would meet the objectives of the Act, are proportionate, practical and feasible. We have been careful not to create a policy that is too complicated or detailed for the public to understand or the District Licensing Committee to apply. We have also been careful to ensure that we consider and balance a range of perspectives. Some of the options proposed by the community and stakeholders were outside of the scope of what a Local Alcohol Policy can consider. Other options that were proposed, while well-intentioned to address alcohol-related harm, were considered a less practical or proportionate response.

Read the Engagement Analysis Report to find out more.


Tell us what you think

We want to know if you support each of the proposed policies within the Draft Local Alcohol Policy. Make a submission by Sunday 18 May.


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