From: Suraj Desor Sent: 04 May 2021 10:57 To: Licensing <Licensing@hounslow.gov.uk> Subject: Applicant Response to Your Representation - Weezy, Brentford New Premises Licence Application Dear Neighbour I act upon behalf of Weezy Group Ltd, who are an online grocery delivery service and I have received your representation to my client’s application for a premises licence for a fulfilment centre at Units 4 & 5, Brook Lane Business Centre, Brook Lane North, Brentford. As the Council’s Licensing Officer may have confirmed to you, if representations remain unresolved, a hearing in respect of this application will be scheduled where parties will be requested to attend. By way of background, my Client, Weezy Group Ltd, is an experienced operator of a number of fulfilment centres across London (and other locations within the country) delivering grocery shopping directly to local customers. They have a good track record of successfully operating whilst continuing to promote the licensing objectives at these sites. Weezy operate in a similar way to other supermarket delivery providers that operate in your area, where grocery shopping can be ordered online either via a website or app. I have included a link to my client’s website https://weezy.co.uk/ The grocery fulfilment centre will cater solely for local customers within less than 10 or so minutes delivery distance given they aim to deliver groceries within 15 minutes of order. I have attached a copy of the product list, which is an extract to help illustrate that Weezy offers a full range of grocery shopping. Upon the website, the prices of the products are also displayed. Together with grocery shopping (focused on high-quality produce including, locally sourced fruit & veg; bakery; butchers; fishmongers; organic and ‘free from’ products), a selection of alcoholic products will be available to order. This distinguishes the business from a typical ‘off-licence’ or alcohol delivery/ distribution centre because it is not exclusively for sale of alcohol and predominantly non-alcohol led because the grocery shopping is higher than demand for the alcohol. The premises will operate as a delivery only business. The premises will not open to the public and will be used for the dispatch of shopping. There shall be no collection of shopping, including alcohol, by the public from the premises. In terms of deliveries, unlike with some other similar businesses, the shopping is delivered by employees who work within the fulfilment centre. When they are not delivering shopping, they are stocking shelves and packing orders. My client does not use third-party couriers to deliver the shopping. I would also like to take this opportunity to clarify changes to our application and address the points raised in your representation. Changes to the Application - reduced hours & additional conditions I attach the original application and plan for your reference. Firstly, taking on board your concerns, we have significantly reduced the terminal hours applied for sale of alcohol off the premises in our application to midnight, so that hours are: 7am - midnight - Monday to Sunday. These hours are in line with other online grocery retailers who deliver in the area.

Further to this, my client is willing to agree these additional conditions which, if the application is granted to the hours now sought, will attach to the licence:

1. The premises will encourage all riders involved in deliveries to use their vehicles in a responsible manner so as not to cause a nuisance to any residents or generally gather outside the premises; not to leave engines running when the vehicles are parked; and not to obstruct the highway.

2. Prominent, clear, and legible notices must be displayed at all exits requesting staff to

respect the needs of local residents and to leave the premises quietly. Addressing your concerns I understand your primary concerns surround public nuisance (noise and pollution) as a result of the grant of the application, in particular due to the late hours proposed. We hope the significantly reduced hours now proposed and additional conditions offered go some way to alleviate those concerns. With regard to the midnight terminal hour now sought for sale of alcohol, my client has significant experience operating to this hour and later at other sites across London (and the country) whilst continuing to promote the licensing objectives, many of which, given the business model, are in close proximity to residents. Furthermore, I understand that there are already existing online grocery delivery businesses within the area that operate to the same and/or similar hours and therefore this permission sought would not be unprecedented. We wish to assure you that my client has training, policies, and procedures in place to ensure the premises operates at a high standard and promotes the Licensing Objectives. This includes an Alcohol Delivery & Age Verification Policy, which is a central document adapted to the needs of the individual site as required. I attach a copy of this for your reference and please note these robust policies will be in place should the application be granted. In terms of measures to mitigate nuisance (noise/ pollution) from deliveries I can assure you that my client's staff use electric bikes/ mopeds, these are quiet and 'green'. Furthermore, staff undertaking deliveries are encouraged to avoid waiting outside the premises unnecessarily or loitering or chatting outside the premises unnecessarily. I note concerns have also been raised as to delivery drivers, parking and associated traffic which is not strictly a licensing consideration. Parking and driving/ riding by staff falls outside of the remit and responsibility of the licence holder and rests with the individual driver of the vehicle. Notwithstanding this, my client has offered additional conditions around drivers using their vehicles in a responsible manner. Additionally, my client can give further assurances that all drivers are made aware of the need to be aware of the local parking regulations and to abide by all traffic laws, regulations, rules as well as policies and any further guidelines that may be issued by the business. My client can assure you that the online system restricts service to customers located in the local area effectively less than 10 minutes delivery distance away. This is the intended market- the local community. Alcohol is not delivered to public places and a condition to this effect has already been offered. With regard to concerns as to underage sales, as mentioned my client has a robust Age Verification policy in place, alongside procedures and staff training to prevent underage and proxy sales. My client operates a Think 25 policy whereby on delivery customers who

appear under 25 shall be challenged to provide proof the customer is over 18. Where appropriate ID proof is not provided the delivery will be refused, logged and reported to the store manager. The delivery will also be refused where the delivery person believes there is an illegal proxy sale, the individual appears intoxicated, or they believe the delivery would create or exacerbate a scenario such as an unruly house party. Additional measures are also in place, some of which are conditions within the application, such as all alcohol orders paid via debit/ credit cards only and full order and customer details are taken, and alcohol verification sticker applied to the delivery package to ensure the promotion of licensing objectives, particularly the prevention of crime and disorder and protection of children from harm. As you may be aware, as part of this application the Responsible Authorities including officers from Licensing, Police and Environmental Health, were consulted. They have raised no objection to the application, even in its original form which sought later hours. As guardians of the licensing objectives, if the Police or Council’s Licensing Enforcement or Environmental Health (nuisance) Officer felt the application would undermine the licensing objectives or add to crime and disorder, exacerbate public nuisance, adversely affect public safety or protection of children from harm, I am sure an objection would have been raised. We appreciate, and are keen to ensure, that an appropriate balance is maintained between the legitimate rights of business and those of residents. We sincerely believe that this application, due to the applicants trading model, coupled with the changes to the application detailed above, maintains that appropriate balance and will not undermine the licensing objectives, nor have a significant impact on nuisance within the area. We believe that the premises will be a welcome addition for the local community who wish to order grocery shopping online, and have it delivered. Should you feel reassured by that the amendments to the hours and additional conditions and are happy to withdraw your representation (confirming this to the Council’s licensing team) so we can avoid a hearing in respect of this matter, then please be assured that my client would be happy to continue to liaise with you as to any issues or concerns you may have. If you would like to call me to discuss the proposals in more detail and better understand my client’s operation, then I would be happy to discuss this with you. My contact details are below:

• Email address: I look forward to hearing from you. Kindest Regards. Suraj Desor Suraj Desor | Solicitor

Poppleston Allen