Spearmint Rhino has submitted an application for its sexual entertainment venue licence renewal:
For the opening times of Monday to Sunday 00:00 to 00:00
The deadline for objections is midnight 22nd March. We advise you to email your objections to: email@example.com
The following is a template letter for you to use. Please feel free to adapt it as you wish, however, your objections need to based on the grounds listed in the letter. You also need to add your name and address, although these details should be redacted when your objection is sent to the applicant and shared on the Council’s website.
Please also add any impacts that this venue has to your particular circumstances, especially if you are a local business and/or resident.
Block C, Staniforth Road Depot
I refer to the application for a sexual entertainment venue licence by Spearmint Rhino, 60 Brown Street, Sheffield. S1 2BS.
This is an objection letter to the application for this licence and I call for the council to refuse it.
I believe that the Council should refuse the licence application under the Discretionary Grounds for Refusal of the current Sheffield City Council’s Sexual Entertainment Venues Licensing Policy on the following grounds:
The Public Sector Equality Duty and Gender Equality
Sheffield City Council has “statutory obligations in relation to disability race and gender” ensuring that these factors are not used to discriminate against anyone. I believe that a sexual entertainment venue directly discriminates against women by normalising the sexualisation and objectification of women, and that this contributes to their sexualisation and objectification in other areas of society. The Council has a fundamental and non-delegable role to give due regard to the Public Sector Equality Duty, including tackling gender inequality. This applies notwithstanding the fact that Parliament has legislated to allow the possibility for SEVs to be licensed in specific areas – subject to the choices of the local communities. Many women have voiced their concerns and fears about the presence of Spearmint Rhino in previous objections.
When walking around this area, which as a Council you encourage people to do due to the other businesses and services in the area, women feel nervous because of the SEV and have to change their behaviour because of it being there, for example having to look around to see if there are people coming out of the SEV, take a different route walking to the centre of town so that they do not have to go past the SEV. Women should not have to feel like this in their city and this is discriminatory.
As Philip Kolvin (2010) cites the Royal Town Planning Institute’s Gender and Spatial Planning Good Practice Note:
‘In relation to the 24-hour economy policy, ensure that the views of women are considered. Evidence shows that in certain locations, lap-dancing and exotic dancing club make women feel threatened or uncomfortable’
Kolvin continues with:
‘If a woman, whether objectively justified or not, fears to use part of the town centre characterised by sex establishments, this may be argued to amount to discrimination, in that her access to the public infrastructure of the town is impaired in comparison to that of men. Where relevant these considerations ought properly to be taken into account by authorities at the decision-making stage, and possibly at the policy-making stage’.
This is further corroborated by 2012 research published in Criminal Justice Matters which states that:
‘. . . the women describe feeling frightened, disempowered, violated, embarrassed, unsafe (particularly if men are around) and avoid certain streets at night where they know there is a lap dancing club.’
In its current policy, the Council states:
“Whilst the Council has not imposed a numerical limit on the number of premises that may be licensed in any area, and whilst it will treat each application upon its own merits, the Council will not licence premises that it feels are in close proximity to:-
a) a school, nursery or other premises substantially used by or for children under 16 years of age;
There are many educational establishments in the vicinity and Brown Street is also an access route to the Sheffield College Granville Road campus and UTC. It is in close proximity to Freeman College which provides education for students (16 – 25) who have a range of complex learning, mental health and behavioural needs.
The Club is also in the centre of the newly designated “knowledge gateway”.
b) a park or other recreational area used by or for children under 16 years of age;
There is the much underused recreational space (formerly known as Festival Square but now named as Cultural Industries Quarter Square on the map of the area which can be found on Sheaf Square) directly adjacent to the club. The Club’s presence deters many from using that space to its full potential.
c) a church or other place of religious worship;
Christ Church Central operates from the Workstation and runs a weekly service.
d) a Hospital, Mental Incapacity or Disability Centre or similar premises;
There are a number of charities and organisations in the area which support vulnerable children and adults, some of which cannot be named because of their confidential addresses. However, we are aware that the Council knows which organisations we are referring to
e) the Cultural Hub of the City (i.e. close to the Peace Gardens and Tudor Square etc.); and/or
f) a central gateway to the city or other city landmark, historic building or tourist attraction.
It is directly opposite the Showroom cinema which hosts family events. It is also opposite the Site Gallery which is undergoing a huge expansion. Spearmint Rhino is also centrally located in terms of proximity to a number of national and international events locations, as well as a direct access route, for example: Doc Fest; the children’s media conference; Off the Shelf etc.
There are young students surrounding the area. The Club is next to Sheffield Hallam Students Union and directly backs onto student accommodation.
Additional grounds for refusal
This image of a high-end establishment portrayed by this SEV goes in some way to normalising this type of venue in a very active part of the city, and as such giving the impression that Sheffield as a city condones both the sexualisation and objectification of women, which is in complete contradiction to the Council’s equality policies. The Spearmint Rhino logo is internationally recognised and is synonymous with stripping and the sexual availability and objectification of women. Renewing a licence would be contradictory to other work that the Council does, funds and promotes. Has the Council for example, as per its own policy, carried out an Equality Impact Assessment?
A sexual entertainment venue in the heart of the city, or anywhere in the city, is simply completely contradictory to everything that the council says it stands for, everything that the council should stand for, and has a duty to work towards.
I will fully and actively support the Council in the face of any challenge to the council by giving a refusal.
The Council is asked to note that in the last few years Leeds City Council successfully defended a refusal to renew two SEV licenses at judicial review:
R (Bean Trading A Ltd) v Leeds City Council (2014)
It was held that a council can “take a fresh look” despite no changes to the character of locality. The Council is also asked to note the following from Philip Kolvin regarding licence renewal:
‘Given that there is potential for the discretion to be exercised afresh, the renewal should not just be a rubber stamping exercise, but an opportunity, if needed, to review the principle and content of the license.’
The case of Thompson v Oxford City Council (2014) was also supported at court of appeal, and the Council told they could “take a fresh look” at any application for renewal.
If the panel feel that they cannot make a refusal decision without further discussion, I would ask that a hearing is held so that the application can be discussed in more detail.
I look forward to hearing from you.
Insert name and address
 Kolvin, P (2010) Sex Licensing, The Institute of Licensing p.87
 Patiniotis, J. & Standing, K. (2012) ‘License to cause harm? Sex entertainment venues and women’s sense of safety in inner city centres’ in Criminal Justice Matters, 88:1, 10-12.
 Kolvin, P (2010) Sex Licensing, The Institute of Licensing p.87
 p. 90