Immigration New Zealand have announced that more Accredited Employer Work Visa (AEWV) applicants can receive Interim Visas that allow them to work in New Zealand if their visa expires while INZ are assessing their application.

To be eligible, the applicant must hold either a work visa or a student visa that allows them to work during term time, have applied for an AEWV and receive their Interim Visa on or after 8 April, 2025. Their Interim Visa will allow them to work for the accredited employer and the job specified in their AEWV application, enabling them to move into their job more quickly.

Interim Visas are usually granted automatically to eligible customers. If a migrant receives an Interim Visa, they can show employers their visa letter, which will say whether they can work and what conditions apply.

Please note:

• Interim Visa conditions are not shown when checking a migrant’s work rights using VisaView.
• If the applicant intends to apply for a Work to Residence Visa, time spent working on the Interim Visa can count towards their New Zealand work experience requirements.

March 2025

Rotorua Lakes Council

1061 Haupapa Street

Rotorua 3010

Introduction

The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to submit on the Rotorua Lakes Council’s Local Alcohol Policy Review 2025. Since 1972, the Restaurant Association has worked to offer advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people.

Rotorua Lakes Council proposal

The Restaurant Association’s priority for Local Alcohol Policies is to ensure that they accurately reflect the different levels of harm from off- and on- licence venues, and the potential impact of LAPs to those in our sector who operate on-licence venues and are already heavily regulated by the conditions of holding such a licence. We are not opposed to those trading conditions – in fact, we see them as commonsense rules which ensure the safe and responsible sale and supply of alcohol. While our more than 2,500-strong membership is made up of hospitality businesses where food is the hero of their operations, many offer alcohol beverages as a supplement to the culinary experience they provide.

In a practical sense, there are far fewer restrictions and regulations for off-licence holders in terms of the responsible sale and supply of alcohol when compared to on-licence holders. For example, when serving alcohol in an on-licence venue, staff must monitor intake and determine when they must stop service to prevent intoxication.

Alternatively at an off-licence venue, customers can purchase as much alcohol as they want, to take home and then consume as much as they want without any concerns. It is clear that a large part of enabling that problem comes from the proliferation of off-licence venues, and those on-licence venues whose primary business is not food.

The Rotorua Lakes Council proposals generally reflect this sentiment, with most of the changes only applying to off-license venues. The Restaurant Association believes the status quo should remain for all on-licence policy options. The Restaurant Association’s views on each of the Council’s proposals are detailed below. 

On-licence trading hours within the Inner City and ‘Eat Streat’

Compared to international standards, New Zealanders traditionally eat dinner and go to bed earlier than many countries around the world. As an industry – and a region – that relies heavily on international tourism to thrive, our hospitality businesses in Rotorua need to be able to make operating decisions that service a wide variety of customer preferences – from the regular who lives down the road, to the group of friends visiting from overseas who are looking for somewhere to sit down for dinner at 10pm.

We’re proud of the contribution our businesses make to our vibrant towns, cities and communities – but we need policy settings to enable that to continue. As such, we recommend that any hours of trade are set by specific licence type – rather than a broad on-licence versus off-licence categorisation – to enable low-risk restaurants to service an increasing number of tourists looking to dine out later in the evening.

We recognise that the proposed 2am on-licence restriction may be appropriate for night clubs, however we submit that greater flexibility is needed for venues such as Class 3 restaurants with an on-licence, and submit that flexibility around classes of specific on-licence types is aligned with the weighting and times specified in section 5(4) of the Sale and Supply of Alcohol (Fees) Regulations 2013.

New on-licence and off-licence location in proximity to sensitive facilities

Decisions regarding restrictions on proximity to sensitive sites should be evidence-based rather than based on intuition or speculation about what could reduce alcohol-related harm. It is the Restaurant Association’s position that any proximity restrictions should be considered on a case by case basis, in particular taking into account:

• The type of licence being applied for (e.g. a Class 3 Restaurant on-licence vs bottle store off-licence)
• How long a business has been operating (e.g. if an ECE or school decides to open near a licensed venue, knowing they will be near a licensed venue, the licensee should not be penalised when they come to renewing their licence).

The Restaurant Association agrees that the policy for new on-licence locations in proximity to sensitive facilities should remain as is.

Off-licence density

While our preferred option would be the status quo, if the Council does implement a temporary freeze on new licence applications, the Restaurant Association believes this should not be implemented as a blanket freeze – rather, it should only apply to certain licence types. 

It is our position that the risk from on-licence restaurants and cafes is significantly lower than that of off-license outlets (or even other on-licences, such as night clubs). The Council should not deter restaurants and cafes from investing in high deprivation communities which is likely to occur if they are unable to obtain an on-licence. This aligns with the Council’s proposal to implement a temporary freeze for 3 years on the issue of off-licences and a presumption against granting off-licences thereafter.

Discretionary conditions

The Restaurant Association would also like to take this opportunity to highlight our other priorities for local alcohol policies:

• Modernising approaches to Restaurant licensing
• Conditions relating to minimum numbers of qualified managers 
• Renewal of licences

Modernising approaches to Restaurant licensing

There is a risk of LAPs impacting the food and beverage sector of hospitality by regulating through broad “on-licence” and “off-licence” categorisation, and we submit there is a need to consider the differing risks posed by sub-class of licences.

We would like to see LAPs be more specific, where for example, when considering any kind of restriction or regulation (such as one way door policies, proximity and density rules or time of sale restrictions), that conditions be set by specific license type, rather than taking a blanket on licence or off-licence approach to regulation.

Conditions relating to minimum numbers of qualified managers

Some Councils have adopted (or are looking to adopt) a discretionary condition whereby the DLC and ARLA are recommended to consider imposing conditions that specify a minimum number of certified managers be present onsite, if appropriate for large capacity premises at peak times. The exact number would depend on the layout, use and capacity of the premises.

This condition fails to recognise the current cost and administrative burden associated with becoming a licensed manager, with those barriers often imposed by the DLC and ARLA themselves. We do not support the imposition of minimum numbers of certified managers without first reforming restrictions around who can hold a managers’ licence, to ensure that we have the appropriately certified workforce available.

Renewal of licences

There is no reason that a licence renewal should be as cumbersome as a new licence application, yet both applicants and councils are facing significant administrative burdens for every licence renewal. The Restaurant Association recommends the Council consider adopting third-party accreditation programmes, such as HospoCred, to streamline application and renewal processes for hospitality businesses.

This could be utilised in conjunction with current council processes: by checking whether any complaints or infringements have been recorded against an applicant in the Council’s own database, and then utilising the comprehensive vetting and benchmarking offered by the HospoCred accreditation programme, local and central governments can streamline workflows, reduce costs, and build stronger partnerships with the hospitality industry.

Conclusion

Thank you for the opportunity to provide feedback on your draft local alcohol policy. We would be happy to discuss any part of this submission in more detail, and to provide any assistance that you may require.

March 2025

Background

Auckland Council are seeking feedback on their proposals for Auckland’s Annual Plan 2025/2026 (annual budget). The annual plan is due to take effect on 1 July 2025 and sets out what the Council plans to achieve over the next financial year and how they will fund these plans.

The consultation seeks feedback on the overall plan, destination management and major events and changes to other rates, fees and charges. There are seven areas of council activities, or investment, that the Council have highlighted what they are planning to deliver under; transport, water, built environment, natural environment, community, economic and cultural development, and well-managed local government. The areas of relevance for the Restaurant Association are built environment, community and economic and cultural development. 

Survey Questions 

Question 1: Overall plan

The proposed Annual Plan 2025/2026 builds on the Council’s Long-term Plan 2024-2034 (LTP). The annual plan focuses on getting on with strengthening the financial and physical resilience of Auckland, while investing where it is needed most to manage growth. In 2025/2026, that includes prioritising investment in:

• transport
• water
• and fairer funding for local communities

It sets out the proposed way to pay for services and investments, including the 5.8 per cent rates increase for the average value residential property which is in line with the LTP, and additional debt to fund $4 billion of capital expenditure.

What is your opinion on our proposed annual plan?

• Support most 

Tell us why 

Since 1972, the Restaurant Association has worked to offer advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people. We are supportive of the overall vision for Auckland to create a stunning natural environment, an efficient transport system and development pattern, decent and affordable public services, amenities, and infrastructure, a diverse and dynamic city, and a thriving economy that supports growth and opportunities for all.

For the seven areas of council activities, or investment, that contribute to the vision for Auckland, we mostly support the following actions:

• Facilitate international and domestic events, including musicals, concerts and exhibitions.
• Work with central government on new funding tools for visitor attraction and economic development, including exploring a bed night visitor levy for major events and destination marketing. 
• Continue to deliver iconic cultural events such as Pasifika, Diwali and the Lantern Festival. 
• Progress a local board led plan for the North Harbour Stadium.
• Boost community safety with initiatives such as safety hubs in the city centre and compliance wardens to fill the gaps in safety across the city.
• Progress city centre works including Te Hā Noa – Victoria Street to maximise the benefits of City Rail Link opening. 
• Progress a masterplan to develop the central wharves into a public space, and aligning cruise facilities and ferry services with Port of Auckland Limited operations.
• Continue to regenerate our neighbourhoods in key areas such as Wynyard Quarter, City Centre, Takapuna, Northcote, Henderson, Avondale, Manukau.

Events are a prime opportunity to stimulate our industry, hospitality. With the success of events like the ASB Classic, we want to see more large scale events in Auckland to help strengthen our regional and national tourism and hospitality brand. Events not only bring tourists to the country, but they also importantly bring out locals – something we want to encourage; dependence on tourism can only get us so far, but for many of our businesses locals are their bread and butter.

There is a clear need for infrastructure improvements in Auckland, and infrastructure disruptions across our city impact vital commercial activities. As cities embark on infrastructure projects aimed at long-term improvements, the immediate and severe effects on local businesses, particularly in hospitality, call for a more supportive approach from councils.

There is a critical need for councils to work more collaboratively with businesses impacted by infrastructure developments. Proactive measures from city councils could significantly alleviate the impact of infrastructure changes on local businesses. One effective strategy would involve councils engaging with businesses right from the early planning stages of infrastructure projects and maintaining open lines of communication throughout the construction phase. Knowing the timeline and scope of potential disruptions enables businesses to plan and adjust their strategies effectively.

Additionally, councils could provide financial relief through temporary tax breaks, grants, or subsidies. This financial support would offer businesses struggling with cash flow disruptions a much-needed buffer. Offering incentives to encourage patronage in affected areas could also help sustain business operations during challenging periods.

Marketing and promotional initiatives play a crucial role as well. By partnering with local business associations, councils can help launch campaigns that highlight that businesses remain operational despite nearby construction. Hosting events, providing promotions, and enhancing signage could dispel the notion that construction areas are inaccessible, thereby attracting customers who might otherwise avoid the area.

Improving access and signage around construction sites is another critical measure. Clear, well-placed signage directing customers to alternative routes and entrances can significantly ease the access challenges posed by construction, helping to maintain or even increase foot traffic. Temporary parking solutions or shuttle services could also be offered to mitigate the inconvenience caused by ongoing construction works.

Finally, establishing a robust feedback loop where businesses can promptly report issues and receive quick responses can dramatically improve the situation. This mechanism allows councils to address problems as they arise, preventing them from escalating and further affecting the businesses.

We have long advocated for the implementation of comprehensive safety measures to protect our member’s establishments, staff and customers so we are pleased to hear that Council will be boosting community safety with initiatives such as safety hubs in the city centre and compliance wardens to fill the gaps in safety across the city. Many of our members believe that the lack of adequate police resources – particularly in Auckland’s city centre – has emboldened criminals, creating an environment where illegal activities can flourish unchecked. This under-resourcing has led to a perceived decline in law enforcement presence and response, exacerbating the issue. 

Question 2: Destination management and major events

Attracting visitors and securing, promoting and delivering major events are vital to Auckland being a dynamic and exciting city. In the Long-term Plan 2024-2034, Council said they would continue to fund cultural festivals and other significant community events. However, without a bed night visitor levy, there will be a $7 million budget shortfall for funding of major events that are expected to attract visitor expenditure, such as the ASB Classic, Auckland Marathon and Auckland Writers Festival, from the 2025/2026 financial year. 

Council continue to advocate to central government to introduce this levy. A bed night visitor levy of 2.5 per cent to 3 per cent paid by those in short-stay accommodation, would raise around $27 million each year to fund even more destination management, marketing and major events activities in Auckland. 

A bed night visitor levy requires central government legislative change and they have yet to agree to introduce this legislation. 

Do you support a bed night visitor levy paid by those in short-stay commercial accommodation, to fund destination management, marketing and major events activities?

• Other 

Tell us why 

As mentioned in our answer to the previous question, the Restaurant Association has long advocated the importance of attracting visitors and securing, promoting, and delivering major events, as well as the need for adequate funding to deliver these events. While we agree that event attraction and destination marketing need more funding, we do not think a bed night visitor levy paid by those in short-stay commercial accommodation is the best way to fund this investment. 

The Restaurant Association is not against the idea of a bed night visitor levy, however, if it was to be implemented, it should be applied to all of New Zealand. There needs to be an end to the three-way tourism funding deadlock between industry, central government and local government.

The $7 million budget shortfall that is said to occur if a bed night visitor levy is not put in place can simply be funded through re-prioritising Council spending and investment. The amount of funding that Auckland Council currently provides for event attraction is a very small amount of their total revenue. The Restaurant Association believes that the economic benefits of investing in major events attraction should be enough of an incentive to reprioritise spending and investment. 

Question 3: Changes to other rates, fees and charges

Would you like to comment on this or the other rates, fees and charges proposals? (Please be clear which proposal you are talking about). 

The Restaurant Association would like to provide feedback on the proposed overall rates increase of 6.8% for business properties. We do not believe that lower growth in the value of business properties compared to non-business properties is an adequate reason to increase business rates by a higher percentage than residential rates. 

Further, we believe that as the number of non-business properties grows (and we believe this is happening at a faster rate than the growth in number of business properties), it will not be feasible to retain the 31 percent share of rates paid by business properties. The Council should review this share of rates, and create a formula that enables a fair calculation of rate share and setting of rates, based on the proportion of business to non-business properties across the city.

Question 4: Local board priorities

Which local board(s) would you like to provide feedback on?

• None of the above

March 2025

Commerce Commission
PO Box 2351
Wellington 6140
New Zealand

Tēnā koe,

Restaurant Association of New Zealand submission on the Commerce Commission’s Draft Decision and Reasons Paper on Interchange fee regulation for Mastercard and Visa networks

The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to submit on the Commerce Commission’s dra decision and reasons paper on interchange fee regulation for Mastercard and Visa networks.

Since 1972, the Restaurant Association has worked to offer advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people.

The Restaurant Association’s priority for reforms to New Zealand’s retail payment system is to ensure the system is as simple as possible to understand for those on the frontline of our retail sector – in particular, the merchant and the customer – to ensure that all parties are paying a fee that is fair and reasonable.

In that vein, we commend the Commission for their dra interchange fee caps of 0.20% for all cards across contacted and contactless payments, except foreign issued cards which have a dra cap of 0.60% for both payment types. This consistency will help businesses – particularly small businesses – to more easily understand what they are being charged to accept payments, and more accurately forecast their anticipated costs.

We reiterate that more education is needed for consumers and the general public to understand why surcharging exists, so merchants can focus on their business instead of filling this education gap. There is still an underlying perception among consumers that surcharges are a way for businesses to swindle their customers, and we believe this will only be exacerbated should the final decision of the Commission be to reduce interchange fees without a careful, easy to understand communications effort that explains how these interchange and merchant service fees flow through to consumers.

We also recognise the next stage in this piece of work may include exploring options to regulate the level of surcharges charged by a retailer or merchant. We are supportive of this step, however we recommend that this work takes place no earlier than Q1 2027, to allow at least twelve months for businesses to experience a full trading year under the new level of interchange fees (based on Figure 1.3 in the Draft Decision and Reasons Paper) and collect a more accurate range of data to inform levels of surcharging to cover their costs.

Should the Commission initiate work to regulate surcharges, this should not be initiated without having developed clear guidance for businesses. As many have agreed through the first stage of consultation, the current level of merchant service fees paid by businesses are confusing – with many businesses having to estimate a surcharge fee to cover their costs of accepting payments. This estimate is based on their best assessment of the fees they incur, and it will take time and assistance to transition to a new fee structure, and any enforcement model should recognise the difference between a large business that has access to corporate support staff which surcharges 4% over what would be considered reasonable under the new system, and a small business run by owner/operator who mistakenly charges 0.5% over what would be considered reasonable.

Finally, we recognise that interchange fees are only one portion of merchant service fees, and we reiterate that there must be a regulatory framework that ensures accountability and transparency on the part of financial institutions.

Conclusion

Thank you for the opportunity to provide feedback on your dra decision and reasons paper. We would be happy to discuss any part of this submission in more detail, and to provide any assistance that you may require.

March 2025

Porirua City Council
PO Box 50218
Porirua 5240
New Zealand

Introduction

The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to submit on the Porirua City Council’s review of its 2017 Local Alcohol Policy and new draft Local Alcohol Policy.

Since 1972, the Restaurant Association has worked to off er advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people.

The Restaurant Association’s priorities for local alcohol policies include:

• Differing licence risk profiles
• Modernising approaches to Restaurant licensing
• Restrictions on the number and location of licensees
• Conditions relating to minimum numbers of qualified managers
• Renewal of licences
• Hours of trade

Differing licence risk profiles

Our priority for Local Alcohol Policies is to ensure that they accurately reflect the diff erent levels of harm rom off – and on- licence venues, and the potential impact of LAPs to those in our sector who operate on-licence venues and are already heavily regulated by the conditions of holding such a licence.

We are not opposed to those trading conditions – in fact, we see them as commonsense rules which ensure the safe and responsible sale and supply of alcohol. While our more than 2,500-strong membership is made up of hospitality businesses where food is the hero of their operations, many off er alcohol beverages as a supplement to the culinary experience they provide.

In a practical sense, there are far fewer restrictions and regulations for off -licence holders in terms of the responsible sale and supply of alcohol when compared to on-licence holders. For example, when serving alcohol in an on-licence venue, staff must monitor intake and determine when they must stop service to prevent intoxication.

Alternatively at an off -licence venue, customers can purchase as much alcohol as they want, to take home and then consume as much as they want without any concerns. It is clear that a large part of enabling that problem comes from the proliferation of off -licence venues, and those on-licence venues whose primary business is not food.

Modernising approaches to Restaurant licensing

There is a risk of LAPs impacting the food and beverage sector of hospitality by regulating through broad “on-licence” and “off -licence” categorisation, and we submit there is a need to consider the diff ering risks posed by sub-class of licences.

We would like to see LAPs be more specific, where for example, when considering any kind of restriction or regulation (such as one way door policies, proximity and density rules or time of sale restrictions), that conditions be set by specific license type, rather than taking a blanket on licence or off -licence approach to regulation.

Restrictions on the number and location of licensees

Decisions regarding restrictions on proximity to sensitive sites should be evidence-based rather than based on intuition or speculation about what could reduce alcohol-related harm. It is the Restaurant Association’s position that any proximity restrictions should be considered on a case by case basis, in particular taking into account:

• The type of licence being applied for (e.g. a Class 3 Restaurant on-licence vs bottle store off -licence)
• How long a business has been operating (e.g. if an ECE or school decides to open near a licensed venue, knowing they will be near a licensed venue, the licensee should not be penalised when they come to renewing their licence).

If the Council did implement a temporary freeze on new licence applications, the Restaurant Association believes this should not be implemented as a blanket freeze – rather, it should only apply to certain licence types. It is our position that the risk from on-licence restaurants and cafes is significantly lower than that of off -license outlets (or even other on-licences, such as night clubs). The Council should not deter restaurants and cafes from investing in high deprivation communities which is likely to occur if they are unable to obtain an on-licence.

Conditions relating to minimum numbers of qualified managers

Some Councils have adopted (or are looking to adopt) a discretionary condition whereby the DLC and ARLA are recommended to consider imposing conditions that specify a minimum number of certified managers be present onsite, if appropriate for large capacity premises at peak times. The exact number would depend on the layout, use and capacity of the premises.

This condition fails to recognise the current cost and administrative burden associated with becoming a licensed manager, with those barriers often imposed by the DLC and ARLA themselves. We do not support the imposition of minimum numbers of certified managers without first reforming restrictions around who can hold a managers’ licence, to ensure that we have the appropriately certified workforce available.

Renewal of licences

There is no reason that a licence renewal should be as cumbersome as a new licence application, yet both applicants and councils are facing significant administrative burdens for every licence renewal.

Restaurant Association recommends the Council consider adopting third-party accreditation programmes, such as HospoCred, to streamline application and renewal processes for hospitality businesses.

This could be utilised in conjunction with current council processes: by checking whether any complaints or infringements have been recorded against an applicant in the Council’s own database, and then utilising the comprehensive vetting and benchmarking off ered by the HospoCred accreditation programme, local and central governments can streamline workflows, reduce costs, and build stronger partnerships with the hospitality industry.

Hours of trade

Compared to international standards, New Zealanders traditionally eat dinner and go to bed earlier than many countries around the world. As an industry that relies heavily on international tourism to thrive, our hospitality businesses need to be able to make operating decisions that service a wide variety of customer preferences – from the regular who lives down the road, to the group of friends visiting from overseas who are looking for somewhere to sit down for dinner at 10pm.

We’re proud of the contribution our businesses make to our vibrant towns, cities and communities – but we need policy settings to enable that to continue. As such, we recommend that any hours of trade are set by specific licence type, to enable those low-risk restaurants to service an increasing number of tourists looking to eat later in the evening than what we would consider usual.

Conclusion

Thank you for the opportunity to provide feedback on your draft local alcohol policy. We would be happy to discuss any part of this submission in more detail, and to provide any assistance that you may require.

March 2025

Background

The Christchurch City Council are testing some ideas that could be included in a draft Local Alcohol Policy for Christchurch and Banks Peninsula. In 2024, Christchurch City Council began to work towards development of a LAP for Christchurch and Banks Peninsula by gathering data and completing a research report. The research report identified that alcohol-related harm is occurring in some of their communities.

From this research, discussions with stakeholders, and community feedback, Christchurch City Council have identified five possible options for conditions and rules that an LAP could include. They are testing and refining these options before they draft an LAP to consult on.

The options

• Reducing trading hours for off-licence outlets at night 
• Reducing trading hours for on-licence venues in suburban areas at night 
• Placing a temporary freeze on new licensed venues and outlets in high deprivation areas 
• Restricting new licensed venues and outlets from being located near sensitive community facilities 
• Introducing a one-way door restriction for venues near closing time
• Other mechanisms to help reduce alcohol harm 

Survey Questions 

 Reducing trading hours for off-licence outlets at night

The current latest closing time for off-licence outlets is 11pm. The Council are considering whether to reduce that to an earlier time and, if they did, whether it should be applied to all outlet types (bottle stores, supermarkets, wineries and small convenience stores) or only some. Remote (online) sellers would be exempt. Currently, only 54 of the city’s 256 off-licenced outlets hold licences requiring them to close by 9pm, 72 are allowed to sell alcohol until 10pm and 105 can sell alcohol until 11pm.

How much do you agree or disagree that Council should reduce trading hours for off licenced outlets across the city and Banks Peninsula?

• Neither agree or disagree

If we did reduce hours in the evening, what time do you think off-licences should stop selling alcohol each day? Please select a time for each type of outlet.

• Bottle store – Don’t know
• Supermarket – Don’t know
• Small grocery stores – Don’t know
• Working men’s clubs – Don’t know
• Wineries – Don’t know
• Specialty stores – Don’t know

Why did you choose those times? 

The Restaurant Association strongly support the Christchurch City Council’s goal of reducing alcohol-related harm however, there is no evidence from any Council that reducing trading hours for off-licence outlets or on-licence venues reduces alcohol-related harm. We believe that any decisions regarding reducing trading hours should be evidence-based rather than intuition-based or speculative about what could reduce alcohol-related harm. 

Reducing trading hours for on-licence venues in suburban areas at night 

The Council are considering setting a reduced maximum trading time for on-licenced venues in suburban areas (outside of the city’s four avenues). They are excluding the central city from this potential reduced maximum trading time as they identified in their district plan that they want to encourage a vibrant central city. Licensing data indicates that if the Council were to include a reduction of trading hours to 1am in suburban areas, 78 (16%) of the 487 on-licence venues operating outside of the city centre could be affected by this option.

How much do you agree or disagree that Council should reduce the latest closing time for on-licenced venues in suburban areas?

• Strongly disagree

If we did reduce the latest closing time for on-licenced venues in suburban areas, what time do you think they should stop selling alcohol? Please select a time for each type of venue.

• Nightclubs – 4am
• Pub/tavern – 4am
• Restaurants – 4am
• Cafes – 4am
• Sports clubs – 4am
• Working men’s Clubs – 4am

Why did you choose those times? 

We would like to reiterate that the Restaurant Association strongly supports the Christchurch City Council’s goal of reducing alcohol-related harm, however there is no evidence from any Council that reducing trading hours for off-licence outlets or on-licence venues reduces alcohol-related harm. 

We strongly disagree that Council should reduce the latest closing time for on-licenced venues in suburban areas for the following reasons:

• The risk of on-licenced venues, in particular restaurants and cafes, is significantly lower than that of off-license outlets for contributing to alcohol-related harm. 
• Reducing the latest closing time for on-licenced venues in suburban areas creates a disadvantage for suburban businesses that are already struggling in the current economic climate. 
• The Council have stated that there would be a limited impact as most on-licensed premises in suburban areas are not open until 4am currently. If there will only be a limited impact, we support keeping with the current Sale and Supply of Alcohol Act conditions that allow trading until 4 am. 
• On-licence venues typically close earlier than those in other countries, which can lead to disappointment for tourists who are expecting late-night options. Servicing tourists should be considered when deciding to reduce the latest closing time for on-licenced venues, as this may negatively impact international visitors and the hospitality industry. 

If the Council did reduce the latest closing time for on-licenced venues in suburban areas we would advocate for restaurants and cafes to be excluded from these changes based on the low-risk they pose to alcohol-related harm. Our more than 2,500-strong membership is made up of hospitality businesses where food is the hero of their operations, with alcoholic beverages offered as a supplement to their culinary experience.

Placing a temporary freeze on new licensed venues and outlets in high deprivation areas

The Council are considering a temporary freeze on new licence applications for any new venues and outlets in high deprivation areas (locations that have a score of 9 or 10 on the New Zealand deprivation index) for three years. Existing venues and outlets could still be able to renew their licence and if they changed ownership, the new owner could still obtain a new licence. 

How much do you agree or disagree that Council should include a temporary freeze on new licences in high deprivation areas?

• Strongly disagree

If we did include a temporary freeze on new licences in high deprivation areas, which of the following venues and outlets do you think a temporary freeze should apply to? Select all that apply.

• Don’t know 

Is there anything else you would like to tell us about how a freeze could be applied?

If the Council did implement a temporary freeze on new licence applications, the Restaurant Association believes this should not be implemented as a blanket freeze – rather, it should only apply to certain licence types. It is our position that the risk from on-licence restaurants and cafes is significantly lower than that of off-license outlets (or even other on-licences, such as night clubs). The Council should not deter restaurants and cafes from investing in high deprivation communities which is likely to occur if they are unable to obtain an on-licence. 

Restricting new licensed venues and outlets from being located near sensitive community facilities 

The Council are considering if restrictions should apply on how close a licenced venue or outlet is located to sensitive community facilities. 

How much do you agree or disagree that Council should consider including a restriction on how close new licenced venues and outlets can be located to community facilities considered sensitive?

• Don’t know

If we did restrict new licensed venues and outlets being located near community facilities, which of the following do you think should be considered sensitive? Select all that apply.

• Don’t know 

If yes to any of the above, Which of the following licenced venues and outlets do you think should be restricted from being close to [community facility]? Select all that apply.

• don’t know 

If we did restrict new licensed venues and outlets being located near community facilities, how far away should a licensed venue or outlet be located from community facility that is deemed a sensitive site?

• 50 metres

Why do you think none of the facilities listed should be considered ‘sensitive’? 

Decisions regarding restrictions on proximity to sensitive sites should be evidence-based rather than based on intuition or speculation about what could reduce alcohol-related harm. It is the Restaurant Association’s position that any proximity restrictions should be considered on a case by case basis, in particular taking into account:

• The type of licence being applied for (e.g. a Class 3 Restaurant on-licence vs bottle store off-licence)
• How long a business has been operating (e.g. if an ECE or school decides to open near a licensed venue, knowing they will be near a licensed venue, the licensee should not be penalised when they come to renewing their licence).

Introducing a one-way door restriction for venues near closing time

The Council are considering if the LAP should apply a one-way door restriction for all on-licence venues. Licensing data indicates that if we did put a one-way door restriction in place at 2am, 101 venues could be affected, – 63 in the central city and 37 in suburban areas. If a reduction in trading hours for on-licence venues in suburban areas was implemented, any one-way door restriction would only apply to venues in the central city. 

Do you think we should include a one-way door restriction across the city?

• No  

If a one-way door restriction was introduced, what time do you think it should be in place?

• N/A

Why do you not agree with or are unsure about including a one way door restriction across the city?

The Restaurant Association agree with the Council’s aim to address alcohol-related harm by encouraging people who are drinking late into the night to consume alcohol in supervised environments; however, there is no conclusive research about whether one-way door policies work to reduce harm. 

Other mechanisms to help reduce alcohol harm

Are there any other mechanisms you think Council should consider developing instead of or in addition to a LAP to help reduce alcohol related harm? 

Is there anything else you would like to tell us about development of a Local Alcohol Policy. 

Since 1972, the Restaurant Association has worked to offer advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people. The Restaurant Association’s priorities for local alcohol policies are as follows. 

Differing licence risk profiles: Our priority for Local Alcohol Policies is to ensure that they accurately reflect the different levels of harm from off- and on- licence venues, and the potential impact of LAPs to those in our sector who operate on-licence venues and are already heavily regulated by the conditions of holding such a licence. We are not opposed to those trading conditions – in fact, we see them as commonsense rules which ensure the safe and responsible sale and supply of alcohol. As mentioned above, while our more than 2,500-strong membership is made up of hospitality businesses where food is the hero of their operations, many offer alcohol beverages as a supplement to the culinary experience they provide. In a practical sense, there are far fewer restrictions and regulations for off-licence holders in terms of the responsible sale and supply of alcohol when compared to on-licence holders. For example, when serving alcohol in an on-licence venue, staff must monitor intake and determine when they must stop service to prevent intoxication. Alternatively at an off-licence venue, customers can purchase as much alcohol as they want, to take home and then consume as much as they want without any concerns. It is clear that a large part of enabling that problem comes from the proliferation of off-licence venues, and those on-licence venues whose primary business is not food.

Modernising approaches to Restaurant licensing: There is a risk of LAPs impacting the food and beverage sector of hospitality by regulating through broad “on-licence” and “off-licence” categorisation, and we submit there is a need to consider the differing risks posed by sub-class of licences. We would like to see LAPs be more specific, where for example, when considering any kind of restriction or regulation (such as one way door policies, proximity and density rules or time of sale restrictions), that conditions be set by specific license type, rather than taking a blanket on licence or off-licence approach to regulation.

Restrictions on the number and location of licensees: Please refer to our answer to ‘Placing a temporary freeze on new licensed venues and outlets in high deprivation areas’ and ‘Restricting new licensed venues and outlets from being located near sensitive community facilities’. 

Conditions relating to minimum numbers of qualified managers: Some Councils have adopted (or are looking to adopt) a discretionary condition whereby the DLC and ARLA are recommended to consider imposing conditions that specify a minimum number of certified managers be present onsite, if appropriate for large capacity premises at peak times. The exact number would depend on the layout, use and capacity of the premises. This condition fails to recognise the current cost and administrative burden associated with becoming a licensed manager, with those barriers often imposed by the DLC and ARLA themselves. We do not support the imposition of minimum numbers of certified managers without first reforming restrictions around who can hold a managers’ licence, to ensure that we have the appropriately certified workforce available.

Renewal of licences: There is no reason that a licence renewal should be as cumbersome as a new licence application, yet both applicants and councils are facing significant administrative burdens for every licence renewal. The Restaurant Association recommends the Council consider adopting third-party accreditation programmes, such as HospoCred, to streamline application and renewal processes for hospitality businesses. This could be utilised in conjunction with current council processes: by checking whether any complaints or infringements have been recorded against an applicant in the Council’s own database, and then utilising the comprehensive vetting and benchmarking offered by the HospoCred accreditation programme, local and central governments can streamline workflows, reduce costs, and build stronger partnerships with the hospitality industry.

Hours of trade: Compared to international standards, New Zealanders traditionally eat dinner and go to bed earlier than many countries around the world. As an industry that relies heavily on international tourism to thrive, our hospitality businesses need to be able to make operating decisions that service a wide variety of customer preferences – from the regular who lives down the road, to the group of friends visiting from overseas who are looking for somewhere to sit down for dinner at 10pm. We’re proud of the contribution our businesses make to our vibrant towns, cities and communities – but we need policy settings to enable that to continue. As such, we recommend that any hours of trade are set by specific licence type, to enable those low-risk restaurants to service an increasing number of tourists looking to eat later in the evening than what we would consider usual.

Thank you for the opportunity to provide feedback on your draft local alcohol policy. We would be happy to discuss any part of this submission in more detail, and to provide any assistance that you may require.

March 2025

Tauranga City Council 

Private Bag 12022

Tauranga 3143

Introduction

The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to submit on the Tauranga City Council’s Draft Alcohol Licensing Fees Bylaw.

Since 1972, the Restaurant Association has worked to offer advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people.

Tauranga City Council proposal

While the Restaurant Association understands the Council’s decision to implement an alcohol licensing fees bylaw, we do not support the Council’s proposed draft bylaw, which sets out indicative fees based on full cost recovery. We understand that no decisions have been made on the timing and level of any potential changes to the fees and would like to highlight our priorities for local alcohol fee bylaws as:

• Retaining a minimum 30% of alcohol licensing costs to be paid for through general rates, in recognition of the benefit of a thriving hospitality industry to local communities, 
• Where fee increases are proposed, ensuring they are phased in over a reasonable timeframe,
• Ensuring Councils are transparent about the cost of alcohol licensing, including which types of licences incur greater costs to the council, and
• Advocating to Central Government for a review of risk ratings set out in legislation.

Public benefit of hospitality

The Restaurant Association submits that all Councils should retain a ratepayer contribution of 30% to alcohol licensing fees, to recognise the contribution of well-managed hospitality venues to the life and economy of communities, and the societal value of having facilities available where people can go to enjoy themselves while drinking safely and responsibly.

Arguments against retaining a ratepayer contribution often cite the user-pays intention of the Act as justification for complete (or almost complete) cost recovery through licensing fees. We submit that ratepayers are part of the user-pays licensing system, and rather than relying on venues to increase prices to cover fee increases, the Council should support access to affordable hospitality for all through its setting of fees.

Phased fee increases

While we recognise that licensing fees were set by legislation 11 years ago, and that Councils across the country need to recover costs, it is our position that businesses should not be hit with such drastic fee increases simply because their local council had not adopted an alcohol fees bylaw sooner. For that reason we recommend that all councils take a more gradual approach to fee increases, by more evenly distributing the cumulative increase over a longer period. Further, we recommend that a cap on annual fee increases be adopted by the Council, limiting annual alcohol licensing fee increases to a maximum of no greater than 15%

Council transparency 

We are concerned that many Councils across the country use cost recovery as a blanket justification for increasing fees across the board, often without any transparency around actual costs incurred by the Council. It is our position that Councils should provide evidence of the actual cost of processing licences as part of their consultation, so licencees can have confidence that the amount being recovered is accurate and fair. This breakdown should also include the difference in cost of processing on-licences compared to off-licences, with a view to recovering costs on a more proportionate basis in the future.

Finally, we would like to see that Councils have sought to improve efficiencies or cut the internal cost of alcohol licences before passing these costs on to licencees. Businesses are not an endless source of funds that can withstand constant levying by local authorities, and we submit that there must be an attempt on behalf of regulatory bodies across the country to build confidence in their activities.

Review of current risk ranking

The Restaurant Association recognises the need to ensure the sale and supply of alcohol is undertaken safely and responsibly. However, we are concerned that the rigid risk rating formula contained in legislation is out of date and no longer matches the realities of modern hospitality environments. It is important that legislation and bylaws recognise there is not only a difference between on- and off-licence venues, but that there is also a difference between types of on-licence venue: for example, both a night club and a restaurant are on-licence venues, but prima facie these businesses have two very different risk profiles.

Our more than 2,500-strong membership is made up of hospitality businesses where food is the hero of their operations, with alcoholic beverages offered as a supplement to their culinary experience. We therefore believe that a more fulsome review of the risk rating of premises within the regulations to better reflect the actual risk of harm. We recognise that the setting of risk ratings is not within the control of this Council, and therefore recommend that the Council passes a resolution in support of a Ministry of Justice review of the risk ratings in legislation, to better reflect the risks of different types of licensed premises.

Conclusion

Thank you for the opportunity to provide feedback on your draft alcohol fees bylaw. We would be happy to discuss any part of this submission in more detail, and to provide any assistance that you may require.

The Kai Keepers programme is making waves in the hospitality industry, helping businesses take action to reduce food waste.

Recently Kai Keeper business owner, Amanda Rogers from Auckland’s Ampersand Eatery, joined the Breakfast TV programme. Amanda shared insights on their experience taking part in the Kai Keepers pilot and how her team is implementing smarter, more sustainable food practices.

Watch the full interview below to learn how Kai Keepers is driving real change in the way we manage food waste in hospitality.

Find out about the Kai Keepers food waste reduction pilot here.

Ampersand Eatery is located Inside Orakei Bay Village, 228 Orakei Road, Auckland. www.ampersandeatery.nz

Find a Kai Keeper.

March 2025

Hurunui District Council
PO Box 13,
Amberley 7441,
North Canterbury

Introduction

The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to make a submission on the Hurunui District Council Review of Easter Sunday Shop Trading Policy.

Since 1972, the Restaurant Association has worked to off er advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people.

The Restaurant Association’s priorities for Easter Sunday Shop Trading policies are in strong support of enabling shops to open during Easter Sunday. This is for the following reasons:

• that the choice to open a business for trade should rest with the business owner, not local or central government.
• employees have the ability to refuse work on Easter Sunday without any repercussions to the employment relationship.
• there should be a consistent approach to Easter Sunday Shop Trading policies, enabling national operations to open across the country.

Hurunui District Council proposal

The Restaurant Association supports the Council’s proposal to retain the existing Easter Sunday Shop Trading Policy that retailers may open if they wish. In particular, the Restaurant Association supports the Council’s current policy providing:

• retailers within the whole of the Hurunui District boundary with the choice to open on Easter Sunday if they wish.
• the Workers Choice Provision which gives employees and employers the ability to negotiate freely and gives employees the ability to refuse work on Easter Sunday without any repercussions to the employment relationship.

Employer and employee rights

The choice to open during Easter should ultimately rest with the business owner, especially when acknowledging the impact of ongoing economic challenges. Employee protections are maintained under the Shop Trading Act 1990, ensuring staff who do not wish to work on Easter Sunday are protected. The Act allows businesses to create consistent schedules which provide more certainty to employees.
Easter Sunday is not a public holiday, and the primary reason for restricted trading is based on religious ideology. Removing these restrictions aligns with the principles of economic freedom and choice. Given the challenges posed by the global pandemic, the focus should be on supporting businesses and not retaining outdated restrictions that hinder economic growth.

Consistent approaches to Easter Sunday Trading

There should be a consistent approach to Easter Sunday Shop Trading policies, enabling shops to open during Easter Sunday nationally. It is the Restaurant Association’s view that all territorial authorities should adopt a local Easter Sunday Trading policy that allows shops to open during Easter Sunday. It is important to send a clear message to both visitors and residents that our towns and cities are open for business. This would also allow ‘brick and mortar’ shops to have greater alignment with online shops trading.

Conclusion

Thank you for the opportunity to provide feedback on your review of the Easter Sunday Shop Trading Policy. We would be happy to discuss any part of this submission in more detail, and to provide any assistance that you may require.

Quick view:

• The Fair Trading (Gift Card Expiry) Amendment Act has amended the Fair Trading Act.
• The Act prohibits the selling of gift cards with an expiry date of less than 3 years.
• There is a transition period and the new law comes into effect in March 2026.

Recent legislative changes impact how gift cards and vouchers are to be managed in your restaurant or cafe. The Commerce Commission have provided some guidance on the key updates that affect both the sale and redemption of gift vouchers/cards, inlcuding:

1. Expiry Dates: Gift cards or vouchers must now have a clearly stated expiry date at the time of purchase, and this date must be prominent on the card itself or easily accessible to the recipient.
2. No Expiry Fees: It’s illegal to charge fees for the use of gift cards or vouchers after their expiry date. Customers should be able to use the full value of the card without additional costs.
3. Disclosure Requirements: Sellers must provide clear information about terms and conditions, including any limitations on where and how the gift card or voucher can be used.

The new requirements will come into effect on 16 March 2026, providing a transition period before the new legislation applies. This means you’ll have time to prepare your systems to implement the changes and/or to sell existing stocks of gift cards with pre-printed dates. It is also important to note that the new rules are not applied retrospectively. The expiry date that is included in any current gift card, or one that is issued up until 16 March 2026 remains the same.

For more detailed guidance on how these regulations affect your business, visit the Commerce Commission’s website (Gift cards and vouchers/Gift card expiry date guidance).

March 2025

Gisborne District Council
15 Fitzherbert Street
Gisborne. 4010
New Zealand

Introduction

The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to make a submission on the Gisborne District Council Easter Sunday Shop Trading Policy.

Since 1972, the Restaurant Association has worked to off er advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people.

The Restaurant Association’s priorities for Easter Sunday Shop Trading policies are in strong support of enabling shops to open during Easter Sunday. This is for the following reasons:

• The choice to open a business for trade should rest with the business owner, not local or central government.
• Employees have the ability to refuse work on Easter Sunday without any repercussions to the employment relationship.
• There should be a consistent approach to Easter Sunday Shop Trading policies, enabling national operations to open across the country.

Gisborne District Council proposal

The Restaurant Association supports the Council’s proposal to re-adopt the current policy (Gisborne District Easter Sunday Shop Trading Policy 2018) as the Tairāwhiti Easter Sunday Shop Trading Policy 2025. In particular, the Restaurant Association supports the Council’s current policy maintaining the ability for shop owners to choose to open on Easter Sunday if they wish to do so.

Employer and employee rights

The choice to open during Easter should ultimately rest with the business owner, especially when acknowledging the impact of ongoing economic challenges. Employee protections are maintained under the Shop Trading Act 1990, ensuring staff who do not wish to work on Easter Sunday are able to refuse work.

Easter Sunday is not a public holiday, and the primary reason for restricted trading is based on religious ideology. Removing these restrictions aligns with the principles of economic freedom and choice, and modernising our collective approach to Easter Sunday trading will only help to support economic growth.

February 2025

Hamilton City Council 

Private Bag 3010

Hamilton 3204

Introduction

The Restaurant Association of New Zealand (the Restaurant Association) welcomes the opportunity to submit on the Hamilton City Council Draft Alcohol Fees Bylaw 2025.

Since 1972, the Restaurant Association has worked to offer advice, help and assistance in every facet of the vibrant and diverse hospitality industry, covering the length and breadth of the country. We’re passionate about our vibrant industry, which is full of interesting, talented and entrepreneurial people.

The Restaurant Association’s priorities for local alcohol fee bylaws include:

• Where fee increases are proposed, ensuring they are phased in over a reasonable timeframe,

• Ensuring Councils are transparent about the cost of alcohol licensing, including which types of licences incur greater costs to the council
• Retaining a minimum 30% of alcohol licensing costs to be paid for through general rates, in recognition of the benefit of a thriving hospitality industry to local communities, and
• Advocating to Central Government for a review of risk ratings set out in legislation.

Hamilton City Council proposal

The Restaurant Association does not support the Council’s preferred option of creating an alcohol fees bylaw in its current form. We are not opposed to the simple act of the Council creating such a bylaw, however, we are concerned by the inherent drastic increase in licensing fees to be paid by applicants in this instance.

If the Council does decide to implement option 1, we recommend two changes are made:

• that 30% of the cost of alcohol licensing be covered from general rates, rather than the proposed 5%, in recognition of the social benefit to local communities from having a thriving hospitality sector.
• that the proposed fee increases should be spread more equally across the 5 year period to prevent such large, up-front fee increases and allow our businesses space to plan and prepare for fee changes.

Notwithstanding the above, we recommend that the Council adopts option 2 by retaining the status quo, as this better reflects our priorities for local alcohol fee bylaws.

Phased fee increases

While we recognise that licensing fees were set by legislation 11 years ago, and that Councils across the country need to recover costs, it is our position that businesses should not be hit with such drastic fee increases simply because their local council had not adopted an alcohol fees bylaw sooner.

For that reason we recommend that all councils take a more gradual approach to fee increases, by more evenly distributing the cumulative increase over a longer period. Further, we recommend that a cap on annual fee increases be adopted by the Council, limiting annual alcohol licensing fee increases to a maximum of no greater than 15%.

Using the Council’s current proposal as an example, in practice this would mean:

• If evenly distributing fee increases, a 28% increase over the next two years, or an 18% increase over the next three years.
• If capping annual increases, a 15% increase over the next three years, followed by a 9% increase in 2028/29.

Council transparency 

We are concerned that many Councils across the country use cost recovery as a blanket justification for increasing fees across the board, often without any transparency around actual costs incurred by the Council.

It is our position that Councils should provide evidence of the actual cost of processing licences as part of their consultation, so licencees can have confidence that the amount being recovered is accurate and fair. This breakdown should also include the difference in cost of processing on-licences compared to off-licences, with a view to recovering costs on a more proportionate basis in the future.

Finally, we would like to see that Councils have sought to improve efficiencies or cut the internal cost of alcohol licences before passing these costs on to licencees. Businesses are not an endless source of funds that can withstand constant levying by local authorities, and we submit that there must be an attempt on behalf of regulatory bodies across the country to build confidence in their activities.

Public benefit of hospitality

The Restaurant Association submits that all Councils should retain a ratepayer contribution of 30% to alcohol licensing fees, to recognise the contribution of well-managed hospitality venues to the life and economy of communities, and the societal value of having facilities available where people can go to enjoy themselves while drinking safely and responsibly.

Arguments against retaining a ratepayer contribution often cite the user-pays intention of the Act as justification for complete (or almost complete) cost recovery through licensing fees. We submit that ratepayers are part of the user-pays licensing system, and rather than relying on venues to increase prices to cover fee increases, the Council should support access to affordable hospitality for all through its setting of fees.

Review of current risk ranking

The Restaurant Association recognises the need to ensure the sale and supply of alcohol is undertaken safely and responsibly. However, we are concerned that the rigid risk rating formula contained in legislation is out of date and no longer matches the realities of modern hospitality environments. It is important that legislation and bylaws recognise there is not only a difference between on- and off-licence venues, but that there is also a difference between types of on-licence venue: for example, both a night club and a restaurant are on-licence venues, but prima facie these businesses have two very different risk profiles.

Our more than 2,500-strong membership is made up of hospitality businesses where food is the hero of their operations, with alcoholic beverages offered as a supplement to their culinary experience. We therefore believe that a more fulsome review of the risk rating of premises within the regulations to better reflect the actual risk of harm.

We recognise that the setting of risk ratings is not within the control of this Council, and therefore recommend that the Council passes a resolution in support of a Ministry of Justice review of the risk ratings in legislation, to better reflect the risks of different types of licensed premises.

Conclusion

Thank you for the opportunity to provide feedback on your draft alcohol fees bylaw. We would be happy to discuss any part of this submission in more detail, and to provide any assistance that you may require.