Sir, - The article by Mr Des Gilroy, "Pub deregulation is no solution" (Opinion, May 29th) raises a number of misleading points.
Mr Gilroy quotes selectively from a Competition Authority report, saying there was statistical evidence of a link between the number of licences and the demand for the product, and that an increase in the number of licences led to an increase in demand for alcohol.
The Competition Authority report in fact referred to the results of UK studies which showed that there appeared to be a two-way causal relationship between licences and demand. If, however, the number of licences is not increased in line with demand, then the effect of an increase in demand is an increase in price. The authority report found that drink prices in Dublin, where there is a relative shortage of licences, were indeed persistently higher than elsewhere. Overall, Eurostat statistics indicate that, on an equivalent basis, Ireland is the most expensive country in the EU for alcoholic beverages.
Mr Gilroy's article also refers to an assertion by Mr Richard Dunne, Vintners' Federation of Ireland (VFI) president, that deregulation would lead to a worsening of alcohol abuse. In the light of this concern by vintners, the recent call by the VFI's chief executive, Tadhg O'Sullivan (as reported, for instance, in the Irish Independent on May 18th) for a reduction in the rate of tax on alcohol is surprising. How does this concern for alcohol abuse sit with the call for a reduction in taxes and is this concern stimulated by the possibility of regulatory reform which would open the market to competition?
Finally, Mr Gilroy's article refers to the serious problems of alcohol abuse in Ireland. We should not lose sight of the fact that we have reached this situation under the current licensing laws. The status quo self-evidently does not protect underage drinkers or prevent alcohol abuse. Mr Gilroy claims, without providing a source for his statistics, that 25 per cent of our adult population abstain from alcohol and that, taking this into account, "we are undoubtedly leading the world in consumption".
The 1999 Eurostat Yearbook places Ireland eighth out of the 15 EU countries in terms of alcohol consumption. Statistics from the 1999 National Health and Lifestyle Surveys would indicate that the true rate of abstention is in the region of 10 to 12 per cent. In fact, only females over 55 have an abstention rate above 25 per cent.
The real problem in terms of the social costs normally associated with alcohol consumption is not the actual amount of alcohol consumed but, critically, the pattern of consumption. It is clear that many EU states, which have a much more liberal system of liquor licensing, consume as much alcohol as we do in Ireland but do not experience the same level of associated social ills. What is required is a debate on the causes of antisocial patterns of alcohol use. The current licensing regime, which encourages the consumption of alcohol as a social activity in itself, rather than as an adjunct to other activities, must be seen as part of the problem.
Those who argue against regulatory reform often use scaremongering tactics to suggest that liberalisation will result in a "proliferation" of licences. The fact is we already have such a proliferation - in rural areas - and a scarcity in Dublin. The effect of freeing up new licences would be to reduce geographical disparities and match supply to demand. - Yours, etc.,
Isolde Goggin, Director, Regulated Markets, Competition Authority, Parnell Square, Dublin 1.