Letter to  Ms C Clark (Premier) re: FUSS, 21st April 2014


CAMPAIGN FOR REAL ALE SOCIETY OF BRITISH COLUMBIA
PO BOX 36082
ESQUIMALT, BC
V9A 7J5
604-719-2930 ▪ WWW.CAMRABC.CA ▪ @CAMRABC

        We are writing this letter on behalf of the Campaign for Real Ale Society of British Columbia (CAMRA BC), a 100% volunteer-run and independent BC craft beer consumer advocacy group—one of the fastest growing consumer demographics in BC—wholly financed by membership dues.

        On September 24, 2013, CAMRA BC representatives met with Parliamentary Secretary Hon. John Yap, Cabinet Director in the Office of the Premier Ken Dawson, and Executive Assistant in the Office of the Attorney General and Minister of Justice Suneil Karod, as a part of the BC Liquor Review stakeholder meetings. We would like to thank you for allowing us to be a part of the process and to tell you we are very pleased that many of the proposals we put forward became recommendations, such as: ● craft beer sales at farmers markets ● allowing minors into liquor primary establishments in certain circumstances ● featuring and promoting BC craft beer in BC Liquor Stores ● streamlining Special Occasion Licences ● allowing happy hours and discretionary pricing ● allowing home-brewed beer to be featured in festivals and served during special events like weddings and family reunions.

        One recommendation we did put forward that was not included in Mr. Yap’s final report to the Office of the Justice Minister and Attorney General was the recommendation to enact policy that would ensure draft beer measures were not misrepresented or misleading, thereby enhancing public safety while minimizing health concerns related to the consumption of alcohol and protecting consumers’ rights.
We would like to provide some feedback and highlight how some of the ideas we discussed with Mr. Yap are essential to the successful implementation of the recommendations endorsed by the Provincial Government. Of specific concern are those recommendations that protect consumers while promoting public health and safety consistent with the consultation’s guiding principles, namely, “balance economic and social interests by ensuring public safety and the public interest of British Columbians and their communities is protected,” and “minimize health and social harms caused by liquor.”

        In 2011, CAMRA BC launched its “Fess Up to Serving Sizes” (FUSS) campaign with the goal of encouraging compliance with, and enforcement of, the rule that all licensed establishments must provide an accurate serving size and price list for all alcoholic beverages served. We launched this campaign because many licensees, whether deliberately or not, were misleading consumers on the serving size of their draft beers, often advertising one measure when delivering a substantially different volume.
By properly enforcing this serving size rule, the LCLB would be:

    ● allowing the consumer to make accurate and informed decisions about their alcohol consumption, and therefore better able to judge how to drink responsibly o we note that glassware advertised as “sleeves” ranges in size from 314ml to 454ml (12oz to 16oz) despite appearing identical
    ● allowing servers to better judge how much alcohol they serve to consumers, resulting in better compliance with Serving it Right guidelines
    ● protecting consumers from being overcharged, and licensees from overfilling


Further to this, making it mandatory for licensees to serve all draught beer in marked glassware (as should be instituted) in addition to publicly posting their serving sizes (as exists but is not enforced) is essential to effectively promoting public health and safety and preventing the presently widespread practice of overcharging, if not outright defrauding, consumers for lower beverage
volumes actually served. We note that this also dovetails with recommendations regarding more comprehensive Serving it Right guidelines and allows better decisions to be made with respect to over-serving and over-consumption.

We note that marked glassware featuring a clear “fill line”
labeled with the certified full volume in millilitres has been the standard in the European Union and most countries for some time now. This method of implementing uniformity in serving sizes represents no additional long-term cost to licensees if phased in over a period of time, allowing licensees to replace unmarked glassware with marked glassware as need arises due to glassware attrition.

By requiring marked glassware certified by CSA, CE, UL, or other recognized testing authority (there are examples of wildly inaccurate volume markings being used on glassware in BC), we feel:

    ● inaccurate and misleading service volumes would be eliminated
    ● consumers will be able to make accurate health and safety decisions (when also informed of ABV)
    ● consumers will finally know if beer they paid for has been withheld by a licensee
    ● consumers will be able to drink a properly poured beer that is not brimming and overflowing, and that has the correct amount of head, while not being under-served
    ● waste from over-pouring/spilling, and the consumer-led risks of systematically underpouring customers, would be eliminated for licensees.

In conjunction with the mandatory publishing of serving sizes and instituting marked glassware, a regulation should be enacted that requires all licensees to prominently post the alcohol content (%ABV) of each beer they serve in their establishments in order to better inform consumers of the quantity of alcohol they are drinking. This also requires that serving sizes be clearly posted and
accurately served. This requirement would also strengthen and support the Serving It Right program, which Mr. Yap has recommended be “expanded and enhanced” in Recommendation 7.

To this end, we see these recommendations from our FUSS campaign as synergistic with Recommendation 18 from Mr. Yap’s report, which states, “[The] LDB should consider tying minimum prices to the amount of alcohol (e.g., a beer with seven per cent alcohol would have a higher minimum price than a beer with four per cent alcohol).” Therefore, CAMRA BC is in support of this recommendation but only as long as it is being made in the interests of public health and safety and not to increase tax revenues ultimately paid by craft beer consumers, who are the primary market for full-flavoured and often higher alcohol by volume (ABV) beers.

Our
recommendation is that this policy will be rolled out to meet a net-zero revenue mandate where any increases in any taxation on higher-ABV drinks be matched by exactly proportional decreases in lower alcohol drinks. This would foster an appreciation of lower alcohol drinks, reduce public  drunkenness and impaired driving, improve public health and inspire creativity among manufacturers. CAMRA BC already promotes lower alcohol beers at our Spring Sessional Cask Festival in Vancouver, which only allows craft beers under 5% to be served. We would expect such ABV-pricing to be imposed upon wine (which we note can vary between 6% and 23% ABV) and spirits as well.

To summarize, BC has the opportunity to catch up with other jurisdictions and to promote and enhance consumer education, responsible consumption, responsible service (Serving It Right) and consumer protection by:

1. Requiring that certified volume-marked glassware (in milliliters) be used and that pricing be based on the marked volume of the glassware chosen.

2. Actively enforcing accurate ABV measurement, ABV posting and serving size rules.

3. Requiring that the accurate ABV content of beer, wine and spirits be clearly posted, both at licensed establishments and on retail packaging.

4. Instituting ABV pricing for all liquor on a net-zero revenue basis.

We would be very happy to meet with the working group who are drafting this legislation to share the benefit of our experience and the consumer point of view with respect to the above matters and others. We see these FUSS proposals as win-win in regards to balancing public health & safety with consumers’ rights and desires. Please feel free to contact our Advocacy Committee Representative, Paddy Treavor, at advocacy@camrabc.ca or 604-719-2930.

Sincerely,
Campaign for Real Ale Society of British Columbia (CAMRA BC), Advocacy Committee
Paddy Treavor - President, CAMRA BC - Powell River
Adam Chatburn - President, CAMRA BC - Vancouver
Chad McCarthy - Vice President, CAMRA BC - Vancouver