MUP vs BBCS

So the government has 'shelved' minimum unit pricing (though Public Health England still insists it's under consideration, but won't tell us how - that would be a matter for the Home Office).

This isn't really a surprise, as it was clearly hinted at by Anna Soubry on 2nd July, and then basically confirmed on 12th.  And further back, the government had clearly already cooled on the subject even before the idea was excluded from the Queen's Speech earlier this year.

The government has instead gone back to the idea of a ban on selling alcohol 'below cost' - i.e. below the cost of duty and VAT - originally promised in the Coalition's Programme for Government.  This is despite saying just over a year ago in the Alcohol Strategy: "We do not currently intend to implement a ban on the below cost sale of alcohol (defined as Duty + VAT)."  But then this was also the document that said, unequivocally, "We will introduce a minimum unit price (MUP) for alcohol".  MUP could be said to be the policy centrepiece of the document.

Yesterday, David Cameron said the new (or should I say old) proposal was 'effectively a minimum price'.  Indeed, Jeremy Browne's statement is careful to frame the measure in these terms: "It will no longer be legal to sell a can of ordinary strength lager for less than about 40 pence."

Now, setting aside the point I would make in an academic setting (that it says something about the views of this government that they chose lager as the illustration), this sparked me thinking about what is different between the two proposals: MUP vs below cost pricing.

MUP has been rejected because the government does "not yet have enough concrete evidence that its introduction would be effective in reducing harms associated with problem drinking, without penalising people who drink responsibly".  However, if there's insufficient evidence about MUP, surely there's also insufficient evidence about setting what's 'effectively' MUP?

In fact, if we take at face value the statement from the Home Secretary that the measures are to 'curb excessive drinking', it seems clear that there's less evidence that a below cost ban will 'work'.  Today, the Sheffield Alcohol Research Group that did the modelling on MUP that's often cited have published a clear comparison of MUP and the below cost ban.  The evidence of the model* is that public health benefits of BBCS, as they call it (Ban on Below Cost Selling), would be tiny compared to MUP at 45p.

It's for this reason that the decision has been branded 'disgraceful', for example.

There's obviously something else going on here.

MUP is generally understood by public health campaigners as in line with a population model (explained by James Morris here).  That is, reduce everyone's consumption by a tiny average amount, and the difference to any specific individual in terms of risk might be almost negligible, but when you add all this up across a population, you get a noticeable fall in the total harm.

However, this is not how the government has portrayed MUP.  Generally, it has been presented as a targeted policy.  The 2012 Alcohol Strategy was very clearly presented as dealing with 'binge' drinkers, with the Prime Minister's foreword beginning and ending with a reference to them.  It is in this context that the promise of MUP was introduced, with an explicit reference to problems caused by 'pre-loading' (drinking alcohol bought from a supermarket/off-licence before you head out to a pub or club).  David Cameron on another occasion explained that MUP was a way of stopping families with a 'reasonable drinking habit' subsidising 'binge' drinkers.

I don't really know what this difference in understanding of MUP is caused by.  It could just be a way to 'sell' the policy to a wider public, using 'binge' drinkers almost as a cover.  It could be a genuine belief that this is how the policy could or should work.  It might, perhaps most plausibly, represent genuine confusion.  Or maybe it reflects the kind of wishful thinking that seems to dominate alcohol policy discussions: that despite the fact that there's a myriad of 'problems' associated with the substance, somewhere out there is a single policy or initiative that can deal with them all.  The debate around MUP seems to have taken this form, with it being seen as the solution to all ills.

I don't think this representation of MUP is any kind of cover.  I would suggest that the government genuinely believes that alcohol-related issues are caused by an 'irresponsible minority', and that those with a 'reasonable drinking habit' should be largely left alone.  The idea of a 'reasonable drinking habit' as something that should be seen sympathetically would certainly grate with a public health view of the world.

If this is true, then the government's ideal policy would not be population wide but something that's targeted.  And duty on alcohol is targeted (if in a slightly bizarre way), varying by drink type.  A key example of this is white cider, which is considered to be a particular problem by the government - so much so that legislation was introduced in 2010 in order to define it as a separate drink.  If my calculations are right, the below cost ban would make 3 litres of Frosty Jack's £7.65, compared to £2.75 in 2010, according to the Daily Mail.  Meanwhile, a bottle of wine will still be able to be as low as something like £2.20.^†  This is precisely the sort of targeting that I can imagine the government being in favour of.

UPDATE 18-07-13
John Holmes of the Sheffield team has informed me that in fact Frosty Jack's isn't taxed at the spirits rate.  That makes me confused about what exactly the 2010 duty change can possibly be doing.  I'm trying to find out what on earth its point is now by the questionable mechanism of Twitter.

In light of its shelving of standardised packaging for tobacco as well as MUP, the government is currently being characterised as in hock to big tobacco and alcohol, symbolised by Lynton Crosby's lobbying connections.  Just like with the Labour debates around union funding, I think it's a lot more complicated than that.

This could be linked to broader ideas of neoliberalism, and I think this helps understand where the government is coming from.  The targeting of individuals comes from the same place: the fundamental approach to government is that market forces should be allowed to roam free, and undesirable outcomes that arise are the fault of flawed individuals, rather than flawed structures.

I've said before that there's a reason big tobacco gives to think tanks like the Adam Smith Insitute: it's not so much that they'll be easily swayed by the cash; it's more that they're already inclined to agree with the idea that the tobacco industry (like almost all others) should be free to operate in a largely unregulated market.

Similarly, at the moment both Coalition parties are led by individuals with a fundamental belief free market principles, and I'd suggest that the idea of banning below cost selling fits more neatly with a free-market worldview than a minimum price (above this level).  Of course in other contexts loss-leading is considered a legitimate tactic within the market.  But then maybe this could be justified by saying that alcohol is no ordinary commodity.  (The distinction here seems to be more one of an impression rather than substance, as the practical difference between the two interventions seems marginal.)

So my conclusion is that MUP has been shelved because the government simply doesn't have a public health philosophy (in terms of defining either the problem or the solution) and it is ideologically defaulted to protecting the free market and targeting apparently problematic individuals.

(As with the issue of the industry funding think tanks, we probably get closer to the heart of the Lynton Crosby issue if we start with the fact that Cameron is the sort of person who would hire a person like Lynton Crosby, who has all these sorts of alcohol and tobacco industry links.)

For public health campaigners this might seem like an unfortunate blow.  However, I want to end on a positive note, so I'll make two points.

First, public health concerns aren't the only issue in alcohol policy, as I've said before, and so we shouldn't expect them to trump everything else - and we should remember that MUP wouldn't have been a panacea for all alcohol-related issues in any case.

Second, and somewhat flippantly, it's nice to know that the population-wide model doesn't always win out at the expense of targeting.  One of my roles is in commissioning drug treatment, and the general approach of this - targeting a few thousand individuals in an area, rather than a few hundred thousand - sits somewhat at odds with the public health population-wide model.  Targeting can sometimes be helpful.  Unfortunately, it can also be stigmatising - but that's something for my next post.

*Some representatives of the alcohol industry would want me to point out that this isn't really 'evidence' according to their definition, as it doesn't look at something that's actually happened - it's 'only' modelling.

^†This is based on the figures on p.7 of the Sheffield report, which give spirit duty+VAT as 33.9p per unit, and wine as 24.5ppu, assuming 9 units in a bottle of wine and 22.56 units in a 3l bottle of Frosty Jack's.