The Baltimore County Board of Liquor License Commissioners is in the process of adopting new Rules and Regulations.

All liquor licensees are required to comply with not only the provisions of the Annotated Code of Maryland, the Baltimore County Code, but also the Rules and Regulations of the Board of Liquor License Commissioners for Baltimore County.

The current Rules and Regulations were last revised in 2014.

A version of those Rules and Regulations redlined to reflect the proposed changes is available here.

The Board of Liquor License Commissioners held a public hearing on February 27, and we both offered written comment and testified at the hearing.

Among the proposed changes, there is a new proposal for cameras to be installed in non public areas of licensed premises. We noted at the hearing that there will be a significant dollar expense of complying with this new mandate for cameras, and we noted that the proposed text is not precise in terms of which areas must have cameras (e.g., is it intended that there will be cameras in restrooms, in storage rooms, in walk in refrigerators, closets? We recommended that this new requirement be delayed until some date in the future, including greater specificity if a camera requirement is going to be implemented.

We also recommended clarification and standardization in the term “licensed premises,” in lieu of the several other ways that the licensed premises are described, including “premises covered by the license” and licensee’s “establishment.” This can be of importance where the Board of Liquor License Commissioners is faced with matters occurring ‘in a parking lot’ or ‘upstairs’ that may be outside of the licensed premises and beyond the control of the licensee. And what is and what can be included within the licensed premises may be a matter of inquiry as the Board approves new licenses.

We also recommended removing from the Rules and Regulations the required specific number of parking spaces from the Exception Licenses. That is, the Exception License that requires square footage of retail and office space is sufficient, especially in a day and age when land use regulations (including that there are LEED green building credits for reduced parking spaces) encourage less off street parking spaces not only in mixed use projects and in transit oriented development, but in all commercial uses. And all parking demand is being reduced by the use of Uber, Zip Car and the like. So, requiring more off street parking spaces seems counter to good environmental stewardship and has little, if anything, to do with liquor licenses.

While it might seem trivial to some, in the interest of staying current with modern trends and regulations, we recommended that the mandate in the Rules and Regulations for flush toilets be removed. That is, in the interest of potable water use reductions, waterless urinals are (not only permitted by the County plumbing code) but are becoming popular (again, they can contribute to LEED green building credits) in our County and waterless urinals should not be prohibited in licensed premises.

The effective date for the new Rules and Regulations is not yet known, but all licensees are well served by reviewing the redlined draft available from the link above.