Clarify definition of "pub crawl" in proposed regulations

We are writing to you to provide comment on the ABCRA’s proposal to permanently amend regulations on pub crawls (Section 712 of Title 23 of the DCMR).

While we fully support the amendment’s intention to curtail and manage the impact of large pub crawls on neighborhoods in Washington DC, we have concerns about the current language that defines what a pub crawl is. Specifically, we are concerned that the language is too broad, and in some ways inconsistent. As a result, we worry that other non “Pub Crawl” type events might be caught up in this regulation.

Section 712.3 states:
For purposes of this section a “pub crawl event” shall be defined as an organized group of establishments within walking distance which participate in the promotion of the event featuring the sale or service of alcoholic beverages during a specified time period.

This definition is a bit unclear.
What is the standard for “organized”? Charging admission? Registration?
What is the standard for “promotion of the event”? Advertising?

The above definition also conflicts with what currently appears on the Pub Crawl Application Form, which adds the distinction that discounted drinks must be involved:
A "Pub Crawl” is an organized group of establishments within walking distance which offer discounted alcoholic drinks during a specified time period.

Below is a list of longstanding community events that could be caught up in the current broad definition, even though they are clearly not “Pub Crawls”.

1) Street Festivals: H St Festival, Adams Morgan Festival, etc. These all feature an organized group of establishments within walking distance that promote the event and feature the sale of alcohol for a specified period .

2) First Friday Art Gallery tours in Dupont Circle: They are an organized group of establishments within walking distance that serve alcohol.

3) “Hash” Running Clubs have been operating in DC for more than 20 years and often visit multiple venues that serve alcohol along their running route.

4) Food and Restaurant tours also would clearly fall under this definition. Googling “DC food tour” or “DC chocolate tour” or “DC beer tour” comes up with many examples.

In addition, Section 712.26’s attempt to limit the regulation to Pub Crawls of more than 200 people is undercut by the lack of clarity in what defines a pub crawl, and also what defines a “participant”. Are participants only those who register for an event, or would additional patrons who happen to be at a venue be included in that count? (Not all pub-crawls close the venues to other customers.)

Instead of the current criteria, we would propose that the below characteristics would better define the types of disruptive pub crawl events that need regulation:
- The party organizing the pub crawl is a for-profit corporation.
- Participation in the event is exclusive (requires registration)
- The event involves more than 4 venues (DC venues are characteristically small; by limiting the number of venues involved, you limit the number of attendees at non-regulated events).

We would thus propose that section 712.3 be rewritten along the following lines:
A "Pub Crawl” is defined as a for-profit event that requires the registration of participants, and features the sale or service of discounted alcoholic beverages at more than 4 venues within walking distance of each other.