The Irish nightclub industry association says the Government's proposed changes to the liquor laws would cause more problems than they solve.
It says banning dancing during drinking-up time and shortening the opening hours of nightclubs will cause more people to empty onto the streets at the same time.
It also says that what is needed is a greater number of gardaí patrolling the streets on weekend nights.
In a 21-page submission, nightclub owners outline their concerns and give their views on where the problems lie and how to solve them.
The Nightclub Industry Association says an annual nightclub license should be introduced.