15/01/2018
What is this document?
This document has been prepared by members of the Brockwell Tranquillity Facebook group, who seek to resist large parts of Brockwell Park (and other community parks) being altered from open public spaces for the whole community to enjoy, into being closed off walled commercial events which are not inclusive, and cause significant disruption to the locality. Please consider it a strong objection from the group.
Wherever possible, all statements provided are interpretations of facts in the public domain. Please get in touch if you believe the information presented in this report is mistaken, incorrect, or misinterpreted. All the points raised in this document are serious concerns that we seek to be mitigated in full and addressed for an event licence to be issued.
“If your event application has been accepted at Stage Three, then the event application will move to Stage Four. If your event application has objections then it will remain at Stage Three until all concerns have been addressed “1
Report Structure
We have broadly structured the report around the core objectives of the 2003 licencing act, followed by additional matters. However these are intended to cover both the event licence stage, and the subsequent licencing stage. As many of these issues occur outside the licensable area, they are meant to apply broadly to both processes of Lambeth giving the event a permit, which will include impacts outside of the licencable area, and for elements in the licencable area/in the licencees gift.
We are a group of volunteers who do not have the resources to provide detailed and tailored reports for the multiple stages of events, but wish to be involved in local democracy. We look forward to an engagement that follows the principals set out by the local government association2
1 http://www.eventlambeth.co.uk/wp-content/uploads/2017/10/EventLambeth-Events-Guide-v.201710.pdf
2 https://www.local.gov.uk/our-support/our-improvement-offer/care-and-health-improvement/integration-and-better-care-fund/better- care-fund/integration-resource-library/communication-and-engagement 15/01/2018
Contents What is this document?...... 1
Report Structure ...... 1
Summary Statement ...... 3
The 2003 licencing Act ...... 4
The prevention of crime and disorder ...... 4
Public Safety ...... 6
Prevention of Public Nuisance ...... 7
Noise ...... 7
Mental Health and Nuisance ...... 10
Shift workers and nuisance / sleep loss ...... 10
Equality ...... 10
Other Nuisance ...... 11
Protection of Children from Harm ...... 12
Other Factors ...... 13
Damage to park ...... 13
Biodiversity Duty ...... 13
Protection of wildlife species by Law ...... 14
Capacity and Seasonality ...... 14
The Value of the park – from the Mayor’s natural capital report ...... 14
Appendix: Councillor Josh Peck, Victoria Park ...... 15
Brockwell Park Community Partners ...... 16
15/01/2018
Summary Statement
We love our park, and the respite it gives from day to day. It’s an important asset for the community. It is designated a site of borough wide importance for nature conservation in Lambeth’s plans, is a grade II listed park, and is a very important community asset in a borough that is among the 10% most deprived authorities in England.3 In Lambeth’s 2020 survey of young people, sport and going to the park were listed as the top 2 favourite activities of young people with 81% and 76% of those surveyed respectively4.
For the 48,000 people living in the voting wards surrounding Brockwell Park, recreation, physical health and mental health benefits from parks could be £10M based on figures in the natural capital report 5from the mayors office. The park is valuable indeed.
Open, unfenced events such as the Lambeth Country Show, whilst not without problems, are accepted and loved by the community, as they have a direct benefit for the community such as building a sense of integration. Similarly, events such as 10k races, muddy dog challenge, etc, promote the core aims of a park, for health and wellbeing of the community. This is in line with the 2020 culture strategy aim of “No matter where you live in Lambeth you‘ll be within 20 minutes average walking time from affordable activities which will improve your health and wellbeing6.” Reducing access to the park for 41 days will inhibit this aim in a core part of summer. Small commercial events such as fun fairs and circus are also welcome, as they are small, do not disrupt general park use, and are aimed at children, for whom there are not always activities to do.
“IN my view, a festival of this size is simply too big to be held in a residential area without causing some substantial impacts to local people. Even if the operator were fully on top of these impacts – which Lovebox never were – I don’t think they could have been fully reduced to an acceptable level.” Councillor Peck, Tower Hamlets
Commercial events in the park such as sunfall, which brought crime including open drug dealing in the park7, are not welcome.
We whole heartedly object to any major or large commercial event in the park (with major being defined as 20,000+ and large being perhaps 10,000-20,000).
3 https://www.lambeth.gov.uk/sites/default/files/State%20of%20Borough%202016%20-%20v3.pdf
4 Page 27 https://moderngov.lambeth.gov.uk/documents/s77363/Culture%202020%20Appendix%201%20- %20Consultation%20Report%20overview.pdf
5 https://www.london.gov.uk/sites/default/files/11015viv_natural_capital_account_for_london_v7_full_vis.pdf
6 http://love.lambeth.gov.uk/culture2020-consultation/
7 See Brockwell Park Community Partners statement on the proposed events in the park for anecdotal evidence 15/01/2018
The 2003 licencing Act
The Licencing Act 2003 requires a number of provisions to be met. There are some concerns whether a number of these can be fulfilled. The Act sets out four licensing objectives which must be taken into account when a local authority carries out its functions. They are:
1. the prevention of crime and disorder, 2. public safety, 3. prevention of public nuisance, and 4. the protection of children from harm
The prevention of crime and disorder
The Licencing Act sets out four licensing objectives which must be taken into account when a local authority carries out its functions, including the prevention of crime and disorder. Lambeth’s statement on licencing 8says “Applicants are advised that they should, in their operating schedules focus on measures that will ensure that their proposals will not add to existing problems with crime and disorder.”
There are crime statistics in the public domain9 associated with one of the proposed festivals LoveBox, which show 63 crimes over the three days. Comparing these figures with background crimes levels in roads around the park (including Railton road, Brixton Waterlane, Tulse Hill etc) from the police crime map 10, we can gain insight into how much crime increases. A significant increase in crime might be considered not to fulfil the licencing objectives. The table to the right shows crimes recorded for the month of June, when no festivals were present. Prorata these to 3 days, and we have a direct comparison with Lovebox. These show that there will be an approximate 6 fold increase in crime on the days of Lovebox. I do not believe that would satisfy the objectives of the Licencing act of reducing crime and disorder.
Crimes in roads around Brockwell In June pro-rated over Park. 2017 3 days Crime category Violence and sexual offences 15 1.5 Anti-social behaviour 23 2.3 Possession of weapons 1 0.1 Robbery 7 0.7 Theft from the person 1 0.1 Bicycle theft 13 1.3 Burglary 13 1.3 Other theft 14 1.4 Drugs 4 0.4 Public order 12 1.2 Criminal damage and arson 8 0.8 Vehicle crime 5 0.5 Total 116 11.6
Indeed on Lovebox, Councillor Joshua Peck from Finsbury Park has been quoted as saying ”The stewarding was of a very variable quality outside of the site, with a very limited number of fully accredited stewards and most of the ‘crowd control’ done by poorly trained, inexperienced young people who did a poor job – for example, I saw four stewards
8 https://www.lambeth.gov.uk/sites/default/files/Lambeth%20Licensing%20Policy%202014%20-%202019_1.pdf
9 https://maps.met.police.uk/globalassets/foi-media/disclosure_2017/april_2017/information-rights-unit--quantities-of-crimes-recorded-against-under- each-category-of-victim-based-crime-other-crimes-against-society-and-fraud-offences 10 https://www.police.uk/metropolitan/E05000423/crime/2017-06/+1zmZIY/
15/01/2018 playing football with festival goers one evening as people sat in front gardens right next to them – precisely what they were there to stop”. See the appendix for the quote in full.
Lovebox have also featured in this article in the NME Article: http://www.nme.com/news/music/lovebox-security-hit-allegations- assault-2112317The previous page was written using LoveBox as a precedent. Our Local Experience is similar.
Referring to the significantly smaller one day festival, Found, “At one point someone brought an SUV into the park, parked upon one of the paths and dealt drugs from the back without anyone trying to stop them. At the Sunfall event the security people hired by the company were not very engaged in controlling the behaviour of their audience which was potentially very dangerous both to park users and the festival go-ers.” Brockwell Park Community Partners. 11
Also, fights 12 broke out, and the police were called to bring order at Sunfall “Festival-goers at the Brockwell Park event described scenes of crowd crushes with police having “to enforce crowd control” as people stampeded barricades in the thousands- deep queue. One fan witnessed “fighting” as revellers grew increasingly frustrated, while another said they felt “lucky to be alive” after the crush, adding: “Organizers should be extremely concerned.”” Fact Magazine
There was a series of vandalism reported after sunfall, including memorial benches ripped up, vandalism to the much loved miniature railway, and in addition, a portion of fence was smashed at around 12am after sunfall and has not been repaired for 6 months (this may be coincidence, but it is highly likely).
Other vandalism was at nuisance levels. The Monday after Sunfall, toilets in the parks were either locked or vandalised. The only open female toilet had cisterns smashed, toilets blocked with paper (and overflowing with sewage on the floor) and excrement wiped over the walls and ceiling. This was a busy day in the park, at the height of summer, full of toddlers, children and their parents and carers, unable to access a basic and expected facility such as a toilet.
For many, drug dealing and fighting in the park would make many view the whole park as a total no go area.
There is not sufficient experience of running events of this variety in Brockwell Park. Before events are scaled up, it would seem prudent to attempt to run a single one day event at sub 20k capacity (as Sunfall was) and deliver this without introducing crime and disorder into the neighbourhood, rather than run 6 event days that are often double the capacity of sunfall.
The above indicate that large scale festivals in our area cannot be developed whilst meeting the licencing objectives of prevention and crime and disorder.
11 https://brockwellparkcommunitypartners.org.uk/
12 http://www.factmag.com/2017/08/12/sunfall-festival-2017-queue-chaos/ 15/01/2018
Public Safety
Another objective of the licencing act is public safety. The main concerns:
The park has not been tested for fenced off events of this scale Can the park be safely evacuated through the “single gate”
Entry The event team from field day series said they would more or less use Brixton water lane for entry, and entry from other gates would not be possible for festival goers.
The pavements on Brixton Waterlane are approximately 1m wide (narrower in places, when street furniture such as bins and bus stops are taken into account). Assuming 40,000 people enter over 3 hours, that's 15,000 people an hour, or 250 people a minute. As Brixton Waterlane pavements are very narrow before bins and bus stops are taken into account, people will be likely to move single file. Assuming they walk a meter apart, 250m of people have to move down the road in 1 minute. For this to happen, they will need to travel at 15km/h. Typical walking speed is 5kmh. This implies road closures will be required, which would have major impacts on bus routes.
Either that or the suggestion that Waterlane will be the exclusive entrance are fanciful, and plans have not been thought through. In addition, 40,000 people entering the park will mean a significant part of the park over the 35% enclosed area will be given up to festival goers circulation, so the real number of space used for festival uses on the day might be nearer 50% of the park.
Exits from the park At the end of the festival, the curfew occurs at a precise time when the headline acts finish. This will result in 3 times the number above leaving. This could pose a serious security risk, as compared to Clapham Common, Brockwell Park is fenced off, with only narrow entrances to the park. These kind of concerns are frequently raised in association with the fireworks in Brockwell Park. In comparison to the Lambeth Country show, there is a much less significant focus to the day, so festival goers leave in a much more staggered manner than is achieved at a paid festival with headliners. Lambeth have made comparisons of the Lambeth Country Show having 100,000 visitors a day to the 40,000 capacity of the proposed events. These are not fair comparative figures. A recent freedom of information act13 in our possession revels that the peak number of visitors to the LCS was 35,000 between 330 and 530pm in 2017, which was 2.5-4.5 hours before closure of the event, in daylight hours, at 8pm.
LoveBox and Field Day will probably be at 40,000 capacity when the headliners finish at 11pm. It has been stated that Brixton Tube will be the transport hub, and it will not be possible for festival goers to enter via any other route. This implies that the same might be true for exit. The exit is approximately 5m wide. The park naturally funnels people to the gate, and 40,000 people leaving through such a small gate could cause significant risk of crush, particularly in the dark or partially lit from mobile lights. Brixton Waterlane is one of the main thouroughfares around Brockwell Park, and is a busy road, with busy bus routes. Assuming that the road is not closed as the festival goers exit the park, there is significant risk of revellers getting in the way of traffic as they cross the busy road, which could result in serious injury.
At the Lambeth Country show, when gates were closed, significant numbers of people jumped over the metal spiked railings. The risk of serious personal injury caused by unrest would be a real consideration.
Police were called to control crowds getting in to Sunfall. It is likely unrest could break out after the event, when revellers have been drinking in the sun all day get stuck in more queues. These above suggests there is a high chance of a public safety issue, which is unlikely to meet the objectives of the licencing act.
13 http://www.brixtonbuzz.com/2018/01/lambeth-councils-attempt-to-compare-lovebox-and-field-day-with-the-country-show-blown- apart-in-freedom-of-information-request/ 15/01/2018
Curfew times
Incidentally, During the signing off of the 2020 culture strategy, Councillors were provided documentation responding to questions they had received. In Appendix C "noise engamgnet issues "Would like to have clarified curfew times" was asked. The response was "EventLambeth are looking to licence the 5 key parks and open spaces so there will be established curfew times – it is likely that these will be in line with events currently taking place in the parks or open spaces." (See page 4 here. Plenty of other interesting comments https://moderngov.lambeth.gov.uk/documents/s83310/01e%20Noise%20Engagement%20Key%20Issues .pdf). This comes from appendix c here https://moderngov.lambeth.gov.uk/ieDecisionDetails.aspx?AIId=30342
In 2016, when the above was conversation was happening the latest curfew in Brockwell Park was 9pm for the Found Festival (and 8pm for the Lambeth country show). https://www.residentadvisor.net/events/783375. The latest events are proposing to close at 11pm.
The curfew times of 11pm cause a public safety issue, as the park will be dark, and it would be much harder to monitor crowd safety issues than at the likely curfew times intended in the original policy sign off with councillors.
Prevention of Public Nuisance
There are many public nuisances likely as a result of the festivals, but here are some we can highlight.
Noise (including stress and sleep disturbance) Anti social behaviour Loss of amenity of local shops Loss of mobile phone coverage
Noise
“Businesses that endanger the public and/or seek to profit at the expense of neighbours or a locality are not welcome.” Lambeth Statement of Licencing Policy.
“Proximity to residential accommodation is a general consideration with regard to the prevention of public nuisance. The Licensing Authority will treat each case on its individual merits, however, stricter conditions will generally be imposed on premises licences in areas that have denser residential accommodation or residential accommodation in close proximity to them. In such cases and where relevant representations are received, the Licensing Authority will have regard to the potential for, and the risk of, nuisance occurring to nearby residents” Lambeth Licencing Policy.
The Code of Practice on Environmental Noise Control at Concerts by the Noise Council. 14The Guide is a benchmark for avoiding noise nuisance from concerts, an objective of the Licencing act. “The purpose of this guidance is to give guidance on how such disturbance or annoyance can be minimised. The Code is designed to assist those planning a music event, those responsible for licencing such events, and those responsible for enforcing the nuisance provisions of the environmental protection act.”
This document is referenced in the Mayor’s ambient noise strategy for London15, and also in Aria Acoustics noise report for the Sunfall Festival. Whilst guidance, it is clearly a recognised document for best practice in industry. Failing to follow the guidance would need a significant explanation.
14 http://www.cieh.org/uploadedFiles/Core/Policy/Environmental_protection/Noise/NoiseCouncilCodeonNoiseControlatConcerts.pdf
15 https://www.london.gov.uk/sites/default/files/mayors_noise_strategy.pdf 15/01/2018
The general guidance suggests that fixed noise level targets might be acceptable for one or two events, when constrained within the levels suggested (65 dBA for urban venues such as parks), but for more than 3 event days, noise levels should be linked to the prevailing background noise levels.
The Code suggests that music noise levels should not exceed 65 dBA if 1-3 concert days are to be held in an “other urban venue” such as a park. A level of 75dBA is only acceptable for Urban Stadia or Arenas. It goes to state that 70 dB Linear in either the 63Hz or 125Hz octave band is useful to control low frequency noise.
The Code suggests where 4-12 event days per calendar year are planned, music noise levels should not exceed the background noise level by more than 15dBA over a 15 minute period (the Arithmetic average of the LA90 of the last 4 hours of the event). Personal Measurements I have made indicate that the background LA90 outside houses on Regent Road is approximately 50 dBLA90 at 10pm. This would imply a noise limit of 65 dBLAeq should be applied to music, and not 75 dBLAeq as is currently policy. A 10 dB increase is widely considered to be a doubling of sound pressure levels. The noise levels are almost certainly likely to cause Nuisance, thus not meeting the objectives of the Licencing Act 2003.
The Events strategy presented to councillors stated that curfews would be similar to those experienced at the time of consultation16. This was about 8 or 9pm for the LCS, not 11pm.
In addition, Lambeths events policy 17states that noise levels should not exceed 75 dBLAeq at the nearest noise sensitive facades. The monitoring positions chosen do not represent worst case noise levels. There should be an expectation to monitor at high level in Meath House, including background noise levels. For example, why was a location by a road behind the lido chosen which will be heavily screened? It is unlikely the noise positions were chosen taking into account the topography of the land.
Being Competitive vs caring about nuicance
Noise levels at Brockwell Park were shifted to be competitive with other major London Venues. “We are proposing to have the same sound levels as other places such as Hyde Park or Victoria Park. This means we can have events that will raise income for Lambeth that we can then use to reinvest into our open spaces. For instance a concert on Clapham Common has previously raised over a £100,000 that can then be reinvested into our local open spaces. However, these event organisers are going elsewhere and Lambeth is losing out on this income”.18
If you compare Brockwell Park to venues such as Clapham, and Hyde Park, noise mapping from Defra for the LAeq 16hr day indicates Clapham and Hyde Park are significantly noisier than Brockwell Park. The clear areas are less than 55 dBLAeq16hr (ie quiet) In comparing the pictures (same scales) thicker areas imply higher noise levels at their centre.
16 https://moderngov.lambeth.gov.uk/documents/s82617/Appendix%20C%20- %20Noise%20Engagement%20Key%20Issues.pdf
17 http://www.eventlambeth.co.uk/wp-content/uploads/2017/05/Guidance-for-Control-of-Sound-at-Outdoor-Events-2016.pdf
18 http://www.eventlambeth.co.uk/new-sound-guidance-2016/ 15/01/2018
The above charts are generated using http://www.extrium.co.uk/noiseviewer.html This data is a product of the strategic noise mapping exercise undertaken by Defra in 2012 to meet the requirements of the Environmental Noise Directive (Directive 2002/49/EC) and the Environmental Noise (England) Regulations 2006. The interpretation of the various metrics of noise can be quite technical, so these are largely presented to enable a simple comparison between noise levels at Brockwell Park compared to the venues discussed in Lambeths Consultation. The short answer is, Brockwell park is considerably quieter than the parks with existing high noise levels.
The code above suggests that for more than 8-12 event days, a condition linked to background noise levels (LA90) should be deployed, based on the average background noise levels in the last 4 hours of the concert. These are likely to be about 5 dB less than LAEQ, and so it would be likely that based on the map, 50 dBLA90 would be the likely background noise level, therefore a target of 65 dBLAeq MNL would be the recommended target to not cause disturbance.
Further evidence of annoyance comes from a DEFRA study19, which suggests that 24% of people who heard the music within 500m of the venue showed higher levels of annoyance. I’d estimate that this is half of the 45,000 people in the three wards around the park are within 500 m, so probably 5000 people would suffer annoyance. Does this constitute a statutory / public nuisance?
Lamebth’s event strategy says that all other events in the park will have lower noise levels. This was not the case for Sunfall, which did not meet the major event in terms of size.
19 http://randd.defra.gov.uk/Document.aspx?Document=NANR292SocialSurveyFINALreport_220311.PDF 15/01/2018
Mental Health and Nuisance
It is well documented that vulnerable groups such as those with mental health issues are more susceptible to nuisance and distress from noise. Fannon House 20is located very close to Brockwell park, and accommodation for those with “a diagnosed mental health issue, who need 24 hour support” and could be particularly disrupted by the events, maybe even leading to a deterioration in their recovery.
It is now widely recognised across public health bodies that access to quality green space provides positive benefits to mental health, and also fights obesity, for residents. Public Health England recognizes the need for protection of green space, for example gives an example intervention in its Prevention Concordat for Better Mental Health: Prevention 21 planning resource for local areas :
‘Create and protect green spaces within neighbourhoods to generate better physical and mental health outcomes for individuals and communities. Accessing green spaces can not only encourage physical activity but other benefits such as greater community cohesion and less social isolation; opportunities for meaningful volunteering experiences;’
Shift workers and nuisance / sleep loss
London has 450k night shift workers22, which corresponds to 5% of London’s population. If this were to apply to the 45,000 living in Herne hill, Tulse hill, and Thurlow park, then here would be around 2500 night shift workers affected by the festivals. This could range from 3 nights consecutive sleep disturbance, to inability to use key transport links such as Herne Hill Station. Many of these night workers could be driving trains, securing a building from harm, or operating heavy machinery, and so the sleep deprivation caused to this group over 3 days could have significant harms to society.
Equality
There is an equality issue worth commenting on also. Research has repeatedly shown that urban green spaces are particularly important to black and ethnic minority residents, who in many cases, find it harder to access nature in the countryside. The Design Council, for example investigated this issue in Urban Green Nation and Community Green. In summary research revealed:
‘in areas where more than 40 per cent of residents are black or minority ethnic there is 11 times less green space than in areas where residents are largely white. And the spaces they do have are likely to be of a poorer quality. Although where you live and the services you receive is intimately related to income, our research found a difference, by ethnicity, that was over and above what would be expected for level of income alone.’
‘Providing good-quality green space is a hugely effective way to tackle these inequalities. Green space has been proven to reduce the impact of deprivation, deliver better health and wellbeing and create a strong community. The simple presence of green space is related to a reduced risk of serious problems like depression and lung disease. Living close to green space reduces mortality, which can help reduce the significant gap in life expectancy between rich and poor.’
Page 8 of the footnoted document 23shows that the areas around Brockwell Park are in the highest category of deprivation in Lambeth (Q5).
20 https://www.homeless.org.uk/homeless-england/service/southside-partnership-fanon-care-fanon-house
21 Prevention Concordat for Better Mental Health: Prevention planning resource for local areas
22 https://www.tuc.org.uk/news/number-people-working-night-shifts-more-250000-2011-new-tuc-analysis-reveals
23 https://www.lambeth.gov.uk/sites/default/files/ssh-lambeth-demography-2015.pdf 15/01/2018
Other Nuisance
Loss of use of town centre amenities If 45,000 people arrive at the festival over 3 hours, that’s 250 people per minute. Assuming a third of these arrive at Herne Hill station, then most of the shops will be swamped, and over capacity, meaning its likely locals will not be able to gain access to supermarkets, cash machines, pubs, cafes etc. and locals are likely to stay away Apart from pubs and supermarkets, many businesses will lose out, and result in a loss of business, at a time when business rates are increasing, challenging further the ability for viable independent shops. Brixton Buzz have reported TFL/Network rail were concerned at the capacity of Herne Hill Station. It is likely that a large influx of people would mean the farmers market there every week might have to be scaled back or cancelled to allow safe throughout fare of the revellers. Severe disruption to mobile phone coverage During sunfall, the phone networks became saturated and it was very difficult to make or receive calls (including to the events complaints line!). Brining in 45,000 people will exacerbate this further. On a personal basis, this means I will not be able to phone friends or family during the festivals, making the locked in home even more isolated! This contradicts the governments it policy that every home should be connected. Any festival should include consideration to brining in additional temporary mobile phone masts to accommodate the additional traffic for festival goers.
Rubbish, urination and other disturbance in streets and estates
Councillor Peck of Tower Hamlets stated large festivals in Victoria Park had generated “A HUGE volume of rubbish along the ingress and egress routes that required constant clearing by the Council” and “Anti social behaviour that ranged from bottles being thrown into gardens, people knocking on doors to use the toilet, people having sex and taking drugs round the back of blocks of flats etc” See quote at end.
Transport severely disrupted Herne Hill station will be severely limited in use by the festivals as confirmed by LoveBox, as the stations cannot safely be used for both ingress and egress with the volumes proposed. As the festivals are proposed on both weekend and week days, it will be very difficult to leave the area. If there are no road closures, buses may be able to operate the opposite direction to people flow, but is is likely to be very difficult for residents. Car Parking for the Lambeth country show usually requires roads near the festival to be cleared of cars, with very little warning (e.g. 3 days last time). Many people had chosen to avoid the country show and leave on holiday, but as there was no notice of having to remove their car at the point of departure on holiday, their car remained unmoved, and they were fined. Roads such as Regent Road have traffic calming islands, and so there is no benefit to removing parked cars to enable emergency vehicles to move down these roads, as the roads are already restricted. For residents remaining at home when the events are on, they will be blighted by 1) Outside space at nuisance noise levels 2) Windows being closed at the height of summer, likely to cause overheating within some dwellings 3) Loss of amenity of the local town, due to significant numbers crowding out the town 4) Anti-social behaviours in their home town, including urination, drug taking, and sex in public 5) Limited mobile phone use for those nearest the park 6) Significant impacts vunerable groups and shift workers. The cumulative nuisance of these factors will be VERY significant, and unlikely to comply with the objectives of the 2003 licencing act
15/01/2018
Protection of Children from Harm
The usual licencing objectives concern “small” venues, and as such, focus on activities in the venue, not the wider area for the protection of children from harm. I suggest however that the objective needs to also consider the impact of bringing 40,000 people to the area who’s target demographic has a history of inappropriate behaviour.
Casual drug use and antisocial behaviour being normalised
As already alluded to, there have been a number of public drug and violence offences in the park associated with existing festivals such as Found and Sunfall. Park users will be exposed to this antisocial activity including vunerable groups such as children, or those with mental health issues, such as those living at Fannon House (see noise nuisance section). As these events become part of the fabric of Brockwell Park, children living in the area will become normalised to these, which will have an enormously detrimental effect on their mental wellbeing.
Degradation of air quality Lambeth has amongst the most polluted sites in London, particularly in Brixton, 24close to Brockwell Park. This has recently been consulted on in Lambeth’s Air Quality Action Plan (AQAP). This highlighted Brixton Hill, Half moon lane, Dulwich Road, Norwood Road as key focus areas. These are basically the major boundaries of Brockwell Park. “Air pollution particularly affects the most vulnerable people in our society: children, older people, and those with heart and lung conditions, who are all classed as sensitive receptors.” “Ensuring adequate, appropriate, and well located green space and infrastructure is included and protected in developments The Lambeth Air Quality Guidance Note includes a reference to Section 9 of the current Lambeth Local Plan regarding Green Infrastructure” To power 8 stages, and food and beverage outlets to feed 45,000 people a day, mobile diesel generators will be brought to site. Many large HGVs and vans will be brought in, plus additional transport. Food and beverage is likely to produce smoke and increase particulates. Therefore Brockwell Park, surrounded by 4 Air Quality Focus areas, does not seem an appropriate location for this.
24 http://www.bbc.co.uk/news/uk-england-london-38529928 15/01/2018
Other Factors
Damage to park
Brockwell Park is also designated a site of borough importance for nature conservation, and is designated metropolitan open land. According to the Lambeth Open Space Strategy Addenda (prepared by URS Consultants, 2013), linked below, Brockwell Park is designated as a major park, a 70-80 quality score (the highest standard), the least vandalism, but is in one of the most deprived areas (lowest score, 0-20 percent bracket). https://www.lambeth.gov.uk/sites/default/files/LambethOpenSpaceAddendaFinaPt2l2013Maps.pdf If the weather is wet, there is likely to be significant damage to the park, to the grass, and wildlife. Festivals do bring considerable damage. I would like to hear how Lambeth have inspected other parks, such as Victoria Park and Hyde Park, to compare the damage there, especially when Lambeth’s plans consider the site of borough importance for nature conservation.
Significant investment has been made by heritage lottery funds to improve the drainage in the park, but the area is still significantly muddy. Would 45,000 people jumping on the land cause compaction, and possibly damage the drainage? Would tree roots become impacted and therefore damaged? It is also worth noting that at the last large festival in the park, Sunfall, several benches were vandalised, as was the model railway, and at 1am after sunfall, a car crashed at high speed into the railings by the lido, which have not been repaired since, leaving lasting damage (most likely associated with a sunfall reveller or worker).
Biodiversity Duty
There is a duty on local authorities to take account of biodiversity in local plans and services, as specified in Section 40 of the Natural Environment and Rural Communities Act 200625.
‘Public authorities should consider how wildlife or land may be affected in all the decisions that they make.’
Brockwell Park is a Site of Importance for Nature Conservation (SINC) Borough Grade 1 in Lambeth’s local plan. The entire park is designated and the Biodiversity duty unquestionably applies. Further details in the foot note. Lambeth has not taken account of this in the events strategy, and with no mention of ecology in the current proposals for Brockwell Park.
26 Lambeth describes Sites of Borough Importance for Nature Conservation on its planning policy website.
‘These are sites which are important on a borough perspective in the same way as the Metropolitan sites are important to the whole of London. Although sites of similar quality may be found elsewhere in London, damage to these sites would mean a significant loss to the borough. As with Metropolitan sites, while protection is important, management of borough sites should usually allow and encourage their enjoyment by people and their use for education. Further information on SINCs can be found in our Local Plan, in particular policy EN1.’
Lambeth appears to be proposing two events which would cause damage to Brockwell Park, hence in its own words initiating a significant loss to the borough. Even more significantly, the proposals being considered deny access to a substantial portion of this site, an even more significant loss to the borough. As highlighted earlier in this report, the area is in the 90th percentile of most deprived areas of the UK, measures include quality of the natural environment.
25 https://nbn.org.uk/news/guidance-on-the-biodiversity-duty-for-public-autho/
26 https://www.lambeth.gov.uk/planning-and-building-control/planning-policy/list-of-planning-constraints 15/01/2018
Protection of wildlife species by Law
There is abundant wildlife in Brockwell Park, as noted in Lambeth’s nature trail leaflet. 27 Local MP Helen Hayes is a Species champion of the Pippistrelle bat 28. Bat species recorded in the park include Pippistrelle, Noctule, Daubentons, Leislers, and Serotonine, all of which are from protected by law from disturbance.
Bird species recorded include House Sparrow, Nuthatch, Great-spotted Woodpecker, Green Woodpecker, Goldcrest, Common Whitethroat, Blackcap, Chiffchaff, Greenfinch, Chaffinch, Whinchat, Common Redstart, Redwing, Meadow Pipit, Peregrine Falcon, Kestrel, Hobby, Sparrowhawk, Swift, Swallow, House Martin. All of these are protected from disturbance during their nesting season (peak period February to July), legally protected until August.
According to Government guidance,
‘These activities can affect wild birds, particularly during breeding season:
• trimming or cutting trees, bushes, hedges and rough vegetation • renovating, converting or demolishing a building • creating disturbance, eg noise, lighting and vibration’
Capacity and Seasonality
We already have one major event regularly held in this nature site of Borough importance. The Lambeth Country Show, while causing some damage, is to a certain extent appropriate for this site, this is because:
It promotes access to nature: It gives all our city children and adults a rare chance to encounter farm animals, horses, horticulture, plants, wildlife charities, vegetable personalities, falconry and bee hives. It is freely open to all It is held relatively late in the year, in July. This allows a certain range of wildlife to get through the active spring element of their lifecycle, including birds fledging, and grasshoppers hatching and mating. It was previously held in August, which is to be honest, a better time for it. It does not involve any disturbance at night (8pm curfew).
The Value of the park – from the Mayor’s natural capital report
The value of parks have been calculated per head in London. Assuming that for the 45,000 people that live in Herne Hill, Tulse Hill, and Thurlow Park benefit from Brockwell Park, the value the park generated for locals, from the natural capital report is below. I have calculated a prorated value for the park based on a loss of the park for 41 days and 6 days.
Value per person Annual Value for Pro-rated for loss of park Pro-rated for loss of per year 45,000 population for (41 days) park for (6 days) Physical Health £67 £3,015,000 £338,671 £49,562 Mental Health £42 £1,890,000 £212,301 £31,068 Recreation £120 £5,400,000 £606,575 £88,767 Total £229 £10,305,000 £1,157,548 £169,397 https://www.london.gov.uk/sites/default/files/11015viv_natural_capital_account_for_london_v7_full_vis.pdf The report also discusses the impact of parks on property values.
Value per person Annual Value for Pro-rated for loss of park Pro-rated for loss of per year 45,000 population for (41 days) park for (6 days) Property uplift £410 £18,450,000 £2,072,466 £303,288
27 https://brockwellparkcommunitypartners.files.wordpress.com/2014/02/brockwell-park-leaflet-wildlife-final.pdf
28 http://love.lambeth.gov.uk/batwalk/ 15/01/2018
Appendix: Councillor Josh Peck, Victoria Park
Thanks for your email and apologies for the delay in replying.
You’re not the only person from Lambeth to have been in touch – it’s been a steady flow so I appreciate the concern.
Whilst I totally understand the financial predicaments of councils who have had their budgets slashed by Central Government, I’m afraid I can’t in good conscience recommend Lovebox to residents of South London or their Council.
IN my view, a festival of this size is simply too big to be held in a residential area without causing some substantial impacts to local people. Even if the operator were fully on top of these impacts – which Lovebox never were – I don’t think they could have been fully reduced to an acceptable level. My experience of Lovebox was that, despite good intentions and some good people:
- Consultation with local people was cursory and did not always feed through to real changes in operation - Measures agreed in any one year (like stewards in particular locations) would not make it through to subsequent years, so residents and councillors had to spend an inordinate amount of time going over the same ground with Lovebox - The stewarding was of a very variable quality outside of the site, with a very limited number of fully accredited stewards and most of the ‘crowd control’ done by poorly trained, inexperienced young people who did a poor job – for example, I saw four stewards playing football with festival goers one evening as people sat in front gardens right next to them – precisely what they were there to stop - Noise impacts were variable – generally much better after a lot of work by the Council in early years, but could be bad if the weather conditions were wrong - A HUGE volume of rubbish along the ingress and egress routes that required constant clearing by the Council - ASB that ranged from bottles being thrown into gardens, people knocking on doors to use the toilet, people having sex and taking drugs round the back of blocks of flats etc - Pretty consistent damage to the grass in the park which didn’t really reseed until the Spring, just before Lovebox was due back
Sorry that’s not more encouraging but I’m afraid I came to the view that we were better off without, despite having started off as a patron of Lovebox originally.
All the best
Josh
Cllr Joshua Peck 07887 990 735
15/01/2018
Brockwell Park Community Partners
Proposals for major festivals in Brockwell Park: Field Day (June 2018) and LoveBox (July 2018)
The Brockwell Park Community Partners has consulted its stakeholders and members of the public as to their opinion on these festivals. The response has been broadly against such large paid events taking part in Brockwell Park.
Paid-for music events have been taking place in Brockwell Park for some years now, largely for audiences up to 20,000 people and most have been attended by problems including damage to the park, littering, drug dealing, anti-social behaviour, crowd control and disruption of ordinary park activities, all of which have been reported by us to Lambeth Events. The current proposals for three-day events for up to 40,000 attendees represents a step-change in the size of the events and the impact on the park.
A lot of the opposition to these events is related to the effect of large paid events on the wider community, on local access to shops and other amenities, on anti-social behaviour and crime and although our remit is Brockwell Park, we cannot ignore these concerns. The park is at the heart of this community and there is an overlap between damage to the park and damage to the community. At present, although there may be additional funding for the park, there appears to be no benefit from the events to the community as a whole.
As the proposals stand, the park will be more or less occupied by these events and the LCS for a period of nearly two summer months, at a time when people use it most.
The ordinary life of the park will become impossible; ordinary access to the park will be very severely restricted. The heavily- used path between Herne Hill and the Lido will be fenced off for some of the time, making access to the Children’s Playground, the Water Play Area and the Walled Garden and the BMX track and the Community Greenhouses much more difficult and forcing people to walk much longer distances to reach them. During set-up and break down, the park will be unsafe for small children and dogs because of vehicle movement. The Miniature Railway will be unable to function during this time; St Matthew’s Project will lose their football space; access to the Lido and the Lido Cafe will be restricted; there will be little space for informal games. We are very concerned that the new Sports Platform, that is now being well-used, will be swallowed up inside the event sites for the duration of both events. Both the surface of the platform, which is not suitable for heavy use and the table tennis table, which has been bought and installed by the community, will be at risk of damage.
Although the event site for each of the events, Field Day and Lovebox will occupy around one third of the park, when the access space is added in and the fact that some areas of the park will be marooned behind the event site and inaccessible, then the loss of space is much larger and more significant.
It is well-recognised that access to open green space is an essential component of wellbeing. People living locally, especially on the western side of the park, very often do not have outside amenity space and loss of wide areas of the park to ordinary use will be a serious deprivation for them.
The overwhelming view of our respondents is that park is simply not big enough for such major events where the attendance is concentrated in one site and cannot spread out.
The park’s topography does not suit the organisation of these large events. The events structures are visible from most areas of the park and from outside and the fencing and stages are highly intrusive. The hilly nature of the park makes sound carry further. Events therefore strongly affect all the park, park users and anyone living close by. Even events judged to be small cannot be ignored; their impact is huge.
For many of our correspondents the experience of significant problems caused by relatively small events leads them to conclude, justifiably in our opinion, that larger events will generate larger problems and will strain the ability of existing systems to cope.
Following the Found Festival in 2015, which catered for between 15-20,000, there was concern by the Police about inadequate stewarding of the large numbers of people leaving the park at the end of the event and of dangerous overcrowding at the Herne Hill gate particularly. For up to 40,000 people to leave the park more or less at the same time raises the possibility that there will be similar problems of overcrowding at this gate and at the Brixton Water Lane gate which may be very difficult to control. At the Sunfall Festival this year there were serious problems of crowd control caused when people were queuing for admittance to the event site such that the Police had to take action. We have no guarantee that “gates” of up to 40,000 people can be handled any better.
Anti social behaviour has been experienced in the park at all earlier events. With larger audiences, this may well reach levels that are very difficult to control. At the first Found Festival poor stewarding of the park led to widespread littering and misuse of the park, drug taking and drunkenness over a wide area of the park (festival go-ers knew they would be searched for alcohol/ drugs on entry to the site, so took drugs and drank excessively before they went into the event). At one point someone brought an SUV into the park, parked upon one of the paths and dealt drugs from the back without anyone trying to stop them. At the Sunfall event the security people hired by the company were not very engaged in controlling the behaviour of their audience which was potentially very dangerous both to park users and the festival go-ers. 15/01/2018
We are also concerned that people attending a three day event may well try to sleep in the park overnight with the problems that this will generate.
There will be damage to the park; this is inevitable. The park is a living space; it will not easily or quickly recover from damage and protracted ill-use.
The Sunfall Festival and the recent Fireworks demonstrated that it is impossible to prevent damage occurring during set-up and break down, although in the case of the Fireworks, the providers were very conscientious. Many of the drivers who bring large equipment to the park are commissioned at the last moment and have no knowledge of the park or of any of the arrangements made for its protection. It is clear that when drivers are faced with numbers of people using the paths they tend to veer off onto the grass, for safety reasons and this can wreck the greensward. This does not recover easily and much park staff time is devoted to analysing the damage and attending to it. A number of our respondents took the view that £15,000 is not a sufficient sum to be set aside for restoration of damage. Tracking really should be fitted for all events but this is expensive and event providers are often unwilling to put in extensive protection for the grass.
The BPCP has worked with the Friends and others for many years to improve the biodiversity of the park, succeeding in turning a desert of municipal greensward into an enriched environment for many species. The Brockwell Hedge, the wildflower slope (at the Lido) the Community Greenhouses garden, the pollinator garden at Norwood Lodge and the meadow on the Cressingham ridge are all examples of investment in biodiversity by the Parks Team and volunteers. The park now hosts many species, including house sparrows and stag beetles (which are both on the endangered lists) , many amphibians, bees, dragonflies and unexpected species of birds. This year the parks has been visited by a pair of swans who raised a brood of cygnets on the main pond.
Large crowds, large vehicle movement and the kind of major noise and crowd disturbance that will accompany these major events are inimical to wild life and the volume of attendees is something that urgently needs to be reconsidered.
We know that councillors are all aware of how much people value and need their local open spaces and I hope that you will be prepared to reconsider these proposals and take action to protect the community and the park. The formal policy of the BPCP, agreed at a general meeting is that there should be no more than two major events a year in the Park, including the Country Show. In addition, we are very concerned that future planning for the park, in particular, the proposed restoration of Brockwell Hall, is compromised by demands generated solely by events.
Ann Kingsbury, Derek Hoare, Susy Hogarth, John Gahan on behalf of Brockwell Park Community Partners (Brockwell Park MAC)