Hello,

I would like to object to the proposed festivals in Brockwell Park, and in particular, , mighty hoopla and other day of festivals. I am concerned about the loss of amenity to enjoy my home that these festivals will bring, nuisance to myself, my family and the local area, damage to the park, and further degradations to air quality. According to the 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). It is a much loved, and much needed community asset.

The key issues are:

• Loss of over a third of the park for at least 6 weeks (from Field day and Lovebox combined), causing loss of a valuable resource for health and wellbeing, mental health, play/learning activities for children, and meeting of the local community.

• Degradation of air quality in 's second most polluted borough, from diesel generators required to power the festival, cooking for attendees, and transport of 45,000 people per day.

• Damage to the park from both ticket holders (particularly if it is a muddy day), HGVs loading stages and equipment, rubbish, and vandalism, (cf broken benches, and damage to model railway at Sunfall).

• Nuisance varying from noise at levels known to cause disturbance (cf Code of Practice on Environmental Noise Control at Concerts), urination in local’s gardens and green space, public drug use (cf N02 debris from Sunfall)

• Changes to noise levels in the parks were not properly consulted, and most residents are unaware of the change. The events strategy is to have 8 events in the Zone, which previously would have included events such as Come Together and Brixton Splash elsewhere in the Brixton zone. All events are now being concentrated in one part of the borough, giving an extraordinary burden on a small portion of residents.

• Loss of use of town centre amenities due to saturation of 45,000 people. For example, can the Sunday market function when 45,000 people may be trying to reach the park from Station?

• Severe disruption to mobile phone coverage – during Sunfall, phone coverage was very patchy due to phone mast saturation (not being able to cope with increased demand of people)

• Access issues; getting home from work will be very challenging. Brixton Buzz have reported that TFL and Network rail have raised concerns about Herne Hill Station and Brixton Station’s capacity.

• Field Day have expressed a desire to use Brixton Waterlane as a primary entrance to the event. Pavements are approximately 1m wide, and so if 45000 people arrive over 3 hours, that’s 250 people per minute entering the gate, which is unfeasible.

• Brockwell Park is also designated a site of borough importance for nature conservation in Lambeth’s own plans. Damage to wildlife in the park from noise, litter, compaction of tree roots and soil (which may also add to drainage issues in the park later in the year).

• The daily festival capacity of 40-45,000 is equivalent of the population of the Herne Hill (15k), (15k) and (13k) Wards combined, and is simply not appropriate for the facilities.

I do not believe Brockwell Park is a suitable size or location to hold the event in question, and do not believe Lambeth have fully conducted a proper impact assessment. One or two events of a much smaller scale such as Found can operate safely in the park, raising revenue, without causing an unacceptable level of loss of amenity. But this scale is far too large for a small park in a residential area. Overleaf, I have provided more information on these issues.

Yours, Rory Huston

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Personal Loss of Personal Amenity I have a toddle and a newborn. I live in an ex-local authority house with a flat black roof, with no insulation in it (same for half of regent road, many of whom are council tenants). During the summer, if the windows are closed, the house can easily get up to 30 degrees on the upper floors, which are not safe sleeping conditions for children. We manage this by keeping the windows open during the summer, which allows cross ventilation, and controls noise to acceptable levels. During the Sunfall Festival, our toddler was unable to sleep during much of the festival because of noise, causing significant stress; either a leaving children (I have two now) in unsafe hot conditions, or no sleep, meaning a very unpleasant day. We cannot afford to go away, so having 6 days like this offers considerable stress loss of amenity. In our street, there was significant evidence of drug use after the festival (nitrous oxide canisters), and I witnessed many people urinating on grass areas in and around the Meath estate where I live. When challenged, the response was basically where else am I meant to go? Probably with an expletive thrown in for good measure. This antisocial behaviour also means I do not feel the public square outside my house is a safe place for my children to play, due to the activities witnessed, so I am very much confined to a hot house. With a doubling/trebling of numbers, at the field day series of festivals, the level of antisocial behaviours can only be expected to grow, leaving to further nuisance and loss of ability to enjoy my home and surroundings. We also use the park for exercising our dog and children. It's a safe environment for our children to exercise and run free. The area where the old changing rooms sit is used as an impromptu after school club for at Jude's Primary in Regent Road, so this area is a natural draw for kids this side of the park. This is great for children’s learning, and also for parents wellbeing by being able to form supportive bonds with other parents. This will be lost for 6 weeks, detracting from opportunities for communities to meet, for children to play together, slowing their development. I have heard rumours albeit unsubstantiated, of a child stepping on a hypodermic needle after Sunfall, piercing her foot. If true, this is alarming indeed.

Value for money for residents The daily festival capacity of 40-45,000 is equivalent of the population of the voting wards surrounding Brockwell Park, Herne Hill (15k), Tulse Hill (15k) and Thurlow Park (13k) Wards combined, and is simply not appropriate for the facilities available, such as access, travel, shops, toilets etc. In 2017, Sunfall paid a £10,000 Park investment Levy, for 20,000 people (source: FOI request). E.g. 50p per person. Field Day is offering between £32,000 and £52,000 depending on the success of the event. It’s therefore likely that 3 weeks of disruption will generate approximately £1 per person who live in the surrounding Herne Hill, Tulse Hill and Thurlow Park Wards. This is very low. Is this a big number? Some comparisons; annual council tax varies from £873 to £2,620 per annum in the borough. The £1 represents 0.03-0.1% of your council tax. Would you notice a tenner change? Probably not. Lambeth reportedly paying £104M for a new headquarters for its staff in Brixton. Interest on £104M at the Bank of England Base rate of 0.5% would be £526,000 per annum. It would seem the revenue generated is very small in comparison to other major expenditure choices and revenue raising opportunities. Scaling back on these would be more logical.

Access to the park “We all know that regular physical activity and cultural stimulation contributes positively to emotional and mental wellbeing by preventing and reducing stress, anxiety and depression. So we want to make the most of the borough’s cultural, physical and sports assets to help local people live healthier, happier lives.” Quote from the 2020 consultation documents

Parks provide mental health and exercise benefits, that help avoid around £952m of avoided healthcare costs each year (reference the mayor’s recent natural land accounting report), and higher figures for value indicated by residential prices. The area around the lido is a beacon for fitness in the area, with regular park runs, outdoor exercise classes, joggers, cyclists, Tai chi and dog walkers all extensively using the area where festivals are proposed. Consultation forms have stated that the set up of the festival will take up 35% of the park for 2 weeks before and 1 week after the event (a total of 6 weeks, if LoveBox is also considered). Lambeth's own reports state that the area is in a top percentile of places deprived of natural space, so this will further increase that deprivation.

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Degradation of air quality Lambeth has amongst the most polluted sites in London, particularly in Brixton, close 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.

Damage to the 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).

Nuisance: Noise I am concerned about noise. The event noise levels, whilst controlled to Lambeth's noise limits, were very disturbing at the last dance music festivals in the park.

The typical noise level close to the gardens in the park is around 55 dBLAeq (15 mins), and the noise levels from the festival are set at 75 dBLAeq (15 mins). This is 20dB above background. A 10 dB increase in noise is considered a doubling of noise level.

The code of practice on environmental noise control at concerts can be found below, and is widely considered the industry benchmark. http://www.cieh.org/policy/noise_council_environmental_noise.html This suggests that for urban venues such as our park, if there are 1-3 event days per calendar year, the music noise level should not exceed 65 dBA over a 15 minute period at facades, or significant nuisance is likely to be experienced. Lambeth’s policy is 10dB above this, subjectively doubling the noise level. If there are 4-12 events days per calendar year, the guidance suggests the music noise level should not exceed the background noise level by more than 15 dBA over a 15 minute period. There is no evidence that noise surveys around Brockwell Park's surrounding residential facades have been conducted to enable these noise limits to be set. Lambeth have based their noise limits on experience of Common, which has an entirely different topology, residential profile etc.

One day of this, whilst stressful, does allow time to recover from the stress. Three consecutive days does not allow a day or even an evening of recovery before the return to be working week. This will have a detrimental effect on mental health and as such productivity if workers resident in the area. With this in mind, it is clear that any festival in the park will be causing a nuisance, and the three consecutive days proposed even more so.

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I would also criticise the noise monitoring positions chosen in Lambeth’s noise monitoring guide. The two locations near Dulwich Road are tucked away behind the lido, screened from the noise, and do not reflect the worst exposed facades. The stated intent of Lambeth’s noise policy is to limit noise at all noise sensitive facades to 75 dBA. The festival plans show significant stages will be on the hill, elevated possibly above the height of ground level noise monitoring positions near Herne Tower and Meath House. I would suggest that a noise monitor should be placed on a top floor balcony of Meath House and Herne hill tower, to ensure an unobstructed view if the festival to ensure the worst case noise exposure can be measured. There is an access point on Meath house between towers that is likely to be accessible.

The noise management strategy for the festival does not take into account the extent of the festival, or local topography, or comply with standard industry guidance, and therefore significant nuisance is likely to be caused.

Lambeth Culture 2020 Consultation / Brixton Zone – over saturation of one corner of the park The Lambeth 2020 Events policy allows 8 events in the Brixton Zone (there are 5 zones). I have lived in Herne Hill since 2012, and do not feel I have ever been made aware of the Culture 2020 consultation, and specifically how noise levels were raised. Many locals have stated similar objections in local meetings on this issue. I have submitted a FOI to ask how the consultation was conducted, and have not been given a satisfactory response. The premise of a zone also implies the impact of these 8 major events will be spread across the zone. At the time of consultation, events such as Brixton Splash and Come together existed. We are now seeing all events being concentrated at one corner of one park in the zone, making a severe impact on a group of residents. No Impact assessment appears to have been carried out. If all 8 events are to be brought to Brockwell Park, they should at least be distributed around the park to minimise the impact on residents.

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.

Access issues The event team from field day series said they would more or less use Brixton water lane for entry. The streets are approximately 1m wide (narrower in places, when bins and bust stops are taken into account). Assuming 45,000 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, 45,000 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. 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 , 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. The impact 45,000 people arriving at a festival will have significant impacts on the local community commuting from work. It will be very difficult to get home from Brixton station when the streets are full of revellers.

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