Object to a loud dance music festival at the Waterworks!
If you think, like we do, that a festival that aims to ‘deliver the volume and sound pressure proper dance music deserves’ is inappropriate next door to a nature reserve then we encourage you to object to the licence application made by Waterworks Ltd by 10th March.
You can see the licence application here: https://drive.google.com/file/d/19-1i5VBpBtNURWx29IQ7C3rScYmH0_Hj/view.
You can use the sample objection below or you can write an objection of your own. If you do the latter, please remember to focus on the four key grounds on which the licence will be decided, namely:
- The prevention of crime and disorder.
- Public safety.
- The prevention of public nuisance.
- The protection of children from harm.
Please note that you must include your full postal address for your objection to be considered.
Sample ObjectionLicensing Service
3 The Square
To whom it may concern,
I should like to make a representation in response to the application for the grant of a Premises Licence at Lammas Road, Leyton, London, E10 7NU, by Waterworks Event Ltd.
The reference number for the application is
I live in [Walthamstow] but spend much of my spare time in the vicinity of the Waterworks Centre, the ‘premises’ in question.
I wish to object to the application and to request that the application is turned down. My objection is on three grounds:
The prevention of crime and disorder
Under Section 1 (5) of the Wildlife and Countryside Act 1981, it is an offence to intentionally or recklessly disturb any wild bird included in Schedule 1 of the Act while it is building a nest or is in, on or near a nest containing eggs or young, and it is an offence to intentionally or recklessly disturb dependent young of such birds. There is no doubt that the noise from the festival will disturb the birds at the Waterworks Nature Reserve. The Lee Valley Regional Park Authority states on its website that the following birds, all listed in Schedule 1, can be seen at the Waterworks Nature Reserve: Green Sandpiper, Wood Sandpiper, Black-tailed Godwit and Kingfisher: (https://www.visitleevalley.org.uk/en/content/cms/nature/nature-reserve/waterworks-nature-reserve-midd/wildlife/).
The Lovebox Festival held in Victoria Park in 2012 – one of whose organizers (Julian Butterfield) is also an organizer of the Waterworks Festival – had an average of 192 police officers and drug detection dogs on duty each day.
Yet, according to the Metropolitan Police,
despite the large number of police and private security personnel and resources used to police Lovebox […] there were 452 recorded offences over the three days of the festival.
This represents an unacceptable level of crime that cannot be tolerated.
Most of the offences related to theft and drugs:
One of the reasons for the increase in the number of thefts is the targeting of festivals in general and Lovebox in particular by international criminal gangs. Their sole intention when coming to these festivals is to steal as many mobile phones and other high value items as possible. They arrive in London prior to festivals taking place where they are provided with tickets before entering the venue and start to commit thefts on an industrial scale.
Lovebox attracts drug users and where there are drug users there are people that supply then. This means that drug dealers will attend Tower Hamlets with the sole intention of selling drugs to those attending Lovebox. Drug dealers will not limit their selling of drugs to those attending Lovebox, they will sell to anyone who wants to buy them. With one of the largest youth populations in the country this represents an unnecessary risk of drugs bring [sic] sold in Tower Hamlets.
There is nothing to suggest the Waterworks Festival will be immune from the criminal gangs that targeted Lovebox, as the two festivals are very similar in nature. (Quotes from http://democracy.towerhamlets.gov.uk/documents/g4248/Public%20reports%20pack%2011th-Jun-2013%2018.30%20Licensing%20Sub%20Committee.pdf?T=10, pages 61–72 of the PDF.)
It is unlikely that ticket holders will want to stop partying at 23:30 and with so much green space nearby there is a very real danger of informal and illegal raves springing up on nearby Hackney Marshes, Leyton Marshes and Walthamstow Marshes. These will carry on late into the night, will cause significant damage, will be a magnet for the drug dealers and other criminals already at the festival as well as local opportunists, and will be difficult to police given the lack of lighting and CCTV cameras.
Many ticket-holders are likely to leave the festival and head home along the canal towpath. There have been a spate of serious muggings along the canal in recent years and people have also been raped on the marshes. These are serious offences that will have a long-term effect on the victims. While many people would normally avoid the canal towpath and the marshes at night, alcohol, drugs and the fact that they have spent the night enjoying themselves on the marshes may cause revellers to let their guard down and put themselves at significant risk.
Section 18 of the application form asks the applicant to describe the steps they intend to take to promote the four licensing objectives. Yet the application seems to do nothing more than state the current legislation regarding the licensing objectives. It does not explain, for example, how it will manage ‘door supervision’ at a site that does not have any doors. It does not explain how ingress and egress will be managed and how theft will be prevented. It does not say how many staff will be at the entrances and exits or how organisers will ensure that no one under the age of 18 is served alcohol and that beverages purchased on the premises are not consumed outside the premises.
It seems to me that Waterworks Ltd has given little or no thought to any of these issues. This is in marked contrast to the detail they have provided about the genres of music that will be playing. This suggests that the applicant is focused on the music and not on managing the event to ensure crime and disorder are prevented, that there is no public nuisance and ticket-holders are kept safe at the event and afterwards.
The prevention of public nuisance
The application is for a period of three years, from 22/8/2020 to 28/8/2022, and sets a precedent for turning an open green space used by local residents into ‘premises’ for live music. If one application is granted, more could follow, and the impact of the noise and light pollution on local residents will be significant.
In its event advertising, Waterworks Ltd says,
Unlike many other London locations we are remotely situated in relation to our nearest residential neighbours which will allow us to achieve unparalleled sound quality.
It also states that it will,
deliver the volume and sound pressure proper dance music deserves; we are confident of levels that are unparalleled in east London.
The implication is clear: the organisers want this event to be very loud indeed.
And it will need to be if music from five different stages is to be heard by five different audiences in such a small space.
Yet the site is not remote and many, many people will be disturbed by the music.
The one-day Holi Festival that took place on the site in 2018 was extremely distressing for local residents, who spent a day disturbed by loud music and DJs swearing.
It is also quite common for people living in Walthamstow to hear concerts taking place in the Queen Elizabeth Olympic Park if the wind is blowing in a certain direction.
Sound travels in this part of London, and this particularly loud event will disturb a huge catchment area for three days each summer.
Instead of spending three days with the windows open enjoying time outside in nature on the marshes, many local people will be shut inside their homes with their windows closed.
The application mentions a
Looking at the map submitted with the application, the boundary of the ‘premises’ appears to abut the eastern, southern and western boundaries of the site blocking the well-used public footpaths used by walkers and cyclists. It is unclear, from the application, how many days people will have to find alternative – and perhaps more dangerous – on-road routes to go about their business.
In a borough that has declared a climate emergency, it would seem sensible to extend the definition of ‘public’ to the environment. The site is next door to the Waterworks Nature Reserve and is designated as part of a Site of Metropolitan Importance for Nature Conservation (SMINC). If the noise and light pollution will be significant nuisance for human neighbours, it will be catastrophic for neighbouring wildlife, particularly birds. This is simply an inappropriate place to hold a one-off one-day music festival, let alone an annual three-day event.
The Walthamstow Marshes Site of Special Scientific Interest (SSSI) is very close to the proposed ‘premises’ and birds particularly will be seriously impacted by the noise coming from the event. Walthamstow Reservoirs, another Site of Special Scientific Interest (SSSI), a RAMSAR site and part of the Lee Valley Special Protection Area (SPA), is not in the same close proximity but birds will be affected by the noise and light emanating from the event. An SPA is a protected areas for birds, classified under the Wildlife and Countryside Act 1981 (as amended) and the Conservation of Habitats and Species Regulations 2010 (as amended) in England, Scotland and Wales, and an event that is likely to cause significant harm to a protected site, as this event surely will do, should not be permitted.
Although the licensing process is not directly impacted by the London Plan, it is important to note that Policy 7.19D of the current London Plan makes it clear that proposals
should give the highest protection to sites with existing or proposed international designations (SSSIs, SPAs and Ramsar sites)
give strong protection to sites of Metropolitan Importance for Nature Conservation
Granting a licence for a loud music festival would be at odds with this strategic proposal.
There is nothing in the application that suggests Waterworks Ltd has given robust consideration to the issue of public safety, particularly whether the site is large enough to accommodate 14,999 people. The map shows five stages squeezed into a relatively small area, presenting a very real danger of overcrowding and consequent crush injuries.
For these compelling reasons, we kindly request that you refuse to grant a licence to this application.
[Your name and full postal address, with postcode]