The Friends have submitted the following objections to the Licensing Sub-Committee today. If you agree with any or all of the objections, please submit your own objections by clicking on the above link. The Sub-Committee will meet on May 30. Thank you.
Friends of Trent Country Park
Submission of objections to Enfield Council Licensing sub-Committee; reference application by Mad Husky (51st State) event in Trent Country Park (TCP) – August 3rd 2019 – and thereafter.
Statement of Objections.
- Safety factors:
- The proposed commercial event calls for a license to admit 17,500 into the park for a whole day’s music and entertainment with alcohol. This number is very large in itself and represents a further and insupportable progression on earlier years.
- Furthermore, it is inconsistent with facilities in the park and neighbourhood such as to raise serious safety concerns for all. The park has no facilities to support major events (10,000+ attendees) Suitable access, emergency egress, refuges and shelter, road lighting, marked emergency exit trails are not available; pedestrian access, parking, paved footpaths and toilets are sized for regular visitor numbers only.
- LBE has progressed from permitting 10,000 attendee commercial events 4 years ago through 12,500, 15,000 and now 17,500 and is clearly proceeding with ever larger numbers which, given the lack of supporting facilities and the crowd carrying capacity of the neighbourhood, the Friends consider wholly unsustainable. The Friends deplore that LBE will not assign maximum visitor numbers to TCP based on objective risk assessments, but proceeds on an ad hoc basis. Residents, visitors and park users all deserve the highest safety standards and, because infrastructure is lacking, lives could well be put at risk.
- Trent Park was laid out as a gentleman’s estate with one 3m narrow gate issuing onto a paved entry road. This is the only paved entrance to the park for events, personnel and equipment. A separate 4m gate in the perimeter wire fence is opened to permit foot entry on events days; it is unpaved so visitors walk 800m over unprepared ground to the event which in wet conditions will be arduous and a risk in the event of any disturbance.
- The presence of 17,500 attendees places overwhelming weight on the two entrances. Orderly evacuation via these gates to Cockfosters Rd would take not less than 90 minutes, with high potential for injury or worse in the event of any disturbance. Egress is only onto the Cockfosters Road, and although this will be closed to traffic in the evening of the event, any rush to the park gate before then would result in chaos. There is no emergency Plan B because there is no practical alternative egress. Assurances from LBE of higher rates of evacuation are without objective substance.
- LBE has represented the wider park grounds as an escape route from the exhibition table, but the Friends find this totally insupportable given the wooded nature of much of the park combined with the likely condition of those fleeing an incident or disruption.
- The whole event plan depends solely on TfL operating the published service from Cockfosters Underground Station. In the event of closure at the station owing to service interruption or concern by staff at pressure on the station, crowds would pile up in the approaches and many visitors would of necessity have to remain in the park, probably in the dark as the event enclosure will stand 0.5 KM from the public road. In reduced daylight or darkness orderly egress is not conceivable since there is no lighting in the park – escape through the woods in the dark is not a tenable proposition.
- Access to the TCP site is primarily by public transport, via the Piccadilly line at Cockfosters. Dispersing crowds via trains that carry 600 persons each has proven manageable with gatherings up to 10,000, but was problematic at 15,000 in 2018 and is regarded as likely to stumble with 17500. Loading each scheduled departure to full capacity is not guaranteed by TfL because of the station layout which was never designed for such mass movements; assertions to the contrary by SAG are without merit. Passenger access to the station is intended by the 2 west stairways which are narrow, steep, with two turns into the underpass which is notoriously slippery when wet; the potential for accidents and worse is obvious when crowds press.
- LBE asserts that TfL has assumed responsibility for the service when it is clear TfL will do no more than operate a regular advertised train service: in the event of any incident on or close to the narrow west entrances to the station, or interruption to the service, TfL will follow its required procedure and close the station on safety grounds. There being no Plan B to disperse visitors, Cockfosters faces a huge gathering of disaffected persons with no obvious means of returning to London. Loose assertions that replacement bus services would be on hand are without merit and would not be commensurate with the press of passenger numbers. The Friends do not regard this as sustainable whatever non-binding assurances may be given by the Safety Advisory
- Clearly there has to be a match between the number of travellers converging on Cockfosters station that equates to its maximum carrying capacity. We observe that LBE is not willing to name that limit because it restrains its freedom of action to license ever larger events in TCP. Considering there is no other means of public transport available in the vicinity on the night we assert that 17,500 persons is beyond the safe capacity of Cockfosters public transport facilities and no evidence has been offered to allay this concern.
- Policing: In view of the potential for disorder and injury we now turn to plans for policing the event. We are not persuaded that police in adequate numbers are available for this event. Management of crowds is to be placed exclusively in the hands of casual marshals. The Friends submit this is carrying cost paring to extremes, and is an open invitation to disorder amongst the crowds typical of these events. Should there be a disturbance there is no way that marshals could contain the situation.
- We also learn that there is reluctance to commit to a significant and appropriate police presence because the number of warranted officers required is just not available owing to staff vacancies and other duties. If true, we hold this event must be resized to bring numbers back within the limits of the policing available. For reference, in 2018 the 51st State event of 15,000 attendees was policed by close on 30 warranted officers; this was by no means excessive coverage and compared unfavourably with police provision at other mass events we have examined. The Friends would not accept the inference that because fatalities have not occurred at events held in earlier years at TCP, policing can be relaxed.
- The Friends observe that events of this nature and size are housed for good reasons in arenas constructed on permanent sites with full infrastructure to support orderly ingress and egress, with all the emergency capabilities and facilities, trained manpower, surveillance and enclosures required to maintain control over crowds. Pressing unprepared sites such as TCP into use as cheap alternatives is bad policy nor is it even required; there is no shortage of arenas and stadia in London.
- We are told that Enfield Council’s Safety Advisory Group (SAG) has reviewed plans with Mad Husky and has no objections, so it can proceed to licensing application. The application is for a whole weekend for three further years. The Friends remain totally unpersuaded that the SAG offers any credible degree of protection to the public in this regard. This committee is constituted and chaired by LBE, which itself declines any responsibility for events. SAG is advisory only, not executive, and by its written remit is excluded from responsibility for any outcome arising from its advice. The Friends have no reason to believe the SAG has commissioned any independent study as to the carrying capacity of the park and neighbourhood, and is proceeding on an ad hoc best endeavours basis. That a gathering of 17,500 has passed scrutiny without a stipulation as to appropriate policing cover in the current high level of emergency threat awareness vitiates its whole stance and credibility; it is simply not performing in the public interest.
- The Friends re also highly concerned that this application by Mad Husky is for two days in future, only one day this year; the licensing committee should exercise all reservations in this respect, given the dilatory way this company has provided LBE with information on its plans, has overrun its timetable, has a history of poor financial management, and is constituted with no apparent financial or managerial reserves at all. We wonder how LBE could possibly encourage such a licensee and consider providing 3 years of licensing cover in view of such a record; we doubt LBE would entertain a park café license on the basis of such a record.
- Enfield Council is misdirecting itself in marketing its public spaces for ever larger commercial events without ever submitting the park for professional capacity assessment; it asserts it has no responsibility for events on public property, which the Friends regard as unsustainable in law, especially since LBE is a material beneficiary to the hiring of the site and licenses its use.
Enfield Council has a duty of care to the public which overrides short term income considerations. For a public entity, managing £1 bn of funds each year to assert it has no option but to place reliance for funding on an unsustainable events policy is beyond public understanding, and places in question the judgement of its officers .
- Nuisance factors and relevant licensing conditionalities:
- Events of this size pose a substantial risk to the structure and integrity of the park. In 2017 rain so softened the exhibition table that large parts of it were denuded by wheeled vehicles used in two major events. Repairs were superficial and tardy because the terms and conditions of licensing do not permit the full cost of repairs to be charged to the event organisers. The scale deposit in LBE’s terms of licensing, at £7500, is wholly inadequate and we see no reason why LBE, which professes a lack of income, avoids taking measures to ensure the park is restored as rapidly as possible at the expense of the perpetrator. We draw our own conclusions that LBE does not wish to pressure event organisers with the true cost of holding events in TCP. We see no prospect that Mad Husky will make good the terrain whatever the outcome, such are its financial constraints.
- The impact of major events on other park enterprises, Go Ape, the animal sanctuary, and the Hockey Club in particular, are substantial and LBE has made no move to resolve their losses. In effect their losses subsidise LBE’s financial policies.
- The Friends calculate that the total cost to LBE of attracting major commercial events to TCP in executive time, processing applications for licensing, control and administration, making repairs, dealing with litter etc, more than halves the gross revenues to LBE. The Friends discount, with justification, claims by Enfield Council that the revenues are worth the overall loss of amenity and damage to the community and Trent Country Park. Events beyond the carrying capacity of TCP, which from experience we place at not more than 10,000 persons per day, are objectively unsustainable and should be halted.
Friends of Trent Country Park