As it is not practical to publish all 173 objections to the granting of a licence to the organisers of the proposed Korean Pop Festival in Northwick Park I publish below two that are representative of the range of objections:
Licensing Objection by the Sudbury Court Residents’ Association,
and supported by our elected representative Cllr Diana Collymoore regarding
Application Number: 33756 made by Magic Sounds Ltd dated 17th December 2024
Firstly, we wish to state that we, and other stakeholder in Northwick Park and the surrounding areas have not been informed of this proposal in a timely manner, therefore not allowing us to contribute to the discussions between the Council and the Applicant until the last moment. As a consequence, the Applicant has walked into several unanticipated problem areas which have been highlighted by local stakeholders by posted objections and mainly the Public Consultation Event on the 10th of January 2025.
Furthermore, the timing of the Licensing Application, being over the holiday period has made it very difficult to make accurate and reasoned responses to the Licensing Application after consulting with partners and stakeholders. We have great sympathy for the event organisers having to re-evaluate their proposal at such a late stage due to the surprises that have been sprung upon them since the proposal has become public. There was a general feeling at the Public Meeting, that the organisers and non-council stakeholders have been terribly let down.
Additionally, we stakeholders are extremely disappointed at how the application has been presented on the Brent Licensing Website. Basically, the application detail and proposed conditions are decidedly unreadable. This is because the application wording is presented as a completely unformatted form, making it almost unintelligible and requiring a substantial amount of time downloading and formatting. Surely, this is not an acceptable practice and requires urgent resolution for future licensing applications.
Premises Licence
The Description of the Premises License includes the following parts which we will comment on in relation to the Licensing Objectives, and we will continue with this methodology throughout this objection.
The proposed premises sit within Northwick Park, a large public greenspace situated between Harrow and Kenton, with Watford Road to the west and Norval Road to the south. Northwick Park Hospital sits to the west of the site alongside the University of Westminster, Harrow campus.
· this is a fair description of the location; however, it omits points such as:
· the park is actually Playing Fields
· It has limited access
· is almost totally surrounded by residential properties
· is flanked by hospital housing which includes shift workers
· is almost flanked by a large hospital serving two boroughs and is always under immense pressure
· there are two residential units right next to the event area
· there is a Care Home at the entrance to the park
· the event area currently sits on top of a cricket pitch, a floodlit training area and most importantly a Gaelic Football pitch.
· there is a Mental Health unit at the hospital.
· The hospital postcode contributes to the majority of crime in the Ward.
Which Licensing Objectives would be affected by these issues? A case could be made for all four, given access to a good Licensing Barrister, which because of the timescales of costs is unavailable to us as stakeholders.
Taking the limited access first, the organisers were no doubt surprised by the lack of public transport capacity, mainly limited because of the narrow tunnel entrances at the two local stations. At the Public Event, the organisers admitted that they did not know what the capacity and throughput would be. They admitted that they would be reliant on holding (hopefully compliant) crowds back by utilising the Disney Method of crowd control, as in, make them walk a very long way to cover a short distance, and stopping them occasionally. The analogy is, if people are moving, they don’t get annoyed.
Another worrying point was getting the crowds onto the platforms and trains. Various methods were suggested during the event. 1. Hold the crowd back until the passengers get off the tube and leave the station and then let the crowd onto the platform. This was later dispensed with by the organisers as they said they couldn’t delay the trains. The next method suggested by the organisers was by preloading the platforms with up to 1,000 passengers and (somehow) holding them back while passenger got off the trains, REALLY! Basically, they seemed to clutching at straws, especially as they had no information from TFL and other relevant stakeholders about the station’s capacities. We hold heartedly believe that two proposed stations do not have the capacity to clear 15,000 attendees in under one and a half hours.
Since the organisers and other members of Brent’s Safety Advisory Group (BSAG) have become aware of our worries, various other options seem to have been suggested, such as bus use, of which there is a low capacity on the Watford Road of circa 120 places per 12 minutes, one would necessitate quite a long walk. The 223 from Northwick Avenue was also suggested, but would not be accessible as it is on the other side of the two tube stations. Harrow on the Hill station has been suggested, it is some 2.5km away, and requires crossing of two London Distributor Roads, one of which carries in excess of 30,000 vehicles a day. Both are prone to regular accidents. This destination would necessitate passing through the hospital grounds. Really, this opens up the Licensing Objectives again regarding Public Nuisance, Public Safety, Protection of Children and Preventing Crime and Disorder. And then through residential roads.
Other options have been muted such as utilising Kenton Station, unfortunately this would require utilising the restricted access at the local stations or a very long walk through residential areas.
In Summary, access to transport is a real issue for this event and should not be taken lightly and without substantive proof that it will work successfully and in a reasonable length of time, and without causing a nuisance and putting the crowd, which is full of youngsters in jeopardy for so many reasons.
The use of private vehicles must be resisted as the area is known to be heavily parked and at risk of gridlock.
The Premises Licensing Headings - Plays, Films, Live Music, Recorded Music, Performance of Dance and Other Activities.
We believe that the hours requested for these listed activities are excessive at potentially an eleven and a half hours duration. For instance, taking the Licensing Objective of Preventing Public Nuisance, if the noise levels are regulated as we expect them to be, (and were detailed in the (incorrectly posted) EMP V1), for say three hours, then one could ‘possibly’ consider this to be reasonable. However, to have this level of Nuisance being possible for much longer periods than that, (it is proposed for eleven and a half hour), it is definitely unreasonable and must be considered a substantial Public Nuisance in such a residential area which includes accommodation of hospital shift workers, and not forgetting the nearby care home and the two residential bungalows right next to the event area.
The Northwick Park area has recently suffered previously by an event at Sudbury Cricket Club where the sound equipment had to be confiscated, also a property on Nathan’s Road that was finally quelled by the issuing of a Noise Abatement Notice. Neither of these events were for durations longer than four hours, but no one can deny that they didn’t cause a Public Nuisance, with Brent’s ENS Team and Local Police being called in on several occasions.
We would request that the licenced hours for the above uses are shortened, to say 2pm to 10pm (with an agreed possible overrun of thirty minutes) with a one-to-two-hour break in the middle, say around 6pm to 7-30pm.
Supply of Alcohol
The supply of alcohol can almost certainly be a contributing factor to Crime and Disorder, Public safety, Public Nuisance and Protecting Children from Harm, we don’t think any of the parties to this Licence Application would disagree, and it is why we have Licensing Objectives to guide us.
Some of our members attended the Public Consultation Event on the 10th of January and were reassured that the organiser appears to know what they are doing, however, none of those at the Public Consultation Event, nor those we have conversed with outside the event can see the need, nor agree that licensing the sale of alcohol for eleven hours is in anyway promoting the four Licensing Objectives. We believe that a substantially reduced period for the sale of alcohol would be more appropriate to the Licensing Objectives. Perhaps the sale of alcohol could start later, perhaps 4pm until 9.30pm at the latest.
Currently the end time is proposed to be 10pm, dependant on over runs. This could force people to quickly consume recently purchased drinks and leave quickly, putting in jeopardy the four Licensing Objectives for obvious reasons. For example; you consume say a half litre of beer swiftly because you are being requested to leave, and within half an hour you need to urinate. You are in a crowd of say 7,500 people with 60% children and the toilets are at capacity and the crowds are not moving because of the Disney Method of crowd control. You must have a picture of this by now, and that it puts several of the Licencing Objectives in peril because of the event location. The organisers will tell you they can control this, really?
We would request that the licenced hours for alcohol sales are reduced to 4pm until 9pm, or at the latest 9.30pm to Promote the Four Licensing Objectives.
Application Wording
Now we move to the Application text which we have had to download and formatted to make it comprehensible.
As the many documents/plans mentioned in the Application are not yet available, it is impossible to comment on this application regarding the four Licencing Objectives, so how can the committee rule on it, nor the officers advise correctly on it?
The most worrying omission areas are “Security and Crowd Management”, “Transport and Traffic Plan”, “Ingress and Egress Plan”, “Drugs, Search and Eviction Policy”, “Noise Management Plan”, “Child Welfare Plan Risk Assessments “
Security and Crowd Management & Ingress and Egress Plan
The entrance/access tunnels at Northwick Park and South Kenton Stations are very narrow. South Kenton’s tunnel being 2.4 metres wide and Northwick Park’s 1.3 metres wide. The access to both station’s platforms is further restricted by cycle barriers, turnstiles and steep narrow staircases that lead to narrow platforms, parts of which can only just cater for a single standing person and one traversing the platforms length, these platform bottlenecks are right at the entrance to the platforms. The main issue here is that access to the platforms at both stations is basically restricted to single file, and that is not taking account of counter direction movements. At Northwick Park one can witness at almost any time, people stepping aside to let people going the other direction pass.
The now removed Event Management Plan stated that at their emergency exits they expected a flow of 66 persons per minute per metre. The plan went on to say that because of the demographic of the expected audience, this throughput would be less!
What does this mean in the real world? Nortwick Park Station, assuming throughput of 66 persons per minute and not taking any account of getting any counter direction traffic, or from the platforms it would take at least 113 minutes to get 50% of the crowd onto the platforms. As well as coping with counter traffic, the platforms would fill to capacity while waiting for the next train. This platform preloading of up to 1,159 persons (being to train’s maximum capacity) would no doubt create a Public Safety Issue on such narrow platforms. Getting 1,000 people on to the platform would take, at a generous 66 per minute, would take at least 15 minutes, however, account must be taken of passengers alighting and persons utilising the tunnels as pure pedestrians. Of course, then there are the delivery bikes using the tunnels on a regular basis.
Obviously extra tub trains can be brought into service, however, the Met-line’s capacity at peak times 8am-9am for Northwick Park, in both directions is 18 trains. However, allowing for passenger getting off onto over-crowed platforms and then 1,000 getting onto the trains, the timetable would be disrupted.
At the moment, we are not at all convinced that Northwick Park station can cope with numbers of users at anything like those necessary to clear the crowd in an acceptable timeframe. The organisers themselves have said at the Public Consultation Event that clearing the crowd in over an hour is unacceptable.
At South Kenton station the access is via a 2.4-metre-wide tunnel, with cycle barriers and stairs restricting the flow to single file and in one direction only. The difference between this station and Northwick Park is that there is potentially less counter traffic and there are no platform turnstiles. Northwick Park does not have a mainline and therefore trains can be delayed which would be helpful, but at South Kenton the platforms utilise the only available track and therefore any delays at the platform will hold up the Bakerloo Line timetable. Most other issues would be replicated from Northwick Park’s figures.
Having consulted the Bakerloo timetable, South Kenton’s Peak Service is ten trains between 8am and 9am, each with a capacity of 851. So, in essence, the throughput at South Kenton would no doubt be lower than at Northwick Park, and therefore it should be expected that it would take longer than the 113 minutes projected at Northwick Park to clear 7,500 persons.
Suggestions have been made that attendees could be directed to Kenton Station, unfortunately the access is via Northwick Park Station or a long walk via residential streets of at least a mile. The 223 Bus was proposed from Windermere Avenue; however, it is infrequent and again is accessed via the stations. More recently, Harrow on the Hill Station has been proposed as a solution, unfortunately this station lies some 2.5 kilometres away and across two very heavily trafficked London Distributor Roads. The Harrow on the Hill station is well known for ASB and large crowds at the weekends therefore its use for such large numbers is untried and fraught with dangers, it is also on the same line as Northwick Park, and therefore the trains may already be at capacity when arriving at Harrow causing crowd frustration and a likelihood of Public Disorder, especially on a Saturday night (it is a known ASB hotspot).
The organisers believe that they can ‘police’ these many routes, which several kilometres, however, we believe this is unlikely, especially when the use of the 182 and 483 buses on Watford Road could be added, this would require walking across fields and unlit passageways, or along residential roads.
All the above must surely come under Public Nuisance, Public safety, Protection of Children and Preventing Crime and Disorder? How moving these crowds utilising the available Public Transport infrastructure can be considered to be promoting the Licensing Objectives must be hard if not impossible to prove.
Transport and Traffic Plan
The use of Public Transport has been substantially covered above and is obviously a substantial problem area with no current resolution being presented other than “we will manage this”.
We believe clearing 15,000 or more attendees is probably impossible to achieve in less than an hour due to the lack of Public Transport capacity, and therefore the safety of the attendees and local residents would be in jeopardy. Basically, the locale was never designed for such numbers, and such numbers have never been tested in over 100 years since the tube lines were laid down to serve the residential area.
Unfortunately, it is highly likely that many attendees will utilise private vehicles and hire vehicles to arrive, and more importantly leave the venue as was suggested recently by a council officer. One only needs to walk the streets surrounding Wembley Stadium after an event to see the number of private vehicles and taxis lining the streets and disregarding all traffic controls, so parking across property entrances, double parking and many other anti-social intrusions will no doubt take place regardless of any Event Security Staff interventions.
It is well known throughout the area that the local roads are narrow and heavily parked due to being located near to the hospital, university and the local stations. Basically, the local streets are made into single lane throughout the area and heavy vehicle often struggle to get through many locations. It is highly likely that Blue Light vehicles will struggle to gain access to the event site, or other locations in the locale.
The set up and tear down phases for the concert will require heavy vehicles to access the site. When Byron Court School was being expanded the council, through planning system and the building contract required that their traffic had to follow a one-way system and also implement yellow lines at the various strategic pinch points. It was also a requirement that the vehicle phoned ahead to make sure they could gain access to the site. We would ask that a similar system is implemented for theses licensed events during all phases, and that fines are imposed as they were with Byron Court for any contraventions. If these rules are not followed, there will be Public Nuisance, Public Safety, Protection of Children and Preventing Crime and especially Disorder.
It should also be mentioned at this point that part of the planning consent for the Byron Court School expansion was that the Pavilion Car Park be utilised for parent parking at school run times and a walking bus be employed to get children to and from the school. Several thousand pounds were spent on building a shelter in the park and a footpath to facilitate the Walking Bus. We request that the concert traffic should not be allowed through the park during term time school run times, whether the walking bus is active or not. Public Nuisance, Public Safety, Protection of Children.
Noise Management Plan
It is interesting that a Noise Management Plan has been suggested, however, it hadn’t surfaced in time for the public or stakeholder to comment on before the licensing consultation period ends. We believe the plan, when it does surface will state that everything will be very rosy and compliant with the law. However, local residents and stakeholders whom we have discussed this with are not convinced. In the past local events have exceeded acceptable levels and neither the Police not the Brent Noise Team managed to reign in the offenders within three days. We therefore have no confidence that the noise levels can be enforced in a timely manner, no matter how many hot-lines there are.
We also have extreme noise concerns regarding some of the nearby properties: the two bungalows by the concert area, the hospital housing within a few yards of the concert area. The hospital and mental health unit, the care home at the entrance to the park to name a few who will be affected badly by the 11 hours of loud noise from the event. Also, there will still be within the exam windows for our local children who will be revising at home. The BBC website states: “GCSE exams in 2025 start from the week commencing Monday, 5 May and finish on Friday, 20 June”. This is a considerable Public Nuisance issue to be considered, and could ruin the life chances of those affected, all for a concert in a park! It should be considered under the Licencing Objective of Protecting Children from Harm.
Drugs, Search and Eviction Policy & Child Welfare Plan Risk Assessments
The Northwick Park Metropolitan Police Safer Neighbourhood Team (SNT) has as one of its three priorities ‘The use and supply of drugs in the area centred on Northwick Park Pavilion and enabled by the two tube stations which due to the extremely narrow access tunnels are ideal escape routes, especially at South Kenton Station’.
Obviously, this no doubt heavily advertised event, and will permeate the local and not so local drug networks who may infiltrate the event locale due to the openness of the area giving many opportunities for trades. The event organiser’s security representative stated that this would be controlled. However, we are yet to be convinced, especially as we have no detail of how or the numbers being deployed, nor the locations. The security representative offered having a Police Patrol Car in the Pavilion Car Park for a for evenings and night to deter the drugs pushers and users. How we wish we residents could have that sort of presence on a regular basis! As it is, the residents of the Park Bungalows are frightened of the persons (be they users or pushers) who frequent the car park in the evening and night, who can often be seen climbing onto the roof of the pavilion, performing doughnuts in the car park to name a few activities. One only needs to visit the pavilion car park to witness the evidence of what goes on at that location. Preventing Crime and Disorder
Additional Conditions
B. We see no need to have a Licence in Perpetuity, we believe that if the Licence it granted against our wishes it should be revisited regularly, and it most definitely must be revisited before the second year, taking full account of events from the first year.
C. At the Public Consultation Event, the organisers were open that they personally don’t want a second weekend, they added it at the behest of the University who would like to utilise the infrastructure from the K-Pop concert for their own events the week after. The ambition of the university should be of concern here, surely any university events would be catering for a completely different demographic, and if Freshers were anything to go by, not an event that be considered ………….
D: To agree to levels as high as 20,000 without any of the Management Plans been presented is implausible. Even at the Public Consultation Event the organisers were not keeping back that they thought over 15,000 was not advisable, nor manageable.
I. As the Premises License Holder will be invited to the BSAG, surely a representative of the public representing the Residents Associations and other Stakeholders, especially the Safer Neighbourhood Ward Panel Chairs should be allowed to attend and contribute at BSAG?
Alcohol Related Conditions
We would add a condition as follows
· No Irresponsible Drinks Promotions
· No games or other activities which require or encourage drinking
· No drinks served above standard measures,
(i) beer or cider: ½ pint;
(ii) gin, rum, vodka or whisky: 25 ml or 35 ml; and
(iii) still wine in a glass: 125 ml;
· No provision of drinks for groups
· No alcohol presented as prizes or rewards
· No alcohol adverts
· Free water is readily available on site
· require individuals who appear to the responsible person to be under 18 years of age (or such older age as may be specified in the policy) to produce on request, before being served alcohol, identification bearing their photograph, date of birth and either—
(a) a holographic mark, or
(b) an ultraviolet feature.
Public Safety
A. Refers to access for emergency services access to the site. As previously mentioned, the local streets are narrow and heavily parked, therefore, the predicted and expected private vehicles and pubic hire vehicles, especially at the egress time and before may well block access to the site, it is therefore imperative that a specific route is kept clear at all times and that information is provided to all Blue Light services. Public Safety. Referring to Wembley events, this is most likely unachievable at this event location.
The Prevention of Public Nuisance
A. Although details of the available public transport and taxi numbers are to be provided, we are not aware of how the crowds of such large numbers will be managed so that all the attendees don’t arrive at the same exit hub, or even a large proportion. There is so far no meaningful plan available as to how this will be managed with a potential attendance of 15,000 persons. It will not be until tickets have been sold that the organisers will be able to work out which Public Transport routes will be the most heavily used, and by how many.
B. Clear notices of travel instructions are all very well, but there is no explanation of how to stop 15,000 attendees arriving at the same exit hub.
E. Although vehicle access and exit routes and dedicated parking zones will apparently be controlled by event staff, there is no evidence that this will be effective. Various local hostelries already show that it is impossible to control these issues. We do not wish to name those hostelries at this time. However, having no police presence in the area in the evening is not helpful, and it should be remembered that the local town centre locations require significant policing and reinforcement.
F. Encouraging customers to leave quietly is not particularly reassuring when a crowd, in a no doubt excited state leave the concert area. The hostelry on Watford Road often proves this point.
G. What is meant by proactively informing customers to leave quietly? What density of security staff will for instance be require to proactively control the customers walking the 2.5 kilometres to Harrow on the Hill Public Transport hub?
Noise Management Plan (aka Public Nuisance Prevention)
A. A qualified noise consultant will be engaged, will this consultant remain during the concerts to make sure of compliance?
B. Which are the Noise Sensitive Premises? To our mind these would include nearby homes, the park bungalows, the Care Home, Hospital Housing and the Hospital itself, including the mental health Unit. Is this correct and how will the event organisers ensure that there is conformity at all these locations. Will the organisers supplement the hospital’s security team?
C. Providing notifications to the residents of the hospital housing is from experience extremely difficult, can the organisers explain how they accessed the circa 1,000 residents in these secure blocks as they believed all the residents have been provided with the initial notification letter?
Public Space Protection Orders
Most of Brent is covered by Boroughwide PSPOs which, as we understand has to be enforced by either the Police or Civil Enforcement Officers (CEO). Therefore, will the Council be deploying extra Police and CEOs to enforce the PSPOs along the miles of routes that the attendees will no doubt exit the area? Or are the PSPOs just there to decorate lamp posts? The relevant PSPO sections are listed below, and this Residents’ Association and other stakeholders we are in touch with, do expect the Council to enforce the PSPOs appropriately.
3. Littering (urination or defecation)
Any person(s) urinating or defecating in a place other than a serviced public convenience.
4. Littering (spitting)
Any person(s) who spit(s).
5. Littering (bottles, cans, packets, food, paper, chewing gum, cigarette butts etc.)
Any person(s) who abandon(s) (leaves behind) bottles, cans, packets, food, paper, chewing gum, cigarette butts etc.) other than in an appropriate receptacle (bin).
Sovereign Network Group
I am writing on behalf of Sovereign Network Group (SNG) to formally object to the proposed planning permission for concerts at Northwick Park. As a provider of homes for key workers, including NHS nurses and doctors, we are deeply concerned about the potential impact these events will have on our residents, the surrounding community, and the operations of Northwick Park Hospital.
Impact on Key Worker Residents
Our tenants, who are predominantly NHS staff and other key workers, require a quiet and stable environment to rest and recover between shifts. Many of them work irregular hours, including night shifts, and disruptions such as loud music, bright lights, and large crowds during concerts would significantly hinder their ability to rest. This could directly impact their performance, with serious implications for the healthcare services provided by Northwick Park Hospital.
Challenges for Medical Staff Access
We are particularly concerned about the challenges medical staff may face in accessing the hospital during concert days, especially in emergencies. Increased traffic on local roads and overcrowding on public transport caused by the influx of concertgoers could delay critical staff members such as doctors and nurses from reaching their workplaces. This poses a risk not only to the staff but also to patients who depend on timely medical attention.
Noise and ASB Concerns
The proposed concerts are expected to generate significant noise pollution, which will carry across the flat landscape and disrupt hundreds of households, especially during the evenings. Past experiences with local events indicate that noise disturbances often exceed acceptable levels, affecting residents' sleep and overall quality of life. Additionally, anti-social behaviour (ASB)—including unauthorised parking, loitering, and public disturbances—has been a recurring issue during large-scale events, posing safety risks to our tenants and the broader community.
Unauthorised Parking
The potential for unauthorised use of our parking bays, which are allocated to tenants, is another major concern. This not only disrupts our residents' routines but also creates safety hazards. Given the limited public transport infrastructure for dispersing large crowds, this issue is likely to be exacerbated, as highlighted by the Sudbury Court Residents Association.
Safety of Access Routes
The proposed use of the Pasteur Court entrance or path is unsuitable and unsafe. This pathway, created informally by passers-by, is not designed to handle high foot traffic and poses significant safety risks. Furthermore, this access route is not approved by SNG for such use.
Impact on the NHS and Patients
The proximity of Northwick Park Hospital amplifies our concerns. Noise pollution and traffic congestion during concerts would not only disrupt the hospital's operations but also affect the well-being of patients who require a calm and quiet environment for recovery. Emergency medical services could face delays in navigating the area, further compromising patient care.
Broader Community Concerns
We also echo concerns raised by the Sudbury Court Residents Association regarding insufficient public transport planning, risks of pickpocketing and assaults, inadequate emergency escape routes, and poor crowd management. The potential for breaches of Public Space Protection Orders (PSPOs), including littering, public urination, and defecation, would only worsen the already significant impact on the local community.
Conclusion
Given the substantial and far-reaching consequences of these proposed events, we strongly urge Brent Council to reject the planning application. The potential disruptions to our residents, the NHS, and the wider community are too significant to justify hosting concerts at this location.
We would welcome the opportunity to discuss our concerns further and work collaboratively to ensure that the needs and safety of all stakeholders are prioritised.
No comments:
Post a Comment