11 December 2007
Michelle Saxton
Licensing Officer
Cotswold District Council
Trinity Road
Cirencester
BY HAND.
Dear Ms Saxton,
Licensing application, Ampney Down Farm, Ampney Crucis
Proposed date 13 – 15 June 2007
Ampney Crucis Parish Council met in special session on December 6th 2007 to consider its response to a request for a licence to run a three day music festival at Ampney Down farm in this Parish. A number of parishioners attended the meeting and there was a public discussion on the issues involved before the formal Parish Council meeting.
There was some discussion over a similar event which had been held earlier this year. This was, apparently, a birthday party attended by around 300 guests but with many of the elements of the proposed festival: a three day event with amplified music. Initially the organisers had applied for a licence to have a birthday party for 1000 people to which the Gloucestershire Police objected. The Parish Council find it strange that the Gloucestershire Police should have objected so strongly in May 2007 to the proposal for a festival on the same site for 1000 people and yet now, we understand, appear to be condoning a very similar proposal for 1500 people for 2008. In relation to the birthday party held in June 2007, local residents remarked that there had been few problems associated with this relatively small scale event as only 300 people attended. The concerns being expressed at the Parish Council meeting on the 6th December were based on the unknown aspects of moving to an annual event with 1500 revellers.
The Parish Council felt that much of the legislation was directed towards the control of licensed activities in an urban setting and that it was ill-suited to assessing the impact of an event to be held in open countryside.
The Parish Council’s concerns are as follows
1. The Prevention of Crime and Disorder and use of Police Resources
· The Parish has experienced unusually high levels of burglary over the last 12-18 months. To our knowledge, none of these crimes has been solved but there appears to be some consensus by the police that the perpetrators have been from outside the immediate locality.
· The Police through the Neighbourhood Watch and two public meetings have asked residents to be more vigilant and to note and report strangers with unusual behaviour. This is of great concern to residents of the Parish. While we would not necessarily ascribe burglary intent to the participants at the event, we are concerned about the influx of so many outsiders in those parts of this parish that are quite remote.
· It seems to us that the statement by the organisers that they will know most of the 1500 people attending is at best misleading.
· We find it a diversion of valuable and scarce Police time and resources, which might otherwise be directed to deal with local crime, to enter into extensive discussions with the organisers (as they clearly have been obliged to do so far) and, if a licence was granted, deploying personnel and other resources to the site during the event (for example, a helicopter to over-fly the birthday event, as occurred at the event earlier this year).
· We find it difficult to find any comfort in the statement of the organisers, that they will have zero tolerance on drugs and will expel anyone in possession of illegal substances. We see from their own statement that the organisers anticipate that drugs would be an expected feature of the festival (as we would have anticipated) and we are concerned about this as a potential cause of further crime in the parish.
2. Public Safety
· We are concerned that insufficient account has been taken of the fact that there are likely to be major tail-backs along the access roads (particularly the Welsh Way from the A429, which is very narrow and, along this section, has no formal passing points at all) as vehicles try to access the small preliminary car park. The application mentions 12 traffic passing points on the access route but this is clearly not the case on this section of road.
· We are not convinced that people will enter the area only from the A429 and are of the opinion that some traffic will attempt to enter from the Bibury Road and along Sheephouse Lane. In fact, this is the route that at least some satellite navigation systems will direct travellers, irrespective of the guidelines provided by the organisers.
· Such problems are likely to be exacerbated by those would-be festival goers who are denied entry (because they don’t have tickets, for example) and therefore, attempt to leave by the only route available to them, that of continuing on down the Welsh Way towards Barnsley, with the potential of meeting oncoming traffic using satellite navigation and other road users on the narrow single carriage way.
· The organisers have provided no answer to the question of what will happen should many more people arrive to enter the event than they have anticipated. Stating that they will be turned away is simply not good enough. We understand that this event will be posted on the internet and the excess number could be considerable. We imagine that any such number would either enter illegally by breaking down the perimeter fence or locate somewhere nearby in the area. We are concerned about the effect of this on public safety, general nuisance and health and hygiene grounds.
· We are concerned about the arrangements for emergency vehicles: all potential routes lack credibility. The way in for these vehicles stated in the proposal is through Ampney Down farmyard. This track does not extend to the Festival site, or to the camping area, and emergency vehicles would be force to travel some distance on field tracks or worse along steep terrain (perhaps in wet conditions). Another feasible entry route for emergency vehicles is along the Welsh Way from the A429 but this involves crossing the weight-limited bridge (acceptable for an ambulance perhaps but certainly not for a fire engine) and provides access only to the camping area. Finally, the Welsh Way from Barnsley could be used but this is very narrow with no suitable passing places, with the consequent clear potential for emergency service vehicles being severely delayed.
· We are also concerned about potential traffic congestion likely to be caused by the vehicles of performers and contractors when they access the site over the weight-limited bridge before, during, and after the event. We believe this serious congestion will consequently be a hazard to public safety.
· We note the point that the organisers will use only 7.5 ton lorries for delivery of equipment, food etc. in sympathy with the 10.9 ton limit of the bridge, but we still remain concerned about the safety of this structure as the brick and stone work appear to be in a very poor condition.
· The Council are of the opinion that the submitted traffic management plan fails to deal with the reality of the situation and has no credibility.
· The Parish and its immediate environs has experienced a number of serious accidents in recent months and the Gloucestershire Highways Department has recently set-up a campaign arranged on the A417 in the Parish to attempt to make drivers more aware of the dangers of the narrow, twisty, flood damaged roads in the Parish. The accidents have included three fatalities and we are concerned that the increased traffic associated with a large event, on difficult roads that are unknown to event goers (especially those who may have been tempted to indulge in drugs or have been taking advantage of the very long bar hours that have been proposed) will increase the risks of serious accidents in the Parish.
3. Public Nuisance
· This proposal represents a major step-up in size from the birthday party that was organised by the same people, at the same location earlier this year and is therefore, most likely to create a proportionately larger public nuisance. We are mindful of the fact that those who live in the village of Barnsley, and those in this parish who live in Sheephouse Lane, will be subjected to 3 days of music, bonfires, fireworks and having strangers with access to alcohol over long periods of the day and night in this rural area. Over the three days, revellers will have access to alcohol sales for over 36 hours - some drinkers will most certainly use this opportunity to good effect. This will obviously increase anxiety levels among residents. While the festival will be over in three days for the participants, the period of time of nuisance for the parish will be much longer taking into account set-up time, dismantling and removal time.
· We are particularly concerned about the level of noise amplification until 3am on two of the nights. We note that the application states that music will be delivered both indoors and out. But we also note that “inside” simply means that the music will be inside a canvas structure which clearly will have a very limited noise-deadening effect in the surrounding areas. The birthday party held at this site by the same organisers in 2007 ceased amplified music at midnight and the disturbance was bearable by nearby residents. Playing loud music in a rural area until day light arrives in mid June is a different matter.
· The proposed three day event is to be located within the Cotswold Area of Outstanding Natural Beauty; one of the most important and prestigious of this designation in the nation. This important national designation has very clear purposes, namely:
(i) to conserve and enhance the natural beauty of the landscape,
(ii) to meet the need for quiet enjoyment of the countryside,
(iii) to have regard for the interests of those who live and work within the designated area.
· The importance of Areas of Outstanding Natural Beauty has long been recognised in national planning policy. They are some of the most sensitive and most vulnerable to pressures for development and change. National policy makes it abundantly clear that there is presumption to protect their special character and appearance. The Countryside and Rights of Way Act 2000 makes it a statutory duty for local authorities, when considering any functions in relation to land in or affecting an AONB, to have regard to the enhancement of the natural beauty of the designated area.
· It is obvious and really does not need further amplification that the proposal is manifestly and totally contrary to all key aspects which the designation is designed to protect. Walking along the Welsh Way from the A429 to the birthday party site used in 2007 ( and that proposed for 2008) there is ample evidence of rubbish and waste having been thrown into the hedges - perhaps this is related to the festival held earlier this year.
· Further, and related to key national environmental designations, the proposed site for the music festival actually encroaches some 4 metres into the designated Site of Special Scientific Interest (SSSI) at the location. SSSI are designated by Natural England under the Wildlife and Countryside Act 1981 and are statutory sites of national importance. They are designated for biological, geological or geomorphological interest.
· These sites comprise areas or features where conservation is considered essential to maintain the site. Any development or use that directly or indirectly has adverse affects on, or otherwise damages a SSSI is not permitted. The organisers have planned some precautions which might prevent unfettered trampling on the unimproved limestone grassland and its related ecology (which comprises a population of rare orchids) of the SSSI at Ampney Downs but Councillors are surprised that the Licensing authority may consider condoning a proposal which is purposefully sited within and on the designated area and which so clearly puts the SSSI at risk. A local respected ecologist is aware of rare orchids and other wildflowers on the site that could be damaged, and the Council suggests that this is investigated.
In almost every respect we believe this proposal for an annual music festival event on Ampney Down farm to be inappropriate and would urge the Licensing committee to refuse the application. Indeed, the Council are completely opposed to the application even for a single event in 2008 for the reasons given above. Music Festivals can be held in many places but it seems to us that this Area of Outstanding Natural Beauty should surely be the very last place that should be considered.
There are, after all, already many events of a similar nature in this locality due to be held at a similar time of year in 2008. The WOMAD Festival, for example, is held annually in Malmesbury and the Wychwood Music Festival at the Cheltenham Race Course runs from 30th May to 1st June. These events amply cater for those who wish to take part in such events.
If, in spite of all this reasoning, the CDC is still minded to permit this function, which the Parish Council feels is inappropriate, and from which residents see no countervailing benefits and to which they are so strongly opposed, we would urge that any Licence is approved should be for only one year at a time.
Yours sincerely,
Helen Tonks
Clerk, Ampney Crucis Parish Council.
cc: Councillor Edward Horsfall