Decision Maker: Licensing Sub-Committee A

Outcome: For Determination

Is Key Decision?: No

Is Callable In?: No

Date of Decision: February 18, 2025

Purpose:

Content: The Licensing Sub-Committee (“LSC”) considered an application made by Rebecca McLeish and Glenville Butcher for the grant of a premises licence in relation to the 4 Corners Music Festival 2025, Circus Field, Blackheath, London, SE3 7AP.   The application requests the following licensable activities, namely, the supply of alcohol for consumption on the premises only, and outdoor live music,  outdoor recorded music, and outdoor performance of dance, to take place from noon to 22:00 on two days, Saturday 24th and Sunday 25th May 2025.   The LSC had regard to the s.182 Guidance, particularly paragraphs 1.17, 2.21 to 2.27, 8.43, 9.37 to 9.38, 11.2, 16.52, 9.42 to 9.44, and the Royal Borough of Greenwich Licensing Policy, in particular, paragraphs 4.1 to 4.6, 4.30 to 4.31, 4.34, and 12.3. The LSC recognises its duty to consider each application on its own merits and did so for the purposes of this application.   The LSC were mindful that the only representations they can consider under the Licensing Act 2003 are those which are relevant to the licensing objectives, namely: i. Prevention of Crime and Disorder ii. Prevention of Public Nuisance iii. Public Safety iv. Protection of Children from Harm.   Further, the LSC may only impose conditions on a licence which are considered appropriate for the promotion of the licensing objectives. The conditions will relate to the premises and other places being used for licensable activities, and the impact of those activities in the near vicinity of the premises. Any conditions attached to licences will be focused on matters that are within the control of individual licensees. The LSC noted that the premises are not located in a cumulative impact zone and noted that it is only if the LSC is satisfied that the licensing objectives will be undermined such that the impact cannot be mitigated, even with amendments and conditions, that the application should be refused.   The LSC had read the papers and noted the written representations as well as the oral submissions of those attending.   Written representations were submitted by the Council’s Licensing team, the Council’s Community Protection team, and the Council’s Events and Culture team, as well as 8 households of residents living within the vicinity of the Premises.   Each of the representations save the Council’s Events and Culture team’s representation referred to the 4 Corner’s Event held on Circus Field on the 1 June 2024. The Licensing team identified its concerns arising from that Event as relating, in summary, to the Event’s Event Manager Competence, section 30 Consent under the Buildings (Amendment) Act 1939 being applied for retrospectively rather than in advance of the Event, the quality of Signage relating to directions to the Welfare point and the printing of Challenge 25 signage on the day following the Council’s inspection, the level of Contractor Responsiveness to the Council’s Officers health and safety concerns, the lack of cordoning of the BBQ Area, and inconsistent Noise Management, which included several breaches of the agreed noise limits. These representations concerned each of the four licensing objectives.   The Community Protection Team noted that there were complaints from residents regarding noise in respect of the 2024 Event, which principally concerned the licensing objective of the prevention of public nuisance. Similarly, the 8 household objections addressed the level of noise during the 2024 Event including that it was “unacceptable”, “disturbing”, and “disruptive”. One resident noted that “We have had several pop festivals on the heath, but this had by far the greatest impact on us in terms of noise levels”. All but one of the residents do not want the Event to proceed. The other asks that the Council “confer with acoustic specialists and set lower than national limits particularly in the lower frequencies”. Further, one resident noted the lack of leafleting to warn of the Event on their street, which is not in the Council’s borough. As regards the conditions sought by the Council’s three teams, the Applicant had agreed to all of the proposed conditions in writing prior to the LSC’s hearing.    As to the oral representations, these were made on behalf of the Applicants, and by each of the Council’s three teams. On behalf of the Applicants, it was noted that an Events Safety Advisor had been engaged. An events safety and management plan had been prepared and specifically, a noise management plan had been submitted to the Council’s Safety Advisory Group (“SAG”). It was stated, amongst other things, that there would be monitoring of the lower 1/3 octave band to monitor in particular bass noise nuisance, and that the sound levels for the crowd speakers would be controlled by a sound engineer, and would be within the sound level of 65dB LAeq 15mins, which was the limit imposed within the Noise Management Plan.  The Events Safety Advisor would monitor the conditions and if it was considered that the sound engineer was not responding appropriately, the Events Safety Advisor would override the sound engineer.   Further, the Applicant had engaged, separately to the designated premises supervisor (“DPS”), an Events Manager.   On behalf of the Licensing team, it sought an amendment to a condition it sought by its written representation, namely to remove the reference to drones in Condition 25 as the reference to drones had been included by mistake. It was noted that there was a Safety Advisory Group meeting on the 11 February, another scheduled for the 22 February, and there would be one more further SAG meeting thereafter. It was stated that the SAG is satisfied with the co-operation of 4 Corners personnel are showing to date.    On behalf of the Community Protection team, it clarified its written representation that there were two contemporaneous complaints regarding noise received during the 2024 Event and noted further that it considered that the conditions sought and noise management plan addressed that issue, minimised community disruption and increased community engagement. For oversight, officers from the Community Protection team would have unrestricted access to the 2025 Event.  On behalf of the Events and Culture team it was noted further to the written submission that there was a meeting of the Blackheath Joint Working Party which noted that there noise complaints from the residents in LB Lewisham, and in response there was to be a map of streets to be leafleted warning of the Event and a requirement for a public meeting for residents to attend in advance of the Event with good communication of that public meeting.   The LSC noted the issues arising from the 2024 Event, which related to the four licensing objectives. The LSC considered the amendment to the Condition 25, which sought to remove the reference to drones, and determined that this would be accepted because the use of drones was not necessary to promote a licensing objective.   The LSC carefully considered, in particular, the representations in respect of noise nuisance. The LSC focused on the effect of the Event on persons living and working in the area around the Premises and whether it may be disproportionate and unreasonable. The objections demonstrated that the licensing objective of protection from public nuisance would be undermined without appropriate and sufficient proposals to address the issues raised.    The LSC reviewed the conditions proposed, and agreed, to mitigate noise nuisance, and in particular, Conditions 1 to 4, 11 to 13, and 52 to 60 (“the Noise Nuisance Conditions”). Condition 55, amongst other things, prohibits the use of the Premises for licensable activities until the Community Protection Team approve a Noise Management Plan, and the licensable activities must be conducted in accordance with the terms of that plan. In respect of overall volume and bass frequencies, the LSC scrutinised, in particular, Condition 56 which addresses the local noise limit of 65dB LAeq 15 mins (measuring points defined within the Noise Management Plan) and provides some controls on noise. Further, the LSC considered the issue of bass frequency noise nuisance from the Event, which has multiple and changing DJs, specifically on people living and working in the local vicinity, and noted that no specified limit or setting had been recommended for particular frequencies as a condition of the Premises Licence. It was proposed to address bass frequency noise nuisance through the Noise Management Plan, for example, by requiring the lower third octave frequencies to be monitored during the Event, and managed through the professional sound crew.     The LSC had regard to the complexity/speciality of measuring noise, including bass frequencies, and its consequences on people living and working in the local vicinity from the Event. Also, the LSC had regard, in particular, to the proposals relating to community engagement i.e. Condition 13 - a public consultation meeting to hear residents’ concerns surrounding the Event, Condition 12 – a letter drop notifying of the Event, and Condition 58 - a letter drop to specified streets in the local vicinity that are noise sensitive to the Event that provides the details for the noise complaints’ process.   The LSC determined that the noise limit, as set, at 65dB LAeq 15 mins (measuring points defined within the Noise Management Plan, was necessary and proportionate to promote the licensing objective of preventing public nuisance. The LSC was satisfied it was not necessary for the promotion of the licensing objectives to set either a different limit on noise, or specific limits on bass frequencies, as a condition of the Premises Licence because of the Noise Nuisance Conditions (with the modifications set out below). In particular, the LSC considered the Noise Management Plan, which is required to be approved by the Council’s Community Protection team, coupled with the community engagement conditions, namely, Conditions 13, 12, and 58 as modified below, would be effective in mitigating the noise nuisance issues raised, because, for example, of the sensitivity of the Noise Management Plan to the issues raised, such as, bass frequencies; the notification of the event to those who live and work in the vicinity who may participate in the consultation meeting; and the provision of details of the complaints process to residents of noise sensitive properties, who may complain during the Event to trigger monitoring of the issue, and where appropriate, mitigation or amelioration of it. The modifications to the community engagement conditions are to require the production of a record of the letter drops and minutes of the public consultation meeting to be submitted to the Community Protection Team. The modifications mitigate the issues of some residents in the local vicinity not receiving notification and/or information of the Event, and/or not having an opportunity to have questions answered and/or their views considered by either the Event, and/or by the Community Protection Team.   In LSC’s determination it was appropriate, proportionate, and necessary to the promotion of the licensing objective to modify Conditions 13, 12, and 58 in the following ways, respectively:   (13) A public consultation meeting shall be held in advance of the event to hear residents’ concerns surrounding the event, which shall be minuted by the Premises Licence Holder, and a copy of the minutes shall be submitted to the Council’s Community Protection Team within 14 days of the meeting. (12) A letter drop must go to residents in the streets surrounding Blackheath on the Greenwich and Lewisham sides, notifying them of the event, on streets, as agreed with the ELSAG. The Premises Licence Holder shall submit a record of residential properties where the letters were dropped and the relevant date(s) when the letter drop(s) took place, no later than 14 days prior to the event, or other timescale as defined by the SAG chair (58) The  Premises Licence Holder shall conduct a letter drop to the nearest noise sensitive properties advising them of the event and complaints process. The nearest noise sensitive residential properties include properties on: (a)      St Germans Place; (b)     Vanbrugh Terrace; (c)      Vanbrugh Park; (d)     Langton Way. A copy of the template letter provided to residents shall be included in the Noise Management Plan. The Premises Licence Holder shall submit a record of residential properties where the letters were dropped and the relevant date(s) when the letter drop(s) took place, no later than 14 days prior to the event, or other timescale as defined by the SAG chair.   With the above modifications, the LSC considered that the Noise Nuisance Conditions addressed the issues that would undermine the prevention of public nuisance, and the set of conditions promotes the licensing objective of preventing public nuisance.   As to other issues of concern, save one, the LSC considered that the conditions sought, and agreed,  addressed the issues appropriately, sufficiently, and proportionally; further they were necessary for the promotion of the licensing objectives. For example, the concern regarding the competence of the Events Manager for the 2024 Event was that they were not competent during either the planning of the event or the build so as to take responsibility and ensure the event’s smooth running. The Licensing Team’s representations specifies issues of concern identified during the inspection of the 2024 Event.  However, another, competent, person took control on the day of the event rather than the specified Events Manager.   The LSC has determined that the concerns over the events manager’s competence - and the issues of concern that arise from a lack of competence, which engage each of the four licensing objectives, - have been addressed appropriately by Conditions 1 and 2; and notes that a named professional Events Manager was appointed, has attended SAG meetings, and SAG is satisfied with the co-operation of 4 Corner’s including that of the appointed Events Manager.   However, the LSC notes with concern that in 2024, the Events Manager also held the role of designated premises supervisor (“DPS”), and this same person is specified as the DPS in this application for the grant of a Premises Licence. The LSC considered the differences in role between an Events Manager and a DPS, considered the Licensing Team’s representations carefully, and also reviewed the debrief letter dated the 25 October 2024.   The LSC noted with concern that one of the issues addressed on the day, following inspection by Council officers, was the lack of Challenge 25 signage, and that the specified DPS was not present, or available, to engage with Council officers inspecting the premises, nor available to resolve the issue identified; another person stepped into this role to remedy the issue. Further, while the other matters raised related to the role of Events Manager, they involved similar duties, namely, supervising and arranging compliance with conditions imposed principally to promote the licensing objectives, and in particular, Public Safety and the Protection of Children from Harm.   In response to a question as to the DPS during oral representations, the LSC was told that the specified person was proposed as DPS for this application and that they would be working in more of a front of house role, and that two personal licence holders would be managing or supervising their own bars.   The LSC noted the absence of representations against the proposed DPS as the specified DPS, in particular, on behalf of the Council’s Responsible Authorities, including the Licensing Team, and on behalf of the police as a relevant representation as defined under s. 18(9) of the Licensing Act 2003.   However, the information provided to the LSC caused it to consider that the specification of the proposed person as DPS would undermine the promotion of the four licensing objectives, and in particular Public Safety, and the Protection of Children from Harm, having regard to the role of the DPS in managing the premises in compliance with the Licensing Act 2003, the Premises Licence, and the licensing objectives. The LSC determined that it was necessary, appropriate and proportionate to refuse to specify the proposed person in the application as the premises supervisor in order to promote the licensing objectives.   ACCORDINGLY, THE LSC RESOLVED AND DECIDED: 1.   that the application for the grant of a Premises Licence for 4 Corners Music Festival 2025, Circus Field, Blackheath, London, SE3 7AP for the following licensable activities, namely, the supply of alcohol for consumption on the premises only, outdoor live music,  outdoor recorded music, and outdoor performance of dance, to take place from noon to 22:00 on two days, Saturday 24th and Sunday 25th May 2025.is GRANTED subject to the conditions set out below and the conditions mandated by the Licensing Act 2003 in respect of the supply of alcohol; 2.   to refuse to specify the proposed person in the application as the premises supervisor pursuant to section 18(3)(b) and 18(4)(c) of the Licensing Act 2003   The following conditions apply to the Premises Licence General Event Management & Planning (1)         An appropriately qualified (IOSH or NEBOSH Qualified) Event Manager in health & safety legislation, approved by the Royal Borough of Greenwich (RBG) Entertainment and Licensing Safety Advisory Group (ELSAG), shall be appointed to run the event, and shall attend all the SAG meetings prior to the event. (2)         The final draft of the Event Safety Management Plan (ESMP), Risk Assessments (RA) and Contractor Risk Assessments must be submitted to the Royal Borough of Greenwich (RBG) Entertainment and Licensing Safety Advisory Group (ELSAG) for approval at least 28 days prior to the commencement of the event, or other such timescale as agreed with the SAG chair. Once approved, the Premises Licence holder and the appointed Event Manager must implement the Event Safety Management Plan and associated Risk Assessments for the duration of the event. (3)         A comprehensive site plan delineating the layout and positioning of all event structures, stalls, facilities, entrances, and exits shall be provided as part of the ESMP. This plan will undergo review and approval by the RBG Entertainment and Licensing SAG to ensure alignment with the safety standards, crowd flow management, and emergency evacuation procedures. (4)         Stages, roof structures, and any further temporary or special structures shall possess adequate strength and stability, both in service and in construction, and their assembly shall be carried out in accordance with plans, calculation and specifications drawn up by a competent designer. Details of these structures, including their construction together with any necessary calculations shall be submitted for approval under  Section 30 of the London Building Act 1939 to the Royal Borough of Greenwich Building Control Department at least 30 days prior to the commencement of the event. All temporary structures shall be included in the site plan. (5)         Comprehensive health and safety plans shall be shared with all staff and contractors to ensure adherence to festival safety protocols. (6)         Contractors shall provide public liability insurance documents and detailed risk assessments for all structures and activities on-site. (7)         An Emergency Response Plan shall be developed in collaboration with local authorities and emergency services to ensure swift and coordinated action in the event of any security threats, medical emergencies, or natural disasters. (8)         Risk Assessments shall be carried out to identify potential safety risks to the public associated with the event site and its operations, including fire safety, structural safety, and crowd management. (9)         A suitable number of toilets, including accessible toilets, shall be provided for the duration of the event, with calculations provided within the ESMP, and guidance used. The location of the toilets shall be clearly indicated on the site plan. (10)      Medical provision shall be supplied in accordance with a Medical Needs Assessment, with details provided within the ESMP and/or separate Medical Plan. (11)      All event staff shall have clearly defined roles and responsibilities, with a hierarchy of control, and contact details for all staff, as specified within the ESMP. (12)      A letter drop must go to residents in the streets surrounding Blackheath on the Greenwich and Lewisham sides, notifying them of the event, on streets, as agreed with the ELSAG. The Premises Licence Holder shall submit a record of residential properties where the letters were dropped and the relevant date(s) when the letter drop(s) took place, no later than 14 days prior to the event, or other timescale as defined by the SAG chair (13)      A public consultation meeting shall be held in advance of the event to hear residents’ concerns surrounding the event which shall be minuted by the Premises Licence Holder, and a copy of the minutes shall be submitted to the Council’s Community Protection Team within 14 days of the meeting.   Alcohol Sales and Management (14)      The Challenge 25/Think 25 or contemporary equivalent proof of age scheme shall be operated at the premises. All customers who appear under the age of 25 will be challenged to prove that they are over 18 when attempting to purchase alcohol. Acceptable forms of ID include a photo driving licence, passport, or home office approved identity card bearing the holographic ‘PASS’ mark. If the person seeking alcohol is unable to produce an acceptable form of identification, no sale or supply of alcohol shall be made to or for that person. (15)      All bar-staff shall be trained in the law about the sale of alcohol. Such training will include challenging every individual who appears to be under 25 years of age and to refuse service where individuals cannot produce acceptable means of identification, acceptable forms of ID and using the refusal register. Training shall be conducted prior to the event.  A training log shall be made available for inspection by Police and “authorised persons” (as defined in the Licensing Act 2003) immediately upon request. (16)      The following posters, or their contemporary equivalent shall be displayed conspicuously on the premises in customer facing areas: (a)  ‘Think 25’ to advise potential purchasers that suitable proof of age will be required for all purchasers who appear to be under 25. (b)Any updated and relevant posters which highlight child protection and safeguarding measures as given by Police and “authorised persons”. (17)      A refusals log shall be kept at the premises and made immediately available on request to the Police or an "authorised person". The log must record all refused sales of alcohol and include the following: (a)  the identity of the member of staff who refused the sale; (b)the date and time of the refusal; (c)  the alcohol requested and reason for refusal; and (d)description of the person refused alcohol. (18)      An Alcohol Management Plan will be produced and contained in the ESMP and shall set out procedures to prevent crime and disorder arising from the consumption of alcohol. (19)      Drinks will not be served in glasses or glass bottles on site. Polycarbonate or paper drinking vessels shall be used for all alcoholic and soft drinks served to attendees and all drinks supplied in glass bottles will be decanted into polycarbonate serving and drinking vessels or other non-glass (plastic, paper, etc.) materials. (20)      No alcohol shall be permitted to be taken off the licensed site. (21)      Customers shall only be permitted to consume alcohol that has been purchased from the premises. (22)      Each Bar/Tent shall be individually managed by a personal licence holder and have a minimum 2 SIA security officers assigned to it, during licensable hours.     Security, Surveillance & Incident Response: (23)      Professional security personnel trained in crowd management, conflict resolution, and emergency response protocols to maintain a secure environment shall be employed and present throughout the duration of the event. There shall be a minimum of 75 SIA licensed security officers employed for the duration of the event, and at least 5 additional stewards. (24)      Body worn video cameras shall be worn by SIA staff holding key positions including Search, Response, Eviction, Perimeter, as well as the Supervisory team. When SIA Security staff are deployed the event organiser shall ensure that records are kept by the Designated Premises Supervisor (DPS), at the event site, of the following details of any door-supervisor employed at the premises: Name and date of birth, full 16 digit SIA badge number and dates and times employed. These records must be made available, in useable form, to the Metropolitan Police, Greenwich Council officers or authorised officers of the Security Industry Authority upon request. (25)      CCTV cameras shall be deployed strategically across the event grounds to monitor crowd behaviour, deter criminal behaviour, and provide evidence in the event of any criminal activity or disorderly conduct. (26)      The CCTV unit shall be deployed from 08:00 hours on both days of the event, until midnight. All recordings made by the CCTV system shall be retained and stored in a suitable and secure manner for a minimum of 31 days and shall be made available on request to the Metropolitan Police, the Licensing Authority or other Responsible Authorities. A minimum of one member of staff on duty will be able to operate the CCTV system. (27)      SIA Security staff wearing Body Worn Video Cameras (BWVC) shall begin recording should there be any incidents of Crime and Disorder, or if they deem it appropriate when an incident occurs. In the event that body worn cameras are switched on, these will only be turned off once the incident has been defused and brought under control. All recordings shall be stored securely for a minimum period of 31 days with date and time stamping. Viewing of recordings shall be made available immediately upon demand by the Metropolitan Police or an authorised officer of the Licensing Authority. (28)      The event will operate a “zero-tolerance policy” towards any forms of antisocial behaviour, illegal drug use, violence, or vandalism. Security staff shall be authorised to remove any individuals found engaging in such activities, from the premises. In the event of any criminal behaviour occurring, all perpetrators shall be detained until the police arrive. (29)      An incident log shall be kept at the premises, and made available on request to an authorised Local Authority or Police Officer, which will record the following: (a)  All crimes reported to the venue; (b)All ejections of patrons. (c)  Any complaints received; (d)Any incidents of disorder. (e)All seizure of drugs or offensive weapons; (f)   Any refusal of the sale of alcohol; (g)  Any visit by a relevant authority or emergency service. (30)      Clearly marked and signage for emergency contact points shall be stationed across the site for attendees to report issues. (31)      The Premises License Holder shall operate an admission search policy for all staff, artists, promotors and entourage. The search will operate a 3-stage process: Passive Drug Detection Dogs (minimum of 2 K9), Wand Metal Detector, Visual & Physical Search (hands on). All bags will be searched and all those entering will pass through the metal detector and/or wands search area. (32)      Security personnel will remain on-site overnight to protect equipment, vendor stalls, and site security during the two-day event. (33)      A secure and robust accreditation system must be in place for VIP’s, guest list, artists, staff/ crew. Backstage areas, access onto stages, back of house and non-public areas must be controlled at all times by security who must maintain the accreditation system.   Search Policy & Drug Control (34)      Random bag checks and metal detectors will be used at all entry points to prevent prohibited items from entering the site. (35)      Strategically placed amnesty bins will allow attendees to safely dispose of prohibited items without facing consequences. (36)      A weapons sweep must be conducted of the event site following completion of the event build up but prior to the event opening to the public. Regular weapon sweeps shall be carried out of the event site and shall be recorded in the Security and Incident log. (37)      All attendees to the event will be subject to search. The search will operate a 3-stage process: Passive Drug Detection Dogs (minimum of 2 K9), Wand Metal Detector, Visual & Physical Search (hands on). All bags will be searched on entry. Searches will be carried out by SIA Registered staff of the same sex. (38)      A clear visible notice shall be placed at the entrances to the premises advising those attending, that it is a condition of entry that all customers agree to being searched and the Metropolitan Police will be informed of anyone who is found in possession of a controlled substance or weapons. Anyone found with drugs will be refused entry, more than the agreed quantities for personal consumption (as outlined in the drugs policy) of controlled substances or NPS the Metropolitan Police will be informed immediately. The Drugs Policy will include New Psychoactive Substances (NPS) and No2/NOS/Nitrous Oxide. No2 will not be permitted on site and any found on entry will be confiscated. (39)      Anyone found with an offensive weapon will be ejected/refused entry to the event, detained by SIA security staff, the Metropolitan Police informed immediately, and the attendee detained until police arrival. The Premises Licence Holder shall be responsible for the implementation and operation of  a weapons policy in conjunction with search and seizure. Any amendments to the policy must be agreed in writing with South East Police Licensing Team 14 days prior to any event. (40)      The Premises Licence Holder will operate an anti-drugs policy in conjunction with a search and seizure policy in compliance with agreed memorandum of understanding with the Metropolitan Police. This will also include storage and disposal procedures. Signage will be displayed throughout the premises. Any amendments to the policy must be agreed in writing with South East London Police Licensing Team. (41)      Passive Drug Detection Dogs shall carry out a sweep of the event site following completion of the event build up but prior to the event opening to the public. The catering, merchandise stalls and any customer lockers will be included within the drug detection sweep.   Ticketing & Attendance: (42)      On any advertising material it must state ‘subject to licence’. No advertising material is to go out before 31st January 2025. (43)      There will no admission of attendees after 19:00 hours. (44)      Every 5 days the venue will provide Police Licensing with an update of how many tickets have been sold from the date of issue of the Premises Licence.   Dispersal Policy: (45)      The Premises Licence Holder shall display clear and visible signage to direct all event attendees towards the nearest transport for the duration of the event. (46)      There shall be a written dispersal policy, which will include a deployment plan for SIA at transportation hubs (Maze Hill, Greenwich and Blackheath), as agreed with the relevant responsible authorities, implemented at the premises and a copy shall be lodged with the South East Police Licensing Team. Any amendments to the policy must be agreed in writing with the South East London Police Licensing Team.   Welfare & Vulnerable Persons: (47)      The Premises Licence Holder shall operate a Vulnerable Person Policy which must include Welfare and Ask for Angela training for all members of staff. (48)      The venue shall have a designated welfare area as required and approved by the Licensing Authority. (49)      The venue will employ welfare officers during the event. These will be in addition to the agreed number of SIA and stewards.   Counter Terrorism Measures (50)      The Premises Licence Holder shall engage with freely available counter terrorism advice and guidance through Counter Terrorism Protect Officers and Counter Terrorism Security Advisors. (51)      All members of customer facing staff, including those involved in the sale or supply of alcohol, shall undertake and complete the Action Counters Terrorism (ACT) Awareness eLearning, before the commencement of the Festival Event. Such training is available at https://www.gov.uk/?government/?news/?act-awareness-elearning? or https://www.protectuk. ?police.uk/?group/?84.   Noise Management & Control: (52)      A qualified noise management team will monitor sound levels throughout the event to ensure compliance with local noise regulations and any locally set limit agreed with the Royal Borough of Greenwich. (53)      Audio systems will utilise directional speakers to focus sound on the festival grounds and minimize noise spill to surrounding areas. (54)      Soundproofing measures, including noise barriers, shall be placed strategically to protect nearby residents from disturbance before the commencement of the Festival Event. (55)      The Premises shall not be used for licensable activities under the terms of this Premises Licence until an appropriate Noise Management Plan has been approved by the Royal Borough of Greenwich Environmental Health, Community Protection Team. The Noise Management Plan shall be submitted no later than 14 days prior to the event, or other timescale as defined by the SAG chair. Thereafter, Regulated Entertainment falling within the ambit of the Noise Management Plan must be conducted in accordance with the terms of that Plan. Any amendments or changes to the Noise Management Plan shall have to be approved in writing by the Royal Borough of Greenwich. (56)      Sound checks shall be conducted before and during the event to ensure compliance with local noise levels, set at 65dB LAeq 15 mins (measuring points defined within the Noise Management Plan). The licence holder shall appoint a qualified Sound Control Manager with demonstrable experience in sound engineering and noise control. The Sound Control Manager shall have the authority to control music volume, including lowering or stopping performances to comply with the noise limit. The Sound Control Manager shall adjust the overall volume and equalisation as needed. If noise levels exceed the limit, the Sound Control Manager shall take immediate action to reduce the volume. (57)      The event organisers shall provide to the Council’s Community Protection Team, unrestricted access to the event and provide contact details for the site management team in the event the Council receives complaints of noise nuisance. Contact Details to be provided in writing prior to the commencement of the festival event. (58)      The  Premises Licence Holder shall conduct a letter drop to the nearest noise sensitive properties advising them of the event and complaints process. The nearest noise sensitive residential properties include properties on: (a)  St Germans Place; (b)Vanbrugh Terrace; (c)  Vanbrugh Park; (d)Langton Way. A copy of the template letter provided to residents shall be included in the Noise Management Plan The Premises Licence Holder shall submit a record of residential properties where the letters were dropped and the relevant date(s) when the letter drop(s) took place, no later than 14 days prior to the event, or other timescale as defined by the SAG chair.   (59)      The Premises Licence holder shall provide a clear written outline of the direction of the speakers for the event & the points they intend to conduct their noise measurements. These shall include points on: (a)  St Germans Place; (b)Vanbrugh Terrace; (c)  Vanbrugh Park; (d)Langton Way. A diagram of the layout of the event including the direction of the speakers to be included in the Noise Management Plan. (60)      Within 28 days following conclusion of the event the event organiser shall provide to the Council’s Community Protection Team: (a)  A copy of the complaints Log made by residents during 4 Corners Festival; and (b)A copy of the DB readings captured at the separate points.   Medical Provision & Emergency Response: (61)      A professional medical team  shall be stationed at a well-equipped first aid point to respond to minor injuries or serious emergencies. (62)      A detailed written plan will outline protocols for handling medical emergencies, including communication channels and designated routes for emergency vehicles.   Public Safety & Infrastructure: (63)      Fire extinguishers shall be placed near potential hazard areas, and fire marshals shall be designated to monitor compliance. (64)      Security and stewarding staff shall be trained in crowd control techniques and emergency evacuation procedures. (65)      Emergency exits shall be illuminated and clearly signposted, with staff stationed nearby to assist in an evacuation if necessary.   Traffic Management & Parking: (66)      Attendees shall be encouraged, including through marketing material to use public transport to reduce congestion and traffic, and environmental impact. The licence holder shall facilitate coaches / buses to accommodate increased demand, as required. (67)      No guest parking will be permitted on site. Limited on-site parking will be permitted to event staff/ contractors and artists with an accreditation system in place. (68)      Stewards and security personnel will direct vehicle movement on and off-site, preventing unauthorized parking and reducing congestion. (69)      Clearly marked no-parking zones shall be enforced around the venue to discourage improper use of local streets. Crowd Management & Code of Conduct: (70)      A published code of conduct will outline acceptable and prohibited behaviours, including guidelines on respect for others, safety, and prohibited items. The code of conduct will be prominently included in all promotional materials, on tickets, and on signage across the site. Non-compliance with the code of conduct will result in corrective action by staff, which may include removal from the site and, in severe cases, referral to law enforcement. (71)      Event messaging shall encourage attendees to respect local residents and businesses when traveling to and from the festival. (72)      A robust security team, both on-site and in surrounding areas, shall manage crowd behaviour, ensure site security, and liaise with local law enforcement. (73)      Two-way radios and a central command hub will enable real-time communication between stewards, security, and event management teams.      RIGHT OF APPEAL The Applicant and any person who has made a relevant representation may appeal the decision of the Licensing Sub-Committee by written notification to the Magistrates’ Court within 21 days of receipt of the decision notice and reasons.