REPORT REGARDING

HOPE AND GLORY

FESTIVAL

LIVERPOOL, AUGUST

2017

PREPARED BY:
The Event Safety Shop Ltd
Charles Hewett and Tim Roberts
59 Prince Street

Bristol. BS1 4QH
October 2017

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1.  EXECUTIVE SUMMARY
The Hope and Glory Festival, held in the St George’s Quarter on the weekend of 5/6th
August  2017,  was  intended  to  be  a  concert  and  family  event  for  12,500  attendees.
Numerous issues arose on Saturday, necessitating substantive intervention by LCC and
others, who should be commended for their actions.
Organisers, tinyCOW cancelled the second day at short notice, following the effective
collapse of their operational management team.   Attendees described disorganised and
dangerous conditions, and the event attracted widespread and negative publicity to the
city.
On  the  basis  of  the  information  provided,  our  opinion  is  that  the  event  was  poorly
planned  and  suffered  from  failures  of  management  and  operational  control.    Serious
risks to public safety resulted.  Whilst cancellation of the Sunday event was no doubt a
disappointment to many, it was an appropriate course of action.
People attending large‐scale events have a right to expect they have been planned and
produced by a competent Organiser.  We conclude that the discomfort, confusion, anger
and  disappointment  caused  to  ticket‐holders  at  the  Hope  and  Glory  festival,  were  a
direct result of the organiser’s planning and operational failures.
We also conclude that opportunities were missed by the Council’s Safety Advisory Group
and the associated Joint Agency Group to identify, shortcomings in advance.
The legal duty to produce a safe event remains that of the Organiser. However, Liverpool
City  Council  should  review  the  functioning  of  the  Safety  Advisory  and  Joint  Agency
Groups along with premises‐licence and land‐use agreements for large events, to ensure
that sufficient time and resources are available to effectively scrutinise complex event
plans.

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2.
INSTRUCTIONS
The Mayor of Liverpool has commissioned this review of the Hope and Glory Festival to
examine the circumstances that led to the operational failure, and eventual cancellation
of the event. In particular the following aspects are to be considered:
•
The circumstances of the event build week, and event delivery on both show
days.
•
The Liverpool City Council (LCC) process for engagement of tinyCOW (CEO Lee
O’Hanlon) as the event organiser.
•
The planning stages of the event, including the thoroughness of the Event
Management Plan (EMP) and the scrutiny provided by the Joint Agency and
Safety Advisory Groups.

3.
AIM
To reach objective findings where clear evidence exists, and to offer opinion (where this
can be corroborated by statements, or other evidence) regarding the role of LCC and
other agencies in their oversight of the failed Hope and Glory event.
It is recognised that people may hope for answers to refund, payment or other queries
relating to the festival, but The Event Safety Shop has not been asked to consider these
issues  and  nor  would  we  be  an  appropriate  organisation  to  carry  out  such  an
investigation.

4.
METHODOLOGY AND DOCUMENTS
The Event Safety Shop Ltd had no direct involvement with the event, and this report has
been  produced  solely  on  the  basis  of  documentation  supplied  to  us,  and  interviews
conducted with a number of stakeholders.  Information has been drawn from:
  Documents relating to the event presented by tinyCOW.
  Event planning documents, such as the Event Management Plan (EMP).
  Minutes from Joint Agency Group (JAG), and Safety Advisory Group (SAG) meetings.
  Interviews with participants from the organisations involved.
  Written de‐brief documents submitted by key participants and organisations.
  Answers to written questions
  Reports and still photographs from various sources, including several members of
the public who have independently submitted material.
  Social  media  statements,  and  comments  from  many  of  the  participants,  and
members of the public.
A full list of interviews and information sources is included in Appendix 1.
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The course of events (as established from the material reviewed) from each phase will
be described, and then a number of questions arising shall be posed.
Conclusions and our own opinion shall follow each section. These will be highlighted in
different colour to clearly differentiate opinion from reported events.

5.
INITIAL APPLICATION
In mid 2015 the Head Of Creative Development at Culture Liverpool (CL), was asked to
investigate sourcing independent music event providers to produce events in the city.
That  concept  is  proven  across  many  cities  in  the  UK,  and  against  a  background  of
declining budgets for councils is a sound strategy, given that the event organisers accept
all the financial risk. It is noteworthy that several independent events have successfully
taken place in Liverpool in the recent past.
In  2015  discussions  were  held  with  the  management  of  Echo  and  The  Bunnymen,  to
produce a stand‐alone show (with support acts), on a single stage in the City Centre. Lee
O’Hanlon (LOH) had been proposed as the Production Manager for the event.
The  initial  concept  failed  to  come  to  fruition,  but  in  mid‐2016  LOH  and  Tiny  Cow,
submitted a pitch document for a similarly scoped music event.
The St George’s Quarter (SGQ) area was seen a potential site, although the precise layout
was still indistinct. SGQ had successfully hosted large events on the plaza in front of the
St Georges Hall main entrance area in the past.
CL recommended LOH’s prospective bid to SGQCIC (Community Interest Committee).
In December 2106 LOH presents to the SGQCIC  ‐ and the concept is approved.
Questions and our opinion
1.  Was sufficient scrutiny undertaken at the time of the initial application?
The LCC event strategy seeks to maximise utility of public spaces and to act as a host for
events of all types for cultural, economic and social benefit of the city.

It  would  be  improper  (and  illegal)  to  bar  certain  categories  of  people  from  making
applications,  and  therefore  there  is  no  formal  process  whereby  applicants  are
‘screened’.

It is reasonable for those receiving initial application for an event of this sort to have
confidence  that  the  emerging  detail  of  plans  will  be  subject  to  scrutiny  through  an
established process of scrutiny by LCC, emergency service and other stake‐holders.
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The  Licensing  Act  2003  provides  for  objections  (or  ‘representations’)  against  an
application on various grounds.  However, it is important to recognise that Mr O’Hanlon
was NOT applying for a Licence under the Act.  A Licence to hold regulated entertainment
for the St Georges Quarter was already in place – and along with every other potential
user of the space, his application sought to operate under this existing arrangement.
During the initial process, all respondents have commented that O’Hanlon appeared to
be knowledgeable and credible, providing information and answers to questions put by
relevant agencies.

The authors have been asked in emails from the public why no ‘background checks’ were
made of LOH or of tinyCOW; claiming that a Google search would have revealed may
have revealed a somewhat chequered history.  We do not concur with this opinion.  A
check  on    membership  of  professional  bodies  or  trade  associations  (for  example  the
Concert  Promoters  Association,  National  Outdoor  Events  Association,  Production
Services Association), would be appropriate – but not on the basis of unsubstantiated
reports found online.

The  minutes  of  the  JAG  held  on  30th  January  demonstrate  a  considerable  degree  of
detailed  examination  and  discussion  between  responsible  authorities  and  tinyCOW
representatives.    There  is  no  indication  of  anything  out  of  the  ordinary  and  such  a
meeting  would  normally  give  a  justifiable  degree  of  confidence  in  the  Organiser’s
proposals.

It is therefore our conclusion that whilst there was no substantive failure at this early
point of the application process.  It is reasonable for stakeholders to simply consider the
‘evidence’ provided at the JAG, rather than undertake extensive background checks.

2.  Should  the  City  have  a  more  robust,  and  formalised  system  for  assessing  the
suitability, capacity and track‐record of independent event organisers?
Yes. More substantial checks at the initial application stage would be an effective means
of assessing applications before they become too advanced.  Particularly events beyond
a certain size or risk‐profile. Many local authorities implement such a system.

6.  EVENT CONSTRUCTION AND DELIVERY
The build week appears to have proceeded reasonably well.  Respondents stated that
there were significant distractions, notably towards the end of the process.
There had been on‐going discussions regarding the use of the Liverpool Museum steps.
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Lee O’Hanlon appears to have been very keen to have them within the event footprint
(though note that they were not included on the Event Management Plan Site Plan – see
Appendix 4), possibly encouraged by the steps use the previous weekend in the Pride
event.
LOH  is  alleged  to  have  repeatedly  threatened  to  cancel  the  event  (in  writing  on  one
occasion) if the Museum steps were not made available. After meetings facilitated by
the SGH LLC Manager, and City Asset Manager with the Museum that issue appeared to
be resolved (the steps did not form part of the event site).
By Friday the site should have been in a state of near completion, but this was not the
case.    This  was  further  compounded  by,  LOH  having  arranged  for  a  ‘secret  gig’  in  St
George’s Hall on Friday night. The site crew were used at short notice to move stage‐pit
barrier and pedestrian barrier into the hall.
Due  to  confusion  over  the  requirements  of  the  main  stage  PA  (which  had  been  sub‐
contracted out at short notice), site crew were seconded to assist with unloading and
installation effectively lost a day from their site build plan.
Respondents stated that regular site and production meetings were not held. It would
be normal practice to have at least one daily meeting of department heads to identify
specific tasks for the coming day, priorities or changes to the printed schedule.
Additionally,  some  respondents  have  reported  that  LOH  appeared  focused  more  on
facilities for the artists, to the exclusion of issues on the main site.
Timeline of important incidents (all timings are approximate)
Saturday 5th August
08.00 – Zoe Rubert (ZR) is on site, in her role as St George’s Hall LCC Liaison manager –
note at this stage, she has no operational role in the event.
09.15 – Ann‐Marie Moran (AMM) from LCC Licensing visited for the first of two planned
inspections. As expected, the site appeared to be in the late stages of build.
11.15 – Licensing meet with Richard Agar (RA) and request sign‐offs for stage, structures
etc. They are not yet available.
ZR has noted:
•
No signage erected
•
Some  debris  on  the  ground  (probably  from  damaged  improvised  curb
protection)
•
Empty equipment stillages being moved around site by plant
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ZR  and  AMM  meet  to  discuss  concerns  of  the  readiness  of  the  site  to  open  (a  ‘soft’
opening has been planned for 11.30).
ZR visits Event Control (EC), and notes a high degree of activity, with a lack of separation
between the EC and Artist Liaison areas. ZR requests a radio.
AMM requests that ZR pursues the sign‐offs from RA.
12.00 – LOH is pressuring RA to get the site ready to open over the radio.
RA is informed by ZR that the sign‐offs must be submitted before opening.
LOH starts to become irate and swears repeatedly at RA over the radio net.
12.00 – ZR calls Angie Redhead, LCC City Asset Manager (AR), to express concern over
the management of the event, and the apparent absence of an operations manager.
12.20 – LOH declares that the site will open in 5 minutes irrespective of sign‐offs and
Safety Managers approval.  There is no evidence that a “Safety Event Checklist” (Event
Management Plan Appendix R) was ever completed, or indeed that any strategic review
of site conditions were carried out prior to opening.
12.20  –  12.35  ‐    Communication  between  RA/ZR,  and  Chris  Sargent  (CS),  the  Site
Manager regarding the readiness to open.
12.40 – ZR receives sign‐offs verbally from RA.
The site opens at sometime between 12.30 and 12.40
The final vehicle plant movements are finishing as the first public enter site.
12.45 – AR arrives on site. After discussions, AR suggests that ZR steps in an operational
role to assist with site issues. LOH agrees and welcomes the help.
13.00  –  16.00  –  The  site  is  open,  but  struggles  to  contend  with  a  number  of  issues,
including  at  the  entrance,  where  there  is  confusion  over  wristbands,  and  the  search
regime, contributing to significant queues. Additionally there are some complaints over
the length of queues at the bars, toilets, and the late running of the main stage acts.
Note that there is still no signage on site.
16.15 – Reports to EC of crowd congestion at the entrance to St John Gardens. ZR and
security meet and agree a simple plan involving barrier and staff to implement a two‐
way flow through the 3 metre gap.
Police arrive on site – as a consequence of a 999 call describing ‘crowd crushing’, the
Duty  Force  Officer  arrives  on  site  with  all  other  available  officers.  By  this  time  the
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congestion has eased. Note that LOH had also asked a PCSO to call 999, stating that ‘he
had lost control’.
Police close the site as a precaution while an assessment is made.
A meeting is held on the Museum steps with the senior police officer, LOH, ZR, RA and
Security lead Paul Mansi – it is agreed to suspend all walk‐up ticket sales. LOH insists that
the problem is the lack of ‘bridge’ (actually the scaffold steps structure on the site plan),
which had not been installed.
AR returns to site, meets with Police – confirms that they are content with the existing
event operations.
Entrance re‐opened and Police leave site.
17.00 – LOH dismisses RA over the radio – RA attempts to remain on site to assist on the
main stage. He eventually is ejected by LOH at 18.30.
ZR calls AMM to check if having a Safety Manager is a Licence condition.
LOH states that he is now the Safety Manager.
18.00  –  LCC  team  and  security  now  ‘fire‐fighting’  multiple  issues  on  site  –  bar  over‐
crowding/generator  failures/fence  jumpers,  and  on‐going  concerns  about  the
congestion at the SJG gate.
18.10 – LCC team call urgent meeting with LOH regarding operational management of
the  site.  LOH  appears  to  breakdown  emotionally  and  leaves  the  meeting.  He  is  not
contactable either by radio or mobile phone.
All respondents present on site concur that LOH is not seen again until after the site is
closed. LCC staff effectively take over full operational management of the event.
LCC team and Security formulate a plan to enable to event to remain open in safety. (1
bar is temporarily shut)
An important consideration is what effect a cancellation would have on the approx. 6.5k
people  inside  –  many  of  whom  are  agitated  and  not  well‐disposed  towards  the
organisers.
19.00‐23.00  –  The  new  management  team  led  by  LCC  staff  deals  dynamically  with
various issues – including staffing the Emergency Exit by the stage ‐ and with assistance
from  the  Traffic  Management  consultant  (Simon  Gilford),  and  the  Police,  co‐ordinate
some short‐term road stops during the egress.
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23.30 – Hot de‐brief held, and measures required for opening on Sunday discussed. Note
that all sub‐contractors are content to be employed by LCC on day 2, in order for the
event to continue.
Note here that LCC approached RA to return to site in a management role for Sunday.
Other site staff, specifically Chris Sargent, worked overnight to ensure that an improved
queue lane system was in place for Sunday opening.
Sunday 6th August
02.00  –  Security  manager  states  that  LOH  returned  to  site  at  02.00  and  spoke  with
technicians from the headline act who were setting up in readiness for the Sunday show.
LOH indicated that the event would be cancelled and dismissed them.
05.00 ‐ Social media post from Hope and Glory account stating “No festival today”
09.30 – Unaware of the developments in the early morning, JAG meeting on site – The
new  LCC  management  team  had  managed  to  organise  remedial  site  works  and  re‐
organised/re‐briefed all the event functions in order to operate safely on Sunday with a
reduced capacity of 8000.
A decision is taken to formally cancel once the overnight activities are discovered.
Questions and our opinion
1.  Was the site ready to open?
No.  Important elements, such as wayfinding and exit signage were not installed, nor was
the pedestrian bridge between William Brown St and St John’s Gardens constructed –
but the absence of this critical feature does not appear to have been noted by anyone
prior to opening.  Staff do not appear to have been properly briefed or prepared.

2.  Did site meet the undertakings given in the EMP when it opened?
No

3.  Were there effective measures in place to monitor the capacity of the site?
No. Reports from respondents and members of the public suggest that ticket checks and
searches were cursory.  Some respondents state they were given incorrect wristbands
allowing access to the full weekend, even though they only had day tickets.  Others state
that their tickets were not torn on entry and could be re‐used

4.  Were  there  grounds for  cancelling  the event, either before opening,  or  after the
temporary closure on Saturday afternoon?
With hindsight it is easy to argue for earlier cancellation.  However, at the time it is much
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more difficult to judge.  Once temporary measures had been implemented to recover
the  situation  at  the  Gardens  entrance,  the  event  achieved  a  degree  of  stasis  (if  not
comfort or customer satisfaction).  This would have to be balanced against the inevitable
risks of cancelling and then seeking to remove an agitated crowd from the site.
The event was only able to continue on Saturday after 18.30 due to the collective efforts
of  LCC  staff  who  had  volunteered  to  assist  and  site  contractors,  notably  Security,
Medical, Site and Traffic Management ‐ they should all be commended for their efforts.

5.  Were the incidents of over‐crowding or pedestrian congestion?
Yes, although it is important to note that over‐crowding may occur in localised areas of
an event site rather than as a result of general over‐population. So, it is possible to have
over‐crowding even though the number of people present is below the Licensed or ‘safe’
capacity.  This is why good site planning is so important.  The site clearly failed at well
below the agreed maximum capacity.  Had 12,500 attended the event, the results would
have been significantly worse and the risk level unacceptable.
The pictures below show the route from William Brown Street into St John’s Gardens



6.  Was there a significant risk to public safety?
Our conclusion is, yes.   Whilst – none of the staff interviewed thought that to be the
case, members of the public who have supplied accounts and photographs were clearly
caught in an area of localised high density and extreme congestion.  Such conditions are
uncomfortable  and  scary.    Even  in  relatively  small  areas  of  contraflow,  there  is  a
potential of injury to members of the crowd, particularly if someone were to trip or fall.
Once caught in a dense static crowd, it is often impossible to see how far you are from
the edge, or how long the congestion will last.  The effects may be very localised, but the
pressure and sense of threat can be very distressing.
Comments received include:
“I  climbed  on  a  bin  and  over  a  wall  to  get  in  and  out  of  Embraces  set  because  the
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bottleneck at the toilet/bar/archway was petrifying.” [C.S.]
“…we had no option but to leave the festival after only a short time. It felt completely
unsafe.” [D.D.]
“People could have been hurt .. very seriously. There was a complete disregard for safety
from the beginning of the event.” [KB]
“As  a  regular  gig  and  festival  goer  I  was  shocked  and  horrified  by  the  situation  I
encountered…” [DB]
It is recognised that such statements have not been obtained under oath or subject to
critical  examination.    However,  the  unbidden  nature  of  the  accounts  and  the  sheer
number presented mean they cannot be discounted as unrepresentative of the general
public experience.

7.  Was it appropriate to cancel the Sunday event?
Yes.  We believe that cancellation was justified on the basis of maintaining public safety.
It is possible that an operational team could have been assembled comprising LCC and
other staff to operate the site safely.  However this would have necessitated substantial
action to address the inherent failings of the site layout. Concerns about the integrity of
the ticketing arrangements added to concerns.
The actions of Mr O’Hanlon early on Sunday morning, dismissing the headline act and
announcing that the event had been cancelled, render this a moot point.  It appears that
the LCC team working to save the second day were unaware of these developments until
at least 09.30 hrs.

7.
THE PROCESS OF EVENT SCRUTINY
Attention is turned to the process of scrutiny adopted by LCC and other stakeholders in
assessing the Hope and Glory event as it progressed from initial plan through to delivery.
Central to this examination is the question of whether the eventual failure should have
been identified during the planning process.
It is not within the scope of this report to provide extensive background on the provisions
of the Licensing Act 2003 or the policy of LCC regarding culture and the arts.  However,
a degree of familiarity is required to understand the process of applying for and gaining
permission to produce an event such as Hope and Glory on the streets of Liverpool.
The  Licensing  Act  provides  a  mechanism  whereby  local  government  regulates  a  wide
range of social and cultural activities; including the sale of alcohol, operating a cinema,
nightclub or late night food sales.  The performance of live and recorded music are also
covered by the Act, so a music festival requires a Premises Licence.
Like many UK cities, Liverpool has granted on‐going licensees to itself for the use of many
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public spaces and parks, including the area surrounding St Georges Hall.  A copy of the
licence for the St Georges Quarter (SGQ), which includes William Brown Street, St Johns
Gardens and the front of the building onto Lime Street, is included in Appendix 2.
The policy removes some of the hurdles for people wishing to produce cultural activity
and makes the event market more accessible to all.  However, there is still a process of
scrutiny which is designed to ensure that any independent event organizer, operating
under the LCC premises licence, meets the core objectives of the Licensing Act.
Liverpool  City  Council,  has  established  a  Safety  Advisory  Group  to  consider  inter  alia
applications for events.   The SAG is supported by a Joint Agency Group, which is also a
meeting  of  representatives  from  key  emergency  service  and  other  subject  area
specialists.  Unlike the SAG, which is convened and chaired by LCC, the JAG is hosted by
the event applicant themselves.  The rationale being that the JAG has time and capacity
to  focus  on  the  detail  of  specific  projects,  whilst  the  SAG  is  obliged  to  take  a  more
strategic  oversight,  dealing  with  a  large  number  of  applications  at  each  meeting.    It
appears that the SAG is largely guided by the discussions and collective opinion of the
JAG.
Guidance for Safety Advisory Groups (SAG) was published by the Emergency Planning
College in January 2015. Whilst every Local Authority is as liberty to constitute a SAG as
they require, the guidance sets out a series of terms of reference for the effective safety
management of licensable events, which includes:

•
Advise the LA or event org in order to ensure high standards of health and
safety
•
Promote principles of ‘sensible risk management and good practice in safety
and welfare planning’
•
Advise the LA/Ev Org in respect of the formulation of appropriate contingency
and emergency arrangements
The  operation  of  a  SAG  does  not  in  any  means  diminish  the  responsibility  of  LCC  to
administer and regulate licensable activity.  The SAG does not become a cabinet with
collective responsibility.  Instead its role is solely to advise:

“The SAG does not make any decisions on behalf of the local
authority or other agencies as its role is advisory and as such it has
no authority to either approve or ban events” [p17]

Whilst  The  Event  Safety  Shop  has  been  provided  with  copies  of  the  minutes  of  SAG
meetings, no formal advice from the SAG has been seen – whether that advice is directed
to the LCC Licensing Officer or to the applicant.
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A  review  of  the  minutes  appears  to  indicate  that  the  SAG  was  a  rubber‐stamping
exercise, where events had engaged with a JAG. The report from the JAG was taken as
confirmation  that  the  application  had  been  assessed,  scrutinised  and  met  with  the
assent of subject matter experts and duty‐holders.
No representation against the Hope and Glory event was made to the SAG or Licensing
Officer,  by  any  member  of  the  public,  local  business  or  responsible  authority.  The
supposition of the Licensing Act is that applications should be granted unless there are
demonstrable and legitimate reasons to withhold permission.
The  minutes  of  the  SAG  held  on  July  19th  show  the  SAG  discussed  a  wide  range  of
forthcoming events, many of which were at least equal in scale to Hope and Glory.  That
item merits just five words in the minutes:
“Hope and Glory; no issues” [Minutes LCC SAG, July 19th 2017, p2]
Such brevity is not surprising, paragraph 3.7.2 of the guidance states:

“Of course, referring an event to a SAG does not necessarily imply
lengthy discussions at meetings as there are ‘smarter’ ways of
discharging the responsibilities..” [ibid p.18]

The Liverpool SAG chose a smarter method by expecting the JAG to carry out the detailed
work.  It would also be incorrect to assume that the words ‘no issues’ mean that the
event is  given the green light  to proceed without any further review.  Additional JAG
meetings were scheduled right up to an on‐site meeting on Friday 4th August.
The final hurdle for Hope and Glory to clear is in obtaining permission for use of land
owned by LCC, in this instance the St Georges Quarter itself.  The Land Use Agreement
invokes different statutory duties to a Premises Licence and offers another opportunity
for proposed activities to be scrutinized.  The Land Use Agreement includes many clauses
and requirements which may have revealed potential gaps in the event plan, however
these did not appear an impediment.
The signed copy of the Land Use Agreement provided to TESS (Appendix 3) is dated 26th
August 2017, i.e. some three weeks after the event. It is assumed this must be a typo



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8.  SAG AND JAG TIMELINE

A summary of meetings and key developments is provided below – drawn from the notes
and documents of several respondents.

17 Oct 2016
Culture Liverpool advise that Hope and Glory is an event Liverpool are keen
to support
1 Dec 2016
St George’s Quarter meeting held where the planned Hope and Glory
event had been presented to the Directors of St George’s Quarter
15 Dec 2016
Joint Agency Group (JAG) meeting where the outline proposal for Hope
and Glory is presented by Lee O’Hanlon
13 Jan 2017
JAG meeting where key dates for the proposed Hope and Glory festival are
set
30 Jan 2017
JAG meeting where Hope and Glory festival is discussed in more detail
Site capacity was discussed, and agreed at 12,500, with measures to be in
place to disperse the crowd around the whole site.
The meeting appears to deal with all concerns raised by traffic
management, licencing, medical, egress points, parking, policing, and site
cleansing as well as providing details of artistic elements of the festival.
The next JAG was planned for 24 April
17 Feb 2017
Separate meeting between Traffic/Highways and Hope and Glory
management to discuss Hope and Glory festival
27 Feb 2017
First public announcement and launch of Hope and Glory festival (at 18.00
hours)
28 Feb 2017
First full event management plan (EMP) issued for Hope and Glory
24 April 2017
Planned JAG delayed until May
16 May 2017
Planned JAG meeting. Delayed due to Lee O’Hanlon stating he had a
serious family illness.  Revised date set for 23rd May
Note: The appointed Production Manager and Health and Safety advisor
for Hope and Glory, Neil Marcus, withdraws from the event.
22 May 2017
Manchester bombing.  Lee O’Hanlon states he intends that all profits will
now go to victim charities
22 May 2017
Lee O’Hanlon issues version 5 of the EMP
23 May 2017
Lee O’Hanlon delays scheduled JAG meeting by email
13 June 2017
Reissued EMP. Version 6
15 June 2017
The twice delayed JAG meeting held
21 June 2017
JAG meeting held. Plans of site issued
Final JAG meeting planned for 6th July
4 July 2017
Lee O’Hanlon cancels proposed JAG meeting, stating all parties see no
need to host JAG.
Subsequently another JAG meeting is proposed for onsite prior to event
4 August 2017
Onsite JAG only attended by LCC
16 August
JAG debrief meeting.  LOH does not attend
2017

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Questions and our opinion
1.  Is the event application process clear?
The process could certainly benefit from simplification.

2.  Was the event Premises Licence flawed?
No. The licence is perfectly proper and legally constituted.
However,  the  specific  usage  and  layout  of  the  Hope  and  Glory  event  should  have
attracted  more  stringent  additional  conditions  –  notably  regarding  capacity.    The
reduction in total number from 15,000 to 12,500 does not appear to have been based
on sound analysis – or indeed any analysis.
Had 12,500 tickets been sold, public safety would have been severely challenged.

3.  Is the SAG properly constituted?
This certainly appears to be the case, however no formal Terms of Reference have been
reviewed by the authors.

4.  Is the relationship between SAG and JAG clear?
In  principal  the  relationship  is  simple;  the  JAG  looks  at  detail  and  the  SAG  retains
oversight.  However, it is clear that the process has failed in this instance.

5.  Did the SAG offer appropriate advice?
The ‘A’ in SAG is  for Advisory, yet there is no evidence seen by the authors of the SAG
offering any specific advice or critique.  Once again it is likely that SAG members assumed
all relevant examination and discussion had been undertaken by the event‐specific JAG.
Overall did the SAG/JAG process meet the EPC guidance document or the reasonable
expectations of the people of Liverpool?
In our opinion, no.  It is entirely appropriate for the SAG to take a ‘lighter touch’ to the
licensing process [EPC guide p.19] as long as an appropriate level of scrutiny is exerted
by other means.
If there is a specific failure, it is that of the JAG to have gone through the EMP and other
documents in fine detail. Given the fact that multiple JAG’s were cancelled (with none
held between January 30th and June 15th ) the opportunity for scrutiny and to ask detailed
questions was much reduced. This period also saw the departure of Neil Marcus as the
Production Manager and Safety Adviser, which should have been cause for concern.
It is understood that JAG members have a wide range of other duties, and the amount
of time available to review each event application is necessarily limited.   It is clear that
no‐one has critically appraised the calculations on p. 106 of the Hope and Glory EMP;
but  after  the  submission  of  seven  versions  of  the  lengthy  document,  is  it  at  least
understandable.
16

The process of appraisal requires time, knowledge and experience.  It appears that at
least one aspect was lacking.
Even after the cancellation, the debrief JAG minutes show that “All present agreed the
event document was a good document.” [JAG minutes p.1]

9.
THE EVENT MANAGEMENT PLAN

Probably  the  single  most  important  document  provided  to  both  SAG  and  JAG    is  the
Event Management Plan.
An Event Management Plan should contain all of the detailed information required for
the successful execution of the event. A copy of which should be in the Event Control as
a reference for the Event Management Team.
The final version (v.7) was released on 11th July and is a document running to 147 pages.
We make the following observations on the contents:
Management  Structure  ‐  The  EMP  presents  a  management  organogram  and  outlines
duties  for  ‘event  operations’,  yet  there  is  ambiguity  in  the  precise  roles  and
responsibilities;
Lee O’Hanlon is described as being jointly responsible for operations in the Introduction,
but not in the Roles and Responsibilities paragraph.
Richard Agar is described as the Production and Safety Manager – but for an event of
this scale these are two distinct roles which would usually performed by two people.
In  many  instances  the  role  of  the  Safety  Manager  is  to  provide  a  critique  of  the
Production  Manager;  to  ensure  that  key  aspects  of  staff  and  public  safety  are  not
subsumed under a burden of construction and production pressures.
A Site Production Manager is also described, but this post was only partially filled by a
deputy to Mr Agar; who ultimately performed a role that would be better be described
as site management.
The outcome was that the stated chain of command and allocation or roles outlined in
the EMP failed to function effectively, with Mr O’Hanlon and Mr Agar either unable, or
unwilling, to take a strategic overview of readiness to accommodate the public.
Event  Control  –  the  EMP  describes  a  viable  system  for  an  effective  Event  Control.
However, this  assumes that the operational management structure is effective.
17

Site  Capacity  –  At  the  very  first  JAG  on  30th  January  the  capacity  of  the  existing  St
Georges Quarter premises was correctly given as 14,999.  Mr O’Hanlon himself stated
that he would not seek the maximum occupancy allowed under the licence, but would
voluntarily limit it to 12,500.
Minutes of JAG 30/1/2017 p.3
There is no explanation of how the 12,500 capacity is arrived at.
The SGQ premises licence includes the plaza to  the east of St Georges Hall and Lime
Street itself.  Appendix 5 shows our calculations using a simple Google Earth Pro plot of
the assumed overall area to which the SGQ license applies as 38,000m2 (excluding the
Hall itself).
Subsequent calculation of the effective area for Hope and Glory (taking account of the
major  elements  of  infrastructure)  indicates  in  the  region  of  17,000m2.  Thus,  a
proportional adjustment to the existing licence capacity should have been in the region
of half, rather than taking off 2,500.  One respondent states:
“Neil Marcus has stated that the only way the site plans would operate effectively would
be with the building of a bridge to allow access or egress into St John’s gardens.
Neil Marcus calculated the capacity to be 7000 for site. Lee O’Hanlon did not pass this
information on as event organiser to LCC.”

In our opinion the decision to proceed with an occupancy of 12,500 was deeply flawed.

The EMP provides no assessment of anticipated density in popular locations (such as in
front of the main stage). Nor is there any indication of how crowd distribution will be
monitored or managed.  For a show of this nature, it would be prudent to expect that a
significant proportion of ticket holders will seek to view the main stage headline show
. The graphic below is our own estimate of available space in front of the stage on William
Brown St, based on the site plan submitted in the EMP (Appendix 4).
This indicates an area of approximately 2,500m2.

18

If only 75% of the ticket holders actually sought to view the main attraction, this would
result in 9,375 trying to gain access to William Brown Street (note: at the time of the
show  the  trees  would  be  in  full  canopy  and  a  line  of  trader  vehicles  would  severely
restrict viewing from St Johns Gardens)9,375 people in 2500m2 gives an average density
of 3.75 person per metre square.
National guidance (Purple Guide, drawn from HSG195 The Event Safety Guide) indicates
2 per square metre as a safe maximum average density.
Emergency Egress – Appendix N of the EMP provides Exit Calculations.  The safe capacity
of  a  premises  is  normally  determined  by  considering  both  available  space  to
accommodate  the  audience,  and  the  available  exit  capacity  for  both  normal  and
emergency modes (how many can you get out). As noted previously, such calculations
should  form  a  fundamental  part  of  establishing  the  safe  capacity  of  an  event.
Unfortunately the text of Appendix N is riddled with typo errors and half‐sentences, and
the exit calculation itself uses outdated methodology and is mathematically incorrect.

19

link to page 20 link to page 20

The  final  conclusion  that  4,571  can  pass  through  the  exit  gates  each  minute,  and
therefore the site can be evacuated in 3 minutes, is a highly dangerous miscalculation.
The opening statement of the Appendix N is that ”The site is designed to be able to either
move people away from a hazard or to evacuate..”  Yet, the Site Plan only identifies ’Evac
points’ to the south and west of  St John’s Gardens. None are marked in the area of peak
demand i.e. in front of the main stage, and none appear accessible to wheelchair users.
The positioning of the main stage on William Brown Street is questionable, since it is
effectively  a  dead‐end  without  adequate  circulation  and  exit  capacity  –  especially  for
those on the Museum side of the stage.
Crowd flows around site – The EMP fails to identify any of the issues that may arise as
crowds move around an open‐air event site. No attempt is made to identify pinch points
or  potential  constrictions  –  particularly  in  areas  where  convergent  or  cross‐flow  of
pedestrian traffic might be expected.  Even if such potential issues are not subject to
modelling or analysis (which could be as simple as arrows on a plan to represent flow),
it  is  reasonable  to  expect  an  organiser  to  analyse  the  site  using  simple  modelling
techniques such as DIM‐ICE1 or RAMP2, or free software such as Google Earth.  But there
is no evidence of any systematic crowd safety approach.
The placement of main toilets block adjacent to the St John’s Gardens entrance is an
example  of  this  oversight.    Queueing  for  toilets  at  an  event  is  commonplace.  Thus,
positioning the main toilets where queues would exacerbate congestion at the Gardens
entrance should be an error easily foreseeable to an experienced event planner.
Section  7  of  the  EMP  provides  the  events  Crowd  Management  Plan,  but  offers  no
explanation of general layout decisions or how people will access and egress from the
site.  The Hope and Glory festival was due to be held just a couple of months after the
Manchester Arena attack, and yet the final EMP dated 11th July makes no mention of
how a search regime may impact on entry rates, or indeed how many lanes should be
provided keep external queueing to an acceptable level.
Risk Assessments  ‐ Appendix A to the EMP is given as the Event Risk Assessments. These
are not actually provided in Appendix A, but are ‘appended separately’.  TESS have not
be  provided  with  these  assessments  by  tinyCOW  despite  repeated  requests.    Their
absence is a concern.

1 DIM‐ICE prompts those responsible for crowd safety to consider Design, Information and Management resources during Ingress,
Circulation and Egress.  See: Introduction to Crowd Science by Prof. GK Still.
2 RAMP is a similar mechanism addressing Routes, available Area, Movement (of people), and the profile of the People themselves.
20

Mersey  Fire  and  Rescue  Service  confirm  that  a  fire  risk  assessment  in  line  with
government guidance was presented and reviewed.  TESS have not had an opportunity
to  view  this  document,  and  perhaps  it  overturns  the  problematic  calculations  in
Appendix N of the final EMP – we can only comment on the documents we have been
sent.
Site Plan  ‐ the final version of the site graphic lacks detail and is at variance from the
eventual  site  build.    A  scaled  site  plan  is  an  invaluable  planning  tool,  and  yet  that
submitted  with  the  final  EMP  failed  to  identify  fundamental  risk  areas  or  means  to
manage the public as they assemble, enter, circulate and depart.
Whilst some variation from a drawn plan is inevitable – the final build for Hope and Glory
fell substantially short of that presented in the EMP.  On page 4, the EMP states “In all
cases  significant  changes  will  be  recorded  in  the  Event  Log  which  is  maintained  as  a
record  of  activity  throughout  the  operation  of  the  site,  including  the  build  up  and
breakdown.”  No event log recording and explaining such changes has been presented.
Production Schedule – lacked in detailed timings and tasks.
Contradiction – though not a critical function, the way the EMP treats the issue of lost
children is an effective illustration of how the document (and the management plan it
embodies) is confused:
On page 35 the EMP states “it is considered that a formal lost children’s point will not be
required.”
Appendix O to the EMP then goes into detail over three pages regarding the Lost Children
Area and the role of the “Lost Persons and Vulnerable adults’ Manager”
Unfortunately  on  the  day  of  the  event,  neither  of  these  statements  was  true:  a  lost
person  point  was    required  and  nothing  outlined  in  Appendix  O  was  provided.    The
Medical provider were asked to manage a facility in an improvised manner (that is not a
usual practice), and eventually the LCC ad‐hoc Operations Manager organised a solution.
SUMMARY
Our opinion is that the EMP was assembled, adapted and plagiarized from a range of
other  documents,  offering  extensive  but  ultimately  worthless  information  about  the
process  of  declaring  Major  Incidents  and  the  establishment  of  mortuary  facilities  –
neither of which are the responsibility of the organiser.
Critical considerations of occupancy and exit capacity are glossed over with references
to 12,500 under the ‘existing licence’ [page 5].  But there is more than a grain of truth in
21

Mr O’Hanlon’s observation that the Safety Advisory Group effectively sanctioned it “in
their agreement to the event at that capacity.” [email 28/9/17]
No credible calculation is provided for effective event area or exit capacity.  No reference
is  made  to  the  challenge  of  people  getting  in    ‐  particularly  in  the  light  of  enhanced
security one may reasonable expect two months after the Manchester attack.
In our opinion the Event Management Plan was not fit for purpose.
In email discussion and written responses to questions LOH has stated that almost all
these failings were the responsibility of Production Manager , Richard Agar.  The authors
are unable to comment on the degree of culpability of either individual, nor would it be
useful to do so.  What is clear is that as a body corporate, tinyCOW failed to deliver either
a safe event or evidence to the authors that effective plans were in place.

22

10.  SUMMARY OF CONCLUSIONS
We conclude that the decision to cancel the second day of the Hope and Glory festival
was justified.
There were substantial failings in the submitted site layout, Event Management Plan and
operational  arrangements  proposed  by  tinyCOW.  It  is  demonstrable  fact  that  the
company were not, on this occasion, capable of delivering an event of this scale
The regulatory process failed to identify these shortfalls.  The promise of the initial JAG
meeting in January was not borne out.  The ambiguity of roles and responsibility between
SAG,  JAG  and  Licensing  presented  an  opportunity  for  all  concerned  to  assume  that
‘someone else’ was examining the documents in detail.
The  workload  of  the  SAG  is  immense,  and  it  is  entirely  understandable  that  it  cannot
examine all the proposals brought before it in forensic detail, however the expectation
that the JAG would somehow fill this gap was not met.
The process of major event application should be simplified, but at some point events of
a certain size or risk profile really must be fully examined.
Holding large scale events of this type under the LCC licence exposes LCC to risk, as they
may retain the obligations of the Licensee.
None of these observations removes or dilutes the primary responsibility of the Organiser
to plan and deliver a safe event, and tinyCOW clearly fell short in this regard ‐ leaving LCC
officers and others to step in and run the event on Saturday night. How culpability may
be attributed within the tinyCOW organisation is largely irrelevant.
The Hope and Glory festival was a public failure the city of Liverpool could do without.
The  saving  grace  is  that  no‐one  was  injured  or  suffered  significant  loss.  Hopefully  the
learning opportunities will be embraced by all.

23

Appendix 1. List of sources
Interviews with:
Paul Mansi – Paramount Security – Head of Security – personal interview, 21/8/17.
Phil Warren and Dr Josh Masheder – Merseyside Medical Services – personal interviews,
22/8/17.
Alan Smith – LCC – SGH manager – personal interview and written notes, 22/8/17.
Zoe Rubert – LCC – SGH manager – personal interview, 22/8/17.
Angie Redhead – LCC City Assets Manager – personal interview, 22/8/17.
Richard
Parkinson
–
LCC
–
Environmental
Health
(with
city
H&S
compliance/enforcement) – personal interview, 22/8/17.
Anne‐Marie Moran – LCC – Licensing – personal interview, 22/8/17.
Andy McNicholl ‐ LCC – Culture Liverpool – personal interview, 21/8/17.
Richard Agar – Production/Safety Manager – personal interview, 23/8/17.
Insp Mike Barrett – Liverpool Police – Force Duty Officer, 5 August. Telephone interview,
23/8/17.
Robin  Kemp  –  LCC  –  Head  of  Creative  Development,  Culture  Liverpool  –  telephone
interview 25/9/17.
Sue McPherson Merseyside Fire and Rescue – email response to questions
Chris Sargent – Assistant to Richard Agar – de‐facto Site Manager – telephone interview
2/9/17.
Neil Marcus – Initial Production Manager – telephone interviews 17/8/17 and 4/9/17
Simon Gilford – TSMDS – Traffic Manager– personal interview 23/8/17.
Lee O’Hanlon – Tiny Cow – Event Manager – awaiting video interview – written questions
sent 7/9/17.
Rob Casson, Skiddle Ticket Agency – failed to respond to requests for information
Documents:
tinyCOW Event Management Plan – v.7 – 11/7/17
Various  written  debriefs  –  Richard  Agar/Angie  Redhead/Merseyside  Medical
Services/Andy McNicholl/Alan Smith/Simon Gilford/Joint Agency Group.
Answers to written questions posed to Lee O’Hanlon –28/9/17
Minutes from SAG and JAG meetings (some provided by LCC, others by tinyCOW)
24

Email correspondence with members of the public (names withheld).
Photographs from various participants
25

Appendix 2. The St Georges Quarter Licence
26

Licensing Act 2003
LA160060
Premises Licence
LOCAL AUTHORITY
Liverpool City Council
Licensing & Public Protection
Cunard Buildings
Water Street
LIVERPOOL
Merseyside
L3 1AH
tel: 0151 233 3015
web: www.liverpool.gov.uk
Part 1 - Premises Details
POSTAL ADDRESS OF PREMISES, OR IF NONE, ORDNANCE SURVEY MAP REFERENCE OR DESCRIPTION
St Georges Quarter
William Brown Street, Lime Street, St Jo, Liverpool, Merseyside, L1 1JJ.
WHERE THE LICENCE IS TIME LIMITED THE DATES
Not applicable
LICENSABLE ACTIVITIES AUTHORISED BY THE LICENCE
- a performance of a play
- an exhibition of a film
- an indoor sporting event
- a performance of live music
- a performance of dance
- entertainment of a similar description to that falling within a performance of live music, any playing of recorded music or a
performance of dance
- the sale by retail of alcohol
THE TIMES THE LICENCE AUTHORISES THE CARRYING OUT OF LICENSABLE ACTIVITIES
Activity (and Area if applicable)
Description
Time From
Time To
A. Performance of a play (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
B. Exhibition of films (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
C. Indoor sporting event
Monday to Sunday
9:00am
11:00pm
E. Performance of live music (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
G. Performance of dance (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
H. Entertainment of a similar description to that falling within E, F, or G (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
M. The sale by retail of alcohol for consumption ON and OFF the premises
Monday to Sunday
9:00am
11:00pm
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LA160060
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THE OPENING HOURS OF THE PREMISES
Description
Time From
Time To
Monday to Sunday
9:00am
11:00pm
WHERE THE LICENCE AUTHORISES SUPPLIES OF ALCOHOL WHETHER THESE ARE ON AND / OR OFF SUPPLIES
- M. The sale by retail of alcohol for consumption ON and OFF the premises
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Licensing Act 2003
LA160060
Premises Licence
Part 2
NAME, (REGISTERED) ADDRESS, TELEPHONE NUMBER AND EMAIL (WHERE RELEVANT) OF HOLDER OF PREMISES LICENCE
Liverpool City Council
Municipal Buildings, Dale Street, Liverpool, Merseyside, L2 2DH.
REGISTERED NUMBER OF HOLDER, FOR EXAMPLE COMPANY NUMBER, CHARITY NUMBER (WHERE APPLICABLE)
NAME, ADDRESS AND TELEPHONE NUMBER OF DESIGNATED PREMISES SUPERVISOR WHERE THE PREMISES LICENCE
AUTHORISES THE SUPPLY OF ALCOHOL
DETAILS REDACTED
PERSONAL LICENCE NUMBER AND ISSUING AUTHORITY OF PERSONAL LICENCE HELD BY DESIGNATED PREMISES SUPERVISOR
WHERE THE PREMISES LICENCE AUTHORISES FOR THE SUPPLY OF ALCOHOL
Issued by
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Premises Licence
ANNEXES
Annex 1 - Mandatory conditions
Supply of alcohol.
1.
No supply of alcohol may be made under the premises licence;
(a) at  a  time  when  there  is  no  designated  premises  supervisor  in  respect  of  the
premises licence, or
(b) at  a  time  when  the  designated  premises  supervisor  does  not  hold  a  personal
licence or his personal licence is suspended.
2.
Every  supply  of  alcohol  under  the  premises  licence  must  be  made  or  authorised  by  a
person who holds a personal licence.
3.
(1) The responsible person must ensure that staff on relevant premises do not carry out,
arrange or participate in any irresponsible promotions in relation to the premises.
(2) In this paragraph, an irresponsible promotion means any one or more of the following
activities, or substantially similar activities, carried on for the purpose of encouraging the
sale or supply of alcohol for consumption on the premises-
(a) games or other activities which require or encourage, or are designed to require or
encourage, individuals to-
(i) drink a quantity of alcohol within a time limit (other than to drink alcohol sold or
supplied  on  the  premises  before  the  cessation  of  the  period  in  which  the
responsible person is authorised to sell or supply alcohol), or
(ii) drink as much alcohol as possible (whether within a time limit or otherwise);
(b) provision  of  unlimited  or  unspecified  quantities  of  alcohol  free  or  for  a  fixed  or
discounted  fee  to  the  public  or  to  a  group  defined  by  a  particular  characteristic  in  a
manner which carries a significant risk of undermining a licensing objective;
(c) provision of free or discounted alcohol or any other thing as a prize to encourage
or reward the purchase and consumption of alcohol over a period of 24 hours or less
in a manner which carries a significant risk of undermining a licensing objective;
(d) selling or supplying alcohol in association with promotional posters or flyers on, or
in  the  vicinity  of,  the  premises  which  can  reasonably  be  considered  to  condone,
encourage or glamorise anti-social behaviour or to refer to the effects of drunkenness
in any favourable manner;
(e) dispensing  alcohol  directly  by  one  person  into  the  mouth  of  another  (other  than
where that other person is unable to drink without assistance by reason of disability).
4.
The  responsible  person  must  ensure  that  free  potable  water  is  provided  on  request  to
customers where it is reasonably available.
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ANNEXES continued ...
5.
(1)  The premises licence holder must ensure that an age verification policy is adopted in
respect of the premises in relation to the sale or supply of alcohol.
(2) The  designated  premises  supervisor  in  relation  to  the  premises  licence  must  ensure
that  the  supply  of  alcohol  at  the  premises  is  carried  on  in  accordance  with  the  age
verification policy.
(3) The policy must 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.
6. The responsible person must ensure that-
(a) where any of the following alcoholic drinks is sold or supplied for consumption on
the  premises  (other  than  alcoholic  drinks  sold  or  supplied  having  been  made  up  in
advance  ready  for  sale  or  supply  in  a  securely  closed  container)  it  is  available  to
customers in the following 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;
(b) these measures are displayed in a menu, price list or other printed material which
is available to customers on the premises; and
(c) where a customer does not in relation to a sale of alcohol specify the quantity of
alcohol to be sold, the customer is made aware that these measures are available.
7. Prohibition on Sale of Alcohol below Cost of Duty plus VAT
(1) A relevant person shall ensure that no alcohol is sold or supplied for consumption on or
off the premises for a price which is less than the permitted price.
(2) For the purposes of the condition set out in paragraph (1) -
(a) “duty” is to be construed in accordance with the Alcoholic Liquor Duties Act 1979;
(b) “permitted price” is the price found by applying the formula -
P = D + (D x V)
Where -
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ANNEXES continued ...
(i) P is the permitted price,
(ii) D  is  the  rate  of  duty  chargeable  in  relation  to  the  alcohol  as  if  the  duty  were
charged on the date of the sale or supply of the alcohol, and
(iii) V is the rate of value added tax chargeable in relation to the alcohol as if the
value added tax were charged on the date of the sale or supply of the alcohol
(c) “relevant  person”  means,  in  relation  to  premises  in  respect  of  which  there  is  in
force a premises licence -
(i) the holder of the premises licence,
(ii) the designated premises supervisor (if any) in respect of such a licence,
or
(iii) the  personal  licence  holder  who  makes  or  authorises  a  supply  of  alcohol
under such a licence;
(d) “relevant  person”  means,  in  relation  to  premises  in  respect  of  which  there  is  in
force a club premises certificate, any member or officer of the club present on the
premises in a capacity which enables the member or officer to prevent the supply
in question; and
(e) “valued added tax” means value added tax charged in accordance with the Value
Added Tax Act 1994
(3) Where the permitted price given by Paragraph (b) of paragraph (2) would (apart from
this  paragraph)  not  be  a  whole  number  of  pennies,  the  price  given  by  that  sub-
paragraph shall be taken to be the price actually given by that sub-paragraph rounded
up to the nearest penny.
(4)
(a) Sub-paragraph (b) below applies where the permitted price given by Paragraph
(b) of paragraph (2) on a day (“the first day”) would be different from the permitted
price on the next day (“the second day”) as a result of a change to the rate of duty
or value added tax.
(b) The  permitted  price  which  would  apply  on  the  first  day  applies  to  sales  or
supplies  of  alcohol  which  take  place  before  the  expiry  of  the  period  of  14  days
beginning on the second day.
Exhibition of films.
1. Admission of children to the exhibition of any film is to be restricted in accordance with the
recommendations made by the specified film classification body.
2. Where -
(a) the film classification body is not specified in the licence, or
(b) the  relevant  licensing  authority  has  notified  the  holder  of  the  licence  that  this
subsection applies to the film in question,
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ANNEXES continued ...
admission  of  children  must  be  restricted  in  accordance  with  any  recommendation
made by that licensing authority.
3. In this section -
“children” means persons aged under 18; and
“film  classification  body”  means  the  person  or  persons  designated  as  the  authority
under  section  4  of  the  Video  Recordings  Act  1984  (c.39)  (authority  to  determine
suitability of video works for classification).
Door supervision.
1. Any  person(s)  required  to  be  on  the  premises  to  carry  out  a  security  activity  must  be
authorised  to  carry  out  that  activity  by  a  licence  granted  under  the  Private  Security
Industry Act 2001 or be entitled to carry out that activity by virtue of Section 4 of that Act.
Annex 2 - Conditions consistent with the Operating Schedule
1. The premises capacity shall not exceed 14,999.
2.   Before the commencement of any Licensable activity, a notification of the
      event  will  be  made  a  minimum  of  30  days  before  the  event  is  due  to  take  place.    An
Event Document will be produced and is teh detailed plan produced under the principles
set out in the Licensing Schedule.  The premises licence is not effective until such times
as specified in this document, and only within the area set out in the plan, as defined by
the road closures.
3.  An event document will be produced and circulated to all joint agences.
4.  The Safety Advisory Group will be informed of the event.
5.  Prior to the event a site specific event risk assessemnt, event documents and site plans,
and  traffic  management  plans  should  outline  how  the  four  licensing  objectives  will  be
met.
6.  To hold a joint agency meeting prior to the event, to hold a de-brief after the  event.
7.      For  events  between  500-5000  a  minimum  of 28 days notice to the Licensing Authority
and Safety Advisory Group, 5,000 - 14,999 a minimum of 90 days notice of the Licensing
Authrotiy and Safety Advisory Group.
8.  No Adult Entertainment.
9.    The  sale  of  alcohol  will  only  be  allowed  if  the  area  is  used  to  stage  regulated
entertainment as specified.
10. Any outside bar will cease sales 30 minutes before the designated finish.
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Licensing Act 2003
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Premises Licence
ANNEXES continued ...
11. Actual streets to be included and bar locations will be identified to Licensing
Authority and Police no less than 30 days before the event commences.
12. Prohibition of sale of Alcohol in bottels or glass container by Licence Holder
13. A register of all stewards and security on duty must be kept on site.
14. SIA security staff and management systems in place.
15. A public campaign to promote the no glass bottles message.
16. Security Management system to be used at perimeter of the site to
encourage the safe disposal of glass bottles and containers and provision
of suitable alternatives.
17. LCC to engage off sales sites in town to promote the no glass message.
18. Proof of age Challenge 21 system to be in place.
19. All refreshments sold/served in plastic or cans.
20. A management plan on site to ensure that no alcohol in open vessels
leaves the site.
21. A refuse plan will be in place for the event.
22. The event organiser will consult with the Safety Advisory Group on plans
for each activity.
23. Local residents and businesses will be consulted by the organiser
throughout the planning process.
24. Inform by way of letter all residents adjacent to the event supplying full event
arrangements and a contact number for enquiries on the day.
25. Music levels must be monitored.
26. A full lost children policy will be in operation at each event.
27. A lost children policy document will be implemented on site which will be
contained in the events document to all staff and stewrds on site.
Annex 3 - Conditions attached after a hearing by the licensing authority
Not applicable
Annex 4 - Plans
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Premises Licence
ANNEXES continued ...
See plan drawing number dated , deposited with the premises licence application and
retained by the Licensing Unit.
Kevin Johnson
City Manager, Licensing and Regulatory Services & Public Protection
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Licensing Act 2003
LA160060
Premises Licence Summary
LOCAL AUTHORITY
Liverpool City Council
Licensing & Public Protection
Cunard Buildings
Water Street
LIVERPOOL
Merseyside
L3 1AH
tel: 0151 233 3015
web: www.liverpool.gov.uk
Premises Details
POSTAL ADDRESS OF PREMISES, OR IF NONE, ORDNANCE SURVEY MAP REFERENCE OR DESCRIPTION
St Georges Quarter
William Brown Street, Lime Street, St Jo, Liverpool, Merseyside, L1 1JJ.
WHERE THE LICENCE IS TIME LIMITED THE DATES
Not applicable
LICENSABLE ACTIVITIES AUTHORISED BY THE LICENCE
- a performance of a play
- an exhibition of a film
- an indoor sporting event
- a performance of live music
- a performance of dance
- entertainment of a similar description to that falling within a performance of live music, any playing of recorded music or a
performance of dance
- the sale by retail of alcohol
THE TIMES THE LICENCE AUTHORISES THE CARRYING OUT OF LICENSABLE ACTIVITIES
Activity (and Area if applicable)
Description
Time From
Time To
A. Performance of a play (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
B. Exhibition of films (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
C. Indoor sporting event
Monday to Sunday
9:00am
11:00pm
E. Performance of live music (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
G. Performance of dance (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
H. Entertainment of a similar description to that falling within E, F, or G (Indoors & Outdoors)
Monday to Sunday
9:00am
11:00pm
M. The sale by retail of alcohol for consumption ON and OFF the premises
Monday to Sunday
9:00am
11:00pm
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Licensing Act 2003
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Premises Licence Summary
THE OPENING HOURS OF THE PREMISES
Description
Time From
Time To
Monday to Sunday
9:00am
11:00pm
WHERE THE LICENCE AUTHORISES SUPPLIES OF ALCOHOL WHETHER THESE ARE ON AND / OR OFF SUPPLIES
- M. The sale by retail of alcohol for consumption ON and OFF the premises
NAME, (REGISTERED) ADDRESS OF HOLDER OF PREMISES LICENCE
Liverpool City Council
Municipal Buildings, Dale Street, Liverpool, Merseyside, L2 2DH.
REGISTERED NUMBER OF HOLDER, FOR EXAMPLE COMPANY NUMBER, CHARITY NUMBER (WHERE APPLICABLE)
NAME OF DESIGNATED PREMISES SUPERVISOR WHERE THE PREMISES LICENCE AUTHORISES THE SUPPLY OF ALCOHOL
REDACTED
STATE WHETHER ACCESS TO THE PREMISES BY CHILDREN IS RESTRICTED OR PROHIBITED
There are no restrictions on access to the premises by children
Kevin Johnson
City Manager, Licensing and Regulatory Services & Public Protection
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Appendix 3. The Land Use Agreement

38

Land Use Application for Temporary Occupation
Applicant summary
Applicant Reference Number
…………………………EVR37273…………………………………………………………………
…
Contact Details:
Lee O’Hanlon
Hope & Glory Festival
Name:
Company:
Tel:
Fax:
xxx@xxxxxxx.xx.xx
Mobile:
E-mail:
Full Invoice
Hope & Glory Festival Ltd
address:
Straddan House
Queen Street
Lichfield
WS13 6QD
Event Details:
Proposed location: ……St John,s Park  /William Brown Street……………….
Date of Event: Sat 5th / Sun 6th August 2017…………………..
Time of Event: 1200hrs – 2300 hrs each day.
Description of proposed Event: Music Festival….
Public Liability Insurance Cover:
For temporary occupation of a public space you must have Public Liability Insurance.
Please enclose a copy of your Public Liability Insurance Certificate.
Company Name:

Allianz
Expiry Date:
8th August 2017

Completing your Land Use Application Form

WE RECOMMEND THAT YOU COMPLETE THIS APPLICATION FORM AFTER
YOU HAVE READ THE ONLINE GUIDANCE FOR STAGING EVENTS AVAILABLE
FROM
http://www.liverpool08.com/Images/Event%20Guide_tcm146-126272.pdf

It is important to provide as much detailed information as possible at the Application stage, as
this will determine if the event may require to be licensed or not, and will determine the type of
License that may be required.

It is important to submit Applications as soon as possible before your proposed activity as
delays may prevent Permission/License from being issued.

Important information relating to applications to use areas in Liverpool parks
or other greenspaces

There are no power facilities or water supplies and very limited toilet facilities in Liverpool
parks – event organizers must take account of this

Access onto public parks and greenspaces will invariably be restricted – event organizers may
be required to demonstrate how access will be managed

Charges and bonds for use in connection with your application are variable – please see
Permission Fees and bonds information separately available

Please return completed application forms to:

Liverpool City Council
Streetscene
Municipal Buildings
Dale Street
Liverpool, L2 2DH

Tel: 0151 233 7030
Email: xxxxx@xxxxxxxxx.xxx.xx

Applicant Ref.
EVR37273

APPLICATION FOR PERMISSSION TO USE LIVERPOOL CITY
COUNCIL PARKS, OPEN SPACES AND OTHER PUBLIC SITES
including APPLICATION FOR CONSENT TO HOLD A PROMOTION IN
LIVERPOOL CITY CENTRE

1. PROPOSED VENUE
St John’s Park, Wil iam Brown Street………………………

Date/s required: 31st July – 9th August 2017
Time/s required: All day…….

*The above should allow for setting up the event and dismantling.

2. NAME AND ADRESS OF ORGANISATION
Hope & Glory Festival, Straddan House
Queen Street
Lichfield
WS13 6QD

3. DETAILS OF EVENT ORGANISERS AGENT/EVENT MANAGER, i.e. the
person responsible for;

a). the event and
b). all liabilities arising from the event

NAME: Lee O’Hanlon….
TITLE:  Event Producer……………..
ADDRESS: as above.….
…………………………………………………………………………………………….......
………………………………………………………………………………………………....

Have you/the event organiser/manager, or any of your/their contractors,  been
the subject of any enforcement action or prosecution under relevant statutory
provisions relating to event management including Health and Safety at Work
etc Act 1974
N/A………….

4. CONTACT DETAILS:
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
•
Please provide as much information as possible

5. INVOICE CONTACT DETAILS if different from above:
…………………………………………………………………………………………………
…………………………………………………………………………………………………

6. PUBLIC LIABILITY INSURANCE CERTIFICATE DETAILS

Insurance Company name: …Allianz

Certificate number: ……………

Expiry date: …8th August 2017…………………………………………..

7. DESCRIPTION OF EVENT
Music
Festival…………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
……………………………………………

8. Estimate of the number of people actually taking part in the event (Give
details of the participants, employees, hired help, stewarding, volunteers etc):
400 performers and support staff, 40 technicians and site crew, 60 stewards, 35
management
staff……………………………………………………………………………………………
……………………………………….................
…………………………………………………………………………………….................

9. Estimate the number of participants to attend:

a). Less than 100       b). 101 to 499                        c). Over 500
……………………                         ….………………            12,500.

10. Will participants be in an enclosed area, and if so, how will they gain
admission?
The site wil  be fenced and secured and admission wil  be by
tickety…………………………………………………………………………………………
…………………………………………………………………………………………………
……

11. If you anticipate that a large number of spectators will attend, you will be
required to consider the following;

How will the spectators be managed?
EMP been signed off by JAG and
SAG……………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………

12. No vehicles will be allowed to move on site (other than emergency vehicles)
during the event running times.

What vehicles will be used oand for what purpose?
Vehicles wil  be used during set up, delivery vehicles and Fork lift trucks for
unloading, service vehicles for toilets wil  be moving on site prior to audience
admission………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………

Supporting vehicles are not allowed, essential vehicles only – Please provide
the registration number:
…………………………………………………………………………………………………

13. Temporary Structures.

What temporary structures will be erected (e.g. platforms, stages, tents,
marquees, scaffolding, spectator stands)?
3 stages, marquees for backstage dressing rooms and
bars……………………………………………………………………………………………
…………………………………………………………………………………………………
……………………………………………………………………………

Please give details of the company/organisation/persons/responsible for
building them on site?
Main contractor Hi-Lights theatre services, Nite0Lites PA, Search toilets and
cabins..................................................................................
…………………………………………………………………………………………………
…………………………………………………………………………………………………

*You will need a copy of their handing procedures, Insurance and Risk Assessment documents.

Description, including size, height and weight of displays/equipment etc to be
used (please include any visuals):
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………

14. Will there be any music and/or amplification?

If yes, please give details and names of any supplier and/or operators:
Nite Lites main stage and 2nd stage PA , Hi-Lights 3rd
Stage……………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………

15. Will there be any special features such as fireworks, lasers, controlled
explosions etc?

If yes, pleased give details and names of suppliers and operators:
None……………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
………………………………

16. Are you providing any supplementary facilities on site such as toilets,
catering, side stalls, bouncy castles or inflatables?

If so you will need to provide details of the suppliers, contractors, caterers
along with their relative insurance, risk assessment and hygiene operating
certificates:
…………………………………………………………………………………………………A
There wil  be mobile caterers on site and wil  be submitted to LCC on the council pro-
forma……………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………………………………………………
……
17. If you intend to charge for the event, for what purpose will the monies
generated be used?
The event is charged for, al  profits from ticket sales are being donated to the
Manchester
Fund……………………………………………………………………………………………
…………………………………………………………………………………………………
…………
…………………………………………………………………………………………………

18. Will you be having raffles, prize draws or collections; will you be giving out
samples?
N/A………………………………………………………………………………………………
…………………………………………………………………………………………………
…………………………………………………………
…………………………………………………………………………………………………

19. What systems of litter collection and removal will you put in place?
…………………………………………………………………………………………………
LCC supplying ful  litter and
removal/disposal………………………………………………………………………………
……………
…………………………………………………………………………………………………

20. Will your event be funded?

If so by whom?
The event is funded by the
organiser………………………………………………………………………………………
…………………………………………………………………………………………………
……………………………………………
…………………………………………………………………………………………………

**For Office Use Only

Grantee:

Site:

Equipment:

Purpose:

Dates

Refer To     For Permissive License:
Refer To Safety Advisory Group For full Premises License:
Date:
Officer:

Land Use Agreement
Terms and Conditions

General
The LAND OWNER has examined the Site and/or Equipment for the purpose as
specified above.  However the Grantee is notified that LAND OWNER does not have
any expertise in the above mentioned Purpose and therefore the LAND OWNER
requires that the Grantee, before exercising the permission hereby granted, must
carry out an inspection of the Site and/or Equipment and must satisfy him/herself that
the Site and/or Equipment is safe and fit in al  respects for entry and use by his/her
employees, agents and invitees for the Purpose as mentioned above and that al
relevant statutory requirements (including without limitation health and safety
regulations and the Licensing Act 2003) relating to such entry and use are ful y
complied with.

In view of this so far as the law deems fair and reasonable LAND OWNER cannot
accept liability for any loss of and/or damage to any property of the Grantee.

Subject to the above the Grantee enters the Site and/or uses the Equipment at his
own risk.  The Grantee shal  be liable for and shal  indemnify LAND OWNER from
and against any liability, loss, expense, claim or other damage not arising from
negligent acts or omissions, nuisance or breach of statutory duty on the part of LAND
OWNER in respect of any injury or damage whatsoever to any property or personal
injury or death arising out of the permission hereby granted.

If the Grantee use the existing PREMISES LICENCE(S) owned by Liverpool City
Council, they wil  indemnify the LAND OWNER against any action arising as a result
of its use. Further they accept that it is for the GRANTEE to meet al  the obligations
contained there in, including the liaison with the emergency services and relevant
responsible authorities through the Safety Advisory Group, and for the production of
an event specific event document.

Declaration
FOR THE AVOIDANCE OF DOUBT, Permission to use the Public Space/Park/Open
Space is not an endorsement of the event or the event management team.

Unless otherwise specifical y agreed in writing, no promotional material may include
any council logo or endorsement.

Organisers are reminded that it is their responsibility to meet al  statutory obligations
and obtain al  permissions around staging the event.

This includes (but is not limited to);

•  The Health and Safety Act 1974 and all associated regulations.
•  The Licensing Act 2003
•  The Occupiers Liability Act 1957

Definitions –
1.  The Event
2.  The Premises
3.  The period
4.  The Plan
5.  The Permission Fee
6.  Grantee’s works
7.  Programme
8.  Promotional Activities
9.  Reinstatement works
10. Specified insurance cover
11. Safety Advisory Group

Special Terms
1.  Conditions of Grant.
1.1. The LAND OWNER gives to the Grantee Permission for use of the Premises
for the Period for the purposes of preparing for the Event; for the Event
Staging; and returning the premises to their original condition after the Event.
1.2. For the avoidance of doubt the arrangements in this Permission shal  not
constitute a tenancy nor give the Grantee exclusive possession of the
Premises.
1.3. The LAND OWNER permits the Grantee during this period, subject to the
rights of al  others in respect there of
1.3.1.  to use the Premises for the purpose solely of preparing for and staging
the Event, including the holding of rehearsals or practice sessions
relative, and removing al  equipment plant machinery and structures and
other similar items brought on to the Premises for the Event.
1.3.2.  Any other purpose must be specifical y agreed in writing, and may incur
additional charge from the LAND OWNER.
1.3.3.  Subject to security arrangements, to have access to the Premises with
or without vehicles by means of such routes as THE LAND OWNER may
designate.
1.3.4.  To sel  merchandise food and beverages on the Premises.
1.4. The Grantee shal  at al  times permit those authorised by the LAND OWNER
to have free and uninterrupted passage for the purpose of gaining access to
an adjoining property.
1.5. The LAND OWNER does not warrant the Premises as fit or suitable for the
Event or any other purpose.

1.6. The Premises wil  only be used for the purposes set out and the Grantee
must provide the LAND OWNER ful  details of the event including
construction and deconstruction.
1.7. The Grantee acknowledges that it has an opportunity to undertake a ful  site
assessment of al  health & safety hazards. They wil  provide the LAND
OWNER a written assessment of these hazards.

2.  Fees
The fee for the use of the Premises (If applicable) is the Permission Fee.
Please refer to table of fees.
Deposit: A deposit of £……….. must be paid to the Council 28 days prior to the
Event.  This wil  be forfeited in the event of any damage or loss to the Venue (or
loss of keys) or held as part of any necessary making good.  The Hirer wil  be
liable for the ful  cost of any damages should this exceed the deposit the Council
wil  issue an account for payment by the Hirer.
3.  Works & Promotional Activity
3.1. The Grantee shal  as soon as practicable at its own costs carry out the
Grantees works, including remedial works to the reasonable satisfaction of
the LAND OWNER in accordance with an agreed timetable.

4.  Grantees obligations & responsibilities
4.1. The Grantee shal  nominate an identified senior officer who wil  be the point of
contact for the LAND OWNER in relation to the management and operation of
this Permission including co-ordination of any RIDDOR incident report.
4.2. The Grantee shal  permit the LAND OWNER its servants agents and al  those
authorised by it to have reasonable access to the Premises by prior
arrangement at al  times, provided the person shal  comply with the Grantee
Health & Safety protocols fro the site.
4.3. The Grantee is responsible for the preparation of the site as received to the
standards necessary for the staging of their event.
4.4. Where the single Premises Licence grant 25th May 2006 is to be used, it is for
the GRANTEE to meet al  the obligations contained there in; including the
production of an event specific event document. This wil  meet the obligations
set out below 4.5 to 4.10.
4.5. The Grantee wil  obtain and pay any costs in association with any premises
Permission, with copies of the Premises Permission and its operating
schedule being provided to the LAND OWNER.
4.6. The Grantee wil  liaise with interested parties through the Safety Advisory
Group including any adjacent building owners, and comply with al  reasonable
recommendations made by this group.
4.7. The Grantee shal  produce to the satisfaction of the Safety Advisory Group a
Traffic Management Plan.
4.8. The Grantee is responsible for al  the health safety welfare and environmental
and security issues arising out of the Event and activities at the Premises
during the period, including without limitation improvement works,
organisation and preparation for the Event, clean up and repair activity after
the event; and the health and safety of person attending the event.
4.9. Levels of competent security first aid and other support staff are to be
present. Numbers to be identified through risk assessment and subject to
agreement with the Safety Advisory Group.
4.10. A suitable waste management programme to ensure the clean up and
removal of al  waste before during and after the Event is the responsibility of
the Grantee and shal  form part of the reinstatement works.

5.  Reinstatement
5.1. The Grantee shal  be responsible to the satisfaction of the LAND OWNER the
removal of al  temporary structures plant and machinery and other things
brought in relation to the event, and restore the Premises to same or agreed
condition prior to the event.
5.2. In event of default on the reinstatement works within the identified time frame,
the LAND OWNER shal  be entitled to carry out the works with the cost being
met by the Grantee. For this purpose, a negotiable bond wil  be loged by the
Grantee with the LAND OWNER

6.  Liability
6.1. The Grantee at al  times wil  hold public liability insurance relevant to the
Event planned, from and against any liability, loss, expense, claim or other
damage not arising from negligent acts or omissions, nuisance or breach of
statutory duty on the part of LAND OWNER in respect of any injury or
damage whatsoever to any property or personal injury or death arising out of
the permission hereby granted.
6.2. In the event this agreement is terminated the Grantee wil  indemnify the
LAND OWNER against any direct costs incurred as a result of the Grantees
failure to fulfil its agreement)

7.  Warrantees
7.1. The Grantee warrants that it is compliant with al  conditions relating to the
Licensing act; Health & Safety at Work Act and associated regulations and
guidance.
7.2. The Grantee warrants that it wil  with due skil  care and diligence conduct the
Event in a professional manner, and undertake that it has the specific skil s
and experience relevant to staging such activity.
7.3. The Grantee warrants that in obtaining any additional services relating to the
event that sub contractors have the specific skil s and experience relevant to
supporting the delivery of that activity.

8.  Assignment
8.1. The Grantee may not assign transfer charge or deal in any manner with this
Agreement or rights under it.

9.  Force majeur
No party shal  be liable for the delay or non-performance of its obligations under
this agreement arising from any cause or causes beyond its reasonable control,
including without limitation Act of God; war; fire; flood; explosion; act of terrorism;
or civil commotion

10. Governing Law & Dispute Resolution
10.1. This agreement s governed by and construed in accordance with the Laws
of England & Wales.
10.2. In the event of dispute or differences the parties resolve to meet in good
faith to resolve the dispute with recourse to legal proceedings
10.3. If the parties have not resolved the dispute within 10 days (or such shorter
period as dictated by the delivery of the event)  the parties shal  endeavour to
resolve in good faith the dispute in association with a procedure
recommended by an agreed expert, whose expenses shal  be met by the
grantee

10.4. If the parties are stil unable to resolve the dispute then it shal be resolved
by the Courts of England and Wales

I acknowledge and agree to be bound by these conditions should my application
prove successful

Signature of Applicant ………………………

Position in Organisation ……………………Lee O’Hanlon…Event producer

Date ………………26th August 2017……………

Appendix 4. Event Site Plan (from the EMP v.7 Final Draft 11th July, p.101)
50

Appendix 5. Surface area calculations
These measurements are indicative only and do not claim to be definitive.
The first plot below shows the area assumed by the authors to be the St
Georges Quarter area licensed in the document in Appendix 2.
Note: neither measurement includes the St Georges Hall itself
51

The plot below seeks estimate the site, taking account of event infrastructure
to show the effective area available for the public. Even this is somewhat
generous, making no allowance for traders, toilet blocks and other
infrastructure, and assuming all parts of William Brown Street and St Johns
Gardens are equally available for use.
52

Document Outline