11th May 2018 Please support the Shepherd’s Bush Market Businesses and local residents and object to Licensing Application 2018/00539/LAPR before Wednesday 16th May 2018 The Shepherd’s Bush Market Tenants’ Association, which hold a strong majority membership of 90% of the traders within Shepherd’s Bush Market have recently become aware of the Application submitted by Esther Worboys of WMC Retail Partners, for a LICENCE to sell alcohol at the Old Laundry Yard W12 8DW. The Shepherd’s Bush Market Tenants’ Association wish to encourage our supporters to protect the livelihoods of the Shepherd’s Bush Market Businesses and to safeguard the wellbeing of the Shepherd’s Bush communities. It is the view of the SBMTA that strong objection should be made swiftly to the London Borough Hammersmith & Fulham Licensing Team before the Wednesday 16th May 2018 to ensure that this Licensing Application 2018/00539/LAPR is prohibited. The notice of Application 2018/00539/LAPR to the London Borough of Hammersmith & Fulham for a licence under the Licensing Act 2003 requests for the Old Laundry Yard to: - Sell alcohol from: - Sunday - Wednesday 09:00 - 20:00 Thursday - Saturday 09:00 - 22:00 And To hold entertainment from: - Friday 17:00 - 22:00 Saturday 12:00 - 22:00 Sunday 12:00 - 20:00 Objection to this licensing application may be achieved by either clicking on the following Hammersmith & Fulham Council link and submitting comment: - http://public-access.lbhf.gov.uk/online-applications/licencingApplicationDetails.do?activeTab=makeComment&keyVal=P7H7RJBI16B00 Or By writing to the London Borough Hammersmith & Fulham Licensing Team in to the following email address: licensing@lbhf.gov.uk It is the SBMTA’s view that the following reason may be grounds for Objection • The SBMTA object to the granting of Application 2018/00539/LAPR for the former Laundry Site, which neighbours with Shepherds Bush Market, as per their current application based on the trading hours of the location, its extreme proximity to the residential properties backing onto the site, its impact on the neighbourhood, its potential for an impact on crime & disorder and anti-social behaviour, and its aim to be a child-friendly environment. Premises location • The former Laundry Site and its temporary trading premises are located in immediate proximity to the famous 100+ year old Shepherds Bush Market, west of Shepherds Bush Common, and adjoining an exceedingly large number of residential properties on Pennard Road. 
 
It is located right between key roads (Uxbridge Road & Goldhawk Road). 
It is within the Town Centre, and surrounded by residential streets, within an area that is the densest 
populated part of the Shepherds Bush Borough. 
 • Around and in the proximity of the Shepherds Bush Town Centre (the area surrounding the Shepherd’s Bush 
Market) is a plethora of Bars and Night Cafes many of which already have operating hours into the night. 
 • Any grant of alcohol licenses to the former Old Laundry Site and those traders operating from the temporary metal cargo containers structures, may exacerbate noise & public nuisance disturbances in an area now 
recognised as suffering a saturation of night economy premises of various varieties. 
 Noise & Nuisance 
 • The adjacent streets are totally residential. It is felt that Residents have enough experience of noise and nuisance of crowds, whether on foot or using cars, congregating by licensed premises and Night Cafes around Shepherds Bush Green, to recognize that granting entertainment and alcohol licenses to trading premises at this Old Laundry Site location may present further upset to both residential neighbours and to the market traders within Shepherd’s Bush Market. • Operators of alcohol & entertainment economy premises generally have little control over the behaviour of patrons on the public highway or public areas surrounding their premises, Bars & clubs may have requirements for Door Supervisors, who often have minimum effect on problematic crowds. 
 • There is question as to what system of security patrols like Door Supervisors is proposed to oversee the activities of both traders and customers of entertainment & alcohol licensed traders at the former Laundry Site without placing financial repercussions onto the neighbouring Shepherd’s Bush Market Businesses or on the local Residents. • One may raise the concern that crowds gathering at and near entertainment & licensed premises have an intimidating effect on residents and other communities in the vicinity, especially if they are older or with children. This is a well-documented form of complaint. Parking 
 • The 100+ Year Old Shepherds Bush Market, New Shepherd’s Bush Market (West of Shepherd’s Bush Market) and the former Old Laundry Site Area, (located east of the 100+ Year Old Shepherd’s Bush Market) have no dedicated car parking. Any customers using cars or motorcycles, must park in neighbouring streets, notably within Zone G, including Pennard Road and Lime Grove. Increased activity in the earlier and latter part of the day may cause nuisance to residents with valid local Zone G parking permits, displacing them, and adding to noise and pollution by the frequent movement of additional vehicles into neighbouring streets. 
 • Additional vehicles may represent an obstruction to the free flow of traffic. 
 • An increase in vehicle movement, particular the starting and stopping of cars, cars with radio systems 
blaring (especially in warmer weather when car drivers tend to drive or sit with windows open) will cause demonstrable adverse impact to local residential premises. Litter 
 • Litter associated with entertainment & food premises is a major issue around Shepherds Bush, where now we see frequent signs of pest infestation (including mice, rats, pigeons, cockroaches & urban foxes). Operators of fast food premises, of the kind envisaged for the former Old Laundry Site, generally have no control over how patrons dispose of litter once they leave the traders stand, and generally do not care, as they consider street litter a council problem, with the net result that council tax-paying residents are subsidizing a premises’ business by Council collecting its discarded food packaging and scraps. 
 • Within the confines of the former Old Laundry Site perhaps the operators may attempt to manage litter, but without doubt much may be taken by customers outside the boundaries of the former Old Laundry Site onto local streets or into the original Shepherd’s Bush Market. 
 • There is concern that the later operating hours of the Old Laundry Site may dictate that once the catering / bars units within the Old Laundry Site Area are closed, further cleaning of the area will have to be performed by sweepers immediately after closing. There will be hope that this cleaning task will not generate further noise and there is concern as to how the sweepers may perform their work adequately with minimal light so not to cause light pollution. The work will of course need to be monitored and signed off each evening by the Old Laundry Site Management, however it is the SBMTA’s view that there is worrying ambiguity as to which personnel are attending to the Old Laundry Site Area. Impact on the traditional Shepherds Bush Market and its traders. • It is felt that the extension of trading into the former Laundry Site is likely to have a negative economic impact on the traditional Shepherds Bush Market and its traders, through risks of noise pollution, anti-social behaviour, and drawing patrons away from the Market into the former Laundry Site. 
 • The original (Orion) plans for the Shepherds Bush Market were allegedly to bring about greater benefit and prosperity to the traditional Market Businesses and to offer an improved alternative, other than Westfield. There is doubt if the new use of the former Old Laundry Site will achieve any of those objectives. Trading Hours of Former Laundry Site 
 • It has been noticed that all the recent documents concerning the use of the former Laundry Site include 7 day trading, and for extended hours into the middle and late evenings. • It is felt important to note that both Shepherd’s Bush Market and New Shepherd’s Bush Market are six day a week markets trading no later than 6pm, and are completely closed on Sundays. • Local Residents feel that the Council have overlooked the fact that an entire row of residential houses back right onto the Old Laundry Site Area, with living and bedroom accommodation within a very few feet of what is apparently intended to be a location for the sale of alcohol and entertainment for crowds. • It should be noted that local residents have objected to any extension of operating hours for trading beyond the hours of 10am to 6pm, and also to any activity on Sundays. Shepherds Bush Town Centre has been designated a Saturation Zone for licensed premises • It is the SBMTA’s understanding that the London Borough of Hammersmith & Fulham Council took the important step (in the views of Residents), some years ago to designate the Shepherds Bush Town Centre as a Saturation Zone within its Cumulative Impact Policy, because of the overload of alcohol related premises within the Town Centre, and the impact of the alcohol economy on the key factors. The essence of the Policy was that there should be no increase in numbers of premises serving Alcohol. (i.e. a new outlet should be one that was replacing an existing outlet.). This Policy for Shepherds Bush is apparently still in place. The Old Laundry Site Area Intention (Application 2017/03851/FUL) • There is question as to what was the intention of the Laundry Site Area Application 2017/03851/FUL, which was granted recently in November 2017, as the application’s majority purpose was allegedly for the dozens of rusting empty metal cargo containers to be used for small offices. Thus, the Licensing Application 2018/00539/LAPR and the seeking of permission for loud entertainment and the sale of alcohol, to an area that may require “quiet” for the prospective “office residents” may be viewed as contradictory and a conflict of the Application 2017/03851/FUL. The prevention of crime and disorder • The granting of an entertainment and alcohol licence to traders at the former Laundry Site may create a gathering spot and a magnet for persons given to anti-social behaviour, particularly in respect of noise and littering as they gather in the neighbourhood of the traders’ premises. That has been observed locally with all other bars as well as nearby late opening Cafes primarily serving fast food. Such gatherings provide an opportunity for other criminal activities, including drug dealing (which has already been an issue within the traditional Shepherds Bush Market, as raised at Ward SNT meeting). • Historically Shepherds Bush Town Centre location has been highlighted as a magnet for persons perhaps considered less desirable as street-side gatherers, with many reports of fights and anti-social behaviour by patrons to entertainment and licensed premises. The particular focus of the former Old Laundry Site is to provide entertainment and alcohol to attract larger groups and subsequently may be overexcited and noisy well into the mid to late evenings. And this will have strong negative impact on the local residents. • The open nature of the former Old Laundry Site, with the cargo containers directly backing right up to the Pennard Road property rear walls, presents a security and crime risk to the houses on Pennard Road. • One may justifiably ask as to what plans or proposals does the Applicant have to eliminate the risk of crime and disorder from patrons to the former Laundry Site, both during and after trading hours? Public Safety • Public safety becomes an issue when innocent pedestrians and customers to the Market and its extension into the Former Old Laundry Site feel intimidated by patrons of licensed entertainment and alcohol serving premises during its (over lengthy) trading hours. The prevention of public nuisance • Where the former Old Laundry Site may act as a magnet to a certain type of patron who would not otherwise be at the location or in the vicinity, a source of public nuisance arises – crowds around the entrance and within the area of the Market, littering, noise. • Particularly in the evenings it is likely that the forms of entertainment, and the profile of patrons to traders’ premises, will mainly persons of an older age profiles (18+). Particularly in warmer weather we have much local experience of gatherings of younger/youthful gangs and groups where there are any public spaces or entertainment or similar facilities to attract them. The protection of children from harm • There may be a risk that younger persons, and minors, will be part of groups of patrons attracted to the former Old Laundry Site and its trading premises, and influenced by life style factors exhibited by older patrons. Minors can be exposed to unwelcome influences, from drinking; smoking, possibly drugs and the risk of gang culture of younger groups gravitate to the location. St Mungo’s – Broadway Day Centre • It should be noted that St Mungo’s – Broadway Day Centre for rough sleepers and vulnerably housed people, supports and offers advice around substance misuse, mental health, sexual health, general health advice is located immediately next to Old Laundry Area, and selling alcohol from 09:00 to 22:00 (Thursday to Saturdays) and 09:00 to 20:00 (Sunday to Wednesday) may be viewed as inappropriate and inconsiderate. Management of the Old Laundry Site Area • There is concern from the Shepherd’s Bush Market Tenants’ Association as to how the Laundry Site Area is presently being managed. The SBMTA have raised various concerns regarding the operation of the Laundry Site Area infringing on the services and facilities of Shepherd’s Bush Market and subsequently causing financial detriment to the Shepherd’s Bush Market service charge expenditure. Unfortunately it is the SBMTA’s view that the management of the Old Laundry Site Area has provided inadequate evidence to eliminate concerns. Increased operating hours of the Old Laundry Site Area is felt may cause further financial detriment to Shepherd’s Bush Market The infringement of the Old Laundry Site Area utilizing the Shepherd’s Bush Market’s Road for vehicle access, the Shepherd’s Bush Market’s drains, and other various services and facilities, is felt to be causing further financial detriment to the Shepherd’s Bush Market Tenants’ Service Charge Expenditure. Any proposal of increased operating hours or increased activity in the Laundry Site Area, therefore may be considered to further threaten the Shepherd’s Bush Market Service Charge Expenditure. Additional Note • (The SBMTA note that the Licensing Application 2018/00539/LAPR appears to specify the address of the former Laundry Site as 17 Pennard Road, yet it is our understanding that this may be incorrect and that the correct address as 15 Pennard Road). Summary • It is the view of the Shepherd’s Bush Market Tenants’ Association that this application should be rejected. Please support the SBMTA and encourage the London Borough of Hammersmith & Fulham Council to value the objections and decline to grant entertainment and alcohol licenses to the Applicant. http://public-access.lbhf.gov.uk/online-applications/licencingApplicationDetails.do?activeTab=makeComment&keyVal=P7H7RJBI16B00 • It is important the LBHF Council takes a stand in its position that reflects its previous decision to apply a Cumulative Impact Policy status to Shepherds Bush, as an area experiencing a saturation level of night and entertainment and alcohol economy related business. And additionally any further granting of alcohol & entertainment licenses granted at this Town Centre location will further impact negatively on local issues of crime & disorder, public safety, public nuisance, and possibly the protection of children. The SBMTA truly thank each and every one for your support and efforts. Together we can protect and cherish our London.