[Your Name

Post Code]

Licensing Service,
Sycamore House
Waltham Forest Town Hall
Forest Road
E17 4SU.

Dear Sir or Madam,

I am writing to express my objections to the recent application for the Grant of a Premises Licence under
section 17 of the Licensing Act 2003 at Walthamstow Wetlands, 2 Forest Road, London, N17 9NH. These
objections are on the grounds of public safety and the prevention of crime.

Firstly, the application to permit the sale of alcohol on and off the premises until 24:00 from Monday to
Sunday has considerable public safety risks. As I am sure you are aware, the reservoirs on these premises
range from ten to thirty-four feet in depth, while a number of them have strong, under the surface suction
systems. In light of these environmental factors, swimming at the reservoirs is currently strictly prohibited.
The consumption of alcohol late into the evening, however, will increase the likelihood of members of the
public ignoring this rule. Given the tragic death of a young man in the nearby Banbury Reservoir in
December 2015, Waltham Forest Council and the London Wildlife Trust must provide assurances that they
have conducted a full risk assessment. Any such risk assessment should occur in conjunction with Thames
Water and should specifically address the consumption of alcohol on the premises.

Secondly, the performance of live music (with associated lighting) will potentially cause interference with
protected species of wildlife in breach of the Wildlife and Countryside Act 1981. This, of course, is a
criminal offence. Before the recent refurbishment, the engine room directly above the café held a
considerable population of roosting bat species, all of which are protected with species one status under
the Wildlife and Countryside Act 1981. In fact, over seven different species of bats have been recorded at
Walthamstow Wetlands. The site also holds the largest national record for numbers of Nathusius
Pipistrelle. Of course, bats are nocturnal animals and are adapted to low-light conditions. This means that
the majority of UK bat species find artificial lighting to be disturbing. As such, the Bat Conservation Trust
recommends that ‘artificial lights shining on bat roosts, their access points, flight paths away from the roost
and important foraging areas should be avoided’. Moreover, ‘excessive noise and vibration (such as loud
music) could potentially disturb bats if they are roosting in a vicinity and should also be avoided’.

As I am sure you aware, under the Wildlife and Countryside Act 1981, it is an offence for an individual or
organisation to ‘intentionally, recklessly or deliberately disturb a roosting or hibernating bat (i.e. disturbing it
whilst it is occupying a structure or place used for shelter or protection).’ A successful application for a
Grant of a Premises License could, then, lead Waltham Forest Council and the London Wildlife Trust to
breach the Wildlife and Countryside Act 1981. As such, an independent body must carry out a formal
survey to assess the impact of this late night licensing application on the roosting bat population.

As Walthamstow Wetlands is a nationally designated SSSI (Site of Special Scientific Interest) and part of
an internationally designated SPA (Special Protection area), Waltham Forest Council and the London
Wildlife Trust also need to consult Natural England about the licensing application and request SSSI
assent. Furthermore, a Habitat Regulations Assessment needs to be undertaken to confirm that noise from
this late night licensing application will also not disturb and displace qualifying species of rare and
vulnerable wintering birds such as Gadwall and Shoveler.

Finally, Waltham Forest Council should reconsider the validity of the licensing application as a whole, as it
appears to contravene the planning permission for the café in the old pumping station. The planning
permission only permits the café to open as a feature ancillary to the visitor’s centre and specifically forbids
its operation as an independent concern. On one hand, the licensing application envisages the sale of
alcohol and the performance of live music until 24:00. On the other hand, it is readily expected that the
visitor’s Centre will close at dusk, so regular visitors will have left the area long before 24:00. Surely,
therefore, the café would have to close at the same time as the visitor’s centre to meet the current planning
permission? If this licensing application is successful, Walthamstow Wetlands may then be operating in
breach of its planning permission.

In light of this information, I would like to formally request a written response to these concerns at the
above address.

Your sincerely,

[Insert Name]