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The Licensing Sub-Committee received report ES/2831 which related to a Temporary Event Notice (TEN) application for the Holistic Woods Campsite, The Walks, Sutton Heath, Woodbridge IP12 3DP.
The Licensing Officer summarised the report, noting that the reason for the licensing sub-committee was that 1 representation against the application had been received. These had previously been circulated as Appendix B of the report.
Since the publication of the agenda a further document was supplied and circulated to members of the committee which was an email from the event organiser. It aimed to address the concerns of the Environmental Protection team relating to the water supply and amplified sound. They proposed using a sound limiter and reducing the hours of the event. They were happy to provide a Noise Management Plan setting out the sound limiter, sound checks, monitoring arrangements, speaker positioning, late-night reductions, complaint response procedure, and named responsible person.
The Chair asked for clarity on who the applicant was. The Licensing Officer explained that Simon Hawthorn was the named applicant who is part of the event organisation and not the owner of the venue.
The Chair asked how close the venue was to Rock Barracks accommodation.
The Environmental Protection Officer did not know exactly where on the site the event would take place so was not sure. The Licensing Officer said there was some distance, but it depended on where the event will be located on the site. The Chair was aware there were children living at the Barracks and it was noted there was a primary school on the Barracks site.
The Environmental Protection Officer said they didn’t have enough information about the site including a plan. They had concerns about the noise and hours. With other festivals there have been site visits. Although the email says they will scale back the hours they had concerns about the DJ social levels and what this constituted. The organiser has volunteered to monitor and to use a sound limiter but Environmental Protection was not sure how this would work in the open air. They had not seen a noise management plan and there was a lack of confidence that the organiser could control the noise as they propose. Normally an event like this would go to the Safety Advisory Group (SAG). They also had questions about the adequacy of water on the site. Would have expected conversations to have been held but there was a lack of information and because it was a TEN it was subject to tight turnaround times to hold the meeting.
Councillor Gee had concerns about the fire acts and if there was a long dry summer there were heightened fire risks. The Environmental Protection officer said SAG would normally input into this. Looking at the Flow in the Forest website it makes mention of the activities and there are Health and Safety implications but this was outside of Environmental Protection’s remit. He reiterated that this type of event would normally go to SAG and these concerns would be discussed with all the relevant bodies.
Councillor Thompson asked if they should go to SAG. The Environmental Protection Officer said they did have concerns but at this stage they don’t think SAG has been approached. It is for the applicant to choose if they want to engage with SAG.
The Chair asked about the water supply and if there was only one standpipe. The Environmental Protection Officer thought that was the case. The Chair had concerns about the lack of handwashing facilities by the portaloos. The Environmental Protection Officer said they didn’t know if the water supply was adequate and they didn’t know what would be offered on the site, eg food suppliers.
Councillor Gee asked if checks can’t be carried out unless they go to SAG. The Environmental Protection Officer said they can enforce without as there is legislation. But they would prefer discussions happened before that and the applicant showed how they would deal with all the elements and concerns.
The Chair asked about the DJ limit and how loud 65dB(a) was in the countryside. The Environmental Protection Officer said he estimated that the background noise will be in the low 20s so there was a significant jump. This is a figure often cited by pubs/clubs/festivals. It doesn’t take into account the low background noise levels. He had concerns about how they would monitor and control it. Festivals normally have someone managing this.
The Chair asked the Legal Adviser to clarify about the counter-notice. The Legal Adviser explained that if this was issued the event could not go ahead. The applicant could reapply but they would need to address the concerns. Without a counter-notice the event could take place.
The Legal Adviser explained that modifications would have to be agreed to. If East Suffolk issued a counter-notice then it would be for the applicant to choose to engage with Environmental Protection or not. If the site layout and plans proved to be acceptable then Environmental Protection would be unlikely to object.
The Legal Adviser summarised what he felt were the reasons for objecting:
• Not sure where on site it is
• No noise management plan
• Not sure about sound levels of DJ
• Effectiveness of noise monitoring
• Noise sensitive premises nearby
• Overall lack of meaningful engagement
• No information about stage location/placement
• Concerns about water supply
Councillor Gee wanted to raise that they had concerns about the fire risk.
Concerns were raised about the amended proposed times and that Friday still ended at 1am. The Environmental Protection officer confirmed they had concerns about the times and the length of the event noting that Thursday and Sunday nights are school/work nights. They also have concerns about how people arrive on site and how noise is controlled onsite after the main event has finished. The Environmental Protection officer explained that they have received noise complaints about the site in the past and this is a noise sensitive site.
The Sub-Committee then adjourned to consider its decision.
Decision Notice
This Sub-Committee meeting has been held as East Suffolk Council’s Environmental Protection Team raised objections to the Temporary Event Notice (TEN) given by Mr Simon Hawthorn. The objection notice was received within the prescribed consultation period after receipt of the TEN, as specified in the Licensing Act 2003. The Environmental Health objection is based upon the licensing objectives of public safety and the prevention of public nuisance.
It was explained that the applicant was looking to hold an event organized by Flow In The Forest Limited for adults involving flow arts, circus skills, fire performance, movement, music, wellbeing and related creative industries.
The Notice was to allow:
The sale by retail of alcohol (on sales only)
19:00 to 01:00 on Friday 18 September, 19:00 to 02:00 on Saturday 19 September and 19:00 to 23:00 on Sunday 20 September 2026.
Regulated entertainment
19:00 to 23:00 on Thursday 17 September, 19:00 to 01:00 on Friday 18 September, 19:00 to 02:00 on Saturday 19 September and 19:00 to 23:00 on Sunday 20 September 2026.
Late Night Refreshment
23:00 to 01:00 on Friday 18 September, 23:00 to 02:00 on Saturday 19 September 2026.
Following receipt of the objection from Environmental Protection the notice giver indicated that they would amend these hours to the following extent:
Thursday 17 September: amplified music to start no earlier than 18:00 and end by 23:00.
Friday 18 September: amplified music to start no earlier than 18:00, with later entertainment limited to controlled amplified sound managed under the Noise Management Plan.
Saturday 19 September: amplified music to start no earlier than 18:00. Live music/main stage to end by 00:00, with any later entertainment limited to the lower-level social/DJ area only.
Sunday 20 September: amplified music to start no earlier than 18:00 and end by 23:00.
Monday 21 September: no amplified music; departure and site exit only.
In response to Environmental Protection’s concerns regarding the control of amplified sound the notice giver indicated that they were happy to provide a Noise Management Plan. This would set out the sound limiter, sound checks, monitoring arrangements, speaker positioning, late-night reductions, complaint response procedure, and named responsible person.
The Sub-Committee heard from the Licensing Officer, who summarised the report and the Environmental Protection Officer. The Sub-Committee noted that the notice giver was aware of the meeting date and time and had been phoned by the Licensing Officer on Wednesday 17 June and again on the morning of the meeting and had indicated this morning that they were unable to attend. The Sub-Committee decided to proceed in the notice giver’s absence as there were statutory time limits for the hearing to take place and the notice giver was aware of the meeting taking place.
During the meeting Environmental Protection maintained that the response from the notice giver had not dealt with their concerns sufficiently to allow them to withdraw their objection. Their concerns remained and can be summarised as follows:
Not sure where on site the event will be located – this is a large site and the location of amplification equipment will help determine the impact on nearby noise sensitive premises.
No noise management plan for the event – although some proposals have been made Environmental Protection is not satisfied that sufficient steps have been taken to fully mitigate the noise.
Lack of clarity regarding sound levels of DJs – therefore it is not clear what noise will need to be mitigated.
Lack of clarity regarding effectiveness of noise monitoring – due to the nature of the site noise mitigation may be difficult in any event. Environmental Protection will require more clarity regarding noise mitigation.
Location of noise sensitive premises nearby – there is a primary school, nursery and numerous residential premises close to the site. It is noted that the event will take place over four consecutive days, two of which are school/work evenings and therefore if there is noise disruption it could cause significant disturbance, in particular to children of school age. Environmental Protection noted that they have received noise complaints relating to this site before. Environmental Protection indicated that although the notice giver gave reference to 65dB(A) being the sound at the nearest noise sensitive boundary, given the nature of the site and that the typical background noise in this area will be much lower than this, eg low 20s dB(A), the impact of this noise will be quite high.
Overall lack of meaningful engagement with Environmental Protection - other than the email from 11 June there has been no engagement with Environmental Protection. Given the length and nature of the proposed event (it is noted that it is being marketed as a festival) Environmental Protection would expect substantial engagement, including potential site visits and Safety Advisory Group involvement.
No information about stage location/placement given the nature of the site – the location and orientation of the stage and amplified equipment could greatly impact on the noise disturbance to nearby premises. Without knowledge of where the siting of this equipment would be, Environmental Protection retains concerns that there is potential for unacceptable noise disruption.
Concerns about water supply – the site is advertised as a wild camp site with what appear to be limited facilities. There are concerns that there will be an inadequate water supply and a lack of hand washing facilities.
Fire risk – there were also concerns about the risk of fire, especially if there is a dry summer, however this was not the main reason for the objection.
Sub-Committee’s decision
The Sub-Committee has decided that under Section 105 (2)(b) of the Licensing Act 2003 that having regard to the objection notice it will issue a counter notice as it considers it to be appropriate for the promotion of the licensing objectives to do so, namely public safety and the prevention of public nuisance.
Reasons for Decision
The Licensing Sub-Committee took seriously the concerns of Environmental Protection, as they are the experts in the field of prevention of public nuisance. The Sub-Committee was concerned that these issues had not been adequately dealt with so it considered it necessary to issue a counter notice to promote the licensing objectives of public safety, in respect of the water supply, and the prevention of public nuisance in respect of the officer’s other concerns. This was for the reasons stated by the Environmental Protection Officer contained above and listed below in summary form:
• Not sure where on site the event will be located
• No noise management plan for the event
• Lack of clarity regarding sound levels of DJ
• Lack of clarity regarding effectiveness of noise monitoring
• Location of noise sensitive premises nearby
• Overall lack of meaningful engagement with Environmental Protection
• No information about stage location/placement given the nature of the site
• Concerns about water supply
The Sub-Committee also had concerns about fire risk, however this is not a formal reason for the counter notice.
The Sub-Committee notes the responsible body’s concerns and takes into account the Statutory Guidance, in particular paragraphs 7.34, 7.35 and 9.12. The Sub-Committee notes that section 9.12 indicates that the Licensing Authority must consider all relevant representations from responsible authorities carefully as they are experts in their respective fields.
The Sub-Committee has also considered its obligations under the Human Rights Act 1998 and the Council’s own Statement of Licensing Policy dated January 2024.
Anyone affected by this decision has the right to appeal to the Magistrates’ Court within 21 days of receiving notice of the decision and at least five working days before the date of the event.
Date: 19 June 2026