Anya Buckley

Festival and Event Solutions Limited

The Coach House
Ford Hall

Chapel en le Frith
High Peak
Derbyshire

SK23 OQR

Telephone Number:
Email address: |

Mr McLoughlin
Senior Coroner

HM Coroner’s Service
71 Northgate
Wakefield

WF1 3BS

19 April 2021

By email only

Dear Mr McLoughlin

OUR CLIENTS : FESTIVAL REPUBLIC LIMITED, LIVE NATION ENTERTAINMENT PLC AND
MATTER: REGULATION 28 REPORT DATED 19 JANUARY 2021 : ANYA LILY BUCKLEY (DECEASED)

! remain instructed by our Clients as set out above, in this matter, but please note my change of
contact details.

Background

The framework for the organisation of the Leeds Festival is that it is authorised by a Premises Licence
issued by Leeds City Council in its capacity as the Licensing Authority. The process under the Premises
Licence is that Festival Republic must present an Event Management Plan for each Festival to
demonstrate that it is promoting the four Licensing Objectives:

e Prevention of Crime and Disorder
e Public Safety
° Prevention of Public Nuisance

e Protection of Children from Harm

Each year, the Event Management Plan is presented to a Multi Agency Group (including the Police,
Safeguarding and Child Protection Agencies) for scrutiny which takes place over a period of several
months before a Festival. in addition, sub-groups are formed to consider specific issues which then

inform the main Multi Agency Group.

Registered Office - 45 Union Road, New Mills, High Peak, SK22 3EL Registered Number — 13223887
This company is not authorised and regulated by the Solicitors Regulatory Authority

A Multi Agency Debrief takes place each year and the experience and learnings from each Festival are
fed into the planning process for the next Festival.

Reading Festival is a sister Festival to the Leeds Festival. It takes place over the same weekend and
has the same audience demographic and the same artists. The learnings from both festivals are
carried into their respective Event Management Plans.

This planning process of submitting a draft Event Management Plan, which is scrutinised and
developed over several months before it is finally approved, is one which has been successfully
adopted for all Festival Republic Events under the previous Public Entertainment Licensing regime (pre
2006) and under the existing regime introduced in 2006. It is a tried and tested process which has
been adopted nationwide by all major promoters and is one which is recognised in the relevant
industry guidance.

In our experience, the Leeds Licensing Authority has been a robust Regulatory Authority whilst being
supportive of our Clients’ efforts to improve the Festival each year.

Police Evidence
Thank you for allowing us to delay this response until the Police had finished their investigation.

This week our Client received a summary of the evidence gathered by the Police regarding the death
of the Deceased and the circumstances of the supply of illegal drugs, which was presented to the
Crown Court at a hearing on 12 April 2021. The summary is shocking. Evidence gathered by the Police
indicate that the Deceased was a party to the conspiracy to take illegal drugs into and supply illegal
drugs at the Leeds Festival in 2019.

The evidence shows that an organised drugs gang consisting of persons between the ages of 17-25
organised and carried out a plan prior to Leeds Festival 2019 to purchase a quantity of illegal Class A
and Class B drugs to sell at the Festival.

The Regulation 28 Report

In the Regulation 28 Report, it is suggested that the entry to Leeds Festival for persons aged 16 and
17 should be restricted.

It is clear from the Police investigation that a restriction requiring people aged 16-17 to only be
admitted to the Festival with adult supervision would have been futile in preventing the death. The
gang members comprised of some persons over the age of 18 who could easily have fulfilled this entry
restriction if it had been in place.

Further, our Clients consider that a ban on ail persons under 18 attending Leeds Festival would be a
disproportionate reaction to the death. The evidence does not support such a conclusion and from
our Clients’ discussions they do not believe that such a proposition is supported by the Licensing
Authority, the Police or other Responsible Authorities.

Registered Office - 45 Union Road, New Mills, High Peak, SK22 3EL Registered Number — 13223887
This company is(fc} authorised and regulated by the Solicitors Regulatory Authority

Leeds Festival is a properly authorised and regulated event with a raft of measures to protect persons
of every age who attend the Festival, these include:

. Aplanning process for each event and the approval by the Licensing and Responsible Authorities
of the Event Management Plan as described above.

° Risk assessments and a Drugs Policy approved by the Police and other agencies which includes

covert operations to detect and disrupt any drug dealing.

An agreed Searching Policy on entry to the Festival including the use of drugs detection dogs.

A drugs advisory service where drugs are tested by the Police.

Amnesty bins on site for the surrender of illegal substances.

Approved onsite medical facilities.

Welfare facilities including safe hubs offering peer to peer support.

A Challenge 21 Policy for all bars.

° Security and Stewarding Plans including numbers and deployments agreed with the Police.

° All security, stewarding and welfare staff are trained to be aware of persons showing apparent
distress. There are specific welfare protocols for assisting persons under 18.

The statistics for Leeds Festival do not demonstrate a failure by Festival Republic to fulfil its duty to
take reasonable care of all persons attending the Festival. The operations for searching for illegal
substances on entry demonstrate considerable success by security in apprehending those who supply
drugs and the Medical and Welfare Provisions are all considered to be of a very high standard. tn
2019, drugs worth over £120,000 were seized and 117 individuals were appropriately dealt with for
drug related matters by onsite security.

Our Clients fully understand the popularity of the Festival with young persons and addresses the
challenge of younger persons attending their events within the provisions they put in place, for
example, by significantly enhancing the Welfare Provision. The data recorded relating to incidents,
welfare and medical interventions in previous festivals {both Leeds and Reading) does not show any
increasing trends involving 16 and 17 year olds.

Actions Taken and to be Taken

Our Clients are not complacent and following receipt of the Regulation 28 Report our Clients fed the
concerns which are expressed in it into their internal planning for Festivals.

In addition, our Clients have liaised with Leeds City Council and fully participated in discussions with
the Council, the Police and other Relevant Agencies which began on 9 February 2020. A Working
Group was formed by Leeds City Council and meetings of the Working Group and the Licensing
Committee of the Council have taken place with further discussions and correspondence also taking
place at officer level,

Our Clients understand that a further meeting is to be held by the Licensing Committee on 19 April
2021 and we will engage with the Council further following feedback arising from that meeting.

However, we feel it appropriate at this time to bring you up to date with the following further actions
which will be taken in connection with all future Leeds Festivals :

° Our Clients will commit to an ongoing specific review of their Safeguarding Plans within the
Event Management Planning Meetings which are already part of the planning process.

e Our Clients will host and participate in a Festival S-Map Group which is to hold its first meeting
on 28 April 2021. This will be a working group hosted by Festival Republic, including

Registered Office - 45 Union Road, New Mills, High Peak, SK22 3EL Registered Number — 13223887
This company Is not authorised and regulated by the Solicitors Regulatory Authority

representatives from Festival Republic, Leeds City Council, Reading Borough Council, the Police,
Forward Leeds and a leading Child Clinician. The purpose of the Group is to discuss harm
reduction campaigns and how best to communicate with and educate Festival audiences
regarding drugs and overall safety, both pre event and during events. It will focus on campaigns
and safety messaging which can be used in conjunction with and at Leeds and Reading Festivals.
Research and findings from engagement with young people will be fed into the Group and there
will be resource and input from the existing Responsible Drinking Programme. An agency will
be appointed to advise upon and create messaging / animations/ communications across social
media platforms and apps appropriate to all age groups.

° Stand alone drugs advisory points and welfare points will be introduced into the arena, rather
than being part of combined service points, to make them more accessible and user friendly.
These will be clearly signed and they will have some younger staff to enhance peer to peer
communication.

. The safe hubs on the campsites will have improved signage and again, these will be made more
user friendly for younger members of the audience.

e Medical provision will be reviewed and increased in the campsites as necessary.

. Specialist medical advice will be obtained to establish whether or not further facilities are
required for treatment of drug related admissions.

. A review of the drinking water facilities will take place and enhanced as necessary.

° A system of wrist bands for under 18 year olds will be implemented so they can be identified
more easily and quickly.

All of the above actions will be progressed by our Clients immediately with a view to the measures
being introduced for the Leeds and Reading Festivals 2021.

We will update you further following feedback received from Leeds Licensing Committee after its
meeting on 19 April 2021.

Yours sincerely

Solicitor
Festival and Event Solutions Limited

Registered Office - 45 Union Road, New Millis, High Peak, SK22 3EL Registered Number — 13223887
This company is not authorised and regulated by the Solicitors Regulatory Authority

Response to the Senior Coroner in relation to the 
Regulation 28 report following the Licensing 
Committee meeting on 19th April 2021 

Approved by Councillor 

 (Chair of the Licensing Committee)

I refer to your letter of 18th January 2021 and the enclosed Regulation 28 report dated 19th January 2021 relating 
to the death of Anya Lily Buckley. This is a response to the report provided on behalf of Leeds City Council (LCC) 
through its Licensing Committee. 

The Matters of Concern raised by the Senior Coroner in the Regulation 28 report have been carefully considered 
by the Council. 

Background 

Leeds City Council’s Licensing Committee granted the premises licence to Festival Republic for the Leeds Festival 
at the Bramham Park site on 28th April 2006.  Each year before the festival the Licensing Committee considers and 
agrees the Event Management Plan (EMP).  Following the festival the Licensing Committee has a de-brief meeting 
including consideration of improvements for the following year. 

The Safety Advisory Group (SAG) also provides advice in relation to the event.  The SAG is made up of 
representatives from the local authority, emergency services, and other relevant bodies.  They meet to review 
event applications and advise on public safety. 

Festival Republic has worked with the Council and other stakeholders, including the Police, over the years to 
introduce and improve on welfare provision on site.  

The legal positon 

The licensing of festivals is dealt with by councils within a statutory framework. The Premises Licence for the 
festival was granted pursuant to the Licensing Act 2003.  To limit the age range of attendees at a festival would 
require a condition to be attached to the licence.  This could be by consent, or otherwise could arise from a 
review of the licence through application of a responsible authority. If a licence holder were to disagree with a 
condition there is a process to follow including a hearing, with a right of appeal to the Magistrates’ Court. 

It is to be noted that there is no national age restriction on those able to attend festivals; neither is there 
guidance suggesting age restrictions on festival goers. 

The Council does not have a policy on restricting the age of festival goers and if it wanted to introduce such a 
policy for festivals, the policy would potentially need to be consulted on and approved as part of the Council’s 
Statement of Licensing Policy by a meeting of full Council. 

Action taken in response to the Regulation 28 report 

Upon receipt of the Regulation 28 report the Licensing Committee immediately set up a working group with key 
stakeholders, Festival Republic and the parent of Anya invited to take part. 

Working group participants:  

Five members of Licensing Committee (Cllrs 

 (chair), 

 and 

); 

Representatives of the following: 
West Yorkshire Police; 
West Yorkshire Ambulance Service;  
LCC Safer Leeds – Chief Officer;  
LCC Public Health;  

Issued: 23rd April 2021 

 LCC Childrens & Families; 
LCC Safety Advisory Group;  
LCC Emergency Planning;  
LCC Environmental Health / Health & Safety;  
LCC Elections & Regulatory Chief Officer (including oversight of Licensing, Environmental Health and 
Health & Safety);   
LCC Entertainment Licensing; and 
LCC Legal Services.  

Meetings took place to discuss the regulation 28 report on the following dates:  

Working Group: 9th February, 22nd February & 12th March 2021. 

Licensing Committee: 2nd March, 6th April & 19th April 2021. 

The parent of Anya, & Festival Republic attended a working group meeting and the Licensing Committee meeting 
of 6th April. A representative from the Loop also attended the Licensing Committee meeting on 6th April.  

Outcomes from the Working Group and Licensing Committee meetings 

The Licensing Committee heard that young people often attend the Leeds Festival to celebrate after receiving 
examination results and that, provided appropriate safeguarding is in place, this can be an enjoyable experience 
for them.  

The Licensing Committee recognised that Festival Republic have worked with LCC since they were first given the 
premises licence to hold the event. The Committee acknowledged that there were already a number of welfare 
provisions in place. 

Additional measures requested by the parent of Anya and considered by the working group and Licensing 
Committee were:  

 

 

 

Increased water on site.  The working group heard that Festival Republic ensure there are sufficient 
facilities on site.  They provide water points throughout the site to the satisfaction of Environmental 
Health/Health & Safety and in addition drinking water is available free of charge from each bar.  They 
have committed to review the drinking water facilities and enhance as necessary.  
Increased medical facilities. There was consideration of whether there should be additional medical 
centres to those already in place.  Operationally there is one main and two supplemental sites with the 
ability to treat festival goers, including ambulance provision to take those further away to medical 
stations.  Festival Republic said they will review this provision and increase in the camp sites as necessary.  
They have also committed to obtaining specialist medical advice to establish whether or not further 
facilities are required for the treatment of drug related admissions.  
Increased education provision to young people about drug awareness. Festival Republic explained what 
measures they have in place already, and confirmed they are committed to working closely with the 
Council’s public health team to widen educational awareness.   

  The provision of voluntary testing of drugs on site. Information from an organisation (The Loop) which 
provides this facility at some sites in the country was considered, though it was recognised that this may 
increase the risk of harm by creating a sense of false security.  Part of the discussion was that such 
organisations may test drugs and be able to say what they are made up of, however they are unlikely to 
be able to say with any certainty what the impact of taking the drug might be on different people. Festival 
Republic were open to consider the use of such an organisation going forward if supported by LCC and 
the West Yorkshire Police.  The working group heard that the Police do already carry out back-of-house 
drug testing. 

  Restricting the age of entry to 18- see below. 

Issued: 23rd April 2021 

 
 
 
 
 
 
 
 
 
 Festival Republic have, in addition to the welfare provisions they already have in place, committed to: 

• 

Joint partnership/working group with LCC Public Health, Forward Leeds and Reading counterparts; 

•  Review of educational and harm reduction messaging; 

•  Additional welfare facility within the arena and drugs advisory information points; 

•  Review of Safe Hub locations and signage to optimise usage; 

•  Review of the medical provision as referred to above; and 

•  Additional West Yorkshire Police covert officers to work with existing Festival Republic security teams. 

Limiting the age range 

The parent of Anya argues that if the event had been restricted to 18, her daughter would not have attended.  
Also that those who attend who are under the age of 18 are children and vulnerable, and should be protected. 

The Regulation 28 report suggests that children below 18 are not allowed into licensed premises.  In fact the 
Licensing Act 2003 does not carry any age restrictions for young persons’ entering licensed premises, but provides 
that they are not allowed to consume alcohol (subject to certain exceptions). 

The Licensing Committee discussed whether the appropriate age limit should be 18 unless accompanied by an 
adult. They considered: 

  As referred to above, there is no legislation or national guidance limiting the age range of attendees at 

festivals; 

  Anya was with a group which included older adults, so such a condition may not have prevented her 

attendance; 

  Festival Republic’s view that it may cause young people to go elsewhere; 
  Festival Republic’s view that the consideration should be on improving the welfare provisions for all who 

attend;  

  The detail of welfare and safety provisions already in place, including a host of information available via 

Festival Republic’s social media, and their commitment to review and improve; 

  There have been no adverse representations from any of the statutory responsible authorities as 

prescribed under the Licensing Act.  

Decision of the Licensing Committee 

Having considered the issues raised at length the Licensing Committee determined that the Chair of the Licensing 
Committee should respond to the Senior Coroner on its behalf.  

The following response is provided on behalf of the Licensing Committee. 

The Licensing Committee: 

  Expresses its sincere condolences to the family and loved ones of Anya following her tragic death; 
  Expresses its thanks to all of the attendees at the working group and Licensing Committee meetings for 

the information provided, including Festival Republic and in particular the parent of Anya; 

  Notes the current welfare and education provisions in place and notes the additional measures to be put 

in place by Festival Republic as outlined above; 

  The Committee recognises that the issue is not as straightforward as indicating a restriction on age, as 
there is the national position to consider and festival age ranges are not restricted by legislation or 

Issued: 23rd April 2021 

 
 
 
 
 
 
 
 
 
 
 suggested by guidance.  The Committee feels that this is an issue which is relevant to numerous festivals 
throughout the country;  

  The Event Management Plan (EMP) will be carefully considered through the Safety Advisory Group 
process for all relevant agencies to be satisfied with the safeguarding, drug prevention and medical 
provisions at the Festival; 

  Notes that Festival Republic, after discussion by the working group and Licensing Committee on how 16 
and 17 year olds are already or could in future be identified on site, intend immediately to implement a 
system of wrist bands for 16 and 17 year olds so they can be identified more easily and quickly;  

  The joint partnership /working group  with LCC, Public Health , Forward Leeds and Reading counterparts 

to be provided with information on drug education in schools at a local and national level and to consider, 
if appropriate, if representations can be considered for this to be expanded on;  

  A sub group of the Safety Advisory Group process, specific to the Leeds Festival, will be set up to consider 

education, welfare and safeguarding, and in particular: 

For the protection of tickets holders in general: 

a.  Whether anything more can be done by Festival Republic and with partner agencies to prevent 

drugs being taken onto the festival site.  

b.  To consider whether front-of-house voluntary drug testing should be available in addition to the 

back of house testing carried out by West Yorkshire police. 

For the purpose of protecting children from harm: 

c. 

In addition to the age verification and wristband system proposed for 2021 to identify attendees 
of 16 and 17yrs, to progress with Festival Republic being able to capture data provided at the 
point of sale of tickets to understand the demographic of attendees prior to each festival.  For 
example, to include the age of the ticket purchaser and the age of the person for whom the ticket 
is intended.  

d.  Look at proposals to enhance the safety of minors at the festival.  
e.  To consider measures to prevent opportunities for child exploitation (for example in relation to 

drug sales or use) at the festival. 

  Following the 2021 festival, the Safety Advisory Group process will be used to measure the effectiveness 
of additional welfare and safeguarding measures and future arrangements going forward, which could 
include, if necessary, consideration of an age restriction of attendees. 

Issued: 23rd April 2021