Full text: London Zoo director Ralph Armond's plea to licensers against World Cup football event
THE FULL TEXT OF RALPH ARMOND'S LETTER OF OBJECTION AGAINST REGENT'S PARK FAN ZONE
I AM writing to you in respect of the Greater London Authority’s (GLA) application for the Fan Fest on Gloucester Green in Regent’s Park (from 11 June to 3 July 2010) in my capacity as the Director General of the Zoological Society of London (ZSL)
ZSL is a charity dedicated to the worldwide conservation of animals and their habitats. We were formed in 1826 so have been recognised as a ‘learned society’ for over 180 years. We employ more than 80 scientists carrying out primary research on questions of zoology and conservation biology, we manage conservation projects in more than 50 countries worldwide and we run two zoos – in Regent’s Park and at Whipsnade, Bed’s, which between them welcome over 1.5m visitors per annum for an enjoyable and educational day out.
I would like to point out at this stage that we value our relationship with the Royal Parks Agency and work very closely with them for the good of Regent’s Park and all its stakeholders. We fully understand and agree with the vision of the park being an important facility for local people as well as being a ‘green lung’ for all Londoners and visitors to London. Regent’s Park puts on an increasing range of special events during the year and up to now, we have fully supported these events – in fact we have not registered any objections to any proposals in our Directors’ living memories!
However, it seems to us that this current event and licensing proposal is of a scale way beyond anything that has been tried out before in this location.
As we understand it the Fan Fest is proposed to run for 24 days, with up to 3 matches per day being screened and a maximum attendance level of 19,999. Its location in the north east corner of Regent’s Park is immediately adjacent to the zoo boundary for the length of approximately 400 metres.
We have concerns about this event in relation to each of the four licensing objectives:
Public Safety
With up to 19,999 visitors per match (and up to 3 matches per day) there will be significant movements of people during the licensing period, in addition to our own daily visitors of 4,000 – 5,000 (of whom 2,000 per day will be school-children on school visits.) These are enormous numbers of people movements in an area of London that is relatively poorly served by public transport (no buses allowed in the park) and the Northern Line tube will be closed intermittently as part of the major line upgrade. Other possible tube stations (Regent’s Park, Baker Street etc) are around 20 – 30 minutes walk away.
We believe the football crowd arrivals and departures will seriously impact on arrivals and departures of zoo visitors – most of the people and vehicle movements will be using just one road – Outer Circle. We consider this a risk to public safety.
Prevention of Public Nuisance
We are not aware of the proposed noise levels as they have not been specified in the application. We do know how much noise the zoo has received from smaller concerts/events in the past on Gloucester Green, and we have accepted this because we have always wished to be seen as ‘good neighbours’ and the events, in general, have been just a few hours long. In some cases we have shut our animals away to keep the impact of noise to a minimum for them (it is appropriate to keep animals contained indoors for short periods, but animal welfare becomes an issue if this happens for longer periods.)
We believe that 24 days of exceptional noise (foghorns, 20,000 spectators, peak ‘roars’ when a goal is scored etc) adjacent to the zoo could create a serious animal welfare issue. According to Professor Adrian Fourcin F.I.O.A (who is an Emeritus Professor at University College London, and an expert in noise studies), a football crowd of 20,000 will produce a noise level of around 100dB, with 110dB in ‘moments of especial interest’. Applying these measures to the DEFRA ‘Noise Map’ he states that “the noise level in the heart of London Zoo would be around 30dB greater than normal.”
There are several scientific papers that have considered the impacts of anthropogenic noise on wild animals. Clearly the situation for wild animals is not the same as for animals in captivity, but studies show that animals in the wild respond by moving away from noisy environments. Clearly this is not an option for animals in the zoo.
Regarding animals in captivity there are 3 studies we would like to highlight:
Our own research on the gorillas at London Zoo (approximately two years of study), shows that when we have busy days and a generally higher decibel level from the public, the behaviour of our gorillas is adversely affected. This is why we limit visitor numbers in July and why we always position a member of the zoo staff in Gorilla Kingdom to quieten noisy children.
We conducted a number of noise studies when we were considering opening a new aquarium (Biota) at Silvertown Quays in the London Docklands. We were particularly interested in the noise from planes overhead and from London City Airport. We contacted Paul Anderson from the Florida Aquarium who is studying for a PhD on sound and stress in fish. Paul’s work was mainly related to fish but it is known that, in general, terrestrial animals have much more sensitive hearing than fish, and his conclusions were that animals that rely on acoustic communication for social behaviour could easily be adversely affected by additional noise and with louder noise exposure there could be some permanent damage to them.
There is a recent study by Wright et al. (2007) on anthropogenic noise as a stressor in animals that does document evidence of negative effects. Most of the evidence here relates to experiments on laboratory rats but the precautionary principle would lead one to assume that similar effects would pertain in our animals. Known effects of noise in animals includes audiogenic seizures and increases in serum cholesterol levels, intestinal inflammation, and increased adrenal weights due to overproduction of adrenal hormones. All these are effects that could arise from prolonged stress response. Stress responses induced by loud or sharp noises have lead to cannibalism as well as a generally decreased reproductive performance in mice. Laboratory rats exposed daily to short periods of white noise exhibited a variety of conditions consistent with the onset of a physiological stress and some pathological effects continued to persist even after removing the noise exposure.
[Wright, Andrew J, Soto, Natacha Aguilar, Baldwin, Ann Linda, Bateson, Melissa, Beale, Colin M, Clark, Charlotte, et al. (2007). Anthropogenic Noise as a Stressor in Animals: A Multidisciplinary Perspective. International Journal of Comparative Psychology, 20(2) 250 – 273.]
In summary, therefore, there are studies showing that animals will avoid noise if they possibly can, and that noise can cause stress in animals that cannot escape from it. This stress can have negative physiological and behavioural consequences for the animals, and these consequences do not necessarily disappear once the noise stops. None of these studies exactly simulates the conditions likely to be faced by our animals, but I think it is fair to say that they do raise serious concerns that the welfare of our animals is likely to be negatively impacted by the level of decibels indicated by Professor Fourcin, and particularly for the prolonged period of the Fan Fest.
The Prevention of Crime and Disorder
We have been assured by the GLA that there will be an adequate security presence. This is essential to us. It is however well known that there is a disorder link between alcohol and football, and we believe the potential for serious trouble is rife, again affecting our animals and zoo visitors.
We also have concerns particularly at the end of the evening, when it is dark, as to how the egress of the 19,999 supporters will be managed particularly as the local transportation system will not accommodate these numbers. The park lighting is non-existent and the Outer Circle street lighting is poor, and our periphery fence is not particularly high in places. We have, in the past, experienced people under the influence of alcohol, trying to climb over the fence into the zoo. This is a potential extra temptation at night when we have such large numbers of people right next to the zoo e.g. “how close can we get to the lions?”
The Protection of Children from Harm
We have no specific issues here other than our general concerns of how well football supporters will mix with our largely family audience profile (plus 2,000 schoolchildren every day during the week.)
In summary, whilst we have always supported previous events in Regents’ Park, we have serious concerns (particularly over zoo animal welfare) from this proposed event, and licensing application. The scale of this event is way beyond anything we have experienced before and its location could not be closer to the zoo (literally metres away from the penguins, macaws, anteaters, lions, squirrel monkeys and Blackburn Bird Pavilion. ZSL is most concerned about the location of this event. We think this corner of Regent’s Park is a wholly inappropriate location for the Fan Fest and cannot believe there is not another location either in Regents’ Park or elsewhere in London that does not have this serious animal welfare impact.
We would urge the Committee to reject this application.
Yours sincerely
Ralph Armond
Director General