(TER0017)

Written evidence submitted by anonymous (TER0017)

Pre-legislative scrutiny of the Terrorism (Protection of Premises) Draft Bill

1. This submission is made on behalf of Amersham Concert Club, a registered charity which stages music concerts in Amersham, Buckinghamshire. These usually take place five times a year during the winter. The Club is run by volunteers and it holds its concerts in a local church.

2. In 2021 we made a submission in response to the consultation on the proposed Protect Duty, expressing concern that the requirements likely to be imposed on small community venues hosting events run by local groups could well lead to their closure, thus depriving towns and villages of places to hold events. Such venues are predominantly run by volunteers and they would be unwilling or unable to comply with the burdens imposed by a Protect Duty.

3. Having now studied the Draft Bill and the Explanatory Notes, we remain of the view that the administrative and organisational burdens on smaller venues will have a detrimental effect on smaller community venues that are predominantly run by volunteers and which offer their premises to local organisations for community activities. Such venues may well conclude that it is no longer worth continuing to offer their premises to community organisations.

4. It is not yet known how the ‘public capacity’ of each venue will be measured; that will be down to ‘regulations made by the Secretary of State’. The proposed criterion for venues to be subject to the ‘standard duty’ is a capacity of between 100 and 799 persons. There will be thousands of village halls and church halls across the country that will easily accommodate 100 people standing, but that does not mean that events held in those venues will involve that number of people attending.

5. Qualifying public venues such as village and church halls are frequently used for ‘recreation, exercise or leisure’ which is one of the specified uses of premises in Schedule 1 of the Draft Bill. This category encompasses use by a wide variety of organisations such as badminton clubs, bridge clubs, model railway societies for exhibitions, yoga and pilates groups; the list is almost endless. Pre-school playgroups often use such venues and will be affected also.

6. It seems unlikely that any of the volunteers running a community venue will want to act as the ‘responsible person’ for the venue, with the burden of registering the venue with the regulator; carrying out and keeping up to date risk assessments; arranging training of ‘workers’ (including other volunteers); and preparing and issuing ‘cooperation notices’ to others using the venue (which notices must be copied to the regulator).

7. No volunteer helping to run a community venue will want to run the risk of being served with a contravention notice or having to pay a penalty to the regulator.

8. If the proposals in the Draft Bill come into effect, Amersham Concert Club fears that it will lose its current venue in a local church because the volunteers who run that church will not be prepared to comply with the administrative and organisational requirements envisaged.

June 2023