TER0048
Scunthorpe and North Lincolnshire Concert Society is a small charity with around 60 members (approximately halved since Covid lockdowns) and an average income over the last five financial years of £10,000. Our small but enthusiastic committee organise seven concerts each year to bring classical musicians of international renown to Scunthorpe, which is a comparatively ‘cultural desert’. Over recent years, we have focused on providing a platform for young musicians to perform to a live audience and are working with the local Music Hub to promote classical music to the younger generation and encourage aspiring young musicians in our local authority area.
Our venue is the main hall of a local Academy, which offers tiered seating, a performance space and access to catering facilities, but at considerable and increasing cost, as obviously, the prime aim of the Academy is the education of the students and not support of the society. The Academy Business Manager oversees the hire of the facilities and ensures the society confirms to all requirements of health and safety, insurance etc while using the premises.
We would like to draw to your attention the potential impact, both direct and indirect, of the proposed Terrorism (Protection of Premises) Act 2023, referred to as Martyn’s Law, for Scunthorpe and North Lincolnshire Concert Society and for the voluntary sector more widely.
Under the proposed legislation the Academy would be responsible for ensuring certain measures are put in place to mitigate the potential of a terrorist attack, but would be able to require a ‘co-operation notice’ for all those hiring premises to conform to procedures. Whilst understanding the need for action to prevent attacks such as the Manchester Arena bombing and acknowledge the devastation this caused to people’s lives, including Martyn’s parents, we are extremely concerned about the implications for our society as follows:
i) The bill places additional burdens on people responsible for premises, both standard premises (capacity 100 – 799) and enhanced premises (over 800 capacity). From our point of view, it is unclear whether these numbers refer to the overall premises, which has a capacity of over 800, or to the actual space which is subject to the hire agreement - the hall can accommodate 300 audience members. This is significant as it would determine what level of additional action we may be required to take, depending on whether the premises we hire are categorised as standard or enhanced. References in the proposed Act to ‘part of premises’ or ‘premises within premises’ lack clarity.
ii) It is unclear whether there will be costs associated with meeting the requirements of the bill, particularly the training requirements; factsheets indicate these are intended to be ‘low-cost activities’. However, we are not convinced this training will be without cost as there is no reference to ‘free’ training in the proposed Act. Certainly our committee members’ time in accessing the training will be involved, even if there is no financial charge. Given recent experience of refreshing our first aiders’ training, we have had great difficulty accessing suitable courses in the local area as none were available; when we did find appropriate training, the courses were costly and the members involved felt obliged to contribute to the costs themselves rather than further deplete the society’s funds. It is also worth noting that not all our volunteer committee members are sufficiently computer-literate to access on-line training.
Our rent is already very high, and the effect of this is being passed on to our members as we are having to select less expensive artists rather than increasing our ticket prices. Is additional training one more cost that will impact on our increasingly precarious financial situation?
iii) The proposed ‘cooperation notices’, which those in charge of registered premises could give to organisations running public events in their premises, would require us to take on a share of the duties. We note that the person in charge of the registered premises cannot ask for action to be taken which would ‘place a disproportionate burden on P (having regard to P’s resources and the premises to which the step relates).’
We have already produced a risk assessment which is reviewed, updated and shared with the Academy annually. Following the original consultation on the Protect Duty, we included a potential terrorist attack in our risk assessment and took steps to mitigate this. To request more than this action we feel would be disproportionate to a small charity with a small number of events and limited resources. It is unclear who would decide what is ‘disproportionate’ in this case.
iv) All these additional burdens and pressures lessen our chances of being able to recruit new committee members in a society which has an aging membership.
More general comments:
i) Suitable venues are already in short supply in our area and rental costs are understandably increasing due to energy and staffing pressures. This proposed Act will not help small organisations but will exacerbate the situation. Those in charge of renting out premises may decide it is just too much hassle and too costly to have to ensure those hiring the premises also comply with the proposed legislation. Our society has already struggled to find a suitable venue and each time we move, our audience numbers reduce.
ii) The proposed Act places burdensome and potentially costly requirements on small charities – quite out of proportion to the effective management of such organisations, which many can ill afford. This proposed Act aims to lessen the impact of attacks by terrorists, but the number of attacks on individuals by those with metal health issues is also rising – will the next step be to require those in charge of premises and those organising events to mitigate against attacks of this sort too?
iii) The potential demise of our concert society, and indeed other organisations, given the additional pressures and costs which this proposed Act could generate would have a detrimental effect on the local community – its health, well-being and social cohesion. If micro-organisations such as concert societies have to close, it will take some joy out of the world. Is that really what Martyn would have wanted - especially as he had been in Manchester to celebrate live music.
June 2023