Dear Councillor Williams,
I am writing on behalf of the Campaign for Freedom in Everyday Life, a civil liberties research and campaigning organisation. We have recently published a report, “Banned from the beach: the crackdown on outdoor community sport”, which documents how councils across England and Wales are imposing licensing fees and paperwork on free and donation-based outdoor community activities. Bristol is one of the councils featured. I am writing to set out our opposition to the parks business licence and the separate Downs scheme.
Our central concern is one of proportion. Charging schemes of this kind grew up in the early 2000s to deal with commercial personal trainers and bootcamps that made money from intensive use of parks. Bristol’s scheme now applies the same requirements to tiny, informal, non-commercial gatherings. When the parks licence was first announced in 2021, the council said non-commercial groups would pay only a “nominal fee”. By the time the scheme was implemented in 2025-26, a donation-based qigong class was being asked to pay the same amount as a commercial fitness business. That is not the promise that was made.
The effect on groups in Bristol is stark:
• Chloe Broomby runs a qigong class on the Downs on a “pay what you can” basis, sometimes for a single person. She faces a licence of £900 a year, charged on the maximum capacity of the class regardless of how many people actually turn up. She has said plainly that she will not be able to continue if forced to pay.
• Julia Turner’s BYOB (Bring Your Own Baby) choir for mothers and babies faces a fee of £400 plus VAT, along with public liability insurance, a risk assessment and a first aid certificate to sing in a park. Mothers have described the sessions as “a lifeline” at a vulnerable stage of life.
• Ailie Tam ran “tree-to-tree” yoga, often for just two or three people, and would need two separate licences because the session moves between two parks. She has stopped, because the fee would exceed anything she could make. She is also a Friends group volunteer who collects litter and plants bulbs in the very park she can no longer teach in.
We were struck by the committee’s stated rationale that the fees are “a regulatory issue to make sure that our parks are safe”. It is genuinely unclear what safety risk a postnatal choir, or a handful of people doing qigong, presents. These groups leave no trace, occupy a space for an hour, and bring real benefit to the parks and the people who use them.
We recognise the council’s wish to manage large commercial events and any genuine damage they cause. But the answer to that is to deal with commercial, high-impact use, not to treat a donation-based community class as if it were a festival with stages and toilets. Tiered schemes, such as different fees for different clusters of parks or a discount for dog walkers, simply multiply the number of charges without addressing the basic objection: that small, no-impact, non-exclusive use of public space should not be charged at all.
We are calling for a blanket exemption for small-scale, informal community activity from parks and business licensing, with any qualification or insurance checks kept light-touch and one-off. We would welcome the chance to discuss the council’s events and parks policy with you, and to explore a more liberal, low-cost approach that would let these groups return to Bristol’s parks and the Downs.
Yours sincerely,
Josie Appleton