17:15
Okay. Well, good morning everybody. It's now 10:00, so it's time to start um this morning's session into the examination
17:21
of the South Tinside uh local plan. Uh, my name is David Spencer, the planning
17:26
inspector appointed to carry out the independent examination of the submitted plan. Can I just check, can everybody in
17:32
the room hear me? Okay. Yep. Good. Thank you. Uh, just remind everybody for to
17:38
ensure that mobile phones are switched off or on their silent settings, please.
17:45
And can I turn to the council at this early opportunity to just set out as per
17:50
normal the usual kind of uh key housekeeping matters please. Thank you.
17:57
Okay. Good morning everybody. Uh we're not expecting any fire alarms. So if there is an alarm please make your way to the nearest fire exit which is on the
18:03
far side of this room and enter the far side of the hotel car park. Toilets are in the corridor outside this room to the
18:10
left. Uh please note that there's cables taped to the floor. So please be careful when you're moving around the room. And
18:15
also if you have a car in the car park, please make sure if you entered your registration number um in the devices at
18:21
the hotel reception. Thank you. Thank you for that. Can I understand is
18:27
anybody present from the local press here this morning? Thank you. I should know your name by
18:33
now, but just to remind the room and myself who you are, please.
18:46
Thank you very much. Uh just generally uh I think looking around the room a lot of people have been to these hearings um
18:52
sessions already but just a gentle reminder that in terms of this independent examination I am supported
18:58
by Annette Feny the independent program officer. H got to get my re reor
19:04
reorientated room. I've got to get my bearings on my right.
19:10
Yeah. Um Annette is your as previous sessions
19:16
is uh first port of call if you've got any um queries about the examination process or need to find any of the
19:22
material. Annette's based here whilst we're sitting uh and otherwise her details uh are on the examination
19:28
website and Annette will be supporting I hope the examination through to its conclusion uh and my my report. So you
19:36
may need to speak to Annette going forward. Uh these sessions are being recorded um
19:43
and the council is uploading them uh onto its website after the sessions are
19:49
concluded. Um just to remind everybody to again please use microphones as we're
19:55
going forward so they're picked up as part of the recording and to help people in the room uh follow the discussion.
20:02
Um, yep. Nothing further I want to say on on
20:09
that this morning. And then before we get on to the first session this morning is on matter 8 in relation to policies
20:16
um for economic development and for town centers. Um just just highlight we're
20:22
obviously now in the sort of the final week of the hearings for this examination. Um obviously by virtue of
20:29
doing a longer week last week, we have the benefit of a shorter week this week,
20:35
but this week we've got some quite fragmented days where we're kind of covering bits and pieces of kind of
20:41
various various issues. So what I'm intending to do uh to accommodate those
20:47
changes is we will take breaks at convenient points. So when we finished the discussion on one point probably
20:53
have a sort of 10 15 people the table to be re reset. So for example after this discussion we're going to talk about
20:59
design. So we'll have a break set up the table for design and and carry on etc.
21:05
And we've probably got similar um tomorrow morning um as well. I would just like to say for the examination and
21:12
for the session that's being um recorded. I don't think it applies to anybody in the room, but I just wanted
21:17
to flag it up at an early stage. Um, and it may become more of an issue as we go
21:23
forward over the next day and a half. The examination is now seeing a bit of a flurry of lastm minute requests either
21:30
to attend or to submit additional material um and information. The
21:36
examination is governed by various kind of procedures and indeed regulations.
21:43
the town and country planning local plan England regulations 2012. There is a process and a protocol around
21:50
additional evidence and material. I've set out at various points of my guidance notes. I'm not accepting late or
21:58
unsolicited u material. I'm looking at the council but it's not an issue that the council has given me. But I just say
22:04
more widely it is starting to become more of an issue in the last um couple of days. There has to be fairness to
22:12
everybody. uh through this process and late material that is not fair. It's not
22:17
fair to me. It's not fair to the council or to potentially other um participants.
22:23
So my general rulings have been I'm not accepting it uh unless there is something there of either potentially a
22:30
legalistic nature or something I feel needs to be uh needs to be um addressed.
22:36
Hence I allowed the uh the very late legal opinion before Christmas uh
22:42
submitted by Mr. Latimer. Just like to again just remind everybody
22:47
probably sounding very heavy-handed for first thing first session. We will be moving after these hearings to a process
22:53
where there will be proposed changes on the plan. Um there will be a a six week
22:59
consultation and we'll be talking about the arrangements for that. So people will get another opportunity to comment
23:05
where it relates to specific changes. Um but I thought I'd say that now. I may
23:11
have to kind of revisit that as we go forward over the next day and a half. I appreciate we are getting to the last
23:16
stages of the examination hearing process and that may be sort of galvanizing people to think I can just
23:24
submit something now very late. I've just had another thought. I want to put this in. I'm afraid that's not how these
23:30
examination process works. You have plenty of time since the matters issues and questions back in September uh to
23:38
submit addition submit statements. So just flag that up. So the first session
23:45
this morning is in uh relation to uh economic development and town centers.
23:52
It's matter 8. Uh the only statement I have in front of me is from the local authority. So my discussion for this per
23:59
first part of today's uh hearings is solely with the council
24:04
um and I look for their uh for their assistance on a number of points and questions um that have been made as part
24:12
of previous sessions. I'm focusing in on whether there are any potential changes that might to be made. But again, on any
24:20
of the particular policies, there's also, I think, just helpful for me whilst I'm here in the room with council
24:26
um officers potentially understand why a policy has been developed in a particular way or what the evidence was
24:33
that kind of helped um to inform that uh that policy. And we'll be using my
24:38
agenda that's previously been circulated which in turn which in turn um reflects
24:44
back on previously published matter um reflects back on previously published
24:50
matters issues and questions before I invite the council's team to introduce
24:57
themselves. Are there any initial procedural questions or observations that need to be raised? No. Thank you.
25:04
So for the purpose of this recording, if I can turn to my left and invite the council's team to introduce themselves,
25:11
please. So good morning. My name is Paul Sherevian, Kings Council acting for the
25:16
council. Good morning. My name is Matt Clifford.
25:22
I'm a senior planning policy officer. Good morning. I'm Deborah Lamb. I'm the
25:28
operations manager for the spatial plan team at Southside Council.
25:33
Morning everyone. Robin Bullock, public health practitioner within the council's public health team.
25:40
Morning everybody. My name's Ellie Forester. I work in South's public health team as a senior public health
25:46
practitioner. Thank you for that. So if we can turn to
25:52
my agenda and the first issue is around the policies that are going to support a strong and competitive economy.
25:58
Relatively few representations on this. So that may be a reflection that the council is on a sound uh track in terms
26:05
of what it's what it's seeking to do do. Um but I'd like to just pick up first
26:11
item and it's really to start with in relation to policy SP um 17. Obviously
26:16
at stage one we looked at the general amount of employment land required
26:22
uh the available supply and then whether there were the exceptional circumstances in relation to um site SP14 the wardly
26:31
collery site. So, we're not going to re revisit that, but nonetheless, the plan contains both strategic and
26:39
non-strategic policies for um uh sustainable economic development in the burough. Policy SP 17 kind of sets out
26:47
the strategic picture and the port of Tine and obviously port related activity
26:53
is recognized within that policy. As I pick up at my MIQ8.1,
26:59
I asked whether it would be necessary within that policy to make a specific reference to the Tine Dock Enterprise
27:07
Park. I think this reflects on uh representations from on port of Tine.
27:19
Thank you, sir. We don't consider that it's necessary to make a reference to the Tyand do enterprise park
27:26
specifically within the policy given the strategic overall nature of the policy.
27:32
However, we're quite open to um making a
27:38
modification to the supporting text to acknowledge that the port of Ty includes
27:43
Ty do enterprise park and that it benefits from enterprise zone status.
27:50
So we feel that's sufficient to acknowledge um the concern expressed by
27:56
the port of tine the policy SP17 does acknowledge
28:03
port of time port of tine estate is it very specific and focused
28:09
in on the enterprise park are you able to advise me on that
28:15
my understanding is it's focused in on the enterprise
28:23
Thank you. And I see from the council's statement and I appreciate the council has entered into a statement of common
28:29
ground with um port of tine um specifically which has been in the
28:34
examination library um for some time now. In terms of the council's proposed
28:40
um modification to the supporting text,
28:46
um we'll come on to this tomorrow. There's kind of potentially two homes
28:52
for changes. One is those that are genuinely needed for plan soundness and
28:58
those that are more a kind of a factual updating or they don't materially affect
29:04
how the plan is going to be implemented. is the change that's put before me here. When I read it, I felt it instinctively
29:10
was a minor modification. It's not something that's genuinely needed for for plan soundness.
29:16
Would that be the council's position? Yes, that is the council's position.
29:37
And then secondly, as picked up on my MIQ 8.2 policy SP18 in the plan, um sets
29:45
out a portfolio of employment sites. Uh obviously the
29:50
international advanced manufacturing park is not part of that and we discussed at stage one how the plan has
29:56
dealt with um that that crossboundary um strategic sites. But just more
30:03
generally when when I ask at MIQ 8.2 and to give the council an opportunity to speak to this are the sites that are
30:10
identified in that policy justified and consistent um with national policy in
30:16
terms of um being suitable to meet employment needs over the plan period
30:21
please.
30:27
Yes sir. Uh the employment site selection process is set out in the site
30:32
selection topic paper in terms of consistency with national
30:40
policy. Policy SP18 is consistent with MPPPF
30:45
paragraph 11 as it seeks to meet objectively assessed needs and with MPPPF paragraph 20 as it makes provision
30:52
for employment development. It also aligns with the following text which is included in the MPPPF.
30:59
Strategic policies should provide a clear strategy for bringing sufficient land forward and at a sufficient rate to
31:06
address objectively assessed needs over the plan period in line with the presumption in favor of sustainable
31:12
development. This should include planning for and allocating sufficient sites to
31:19
deliver the strategic priorities of the area. And that's MPPPF paragraph 23.
31:26
And the the allocation of land for economic development is consistent with the need to support economic growth and
31:32
productivity as set out in MPPF paragraph 81.
31:37
So I referenced that the employment site selection process is set out in the site
31:43
selection paper. I can if you wish me go through that but it depends whether that would be helpful or not.
31:51
That's that I think at this stage I've got the obviously the reference and the direction to that evidence. So that's
31:56
that's I think helpful or sufficient at at this stage. Thank you Mr. Clifford.
32:03
And just generally as we kind of move forward with the plan, I appreciate the council's not um putting forward
32:11
um at this stage any kind of specific changes to policy SP8, but obviously
32:18
there's a lot of um detail within there in terms of particularly land area land
32:23
area available. Just trying to think strategically around other discussions whether there's
32:30
a need to just before we get to main modifications just sense check that
32:36
those figures remain the figures or am I being um unduly nervous that or anxious
32:43
that there might be potential changes to some of those figures in policy SP8.
32:49
I think a sense check will be sensible. Yes, sir. Okay. Thank you. So, I'll just make a
32:55
note to myself. That's something we'll just need to keep an eye on before we press go on main modifications. Thank
33:02
you.
33:15
Thank you. As I say, there's very little comment or representation uh on these sites. So um very little I think for me
33:22
to discuss is very little I think for me to discuss and say Mr. Clifford I've got
33:28
the site Mr. Clifford got the site selection um process um before me
33:34
in terms of then moving on to policy SP19. So we come back again to the theme
33:40
of port and river um related um development.
33:45
uh and I ask at my MIQ8.3 whether that policy is generally justified and
33:51
effective. Uh I'm imagining this is a kind of a key strand to the economy of
33:56
the burough and obviously um seeking to make the kind of the most of that kind of geographical um
34:04
circumstance to make the kind of the most of that kind of geographical um circumstance.
34:10
And then specifically the policy supports um green technologies within
34:16
within this area and just understand what that what that might um entail. I
34:23
think if I just invite the council to kind of briefly respond to its its answer to my MIQ 8.3.
34:35
Yes, please. Yep. So this was included at the request of
34:41
the port of time. Um they considered defined within the
34:47
supporting text I think to policy SP19 as to what green technologies comprise.
34:57
So the port of Tine um requested the policies extended to cover green
35:03
technologies to encompass a wide range of business sectors and reflect market
35:09
demand. And it's defined at paragraph 9.17 of
35:15
the supporting text. Thank you. And I see from that it's very
35:22
much um towards um the renewable energy um sector. So presumably that is either
35:29
the manufacturer or transportation of kind of turbine
35:35
components or elements at this moment in time. Yes sir. That's correct.
35:53
Thank you. And then just a matter of detail then. So within the wider um port of Tine
36:00
uh area we've referred to earlier this then the specific proposal of the TIN
36:05
dooc enterprise park and I ask at my MIQ 8.4 for whether the wider policy
36:11
strategic policy at SP19 uh also encompasses the time dock
36:18
enterprise park site uh and whether that needs to be reflected on the the policies maps. This is my MIQ um 8.4.
36:30
Yes sir. can confirm that it does uh encompass Tyand do Enterprise Park and
36:38
we have therefore proposed an amendment to the policies map to to clarify that that is the case.
36:51
I see. And it's it's effectively a kind of a finger of land along the sort of the river um frontage
36:58
I think going up to where the new houses are being built. That's correct. It it uh is a finger of
37:06
land as you say which goes up towards where the whole development is taking
37:11
place.
37:20
Thank you again. We'll come on to tomorrow about potential modifications to the policies map and ensuring kind of
37:27
cross reference so people can see uh and understand where these uh potential changes um are being made. And then I
37:35
ask at my MIQ um 8.5 whether it would be necessary for
37:40
soundness to positively allocate or identify uh further
37:46
Riverside land for ports um and related um river related development or whether
37:53
things are going to be primarily focused at the port of tine operations or whether there's kind of flexibility
38:00
elsewhere within the burough for suitable um locations. And I think this
38:06
is something we discussed at stage one when we were looking um at the Roman
38:12
house site in Jarro that was put forward by others as you know an alternative
38:17
housing site. Thank you sir.
38:24
Except as you mentioned for the former Ramen Hite, no other available
38:31
riverside land has been identified through our evidence base. as deliverable for employment purposes.
38:42
The industrial estate of Wagon Way Road has a Riverside location, but it's in
38:48
established general employment use. And the landbound by Priaryy Road and
38:54
Church Bank, which is reference ED.5, has a riverside location,
39:01
but it's safeguarded to allow for importation, processing, and distribution of marine aggregates.
39:09
The allocation of the Roman Hite is for general economic purposes,
39:15
but it does not preclude specialist port and river related uses if they were to come forward. So there's there is that
39:21
flexibility but we felt it was important to give it
39:27
that overall flexibility.
39:35
So to summarize, we we don't feel there are other opportunities for specialist
39:41
port and river related uses elsewhere in the burough that are deliverable.
39:50
Thank you. And just so I can get my bearings, if we go back to policy SP 18,
39:58
is is the Roman house site in there? But by another name.
40:09
Yes sir. Yeah. Yes sir. It is ED.6.
40:25
Thank you.
40:32
And then finally in sort of uh river related matter or employment and river related
40:39
matters asked on my MIQ 8.6 six. I think this has come from Historic England.
40:45
uh and site E35 which I think is within the wider area
40:50
covered by policy SP19 whether there needed to be further detail within policy SP19 whether
41:00
um other policies of the plan uh would satisfactoryy deal with I think
41:07
this is principally an issue around the setting of various kind of heritage assets if the council want to say anything further in relation to MIQ 8.6.
41:18
Thank you, sir. Development on E35 has the potential to result in less than
41:24
substantial harm to the setting of the heritage assets identified in the heritage impact assessment.
41:32
However, the local plan policies, particularly those relating to heritage, design and landscaping,
41:38
will ensure that development on the site is delivered in a manner that minimizes
41:44
and mitigates harm to the historic environment. So, we feel that we have the policy framework to deal with that
41:52
issue. Thank you. And I note you've entered into a statement of common ground with
41:59
Historic England as say that at paragraph 817 of your um your matter
42:07
eight statement to that that effect. So that's that's noted.
42:13
And then in terms of um having sort of positively identified
42:19
sort of areas for economic development through um those kind of three um
42:25
strategic policies kind of the other side of the other part of the equation is to then kind of protect
42:32
uh employment areas um where they serve um a particular
42:37
uh function in a need and that's obviously done through policy um 22 um obviously various ious um
42:46
matters, issues, questions relate to this um this policy. Um
42:53
I'll start with MIQ 8.7 as this kind of straddles what we've been discussing
42:58
around the port and then protecting existing employment uses. So whether it would be necessary for soundness I think
43:05
to include further detail within policy 22 um around the port of Tine and
43:12
specific kind of protection measures. I think invite the council to speak to its
43:17
response to MIQ 8.7 please. We don't think it would be appropriate
43:23
to include further detail in policy 22 specific to the port of Tine.
43:30
Policy two is a a buroughwide policy and
43:36
the port of Tine already has a very high innate degree of protection and that
43:43
they're the owner of the estate as well. Um
43:48
so we're not uh we don't believe that um policy 22 requires amendment
43:56
um specific to the port of time. They already have a very high degree of
44:02
protection and control uh over proposals for alternative uses
44:07
should they wish to resist them. So
44:13
as a state policy 22 is is a burough wide policy. It would strike me as in congruous to to flex it to have a
44:20
specific reference to the port of time.
44:26
Thank you. Um and then more generally as you say Mr. Clifford policy 22 is a is a
44:32
buroughwide um policy um obviously reflecting or
44:38
drawing on the evidence from the employment land review uh and other sources.
44:44
Uh ask at my MIQ 8.8 eight, whether part two of the policy
44:50
is consistent with national um national policy at paragraph 82 and it's probably
44:56
subp part D of that par that paragraph in terms of kind of flexibility and thinking about kind of employment needs
45:04
going forward. So the first first part of the policy I think is recognized and um understood from the
45:11
employment and evidence. So, where a site comes forward um within one of the
45:18
allocated employment areas, it's got to go through a 12 month marketing period if it wants to come out of employment
45:23
use terms of the second part of the policy. Um what is the council um seeking
45:31
through this? Is it additional material or evidence that the existing use is not
45:37
viable? So, it's a separate kind of vi would it be a viability
45:43
um assessment or perhaps a more judgmental kind of
45:49
appraisal of whether the business and and the unit is is kind of viable as a
45:54
going concern and what what potentially would be
46:01
sought further than the 12-month marketing exercise.
46:09
Sir, can I come back to you on specifically what we would think in that situation?
46:22
Yep.
46:58
It is intended actually to um go further than criterion one in the
47:07
sense that criterion one will be factual evidence of marketing and no interest.
47:15
But of course that marketing um exercise has to be undertaken. But
47:22
the lack of success of that marketing enterprise might be because of other
47:27
factors. For example, an owner allowing a site to fall into disrepair or decay
47:34
for example. um and there may be other issues affecting viability
47:42
uh for particular employment uses but not others. So what it does is is expand
47:48
the list of qualitative factors that may be taken into account
47:53
without specifying what they are because of course one can't anticipate them all.
48:01
I'll reflect on whether we're into main modification territory versus something
48:06
that kind of assists the implementation of the plan, but is this an area where some further supporting text could just
48:14
aid future users of the document? I think that would help actually um because you've raised an issue
48:22
um from your reading of the policy and what we want to do is to um explain how
48:27
paragraph how criteria one and two work.
48:32
So I think that will be helpful.
48:50
And then finally from the council on policy 22. Um I think this is an issue
48:56
that's been raised. Uh again I think it's port of time but it is a perhaps a more widespread sort
49:03
of buroughwide issue um in terms of the agent of change principle that's reflected in the national planning
49:10
policy framework. Obviously there are legitimate uh employment uses out there
49:16
uh and ensuring that they are protected or safeguarded
49:21
uh in terms of what they're doing from sort of potential changes particularly on existing employment areas and
49:26
ensuring that something doesn't kind of come forward in that area that's then going to um harm the viability of other
49:34
lawful businesses.
49:39
Thank you, sir. The agent of change principle uh paragraph 187 of the MPPF
49:45
states existing businesses and facilities should not have unre reasonable restrictions placed on them
49:51
as a result of development permitted after they were established. The council is fully supportive of this
49:57
principle as it wishes to support existing businesses as well as
50:03
facilitate new investment. Part four therefore seeks to provide this balance by supporting changes of
50:11
use within allocated employment areas where the applicant has clearly demonstrated that quote the operation
50:19
would not prejudice the operate operation of neighboring properties and businesses. So we feel it strikes a
50:26
appropriate balance.
50:32
I hadn't raised on my agenda MIQ 8.10. And this is the issue of um obviously
50:39
the plan when looking more widely at the economy of the burough is looking at
50:44
kind of leisure and tourism um as understandably a key aspect of the of
50:52
the local economy. Um and part three of the policy is encouraging I think more
50:57
water-based recreation and leisure. um particularly on the river Tine. Obviously been
51:04
discussing significance of the port of Tine um to the local economy and whether
51:10
there was a a potential issue or conflict between encouraging more um leisure or
51:18
recreational use in a commercial um shipping channel. I don't have any
51:25
sort of further questions on that. I don't know the council just before we
51:30
move off kind of economy whe there's anything further the council wish to say in relation to um MIQ 8.10.
51:40
No sir I think we've we've set everything out in our response to MIQ 8.10. Thank you.
51:57
Thank you. And presumably there are people bodies out there who would advise the council if there was an issue in
52:04
relation to the safe operation of the river. Um I don't know
52:11
if there I think harbor commissioners or people like that who are kind of be able
52:16
to feed into the the development management process.
52:25
I would assume this issue may have come up in relation to the whole development. Um so I'd assume that there are bodies
52:32
who can advise port of time.
52:44
Thank you. And before I move on to retail, I'm going to sound like a news readader and say, and finally,
52:51
um, the council produced a very helpful, um,
52:56
I'm afraid we're going off, we're going off pie. It's not on my agenda, but the council produced a very helpful associated uh, matters update paper at
53:04
the end of October. Um, it's document post sub43
53:09
in the examination library. Now we mentioned the international advanced managing international advanced
53:17
manufacturing part. We looked at that part of stage one had you how the plan
53:22
has has dealt with this issue bearing in mind that's an area covered by its own um air action plan understand the
53:29
council's approach to employment land has been through this plan to kind of look to complement and support what is
53:36
going on uh on that crossboundary um location but not necessarily to directly
53:41
kind of compete with it or positively allocate further land that would kind of
53:46
replicate or um uh seek to to um
53:52
what's sought to be achieved at that um location. The council's paper refers to
53:58
obviously the council's had a through its local development scheme uh an objective to kind of update and review
54:05
the area action plan. And through that um update paper, there was a reference to whether that's now necessarily going
54:12
to go forward. Not entirely clear what bearing that may have for this plan
54:18
given obviously the will there is an adopted air action plan for the I I'm going to slip back into the uh acronyms
54:26
for the IMP um or whether it's it's something for information at for my purposes at this
54:33
stage um and it will be a matter that will feed into um plan review which
54:39
we'll again touch on tomorrow is it Mrs. them. Uh yes that's right. So in the update
54:45
update paper we uh set out that um of ZA council along with Sunland were sort of
54:51
progressing amp AAP uh a new document um for that area um as set out in the paper
54:58
and progress on that uh review has paused um at this point and that still remains the case as it is. Um I think in
55:06
terms of how that affects um our local plan um I don't think it has any impacts. I think we set out quite
55:12
clearly at stage one where there was discussions about the relationship between the IMP and the AAP and the
55:17
policies in the plan and we set out that there wasn't a a connection. We have before some um additional um supporting
55:24
text which sort of sets out that relationship more clearly. Um but I think I am um going forward will be
55:30
something for future plan reviews um for probably for both authorities but I say
55:36
it's fair to say there's a degree of flux in terms of plan making at the moment. So, it's um yeah, we'll we'll see how things progress on that.
55:43
Can I just ask the council if things do change or progress while we're still in examination? So, before I potentially
55:50
issue a a report to the council, can I just um request that the council just factually update me if if a decision is
55:57
made and something is changing and um you know, just in case I've made a kind of a reference to there will be a future
56:04
review and maybe that's not the case, I think it' be helpful to kind of be just
56:09
be made aware of that if something does does change. Yeah. Yeah. Okay. I've got nothing further on issue
56:16
one on the economy. So, thank you uh to Mr. Clifford for answering all those uh
56:22
questions. I'm now going to move on to issue two uh ensuring the vitality uh of
56:29
centers uh and probably reflect with a slight tear in my eye to retail used to be such
56:37
a big part of plan making and develop and planning appeals and it's obviously
56:42
the landscape is changing and we um but nonetheless very important that the plan
56:50
uh has an effective policy framework work around ensuring the vitality of centers within the burough. That's a
56:56
requirement of national planning policy. uh and I asked at my MIQ um 811 around
57:03
policy SP20 which sets out a hierarchy of centers and I think looking at the
57:09
evidence um I understand and follow through um that that's a sort of um
57:15
seems a fairly logical um approach but ask my MIQ 8.11 representation or a
57:23
representation has been submitted that the C winnings
57:28
way which I'm going to describe as in Westo but people may have a different uh geographical interpretation should be a
57:36
local center and whether it would be necessary for soundness to add it to criterion three of policy 20 please
57:45
thank you sir sewinnings way at westto crown village
57:53
um has been identified as a local neighborhood hub rather than a local
57:59
center and we consider that to be justified. The local centers and neighborhood
58:05
centers assessment concluded that Seaw Winnings Way meets the definition of a local neighborhood
58:12
hub being a small parade of purely local significance. So we don't feel it has
58:20
sufficient significance to be classified as a local center.
58:25
That's based on the assessment work that was undertaken for that study.
58:37
Thank you. Thank you for that. And in terms of my MIQ 8.12 just more widely
58:44
um as say the landscape on kind of retail um demand is is changing but is
58:50
the policy framework and we're looking here specifically at the strategic policy SP20 and then the council's kind
58:57
of work through a number of non-strategic policies 26 27 and 28 um
59:05
is that sort of framework justified in terms of the evidence evidence that supports um the plan.
59:16
Sorry. Yes, sir. the evidence it's based on the stage one town and district local
59:23
census study and um
59:31
the hierarchy that's set out in limbs one two and
59:36
three of the policy was directly informed by the town district and local
59:41
centers study the study confirmed the three tier hierarchy for South Tinside side.
59:48
So we consider that's clearly evidence-based and
59:56
reflects the existing situation um
1:00:03
which was reviewed by the consultants and they confirm that that hierarchy maintains the val
1:00:11
is still the valid hierarchy for Southside.
1:00:20
Thank you. And then just a further reflection on policy 26
1:00:26
around the vitality and viability in in the kind of the three hierarchies. Part two of the policy at criterion 4
1:00:34
the council seeking to kind of look at and um carefully manage where clusters
1:00:40
of uses arise. You see that at uh part two of policy 26
1:00:47
subp part 4. Does the council have in mind what kind of uses
1:00:54
or cluster of uses it might might be thinking of in terms of this part of the policy and often come across other
1:01:02
authorities where they're thinking about things like hot food um takeaways or they might be thinking about betting
1:01:08
shops with the does the evidence kind of refer to kind of particular clusters that
1:01:15
policy should should be managing
1:01:22
So I think it's the experience of the authority that clusters such as the kind
1:01:28
of uses you describe um are not necessarily conducive to the
1:01:34
vitality of the center. Uh obviously a balanced approach has to be taken because
1:01:40
um there is less utility in national
1:01:46
planning policy. know to control uses. Um but those are the kind of uses which we
1:01:54
would probably seek to avoid a cluster of
1:02:08
thank you. Yeah, I think I just wonder if similar to when we were looking at um policy 22, I reflect on an area this is
1:02:14
a part of the plan where there might be some a benefit of some further supporting text to kind of aid
1:02:22
uh users of the document again in terms of what that might might mean or refer to.
1:02:28
Yeah. Okay. And then just very briefly on policy 28,
1:02:35
obviously the national planning policy framework has a kind of default national kind of threshold for impact assessment
1:02:41
at 2 and a half thousand square meters gross. Obviously this is a plan that's proposing a lower kind of local um
1:02:49
threshold. I don't think I'm aware of any soundness concerns that have been
1:02:55
been raised on that, but presumably that is evidenced by the uh the latest retail
1:03:01
evidence underpinning the plan. Mr. Clifford. Yes, sir. It directly reflects uh the
1:03:07
evidence underpinning the plan, the retail study. Thank you. And obviously national MPPPF
1:03:15
paragraph 90 um obviously allows allows excuse me allows for that.
1:03:21
And in terms of the need for additional retail amount the main town center uses over over the plan period this is my MIQ
1:03:29
8.3. Uh what what is the evidence? I think
1:03:34
it's Thank you sir. The plan does not
1:03:40
identify any additional retail or commercial leisure floor space floor space that would require the allocation
1:03:46
of additional sites. The retail study does not identify any
1:03:52
surplus capacity which could support additional convenience or comparison goods floor space within the short,
1:03:59
medium and longer term. The retail study did not anticipate there would be any operator demand to
1:04:05
bring forward large format leisure uses over the plan period. The study identified a requirement for
1:04:12
900 square meter of food and beverage floor space which it anticipated will
1:04:18
comprise relatively small scale cafes, restaurants and bars which would generally be accommodated within the
1:04:25
three principal centers and to a lesser extent the district centers.
1:04:31
The study recommended that this requirement is met through the reuse and repurposing
1:04:37
of vacant floor space which is consistent with point one of policy 26.
1:04:43
So to summarize, we don't feel we've got evidence for additional um sites.
1:04:54
Thank you. And I think of looking back I think the only um sort of
1:05:00
additional provision I think the plan is making is a policy SP8 at Felgate where
1:05:06
as part of that development the policy is currently drafted and I'll I'll wait to see how the council
1:05:13
potentially wants to kind of look again at that policy does envisage a local center as part of that 1,200 home
1:05:20
development. That would be the only kind of new excuse me kind of retail
1:05:27
or yes retail sort of community sort of center within the plan.
1:05:32
Yes sir. That's correct. Yeah.
1:05:42
Thank you. And now finally move on to hot food takeaways. uh and it's my MIQ 8:15. So policy 32
1:05:53
seeks to address this issue through the plan um through a number of um mechanisms um
1:06:02
a fairly frequent policy to be found in local plans. Obviously the planning practice guidance um kind of allows a
1:06:10
national policy allows for this where evidenced and kind of justified. Suppose if I invite the council in the first
1:06:16
instance to kind of just perhaps briefly kind of set the scene to why uh a policy
1:06:22
on hot food takeaways is needed in a in a South T side context.
1:06:34
Thank you. So just to give an overview from a health perspective um we have
1:06:40
identified childhood obesity within our health and well-being strategy as one of our key priorities and the reason for
1:06:47
that is because we have a program a national program called the national child measurement program which weighs
1:06:54
and measures children in reception and year six every year and that is a database that we monitor on a yearly
1:07:01
basis and just to give an overview of our position in South Tinside. Our year
1:07:08
six obesity prevalence is um significantly higher than the England
1:07:13
average and the regional average and we are actually based on the most recent
1:07:18
2425 release, the highest in the region for year six obesity prevalence. So the
1:07:25
um hot food takeaway policy therefore seeks to address that by limiting the
1:07:30
number of hot food takeaways. And the reason for that is because we know that the environment does impact on obesity
1:07:38
within the area. And what I would say from a health perspective is that the hot food takeaway is one intervention as
1:07:45
part of a wider suite of interventions which look to work simultaneously to
1:07:50
address obesity in the local area. Thank you.
1:08:02
Thank you. It was a long It's been a long time since I was in school. Year six. What does that mean to an old fddy
1:08:10
duddy like me? 10 to 11 years old. So that's starting high school.
1:08:17
Yes. Yeah.
1:08:25
And in terms of the the policy and how it's kind of um intended to to work. So
1:08:33
as say come across this type of policy um fairly frequently now and um as
1:08:40
you're saying if the evidence is around particularly that kind of high start of high school kind of age cohort is where
1:08:47
um the issue is being uh particularly identified um you set out in the policy in terms of
1:08:54
the 400 meter uh radius from secondary school um entry points. So um and that's
1:09:02
mapped in the local plan um itself. So obviously the various kind of large
1:09:09
parts of the burough that wouldn't be um affected by by that criterion.
1:09:17
The other part of the policy refers to where uh it would be an award where
1:09:22
levels of obesity in year six pupils is over 10% and then the council helpfully sets out in the statement I think a bar
1:09:29
chart. I'm assuming that is covering is a figure two I think of the statement
1:09:35
and I'm assuming they are all the wards in South Tinside.
1:09:40
Yes, that's right.
1:09:49
And then if I look at that um
1:09:55
bar chart. So all the wards are over 10%. Yes, that's right. So that's based on
1:10:01
the 23 24 data. We have just received the 2425 data but we don't have the ward
1:10:07
breakdown yet. Um but we can provide that once we've got that. But yes, all over 10%.
1:10:14
So as things currently stand on the evidence through that policy me there would be no further
1:10:21
hot food takeaways. That's right. So we would intend to
1:10:26
respond to all hot food takeaway applications because obviously the 10% threshold would be met.
1:10:38
Obviously it won't affect existing uses. they're there, they're they're safe, they can continue to operate. Uh just in
1:10:45
terms of kind of the reasonleness or the justification around the 10% figure
1:10:51
being in mind what it could potentially mean, I appreciate monitoring might change those that scenario. Um
1:11:00
how's how's the 10% figure been arrived at again? Is that is that justified?
1:11:08
So the 10% figure um is sort of a following forward of the the SPD that we
1:11:13
currently have which was adopted in 2017. Um so that was produced um based
1:11:19
on the evidence that was available at the time then and also follows um the the Gates Head um hot food takeaway SPD
1:11:26
which also implemented a 10%. sort of consistency reasons in terms of the the local area we also adopted that 10% um
1:11:34
threshold which like I say has been followed forward into into this policy at this point
1:11:40
and are you able to advise Mrs. Now in terms of that 10% figure, have you had
1:11:46
that tested through the development management process? Has that been
1:11:54
scrutinized, supported? Yes. So the SPD has been used um since
1:12:00
it was adopted in terms of determining plan applications for health food takeaways. Um I do have a little number
1:12:06
here of the number of um applications which have been um
1:12:12
refused um since that was adopted. So in total since 2017 we've had 29
1:12:18
applications that are um hot food takeaways. Um 10 of which were refused um 11 with with withdrawn and eight were
1:12:26
granted plan permission. um that was those that were granted plan permission were either in areas where in the LDF
1:12:32
there was a policy which identified A5 uses as being suitable in that location. So obviously the SPD couldn't trump
1:12:39
that. So it was a it was an acceptable use um through that. Others have been
1:12:44
sort of associated with mixed use um proposals um so it could be a restaurant with a hot food takeaway element where
1:12:50
it's been ancillary to that. So it's it's been um approved and others have been sort associated with lawful
1:12:55
development certificates as well. So the the SPD has been um has been used
1:13:01
through the DM process. Um but I say there has been occasions where those
1:13:06
users have been granted planned permission as well.
1:13:12
Thank you. So, if a hot food takeaway proposal passes through a high bar of um
1:13:19
being in a a ward area where it's not there isn't the 10% of year six
1:13:25
um uh pupils who are identified as obese. Um it's in a um suitable location
1:13:35
I think beyond 400 meters from a secondary school entrance.
1:13:41
it will then have to go through other um criteria. Uh so criterion two
1:13:48
um says they'll be assessed in terms of their impact on the vitality and viability of the shopping center or the
1:13:55
center where it will be located. I just wonder whether that's invite the
1:14:00
council as to whether that's justified. Obviously, restaurants, drive-th through restaurants, a main town center uses the
1:14:07
council have a view in terms of hot food, why hot food takeaways would have to go through this extra.
1:14:15
Yes. So, it sort of touches on what we've been speaking about in terms of clustering and sort of the negative effects that these sort of uses could um
1:14:24
end up causing in in town centers and in shopping um districts across the burough. So that's really what those
1:14:30
limbs of the policy are there to um to manage. So if um an an application does
1:14:36
say pass through um the earlier limbs of the policy that would then start to look at the the impacts on vitality and
1:14:43
viability of the areas and also we've got um sort of the meany aspects as well which is set out in um criterion four of
1:14:50
the policy. And then in terms of criterion three of
1:14:56
the policy, there's obviously some specific factors there and it's um kind of got echoes back to when we were
1:15:02
talking about houses of multiple occupation in terms of number of unit uh number of uses within a particular
1:15:08
uh area or frontage. is that again has that been drawn through from the SPD and
1:15:16
now embedded in development plan policy just to understand how some of those
1:15:23
uh criterion in part three of the policy have been been developed. Um they've been um drawn on from the
1:15:30
existing DM3 policy which is in our development management um DPD at the moment.
1:15:57
Thank you. And if I was just kind of come away from this session with kind of thoughts in my mind or reservations in
1:16:03
my mind about kind of the uh the justification for parts of this
1:16:08
policy and whether it was being sort of too stringent on um hot food takeaways.
1:16:13
What the council's is there anything the council would say in terms of
1:16:18
for one of a better phrase you know watering down of the policy what the potential kind of adverse impacts of
1:16:24
that could be for South Tinside is it is the issue I think as I was told earlier you know you are the re regionally the
1:16:31
highest for this year group. Yes. So I think um when we look at our
1:16:39
childhood, excuse me, when we look at our childhood obesity figures, they have
1:16:44
been increasing year on year and I think our concerns if the policy was watered
1:16:50
down would be that we would continue to see an increase in those obesity figures
1:16:56
and um we are very clear that the policy itself isn't going to solve childhood obesity, but actually we need to look at
1:17:03
it as part of our whole systems approach to obesity in which that would form part of um our approach within public health.
1:17:14
I know are you able to just briefly advise or just to tell me what some of these kind of other when you say it's a
1:17:20
whole systems approach and you mentioned earlier it's this policy is one intervention of several
1:17:26
um and I think the planning practice guidance refers to kind of looking holistically at what's what's being um
1:17:31
being done what kind of other measures that are being looked at that this
1:17:37
policy would fit into and and complement is yeah absolutely so when we talk about a
1:17:42
whole systems approach. We look at everything from the environment. So that would cover the likes of hot food
1:17:48
takeaways, unhealthy advertising, etc. to the individual themselves. So looking
1:17:54
at um physical activity both from an environmental perspective as well as trying to encourage people to make
1:18:00
better choices around their health, physical activity. We also have a large
1:18:06
body of work happening around sustainable food. So trying to um improve the actu food within South China
1:18:12
side. Um but also we look at um cooking demonstration classes to equip residents
1:18:19
with the skills to be able to cook sustainable and healthy food. Um there's
1:18:24
a whole body of interventions that form part of that kind of wider system working. Thank you.
1:18:38
Thank you. And just finally on an operational front, obviously the council will have its local plan in terms of um
1:18:45
managing and guiding development. Obviously here got two colleagues this morning from public. So the council
1:18:50
itself has the direct kind of public health role and responsibility in terms
1:18:56
of implementing some of these things that you've referred to. Yep. Yeah. So as a public health team, we
1:19:02
would facilitate that whole systems approach. Um but obviously we rely on a number of our partners to support us
1:19:09
with that because it is a massive agenda and um does require a multi- agency
1:19:15
approach.
1:19:24
Thank you. I've got no further questions on hot food takeaways. So I think that brings matter 8 um to its conclusion.
1:19:33
Thank you for that. What I'm going to suggest now just before I move off from is there anything further from the council that it wanted to raise in
1:19:40
relation to matter 8? No. Thank you. Okay. It's just gone 11:00. Uh the next
1:19:45
item uh for this morning it's just gone 11:00. Uh the next item uh for this
1:19:51
morning we're going to jump to uh for this morning we're going to jump to matter nine. And it's
1:19:58
specific issue of design. Uh it's just gone 11 o'clock. I'd like to be back in this room at quarter. Just check with
1:20:04
the net. It's quart 11. Yep. Quarter. Uh I'll have a break and then we'll resume the discussion. Thank
1:20:11
you.
1:33:51
Okay, it's just gone quarter past 11, so it's time for me to uh start this uh
1:33:56
hearing session into the examination of the South Tinside local plan. Um
1:34:02
I won't introduce myself. I think looking around the table and from various hearing sessions most people will know now who who I am. Um we are
1:34:10
here for discussion on it's part of the wider matter nine agenda but it's specifically issue four and it's
1:34:16
relating to um matters of design and the design policy policy for the uh for the
1:34:23
burough. Um again just ask people to ensure that mobile phones are switched off or on
1:34:30
their silent settings please. As indicated previously these sessions are being recorded so people can use their
1:34:36
microphones when making submissions that'll be helpful people in the room and also to kind of uh those who are
1:34:43
watching um the recordings. Does anybody wish to make their own or separate
1:34:48
recording of this discussion? No. In which case if I can start on my
1:34:55
left with the council to just uh introduce who would be speaking for this subject please.
1:35:01
So good morning my name is Paul Sherevian Casey acting for the council.
1:35:07
Rachel Cooper senior plan and policy officer at South Tai Council.
1:35:12
Rian Lavick and I'm one of the planning policy officers at South Tai Council.
1:35:18
Andrew in senior manager for planning at the council. Chris Martin, Homebuilders Federation
1:35:25
representative body of the house builders in England and Wales.
1:35:30
Mark Murphy from Pegasus Group representing Bellway Homes.
1:35:35
Morning everyone. Joe Thompson um on behalf of East Balden Neighborhood Forum.
1:35:41
Uh good morning. Mvin Butler, Clean East Balden Labor Party.
1:35:47
Thank you. Now, we're going to work through an agenda that's previously been um circulated for uh matter 9 issue 4.
1:35:54
We're looking at uh mainly policy 47. Uh in terms of the design principles,
1:36:00
it's quite a long policy, but it is probably reflective of the significance
1:36:05
of securing highquality design as part of the planning system. Now, I hadn't as
1:36:11
part of my agenda referred to there are two further MIQs that I'd published. One
1:36:17
was in relation to treeline streets and another was in relation to local design
1:36:22
guides. I am going to allow discussion on those but we'll deal with those two points after we've gone through
1:36:30
uh the three items that I had on my um my agenda and we'll we'll link back to
1:36:35
those um those MIQs at that that after we've yeah at the end of the
1:36:41
discussion. So if I can turn first then to um
1:36:48
uh the it the issues that I've identified really is a reflection of what's been uh raised as soundness
1:36:54
concerns through the various representations and the first area I wanted to um explore reflected in my MIQ
1:37:02
921 was about um the effectiveness of the
1:37:07
policy um when it refers to uh I think it's in part Six of the policy when
1:37:14
looking at homes and buildings that it would provide uh envir good quality internal environments with adequate
1:37:21
space for users and whether what adequate space meant
1:37:26
and whether it was meaning um
1:37:31
one of the optional technical standards in terms of the nationally described space standards. So perhaps I can turn
1:37:38
to the council in the first instance to kind of just explain uh what part six of that of the
1:37:45
policy is seeking to achieve please. Yeah. So the plan and that specific
1:37:50
policy don't have a specific requirement in terms of nationally described space standards. The plan elsewhere does have
1:37:57
a range of policies which seek to achieve good design and provide a mix of housing types and sizes. In terms of the
1:38:04
sort of ambiguity around that part of the policy, we have proposed a modification to the supporting text um
1:38:11
under question 9.21 in the hearing statement and that just intends to
1:38:17
provide a little bit of clarification around what we mean in terms of internal space.
1:38:37
Thank you. And in terms of that modification that's been put forward, if others haven't had the opportunity to to
1:38:44
refer to it, uh it's not prescribing the nationally described space standards,
1:38:50
but it's signposting people to that they exist and regard should be had to them.
1:38:59
Yeah, that's correct. And the council considers that other policies within the plan such as policy 21 and the design
1:39:05
policies have an impact on internal floor space and obviously regard should be had to them as well.
1:39:17
Thank you. So if ultimately a scheme comes forward that's a slight variance to the nationally described space
1:39:23
standards but would otherwise in the council's judgment provide for an adequate
1:39:30
uh space for users. It would satisfy the requirements of the policy flexibility.
1:39:37
Yeah that's correct.
1:39:52
And just very briefly in terms of what's been happening in um South Tinside and
1:40:00
through monitoring even if the policy didn't require u
1:40:07
nationally described space standards and which just for the benefit of the room I guess most most people are aware of they are optional techn technical standards.
1:40:13
So they're not mandatory. They're not something councils have to introduce. But nonetheless,
1:40:20
if one was concerned more widely about this issue, should should we be or is
1:40:25
actually what's happening on the ground pretty close to stand the space standards in in any
1:40:32
event? Um yes. So, as part of the hearing statements, we did a a review of some
1:40:39
recently um permitted developments um and it found that there wasn't a
1:40:46
significant variance from NDSS in terms of what has been permitted and what is being developed on the ground.
1:40:57
Thank you. Before I bring in others, if I can turn to I'm going to call you the development sector or representatives
1:41:04
for the wider development sector. When I look at the council's evidence and monitoring and it's revealing that there
1:41:09
isn't a significant variance from the nationally described space standards, I'm fairly clear, Mr. Martin and from
1:41:16
Mr. Murphy. I think your position is there's no need for soundness reasons to introduce a specific requirement to meet
1:41:24
this standard. is what I'm seeing in terms of the council's evidence a reflection that the
1:41:30
sector and the market has products that meet this in any event because some
1:41:36
authorities do seek nationally described space standards. I'm presuming as house
1:41:42
builders don't want will have certain kind of products that
1:41:48
are going to meet whether if that applies I don't know not going to say Gates had ever introduce it but you know just more locally or regionally if other
1:41:55
authorities have that kind of product sorry policy requirement
1:42:01
thank you sir yeah if I may may come in um I think it there's a you know as a as
1:42:08
a as a body we represent wide variety of of house builders. Um, as as I've
1:42:14
mentioned previously, sort of the large PLC's and the smaller and medium uh sized house builders and they all have
1:42:20
slightly different models as to how they how they work. Uh, so whilst there might
1:42:27
well be a lot of house builders that that only offer sort of NDSS
1:42:32
type house types, there will be other house builders which do not. and it's usually driven by their business model
1:42:39
and how they they operate. The reason why um a house builder may not want to
1:42:46
go with NDSS is simply it's about choice. It's about affordability as
1:42:51
well. So in areas where there is affordability issues, if you're requiring NDSS, inevitably that means
1:42:59
the houses tend to be a bit more expensive because they are a bit larger.
1:43:04
The issue sometimes our members have come across is if you're in an area of where the affordability is an issue, you
1:43:11
may well have a family who uh are wanting a three or a fourbedroom house,
1:43:16
but in that area and as a result of the NDSS, they might only be able to afford a twobedroom house. then that creates an
1:43:24
issue potentially of overcrowding within houses which then sort of is the
1:43:29
antithesis of what NDSS is trying to achieve in the first place. So some of
1:43:35
our members have NDSS house types but they also have non NDSS house types in it. It just very much depends on the
1:43:42
market that they're they're aiming for in in this case. Uh if I may sort of add
1:43:48
to add to that um I'm happy that the council have clarified that in this case
1:43:55
there would not be a requirement for NDSS. Obviously, there's the PPG and the tests in the PPG that would need to go
1:44:02
through to um justify a move towards NDSS that I haven't seen in the council's
1:44:09
evidence base and they obviously acknowledge it in a hearing statement that the evidence isn't there because it's not just saying X amount of houses
1:44:17
have been built to NDSS standards or not NDSS standards. It's to do with the
1:44:22
outcomes of that as well. So, are the people moving into those non-NDSS
1:44:28
houses? Are they happy with the size of those houses? You know, usually there's
1:44:33
a bit of research there as to what the outcomes are. Um, it's not good enough in my view just to say, well, houses
1:44:39
haven't been built to NDSS, therefore NDSS is needed because they might be suitable for the needs of those people who are living there. Um,
1:44:48
where I potentially differ from the council's view and what's in a hearing statement is I think
1:44:55
putting something in like having regard to NDSS, the danger with that is it muddies the waters a little bit and
1:45:02
it would be then I can foresee instances potentially where development management
1:45:08
officers might have different interpretations of what has regard to means. uh and you know you have this
1:45:15
often when you have policies like that which aren't definitive you may get some DM officers who will want to um have
1:45:23
that you know apply that rigorously you might have others who might take a bit more relaxed view so it's to do with the effectiveness of putting that in I think
1:45:30
either you go for NDSS or you don't and I think the policy at the moment is a bit of a a bit of a a muddle and could
1:45:37
muddy the waters um that's just my comment on that on that on that uh
1:45:43
change. Thank you. Thank you for that. As indicated
1:45:49
earlier, I was quite clear from the statements and representations the view from the homebuilders federation in
1:45:55
terms of not needing to go down the the route of nationally described space standards. Mr. Murphy from um Belway's
1:46:03
perspective would mainly going to be reading the point of Mr. Martin um in terms of there are
1:46:10
going to be instances where it's appropriate not to um prescribe NDSS standards be incorporated within um
1:46:16
house types. Um, and also I would also
1:46:21
voice echo my concerns about including that supporting text within the policy just because you might be trying to
1:46:27
secure NDSS by the back door in the fact that they might when it comes to the planning application stage if they're
1:46:34
having regard to NDSS standards then they might actually as Mr. Martin states
1:46:39
actually strictly apply those standards as part of um the processing of applications. Thank you.
1:46:58
Thank you. And on the other side of the equation, I have the representations from East Balden. Um, so I hear first
1:47:04
from Mr. Thompson at the forum and then from Mr. Butler. And I think Mr. Thompson, from your organization's
1:47:10
perspective, you're going to refer me to Cleonen Lane as a practical
1:47:16
example of why nationally described space standards should be a a policy requirement.
1:47:23
Yes, thank you sir. Um we have submitted now a detailed response to your question
1:47:30
an appendix which sets out that evidence that you mention. I'd just like to talk about three main
1:47:38
points um with regard this