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A
B
The
examination
there's
no
programmed
fire
alarm
test.
So
if
the
alarm
does
sound,
please
make
your
way
to
the
nearest
exit
and
gather
on
the
corner
of
Claremont
Terrace,
which
is
outside
the
GMB
building,
which
is
just
here
left
as
you
go
up.
The
main
dares
do
not
stop
to
retrieve
any
belongings
but
exit
the
building
as
quickly
and
safe
as
possible
following
the
green
exit
rules
and
do
not
enter
the
building
until
a
fire
marshal
Our.
Member
of
the
fiber
grade
tells
you
it's
safe
to
do
so.
B
The
toilets
are
situated
on
the
ground
floor
just
down
at
the
back
of
that
Corridor
drinking
water
is
available
on
the
tables,
but
for
people
in
the
public
area
sitting
out
upstairs
and
this
whilst
available
in
the
fire.
All
the
refreshments
that
are
available
from
coffee
shops
and
places
to
eat
on
Julie
gate
there's
also
a
Sainsbury's
Express
on
both
of
them
and
also
others
in
our
test,
scores
just
down
the
road
on
Julie
gate,
but
the
dogs
have
a
coffee
machine,
also
filming
the
proceedings
are
being
filmed.
B
So
if
anybody
has
any
issues
about
being
on
camera,
if
you,
let
me
know,
I'll
put
you
in
a
location
that
you're
not
picked
up
on
on
camera,
Wi-Fi,
Citadel,
guest
and
password
is
General,
Booth,
1883
and
those
are
written
on
the
posters
outside
of
the
building.
Along
with
my
contact
details,
thank
you.
A
A
Thank
you
very
much
all
good
morning
and
welcome
to
the
last
day
of
the
scheduled
hearings
for
phase
four
I.
Don't
think
that
I
probably
need
to
explain
to
anybody
and
unless
you,
unless
you
ask
any
questions
about
the
kind
of
procedure
that
we'll
be
using
today,
but
just
just
in
case,
you
know
if
you
do
want
to
come
into
the
discussion
at
any
point,
please
append
your
your
name.
Plate
and
I
will
bring
you
in.
C
C
It
is
only
that
first
first
paragraph
or
a
numeral
one,
and
that
is
an
update
in
Mass,
so
given
given
local
circumstances
and
how
matters
have
moved
on-
and
we've
talked
about
all
of
this
since,
since
this
policy
was
first
drafted,
I,
don't
think
I
need
to
say
any
more
about
that.
No
I
think
that's
everything
from
us
on
DB1,
so
it'll
take
the
vesters
red.
A
C
Funny
so
db2
is
slightly
more
extensive
and
its
revisions
are
low.
I
think
all
of
them
are
ones
which
you
have
heard
from
us
or
been
alerted
to
from
us
at
previous
hearings,
but
for
convenience.
Mr
mamode
will
will
briefly
talk
through
each
of
those
and
again
they're
highlighted
in
yellow.
It
actually
starts
on
the
on
the
second
page
of
this
policy,
but
we'll
take
you
through
those
now.
D
So
the
primary
changes
that
you
see
there
are
changes
agreed
with
the
environment
agency
and
formalized
through
a
statement
of
common
ground
which
relate
to
the
water
directive.
Framework
you'll
also
see
a
additional
bullet
point
that
has
been
added
in
relation
to
mitigation
and
adaptation
to
climate
change
in
that
section,
and
that
was
reflected
in
our
phase
two
Mata
8
statement
as
well,
where
that
was
proposed
and
revisions
to
supporting
texts
make
reference
to
this
change
to.
A
H
Thank
you,
sir.
It's
a
point
around
Effectiveness
when
it
comes
to
soundness
of
dp2
and
also
our
principle
about
the
development
management
principles.
Setting
out
a
broad
statement
then
picked
up
by
further
policies.
Further
down
and
we'll
in
dp2,
we
were
a
little
concerned
that
it
was
a
bit
weak
on
health
and
well-being
when
actually
there
are
some
specific
policies,
as
you
know,
find
well
hw17
that
actually
pick
that
up
in
detail,
but
nothing
within
dp2.
That
really
brings
that
into
the
conversation.
H
So
our
suggestion
was
that,
within
the
bullet
points
under
Section
II
in
dp2,
there
might
be
an
inclusion
that
it
should
reference
support
the
the
development
principles
or
support
communities,
Health
social
and
cultural
well-being
under
that
subheading,
and
that
would
allow
those
further
policies,
hw1,
hw7
and
D3,
to
then
be
introduced
and
bring
some
further
detail
into
it.
So
we
just
we
just
thought
that
was
something
that
was
missing
from
to.
D
D
C
And
that
can't
possibly
be
right,
because
we
don't
need
any
introductory
words
here
in
order
for
those
policies
which
went
through
yesterday
with
virtually
no
comment
from
the
Civic
trust
to
operate
effectively,
it
simply
without
absolutely
nothing
for
the
purposes
of
soundness
and
Effectiveness.
It's
is
it
best
presentational.
A
G
Obviously,
some
of
those
arguments
refer
to
matters
that
we've
touched
on
in
earlier
phases,
which
will
obviously
await
your
decisions
and
and
views
on.
But
there
were
some
additional
issues
here
that
we
wanted
to
raise
in
terms
of
the
wording
issues
in
terms
of
the
points
that
we
make
on
page
two
and
page
three
of
our
written
submission
in
terms
of
the
transport
issues,
the
importance
of
referring
to
the
hierarchy
of
Transport
users.
G
We
also
think
that,
in
terms
of
the
highway
network
capacity,
there
needs
to
be
appropriate
qualifications
in
terms
of
just
proceeding
on
that,
without
a
full
appraisal
of
its
economic,
social
and
environmental
and
carbon
impacts
and
the
carbon
implications.
Given
the
massive
challenge
that
we
have
to
achieve,
the
Net
Zero
targets
of
both
government
and
the
local
York
ones,.
C
G
The
modification
you
published
modifications
to
dp2
in
the
documentary
table
here
they
aren't
actually
they
weren't.
Actually
in
your
written
statement
and
I
checked
the
major
modifications
document
and
they
weren't
in
there
either
so
the
first
time
we've
seen
them,
but
I
I
don't
have
a
problem
with
them,
but
I,
don't
you
know,
that's
sure.
C
Yeah
there
are,
there
are
a
couple
highlight
them
if
it's
necessary,
but
the
few
extras
in
the
usual
way
is:
we've
looked
at
Mata
statements
and
taken
on
what
people
have
said
and
we
will
include
those
as
part
of
the
modifications
that
will
be
transported
on
due
chores.
I
mean
this
is
an
issue
that's
been
raised.
I,
don't
propose
to
address
that
part
of
the
submissions
any
further.
D
So,
just
just
on
that
point
those
modifications
were
set
out
in
our
phase
two
matter:
eight
and
Mata
one
hearing
statements
and
I
apologize
that
they
were
omitted
for
completeness
in
the
in
this
phases.
Hearing
statements,
but
that's
why
we
provided
the
hard
copies.
So
people
would
have
those
conveniently
to
hand.
C
C
We
don't
accept
that
there
needs
to
be
a
change
in
in
the
way
that
is
proposed
by
the
Civic.
Sorry
not
to
adjust
the
labor
party
and
those
others
who
Mr
Matt
represents
that
those
projects
as
they
come
forward,
will
of
course
comply
insofar
as
they
have
to
with
eia,
and
indeed
any
other
policies
Within
the
plan,
insofar
as
they
are
development
within
the
stroke
of
this
plan,
and
that
will
capture
all
of
those
matters
which
Mr
Merritt
has
raised
in
his
proposed
amendment,
insofar
as
they
are.
C
G
Could
just
come
back
about
the
hierarchy?
Yes,
I
accept,
it
is
in
the
ltp3
which
we
have
I,
think
in
other
locations
in
other
hearings,
recognized
is
considerably
dated
and
therefore
the
weight
that
developers
might
put
on
it
might
not
be
what
it
should
be,
but
the
point
about
the
hierarchy
is,
it
doesn't
just
influence
the
transport
Provisions.
It
also
influences
the
design
of
developments.
G
E
E
E
E
So
we
would,
we
would
tend
to
apply
that
and
say
well,
actually,
our
preference
in
line
with
ltp3
is
that
the
site
is,
you
know,
as
many
trips
within
sight
and
to
and
from
the
site
take
place
by
sustainable
modes.
So
the
first
thing
is
to
make
sure
that
they
are
accommodated,
and
then
you
would
ensure
that
the
infrastructure
is
there
and
then
accommodate
vehicle
trips.
After
that.
E
That's
that's
absolutely
how
it
works,
and
it's
it's
very
useful,
because
it's
a
very
clear
statement
of
our
our
policy,
because
when
you're
negotiating
section
106
agreements
with
Developers,
you
know
sometimes
there
is
a
tendency
to
say
perhaps
because
they're
more
familiar
with
other
parts
of
the
country
where
there
isn't
this
Focus,
they
might
say
well
this
is
it
really
necessary
to
provide
this
cycle
facility?
Is
it
really
necessary
to
provide
these
bus
services?
Well?
No.
E
C
So
I
think
the
word
used
tool
is
important
is
a
tool
within
that
overarching
strategy
and
it
falls
part
of
those
negotiations
with
developers
on
a
site-specific
basis.
It's
not
applied
as
a
policy
and
would
be
odd
if
it
was
applied
to
the
sort
of
policy
it
needs
to
inform
the
disruptions,
as
the
development
comes
forward
in
the
way
that
Mr
ridges
described.
Hence
why
we
say
it's
best
located
where
it
is
I.E
within
the
suite
of
The
Wider
issues
in
in
lpt3,
with
the
appropriate
cross-reference
that
we've
ordered
all
your
attention
to.
A
C
C
If
you
look
at
dp3,
Roman,
numerals,
I'm,
sorry,
I'm,
jumping
ahead
slightly
that
deals
specifically
the
promoting
integration,
connectivity
and
accessibility
to
from
within
the
site
by
maximizing
opportunities
for
dot
dot
dot.
Essentially,
it's
it's
capturing
very
much.
What
Mr
ridges
described
to
you
we're
not
going
to
have
any
difficulties
with
a
reference
to
the
hierarchy,
perhaps
within
the
support
and
text
that
follows
paragraph
220
to
that
policy.
That
would
be
an
amendment
that
the
chance
would
be
comfortable
with
and
if
that's
something
that
would
achieve
what
you've
just
suggested.
A
E
C
G
Can
I
express
my
appreciation
to
yourself,
sir,
and
to
the
Council
on
in
in
that
regard?
Can
I
just
make
one
final
Point
the
point
the
answer
is
Mr
Ridge
gave
to
you
highlighted
that
the
use
of
the
hierarchy
in
dealing
with
the
transport
aspects
of
planning
applications,
as
I
said
in
my
earlier
comments,
we
see
it
as
a
two-fold
function.
It
also
should
inform
the
layout
of
significant
major
new
developments
in
terms
of
being
able
to
encourage
walking
cycling
and
so
on.
G
C
C
A
H
Just
to
say
the
outset,
and
we
strongly
support
the
principles
laid
out
by
the
Council
of
dp3.
Our
issue
is
around
the
use
of
phrase
historic
character
by
itself,
and
we
think
it
goes
towards
the
consistency
with
national
policy.
Whilst
we
welcome
the
the
the
emphasis
on
enhancing
and
respecting
historic
character,
we
don't
think
it's
strong
enough
and
there's
no
definition
within
within
nppf12
of
historic
character
where
I
there
are.
H
There
is
definite
there
are
definitions
of
historic
environment
and
Heritage
assets,
and
we
think
the
addition
of
that
for
those
two
terms
that
are
well
defined
within
mppf
and
well
well
established
as
accepted
terms,
in
addition
to
Historic
characters
to
replace
historic
character
in
principles,
Roman
numeral,
one
and
Roman
numeral
three
would
actually
make
the
dp3
more
sound.
Sorry
would
make
it
sound
and
more
compliant
with
National
policy.
So
it's
just
that
and
we
think
it's
it's
just
it's
as
again.
It's
that
point.
This
is
this
is
the
at
the
outset.
A
Is
that
Mr
Morrison,
because
I'm
I'm,
just
trying
to
well
I,
just
want
to
be
absolutely
sure
that
that
I
fully
get
get
your
point
is
well.
Do
you
say
that?
Is
it
the
word
character
frankly,
and
is
it
because
the
things
that
need
to
be
respected
and
enhanced
in
relation
to
the
historic
environment
might
not
necessarily,
or
they
might
go
beyond
character,.
H
Yes,
sir,
it's
exactly
that.
It's
the
fact
that
you
know
in
the
historic
environment
and
Heritage
assets
are
very
well
defined
with
mppf
and
go
beyond
a
sense
of
what
a
character
might
be,
which
we
think
is
a
little
bit
subjective.
So
it's
just
it's
just
to
reinforce
those
two
principles
by
using
terminology
from
mppf.
D
The
mppf
terminology
referred
to
is
is,
of
course,
dealt
within
the
design
policies
of
the
plan
where
we
make
explicit
reference
to
this
I
think
historic
character
in
this
context
is
intended
to
be
again
broader
into
capture
those
those
elements,
but
also
wider
elements
of
the
historic
character
of
the
of
this.
The
city
I,
don't
think
so.
This
is
a
soundness,
a
soundness
point
and
I.
Don't
know
that
changes
with
necessarily
even
had
Clarity
when
we
look
at
this
policy
in
combination
with
the
design
policies
in
later
sections
of
the
plan.
C
We
see
the
historical
character
here
is
encompassing
all
of
those
matters
in
the
historic
environment,
but
actually
being
slightly
wiser
because
of
those
into
relationships
and
because
of
the
way
in
which
the
authors
developed
and
which
permeates
not
just
assets
listed
or
otherwise,
but
also
titles
matters
such
as
purposeful.
When
we're
dealing
with
the
green
belt,
the
historic
character
comes
into
play
there.
We
think
that's
the
best
term
to
capture
all
of
those
different
components
in
this
special
context
of
York.
G
As
we
indicated
in
our
written
submission,
we're
concerned
that
there
has
been
some
watering
down
of
the
npf
policies
in
the
actual
York
plan,
introductions
of
where
possible
and
we'd
like
to
see
those
were
possible
deleted
and
the
firmer
words
that
are
in
the
npf
used
in
the
York
policies
and
we'd
be
quite
support.
We're
supportive
of
the
perhaps
more
of
a
comprehensive
comments
that
the
Civic
trust
has
made
on
their
issues
in
in
their
response
to
this
question.
C
No
change
is
needed.
Therefore,
my
submission
that
to
that
part
of
this
policy
and
as
to
the
next
point,
which
deals
with
the
precedent
paragraph,
we
don't
accept
that
there's
any
inconsistency
with
the
nppf
using
the
language
of
promotion
and
the
land
resolve,
facilitate
and
certainly
certainly,
nothing.
That
goes
to
the
issue
of
soundness.
It's
really
quite
clear
what
this
policy
is
seeking
to
achieve,
and
it
does
so
in
very
positive
terms.
Nothing
further
is
required
in
our
submission
on,
for
the
reasons
of
soundness,.
C
H
You,
sir,
as
far
as
we're
aware,
dp4
is
based
on
guidance
from
mppf12
to
power.
14.
and
mppf-21
revision
has
redefined
some
of
this
guidance
in
power
11,
and
we
wanted
it
to
take
it
importance
of
points
of
climate
change
as
well
as
protection
of
historic,
further
protection
and
historic
environment,
and
we
wondered
whether
actually
the
second
bullet
point
specified.
H
Policies
in
that
framework
indicate
that
development
should
be
restricted,
should
actually
be
updated
to
be
more
from
our
reading
more
in
line
with
mppf-21
to
reference,
Paris,
11
and
and
want
it
one
and
footnot
768.
It
just
feels
that
mppf,
the
the
local
draft
local
plant
and
National
policy
has
got
a
little
bit
out
of
line
here.
So
it's
just
whether
that
whether
referencing
mpf
ppf
21
revisions
would
strengthen
in
terms
of
consistency
with
national
policy.
That
second
bullet
point
Within
dp4.
C
They
capture
essentially
the
same
point
that
reoccurs
in
the
final
bullet
point
of
what
is
now
paragraph
11
of
the
2021
and
BPF.
The
footnote
has
changed
between
in
terms
of
its
its
numbering,
but
it
captures
the
same
matters,
habitats,
green
belts,
local
Green,
Space
anbs,
how
to
chose
National
parts
and
all
the
broads
designated
house
assets,
flooding,
Coastal
erosion.
C
C
A
A
A
Applying
this
element
of
national
policy
is
sometimes
complicated,
tricky
even
for
inspectors,
sometimes
I,
think
yeah.
We
could
almost
go
either
way
on
this
as
well
frankly,
but
whatever
is
in
this
plan
and
I
know
that
we
are
undertaking
this
examination
on
the
basis
of
the
2012
mppf,
but
insofar
as
there
may
be
any
difference
in,
let
us
call
it
the
new
mppf.
A
This
policy
absolutely
needs
to
reflect
that,
rather
than
mppf
2012.
If
there
are
I
mean
I
can't
remember.
Actually,
if
there
are
any
big
change,
yeah
yeah,
subtle
though
they
may
be.
The
last
thing
that
the
council
wants
is
any
complication
arising
from
slightly
different
wording
in
the
plant
in
the
current
nppf.
C
So
yes,
I
entirely
appreciate
the
point
that
there
are
subtle
changes:
I
call
to
appeal
in
Monks,
Hill
gladman,
all
of
my
colleagues
applying
their
forensic
hyperscrutiny
tea
these
words
and
indeed
to
the
footnotes,
I.
Think
on
that
basis
there
are.
There
are
wider
reasons
why
we
might
be
uncomfortable
for
retaining
it.
C
A
C
Policy,
no,
so
that
actually
introduces
further
complications.
You
get
more
barristers,
making
clever
arguments
about
whether
you
can
achieve
the
presumption
within
the
plan
rather
than
having
to
go
outside
the
plan.
That's
simply
a
bigger
headache
than
dealing
with
it
in
the
usual
way
and
so
I
think
that's
another
reason
to
get
rid
of
it.
H
A
C
D
D
Thank
you,
sir.
The
changes
that
you
see
are
quite
limited
and
were,
in
fact
discussed
in
phase
two
under
Mata
eight
and
the
the
specific
changes
we've
made,
responded
to
the
discussion
that
we
had
in
that
session,
where
we
needed
to
make
more
explicit
the
potential
for
viability-based
reviews
again
that
was
discussed
at
phase
two,
and
so
what
we've
done
is
just
pulled
that
modification
across
and
reflected
it
in
the
statement.
G
C
C
A
G
C
G
E
I
think
it's
part,
it's
part
of
the
wording
of
the
original
plan
and
you
know
I
didn't
write
it
I,
don't
know
what
was
going
through
the
mind
of
the
person
who
did
but
I.
Don't
think
whether
it's
in
there
or
not
goes
to
soundness.
To
be
completely
honest,
I
must
admit.
I
I
would
have
a
preference
to
spelling
it
out
because
sometimes
sustainable
transport
is
used
in
my
experience
a
bit
selectively.
So
it's
actually
quite
useful
to
have
a
a
more
serious
statement
of
what
it
is.
I
E
G
In
in
the
fifth
and
sixth
sentences,
it
refers
to
increasing
travel
time
across
the
transport
Network.
It's
approximately
13
30
and
the
increase
in
network
delay
is
approximately
55
percent.
Those
appear
to
be
the
figures
from
the
2018
transport
topic
paper,
but
that
was
superseded
by
the
2019
version
and
I
think
those
figures
should
be
35
and
65
percent.
G
But
having
looked
at
the
data
and
comparing
the
State,
the
roots
that
are
in
the
previous
table
15.1
and
the
proposed
replacement
15.1,
it
is
clear
that
there
is
a
substantial
increase,
at
least
in
the
unweighted
average
peak
hour
travel
times.
So
those
figures,
even
at
35
and
65
percent-
are
actually
lower
than
the
latest
Visa
modeling
would
suggest.
G
G
G
If
you
look
at
the
dfts
traffic
data,
the
trips
in
2001
were
736.3
million
and
using
the
2019
rather
than
the
2021
figures.
Because
of
the
pandemic
issue
2019.
As
the
last
pre-pandemic
issue,
the
figure
was
983
million,
and
that
is
a
33
and
a
half
percent
increase.
So
in
effect,
trans
trouble
has
been
increasing
two
and
a
half
times
faster
than
the
population
increasing
and
again
that
reinforces
the
concerns
that
we
have
previously
expressed
on
the
unsoundness
of
the
transport
aspects
of
this
plan.
E
Okay,
there
are
a
number
of
things
there.
The
reason
why
the
figures,
the
30
figure
for
the
increase
in
travel
time
across
the
network
and
55
increase
in
network
delay,
is
still
within
this
paragraph
As.
In
fact,
they
are
reflective
of
what
comes
out
of
the
2022
modeling
and
therefore
there
was
that
there
was
seen
to
be
no
need
to
change
them.
E
Although
admitted
the
the
2019
transport
topic,
paper
has
different
figures
in
the
numbers
that
come
out
of
the
network
model
are
for
all
trips
in
York,
so
they're
not
directly
comparable
with
the
basket
of
corridors
which
is
given
in
the
big
table.
So
you
can't
you
can't
read
across
you
can't
infer
that
one
is
the
same
as
the
other,
so
I
I
think
those
numbers
should
stay
the
information
about
the
about
the
traffic
modeling
and
the
the
increase
in
population
and
the
DFT
traffic
statistics.
E
We
dealt
with
this
last
week
at
some
length
and
we've
actually
issued
a
note
which
is
in
the
examination
Library
as
ex
cyc
I.
Think
it's
112.,
where
the
council
put
forward
its
view
unambiguously
that
the
DFT
figures
are
not
should
not
be
used
in
a
way
that
the
labor
party
in
the
Civic
trust
are
using
them
because
they
are
based
on
estimates
and
the
DFT
themselves
in
the
rider
to
those
statistics
so
that
they
should
not
be
used
for
small
areas
and
their
their
Regional
statistics.
E
E
G
Reiterate
please
Julie,
as
I
say,
I
think
there's
still
concerns
as
if
the
council
is
claiming
that
the
Visa
modeling
now
produces
those
figures.
I
think
it
would
be
helpful
if
the
evidence
to
back
that
statement
was
provided,
and
we
can
then
obviously
make
any
comments
that
we
feel
that
are
still
appropriate
when
the
modifications
are
published.
C
So
that's
what
I
can
deal
with
very
very
shortly:
it's
not
a
question
of
don't
use
or
use.
We've
considered
all
these
matters
we've
used
what
we've
translated
to
be
the
most
appropriate
evidence
for
the
reasons
that
Mr
Bridges
already
explained
to
you
and
which
are
in
the
note
equally,
the
evidence
is
there.
Everything
that
you
need
to
consider
this
matter
is
in
that
note.
G
A
C
D
D
The
45
Target
for
affordable
dwellings
again
discussed
at
the
last
phase
of
hearing,
so
there
are
those
those
two
key
changes.
There
there's
also
reference
in
later
sections
to
prioritizing
and
making
the
best
use
of
previously
developed
land
and
directing
development
to
the
most
sustainable
locations
and
the
strike
through
of
viable
and
deliverable
and
the
ReUse
of
previous
developed
plans,
and
so
you
can
see
those
changes
have
been
made
there
for
clarity.
C
F
Thank
you,
sir
I
welcome
the
change
that's
been
made
in
reference,
superior's
developed
land,
that's
something
that
I've
brought
up
because
there
is
no
phasing,
so
the
proposed
change
now
makes
a
lot
more
sense.
I
appreciate
that
and
the
other
mat
I
just
want
to
raise-
and
this
is
the
difficulty
in
that
how
many
hearing
sessions
we've
had,
and
obviously
this
is
a
proposed
change
from
an
earlier
hearing
session.
But
it's
just
in
relation
to
the
first
part
of
the
policy
that
talks
about
to
ensure
Greenbelt
permanence.
F
It's
just
to
reiterate
that
same
point.
The
whole
point
of
setting
Green
Belt
boundaries
is
in
this
plan
is
not
about
the
allocation
of
land
or
accommodating
at
the
allocation
land.
It's
about
ensuring
that
the
green
belt
boundaries
are
permanent
because
they
make
sense
on
the
ground
in
terms
of
where,
due
where
the
character
the
site
supports
that
boundary.
F
So
the
idea
that
the
council
is
allocating
land
and
defining
the
boundaries
on
the
basis
of
allocations
just
fundamentally,
is
wrong
in
terms
of
the
principles
of
why
Greenbelt
boundaries
are
meant
to
be
set
in
the
first
place
it
shouldn't
be
about
allowing
land.
It
should
be
about
making
sure
that
the
boundaries
are
permanent
because
they
are,
they
have,
they
form
the
function
of
green
belt.
F
F
We
then
try
what's
been
tried
to
be
introduced
by
the
the
reference
to
average.
Is
that
an
average
delivery
of
822
will
then
occur,
irrespective
of
that
overall
Target
and
it's
changing
the
emphasis
of
the
policy.
If
we
look
into
the
first
bullet
point,
there
is
no
mention
of
an
average
annual
net
provision
in
respect
to
jobs.
It
just
talks
about
an
annual
provision
of
650.
So
there's
an
inconsistency
between
bullet
points.
F
A
F
So
I
get
that
we
took
the
13
152,
divided
it
by
the
number
of
years
to
get
to
reach
822,
but
so
so
that
is,
it
has
been
average
in
order
to
arrive
at
the
annual
Target,
but
including
it
in
that
bullet
point
in
the
way,
it's
now
included
then
suggests
that
the
council
is
only
going
to
deliver
an
average
of
the
822,
which
then
caps
the
number
of
overall
houses
to
provide
it.
So
it
won't
be
at
least
13
152,
that's,
provided
it
will
be
only
13
152.
F
That's
provided
because
they're
going
to
keep
averaging
out
the
numbers
over
the
years
to
make
sure
that
they
don't
deliver
more
than
the
822
every
year,
but
actually
it
should
just
be
that
there
is
a
an
annual
Target
of
822
per
year
that
contributes
to
then
delivering
at
least
13
152
dwellings.
What
in
effect
is
happening
is
that
the
inclusion
of
the
word
average
means
that,
if
there's
any
over
provision
in
any
year,
then
that
over
provision
then
means
counts
towards
the
averaging.
That
brings
the
target
back
down
to
the
13
152.
F
I
F
Applied
so
they
don't
ever
deliver
more
than
that
requirement,
so
it
doesn't
become
at
least
1352.
It
becomes
an
absolute
of
13
152
because
if
there's
under
Supply
one
year
and
then
over
Supply
another
year,
they'll
average
it
all
out
on
a
continuous
basis
and
if
they
ever
become,
if
they
ever
exceed
822
they'll
turn
the
supply
off
and
if
they
have
less
and
obviously
they'll
keep
granting
planning
permissions
to
get
up
to.
But
in
that
effect
the
mppf
is
clear
that
it's
about
significantly
boosting
the
housing
Supply.
F
A
I
I
certainly
don't
quite
follow
your
your
point
about
I.
Think
you're
kind
of
I
think
you're
saying
that
this
in
some
way
introduces
a
ceiling
and
I
I'm,
just
not
I'm,
not
seeing
that
deliver
a
minimum
average
annual
net
provision
of
822
I
I,
don't
see
how
there's
there's
any
kind
of
ceiling
involved
there.
A
Like
I
think
and
the
council
can
correct
me
if
I
get
this
wrong,
but
I
think
the
word
average
is
there
to
make
it
clear
that
the
plan
isn't
seeking
to
deliver
a
minimum
of
822
dwellings
every
year,
necessarily
because
there
will
be
years
where
maybe
it's
less
than
that
years,
when
it's
more
but
on
average.
Overall
it
is
822
per
year,
but
there
isn't
a
kind
of
annual
Target
every
year.
I
think
that's
why
the
word
averages
is
present
has
been
proposed
to
be
added.
I
At
some
point
in
the
future,
the
council's
put
in
the
position
where
it
needs
to
demonstrate
what
its
Supply
is.
Then
what's
happened
in
previous
years,
wouldn't
be
taken
into
account.
It's
a
forward-looking
matter,
so
you'd
have
to
show
that
you
could.
Oh
you'd
have
to
demonstrate
that
there
is
a
supply
of
822
a
year
looking
forward
and
what
happens
previously
doesn't
really
matter.
I
mean
you
might
have.
You
might
have
delivered
1500
houses
in
the
previous
year,
but
you've
still
gotta.
I
C
The
slightly
longer
answer
is
what
inspector
Barkley
said,
which
is
we
are
seeking
to
achieve,
at
least
that
number
we're
going
to
express
that
as
an
average
over
the
plan
period,
it's
not
appropriate
to
have
any
sort
of
annual
tide,
which
is,
as
we've
explained,
through
all
the
housing
evidence
of
Miss
Bartles
trajectories
houses,
don't
come
forward
on
an
average
basis.
They
never
do
a
plan.
A
plan
needs
time
to
get
up
to
speed.
C
Then
it
will
deliver
very
quickly
in
the
middle
and
then
in
I'm
generalizing,
but
it's
a
pretty
sound
generalization
towards
the
end
delivery
that
takes
on
a
different
trajectory
that
that
is.
That
is
how
the
market
operates
and
they
are
probably
work
within.
But
an
average
approach
is
is
sensible
in
the
in
that
context,
it
doesn't
impose
a
cap,
in
any
sense
the
eight
two
two.
Yes,
that
will
form
the
basis
for
the
assessment
of
supply.
C
There's
a
mass
that's
been
before
the
troll
several
times.
We
don't
need
anything
further
here.
That's
really
a
separate
exercise,
albeit
I,
appreciate
that
this
examination
has
earlier
transited
Supply,
it's
not
dealing
with
that
question
here.
This
is
just
setting
out
that
headline
figure,
given
it
as
an
annual
approach
on
an
average
basis,
and
we
say
it's
it's
entirely
clear
what
what
is
being
achieved.
Importantly,
no
cap.
I
I
think,
if
I'm,
if
I'm
looking
at
this
policy
without
the
word
average
in
what
it
commits
the
council
to
doing,
is
deliver
a
minimum
net
provision
of
822
every
year.
But
as
you've
said,
there
are
ups
and
there
are
ups
and
downs.
There
will
be
some
years
when
you
don't
deliver.
Eight
two
two
there'll
be
some
years
when
you
deliver
more
than
eight
two
two
that
would
that
would
be
the
basis.
C
For
that,
so
yes
and
Miss
Bartle,
hopefully
reminds
me
from
behind
that.
Actually,
when
one
looks
at
the
evidence
that
we
have
put
before
you
that
shows
a
minimum
of
17
000
and
a
little
bit
over
the
remaining
11
years,
the
plan
p.
That's
a
good
example
of
us
not
treating
this
as
a
cap
and
cyc
76.
If
you
want
the
reference
so
yeah
precisely,
is
you
say
that
we've
not
looked
at
this
as
a
chart?
C
Yeah,
yes,
sir,
we
think
it's
necessary
for
clarity
to
avoid,
unfortunately,
the
confusion
that
we've
had
this
morning
as
about
whether
there
is
a
sort
of
a
second
annual
Target,
you
know
that's
not
and
I'm
afraid
it's
a
point
that
would
cut
both
ways
of
your
developer.
If
you
don't
look
at
it
as
an
average,
then
you
can't
run
any
arguments
about
shortfall.
F
C
So,
no
because
this
reflects
how
the
the
evidence
on
jobs
has
been
produced
and
how
it's
been
put
before
you
would
also
reflects
the
fact
that
one
doesn't
have
to
deal
with
the
provision
of
jobs
through
the
local
plan.
In
the
same
terms
is
what
has
to
deal
with
the
provision
of
house,
and
that's
you
know,
that's
that's
how
the
nppf
is,
and
we've
reflected
that
in
our
approach
and
the
evidence
and
the
submissions
that
we've
made
to
you.
C
Can
I
try
to
just
jump
out
on
the
Green
Belt
Point?
That's
a
really
quick,
really
quick
Point.
It's
incorrect
to
say
that
we
have
set
Green
Belt
boundaries
on
the
basis
of
allocations
and
that
somehow
this
is
one
has
led
to
the
other.
That's
not
right.
You
will
recall
all
of
Miss
Healey
Brown's
evidence
where
and
we've
taken
you
through
all
the
dependencies.
In
fact,
we
don't
have
to
return
to
items
like
later
today
on
a
specific
matter,
but
part
of
that
Transit
duration
has
been
as
a
standalone
aspect.
C
I
D
G
C
A
Okay,
I
think
what
I'm
going
to
do
is
to
take
a
short
adjournment
and
then
look
at
Mata,
one,
that's
green
belt
boundaries
and-
and
it's
section
eight
of
the
green
belt
boundaries
that
we
will
be
considering
when
we
return
so
I
make
it
10.
46
I
joined
the
hearing
to
resume
at
five
past
eleven.
Thank
you.