Saturday 29 April 2023

Wembley Stadium - what might have been

 A Wembley Stadium centenary guest snippet from local historian Philip Grant.



Euro 1996 football fans, heading for the future! (Image: Foster & Partners)


It’s 1996, and Wembley is staging the final games in the Euros football tournament. But the original stadium, built in 1923 for the British Empire Exhibition is showing its age, and it has been agreed that it needs to be replaced.


In April 1996, the “go ahead” Brent Council had launched its masterplan for the redevelopment of the area around the stadium, with improved public transport links and parking facilities, and more public open space around the stadium to improve pedestrian circulation. At the centre of this new Wembley Park would be ‘a world class Wembley Stadium for the 21st century’, designed by Foster and Partners for the English National Stadium Trust.


The logo of the old Wembley Stadium, up to 2000. (Image: Wembley Stadium Ltd)


But, of course, you could not demolish the iconic “twin towers”. They had been made a Grade II listed heritage asset in 1976, and English Heritage said that they must be retained. Many football fans, and many in the press and general public, agreed.


The stand-alone “twin towers”, in front of the new “Wembley Wave” stadium. (Image: Foster & Partners)


Sir Norman Foster’s solution was to demolish the rest of the old stadium, and move the twin towers northwards, by around 100metres, towards Wembley Park Station. They would still provide a gateway to the stadium precinct for spectators coming up Olympic Way, but moving them would create the space for the pitch to be turned through 90º, so that it would get the best natural light.


The new stadium would have a fully retractable roof, supported by a metal framework running above the top of its outer walls, and dubbed the “Wembley Wave”. It would seat 80,000 spectators for football and rugby matches, and 75,000 for athletics events (the track would be under retractable seating). The external skin of the stadium would provide a giant screen, on which pictures could be projected.  


The new stadium lit up at night, with a large open space to its north-east. 

 (Image: Foster & Partners)


Those pictures could include moving images for the benefit of spectators outside the stadium, in a large square to the north-east of the new Wembley. This open space would allow fans to circulate more freely around the stadium, and avoid congestion, both before and after matches or concerts. 


As we all know, this is not the new stadium Wembley actually got, in 2007. I think there are parts of the 1996 design, including the extra public space around the stadium, which would have been an improvement! [Others, like moving the “twin towers”, were probably impractical.] What do you think?


Philip Grant
(With thanks to Paul, for the pictures)



Friday 28 April 2023

UPDATED with questions for the Barham Park Trustees from Cllr Paul Lorber - Brent Council on Barham Park Covenant: 'Move along, nothing to see here.'

 The is a covenant on the plot in Barham Park which is the subject of a planning application to demolish two 2 storey houses and replace with four 3 storey houses. The restrictive covenant may have to be removed to allow development, so I put in an FoI request to Brent Council on its valuation.

This is the answer received today:

 1. Please confirm if you have acquired a professional valuation of the
Covenant attached to the two  properties at 776-778 Harrow Road, Barham
Park that were sold to George Irwin.

Response: The Council has not acquired a professional valuation of the
covenant attached to the two properties at 776-778 Harrow Road, Barham

2. If not, have Brent Council officers made their own valuation and
informed the Trustees of  Barham Park accordingly? 

Response: No. 

3. If either have been done, what is the valuation of the Covenant?

Response: This is not known as a valuation has not been carried out.

UPDATE Cllr Paul Lorber has submitted the following comment with some vital questions for the Trustees of Barham Park.

Thanks to Martin for asking for information which should not be cloaked in secrecy.

I am would be surprised if none of the Trustees (5 Labour Councillors who sit in the Cabinet) asked for a valuation of the Covenant. The 5 Trustees/Councillors have a clear fiduciary duty to protect the value of the Charity assets and the Covenant may well be the Barham Park Charity's most valuable asset.

As the applicant also confirmed that they do not currently own ALL the land to which the latest application applies there is clearly some land owned by the Barham Park Charity they wish to build or take ownership off.

If I was one of the Trustees I would certainly ask for full legal and financial advice on the implications of both the Planning Applications, The Covenants (including it value) and the land not currently in the applicants' ownership which may be lost to the Park should the application be approved.

Aside of the Panning Application we therefore have 2 very clear issues for the Trustees to consider and to be properly advised on:

1. Will the Trustees stand by the Covenant and block any expansion of building in Barham Park?
2. If not why not?
3. If not what price will they charge instead of enforcing the Covenant?
4. Will they protect Barham Park in line with Council policies in relation to Open Spaces and refuse to sell any part of the Park that the applicant clearly needs as part of the current planning permission?
5. If they are mindful to sell the extra land needed by the applicant what price will they require to do so?

The Trustees duty in this case is to the Barham Park Charity and NOT to the Council and they will no doubt be reminded of this. The Council Officers may well feel obliged to obtain expert legal advice and possibly guidance from the Charity Commission to ensure that the Trustees act in the best interests of the Charity and no one else - even if this means blocking any building in the Park irrespective of what planning permission is granted.

As the land is part of a charitable endowment there are complex issues to consider as simply granting planning permission will not be the end of the matter - after all somehow a planning permission to demolish the two houses and replace them with more slipped through in 2017 and was never implemented.

The issues of the Covenant is also not simply as there are numerous beneficiaries to whom the Covenant may relate to - including possibly all the current leaseholders of the parts of the other buildings in Barham Park.

One of those leaseholders is Barham Community Library which pays rent to the Barham Park Charity.

I am one of the Trustees of Barham Community Library and as such am especially keen to ensure that Brent Council Officers managing the Barham Park Charity deal with this matter properly, obtain all the necessary advice and be transparent in all their dealings.

Hopefully Martin's questions will now prompt Brent Council officers to obtain the Valuations and advice they and the Trustees will need.

Thursday 27 April 2023

‘The Battle of Footerloo’ -The First FA Cup Final at Wembley Stadium, 28 April 1923

Guest post by Janet Kear


Some of the most iconic sporting photographs in history are of a police officer on a white horse, clearing the crowd from the Wembley pitch so that the 1923 Cup Final could take place.



 1.      PC Scorey and Billie in the middle of the crowds on the pitch. (Image from the internet)


PC George Scorey, with his horse Billie, would later be recognised as the man that saved the game, and it is often referred to as the White Horse Final. Although, as can be seen from this photograph of the match, there was more than one horse involved!  It was just that all the other horses were dark in colour. But this article is not intended to discuss the action on the pitch - the result is well known - but rather to look at the events leading up to and after the match.



It was the Prince of Wales, later to become King Edward VIII, who’d proposed in 1921 that the British Empire Exhibition, to be held at Wembley Park, should include ‘a great national sports ground’. The stadium would be capable of holding 125,000 spectators, and the FA had already signed a deal for its Cup Final to be played there for 21 years, commencing in 1923.  The first turf for the Stadium was cut and the foundation stone laid by the Duke of York, on 10 January 1922.  This also symbolised the start of the building work for the exhibition site.




2.     The Duke of York, cutting the first turf for the stadium in January 1922.



It had been intended to open the surrounding British Empire Exhibition in 1923. However, once construction started, it became clear that the 13 months was not long enough to complete the work. So the opening date was delayed until 1924. 




 3.     In February 1923 they still had a considerable amount of work to complete.



In April 1923 the completed stadium stood in isolation on the Wembley Park site, with building works going on around it.  You can see from the plan below that it was surrounded by a hoarding, which was only 5’ 8” feet high, with just three entry points to the circulating area, at the bottom of the steps that gave access into the stadium itself.




 4.     A plan of the stadium and its approaches, as it was for the 1923 Cup Final.



This was the first “National” Stadium. It was considerably bigger than any other stadium in the country, and building work had only been completed four days before the final was to be held.  Unlike the new Wembley, there had been no test events where the facilities and systems could be tested by gradually increasing crowd sizes.  Therefore, any planning work for the big match on 28 April could only be based on assumptions. That being said, a lot of planning work was undertaken. 



Documents in the National Archives demonstrate that the Stadium had prepared, what we would call today, an Event Manual.  It covered all sorts of issues including identifying people for specific roles and even detailed where to store the footballs when they were received from the FA.



The British Empire Exhibition Authority had had extensive discussions with the Metropolitan Police about the police presence at the event, both inside and outside of the Stadium.  Initially it was planned to have a total of 334 police present.  Control Staff wrote to the Police on Monday 23 April asking for more police resources as, on the previous Sunday, a number of people had been found to be ‘nearly entering the Stadium by way of the Great Central Railway Embankment’ and ‘at a few points along the temporary fencing’



They also expressed concern that there was the need to ‘make some provision in the possible event of a large number of people arriving after the Stadium is full.  It is, of course, possible that there may be 10,000 people, or more, who may have to be shut out because the Stadium is full, and the turnstiles barriers in themselves may not prove sufficient protection’. As a result of the letter an additional 56 police were provided, ‘which together with a CID contingent furnished from Scotland Yard made the total 428.’




 5.      Turnstiles under construction for the 1923 FA Cup Final. (Image from the internet)


The Stadium arrangements were inspected in the morning and afternoon of Friday 27 April and defects were noted and repaired. A third inspection took place at 9am on Saturday 28 April at which it was noted that the numbers outside the turnstiles were ‘negligible’.



The turnstiles opened at 11:30am as planned, with the match due to kick off at 3:00pm. By midday the area was packed. 45,000 tickets had been sold in advance.  The remining 80,000 tickets had been advertised for sale on the day and it seemed that everyone thought they were going to get in.




6.      Crowds outside the turnstiles for FA Cup tickets on the day. (Image from the internet)



There were 153 turnstiles of which 73 were for cash visitors and the remainder for ticket holders.  Boy Scouts were at each turnstile to count the numbers passing through.  It was later estimated that at one point 1,000 people were entering per minute.



People were entering the Stadium from everywhere and the staff and police were overwhelmed and helpless.  At 1:45pm, when the returns showed that the standing accommodation was nearly full, instructions were given to close the turnstiles. This then led to people breaking through the turnstiles and climbing over the hoarding, some using ladders from the surrounding building site.




7.      Football supporters climbing over the closed turnstiles to get to the Stadium. (From an old film)




8.      West Ham fans between the barriers and the Stadium before the match. (From an old film)


 At 2pm the police were asked to phone Scotland Yard to request a large force of mounted police.  Calls went to the local police stations to send more officers. At 2:15pm the crowd broke through all the barriers. Between 2pm and 2:45pm it was estimated that 50,000 to 100,000 entered the Stadium by climbing in. By 2:40pm the whole of the interior of the Stadium was full of people. Stadium Control had to phone the Railway Companies and ask them to stop sending trains to the area, so as not to add to the crowd that was already there.




9.      The packed stadium, with crowds across the pitch, before the match. (Image from the internet)


The King arrived at 2:45pm to a rapturous welcome and somehow the bands of the Irish and Grenadier Guards managed to play the National Anthem, which appeared to ease the tension in the crowd.  At some point the mounted police arrived.



The teams had been due on the pitch at 2:40pm but it took till 3:10pm for them to make their first appearance, they were immediately swallowed up by the crowd.  At one point the Stadium authorities gave serious thought to abandoning the game, although this was balanced against the protest that might happen if they did.




10.   The crowd being pushed back to the edge of the pitch. (Image from the internet)



Eventually at 3:43pm the match kicked off, but it was not without its difficulties.  Balls that would have naturally left the pitch rebounded off the spectators straight back into play.  All the corners required a path to be cleared with the help of the police, so that a run up could be taken. Thirty minutes into the game the crowd surged onto the pitch and the mounted police had to be called back into action, this caused another 12-minute delay.  At half time the players and the officials decided to stay on the pitch, leaving not really being an option. The final score was Bolton Wanderers 2, West Ham United 0.




11.   The Cup Final match in progress, with crowds up to the touchlines and people watching from the roof.  (Image from the internet)


After the event there were many reports in the press. National and local papers all had a view. The crowd was estimated in various places between 150,000 and 200,000 although the official attendance was recorded as 126,047. The Police estimate, immediately after the match had finished was 300,000!




12.   Headlines from The Guardian (broadsheet) and Daily News (tabloid) on 30 April 1923.


The Home Secretary was asked questions in the House of Commons about the adequacy of the arrangements that had been made and whether the event needed licencing, which it did not. Unlike today, where sports grounds need an individual licence and a Safety Certificate from the Local Authority in which they are located. In answer to a question about how many police were present the reply given was 12 inspectors, 53 police sergeants, and 530 police constables, more than at any other Cup Final (a considerable increase in the numbers agreed in the planning stage).



There was a lot of speculation in the press about the number of spectators that had been injured at the event.  Most reports settled around the 900 figure.  The Exhibition Authority’s report after the event states that the actual number could not be confirmed, as the Red Cross had not been counting the cases they had dealt with on the spot, which were mainly fainting.  There were 22 cases which the Red Cross sent to Willesden Hospital.




13.   Reports on the crush and casualties in The Times (broadsheet) and Daily News (tabloid), 30 April 1923.



Immediately after the event the FA issued a statement saying ‘The FA greatly regret the inconvenience caused to the spectators at the match, but wish to assure the public that the arrangements were not in their hands, and therefore they cannot accept responsibility.’  There was friction between the British Empire Exhibition Authority and the FA as to who was responsible for crowd control and at which point.  Letters went to and fro between the organisations, each criticising the other for the role it had played in the event.  Eventually though the FA refunded ticket holders who were not able to get to their seats.




14.   Who was to blame? Headlines from the Daily News, 30 April 1923.


It is difficult to know what caused so many people to descend on Wembley that day.  I suspect a combination of factors influenced people. The Stadium had been advertised as ‘the finest in the world’, and ‘the largest in the world, the most comfortable, best equipped’.  Did people just turn up to “see inside” as evidenced by the ones that had tried to get in the previous Sunday?  Would it have been different if there had been two northern teams? If West Ham had lost the semi-final to Derby?  Perhaps the factor that influenced people the most was the sale of tickets on the day? 



But they did turn up and the problem then became how to manage the situation. Had the Cup Final been held in a Stadium that was finished?  Were the turnstiles of a sufficient construction?  Were the stewards inexperienced? Were the police arrangements sufficient to deal with the disruption?



These are all questions we will never know the answers to.



In June 1923, a Commons Committee was formed to inquire into ‘the arrangements made to deal with the abnormally large attendances at athletic grounds.’ The resulting 1923 Shortt Report concluded it was ‘safe to leave it to the sport’s governing bodies.’



By 1924 the temporary hoarding had been removed from around the Stadium and the turnstiles had become part of the Stadium structure. The Stadium itself had become part of the wider British Empire Exhibition site.



As late as February 1924 the matter of not allowing ticket sales on the day for that year’s FA Cup was still being discussed.  The FA were against the plan put forward by British Empire Exhibition Authority and supported by the police for all tickets to be sold in advance. But eventually they conceded after receiving a letter from the Home Secretary (at the request of the Exhibition Authority), but in their acceptance they declared that they ‘accepted no responsibility for the decision.’



The British Empire Exhibition opened on 23 April 1924 and the 1924 Cup Final was held 3 days later, on 26 April, finishing Newcastle United 2, Aston Villa 0. It passed without incident.



Janet Kear,
April 2023.

With thanks to Philip Grant and Graham Cooksley (Twitter: @wembleyarchive) for their help with fact checking, pictures and editing.



Resources / References:


The National Archive

The Times Newspaper


The Lads of ’23: Bolton Wanderers, West Ham United and the 1923 Cup Final – Brian Belton


Be Fair on the Fun – An open Letter to Brent on councillors’ free rides

 Guest post in a personal capacity by Philip Grant


George Irvin’s Fun Fair at Roe Green Park, 21 April 2023.


Last week, Martin revealed that Brent councillors had been offered free tickets for George Irvin’s Fun Fair at Roe Green Park, on 21 and 22 April. This raised some concerns, because George Irvin is also involved in a planning application affecting Barham Park, which may come before some of those councillors for a decision within the next few months.


In the circumstances, I thought it best to make sure that Brent’s Monitoring Officer was aware about the situation, and that she knew that there would be public interest in how she responded to it. The open letter which I sent her on 25 April is set out in full below. I know that some readers may find my letter hard to follow in places, because it refers to parts of the Brent Members’ Code of Conduct, but I hope that many of you will take the trouble to read it. 


I believe it is important that decisions made by the Council, its committees and their members, are not only fair and impartial, but that we, as citizens of the borough, can feel confident that they are fairly and properly made. That must mean that there should be no suspicion that the people making the decisions may have been influenced by a gift received from, or any personal friendship with, a person who could benefit from that decision.


One of the comments made under last week’s blog was: ‘why can’t residents be on the Barham Park Trust Committee to ensure our park is protected?’ That is a very good question! Why should that committee have just  ‘5 members of the Cabinet appointed by the Cabinet’?  You will see that the final recommendation I made to Brent’s Corporate Director of Governance is that there should be an independent review of the committee’s membership.



This is my open letter:


To: Debra Norman                                                                   From: Philip Grant                              
      Corporate Director of Governance and Monitoring Officer, 
Brent Council.

                                                                                                                       25 April 2023



Dear Ms Norman,


Gift to Brent Councillors by George Irvin, and its implications
for ‘sound and transparent decision making’.


I know that in both of your roles, as Brent Council’s Governance Director and as its Monitoring Officer, you wish to ensure that Council members abide by the Brent Members’ Code of Conduct, Planning Code of Practice and Licensing Code of Practice.


It has become public knowledge (see: ) that the principal owner of the George Irvin’s Funfairs business recently offered a gift of free use of his funfair at Roe Green Park on 21 and 22 April 2023 to Brent councillors, ‘along with family and friends’. I’m attaching a true copy of the blind-copied email of 14 April, containing this offer, in case you have not seen it.


As there is at least one application to the Council, from George Irvin or a company he effectively controls, which councillors are likely to have to decide within the next few months, I believe that the Council needs to be pro-active in dealing with the implications of this gift. 


I will set out my views on this (as a retired public servant, formerly in a role where integrity and fairness were at the heart of my responsibilities), and offer some suggestions / recommendations. I will number these, and put them in bold type, and would ask that you consider these, please, and respond to me on them.


The email to Brent councillors, from the Senior Manager at Irvin Leisure, does not contain the “usual” offer (to use George Irvin’s description from his response to the blog article) of ‘£10 of tokens to all the councillors that can be given to anyone including charities’. 


Instead, it says: ‘we would like to invite you along with family and friends to our Funfair free of charge as I will arrange tickets for you all.’ In order to obtain those tickets, councillors are told: ‘Do confirm to George direct if you wish to attend’, and are given George Irvin’s personal email and mobile phone contact details.


What is being offered is clearly ‘a gift or hospitality’, in their capacity as a member, likely to be covered by para. 31(c) of the Brent Members’ Code of Conduct, subject to the value threshold.


1. I would strongly suggest that, in order to ensure that all councillors comply with para. 31(c), you write to all members of the Council and require them to notify you if they accepted free tickets for George Irvin’s funfair at Roe Green Park this month. If they did, they should advise you, as Monitoring Officer, of how many free visits they made to the funfair, and how many family members and/or friends also used free tickets to the funfair on 21 or 22 April. As required by para. 31(c), they should also advise you of what they believe was the value of the gift they received.


I’ve suggested that you require all members who took advantage of George Irvin’s gift to notify you, as they could easily underestimate the value of the gift, especially if they had family or friends with them. As shown on the poster which formed part of the email, entrance to the funfair was £2 per person. Tokens for rides were 10 tokens for £10, but as the very small print underneath states: ‘number of tokens per ride varies’. 


Roe Green Park is my local park, and as I was walking through it on 21 April, looking through the fencing around the funfair, signs were showing 3, 4 or 5 tokens per attraction (some of the big “thrill” rides may have been even more), or the same amount in £s if paying contactless. This was a typical example:



2. I would suggest that a reasonable approximate value, per person per visit to the funfair, to be applied when calculating the value of the free funfair gift from George Irvin or his company, should be treated as at least £25 (unless a councillor can provide details of which rides etc. he/she and their family and friends went on, and the number of tokens for each). As the rides were being provided ‘free of charge’, they are more likely to have been taken advantage of than if those enjoying them had to pay £4 or £5 for each ride, for each person.


The planning application I referred to above is 22/4128, seeking to demolish two houses in Barham Park (actual address 776-778 Harrow Road, Wembley), and replace them with four 3-storey houses. The applicant is Zenastar Properties Ltd, owned by members of the Irvin family. Although George Irvin is not shown as a director of that company, the architects drawing up the plans submitted in support of the application had no doubt that the client they were acting for was George Irvin, as shown by this example:



There may be other planning, or licensing, applications to Brent Council by companies which George Irvin is either a director of, or where other members of his family are directors but he still has a controlling interest. In view of this, it is important that all councillors who accepted the offer of funfair tickets, free of charge, are identified, and that the ‘gift or hospitality’ they received from George Irvin or Irvin Leisure is recorded in their Register of Interests on the Council’s website at the earliest opportunity.


3. I would recommend that you advise any councillor who has received such a gift that they have a ‘personal interest in any matter being considered by the Council’ under para. 32 of the Brent Members’ Code of Conduct. And that, as a result, they should not take part in considering and deciding any planning or licensing application, or any other matter involving George Irvin or any company over which he may exert some control, including planning application 22/4128.


The second part of the sentence in the 14 April email to councillors (‘Do confirm to George direct if you wish to attend as many other Councillors will be attending’) gives the impression that George Irvin or Irvin Leisure may already have made the offer of free tickets personally to ‘other Councillors’, and that they have already accepted that offer.


If correct, that implies that Mr Irvin or his companies may already have had a business or personal relationship with some Council members. I was already aware of a rumour, mentioned in a comment on an online article about the offer, that George Irvin had ‘attended the wedding of at least one senior councillor's offspring.’ This gives rise to the possibility that George Irvin could be considered a ‘friend’ of one or more, possibly senior, Brent councillors, which would make him a ‘connected person’ of the councillor(s) under para. 30 of the Brent Members’ Code of Conduct.


4. I would strongly suggest that in writing to all councillors (under 1. above), you require them to disclose to you any other contacts or meetings, business or personal relationships, they have had with George Irvin, or members of his family. If any such relationships are disclosed, you should consider whether these amount to George Irvin being a ‘friend’, or ‘person with whom [the councillor] has a close association’. If that is the case, you should advise the councillor that Mr Irvin must be treated as a connected person, they should not take part in considering or deciding any matter involving George Irvin, or any company over which he may exert some control.


This may become particularly important if planning application 22/4128, or any subsequent application in respect of 776-778 Harrow Road, were to be approved. Mr Irvin, or Zenastar Properties Ltd, could potentially make a large profit if they were able to replace the existing two (former park keepers’) homes with four new homes. But to be able to build four homes on the site, they would need to remove the covenant which restricts the site to two homes, and possibly to acquire a small extra piece of the Barham Park land.


Any change to, or removal of, the covenant, or any sale of land, would require a decision of the Barham Park Trust Committee. 


5. I would strongly suggest that any member of that Committee who has either accepted the offer of free rides at the Roe Green Park funfair, or any other George Irvin or Irvin Leisure funfair, or has had any relationship with Mr Irvin or any of his companies, other than a purely business one in their role as a councillor or Cabinet member, should be barred from involvement in any decision of the Committee relating to that covenant and/or any sale of land in Barham Park. Even if the relationship might not meet the para. 30 threshold, in the circumstances of this matter ‘a member of the public knowing the facts would reasonably regard it as so significant that it is likely to prejudice [the member’s] judgement of the public interest’, under para. 34 of the Brent Members’ Code of Conduct.


As you are aware, the Barham Park Trust Committee is currently treated as a sub-committee of Brent’s Cabinet, and ‘comprises 5 members of the Cabinet appointed by the Cabinet.’ This Committee is ‘responsible for the trustee functions in relation to the Barham Park Trust.’ But the Trustee is the London Borough of Brent, which holds Barham Park ‘on trust to preserve the same for the recreation of the public.’


One of those who commented on the blog article which made public the offer, of free funfair rides to councillors, wrote: ‘why can’t residents be on the Barham Park Trust Commitee to ensure our park is protected?’ That is a good question. Is there any good reason why the Committee should be the sole preserve of self-appointed members of Brent’s Cabinet?


6. I would recommend that the question of the membership of, and voting rights at meetings of, the Barham Park Trust Committee is the subject of an independent review, possibly under the auspices of one of Brent’s Scrutiny committees. The independent review should be allowed to make recommendations, which would initially be considered by the relevant Scrutiny Committee, and that Committee could place its final recommendations, if any, before a meeting of Brent’s Full Council.


Finally, in the interests of transparency, I should say that I was one of many objectors to a previous planning application in respect of 776-778 Harrow Road. As a result of this, I received a letter on 18 April 2023 from Brent’s Planning and Development Services, headed ‘PLANNING APPLICATION - THIS MAY AFFECT YOU.’ It advised me of application 22/4128, and said that if I wished to make comments on it, I should do so by 9 May. I have not yet had time to consider the application documents properly, so have not yet decided on any comment I might make.


I look forward to receiving you full response to the six suggestions / recommendations I have made, once you have had chance to consider and follow-up on them.


Yours sincerely,

Philip Grant.