Truman's Public Inquiry PM - Thursday 16 October 2025, 2:00pm

Truman's Public Inquiry PM
Thursday, 16th October 2025 at 2:00pm

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So we can resume.

I ought to report back that at lunchtime,

I did as invited go for a walk around

and took in Grey Eagle Street along its entire length,

both directions.

And I also spent some time around Allen Gardens.

I've done that before,

but same goes for Grey Eagle Street,

but it was useful having just heard the evidence.

We can do it again when we come to talk about site visits.

Unless there's anything else, I'm going to hand over to Mr. Harris.

It's safe to say that the invitation was also to go to Wilkes Street, which you might have done as well.

I did, yes. Sorry about that one.

Thank you. That's really helpful.

Again, I'm not going to cross -examine on the same broad issues,

even though there is notionally at least a distinction

between heritage and townscape,

you will appreciate that there's a fair bit of overlap

in relation to both.

Mr. Reynolds, how are you?

Good afternoon.

Now in this case, Mr. Reynolds, unless I've got it wrong,

for two of the three reasons for refusal,

or sets of reasons for refusal, you were here to represent elected members' position as

reflected by the reason for refusal contrary to officer advice.

That's correct, yeah.

That's what I thought.

And that's what I'm going to concentrate on because they concentrate on scale, bulk,

height, mass, and relationship to the character of the area.

We'll go to the exact reasons for refusal later.

But you aren't a sort of design review panel.

You're here acting for the council,

representing elected members' concerns as stated, correct?

Yes, supporting the position that they took.

Good, thank you.

Second broad thing is you tell us very clearly in your proof,

I think it's paragraph 1 .2 .2, that when it comes to matters of heritage and character

and appearance of the conservation area, you defer to Mr. Frohman in terms of heritage

matters.

Correct, yeah, I focus on townscape rather than heritage.

and there needs to be a sort of consistency of approach,

even if theoretically the two could be entirely separated,

which they can't.

All right, let's start with Eli's Yard, shall we?

Yeah, and again, I'm not going to go through

all of the things that we heard this morning

in relation to Eli's Yard.

I just want to explore a few big picture issues with you.

Eli's yard is in the conservation area, isn't it?

It's immediate and surrounding context and almost all the views that we looked at this

morning are also in the same conservation area, aren't they?

Because it's a big conservation area.

Now, Parliament has decided that the protection for conservation areas is to be set out in

different terms to the protection for listed buildings and their settings, hasn't it?

I don't know. That's not the heritage point, probably, rather than a task.

Well, that's what I was wondering. You see, what Parliament has done in terms of conservation

areas – and you've referred to this once or twice in your proof – but what Parliament

has done in relation to conservation areas is that they are statutally protected and

you're required to give special attention to protecting the character and appearance

of the conservation area, correct?

Correct, yeah.

Fine, good.

Good.

And if I look at the reason for refusal for Eli's yard,

as expressed in the reason for refusal,

it's your proof, 212 for example.

Yeah. Is it 217 in fact, 217?

Yeah. We see that the reason for refusal that you speak

to is height, bulk, mass, resulting in incongruous and overbearing addition to

the local townscape, failed to respond appropriately to the character of the

Truman Brewery estate and surrounding streets. All of which are in the

conservation area also. Okay, good.

Now, Mr. Frohnemann finds that the character and appearance

of the conservation area in this area is, in fact,

preserved by the proposal.

Did you hear that yesterday?

Yeah. Yeah.

So did the local planning authority

in terms which we've seen.

And you defer to his assessment in terms of character and appearance of the conservation

area, you tell us.

For heritage, yes, not for telescope.

Yeah, but it must follow that any impact, if you are deferring to Mr. Frunerman, if

you defer to him, then any impact which you identify, whatever it does, falls short of

being a harmful impact in terms of heritage.

That's Mr. Frohnemann's assessment.

No, but it also means, when you look

at the totality of your case, that when

you say something's overbearing or harms a view of Christ

Church, we defer in this case to Mr. Frohnemann, who

doesn't find harm to Christ Church

and doesn't find harm to the character and appearance

of the conservation area as a result of Eli's yard.

Do you see my point?

So you can have your own townscape position,

but it never escalates sufficient to mean

that you give rise to a harm to the character

and appearance of the conservation area,

because that's not your case.

Not the character and appearance of the conservation area,

but it doesn't mean there's not harm, in my opinion,

to the townscape.

I understand, but it can never.

I don't think in my evidence I say

that there is harm to Christchurch,

with not for this scheme, because I'm

talking about the view on Grey Eagle Street,

not the view from within the brewery.

Yes, I know.

Just to pick up on that point, I think

I did hear you say we've heard about harm to Christ's church

this morning.

Remember when we were looking at,

Specter's just been up there.

That's not the case of the local authority, is it?

No, so the case of the local authority

is that there's no harm in heritage terms,

i .e. setting, et cetera.

Yes.

That doesn't mean that there can't

be harm in terms of the value of that

as a marker in the landscape, the same as any other building.

But even again then, the weight to be

given to that's a matter for the inspector, obviously.

But it can't escalate to the point

where it is a heritage harm which

has special weight and importance

as a result of the requirements of statute.

And it's important that we don't intrude that.

I think I've been clear in my proof

that where I talk about harms to townscape,

it is as a townscape issue, not as a heritage issue.

Oh, I know.

But character and appearance is relevant to both, isn't it?

And what we've got is a witness from the local authority

to whom you defer telling the inspector in terms

that none of the harms, in terms of overbearing or, as you

suggest Eli's yard being too big and dominant.

None of those escalate to being a heritage harm.

They can't.

No, but I think there is an important distinction, which

I'm sure the inspector is fully aware of and able to make,

between townscape impacts and heritage impacts, which

are effectively around the special character

of the conservation area, why it's designated

a conservation area, et cetera.

No, it's about character and appearance in the round,

but for sure.

Yeah, I'd probably disagree.

Because I think if it wasn't a conservation area,

you wouldn't say, well, it's not a conservation area,

therefore there can't be any harm to townscape.

No, no, nobody's saying that.

Nobody's saying that.

So you've got the difference between us crystallised.

Good, thank you.

And I'm not going to take that much further.

I'm going to pick up on the two points, though.

that rather, if you don't mind me saying,

go way beyond elected members' position

as reflected in the reasons for refusal

or even in the Rule 6.

But can we deal with this connexion issue

that you have, which you took a learned friend

through this morning?

There's no mention of that in the reason for refusal.

There's no mention of that in the Rule 6.

It was never a point that was raised as being important

by either conservation officers or other officers.

What they did was identify that that was a benefit,

a significant new route, and something which would enliven

Great Eagle Street.

I mean, go to it if you like.

But the point that you raised, a very specific point there,

if you like, it's a Reynolds point.

It's not a Reynolds point.

I think, as I said, that there is

a benefit for the connexion, which is said by others.

I'm highlighting that I think that benefit is not a significant one, which is to aid

the inspector in the way he feels he should place on that.

And I think it is referred to in the policies that are cited, so for example, DH2, attractive

street spaces and public realm, is one of the reasons for refusal policies.

But for sure, these points have not been raised before, and there's a duty on local authorities

and those representing them, including antiquaries of this nature, A, to consider whether it's

good point and you've heard why we consider it's not and you probably hear

it again but B to consider whether those sorts of difficulties there's a tree in

the way for example you say we say well that's not harmful but if there is a way

of ensuring that this benefit of a significant new route which you said

would be a very large benefit could be secured in a Reynolds friendly way by

way of a condition then you should consider that shouldn't you yeah surely

inspector will. No but have you? The duty is on you to consider whether your

your concerns about the connexion not being as powerful as it could be if you

think it needs to be more powerful. That's exactly the sort of thing that

could be dealt with by way of a condition isn't it? Potentially it could

be however it would require a redesign of an element of the scheme. So my

role is to to comment on the scheme that's been put before members and the

members have decided to refuse planning permission for.

My role isn't to redesign the scheme to make it acceptable.

No, your role is, if you look at the Pins Blue Book,

to consider the reason for refusal,

to consider in terms whether there might be a condition

saying, for example, as we often see,

notwithstanding drawing XXYY,

a scheme for the rearrangement of the entry

should be submitted to and agreed by the local authority.

That's part of your role.

It is, but I also have to take note of the drawings which are before the inquiry as the

drawings for approval.

And those drawings are what are on those drawings.

It comes back to my point around I'm not able to redesign things to make them acceptable.

I'm just highlighting that as it stands, as the drawings are tabled before the inspector.

You're just denying the role that you've accepted you have, which is to accept whether

condition or something could deal with your concern but I think we've gone over

that as best we can. Vue 36 next I don't think we need to put it up but this is

the view along Dray Lane is it which is to the open space yeah upon

which Eli's yard presently is.

Now, we know that that space is not a historic space.

We got that yesterday.

And in townscape terms, I think we know and understand

that that is definitely one of these sites, which

Historic England and others pointed to,

as being a site which could enhance the conservation area,

but also make a contribution in terms of sustainable development.

It's an empty site, yeah?

Yeah, I don't deny that.

Good. And so the planning system should be striving to ensure

that the use of that site is optimised, shouldn't it?

Correct, yeah.

And if in a different world you were to put another building

on that site, one that found favour with you,

even though it doesn't harm the conservation area in terms of character and appearance,

then that view of the open space would be lost in any event, wouldn't it?

It could be, but I'm assessing the baseline situation, which is in an open square, not

what was there 30 years ago, versus the scheme that's before me.

There's no part of the council's case that that should remain an open square, is it?

No.

So the loss of the open square as a harm is a pretty strange thing to be

asserting because the local authority should have and do have extant and

emerging plan do have plans and hopes that that development will take place in

a way which will make a better use of a brownfield site with a PTAIL of 6B.

I don't recall, and apologies if it came across that way in my evidence, I don't recall objecting to the loss of the open space.

What I recall objecting to is the design of the building that's been put there, which doesn't suggest that there's anything beyond it.

For example, if you were to switch the floor plan around so that the large double height open food hall was at the end of the Dre Walk view and the office entrance was on the other corner,

then some of my concerns would go away,

because you would get clear visibility down.

That's really helpful.

So it's a design of the building point.

It's not an objection to the loss of the open space.

I hope that's clear in my evidence.

Well, certainly not from your evidence in chief,

because you said you'd lose the ability to see that activity,

to see everything that went on there at present

in terms of open space.

And of course, you do that.

In terms of activity, I don't think any of that's

reliant on it being an open space.

All right, good.

That's really helpful.

Thank you very much.

So any development there would mean

that the activity that's presently

available on the site, the open activity that you spoke to,

would go.

Your concern, you're saying, is with the disposition

of that building in that view.

It's the appearance of it.

It's a core point of the townscape.

It's about how that works.

As you look down that view, at the moment,

you've got active frontages all the way down

on the left -hand side, tables, chairs,

people sitting outside.

It's very clear that that's somewhere you walk down,

comes back to the point around active frontage.

What you see at the end, and it's more obvious

the further you go along, as we saw in the architect's image

is that's not an active frontage,

it's just an office entrance.

Right, well, we'll hear from the architects

on that in due course, thank you.

And of course, what we've got from the local authority

in relation to this is a consistency of position

between what is said in townscape terms and what is said

in heritage terms as opposed to the inconsistency

that we've got I would suggest between you and Mr. Fronman.

Can we look at it please?

Because I don't think we've looked at it yet.

So you need to pick up the committee report.

And this.

Yes, Eli's Yard is CDL03.

Yeah. Good.

And I know you've read this because you said so.

Yeah. And I don't ask that we read it all, but the conclusion is set out at 846 in terms

of design, and having referred to the new pedestrian route in 843,

the primary ground floor frontage of the building opening out into Eli's yard,

The proposal introducing five upper floors of windows overlooking Grey Eagle Street,

compared to the existing scenario with no surveillance overlooking ... balconies,

etc., ground floor external lighting, etc.,

concludes that the proposal responds appropriately to its immediate context

in respect of scale and massing.

Proposed building would be acceptable in respect of detailed design,

make an important contribution to the activity and surveillance at Grey Eagle

Street that's their conclusion in relation to in relation to townscape

and then we go over the page and we start in heritage terms yeah and we've

got the assessment there set out in particular that 857 the proposed

building has been designed to respond to the industrial scale and character of

the estate part of the conservation area be visible etc deals with Christchurch

in view 35 in conclusion there'd be no harm to the conservation area or nearby

listed buildings from the proposed development now here I don't expect you

to agree with all of that and I'm not even going to waste my time asking you

the inspector will take all that into account but but there we've got a

consistency of position in terms of character and appearance,

however defined.

They are finding in architectural terms

and in terms of townscape that it's

acceptable and appropriate to its location and character

area, et cetera, and also in terms of heritage terms,

in terms of heritage impact on character and appearance.

And there's a sort of internal logic about that, isn't there?

I don't agree.

I think it could be that Heritage and Townscape are the same.

And theoretically.

It could be that Heritage and Townscape are different.

That's true.

In this case, officers have found it to be the same.

We know that.

They recommended it for approval.

The reason I'm here is that I agreed

with members who felt that Townscape terms

wasn't acceptable.

And I support that view.

The reason Mr. Frohnemann's not presented evidence on this

he didn't feel that there was a heritage issue.

Well, let's be honest about this.

The fact that we have a different opinion

doesn't mean that there isn't a townscape issue

because there isn't a heritage issue.

I mean, in a purely platonic world in which anything

is possible, I'm sure that's the case.

But can we remind ourselves of this,

that when elected members resolved to refuse permission,

and you know where this is going,

they resolved to refuse permission because the bulk, height, mass, etc. were

harmful to heritage and townscape, weren't they? So they did think that

there was a consistency of approach and that it was the same impacts which gave

rise to those twin harms. Now what happened was Mr. Frohnemann came along

and said, well, I've looked at this,

I've looked at lack of impact on Christchurch and et cetera,

I can't support elected members in terms of that, correct?

It's actually exactly what happened.

Because what happened was members said

there was an impact on heritage and townscape.

Yeah.

Mr. Frohman was appointed before I was,

and I was asked, or I was told,

it had been refused on grounds of heritage and townscape.

Mr. Frohman had said he didn't feel

he could support the heritage, did I feel I could support the townscape? And I assessed

it and I said actually yes, I think there is a townscape point on those grounds, bulk

scale massing etc.

But one, in a huge conservation area which never passes the threshold of harm in conservation

terms.

I'm not assessing the threshold of harm in conservation terms.

No I know, but it must be the case that everything that you've said about overbearing, everything

that you said about impact on views.

Yes, I accept.

Theoretically, it could be an appropriate thing

to say in townscape terms.

But it never in a conservation area

breaches even the less than substantial harm

at the lower end of less than substantial harm.

That's Mr. Frohman's findings.

No, no.

It is the case being put by the local authority, isn't it?

In heritage terms, yes, but not in townscape terms.

Well, no, no, no.

The two have to be read together.

All right, thank you very much for that.

That's the end of that issue.

Next issue, I want to go to the main site.

And I'm going to go to the main site without block J

for a minute, and to 3A and 3B.

And again, here, the reason for refusal quite clearly

highlights dominant bulky form, which Mr. Frohman says

gives rise to a heritage arm.

So there's consistency there.

undermining the character of the local area,

all of which is in the conservation area.

So on this one really, there's a bit of overlap

and all those points were put by me to Mr. Frohnman yesterday.

I'm not going to put those again,

but I do want to ask you this, please.

The inspectors just been to Allen Gardens.

Yeah.

Yes.

Allen Gardens is a large scalar element of the townscape, isn't it?

It's a large open space, yeah.

It's horizontal and flat, but it's huge in its scalar presence, isn't it?

It's a large open space, yeah.

It's not fine scale or delicate in the way that you describe the character of the conservation

area as a whole. This part of it is not fine scale and delicate, is it?

I don't think I describe the character area of the conservation as a whole as fine scale

and delicate.

Well, we could go to it if we need to, but let's just see. Let me come back to that,

because you certainly do. But it does not necessarily – here we are. The urban grain

of the areas defined by streets and internal yard.

The rhythm of narrow shop fronts and frequent doors,

as can be seen along Brick Lane, maintains the area's fine

urban grain.

You say.

Sorry, which paragraph?

Paragraph 227.

In relation to the Truman Brewery estate as a whole?

Yes, so not the whole conservation area.

I'm talking about the Truman Brewery estate.

OK.

All right.

That's why it's under that heading section.

It doesn't really make a difference from my point.

Allen Gardens is not a small -scale, fine -scale intervention in the townscape, is it?

No.

but it's not within the treatment brewery estate.

OK, well, it doesn't really matter.

Now, let me ask you this.

You've heard from a number of architects

sitting on this side of the room who you will know and

understand in general terms.

Doesn't mean in this case they're any good,

but are at the top of their game.

They're world renowned and understood

to be architects of the finest type.

Yes?

I heard all about their awards, yeah.

Yeah, yeah, yeah.

Good.

Well, this site has got an award, which no doubt they'll tell you about.

Apparently so.

Already, yes.

I would liken it to saying an Oscar -winning actor could still make a bad film.

Yeah, yeah, yeah.

I think that was involved in my question, wasn't it?

But we've got this large scale element of Townscape,

which has been introduced into the area

after the closure of the brewery, haven't we?

Sorry, you're referring to Allen Gardens.

Allen Gardens, yeah, yeah, yeah.

I'm definitely referring to it.

Because you heard our architectural team

explain that that was a feature that

needed a response in terms.

It's definitely part of the context of the site.

Yes, good.

And they explained that it's a robust, large -scale element of the townscape that is robust enough

to accommodate some height on the application site.

Yeah, I heard that's what they said.

And do you agree?

I agree that it's a large -scale site.

I agree that it can accommodate some height.

But I also note that when you look at, when you're doing this, when you're undertaking

any kind of site design exercise, you look at the context in the whole.

You don't just say, well, there's a large space opposite, but it's surrounded by small scale

buildings, therefore, well, we're going to pick the large space and respond only to that.

So I think it's a balancing exercise between all the different elements.

And you really unfairly characterise what Mr. Euermann said he did. He didn't just say,

well, there we are.

No, I'm not saying that's what I did.

I'm just saying my view is that, yes, I

knowledge that there's a large open space office there.

But I don't think that's the only thing

that you could bear in mind.

And that would have been true of those that fed into the SPG,

those that fed into the design capacity analysis,

and those that fed into the emerging plan as well.

Because every single response to this site,

which has come from any hand with any degree of skill,

has had large scale responses to the new large scale scalar

element, which is now Allen Gardens, hasn't it?

They've certainly had larger scale

than is there at the moment.

But I don't think they're as large a scale as we see

before us in this inquiry.

I mean well for a simple fact as I said during my evidence in chief, I think both the SPD,

the quashed SPD and the capacity study look at residential solutions.

Yeah they do.

So an equivalent height I think is seven storey or seven plus one.

So you know that automatically will be seven to eight metres lower than the buildings we've got here.

No forgive me.

Just purely by the fact that they're of different use.

Sorry, you're just simply wrong in relation to that.

If you look at the SPD and you look at the other things,

they are of a height.

And you can judge the height from that.

And what we're talking about here is a height, not

a relationship of storeys.

I don't want to go into great detail with you in relation

to that, because I'm only trying to establish the principle

that you don't put a two or three storey building here.

It's a matter of judgement as to what you do.

But the right response in this location

is, in townscape terms, from everybody

who's tried to do it to get some heightened bulk and mass

to respond to the new Allen Gardens

element of the context.

Not only that, but everybody who's done it

has done that, haven't they?

So everyone who's done it has put an element of height.

I don't think I said that it should be two or three storey

buildings, anyway, were evidence.

I think all the other alternatives I've seen are lower than the scheme before us

Yeah, I think you've said they all say there should be an element of height bulk and mass. I don't think that's true

I think certainly the

Community scheme for example that may have heights, but it doesn't have the same bulk and mass

So again, I think they're all very different in the approach they take I would totally agree with you that it can be high

I'm not suggesting it should be a two -storey building.

But I don't think that the height that's proposed

is acceptable.

And in fact, I think in the officer report,

it suggests they should be one to two storey lower.

One storey lower.

But then it's a matter of judgement, isn't it?

But what we are agreeing on is that in townscape terms,

this site is an appropriate site to make an appropriate gesture

in relation to its entire context,

but including Allen Gardens.

Right, good.

Thank you.

That's really helpful.

Block J next, please.

I'm just going to ask you this question.

Townscape is about improving things and potentially

about taking all the opportunities you

can to make things as good as they can be.

Townscape.

Yeah, I'm broadly summarising.

But I just want to see how far you take Block J

and your analysis of it.

We all walk down there at lunchtime.

How would you characterise the existing townscape contribution

of the two sheds which are huge in scale

and the large scale car park?

Minimal?

So minimal suggests that it's positive, but in a small way.

Doesn't it? Because that's what I've read from your proof. But that's nonsense, surely.

Well it generates a lot of activity.

Yes. In townscape terms, please.

Positive, yes. activity is an element of townscape. So I think from that point of view it's positive.

I think the art wall which is being repainted at lunchtime today, I think that's probably

a positive part.

Our ideas are better than yours.

A part of the townscape.

So I think there are elements to it that are positive,

but I'm not gonna say that it's a outstanding

architectural contributor.

So we start up here with outstanding

architectural masterpiece, like the Shard or something,

and I'm asking you about the cash and carry.

Yeah, I would say it's down to the people.

So I'm asking you to accept that the existing

townscape contribution of the cash and carry

and the blank car park is harmful in a significant way.

to the character and appearance of the conservation area.

I wouldn't say that it was harmful,

but I would say that it's not very beneficial.

Right, so what have you got then?

We start from the proposition that the cash and carry

is a positive contributor in the conservation area.

I'm not talking about it.

Or in townscape terms.

No, because I'm not talking about its contribution

within the conservation area.

I'll recast the question.

Because the conservation area is a heritage issue.

I'll recast the question.

I'm talking about it from a townscape.

In townscape terms, it's a positive contributor

to the townscape.

I don't think it's a negative one.

I don't think the townscape around there

is particularly brilliant, full stop.

I'm going to try one last time.

You don't think it's positive or you do think it's positive?

I think what I've said in my proof is it's very low positive.

That's my point.

And you're going to stick with that?

I am.

All right.

Well, that's like a benchmark.

I don't really mind which way that goes.

And then do I take it?

Because it's not expressed in these terms in your proof,

that Mr. Henley's architecture actually

worsens the position in townscape terms

from that which is there.

Is that your evidence?

I don't think that's what I say in my evidence.

Well, it must be, mustn't it, because you ascribe it

townscape harm.

You see, here I want to understand from you where exactly you are putting your case here,

because I couldn't understand it from the proof.

You've made it clear that you think the cash and carry is positive, albeit minor.

Are you saying that Mr. Henley's architecture worsens the position in terms of landscape?

Let me just go back to my assessments where I've set it out.

It's fairly fundamentalist though, isn't it?

Well, I just want to be clear what I've written in mine.

I can't remember what the view is now, is it?

View 19, view 19?

Well, there are a number of views. We've got the cash and carry on, view 19.

Yeah, so in view 19, yeah, so I've said on those ones that it's adverse, yeah, as a change

to the baseline.

Yeah, yeah, no, but that's why I'm asking you the question.

I wanted to really understand that you were telling this inspector that the baseline was

positive and that Mr. Henley's architecture made it worse.

I'm saying that it's an adverse change to the overall townscape.

So that's what you're saying?

Mr Henley's position, just in straightforward townscape terms.

Hang on, not just in straightforward townscape terms, because in townscape terms I'm talking

about in view terms.

Yeah, yeah.

So that's visual assessment.

So you have townscape assessment and visual assessment.

Okay.

So what I talked about there is the visual impact of that scheme.

Right.

So that's on the whole viewpoint.

The townscape assessment is a completely separate thing, which is set out, if you go to my appendix

and set that up.

I did that too.

That's why I'm asking the question that I am.

Are you really saying that the cash and carry is better

than Mr. Henley's architecture?

And you can include use in that as well, if you like.

Because use is important, isn't it?

And this is much needed housing.

It's not.

I don't think I make that assessment that you're asking.

I'm asking you to make it now, because it

must be a material consideration for the inspector

that if this proposal, in townscape terms,

is better than that which is there,

that weighs in favour of the proposal?

I think it's an improvement over what's there at the moment.

But I don't think it makes a material change

to the townscape character area.

I forget which one is it.

I'll have to pull the plan up.

I can ask others about that in due course.

So it's an improvement in townscape terms

to that which is there?

Yes, right.

Why doesn't that come in the proof, please?

I didn't realise that it wasn't in my proof.

Yeah, well, you know it might be said as mr. Froman says of the yard

It might be said that it's sort of

Bleeding obvious it might be said that if you formed that judgement it was important for the inspector to know and understand it

What do you think but what I've what I've done is I've done an assessment of the townscape which is in my table

Yeah, I've done an assessment of the two view points that you can see the building in three

which are in my table, so that is set out before the inspector.

And I've also set out in my main narrative what I consider to be the issues with the

building.

Yeah, I know, but what…

It can be an improvement, but not be the perfect solution.

Ah, that's exactly right.

And I think there are a number of problems with the building as I set out in my evidence

in chief earlier.

It's an improvement, but not the perfect solution.

Correct, yeah.

All right.

Well, I think if you put it that way, we'd have all understood.

We wouldn't have agreed, but it would have been clearer than the way that we've got at the present.

I'm going to ask now the same issues with Block A, please.

Block A, because the same approach applies, what's the existing contribution in townscape terms of Block A?

Limited.

A positive?

Are you saying that's positive?

I don't care which way this answer goes.

I would say it's actually neutral in townscape terms

when you look at it and the overall townscape.

It's not detracting from the overall townscape

because the overall townscape isn't very good.

Okay, okay, I've understood that.

And again, please,

there is a general proposition

throughout the various documents

that the architectural approach to the data centre,

come back to the use of the data centre in a minute,

is high quality.

I want the judgement in the same terms

as I asked the last question,

as to whether you are in fact saying, in truth,

that the data centre is more harmful

than the existing dilapidated building.

I wouldn't say it's more harmful, but I wouldn't say it was an improvement.

So it would be a very fractional improvement.

As I said, I think the entrance provides a very limited amount of active frontage, which

would be an improvement.

But overall, I don't think it's an improvement.

Fractional improvement I've written down.

Is that accurate?

Yeah, I think so.

Right.

So better than that which is there.

We'll come on to activity in a minute shortly.

Now, there's no objection either in the Rule 6, in the reason for refusal, or in the report

to committee to our data centre in principle being located at that site, is there?

No, and I don't have an objection to it.

In principle, land use terms.

However, you have to assess everything on its site.

And I don't think, irrespective of how good or bad an architect might be, that you could

come up with a data centre design that would be suitable for that site.

Hang on, that's an in principle objection then, isn't it?

No, it's not actually.

No, it's different.

All right, well let's see whether we can pass the difference between us here.

So you're accepting, as does now, the statement of common ground in draught, that a data centre,

a BH use on that location is in principle acceptable.

This local authority has granted three data centres in the conservation area in the last

five years, hasn't it?

I guess so, yeah.

We know, we've got them all before us, including for example on the northeastern part of the

main site.

Yes.

And it must have thought in principle that a data centre with all of its concerns, et

in principle was acceptable.

As I said, I don't object in principle,

but just because something's acceptable in principle,

it still has to be looked at on its individual merits.

I think we're agreeing.

And I'm saying that I can't imagine any data centre design

that would work on this site.

That's not to say you couldn't put a data centre there,

but if you were to design something that was acceptable,

I suspect it wouldn't work as a data centre.

That's not the same thing as saying a data centre is not an acceptable use.

Well, I mean, let's agree to disagree on that because what you're saying is in

townscape terms the data centre is never going to work there. Therefore, in principle, you

can't put a data centre like that in townscape terms.

What Mr. Froman says is there are other data centres on the campus which are acceptable.

Yeah.

And they're acceptable for a number of reasons. So your concern is not about the principle

of a data centre which has been designed and can be designed and is in fact in

existence on the site. Your concern is about the particularity of this one and

in particular its activity position. Well it's the overall design of it is what I've stated.

Yeah, yeah, I've understood that. Okay, yeah, sorry, I should refresh my position. So yes, you could design, you could design a

building for this site, which I think would be acceptable. That building could be

a data centre, but what I would suggest is I suspect, and I might be wrong, that those

two things would not be an acceptable building and a data centre would not be compatible.

That's not the same thing as saying a data centre in principle cannot be located.

I've got you. And now I understand where you are, and I think you are saying a data centre

in principle could be acceptable. One of the things that you're particularly concerned

about is activation.

Amongst others.

Yes, well let's deal with the activity please.

The existing site has no activity,

apart from the odd drug deal.

In terms of activity, the existing site is harmful.

I wouldn't say it's harmful.

It doesn't have any activity.

OK, but you like activity, so not having it

is harmful, isn't it?

Yeah.

Yeah, I would say it's negative.

It doesn't remove any activity.

activity thank you now we need to be careful about this part of the

conservation area and this part of the sort of planning makeup this street has

been specifically left out of the town centre designation hasn't it

well it's not in the town but it's been specific you can see where the line has

been drawn it's excluded I don't know why that is the case but you know it

means that the policies relating to activity and active uses etc that are

specific to town centres don't apply here. We know that the existing site has

no activity whatsoever, in fact if it has activity it is negative. Yes?

It has no activity yes. And if there is activity it's negative.

On the basis that it tends to be criminal.

Mostly criminal and or people parking for no particular reason.

Well yeah, the other day when I was there, there was a group being shown around doing a street art tour.

Well that's activity I suppose.

That will continue of course.

Now, can we agree that in activity terms, in activity terms, the proposal will be better

than the existing?

I think I said that in my proof, yeah.

Yeah, good.

Thank you.

And of course, you've got to look not only at this in principle acceptable, as we'll

are, but you've also got to look at what the officers did, which was to take into account

the overlooking, the activity, the new entrance in relation to Eli's yard.

That's all better than existing as well, isn't it?

Well, for Grey Eagle Street, you mean?

Yes, they've said that in the officer report.

Yeah, well, but it's true.

But not for Block A, because obviously Block A was recommended for refusal.

No, no, no, but Block A in terms of its activity can be activated from Eli's yard and from

the new access and you already agreed that in its own right it's better than that which

is there.

Good.

Okay, that's great.

Thank you very much.

I think I qualify it by saying that it could be a lot better than it is.

Yes, yes, it could be perfect.

around the viability of the retail unit and issues around the overseeing because

it's a commercial building it will be daytime yeah so that nighttime there

won't be that overlooking so I think I've understood that but what we've got

is a much -needed use which is in principle acceptable which is in

activation terms better than we've got no and I would say literally by a street

but we don't need to fall out about that and you'd agree it it's better than

Yes. Yeah.

All right.

Good. Thank you very much.

So that's all I ask.

Thank you both.

Yeah, there's nothing particular I want to ask.

I think I've rehearsed all my questions.

Mr. Flanagan, did you have anything in re -examination?

Thank you.

Yes, just a few questions, Mr. Reynolds.

In terms of the connexion between Eli's Yard and Grey Eagle Street, it was put to you in

cross -examination that there's no mention of it in what's called the Rule 6, which I

take to be a reference to the council's statement of case.

Can you just turn that up, CDI .01?

And in when you get there.

Sorry, CDI 01.

That's correct.

Hopefully that should be the town hamlet.

The main document or the six zero.

Or is it one of the appendices?

It's the main document.

Yeah.

and in the main document if you go to page 17 paragraph 6 .17 yeah so this

being the council's formal statement of case for the appeal and in 6 .17 pick it

up from line 4 the scheme introduces a narrow and ungenerous pedestrian route

between Eli's yard and Gregor Street yeah which fails to improve visual

permeability and represents a missed opportunity

to enhance connectivity and public realm quality.

Do you agree or disagree with that assessment?

I agree. The, it was, in cross -examination also,

it was put to you just now that you could conceive

of a condition requiring a new plan for you

to replace existing plans.

So this statement of case is dated,

you see on the front page, page one,

the 22nd of August yes have you mr. Reynolds in the

appellant's proofs or rebuttals since that statement case which was producing

any suggestion of how you might do what's being suggested now by why have

you plan no thank you the other point

End of cross -examination about data centres on this site or this street, Grey Eagle Street.

And there was reference to the officer's report about lack of in principle objection

to data centre use.

You remember that?

Yeah.

I'll just take you to that to see what you agree with or disagree with.

If you go to it, it's CDL .02.

Yeah.

And on the front page, this should be the office report

for the Greigle Street, Calvin Street site.

Yes.

And within that, if you go, please,

it's page 30 of the PDF.

And it's paragraph 8 .44, I was going to ask you about.

Yeah.

Paragraph 8 .44 states, in conclusion, the assessment of the application demonstrates

this is an inappropriate location for a data centre in respect of the design, scale, and

and lack of active frontages?

Yes.

Is that accord or not accord with your position?

Yeah, that aligns with my position.

That's my position.

I have A14 that I don't know.

I don't think you took the witness to any paragraph,

actually, but that's.

A44.

We didn't go to any paragraph.

I don't really.

Well, I didn't.

I referred to A14.

I understand it's A14, but it's just inside.

OK.

Mr. Reynolds, perhaps if I deal with it

Five questions.

Mr. Reynolds, if you look at 814 to which we're being referred,

have you read that?

I think that.

Just pause.

Have you read that?

I have, yeah.

In your view, do we read that alongside or not

alongside paragraph 844?

Alongside.

I think those two paragraphs together

are exactly the position that I made.

It's not an in principle objection.

It's an objection because of the scale massing design

of the building, effectively.

Good.

And in terms of 8 .44, your concerns,

I think you said it would be theoretically possible in your view to design a data centre,

design of

Building with data centre use that didn't have those issues

844 as we've just seen talks about this being an inappropriate location for a data centre

How do you understand that corresponds to your what you've expressed about the

Theoretical difficulties of getting a data centre within an acceptable design on this site

Yeah, I mean again it kind of summarises exactly the position that I was taking because it's saying here. It's inappropriate

in respect of design scale and lack of active frontage.

So, I would agree, I don't think you could get a data centre here,

but it's not an in -principle objection.

Good.

The final point puts you on a number of occasions

about something being...

The pros will be better than what's existing.

In townscape and visual terms, your approach,

does better than existing make it acceptable?

No.

Thank you, Mr Reynolds. That's the re -examination.

I wonder, Mr Rose, could you expand on that last answer that you gave?

Why is better than what's there not acceptable?

Because MPPF tells us that only good design should be approved,

which means that poor design should be refused and mediocre design should be approved.

So something is capable of being better than is there now, but not being good design.

And I think that's fundamentally the point.

That's very helpful.

So essentially what you're saying is that something that fails to take the opportunity in design terms that's there.

Absolutely. Yeah, and I think the wording of, you know, I mentioned a couple of the paragraphs in the

public realm policy in particular

all refers to that and it says about, you know, you should be maximising the benefits, doing the most you can, etc, etc. So

you know, a lot of what we're talking about is yes, it's better, but it's not what it could be and should be.

I understand that's very helpful. Thank you. Thank you both.

Good. Thank you, Mr. Reynolds then. We're just coming up to three o 'clock.

Nice round figure. I'm going to suggest we break because we'll need the changeover. Mr. Yeoman, you told me is up next.

I could have just attended him.

Uh -huh.

He's already introduced himself, so I don't even think I need to do that.

Okay. Okay. Well, we'll resume at 3 .15 then. Until then. Thank you.

Miss Cross's determination. Okay. Have you, are you going to go first, and then Miss Curtis afterwards?

Is that how you planned it? Or Miss Curtis, were you minded to ask some questions if there were any left?

Yes, I think the plan was for Mr Farner going to go first and then myself afterwards.

Yes, and there's no chief, is there? No chief, sorry.

Yes, I was just telling the witness, as I explained earlier. Thank you very much.

Thank you. Over to you then. Thank you.

Yes, sir, with this witness it will be short and sweet actually.

Mr Yeoman, to explain to you, good afternoon, and everyone else,

In your proof, you helpfully say that the block specific

architects are best placed to evidence and explain

the merits of their own designs.

So that's Mr. Morris, as I understand, for blocks A,

Eli's Yard 3A, 3B, and Mr. Henley for block J.

Those are the particular focus of the objection

from the council, so on that basis, I'm gonna ask

Mr. Morris and Mr. Henley about those buildings

rather than duplicating questions to you.

And I've only got one relatively short matter

to ask you about, if I may.

It's about the public realm and how

it might be affected by bulk and scale on the main site.

If you go to your proof, please, at page 234.

I'm at 200, so I'm getting close. Let me know when you get there.

Yeah, will do. Yeah, 234.

Yeah, so at 234, we've got a layout of the main site.

And you've put, hopefully, the distances of the various yards

and lanes and passages.

And Cooper Ridge Passage, I don't

think it's labelled as such, but I

think everyone knows which one it is.

It's the one between 3A and 3B in the northeast corner.

Yes.

We can see that that's 5 .3 metres wide.

And we can see the width of the other passages or lanes on the scheme.

6 .8 for chimney.

Lane 8 .3 for the passage going down to 7 .1 between the two yards.

6 .1 going out to Spittles Street.

In terms of the main application site, Cooper Ridge Passage,

it's the longest of all of them.

It's also the one that connects to the important public space

of Allen Gardens, yet it's the narrowest. In design terms, making the longest route

and the one that goes to the important public space is the narrowest, it doesn't

optimise and doesn't best take that opportunity, does it? I'd refer you back

to one of my earlier pages on, within my proof, page 79,

which talks about the hierarchy of the routes.

Yes, you are right, that it's 4.

Sorry, 5 .3 metres wide.

But Brick Lane is actually only four,

and that is a very major route going up through there.

So I don't agree that 5 .3 is narrow or that it's perhaps inappropriate for the link to Allen Gardens.

I do accept that it is the narrower route compared to other ones on that particular drawing 2, 3, 4.

But I think as I said in my presentation yesterday, what we've tried to do is capture a series

of hierarchical routes which reflect and add to both the Truman Brewery site itself, but

also to the wider conservation area.

So if you take it in isolation, it's 5 .3.

I'd argue 5 .3 is a good width.

It's wider than some of the other routes around.

For example, Woodsteer Street.

It's very close to the width of, to Hanbury Street.

All of which are very lively, very well used, and lead people to and from them successfully.

Thank you. Just picking up one point of detail.

If you look at page 234, there is a width for Brick Lane and it's 8 .4, not 4 metres.

At that point it is, it's narrower as you move further back in terms of the actual width

of the road. Sorry, on page 79. But I can confirm that back to you as an exact dimension

if that would help to make sure there's no confusion.

On page 79, you're obviously looking at it.

You say there is a four metre width there.

I think it would just be worth checking

if that excludes pavement, because it is obviously

quite a jump down from 8 .4 to four metres.

Perhaps that could just be checked.

Yes, sir.

Very happy to cheque that and come back to you.

I think it still, you would agree that hopefully

the dimension of Hambridge Street that I referred to being as five metres, which again we walked

around at lunchtime, I think everybody sort of had a stroll around there. So I just make

the point again that I think whilst you've rightly identified that Cooper's Passage is

the narrower of the routes that we have designed or I have designed, I don't think 5 .3 is a

Thank you. Just one related point on that. If you, it requires you to take up the

officer report, so that's CDL, different document CDL 0 .01.

CDL.

CDL 0 .01. That's correct, yeah.

I see agenda, is it?

Yes, I think the report follows it.

So hopefully the PDF is about, it should be 213 pages.

Okay, it might be.

And if you go to the paragraph starts at...

My one's stopping at page six here.

Let me just go back and make sure I've got the right...

The paragraph's 7 .95.

Sorry.

Sorry Mr Flaggion, which paragraph?

7 .95

7 .925?

No, 7 .95

There's a subheading Lanes and Passages

7 .9. Almost there.

Yep. And under that subheading lanes and passages,

is it goes from 795 to 7 .100.

Yes.

Won't read it all given the length of it.

But just picking up a couple of points,

you'll see the first paragraph, 795,

talks about the lanes and passages generally.

7 .96 picks up on this Cooperage passage

that I've just focused on.

Yeah.

Says it would be the longest route in the proposal

at 35 metres from Cooperage Yard to Buxton Street

and the narrowest at 5 .3 metres width.

797, it would be fronted predominantly blank walls

or entrances with relatively low levels of activity.

798 talks about the bridges.

799 says design approach to Cupid's Passage

was considered by the Independent Quality Review

Panel at sessions in December 23 and March 24.

QRP questioned the proposed hierarchy of Cupid's Passage

and Chimney Lane.

The former appears to have the prime location

in respect of the connexion between the Dovah and Salop

Gardens.

However, the QRP noted this appeared

to be treated as a secondary route in respect to proportions

and limited activity.

The QRP advised that Coopridge Passage

ought to be a primary route through the site offering

a clear connexion.

The design approach to Coopridge Passage

was not significantly amended following QRP sessions.

In this respect, the decision maker

must give appropriate weight to the limitations of Coopridge

Passage and its impact on the success of the development

overall

Proposal would transform the application site and create new public squares majority of routes into and out of the site would be well proportioned

Local plan policy requires the development to meet the highest standards of design and layout and to optimise active frontages

However, Cooperage passage would be compromised in the success and would represent a missed opportunity

for this key connexion with Allen Gardens

So just the position as I understand it. We've got the officers position there

they refer to the quality review panel.

We've also heard Mr. Reynolds,

I'm gonna suggest to you there's a consistency of view

amongst those design experts, the officers,

the QRP panel.

Your position essentially is inconsistent

with all three of them.

Yes, it is.

And I'll explain why, sir.

Because I think across the conservation area and throughout the Truman Brewery, there are

a mixture of widths and routes and some of those routes have service access on and others

don't.

I think the key thing here is the difference in the two yards.

And when I was giving my presentation, I think it was a couple of days ago now actually,

I was talking about the fact that Cooperage Yard is a slightly quieter, greener space,

as is Allen Gardens in a way, whereas Chimney Yard and the route is a much more busy, lively yard,

which connects to the exhibition space and to the cinema, and therefore it makes pure logic

that the cooperage passageway should be a quieter subservient route to the

busier passageway from from chimney yard that was a piece of design that I took

you through I did I do disagree with officers and the QRP the QRP we took on

a lot of their comments and I think ultimately they concluded that it was a

piece of high -level design that's not to say that they don't have specific points

that we disagree on this may be one of those met one of the one of those one of

those points but but overall I think as you've right as as you've rightly said

mr. van again the QRP concluded that it was a successful mix of yards and

passageways and lanes yeah we've got the conclusion thank you mr. Yemen that's all

Thank you.

Thank you, Mr Flanagan.

Ms Curtis.

Thank you, Mr Yeoman.

Just before we start, it might be helpful to flag, so I was planning on referring to Mr Yeoman's proof, of course.

also the NPPF the National Design Guide which is CDE03 and the planning practise

guidance on design I know that that planning practise guidance as a whole is

CDE02 but I don't think that the entirety of the planning practise

guidance has been put into the core documents but I'll be referring to the

specific section on design. Mr. Osmani's proof CDM 15 and the landscape proposals

CDA 09 and also the statement of community involvement CDA 28. So Mr.

Yeoman as you will have heard Mr. Burrell made some criticisms yesterday of the

master planning process and I was going to take you through some of those

criticisms and so the first topic discussed by Mr. Burrell was the point

about community engagement.

So I'll start there.

I mean, in your proof and in the design documentation that has

been submitted by the appellant for these applications,

you've repeatedly described your master plan for the main site

as being community -led.

That's correct, isn't it?

That is correct.

It's one of the leaders.

And in terms of the context in which those points sit, I think it's a very interesting

design that my learned friend raised yesterday with Mr. Burrell, so I thought it might be

helpful to just set out where I'm coming from here. So looking firstly, then, at the National

planning policy framework and that's CDE01. Paragraphs 40 onwards, which are

electronic page 13 for anyone accessing electronically. This is what Mr. Harris

was speaking about yesterday in terms of front loading and pre -application

engagement, the concept of front loading. Paragraph 41 can see there that it's directed

at local authorities, but first sentence there, sorry, not the first sentence, the penultimate

sentence, local planning authorities should, where they think it would be beneficial, encourage

applicants who are not already required to do so by law to engage with the local community.

Can you see that there?

Sorry, I missed it.

Sorry, did you see?

Yes, I've got that here in front of me.

And paragraph 42, the more issues that can be resolved at pre -application stage, including

the need to deliver improvements and affordable housing, the greater the benefit.

So as part of that front loading, then community involvement can be beneficial.

And similarly, paragraph 131 of the MPPF.

Yes.

And here we're specifically on design.

Final sentence, and this is a general paragraph

dealing with the creation of high quality buildings.

Final two sentences, rather.

Being clear about design expectations

and how these will be tested is essential for achieving this,

so too is effective engagement between applicants,

communities, local planning authorities,

and other interests throughout the process.

So again, there are a message from the NPPF

that effective engagement with the community

is an important component of good design.

Yes.

And unsurprising then that paragraph 135C, for example,

lists as one of the aspects of good design and that it's sympathetic to local character

and history and presumably some of that can come from an understanding from the local

community of that history.

Similarly, in the National Design Guide, CDE03, looking at paragraph 17, which is on page

Yes.

Local communities can play a vital role in achieving well -designed places and buildings

and making sure there's a relationship between the built environment and quality of life.

So again, another message from design policy about the importance there of local communities.

and also it refers to the planning practise guidance there, which I think probably not

necessary to go to individually.

But again, planning practise guidance deals with the importance of effective engagement

of communities in design and how that can effectively shape development.

And you would agree with that sentiment?

I certainly would, yes.

And in terms of the specific design characteristics in the NDG, page 8, obviously, we have set

out the 10 characteristics for well designed places.

Page 10 onwards dealing with context.

And paragraph 39 of this document, which is on page 10, makes clear that an understanding

of context, history, and cultural characteristics of a site, neighbourhood and region, siting

and design of new developments.

Apologies, I've just really summarised that, but the important bit being an understanding

of the context, history, and cultural characteristics of the site is a component of good design

here.

And then turning over the page, paragraph 41, final few bullet points there indicates

it's that some aspects of context are non -physical,

such as social characteristics, economic factors,

and the aspirations, concerns, and perceptions

of local communities.

So then express further recognition there

in the National Design Guide that in terms of context,

one of the principles of a well -designed place

includes those non -physical aspects,

including the aspirations and perceptions

of local communities.

Correct, yes.

Page 14 onwards, then looking specifically at identity.

Paragraph 50 there.

Well designed places have a positive and coherent identity

that everyone can identify with,

including residents and local communities.

And similarly, a helpful way of gaining understanding

of what kind of a place local residents and communities

would identify with is to ask the local community, isn't it?

So in terms of the process that you followed

for the master planning exercise for this site

and implementing those principles,

you have indicated in your proof,

and I note that it's repeated in many of the design

and access statements, master plans,

that public consultation exercises were carried out.

If you could turn to page 65 of your proof, I think this is where you deal with public consultation as part of the planning consultation process.

And it's section 4 .03.

Yeah.

You say that public consultation was carried out and you refer to the statement of community involvement.

You give a little bit more information, I think, at page 252 to 254 of your proof, setting

up the three public consultations that were carried out.

But again, you mainly refer back to the SCI.

So in your proof then, a total of four pages in that 255 -page document deals with the engagement

that you had with the local community as part of your design process, that's correct?

Correct.

So I can take from that that no changes were made to the design that was sufficiently important

that you thought it was worth specifically addressing in your proof?

No, that's not correct.

So we did consult on three occasions, I think there's a live website as well which is still going on,

people can comment and all the responses are on that.

The reason that I said no to that is because the public consultation is very

important and I think as you rightly point out Miss Curtis that is not my

field to get take everybody through that process Mr. Margerson will do that.

However in terms of your question about informing the master plan the feedback

from those consultations was in a large part not about physical architecture or

master planning. It was about comments such as support for local

businesses and SMEs and we did address that in ensuring that the plot sizes the

buildings that we were forming from our sort of master plan public realm were of a sufficient

size and an ability to be able to cater for differing sizes of businesses and I think

I took you through that in my presentation from very, very small micro businesses to

bigger and grow and they allow them to stay there.

So that was a big part of the public feedback that we had.

The second aspect of the consultations was around public access and permeability because

the current site doesn't have any of that and people were very keen to be able to access

that part of the site both on foot and bicycles and so we did take that on board in terms

of our lanes and yards and the way that that connects and the natural routes and links

that we did. So there were comments around businesses and SMEs, there were

comments around access and permeability, there were then comments around green

spaces and open spaces and again hopefully yesterday and I'm happy to do

so again now I've taken you through how we responded to those public spaces and

though that was also linked with another comment which was around safety and the

public realm enhancements.

There are parts of the site

which are not particularly enjoyable at the moment.

We've all heard about Allen Gardens

being this great, wonderful open space, and it is,

but there are aspects of it

which are not particularly pleasant,

and we hope to improve that with work that we've done.

So just to reiterate, there were comments around SMEs,

there were comments around public access,

there were comments around green spaces

and the safety of the public realm.

And if you will, I've got some notes I made here

from those public consultations.

Cultural community spaces was another aspect

of the sort of comments that came out from our engagement.

And again, working with Publica,

I think I took you through in my presentation

the way in which those community spaces

are dotted throughout the master plan

and they're of different sizes and allow people to do it.

So from my position as an architect,

I'm providing those spaces.

It's not for me to curate or decide

who goes in those spaces ultimately,

but that was part of the feedback.

There was comments around the integration of street art,

and people felt that that was very much a part

of the character of the area.

And they wanted to make that point

in the public consultations to ensure

that we weren't designing something which was too

pristine or not of the area.

and again I think hopefully I took you through that in explaining how we took

that on board. There were of course comments about affordable housing as one

would imagine there would be and again the master plan identified sites for

housing and the last comment really of the sort of broad brush of the

thorough comments was around the economic activity and what this was

going to bring to the wider community in terms of economics and to some degree that's beyond

my dreams of evidence. So I mean hopefully I've answered your question, sir, in that

there was public engagement that will be taken through in much more detail by Mr. Marginson,

but in terms of your question of how that influenced my work, hopefully I've answered

that with all of the points that I've just made.

We haven't set any of that out in your evidence before today have you?

I think it's not that the evidence of the public consultations has been set out in the evidence from the entire team as I mentioned.

There's a public consultation document, Mr. Marginson will take us through the planning process and how that happened.

So I've touched on it in my proof, but I didn't feel it was my expertise to cover that.

And are you aware that there remains substantial local objection to the schemes?

I'm aware of that.

So certainly any changes that you did make haven't gone to the heart of local residents'

concerns?

Well, it depends what those objections are.

So your design...

I don't think a lot of those objections are about necessarily architecture.

So your design of the master plan hasn't addressed the needs or aspirations of the local community?

I think it's gone a long way to addressing those needs and aspirations of the community

insofar as it can do so as a piece of architecture and urban planning. Some of the concerns,

as I understand them, to be the wider community are really around political and economic issues.

Moving on then to local identity, on the point about understanding local identity and this

being part of good design, hopefully I don't have to go to too many of the documents on

this, but it's clear that part of the local character and history of this area is its

immigrant community, that's correct.

That's correct.

And the conservation appraisal and other witnesses have specifically mentioned the French -Hujonault

Jewish communities and the Bangladeshi community

were recently.

And of course, I heard this morning

about the immigrant community of Welsh dairy men and women

who have egregiously been missed out of the conservation

area at Brazel.

But certainly in recent years, Brick Lane in Banglatown

has been at the heart of London's Bangladeshi community

specifically.

And if you look at CDM 15, so that's

Mr. Osmani's proof of evidence.

If I can take you to SO26 of Mr Osmani's appendices.

Which page is that, sorry?

So it's SO26 of the appendix, so electronic page 40 of the document.

Page 40.

So Mr. Osmani has explained in his proof the importance of Banglatown as the first Banglatown

in the global west and this page of his appendices is shown how the presence of the Bangladeshi

community has had not only non -physical cultural impacts but also physical impacts on the built

fabric of the local area, street art, the Banglatown gate, bilingual street signs in

the area.

I find it striking that in your extensive analysis of the context of the local area

that you carried out as part of the master planning process that there's practically

nothing in your proof or the other volumes of design documents that are before the inquiry

about the cultural impact of the local Bangladeshi community, both in terms of the built fabric

of the area and the broader contribution that they make to the identity of the local area.

So again, can I take it that the absence of that reference means that it's something that

isn't really something that's heavily influenced your design?

No, you can't take it as black and white as that.

I think what you've rightly touched on and we've heard a lot in the last few days is

the changing nature over hundreds of years of this part of London.

And you mentioned yourself the different communities that have come through this area.

And I think we also heard about how buildings have adapted.

And we heard one particular one on the corner of brick language over time has changed through

the use of it from the mosque to the synagogue to the church.

So I think what we have tried to do in the design of our buildings, and this is not just

truth is to design buildings which are robust, flexible, long life, loose fit that hopefully

will be there for hundreds of years and will allow them to adapt and change to

the communities which may follow or currently there now. It's we want to

allow a flexibility and a loose fit to those buildings.

In terms of that point then on flexibility because this is a point that

Mr. Burrell raised in terms of adaptability and flexibility of the

buildings. You've given evidence, Mr. Morris has given evidence about how

these buildings will be adaptable to other employment or commercial uses but

it's Mr. Burrell is correct isn't he that these floor plates are not going to

be adaptable to a residential use? As the master planner it's difficult for me to

answer that question without interrogating each building. I think

there are certain buildings which would be very easy to convert and I think

there are other buildings which may need a bit more cut and carve for want of a

better phrase but we as a practise over the last 28 years have converted many

buildings into residential which were not originally designed as residential

a number of those buildings have larger floor plates than one would normally

imagine could be converted into residential. So I think there's many

examples in London and I think we could work through, we haven't done so

personally as master planners though I know the plot architects may have done

so, to specifically look at how some of these buildings could be converted into

residential in the future if that was appropriate. But you haven't done it yet

So you can't some of the politics I believe have done it

Thank You mr. Yeoman and

In terms then of the main site and the public realm

Would you agree that mr. Burrell that the Truman the main Truman site is unusual in being such an open

undeveloped site at this location

Yes, I would agree that it's unusual in its current state as it stands now, yes.

And so it does present the opportunity to design a master plan that is generous in terms

of the open space offered?

That's not a logical step.

Yes, I agree that it is a – it's different at the moment because it's open, but that

logically lead me to your question that that's an opportunity to design an open space.

And you said in your presentation earlier this week that a large part of your vision

for the master plan was to open the site up and to allow the vibrancy of the surrounding

area to come into the site. That's correct. That's correct.

So in terms of that process of opening up, we can see in your proof of evidence at page

The yard on the site, and I think this has already been discussed in Heritage terms,

but it's been there, that open space since, sorry, the yard on the site remained present

until at least 1945 before more built development was introduced onto that site, that's correct,

isn't it?

Sorry, could you say that again just so I'm clear on what you're saying.

I'm looking at page 39.

Apologies, I think that actually might be a point best left.

But in terms of the open space that's going to be provided on the site, it's correct that

in certain, at certain times that public space is going to be gated.

I think we heard earlier from Mr Harris that the proposal is that it's

closed between 2 a .m. and 6 a .m.

And when it's not closed there will still be presumably gates so that it can be closed?

It's a level of detail I think at that point from the master plan point of view.

I'm not going to say no, but I don't have any evidence there yet, so I would imagine

that yes, if it's closed between 2am and 6am and that is closed by means of gates,

if that is a detail that comes forward, then those gates will be there when they're open.

The question I'm asking is that it will be apparent to those in the local area and

local residents then that it is private land that is not always going to be open, regardless

of the specific hours?

I would say yes in the way that public parks are.

I mean I think it'll be slightly different to a public park because a public park is a big open space that everyone can see into and everyone knows that it's a public park.

A huge employment site isn't going to look like a park to people looking into it, is it?

I agree with that.

But if your question is that would the fact that this piece of the jigsaw be closed between

2 a .m. and 6 a .m., would the way in which that is closed affect its use?

I'm not quite sure what your question is.

I suppose the question is whether or not it will be off -putting in terms of the regular

use of the passageways by members of the public.

Ah, OK.

I can't speak whether it's off -putting or not,

because different people have different feelings

towards gates.

I don't think it would be off -putting,

if that's a question to me.

OK.

Moving then to just a couple of points

on the landscaping of the site.

CDA 09 the landscape strategy.

And this is a point that Mr. Forshaw has raised.

But if you look at page 39 of the landscape strategy,

there's an image there of Cooperage Yard.

I might be able to do it for memory, but I'll try and do it.

CDA... apologies, that's to remind me of the number.

CDA...

CDA 09.

Yep.

You can see again in this picture, which I think is a cross -section of Coopridge Yard,

you can see that it's going to be quite dwarfed by the buildings surrounding it, that yard,

isn't it?

Page 39, did you say?

39, yep.

Have it.

Sorry, is your question is going to be dwarfed?

Yes.

No, I don't think it is.

I suppose that would be a matter of judgement for the inspector looking at these images.

But if you turn similarly to page 27.

Apologies, I think I've got the wrong reference there.

It may be your proof.

Just give me a second.

I'll make the point without going to the reference.

I mean in terms of Chimney Yard, looking into Chimney Yard from Buxton Street, people who

are looking into that passage from Buxton Street will not be able to see through to

Woodseer Street.

Looking into Chimney Yard from Buxton Street would not be able to see into Woodseer Street.

Yes, that's correct, they won't.

So again, in addition to the fact that the site is gated and it will be obviously private

land, it's unlikely that people who are not using the appeals site itself will actually

enter the site to use that yard.

Just so I understand your question, you're saying people walking in from Buxton Street

into Chimney Yard won't be able to use the site?

Although they won't be able to, but I mean it's,

I'm thinking about members of the local community,

are they actually going to use these spaces?

If you'll, first of all, we have the fact

that the yard is surrounded by the massive buildings.

Second of all, if you're looking into the site,

looking in towards Chimney Yard,

it just looks like you're walking

into a big built development.

Compared to, for example, Allen Gardens right behind you,

that's not going to present

as a particularly attractive public space

for members of the community to go into.

I'm not sure that there's a lot of,

yeah, there are a lot of statements there.

It is gonna feel very different to Allen Gardens, correct?

That is because it's been specifically designed

to feel different to Allen Gardens.

I think I took everybody through how we got to

where we got to, I'm happy to do it again.

But the yards and the roots have been,

we've looked at similar sizes of yards and roots

across the conservation area and the wider townscape of East London and we've tested

those against the heights of the buildings, against the widths of the yards and we feel

that they are very appropriate and we've shown yards and particularly the yards which are

close by which are hugely successful in the same scale and with buildings adjacent to

to that size. So in answer to your question, yes it will feel different to Allen Gardens,

it is designed to do so. It will feel very, very similar to the rest of the conservation

area. I think we've heard in the last two days nearly all of the witnesses saying that

in terms of figure ground that they think it works very, very well. So I think the widths

and the narrowness and the change of hierarchy seems to be accepted by all parties as to

be very good. Now some parties have questioned the height of some of those buildings that

then form into 3D. Having tested that in terms of going and seeing real spaces that are of

that nature as well as the technical analysis that our team have done in terms of sunlight,

daylight, wind, we have concluded that they are very enjoyable, usable spaces.

Looking at some of the comparators that you've offered, looking for example at the landscape

strategy again, page 56, I think it's a little bit more complicated than that.

So this is a comparison, I think, Gibbon Rent that you've drawn between Coopridge Passage

and that pathway.

Quite obvious difference if you go onto the previous page is that Gibbon Rent isn't bounded

on either side by seven storey buildings whereas Coopridge Passage is, isn't it?

Yes.

So in that analysis of the comparison between similar sized spaces that are well used and

Coopridge Passage, it's not really a fair comparison, is it?

I think it's a fair comparison in terms of what this document is doing, which is comparing

its width.

Thank you, Mr. Yeoman. Finally then on the public realm, if you go to section 4 .1 of

the landscape strategy.

And that is Chimney Yard.

And you can see on the pages that follow, for example, from page 37, that again,

This is a yard that will be right up against buildings of significant scale, including

block two and block 3A.

I can see on page 37 of the landscape the visual of block two and block 3A.

It looks great.

And in term, if you look then on page 32.

Yes. Sorry, page 31. You can see again that the page 31. Yeah, the scale of block A

is going to be considerable against Chimney Yard and Cooper Ridge Lane, isn't it?

I think considerable is quite a strong word.

I think it's going to be appropriate.

I suppose the overall point being these are not spaces that it is likely that specifically

members of the local community are going to enter and want to use.

Well I would disagree with that very strongly.

I think they've been designed specifically as spaces that can be used by anyone.

local community being one of those people, visitors, people that work there, people that

live there, throw your net of community as wide as you wish. But I think they are spaces

that would be very enjoyable to use and they connect the site to the wider community. So

I think they are good spaces.

Well that will be again I think something for the inspector to judge by reference to

the images provided and the views that have been expressed by the local community.

Finally then just a point on the landscape transition at page 16 of your proof which

I think shows a transition from a slightly harder left -hand side of the master plan towards

a more green, soft landscape to right -hand side.

And that's said to represent a transition from the more commercial western side to the

more eastern residential side.

But that transition doesn't actually involve introducing any residential features into

this design of the public realm on the east.

It's just more soft landscaping and greenery.

That's correct.

I'm really glad you've raised this because I'm sorry.

I'm not sure it's page 60.

Can we just?

16.

Thank you.

I think there's been an interesting discussion

over the last few days about the transition

between the west of the site and the east of the site.

And what's interesting is where people draw that line.

Because we have taken the view that,

and we strongly believe this,

that the Truman Brewery campus really extends as far

as Spital Street.

And it's at that point that you begin

to get the softer change.

the buildings change in their

Style

Massing shape as you move towards we where we are today. I don't want to interrupt. Mr

Yomi, but I think the question I asked was the transition in that plan is basically

Introducing more greenery towards the right -hand side of the correct. Yes

Come and just be

Can I just be clear what page you're looking at?

16 of the landscape strategy.

Oh, the landscape strategy.

So I thought you said my proof.

That explains it.

Yeah.

So was I, yes.

I was looking at my proof, sorry.

Oh, I see.

I get your point, Miss Curtis, that's fine.

Sorry, that's probably me not listening.

So just as a question then, I mean the fact that the harder approach I suppose is being

taken on the chimney yard side of things means not only that we're not seeing as part of

this transition the reintroduction of any residential development into the northeastern

corner of the site but also reclaimed materials which we saw from Mr. Forshaw's evidence

were across quite extensive parts of this site as a whole aren't going to be

reintroduced on the on the western part of the site? Yes they are, if you just

bear with me there is a a drawing in the landscape pack which shows where the

recycled materials are to be used and they are a mixture of...

Let me just see if I can get you the right page.

There is an intention to reuse the materials across the site.

There is hard, if you look at page 45 of the landscaping evidence, which is Coopridge Yard,

you can see that it's a mixture of soft and hard landscaping and the intention is that

cobbles, reclaimed slabs will be used in that area as well as in Chimney Yard.

But that's the image that you've taken us to is Coopridge Yard, so the eastern side

of the site. So as I said... Sorry that was your question wasn't it? You said that in

in the in cooperage yard the eastern side of the site because of its softer nature we

wouldn't be using any of the reclaimed materials is that is that no sorry that's the opposite

of what i understood from your landscape strategy which is the reclaimed materials are proposed

for that side but aren't going to be reintroduced to the same degree not the western side not

to the same degree because it is a softer it is a softer yard to the one on the west

So not to the same degree, but still introduced.

Thank you, Mr Yeoman.

Thank you, Ms Curtis.

Mr Harris, did you have anything in re -examination?

I think just three short points.

The first point relates to public realm hierarchy

and Cooperage passage.

You took my learned friend to page 79 of your proof.

Can you go there again, please?

Yes, urban design mythology.

That's it.

Yeah.

And I'm interested in particular in step four, which says,

establish hierarchy of roots.

And if you look at it, there are two roots

in from the area of Allen Gardens.

and in particular Buxton Street. You see them on step four clearly marked.

I do. Yeah. Which is the primary entrance and in architectural terms why?

The primary entrance is the one that currently exists which is the seven metre wide

route that was the original entrance to the cooperage from Buxton Street.

that width exists, that is the primary route. The reason that it is there is because that

is the busier side of the site in our view and allows people to walk into the site from

Brick Lane almost in a B -road kind of fashion. If one imagines Brick Lane as being a very

busy thoroughfare you can peel off into the new piece of the jigsaw. That also is where

there is a greater activity in terms of the exhibition space

and the cinema activities that was the uses were designed

to reflect that.

So and then you can come back into Brick Lane to the north.

Hopefully that's answered your questions.

Thank you.

In historic terms, does the fact that it

is the existing and historic entrance to the estate

have any relevance at all? Yes I think it does I think it has been there for a

long time it also it provides a bit of relief to the boiler house naturally it

would be rather perverse to ignore it I may say so sir. Thank you and we we heard

just a few hours ago, how the local authorities'

townscape witness thought it was an advance

over that which was there and was to be given

significant praise, and he gave his reasons.

Now, here's the question.

Why is Cooperage the secondary of those two entrances?

It is the newer of the two entrances. You've just asked me the question about the hierarchy,

so it is subservient to the main existing entrance, therefore it is a little bit narrower,

but I do refer back to my earlier answer to Mr Curtis' question about the width. The width

is still a good width, five metres.

So and that, again, to answer Mr. Harris's question,

is in our view the quieter side of our site

and links to the arguably quieter, naturally quieter

space of Allen Gardens to the north.

Is anybody suggesting, so far as you're aware,

that there's anything inappropriate with the access

at seven metres, the main access, the one that has just been praised by the local authority?

I'm not aware of anybody knowing.

In hierarchical and in architectural terms, particularly looking at the location, what

would be the argument for having or not having two accesses of the same hierarchy?

The answer to that would be it's very hard to establish a hierarchy when two things are

exactly the same. I think we should also acknowledge that the route to Allen Gardens is through

3A and 3B, whereas the route on Chimney Yard, the route from Chimney Yard, is through the

is between a new building and a listed building.

And it also, remember my point earlier in the week

about trying to protect the chimney,

that in lots of ways, the building form,

historic entrance, the listed building,

everything points to that route being more respectful

of the chimney and the listed building at that point.

Thank you. And again, with my learning friend's question in mind, can we go to page 86 of

your proof, please, where you deal further with this same point?

Yes.

And you've there got steps 7, 8, and 9, which explain how the new urban form is in keeping

with surroundings but also deals with the function of the place. Do you see the two

two axes in are identified at step eight.

Yes.

What is it between the two axes that you identify there

by way of cutback?

What is that cutback for?

What is placed there?

And how, if at all, does that fit in with the hierarchy?

So the cutback is very important because it provides relief

to Buxton Street and provides a pedestrian route to Buxton Street on the

south side which there isn't there isn't currently so that is that is the reason

for the setback how is that set back going to be used and then in terms of

uses there is both a restaurant and a cafe space on the ground floor of block

3b which which allows uses to occupy the external space that we've set back so

as a sort of pavement culture.

Thank you.

And then in terms of usability, you've explained the hierarchy.

You also said in answer to Malone and Friend's question

that it was a very usable passage, Cooperage passage.

Can we look, please, to the committee report

that he took you to?

Make the tech work.

CDL01, I think.

So although there might have been an issue between you and the officers in terms of hierarchy,

et cetera, I want to look at usability.

Tell me when you're there.

I've got CDL -O.

go to paragraph 7133.

7133.

Yes.

See this?

The public realm, including Cooperage Passage,

would provide good pedestrian comfort levels

as assessed using the TFL methodology

in respect of sunlight to the proposed yards.

Chimney Yard would fall slightly below.

Cooperage Yard would comfortably pass the test.

Overall, this is a reasonable sunlight outcome and indicates good sunlight.

So in terms of usability and pedestrian comfort, any issue there?

No. And I think I said that earlier, sir, and answer your question.

But Mr. Harris has very helpfully pointed me in the right direction of a third party saying the same thing.

Yes. And then there was this, we've got a consensus of opinion and you're wrong and the consensus is right.

Can we look at what the GLA said?

The GLA look at many large schemes of this nature and have got a specific expertise as

identified in 7133 TFL in terms of pedestrian access, et cetera.

7136, please.

Yeah, in the same report.

Oh, it's two paragraphs on, so you don't need to look very far.

Yeah, I've got it.

Because right at the end of this, I call it a passage,

right at the end of this passage,

which my learned friend took you to,

the officers note something,

and they note the GLA stage one report,

which says the master plan shows that the development

would be highly permeable through the provision

of series of yards and passages,

which lead visitors into and through the site.

This has the potential to be a positive addition

to the already vibrant brick lane neighbourhood.

Each yard has more than one route option for entering and

exiting and generally good sight lines into the key spaces. This

should help facilitate a greater sense of safety and inclusion

for all than currently exists on the routes around the site.

Generally, the proposals provide good street -level activation

onto the yards and onto the adjacent streets, providing a much

needed passive surveillance.

So far as you are aware, was there ever an issue with any of

the routes or any of the yards from the GLA?

No, I'm not aware of any issue with the GLA.

Thank you very much.

That's the end of that issue.

Turning to my own friends points for the Rule 66 party,

you were asked about public accessibility

the various components of that and gates, et cetera.

We'll see it's in the State of the Common Ground

and also in the Section 106

that whenever the premises is open to the public, so that's all the hours of day

apart from the four that we've identified, the gates must be open. Good

practise or bad practise? I think it's good practise. Good, thank you. Local community

and whether the local community will use the area, what's the function of the

There's a there's an art gallery. There's a flexible spaces. So

And then I think there are some some of that some opportunities for local

businesses within the market the backyard market space

Very much like we see in other areas of the Truman brewery

So we've provided the spaces and I think history proves that the treatment brewery estate

and actively engage with it.

Thank you.

How does the local community use the Truman estate at the minute,

so far as you're aware?

I can ask somebody else if you don't know.

I can only give my own personal opinion, sir.

It strikes me that they use it very heavily and very well.

All right.

Thank you very much.

Thank you, sir.

Those are my questions in re -examination.

Thank you.

Just keeping up with notes, I think we've got time for questions.

Great. Thank you, Mr. Yeoman.

Pleasure.

With that, 20 past four, was it your intention, Mr. Harris, to call anybody else?

Yes, it was. Mr. Morris.

Yes.

Would the idea be to deal with Mr. Morris in chief?

I'm just going to tend to him, sir, in the same way because he's already spoken for over an hour and a half, and I think that's fair and appropriate.

Okay. Mr. Flanagan?

So I won't be finished with Mr. Morris by close of play.

Okay.

And I mean there is a, there's an alternative

which I slightly hasn't raised.

But if you did want to not have any net loss, there is the,

I suppose, nine, stopping now and starting at 9 .30.

Yeah.

It makes up the half an hour.

Well, it's just a question of, I'm just thinking

about the best way to do this logistically.

I'm not – I've got travelling tomorrow, as you'd expect, so I'm not expecting to sit till this sort of time tomorrow, you'll understand.

I've got to get to the West Country, so – where I live.

So it would be my intention to sit till, I don't know, two -ish tomorrow.

But I'm quite prepared to start early to make the best use of time.

So it may be better that we start at 9 .30,

or are you relaxed about breaking?

I'm more than relaxed.

And to deal with my friends' point about no net loss,

if we're stopping at 2, then there's

an argument we should press on now and start at 9 .30.

With respect, it's really only 20 par.

Time is travelling on as we're arguing about it.

But when we started this, it was about quarter past 4.

and I've got no examination in chief.

I'm very content and can explain to Mr. Morris,

who's given evidence lots of times anyway,

what the issues are.

I see no good reason not to make the best use of inquiry time.

But it's entirely up to you, sir.

But bearing in mind if we're finishing at two tomorrow

as well, which is understandable.

Mr. Plunk, are you happy to?

Let's start and break.

Mr Morris, you'd have to be sort of isolated when we finish tonight and then before we

start again tomorrow, you'll understand that.

Well, we'll have five minutes then so that you can set up.

Thank you, Mr Flanagan, I am grateful.

Same as last time, so then I'll just re -tender the witness.

Mr Flanagan, I'll hand over to you. I mean, I'll leave it in your hands. When you reach

a convenient point at five o 'clock or afterwards, then let me know and we'll call it quits for

the day and then start at nine thirty in the morning.

Thank you, sir.

Good. Thank you, Mr Flanagan.

Good afternoon, Mr Morris. So, Mr Morris, if you take up your proof and if you go to

page 23 of it to start with, at which there is a timeline.

And you'll see from the timeline right at the beginning,

August 2023.

And then underneath that it says London Tower Hamlets,

Pre -App 01, just before August.

I think it was in July.

Just identifying the chronology.

If you go over the page then to page 24,

you get some detail on that.

It's headed pre -application meeting number one feedback.

Meeting on the 19th of July, 2023, according to this.

And we see from the image,

and there's in the top right hand of the page,

there's a label that says below,

scheme as presented at pre -application meeting number one. Yes. So that was the

stage of evolution at that point and just to ground ourselves in the

chronology go over to the next page that's page 25 now. First paragraph on

On that page 261 says feedback from quality review panel number one meeting 13th of December

23.

And we've got an image and similarly at the top right with a label scheme as presented

at QRP number one.

So that's December 23 and there's an image stage of evolution there.

So just putting ourselves in the chronology, can I ask when were you Mr Morris first appointed

and when did you or your firm commence work on these three schemes?

One question.

Certainly before QRP01... Sorry.

Sorry. Certainly before QRP01, I can't be precise on whether or not I was at the first pre -app.

The first pre -app was July 2023.

Yeah.

Was your firm appointed in July 2023?

I would guess we were.

I can't recall the exact timing of our appointment.

So you can't recall whether you were

at the July pre -app meeting?

Well, we were there, yeah.

I just can't recall the time that we were appointed.

Well, if you were appointed,

you'd be at the meeting, surely?

Yeah, I don't know the time, though.

Okay.

You're clear you were appointed?

I was at that meeting clearly, yeah.

You were at the July 2023 meeting?

Yeah.

And...

you had obviously undertaken design work on the blocks for which you were responsible,

3A and 3B, because they were being presented at that July 2023 meeting, yes?

Correct.

And there had been some evolution by the QRP December 23 that year, yes?

Yeah. Okay. That's 3a and 3b, that's what we see in those two images and the rest

of the main site. Same question for block A, the data centre. When were you appointed,

when did you start work on that please? Again I don't have the dates on me and I

I could clarify that later, but it was definitely after we were appointed on this block.

I don't know the dates to hand them, I'm afraid.

Well, perhaps if you can easily cheque overnight, that would be useful, thank you.

And the same question about Eli's yard as well.

They were almost, from memory, without having the dates in front of me, they were almost

simultaneous.

Not long after we were appointed to proceed with block 3 and then block A came, the data

centre came last.

I don't have the exact timing of those to hand I'm afraid.

If you're able to cheque and give me a, you know, to the month or something that would

be useful.

Okay, in your proof you set out hopefully your credentials, experience, etc. You don't

say that you're a qualified heritage expert and you don't say that your firm Morrison

Company employ any qualified heritage experts who worked on this or any of these three schemes?

Correct, yeah.

Mr. Dunn and Miss Killar -Lee tell us

that the Townscape consultancy became involved

as heritage consultants on the project in February 2024.

So you've got the chronology.

We've seen the two images there.

So the heritage consultants came on board in February 2024.

So it's right, Mr Morris, is that no heritage consultants were appointed to work with you,

either internally in your firm or externally, on the design of Block A, Eli's Yard or Blocks

3A and B until February 2024.

Correct?

I've got no means to challenge you on that,

so we'll take it as accepted.

February 2024 was well after the fundamentals

of the massing height and scale of the buildings which

we see in the images on pages 24 and 25 of your proof had already been established.

To a degree, yeah. Sorry, to a degree? To a degree.

What, you're relying on amendments after February 2024 then?

Sorry, if you could just repeat your question. The fundamentals of the massing height and

scale of blocks 3A and 3B had already been established

by the time the Heritage Consultants came on board

in February 2024, correct?

Yes.

The same applies to block A, the data centre.

The fundamentals of the massing height and scale

of that building had already been established

by the time the Heritage Consultants came on board

in February 2024, and the same applies to Eli's yard, yes?

I would, again, without having the evidence in front of me,

I would suggest it was running at a different pace.

So we certainly weren't as advanced on either Ellie's or Block A

at the same time that we were looking at sort of plot three.

So the fixity that you're describing wasn't wasn't there in the same way.

and actually both projects were fluid for quite some time.

Understood.

Just dealing with the first block I referred to then,

I heard your qualifications about Eli's Yard and Block A.

Dealing with 3A and B.

And see, we've got the images in front of us at December 2023

before the heritage consultants came on board. It's right that no expert heritage professional

had analysed the conservation area and advised on the appropriate massing and scale of the sites

when the fundamentals of that scheme were being designed. That's a fair point but equally after

they were appointed, there wasn't a sort of directive

to proceed in any different manner.

I think, obviously, absolutely take on board your position

about my expertise as a heritage consultant.

But as an architect who responds and deals

with matters of heritage through design

and sort of iterative response and all sorts of other issues

taking everything into account, one

tries to make a judgement on the best fit for a scheme

within a certain context.

knowing that the entire duration of a project is subject to ongoing negotiation, ongoing

collaboration, discussion and dialogue with a very vast array of different people.

So absolutely we've taken the scheme to the point that you're referring to in the way

that we have here, obviously with planning advice, with all sorts of other advice on

that, with our own assessment as an expert in creating spaces in urban places for over

20 years, and then taking on board the advice of not just our own heritage consultant, but

working through the discussions with local authority at the same time, and then adjusting

that as we went.

Yes. Mr Norris, a number of times in your proof, the appellant repeatedly in application

appeal documents describes the main site scheme and the other two schemes as heritage -led.

It cannot be heritage led without an expert heritage professional advising and guiding

from the outset, can it? I would argue that there's a philosophy of

heritage involved in the project in the absence of an expert, but clearly for over 50 % of

the duration of the project, there was advice on the table

with a heritage expert.

And prior to that, using our own philosophy

in terms of strong contextual understanding,

really understanding how buildings

should relate in good order, those strong philosophies

were applied.

Yes, but using even that sort of terminology,

this is an important and sensitive heritage context.

And the appellant, the applicant then,

didn't get heritage professionals involved

until you were 50 % through the process.

Yeah, sure.

And again, without having to sort of explain the kind

of design process, but the design process

is proceeding on many fronts.

It's not just a massing conversation or a material

conversation.

and there are many other factors at play.

So a lot of background coordination work

is also happening, which isn't about pure placemaking as well.

It's about straight up technical stuff and coordination.

So I guess I don't know if that answers your question.

Thank you.

Just turning to specifically the data centre now.

So zooming in on that, if you go to your proof,

please, page 224.

Almost there.

Thank you.

So 224, at the top of the page, block A, introduction, project,

brief and vision.

And at 4 .3 .1, you tell us that the appellant

has set a project brief for a new data

centre within an urban context.

So just to confirm, Mr. Morris, the brief was a data centre.

That's right.

Those three words there.

There was no study that you did or you're aware of with design input to understand whether

a data centre was the most appropriate land use for this site, this street.

Not that I was involved in that.

Policy in the London Plan, I won't go to it, I'll just put it to you.

You'll probably be familiar with this bit at least.

Policy in the London Plan seeks a design -led approach.

This does a lot of other policy.

Design -led approach.

The London Plan tells us that design -led means,

quoting from D3, anyone who wants to know,

ensuring that development is of the most appropriate land

use for the site.

So Mr Morris, in the present case, from your answer you've just given me, it was never

asked, at least not by you, whether the development, a data centre on this street, is the most

appropriate land use for the site, correct?

Of course.

In short terms, that means the scheme cannot be design -led because that fundamental first

question is whether or not the moment of design -led, the design in that context with the appropriateness

of the use could happen prior to my involvement.

So, again, you could imagine that a well -tuned -in client with years of experience, with an expert

team at its hands, having had due consideration for everything, could have also come to a

conclusion on whether or not the brief for the project was appropriate.

We simply have taken the brief that was given to us in terms of its capacity and its programme

and use and have processed that in a design -led approach.

Yes, but you haven't undertaken that exercise.

I wasn't asked to, and actually I wasn't asked to do that

on any of the other plots either.

I haven't been asked to test any alternative uses.

That wasn't our brief.

No, understood.

And I understand obviously you work within your brief,

and I'm just exploring what design -led means,

what that means for these schemes.

Still on design -led, the officer report, we can go to it if we need to, it's a short point though,

the officer report talks about Grey Eagle Street, there being existing issues of inactivity and poor

public realm along Grey Eagle Street

and it being affected by antisocial behaviour.

Is that a broadly fair summary?

Yeah.

Thank you.

Data centres, Mr. Morris, generate limited footfall

and provide limited natural surveillance, correct?

Correct.

In light of that existing nature of Grey Eagle Street and in light of data centres generating

limited football and limited football and limited natural surveillance, a design led

approach would not suggest a data centre as a land use for Grey Eagle Street would it?

Why?

Because it would exacerbate and not address those existing issues.

Well, I guess you have to take, again, it's

a very narrow and black and white position you're

taking on one specific plot in the context of a context.

Taking into consideration there are more matters at play

than a purely an active frontage with a window.

It's a proportion thing, a scale thing.

It's about how land is used.

It's about the scale of pavements.

There are a whole raft of things at play here,

which doesn't, I don't think it just boils down to a kind of a run of windows,

which I think is what you're alluding to.

I'll come to some of those in a moment.

Just continuing your proof, if you go over to page 225,

it's the next page.

There's a heading of 4 .4, wire data centre.

Yeah.

And there's some paragraphs on that page,

which you can see from the bold text talk about critical data infrastructure, the benefit

of low latency finance application. In answering that question that's posed on that page, why

a data centre, there is nothing about addressing the public realm issues on Grey Eagle Street

and there's nothing about heritage, which again indicates, doesn't it, that this is

the data centre is not a heritage or design -led scheme?

Again, taking it as black and white and with a narrow view,

I can see why you're saying that.

So this page is merely assessing the need for a data centre

or programme in that location relative to a surrounding context.

That's all that page is trying to get across.

So again, there are many, many other wider issues at play,

which are sort of demonstrated through our design and access statement

and the ambition of the project.

But this page is specifically trying to ascertain

the appropriateness of a data use in this location

relative to the relationship to the city and so on and so forth.

That's OK. So that's dealing with need

in terms of the proximity of the city, etc.

Mr. Norris, in your proof, and I think you've answered the question already perhaps, you

don't go on to say, well, in design terms, is a data centre use appropriate for this

Grey Eagle Street?

Because that was the brief that you were given.

That had already been decided.

We received a brief for a data centre on this location.

Thank you.

Point of detail on that brief.

I think in this proof, in these two pages and elsewhere, I don't think you say that

the brief included any floor space or volume requirement for the data centre.

Is that because it didn't include any floor space or volume requirement?

Not as such, no.

So it was, I guess again, it's a hard thing to be specific on,

because again, these things generally

sort of go through an evolution.

So the word optimal and efficient

for the actual function of the data centre

was an absolute requirement.

And I guess what you do in these instances

is you go on an iterative process,

of an evolutionary process of testing different fits

to ascertain the most efficient and logical layout of data,

taking into consideration other contextual matters, daylight,

sunlight, massing, context, setting, et cetera, et cetera.

So it's one that in some ways you start with,

and in principle, you arrive at a conclusion

based on that creative process.

Good.

Activation I said I'd come to in a bit more detail. I will now. So

Just go to a different part of your proof

Come back to the data centre bit. You go to proof in your proof page 90

9 0

Yeah, it's the plan of 3a and 3b.

And then on the left hand side there's some text, paragraph 2 .68 .2, the penultimate one,

explains that active frontages animate the surrounding streets and passages, and I think

you're talking about the active frontages proposed in the main site?

On this particular plot, yeah.

Yes, okay. You continue, the proposed ground floor plan is a vast improvement on the consented

data scheme. Just pausing there, that's the one that's got permission on the main site.

So the proposed ground floor plan is a vast improvement on the consented data scheme,

which offers much less in terms of active frontage. So you're contrasting what you get

with a data centre with what you get from different uses,

retail, commercial, of that more active frontage, yes?

On this location, yeah.

Yes, well, you say on this location,

but exactly the same point applies on Grey Eagle Street.

You get to a data centre and you still

lose that active frontage that you might

get from a different use.

You actually do, but the two conditions

and how those urban spaces work are completely different.

OK, I'll come back to that.

So continuing on this theme, maybe we can, yeah, page 40,

40, page 40, paragraph 2 .20 .2 on the left hand side. Second paragraph, and here you're

dealing with again the main site and 220 .2 you say, although the graffiti covered walls

add to the colour and character of the area, streets which lack visible activity and passive

surveillance could feel less safe for pedestrians, particularly at night. And you're dealing

with Buxton Street, I think, and the existing...

Yeah, I mean, Brick Lane, Buxton Street and Spittles Street specifically.

Yeah, okay. So you talk about there that Buxton Street in particular, covered in graffiti,

But that street art graffiti does not prevent Buxton Street having issues in respect of

activation.

As Mr Reynolds perhaps put it, the animation you might get from art doesn't lead to activation

in terms of activity, natural surveillance, things like that.

Take that, your own words, put them in Grey Eagle Street.

Gragel Street full of art at the moment but suffers from quite severe public

rail issues yes? Correct but not as a consequence of the art necessarily. Fair

point but in terms of what's going on then you in a number of places talk

about how that your proposed data centre in Gragel Street will be a canvas for

street art that is not going to remedy the public rail issues on not going to

address the public rail issues on Gragel Street is it that's street art. On

I'm not suggesting that by itself it does. It won't activate, Greg.

I'm not suggesting that the street art is an active thing.

I'm suggesting it's a complementary part of our approach.

That's agreed, that's fine. Good. So that's street art and activation.

It's reference in the appellant's case also to the security that goes with a data centre,

particularly the necessity perhaps for CCTV coverage on the approaches to

streets around a data centre.

Tomorrow's security cameras don't activate a street do they?

Page 261 of your proof. Go to that, please. Back in the data centre part of your proof.

At the top of the page, the text 438 .1 tells us that a set of isolated elevations for Greigle

Street are used to demonstrate an understanding of the data centre brief, which directly impacts

the façade. And you go on to explain that in a bit more detail. The design that you

come up with the absence of windows, active frontages other than the entrance,

is a direct consequence of the internal use of the data centre, isn't it?

Certainly associated, yes.

That's a constraint imposed by the clients brief? Yes, largely and its

context? It's a two -sided building you see so I guess yes you could without

trying to be slippery at all but it's a sort of it lands in a certain way with

the constraints that we have on the site and the and the brief yes. And then on

the entrance which has been referred to I think Mr. Frohman took us to the

design response document which explains the amendment that was proposed in

respect of the entrance.

Originally, it was an entrance.

And then what happened was that the security office, which

was more internal in the building,

was brought to the frontage and glazing put along both

the existing glazing on the doorway

and then glazing put on the security office.

Mr. Frayman was right, wasn't he,

that given where that security office originally was,

it was a windowless room inside the middle of a building,

you've brought it to the front of the building

and put some glazing on it,

but the activities that are gonna take place in that room,

given where it originally was,

are not the sort of activities

that are going to activate a street, are they?

Not in their entirety, no.

And again, obviously, a data centre usage,

no matter how many windows you put into that,

would have a similar effect, I guess.

Good.

Height and scale then now on the data centre.

In your proof you deal with this, page 226.

If you could go there, please.

226.

It's the one with the eight circles on you.

Yes, absolutely.

So the first circle, number one,

asks, what is the justifica...

I'll put this in context.

This is pre -application engagement of comments.

The first one of those is,

what is the justification for the building maps and impact on neighbours?

How will the proposal address this?

Then there's an arrow to another circle which says,

the proposed building line has been pushed back from the street,

setbacks were introduced on the upper storeys and one storey was removed.

I'm going to suggest Mr Morrison,

the question was what is the justification for the building mass

and impact on neighbours?

The circle below does not answer that question, does it?

No, it doesn't. Again, I suppose it's quite a phenomenal way of trying to describe a process.

So you see underneath it as well there's a reference to plans and townscape assessments.

So it's a sort of, again, not in isolation but with an expert team looking at multiple

things at the same time. So you're producing, again, without teaching anyone to suck eggs,

but it's a case of an evolution of plan, section, elevation, massing,

creating digital models, viewing the digital models,

reacting to those and testing those over and over again

in order to arrive at a position.

I guess that is a short -circuit description of that process,

which is very long.

Yes. Okay, well...

What you've just told me maybe, but in terms of evidencing that this is a design -led process,

the specific question with which this inquiry is concerned in large part is asked there,

what's the justification for this mass and scaling? And it doesn't give us the justification

either for the original height or the amended height.

This page doesn't. The DAS does.

Okay, well there is some more material, I'll come on to that. So you go on page 239.

Which is the photographs of the existing, yeah.

Yeah, and we have some heights here and

What we

We're told on the right hand side 4 .17 .1 is block a surrounded by four and seven storey build at tall buildings

The frontage heights and length noted on this page helped to inform the massing of the new proposal

Just want to understand how that

How that informs the proposal.

In terms of the Grey Eagle Street elevation,

so that's the top one.

Got Jack's place at 26 at the far south.

Adjacent to the proposed building,

we've got the telephone exchange at 19 metres.

then you've got the existing site.

And then on the north, you've got the 19 metre residential

block, yes?

So in terms of the directly adjacent buildings, 17 and 19,

and the building, I agreed in the statement of common ground

may be elsewhere now, 26 metres to Parapet.

And then if you include the plant,

it gets up to 29 metres.

So the building is 26 metres to parapet, 29 to plant.

And its neighbours are 17 and 19.

Then if you look at the neighbour on the west.

Where's the 17?

Sorry, apologies.

I was looking in the wrong elevation.

It's 19, isn't it?

19 and 19.

You're quite right.

19 and 19.

Then the facing elevation on Grey Eagle Street of the existing

data centre, also 19.

So that's the third side directly adjacent.

And then the fourth, the fourth side, is the final elevation, Calvin Street South.

Calvin Street South is 11 metres.

So we've been through the four sides.

I'm not ignoring Jack's place, but I'm just focusing on the immediate neighbours at this

point.

The height of the proposed building, whether parapet or total height,

is obviously significantly in excess of all four facing elevations

from its neighbours, isn't it?

I wouldn't say it's significantly higher, no.

I think the point...

I can see the point you're trying to make here.

Cities and streets don't really work like that.

And again, it's a continuous judgement

on the rhythm of streets, the rhythm of buildings,

the heights of buildings, we all know that.

There's other experts in the room

that would attest to that.

So it's not a case of us having to, in effect,

bind a building directly to the millimetre

and with the surrounding set of buildings.

That's not, I don't think there are,

that's not a kind of black and white case

on how you approach these things.

It's a judgement on a building within its setting,

taking into account a number of different buildings,

Jack's Place being one,

you know, the data centre opposite and various other buildings and looking at them in the

round and then testing them in, again, in a sort of real eye level views and sort of

understanding how buildings set back.

So kind of the elevational, I guess, treatment of buildings is also one of those kind of

unfortunate things which people often refer to, which is not a way in which you really

ever see a building as well.

You see it sort of dynamically.

So our building is stepping up but it's stepping away at the same time.

So what we've, again, it's a sort of, it's a balance of trying to, you know, it's a

balance of internal and external, it's a balance of context and specific sites, it's

a balance of reading, it's a balance of daylight and sunlight and adjacencies and

all sorts of things and we've landed where we've landed.

And if you go on just to understand design response in light of feedback, if you go to

page 249, please.

Yep.

On page 249 in the top two drawings, you've got the pre -app one scheme and then submission

scheme of the next two drawings. And we can see from the dotted line that it's been,

I think you described it on the right -hand side, has been and indeed below, floor removed.

And it's gone, the parapet, is this right, the parapet's gone down from 29 metres to

26 metres or so. Yeah, so it's a storey down.

It's a storey down, okay. I've also stepped the building in from the street edge as well,

just to note it's about just over a metre step back as well as a consequence of that

discussion. Yeah, so you've stepped it down from a total power cut height of 29

to 26 but you've still left it seven metres taller than its 19 metre

neighbours and considerably more than its Calvin Street neighbours. I mean if you go

back a page to 248 again that's the that's the building within its context

So as you can see, the point I'm trying to make as a response to the point that you're making is that yes, you're absolutely right

There are it does step up from its immediate neighbours

But within the context as a judgement on how the building relates to many buildings within its context

As I say streets aren't a single line streets are ranges of blocks which step up and down

and do all sorts of different things and

Hopefully the two diagrams on the left -hand side

which shows those elevations demonstrate the point I'm trying to make.

That I accept what you're saying and I'm not contesting what you're saying,

but there's a reason for it, which is demonstrated by the points I'm trying to make

and has illustrated in that diagram.

Thank you.

Another aspect of scale and massing, just the building line,

which you mentioned just now.

The building line at present, it's been described by other witnesses.

The building line at present comprises the line from the telephone exchange, the derelict

building on site itself, and the flats on the north side of Calvin Street is one consistent

building line.

Yeah.

In terms of what is being proposed,

if you look at your page 251, over a couple of pages, 251,

we can see this outline.

And on the left -hand side at 4 .28 .2,

You say that the building line of Grey Eagle Street is pushed three metres away from the

edge of the street. Mr Morris, that's not right. What you are doing is pushing the building

line of Grey Eagle Street closer.

The plot boundary, the red line is further forward of that. So effectively we are pushing

the developable site edge back from the street edge,

again, in semantics, absolutely we're pushing it forward

from its current building line by three metres.

But we could have pushed it further, but we didn't.

We kept it at a three metre setback from the street,

which was deemed to be a better position

for the way the street works.

And actually, if you spend any time in the area,

you can see that the two adjacent buildings,

the housing to the north and the telephone exchange,

They've actually demonstrated that the space right out the front of the buildings

isn't a space that's in any way productive or useful.

They've fenced them off.

It's scrag land full of bits and pieces and storage and things tossed in there.

So, again, on balance, it was felt that this was a much better building line

and hopefully potentially a catalyst for the improvement of the street longer term.

Yes, but putting to you it's important to recognise that you're breaking the building

line, because in a street which is already narrow, as a number of people have called

it, you are introducing more scale and taking away space.

We're moving a two -storey volume forward in three metres, leaving a really adequate

pavement line which in normal circumstances would be generous.

There's just one more matter before it might be a helpful time to break.

Just carry on in your proof still on Grey Eagle Street, you go to page 273.

Sorry, just bear with me as quick as I can.

So it's the view looking north of the proposal, yeah?

Absolutely.

The view looking north, and I just

want to understand the design philosophy, as you say,

behind this.

449 .1, top of the text on the left -hand side,

says, the proposed building echoes the cascading massing

of the telephone exchange, stepping forward

such that segments of its south elevation

appear from behind existing parapets.

Just applying that language to the building that we see,

we can see the brick two -storey podium base of the proposed,

and we can see what's above that.

Compare the telephone exchange next door.

The metal upper floors of the proposed building

do not cascade back like the telephone exchange, they're almost a sheer vertical wall.

They absolutely don't mimic it, that's correct.

They don't mimic it, but they...

So I'm looking at the building in its totality, I guess you're trying to...

you're focusing on one element of the building, but the building clearly does

step down in several steps onto that main street

and actually if you cast your eye further along the elevation to the north,

you can see that the building as it steps back onto Calvin Street

also introduces a further sequence of step -backs.

It isn't in any way trying to mirror what the telephone exchange is trying to do.

It's taking it as a cue.

Yes.

The almost vertical elevation of the metal element of the upper storeys

exceeds the entire height of the telephone exchange cascade, doesn't it?

On this view, yes. Yeah, so that's that view, that's Greigle Street.

Except you've got to also look at Calvin Street, so there are setbacks are greater

there on Calvin Street. So I just want to deal with that finally today. You deal

with that at page 286 of your proof.

And on page 286, the final paragraph, 4 .61 .5.

And you say this, the setbacks respond to two key parameters.

You say, firstly, the first setback, which forms the plinth, responds to the height of

the immediately adjacent context.

The telephone exchange to the south of the site features a setback at the same height,

while the proposed plinth ties into the level of the top

of the adjacent residential buildings on Calvin Street,

forming a clear urban continuity in mass and materiality

along Calvin Street.

So made that point, got the plinth height

is tying into the telephone exchange on Calvin Street.

So that's got that point.

It's the second one.

You say, secondly, the remaining setbacks

is the ones you were just talking about, the metal

storeys further up.

Secondly, the remaining setbacks above respond to the rights of light envelope, ensuring

good daylight is maintained to residential neighbours. So this is the Calvin Street,

which obviously has residential use on it, and there's greater setbacks there.

Mr Morris, the reality, just looking at the form of your building, I put it the almost

sheer elevation on Grey Eagle Street but the greater setbacks on Calvin Street is

that you are including significant setbacks and upper storeys only when you

have to essentially for technical rights of lights issues.

Is that a question or statement? I'm putting that to you as what is going on in the

design of this building. So it is clearly in there, it's clearly one

of the elements that we're dealing with here, which is the, I guess, the kind of, you know,

the dichotomy between an internal function and an external place.

Absolutely.

And, you know, we're not shying away from that.

This is a intended to be, and I believe it is, a measured response taking into account

multiple issues at the same time.

There isn't one single issue which is, which the building can respond to by itself.

It is taking into account lots of different things.

So yes, there is a degree there,

and there is a fair amount of assessment and modelling

and data analysis of its impact on surrounding buildings.

The Calvin Street one in particular,

the setback there and the measure of its setback

ensures that it is neighbourly in the context

of the surrounding residential streets,

residential buildings on Calvin Street.

We don't have the same complexity on the street elevation

For grazing for example and its context is different the existing data centres different the the scale and heights of Jack's place

Is different so again the streets themselves are sort of you might argue that Greg is a secondary Street

Let's say Brick Lane is a primary you might even suggest that Calvin Street is a tertiary

And we're trying is a measurement of how we sort of step the building down in a in a in a you know in a

in a measured way to address these two different conditions.

Yes, but you're responding to technical rights of light

issues, which are a hard constraint,

if I put it like that.

The more design -led matter of dealing with the public realm

on Grey Eagle Street, not putting a sheer vertical face

there.

There isn't a sheer face on there.

It's set back from the main street setting.

So again, if you were to walk along the street edge,

I think much of the upper levels wouldn't be visible on that western edge.

I put the point.

That's it on the data centre, so that's a convenient moment as well.

Well, thank you. Thank you, Mr Morris. Thank you, Mr Flanagan.

We'll resume at 9 .30.

You've appeared at public inquiries before, Mr Morris,

So you'll understand your duty that you're

talking about the case.

As long as you understand, that's fine.

Is there anything else we need to touch on this evening?

Yes, there is just very briefly.

And that is ordinarily in the course of things.

I would be calling Simon Henley there the trio.

He's stuck in Paris.

But I can get to call Mr. Dunn tomorrow,

just so my learning friends know and that may or may not be reached I don't

know I'm in my learning friends hands. Sorry so what's the order for tomorrow

then? Well we continue with this witness and then Mr. Dunn. And what about the

Miss Killarlay? Yes and we can get to Miss Killarlay by two that would be

brilliant as well. So you're reversing the order Mr. Dunn is going to go as next

witness yes I didn't know it was a reverse of the order in my mind he was

always next okay we had an indicative order oh well that's your yeah but you

put that together indicative yes mr. Dunn next if that's okay unless there's

good reason otherwise yeah the only the only sense of doing it in in the order

that I thought it was is that a lot of the matters are going to be covered it

will mean it'll be possible to cross -examine mr. Dunn more briefly but I

it's matter for you. Yes that's that's fine but I'm calling Mr. Dunn first and

Miss Killarly second. Does that make sense? If that's how you prefer it.

Yes yes I think it also makes sense. And hopefully Mr. Henley will be back

from Paris next week. For Tuesday yes. That's the theory. Well I'm grateful to you if

you can if you can respond to that little change obviously we need to try

and make use of time tomorrow in some way or other. The two -ish stop is

without a break for lunch?

Well, I mean, what I would intend to do on a day like that

is perhaps have a longer mid -morning break between 7 and 11 .30.

So we'll have plenty of time now, and then we'll work to the 2.

And then, yeah, late lunch.

And I'll work to the end of the day.

But having two.

OK.

Thank you, sir.

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Truman's Public Inquiry PM - Thursday 16 October 2025, 2:00pm - Tower Hamlets Council webcasts

Truman's Public Inquiry PMThursday, 16th October 2025 at 2:00pm

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Truman's Public Inquiry PM
Thursday, 16th October 2025 at 2:00pm