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Keeping Everton in Our City • View topic - ENQUIRY WEEK 3 - DAYS 9-12

Keeping Everton in Our City

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 Post subject: ENQUIRY WEEK 3 - DAYS 9-12
PostPosted: Wed Dec 03, 2008 1:28 pm 
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Tuesday, 02 December 2008
Day 9 - Exclusivity deal is over, or is it?
Today, Tesco reiterated their threat that they would refuse to redevelop the existing £65m Kirkby town centre should they not receive planning permission for 'Destination Kirkby'. Tesco's expert on corporate matters Philip Cole told the public inquiry that like the custodians at Everton, Football Club they too have no 'Plan B'. It was established that Tesco wouldn't be a very responsible asset manager in that case given they own the existing town centre.

Stephen Sauvain QC enquired whether there would be any improvement to St. Chad's parade in Kirkby (the main shopping street in Kirkby) within two years should planning permission not be obtained for the scheme. He was told that improvement would limited.

Rogert Lancaster, acting on behalf of the combined authorities asked whether Tesco would hold on to the land to prevent competitiors obtaining permission for a store and attempt to deter redevelopment from other companies. Mr Cole said that Tesco have no plans to build a supermarket in the existing town centre and do not purchase land to stymie development.

Cole was asked whether the name 'Cherry Meadows' was coined to disassociate itself from Kirkby. He said that the name had since been dropped because Cherrys are generally associated with the colour red and would be an unsuitable name for the development.

Mr Sauvain wanted to know more information on the cross-subsidy i.e. where exactly are Everton going to obtain the money from because it is now assumed that the money will be derived from the uplift in land value should planning permission be granted. Mr Cole suggested that the question be asked to Knowsley Council.

It was established that the Tesco supermarket would be the largest store in the North West and that the store is to compete with Asda and Morrisons in surrounding areas.

It was also revealed that Tesco first approached KMBC in December 2005 with regards to building a new store and stadium on the Kirkby Hills area (unknown to Everton FC at the time apparently). It is worth noting that Sheena Ramsey, the Chief Executive of Knowsley Council has said that the proposals first surfaced in March 2006 and also that Walton's MP Peter Kilfoyle had been involved in discussions regarding Everton's relocation in January 2006.

When Mr Lancaster asked why the Walton area of Liverpool was not reknown as being the home of Everton Football Club and Goodison Park, Mr Cole said he was not the best person to ask why this was the case.

Kirkby Residents Action Group's Tony Barton enquired about the December 2005 plans for Kirkby, he was keen to establish whether the proposals had scuppered plans for a new school that had been earmarked for that particular site already but was told that would be a matter to discuss with Knowsley Council.

He also sough clarification from Mr Cole as to whether Tesco would allow Kirkby to 'rot' if they did not receive planning permission, he was told that Teso would cut thier losses at some point.

Kirkby resident, Mrs Pethard who will live near the stadium development asked why there had been no proper risk assessments on the area and stated that no assurance that the bund to be built near her home was up to the task. She was told by Mr Cole that 3d images had been released and David Clarkson QC (representing Tesco) told her that 20,000 DVDs had been sent to Kirkby resident.

Like many Evertonians, she was curious about the status of the infamous 'Exclusivity Agreement' and was told by David Clarkson QC that Everton signed it in November 2006 and it had expired in July 2007.He later stated that a land agreement had superceded the exclusivity agreement and that had expired a couple of weeks ago.

Robert Elstone read out the summary of his proof of evidence in the last hour and he will be cross examined by KEIOC tomorrow.


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 Post subject: Re: Day 9 - Exclusivity deal is over, or is it?
PostPosted: Thu Dec 04, 2008 12:13 am 
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Lies,lies and more damn lies!

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 Post subject: Day 11
PostPosted: Fri Dec 05, 2008 11:03 am 
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on the official site - which missed out a few bits...........

http://www.evertonfc.com/news/archive/o ... ?page=full

Other Ground Options Dismissed

by Scott McLeod | Thursday 4 December 2008, 19:42

Everton's options beyond the Kirkby development were ruled out in dramatic fashion during a compelling and enthralling 11th day of the public inquiry.

The focus of the inquiry turned to the Club's plans for the stadium, with the focus of much of the cross-examination examining the alternative sites and options for the Club away from Kirkby.

During a rivetting exchange of questioning for the two witnesses - Chris Potts an expert on planning from the Savills group and David Keirle, an expert on stadium design from the KSS Group - the options that had been looked at by the Club over an extended period were examined, with the witnesses providing impressive evidence backing the assertion that Kirkby is the only viable option open to the Club.

The questioning followed Mr Potts' examination by Patrick Clarkson QC representing the applicants.

During that examination Mr Potts revealed that over the past 10 years redeveloping Goodison Park had been found to be not viable and the Club needed a new stadium to secure its future competitiveness with facilities to meet current standards.

He said they needed a stadium with 50,000 seats and the possibility of expanding to 60,000, between 2,000 to 3,000 hospitality seats, high quality facilities for players, improved views, compliance with new regulations and a comprehensive travel plan for match days and iconography. He added that cross-subsidy was essential.

He added that he had assessed a series of possible sites on the grounds of their availability, suitability, accessibility, viability and deliverability and he stressed that no football club would seek a location for their stadium without conducting this very thorough approach.

He cited the Kings Dock scheme and the fact the Club had been forced to abandon the proposals due to spiralling costs and the complexity of the project. He added the Club had pursued proposals to site a stadium at Switch Island until Sefton Council chose to oppose the scheme and that Liverpool City Council had failed to come up with any other options but Stanley Park.

Mr Potts added that after the ballot of fans on the Kirkby move, the leader of Liverpool City Council came up with another opportunity on the Loop site but that he advised Everton that scheme was undeliverable as it was too small, accessibility was a problem and it would be very costly. He added that Liverpool had also considered the site and rejected it.

Mr Potts revealed he had not received any viable alternatives from Keep Everton In Our City and stressed Everton had adopted a thorough approach to its search for a new stadium.

He said the Tesco scheme had considerable merit and it met the availability, suitability, accessibility, viability, deliverability standards he had set before concluding that, in his opinion, Kirkby was the only option for a new stadium and that neither Everton or Liverpool considered sharing a stadium as a serious proposal.

Having provided his evidence, Mr Potts was cross-examined - providing strong and impressive answers to each line of questioning - backing his assertion regarding the Kirkby project.

Stephen Sauvain, QC, cross-examined Mr Potts on behalf of Liverpool City Council.

Mr Potts said that the "whole concept" of enlarging the footprint of Goodison Park had been examined in detail and that redeveloping in situ was not a viable option before adding that if the Kirkby scheme did not succeed, the search for a new site would continue.

Everton had always made it clear they needed a subsidy from a high quality development, which, he added, was a fairly well-established option in building stadia. He agreed that the value of subsidising development, such as housing, was declining in the current economic climate, so finding such a development was becoming more difficult.

He agreed that the Kirkby proposal was contrary to Knowsley's existing planning policies but he pointed out that Stanley Park in Liverpool, the proposed site for Liverpool's new stadium, was designated as an historic park in Liverpool's Unitary Development Plan. But he said Liverpool City Council felt comfortable in setting aside those planning restrictions because of other, wider considerations.

He said that, at the beginning of Liverpool's most recent Local Development Framework process, Everton had highlighted the Club's difficulties at Goodison Park and the need to move and need for subsidy. He said the Club had received no positive response to those submissions.

Mr Potts said, since 2006, Everton had been looking at sites that could allow subsidising developments, without prejudice to planning policies. He added that Everton had not applied to the North West Development Agency for a grant towards the cost of their stadium, as Liverpool had done.

He said Liverpool had received £10 million from the NWDA and if Everton were eligible for a similar amount, this would represent only a "fairly minor part of the overall cost". Mr Potts also said that the NWDA grant was ring-fenced for work on infrastructure around a development and could not be used on the building of the stadium itself.

He also made the assertion that he did not think finding a new owner for the Club would necessarily resolve the financing of the stadium, pointing to the fact Liverpool had changed owners 18 months ago and yet the club had endured further delays in achieving a new stadium.

Peter Fisher of Knowsley Liberal Democrats asked what other site opportunities had been examined.

Mr Potts said the Everton board had given him background information on sites that had been looked at before, including sites within the docks and locations away from the city centre, and that Everton had been approached by Tesco on the possible Kirkby proposal at a meeting with Liverpool City Council.

Mr Potts said proposals such as these were very complex and challenging. He said that after the initial approach from Tesco, he had been impressed by Tesco's thorough approach to developing the proposals and that regular meetings were held.

He added he had taken enormous comfort from the considerable support they had received from Knowsley Council who were clear about the challenges of the proposals but also the need for regeneration in Kirkby.

Mr Potts explained that Everton had not considered the possibility of siting the stadium on Knowsley Golf course because the land was in the greenbelt and was owned by Liverpool City Council.

Trevor Skempton then cross-examined Mr Potts on behalf of Keep Everton in Our City.

Mr Potts denied Everton was being treated like a franchise. He said this proposal gave Everton the opportunity to have a stadium that met their requirements, was affordable, and was sited in the heartland of a lot of Everton supporters. He insisted a stadium at the Kings Dock, alongside the current arena wouldn't be viable.

On the subject of the Loop site he said, to his knowledge, Everton had not received any formal plans or proposals about the possibilities on the Loop site. He said he had assessed the site himself and had taken advice from stadia experts and they had jointly concluded that the site failed.

Mr Keirle was then presented as Everton's third witness, revealing he was an architect with over 25 years experience in the strategic design of football stadia, including the Manchester City stadium.

He said the area around Goodison Park was very constricted in terms of housing and transport and that parts of the stadium had an "historic charm" but facilities were poor in three of the four stands. He said a lot of the seats had a restricted view, spectator facilities were very poor and were "some of the worst to be found in sports stadia in Europe".

He said the stadium had been built in a piecemeal fashion without the same consideration for safety as was paramount today. He said access around the stadium was difficult as a result. He said older stadia were often built right on to narrow, local streets which created considerable problems at a club, such as Everton, that attracted large crowds. He said this situation was currently dealt with by street closures on match days.

He agreed that Goodison Park did have a great atmosphere on match days but said stadia planners now aimed for facilities that would attract families to events, with safe, comfortable surroundings, good views and easy access to toilets and food and drink outlets. He said that none of these were present in most areas of Goodison Park and as a result it did not attract many families.

He explained the facilities in the Everton hospitality areas were good but there were not enough of them and those there needed improvement.

He said a number of feasibility studies had shown that rebuilding on an extended Goodison Park site would be very difficult and would require the purchase of a school, 100 houses and a large garage business.

He said the cost of building a stadium on an extended Goodison Park would cost between £205 - £245 million and that was without the costs of buying and relocating the properties around and the loss of revenue during construction. This was not considered viable by Everton.

He then detailed other options which had also been ruled out, such as redeveloping the existing Goodison Park site, and said these had proved too costly and would not provide the extra seating and facilities that Everton needed, adding the new stadium had been designed to standards of comfort that far-exceeded Goodison Park and would provide an excellent all-round experience for visitors. The design was uncomplicated yet distinctive and the roof had an "elegant simplicity".

He said the creation of Everton Way would help to build up atmosphere around a game, create a good vista of the ground from the town centre and would draw fans in to access the stadium that way.

He said he did not think the stadium was "a lost opportunity" as suggested by CABE (Commission for Architecture and the Built Environment).

He said there was no doubt that the designers had been pushing for the "best spectator experience" and that this design was high quality and striking.

He said stadia were very expensive to build and that he was aware of many proposals that had begun in a "blaze of glory" and had "never seen the light of day".

He said it was crucial for Everton that this proposal was deliverable and he said that "from day one this had been designed to budget" and to a realistic budget.

Dave Kelly cross-examined Mr Keirle on behalf of the Kirkby Residents Action Group and asked about other stadia developed on or near the existing site.

Mr Keirle said Chelsea's ground at Stamford Bridge had been redeveloped on site but said this had taken nine years to complete on an "incredibly complex site" but agreed that Spurs were creating a new stadium near to the existing ground at White Hart Lane.

He said Goodison Park had been improved as much as was possible on the current site and he stressed that, in his professional opinion, several attempts had been made to find a suitable site for a new stadium for Everton - and the Kirkby site was the only one that was viable.

Trevor Skempton then cross-examined Mr Keirle on behalf of Keep Everton In Our City.

Mr Skempton asked several questions about how the atmosphere at Goodison Park could be recreated at the new stadium.

Mr Keirle said the roof design, enclosures at the end, slope of the stands and shape of the stadium had all been designed to create the right atmosphere.

He said they had created different sizes and types of seats to cater for different preferences. He agreed the acoustics of a stadium were a very "real issue" and contributed to the atmosphere of a ground. He said the sound at the Kirkby stadium would be funneled towards the goals and kept within the stadium by design to intensify the atmosphere and minimise disturbance for local residents.

He added that it was not viable to keep the capacity of a stadium small to retain the atmosphere – he said the Everton board would not accept this.

Mr Keirle went on to say that the stadium designers had discussed with Everton the possibility of working with a group of fans to create areas in the new stadium where supporters that had traditionally stood together could move to. He said he thought it was a fanciful notion to incorporate the historic Bullens Road and Gwladys Street stands in the new stadium. He said he thought these were horrible, claustrophobic structures that were "truly horrific" to anyone other than hardened football fans.

He agreed that the capacity of the Park End stand could be increased to create a lot more capacity at Goodison Park but he said that would leave all the problems in the other stands and ongoing high maintenance bills.

Inspector Paul Jackson, a Chartered Architect, asked Mr Keirle about a number of aspects of the stadium's design.

Mr Keirle stressed that the days of poor quality design and build schemes had largely gone. He said clients demanded higher standards now and were involved at all stages. He said Barr knew how to design stadia and they had created something that met the client's requirements and created the right atmosphere.

Mr Keirle said he thought CABE were misinformed when they criticised the crowd control elements of the stadium design and added CABE sometimes looked for architectural perfection rather than a technical solution that worked safely.


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 Post subject: Re: Day 11
PostPosted: Fri Dec 05, 2008 11:08 am 
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views from other fans on the events on the day:

Quote:
Chris Potts says he's looked at The Loop (although he's never actually been given a copy of the HOK report that shows a stadium can be built on it, or visited it in any way other than driving past) and that it fails

He slags Goodison off some more

Then another witness, an architect Spurs fan, comes out with this little gem....

He said he thought it was a fanciful notion to incorporate the historic Bullens Road and Gwladys Street stands in the new stadium. He said he thought these were horrible, claustrophobic structures that were "truly horrific" to anyone other than hardened football fans.

Oh how damn important this move is to some people that they will allow this kind of verbal demolision of our stadium

funnily enough though, the report on the Official Site misses out a few bits....

the same witness who said the Street End was "truly horrific" also admitted that as stand tiers go higher the rake increases up to a maximum of 34 degrees. The top tier at Kirkby will be the maximum of 34 degrees and as such can only be fitted out to a capacity of 60000 maximum. To go over this, the top half of the stadium would have to be demolished and rebuilt, which if you recall is one of the reasons as to why GP cannot be rebuilt, ie playing in front of reduced capacity.

he brought up that the Stadium Green Guide has just had another edition published, edition 5, and GP does not comply with it. He did say that the Guides cannot be applied retrospectively.

He went on to say, even without a spade being put into the ground, that the Kirkby stadium plans will NOT be brought into line with edition 5!

I still don't understand why the major focus on how bad Goodison is though.....surely the Inquiry doesn't need a whole fucking week of "evidence" to prove we need a new ground?

The board are well and truly Donald Ducked if this whole debacle comes crashing down around them - and I reckon it stands more chance of doing just that than Goodison Park does!!


Quote:
Yet more revelations from the inquiry today.

#1 - cast your minds back to when Wyness told prominent citizens of Liverpool that Evertons requirement is to have stadium with an eventual capacity of 70000/75000.

Well today David Keirle, the clubs KSS stadium expert, said that as stand tiers go higher the rake increases up to a maximum of 34 degrees. The top tier at Kirkby will be the maximum of 34 degrees and as such can only be fitted out to a capacity of 60000 maximum. To go over this, the top half of the stadium would have to be demolished and rebuilt, which if you recall is one of the reasons as to why GP cannot be rebuilt, ie playing in front of reduced capacity.

#2 - David Keirle brought up that the Stadium Green Guide has just had another edition published, edition 5, and GP does not comply with it. He did say that the Guides cannot be applied retrospectively.

He went on to say, even without a spade being put into the ground, that the Kirkby stadium plans will NOT be brought into line with edition 5!

#3 - David Keirle is another Spurs fan!

#4 - The Kirkby stadium has been 'built to a budget', ie you get what you pay for! This aspect has been picked up by CABE.


Quote:
..........I've just read the OS mate. Are you basing this judgement on being there today or the 'giddy' scribblings of Scott McLeod, club employee?

Hat's off to Messrs Potts and Keirle's 'major number':

Own goal.....(plan B option effectively accepted)"if the Kirkby scheme did not succeed, the search for a new site would continue."

Own goal....(shit point and not relevant to the inquiry - DK was called in, Stanley Park wasn't because it complied with the local plan) "He agreed that the Kirkby proposal was contrary to Knowsley's existing planning policies but he pointed out that Stanley Park in Liverpool, the proposed site for Liverpool's new stadium, was designated as an historic park in Liverpool's Unitary Development Plan. But he said Liverpool City Council felt comfortable in setting aside those planning restrictions because of other, wider considerations."

Own goal..."since 2006, Everton had been looking at sites that could allow subsidising developments, without prejudice to planning policies. He added that Everton had not applied to the North West Development Agency for a grant towards the cost of their stadium, as Liverpool had done."

Own goal..."He said the stadium had been built in a piecemeal fashion without the same consideration for safety as was paramount today." (Shitdome, it turns out. is Green guide non-compliant too)

Own goal...."He agreed that the capacity of the Park End stand could be increased to create a lot more capacity at Goodison Park"

In other parts Mr Keirle said how atmospheric Goodison Park is, how hospitality areas at Everton were 'good', that building on an extended footprint would be difficult (therefore not impossible).


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 Post subject: Day 10 Kirkby Fears Confirmed –
PostPosted: Mon Dec 08, 2008 11:12 am 
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Monday, 08 December 2008
Kirkby Fears Confirmed – No Investment - No Demand - No Money
On day ten of the public inquiry at Kirkby Mr Stephen Sauvain, Liverpool City Council’s QC, began his cross-examination of Everton’s acting CEO Robert Elstone.

Mr Sauvain began by establishing that the club is for sale and that if planning permission was given the clubs owners would have a more valuable asset than they do now. He asked Robert Elstone to confirm the Club’s majority shareholders, Bill Kenwright, Robert Earl and Jon Woods, and that there were approximately 1500 minor shareholders. Mr Sauvain then asked if it were true that the club was for sale contrary to a statement within the DTZ report. Robert Elstone responded: "To my knowledge, the club has been for sale since Bill Kenwright became Chairman, from day one he has consistently said the Club is available for sale to the right bidder. Mr Sauvain suggested that the planning application's approval would make the Club more valuable, meaning that it would be more attractive to potential purchasers, Robert Elstone confirmed that this was a possibility.

Mr Sauvain enquired if Everton had asked the City Council if they could provide a suitable site with additional space for an enabling development? Robert Elstone explained that Everton needed a stadium that they could afford and as they couldn’t afford to pay for it alone they required an unspecified level of enabling development as a contribution.

Moving on to questions about the Kings Dock fiasco Robert Elstone explained that it collapsed due to escalating costs and the complexity of the scheme. The decision was taken that it wasn’t worth the risk. Obviously Robert Elstone’s version differs somewhat from that remembered by Evertonians attending various shareholder meetings.

After some questions concerning company debt, Mr Sauvain queried the length of time surrounding Everton's partnership with Tesco. Kirkby was 2006 but there had been an earlier collaboration between the parties. Mr Elstone explained: "We have consistently looked at what the Club can afford with our advisors and we believe we can afford £78m. The cost of the stadium we would want and need is considerably greater than that so we need the subsidy offered by this three way partnership. There's no evidence of any other way of meeting that funding gap."

On the matter of the prospective stadium naming rights deal Robert Elstone explained that Arsenal had secured a £90m deal over 15 years but refused to confirm the clubs expectations, perhaps forgetting that Keith Wyness had previously confirmed the figure in 2007 he refused to reveal any figures citing commercial sensitivities.

Moving to funding derived from the sale of Goodison Park and Bellefield, Robert Elstone confirmed that both schemes would involve residential properties, that under the current climate the schemes would offer a declining value but that there was another (unidentified) source available if the Bellefield scheme failed to deliver the required level of funding. He conceded that no guarantees could be made at the moment about residential development at Goodison or Bellefield.

The amount of contribution identified by Everton as affordable was confirmed to the inquiry as £78M. In a rare moment of explanation, Robert Elstone confirmed the projected cost of the stadium was £130M and that total figure had been tested by the clubs experts and that the £52M cross-subsidy would enable the club to obtain a 50,000 seat stadium with the potential to expand to 60,000.

After briefly covering the job benefits that Everton would bring to Kirkby and how in his view the presence of the club in the town would encourage increased awareness mainly through the newly identified 13M Evertonians; Mr Sauvain suggested that people would only know Kirkby through the stadium name, similar to the Ricoh Arena and the Reebok Stadium. Mr Sauvain suggested that perhaps the urgency to relocate was motivated by the need to increase the asset value of the club as quickly as possible for the benefit of the main shareholders. Robert Elstone explained: “The board are the custodians of the Club, they’re motivated by the desire to take the Club forward, as are the board of Chelsea and Tottenham football clubs that are also intending to relocate. Our revenue every game is considerably less than our competitors and we're asking our fans to endure sub-standard facilities compared with modern stadia. Without this scheme we will not go forward.”

Mr Roger Lancaster, the barrister representing Sefton, West Lancs’ and St Helens Council’s, then began his cross examination. Mr Lancaster asked why Everton should receive a cross subsidy from money derived from public land; “would you expect Woolworth’s to be given such a subsidy to help them?” Robert Elstone replied, wittily, that he wasn’t familiar with their business model!

Mr Lancaster then examined Everton’s methods of raising their financial contribution towards the stadium construction cost; Mr Lancaster asked if Everton had considered a rights issue, Robert Elstone explained that the Club hadn’t because it was not affordable on top of the £78m figure that their advisors had indicated was achievable. Mr Lancaster then enquired if a sale and leaseback scheme on the stadium had been considered, “No it hadn’t” was the reply. Mr Lancaster then referred to the applicant’s own DTZ report which stated that the major shareholders had no intention of selling their interest in the Club. Robert Elstone pointed out that selling shares would not raise funds for the club just the shareholders. Mr Lancaster focused his attention on Bill Kenwright’s statement at the recent EGM concerning the sale of the club to a billionaire and the apparent engagement of Keith Harris of Seymour Pierce; Robert Elstone refuted this adding that the club hadn’t engaged Seymour Pierce or anyone else. It was established that the club is for sale, although this is not mentioned in any of the 6,000 pages of the planning application. Mr. Lancaster hypothesized that if the club was sold, there wouldn’t be a requirement for the £52M cross subsidy; the £52M wouldn't be needed. Mr. Lancaster asked, “What happens if a Manchester City occurred the day after this inquiry closes?” Robert Elstone replied, “Who knows?” Mr Lancaster asked about average attendances in recent Premier League fixtures, indicating that no game had an attendance of 50,000 and only Manchester United and Arsenal actually had gates of that magnitude, Robert Elstone explained that Newcastle, Sunderland and Manchester City have those capacities and that Liverpool, Tottenham and Chelsea plan to develop grounds with that capacity.

Mr Lancaster, now in full flow, then suggested that Everton were trying to steal a march over their rivals by getting a bigger stadium, a stadium that they can't afford. He established that no investment had gone into GP in the last thirteen years and that it wouldn't cost that much to improve facilities. He finished off by suggesting to Robert Elstone that if a private business received £52m from a council and then its owners sold up and made an increased profit due to that money, “there would be a public outcry wouldn't there?” “Perhaps” replied the Everton CEO.

Mr Peter Fisher, Knowsley Constituency Liberal Democrats, observed that whilst Arsenal and Manchester United couldn't meet the demand for tickets (at their stadia), Everton only had a 60,000 active database; “is the attendance figure of 50,000 deliverable?” Robert Elstone replied that he believed it was, explaining that over the last three years 30,000 people had held a season ticket and an additional 60,000 had bought at least one ticket, indicating a total figure of 90,000 potential supporters, this gave the Club confidence of moving to a 50,000 stadium. Mr. Fisher continued to question the current attendance levels at Goodison Park, Robert Elstone laid the blame on the credit crunch. Mr. Fisher pointed out that Standard Liege didn't sell out, and asked if Everton were in Europe again, would attendances increase? Robert Elstone replied that average attendances, last season, were close to 37,000 but admitted that the current economic climate was having an effect. Mr. Fisher closed with an attempt to establish if the fans perception of the club would change if it came to Kirkby, the answer was no, it would still be a club in the Liverpool area and would be viewed in the same way as now.

John Fleming, on behalf of the Kirkby Residents, then took his opportunity to question Everton’s CEO. “Why should the residents of Kirkby bail out Everton Football Club when their board had been incompetent?” Without waiting for an answer Mr Fleming continued “what connection did Everton have with Kirkby and when Mr Wyness told supporters that it was the deal of the century did he mean for Everton or the people of Kirkby?” Robert Elstone chose not to answer the first part of the question but stated that he felt that Everton would be an asset to the community. John Fleming questioned this pointing out that the presence of the stadium would devalue the quality of life and increase anti-social behaviour. Mr Elstone disagreed and put forward the contention that the Stadium would improve and enhance behaviour and conditions in the town. John Fleming then cited a letter from the MP for Walton, Mr Peter Kilfoyle, in which he questions Everton’s value to the area of Walton, “perhaps this had been inaccurate?” observed John Fleming. When Everton's previous links and association with the town was questioned, Robert Elstone explained that “the town had a large population of Everton fans and had a strong association with the Club as a result.”

After lunch the afternoon session began with Robert Elstone fielding questions from Colin Fitzpatrick on behalf of KEIOC.

Colin began by asking Robert Elstone to explain what was his previous involvement in the scheme prior to assuming responsibility. Robert Elstone explained that this involved the stadium search, the naming rights deal and he’d also had a major input into developing the business plan. Colin enquired further, “after the sudden departure of Keith Wyness has there been any major changes to that business plan?” “No” replied Robert Elstone.

Highlighting the statement in Robert Elstone’s proof of evidence concerning the identification of 13M Evertonians, Colin enquired how this figure related to other premiership clubs; Arsenal, Manchester United, Liverpool, Tottenham, Aston Villa and Newcastle. Robert Elstone replied that web traffic was a good method of estimation. Colin asked if they’d simply extrapolated the figure from this but Robert Elstone explained no, they used independent experts to identify it. He didn’t know the figures for other clubs. Colin went on to explain that prior to relocating to their new stadium at Ashburton Grove, Arsenal had identified their worldwide fanbase as 15M which had been attributed to their constant participation in the champions league and the winning if the premiership and other cup competitions, “what would you attribute Everton’s 13M fanbase to?” “Heritage, tradition and family ties” reponded Robert Elstone. “Do you know what Arsenal used this 15M figure for?” Asked Colin, “no” replied Robert Elstone. Colin informed the inquiry that it was apparently used to secure their stadium naming rights deal.

Colin then asked, “Emerging football finance guru Miss Amanda Staveley, owner of PCP Capital Partners, speaking on behalf of Middle Eastern Investment vehicles such as DIC and QIA, you’re familiar with QIA?” Robert Elstone replied “No, don’t know them.” Colin continued “Ms Staveley has described English Premiership teams as “the key provider of digital content on media platforms worldwide”. Does this have any significance to the aforementioned figure and would an identified large worldwide fanbase encourage potential owners of football clubs to buy into clubs that were on the market?” Robert Elstone replied, “Our media assets are limited, they’re distributed by the Premier league.”

Turning to past investment, Colin asked Robert Elstone to confirm that recent investment in Goodison Park had been practically non-existent, Robert Elstone confirmed this was the case. “Yet others, notably Manchester United, Aston Villa, Newcastle, Chelsea, Blackburn and Liverpool have invested in their current facilities have they not? “Yes, they have” responded Robert Elstone. “In fact in para 3.6 you say that premiership clubs have invested £1.8 billion, by comparison, and just to confirm, how much have Everton invested in this same period (fourteen years)?” “£13M over fourteen years, it's been modest, small investment in lounges and for safety reasons, investment in disabled areas, small last year, approximately £1.5M, including maintenance.”

“Why haven’t Everton invested in their stadium during this period and whom are the people responsible for this lack of investment?” asked Colin. “There are constraints that Goodison Park presents, its footprint…..” Mrs Wendy Burden interjected “I think the question is whom Mr Elstone, not what!” “Well, the board, on the basis that they didn't have the facility to.”

“There’s a site favoured by many in the Scotland Road area; has the owner of the site attempted to meet with the club?” asked Colin, “I’m not aware that he has” responded Robert Elstone. “You’re aware that he’s spent £30,000 on a feasibility study that confirms that this site, adjacent to the city centre, is suitable for a 55,000-seat stadium?” Robert Elstone stated that it was not affordable or deliverable. “Are you also aware that the site has the full backing of the council?” Mrs. Wendy Burden again interjected: “This is a question for Mr. Potts.” Colin persisted “Can you confirm that Everton have insisted in the past that there needs to be 500,000sq ft of enabling attached to any site?” Robert Elstone responded, “No, we have confirmed that we need substantial support to deliver a new stadium.” “Keith Wyness specifically mentioned a figure of 500,000sq ft, did he just pluck it out of the air?” Robert Elstone didn’t offer an answer, Colin continued, “you know you’d never get that in Liverpool don’t you?” “Yes I Know.” Colin persisted “So is this to prevent other alternatives to Tesco’s proposals?” Robert Elstone chose not to offer a reply. Colin tried again “Would you agree that this insistence is little more than a device to prevent the emergence of a viable alternative (to Tesco’s proposal) that would be located in Liverpool?” Robert Elstone; “No.”

Colin next turned his attention to the subject of relocation. “Are you aware that this isn’t the first time the club has attempted to relocate to the Kirkby area?” Robert Elstone confirmed that he was. “The then chairman, Peter Johnson, advocated a relocation to Kirkby Golf Course, the second site was Gilmoss, just up the road from where we are and the final location was Cronton in South Knowsley, two miles away from Widnes town centre, in Cheshire. Are you aware of these failed plans? Robert Elstone “Yes”. Colin continued, “The current chairman, Bill Kenwright, was opposed to this relocation away from Goodison Park was he not?” Robert Elstone “Bill's preference would be to Keep Everton In Our City.” Colin, “I’d agree, in fact are you aware that he was so opposed to the idea of leaving Goodison Park that he gave a substantial financial donation to the supporters group opposed to the move at the time?” Robert Elstone replied “No.” Colin pushed on; “I appreciate that he’s now the chairman but why is he now so keen to relocate to Kirkby and what has changed?” “The financial circumstances have changed for clubs in this league, this is now viable and deliverable, one that was unique” offered the CEO. “You also know that Everton attempted to relocate to the Kings Dock on Liverpool’s waterfront, why did this fail?” “Complexity of the scheme and rising costs, the risks were too great.” Colin challenged this by asking “Everton told LCC that their £30M contribution was ring fenced didn’t they?” Robert Elstone replied, ”All I know is the costs were increasing.”

Returning to Goodison Park, Colin now asked “Are you aware that at the time of the first proposed relocation to Kirkby a study by Ward McHugh Associates, designers of Twickenham, indicated an ultimate capacity of 55,000 (through extending the footprint of Goodison) could be achieved? Yet you claim in para 7.2.2 that a redeveloped Goodison could now only have a maximum capacity of 36,000, how is this?” “Based on the advice I've been given, yes” responded Robert Elstone. “This report was paid for by a supporters group after being told by the then chairman that Everton had in their possession a report stating that they could only redevelop Goodison Park to a smaller capacity than it currently held at that time, it was later admitted that no such report existed” stated Colin. “Not aware” was all that Robert Elstone was prepared to say.

Colin continued; “This latest report is lower than the current capacity is it not? Who produced this report?” Robert Elstone replied “We have consistently looked at if (the redevelopment) is doable, it's highly risky and highly expensive. We revisited it before the EGM, a fresh look. No agenda. That work suggested that the club couldn't redevelop.” “What was the scope of this latest report, the one indicating a redevelopment figure of 36,000? What were the terms of reference?” Robert Elstone explained “One: what can be done on the existing site for a modern stadium, two, can we extend the footprint and three, what can we achieve with £78m. KSS got to £50m without added hospitality. We could go to 44,000 for £71m.

Colin; “You say in para 3.7 that Everton’s inability to invest in its stadium has resulted in the club being at a competitive disadvantage to other clubs do you not?” “Yes.” Colin continued, “Yet during this period of time Everton has enjoyed above average attendances but they’ve been unable to follow what other clubs have done?” “We haven't been able to invest due to shape of site.” Colin pressed further; “Would it be fair to say that the situation Everton find themselves in, you describe it in para 3.5 as ‘the deficiencies of Goodison Park’ and the apparent inability to afford the redevelopment or construction of a new stadium is primarily a consequence of the failure of successive owners of Everton to invest in their Stadium?” Robert Elstone; “Restrictions of site have made investments impractical and unworthwhile.”

Colin, returning to investment asked, “In the main, highly successful business people typically own these premiership clubs, how do these owners obtain a return on their investment?” In a bizarre reply for a chartered accountant, Robert Elstone told the inquiry “In a variety of ways: emotion, profile, status.” A clearly confused Colin put the question another way, “would you agree that they take the long view, that they’ll obtain their return when they sell their club?” “There is evidence of substantial capital growth in the Premier League.” Obtaining the accountants answer he wanted Colin went on to ask “You indicate that Everton have failed to invest in their revenue generator, their stadium, would it be a fair observation to state that the current board have never invested a single penny in the club?” Robert Elstone answered honestly, “Yes, that's true, so when they sell, that's a return.”

Now once again changing quickly to finance Colin asked “This asset utilization and disposal plan that has been adopted by the board, it can’t be sustained forever can it?” ”No” came the reply. “It’s inherently unsustainable, won’t the assets run out and the loan repayments overwhelm the clubs ability to provide sufficient funds to obtain better players?” “We have a highly qualified finance team and a good relationship with the bank. That wouldn't be allowed to happen” replied Robert Elstone. “The lack of available funding clearly indicates that a change is needed” continued Colin, “we can completely understand the need to become facility led. One would assume that improvements in the Stadium would, if correctly managed, lead to increased revenue streams from ticket sales, increased ticket prices that reflect the better amenities available, increased catering, hospitality and corporate sales and higher commercial and merchandise revenue, this is what you’re after is it not?” “In broad principles, yes” replied the CEO.

Now moving on to the site of the proposed stadium Colin, somewhat mischievously asked Robert Elstone, “This criteria, Available, Suitable, Accessible, Viable and Deliverable, was this developed by Everton or was it borrowed from Tesco? It seems to be for a supermarket and retail park development?” Robert Elstone replied, “Seems sensible to me, I’m not aware that it's a Tesco plan.” “The reason I ask is that in many people’s eyes this location doesn’t meet the stated criteria, does it in your opinion?” “It does” “We’ll agree that it’s available, Knowsley have bent over backwards to accommodate you, some would say forwards but as for being suitable it's a park on a former tip with class one and two waste isn’t it?” “We have engaged with experts who say the site is possible.” Replied Elstone. Colin came back again, “Do you know if the site is going to be excavated or compacted?” “Don't know.” Said Elstone. “So that'll be an additional cost?” “Our advisors will have costed this.” “Even if they don’t know if it’s to be compacted or excavated?” “It’s been costed.”

“The stadium was originally described as a 55,000-seat stadium but was capped at 50,401 in this application; do you believe that a town of 42,000 after experiencing an influx and rapid departure of 50,000 supporters over a four-hour period, would agree to a 20% increase in capacity?” “Yes, ask Mr. Ellis of SDG.” “Would you agree that this proposed stadium has clear and apparent access issues? In paragraph 7.1.3 you describe access as critical, yet you’re so concerned with access issues you’ve borrowed another tactic from Tesco and you’ve set up your own transport group, haven’t you?” “Yes” Elstone agreed, “we have set up a group.” “Do you agree that Evertonians of all ages should me made to walk up to 45mins, queue for buses that may or may not be available or wait in pens for over one hour and a half before being “crush loaded” onto trains?” Colin received no reply so he pushed on, “Have you considered that the old and the infirm will be the slowest to exit the stadium so, being last to arrive at the bus or coach facilities, they will wait the longest. I’m amazed that anyone would claim that this criterion has been met?”

At this point, Mr. Patrick Clarkson QC, acting for Tesco, perhaps wishing to protect his witness, interrupted and pointed out that these were matters for SDG and that Mr. Fitzpatrick had been so informed. Mrs. Wendy Burden agreed that it was a matter for another witness. Colin protested, “Madam, I appreciate what you’re saying but I would point out that I’m asking the CEO as we’re talking about his customers here.” Mrs. Burden reinforced her point.

Colin continued “When it comes to viability the cross subsidy is clearly available, have we decided if it’s still coming from the critical mass of retail or is it now being provided by another source such as the value of the land provided by Knowsley and purchased by Tesco?” “Yes” responded Robert Elstone. Colin went on to ask “We’re sitting in a public inquiry surrounded by neighbouring authorities citing significant departures from a whole host of planning policies, how can you say that this is deliverable, Isn’t it the case that three of the qualifying criteria are clearly unsatisfied Or is two out of five acceptable?” Robert Elstone: “We believe it is deliverable.”

Now switching to the ability of the stadium, Colin asked: “What research have you conducted to assure and confirm that this figure can be obtained?” Robert Elstone replied “We've looked at the volume of ticket buyers and the dispersion of the fan base. 75% are within 12 miles of Kirkby. We will also be working on new marketing programmes.” Colin continued, “You’ve previously told me and shareholders that Goodison generates £800,000 of revenue everytime it opens it gates?” “Yes.” “Does this figure include everything? Ticket sales, catering, hospitality?” “Yes.” “So you could say that over the course of a nineteen game premiership season and three additional cup competition games, on the basis that an average attendance of 37,000 generates 800,000 per event an increase of 10,000 would generate an additional £5m per season and a further £1m from the six additional events as outlined in para 10.3.2?” “That information is confidential.” “But it’s confirmed in a letter from Deloitte, Dan Jones stated from our work with the club to date on its business plan we understand the annual potential business to the club of the new stadium is of the order of £6M” “Robert Elstone replied “That’s profit not revenue”

“And just to confirm” Colin asked, “this figure is based on a target of 47,000?” “Yes” was Robert Elstone’s reply. Colin then asked; “What research have you undertaken to prove that you can fill the stadium?” Robert Elstone replied that he had responded to this earlier in the day when he gave details of ticket sales analysis. “In para 8.1.8 you tell the inquiry that Everton conducted a ballot in 2007, what was the result?” “Other schemes were mentioned at the time and we got 60%” answered Elstone. “40% of your customers were against this?” “Yes.” “Has there been some unrest since this?” Robert Elstone laughed and said “you could say that, yes.”

“You say in para 8.4.4 that Everton has a pool of 60,000 matchgoing supporters, 25,000 season ticket holders and 35,000 that you describe as active buyers, is that correct?” “ No, 30,000 had held a season ticket over the last three years, a further 60,000 individuals had attended at least one game” “So, you’re now saying there are 90,000? Most match going Evertonians weren't given the vote, but you’re now expecting them to flock to Kirkby? Why where they not included?” “We canvassed the most active” was the CEO’s response.

Colin continued “Have you surveyed the fanbase since the ballot to ascertain if their feelings towards Kirkby have changed?” “No” came the reply. “Why haven’t you done this? Is it because some people are alleging that the club and Sir Terry Leahy misled the fans and that the result of any survey would be detrimental to your claim surrounding a mandate?” “I don't think it prejudiced the ballot” responded Robert Elstone. At this point an attempt to refer to material surrounding Keith Wyness and Terry Leahy was challenged by Mr. Patrick Clarkson and upheld by the planning Inspector.

Colin, dropped that particular line of questioning and began a new attack; “Other clubs have elected to follow the relocation route in a bid to increase their stadium derived revenue, Arsenal have already relocated to a 60,000 seat stadium Ashburton Grove, around the corner from their traditional Highbury home. Tottenham are building a 60,000 seat stadium next door to White Hart Lane, West Ham are hoping to relocate to a new ground in the east end of London and our nearest and dearest across the park; Liverpool, are attempting to build a 60,000 seat stadium in Stanley Park next to their ground at Anfield. Can you tell me Robert what was Arsenals season ticket waiting list before their move?” Robert Elstone; “Not sure.” Colin; “It was 20,000, what’s Tottenham’s?” Elstone again;“Not sure, its substantial, 28,000?” “It’s 22,000 and West Ham is 8,000, no laughing, what’s Liverpool’s?” This time it was Robert Elstone who asked the question; “Go on?” “It’s 65,000 according to their website, it probably includes 32,000 Norwegians but none the less it’s substantial. What’s Everton’s?” “We don't have one,” replied Elstone, before claiming that “Other clubs have filled stadia without waiting lists.” “Really?” Asked Colin. “Bolton, Middlesbrough and Sunderland prior to the development of their new grounds didn’t but that the new stadiums were filled after the completion of the development.” “Really?”

Colin pressed on. “As the person responsible for delivering commercial growth, principally via filling the stadium at higher yields, as confirmed by you in para 1.2, could you describe what measures you will employ to overcome the loss of the new stadium effect?” The CEO answered, ”We will work with the local community”

What’s happening to Goodison’s attendances at the moment, where are they in relation to last seasons 37,000?” “As I said earlier…….” Came the reply.

Colin once more changed tack. “While I remember, at lunchtime I was sat with three other Evertonians, between the four of us we had over two hundred years of attendance at Goodison yet not one of us had ever heard of the 53% figure for obstructed views that you mention in para 5.3.11. When was this introduced? For the inquiry?” Robert Elstone explained; “It’s been there forever. It's not a figure I was familiar with though.” Colin continued ”Do you discount all of these tickets?” “No” replied Elstone. “Thought not,” said Colin, before continuing; “you go on to say in para 8.4.4 that Goodison Park only has 3, 500 obstructed view seats, which is it, 3,500 or 21,000?” “It's clear in the application. 17,000 obstructed, 3,500 can't see the goal mouth.” Colin clearly wouldn’t let this go, “so that I’m clear here, it’s a 40,000 seat stadium and we have 25,000 season tickets, you’re telling me that we have 6,000 season tickets holders who have paid for seats with obstructed views?” “Absolutely” said Elstone, “yes”

“Returning to demonstrating future demand,” Colin continued, “have you conducted a survey of match going Evertonians as to what their requirements are?” Elstone was clear; “No.”

“The route Everton has elected to take, relocation, rather than redevelopment, how successful has it been for other clubs?” “Arsenal, Sunderland, Man. City, Bolton they’re all successful.” “Really? Table 8.2 lists all the new stadia constructed since 1992, do you know what the combined average attendance is for these stadia? Elstone was again clear; “No.” “It’s 77%,” replied Colin, “that would mean an attendance figure of 38,000, that wouldn’t be good would it?” Elstone was in no doubt; “No.”

KEIOC were unable to exhibit the following chart at the inquiry for procedural reasons, it was described to Robert Elstone:

Image

Colin asked “What steps have you taken to ensure Everton will be nearer Arsenal’s attendance than Sunderland’s?” Mr Patrick Clarkson once again interrupted saying that this was old ground.

Colin started again “In section 8.4 you list the financial benefits of moving to Kirkby, you claim that you’ll achieve substantially increased ticketing revenue, I think we’ve established that this may not be the case. You next claim that corporate hospitality sales will improve. You appear to be doing what you’ve done with the stadium here, you’re putting forward a build it and they will come plan. What evidence have you got that people will flock to the new corporate facilities at Kirkby, what research have you done, have you surveyed people?” “None, that I know of” was Elstone’s reply.

“Are the current hospitality facilities at Goodison over subscribed?” “No not all of them.” Said Elstone. “How many lounges are there?” “Eleven.” “And how many are under-subscribed?” “Nine.” “So the vast majority then”

“The marquee, does it sell out on a regular basis?” “Irregularly.” Replied Elstone. Colin asked “Why?” “It's a poor facility in a poor location, you have to walk across the car park.” “But it’s true Liverpool wanted to use it as they have too many guests to cope with at Anfield?” “Yes” said Elstone. “Would this have brought money to a club with limited funds?” “Yes” confirmed the CEO. “Who prevented it going ahead?” “The board didn't like it.” Colin continued; “So Liverpool could fill it but we can’t?” Again, Elstone agreed; “Yes.” “Despite telling all and sundry how poor the facilities are could you just tell me how good the hospitality is at Goodison?” “It’s the bottom of the league” said Elstone, “the parking facilities are poor, like I said earlier”

Mr Clarkson again felt the need to interrupt proceedings, claiming that this had been covered by other people, Colin remained firm “Madam I have a point to make, it hasn’t been covered.” “So these are poor are they? Can you confirm that they are in fact award winning services, didn’t they win the directors choice award when the opposition was Arsenal, Newcastle and Chelsea amongst others?” Robert Elstone explained “that was just for directors hospitality.” “No it wasn’t, the club also won a Certificate of Achievement award for the overall hospitality experience.” “That was just for service…….” “Let me read out the examination criteria “PARKING, SIGNAGE & WELCOME, FOOD QUALITY & STANDARDS OF SERVICE”

Colin continued; “So can I ask you again, why, is it that Everton can’t sell these award winning services and can you demonstrate that you will in Kirkby?” Robert Elstone responded, “The Marquee arose out of surplus demand but the quality has deteriorated. The majority of our buyers are Evertonians, currently 75% of hospitality members were fans of the Club, we don't benefit from neutral corporates”

Image

Colin once again changed tack: “Does location play any part in this conundrum? Wasn’t it Konrad Hilton that once said the three most important things for a hotel are location, location, location does this not apply to a football club?” Robert Elstone replied “I don't believe it will have a significant impact” “Won’t being nine miles from Liverpool City Centre provide an extra challenge to the management team at Everton?” Colin asked, before continuing; ”What research have you conducted, have you surveyed the fans, the bulk of which live in Liverpool, Wirral and North Wales, on if they will make the extra journey that will prove very time consuming due to congestion?” “Don’t Know” replied Elstone, before asking “is Kirkby five miles from Goodison?” “Yes, it’s not me that saying it, it’s the RAC, the average distance a premiership club is from their major center is 2.6 miles, Bolton is 5.5 you’re proposing taking Everton 9 miles. “

Colin then explained that he wanted to close by asking some questions on Everton’s ability to pay. Colin asked, “First the securitisation of a stadium naming rights deal. Can you just describe how these deals are structured? Are there various elements such as a basic award and then bonus performance related payments? Which element is securitizable?” Robert Elstone; “It depends on the partner, brands won't commit without planning permission.” “Where are Everton with their deal, you said it would be concluded in December and here we are, what’s the status?” A smiling Robert Elstone explained, “It’s delayed.” “Why?” “Because it requires a stadium!” “Was Mr Wyness correct when he said Everton are expecting £25M?” “Don't want to put target figure in public domain” said Elstone. “He’s already stated this last year, it’s already in the public domain and there’s no change of business plan.”

Once again Colin, “It was originally stated that Everton would receive £15M for Goodison, would you say that this is optimistic, what are the land values in Walton?” “We have targets” replied Elstone “and are confident about delivering the funding mix.”

Colin moved to the sale of Bellefield, “The sale of Bellefield, do you still believe that you’ll obtain £8M or have you revised your estimate? I’d be amazed if we’re not looking at finding approx £45M through the last two methods” Robert Elstone responded “None of the sources are guaranteed. We can raise the money at the right time.” Colin informed the CEO that “this isn’t what Everton’s barrister told the inquiry in Liverpool into Bellefield.”

“To bring this all together it would appear to many, and I must say I’m even more convinced that this is not right for Everton. Would you agree that what we have here is a scheme that nobody knows the true cost of, that nobody knows if the fans will travel to Kirkby, that nobody is completely certain where the money is coming from and that all the indications are that it is being promoted as something it isn’t; that is a long term cash generator that will be beneficial to Everton Football Club? Didn’t Everton have to prove to Knowsley that they have the funds?” Robert Elstone responded, “I’m not aware that KMBC asked if Everton had the money.” “Really?” Asked Colin. Robert Elstone said “Yes.”

Colin closed with “Everton have a wish list of methods to raise funds, how much money from that list has been secured to date?” Robert Elstone answered “Nothing.” “You’re saying you haven’t got a penny?” “No.” “Isn’t it the case that this was little more than a Trojan horse that was originally promoted as the means to deliver an inappropriately sized supermarket and retail park and that on close inspection it would appear to have the capability of transforming into yet another of Kirkby’s infamous white elephants.” “No” replied Robert Elstone, “I believe the main beneficiaries are our children.

Colin thanked Robert Elstone and Mrs Burden, Mrs Pethard from the grange then took over the questioning, her first question concerned the possibility of concerts being given planning permission in the future, contrary to the current planning application. Robert Elstone explained that he was unaware of that condition being removed in the future.

Mr Clarkson then took the opportunity, as is his right, to cover any of the points that he felt needed some clarification.

We Interviewed Colin at the close of the inquiry he explained “It was a lot tougher than I imagined, Robert Elstone was a very credible witness who put on a good performance but I thought we scored a few points.” He came over for a friendly chat afterwards, there was no animosity, irrespective of the inquiry we’ll be taking up a few of our concerns particularly surrounding the future performance of a new stadium in Kirkby!

The KEIOC campaign would like to thank the donator who came forward at the end of the day and presented the campaign with a cheque for £500.

Day 11, Everton’s experts come under scrutiny.


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 Post subject: Re: Day 10 Kirkby Fears Confirmed –
PostPosted: Mon Dec 08, 2008 3:53 pm 
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Just read through the whole piece , I thought Colin Fitz did a great job .


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 Post subject: Re: Day 10 Kirkby Fears Confirmed –
PostPosted: Tue Dec 09, 2008 11:50 am 
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jartyjones wrote:
Just read through the whole piece , I thought Colin Fitz did a great job .


Absolutely agree - having read the piece, he seems to have done brilliantly.

Hopefully his line of questioning will go/has gone some way to illustrating just how incredibly badly 'thought' out, lazy, desperate, dumb and slip-shod, Kenwright's folly really is.

k e i o c !


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 Post subject: Re: Day 10 Kirkby Fears Confirmed –
PostPosted: Tue Dec 09, 2008 12:01 pm 
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Agreed - Colin and the rest of the committee have done superb work on the campaign so far but moreso during the enquiry, to go through the documents and to stand up and cross examine those representing the club isn't an easy thing to do but they deserve many thanks and credit for doing so


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 Post subject: Day 11 – “Kirkby Fails to Meet Standards.”
PostPosted: Sat Jan 03, 2009 8:56 pm 
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http://www.keioc.net/index.php?mact=New ... eturnid=15

Friday, 12 December 2008
Day 11 – “Kirkby Fails to Meet Standards.”
The previous day concluded with Mr Chris Potts of Savills being led through his evidence by Tesco’s QC, Mr. Patrick Clarkson. Chris, well known to shareholders at Everton for presentations given at general meetings, explained that over the past ten years it had been discovered that the redevelopment of Goodison Park wasn’t viable, as the club needed a stadium that met current standards.

Clearly not present at the earlier cross-examination of Robert Elstone he went on to explain that Everton needed a 50,000-seat stadium, expandable to 60,000 (forbidden by KMBC), with seating for corporate hospitality guests of 2,000 to 3,000 and a host of other facilities that any new or redeveloped stadium could potentially offer.

Having personally assessed many sites around Liverpool using the supermarket type criteria of availability, suitability, accessibility, viability and deliverability Chris explained that no football club would attempt to move without applying this thorough approach and went on to explain, incorrectly, that after the ballot Liverpool City Council “came up with” the Loop site proposal, clearly the 4,000 Evertonians visiting the KEIOC exhibition in St Georges Hall at the time of the ballot were simply passing through? Chris continued to inform the inquiry that he had advised the club the site in question was too small, inaccessible and would prove very expensive to deliver. KEIOC can confirm that not as mention of a plinth was made throughout the presentation. For those inquisitive readers that wish to know what a plinth is, you can read here (and probably weep).

Mr Sauvain QC, acting on behalf of Liverpool City Council began his cross-examination of Chris Potts by asking questions concerning expanding the footprint of Goodison Park. Chris explained this had been looked at in some detail but was simply not viable.

Chris explained that since 2006 Everton had been investigating the possibility of sites with the potential of enabling facilities and that Everton hadn’t approached the NWDA for funding as LFC had done with their development, they’re receiving £10M towards the total cost of their stadium. Everton not pursuing this method of funding may have something to do with Tesco having approached the NWDA for a similar amount; unfortunately Mr Sauvain did not ask this question.

Chris finished by innocently offering the opinion that a change of ownership at Everton would not necessarily resolve the funding of the stadium, citing the problems involving the new ownership at LFC. So if nothing else Chris has confirmed that there are funding issues concerning Everton’s ability to finance the move at this moment in time.

Trevor Skempton, Urban Design Consultant, questioned Chris Potts on behalf of KEIOC.

Trevor stated: I wish to establish the precise nature of the site that was being sought in the various investigations that led to the extraordinary conclusion that there was nowhere suitable anywhere within the City of Liverpool.

Trevor asked, “I notice in your CV that were involved in the highly controversial move of Wimbledon to Milton Keynes” Chris replied “No, MK Dons were already there, I moved them to a new stadium” Trevor “Do you think that the treatment of football clubs as franchises to be moved from older cities to new towns [to give them some sort of instant identity] is going to be – or should become - a pattern in the future?” Chris” I’m not aware that they are operating as franchises; the structure is not something I'm clued up on.

Trevor continued “Yesterday, we heard the phrase: ‘location, location and location.’ But do you think that, in this particular case, other factors that are more important? “We have heard that Everton’s highest density of support lies across Merseyside and North Wales. This is the same region that is served by Liverpool’s theatres, the Philharmonic, the Arena and of course the new Liverpool One development. Not to mention the city’s cathedrals…. Can you envisage any of these being wrenched from the heart of the city?” Chris replied “A blend of issues; it (Kirkby) meets the requirements and is affordable, within the heartland of EFC fans. I’m not sure if commenting on location strategies is what I'm here for.

Trevor continued “With reference to your answer on enabling – or as you have called it ‘subsidizing’, the process leading to the identification of a site for the relocation of EFC has not solely been made on the basis of simple land availability or suitability for a stadium. The viability for the construction of a stadium for Premier League and potentially Champions League football in terms of quality, capacity and facilities; requires EFC to include enabling development funding, have you considered forms of enabling development other than major retail?” Chris replied, “The only case to secure a non-retail subsidy was the Emirates, for 2,500 homes in Islington. Islington prices equal a subsidy”

Trevor “You go on, in the same paragraph, to state that [of enabling development]: “this was a key factor behind the ultimate collapse of the Kings Dock proposals…. and viability remains the key factor.” How was ‘enabling’ a key factor in the collapse of the Kings Dock proposal? Chris responded, “King's Dock was a combination of factors, it was incredibly complicated and created a lot of costs. Trevor responded “As I recall, LCC invited bids from Developers (as they did with Grosvenor and the Liverpool One development) and selected Everton (under the name of Houston Securities) from a short-list of four after a rigorous public exhibition and consultation process. Was it not the case that the Kings Dock proposal was a partnership between Everton and a major events organization, in this case the public sector, and that the deal offered to Everton was even more favorable than Kirkby, on a site that had widespread support?” Chris replied “EFC pursued King's Dock with great vigor; a regrettable conclusion.” Trevor pushed on ”Was it not the case that the City Council were anxious to secure the deal as part of their successful bid to be European Capital of Culture (awarded in June 2003) and gave Everton an ultimatum to put up or shut up?” Chris “I can’t comment”

Trevor “Isn’t it the case that the reason that no site was available is that your search has been fixed on a type of development that was clearly contrary to Planning Policy, and could therefore not be supported by the City Council” Chris gave the response ”Incorrect, in most cases the planning authorities can see the benefits.” Trevor enquired, “Isn’t this the reason that the search switched to investigation of sites outside the city boundary, in Sefton and Knowsley? Chris” No”

Moving on to the current Arena and Conference Centre site, at the Kings Dock, Trevor enquired “Are you aware that the remainder of the site has more than enough space to house a stadium like the Millennium stadium, together with a sliding pitch? Has the exclusivity agreement between Everton, Tesco and Knowsley prevented discussion of alternative opportunities such as this as they arise and furthermore would you agree that, especially with the collapse of the housing proposals for that site and the potential for linkages and synergy with the very successful Arena, Exhibition and Conference Centre, that this might be investigated as a potential Plan B for either football club, if their current stadium proposals cannot go ahead?” Chris “You have raised the site, I've looked at it. It lacks enabling facility. It's a world heritage site and therefore unaffordable. English Partnerships wouldn't want us to go there either.” Trevor “ Not a plan B then?” Chris “ I don't believe it's available, viable or suitable.”

Questions then moved on to Goodison Park:

Trevor “Goodison Park is one of the most historic and atmospheric stadia in the World, and may indeed be one of the reasons for the club punching above its commercial weight. A group called “Goodison for Everton” campaigned against a previous Chairman’s proposal to move out of town. They appointed Ward McHugh Associates, architects of Twickenham, to investigate the potential for redevelopment of the existing stadium, which they did, are you aware of the Ward McHugh proposals?” Chris, “Yes they undertook a piece of work prior to Kings Dock.” Trevor “In your evidence you have said that the Club instructed Ward McHugh [para 2.1.2]. It is my understanding that the Ward McHugh study was commissioned not by the club, but by supporters to demonstrate (which it did) that redevelopment of their Goodison Park is indeed possible, can you confirm this?” Chris “ I've seen the study, it doesn’t work.” Trevor “Have discussions been held with Liverpool City Council and/or the local community over the possibility of extending the Goodison Park footprint?” “Chris “No”

Trevor next questioned Chris on alternative Sites: “I will be dealing with many of the 35 sites, and a few others, later in the inquiry )and will be arguing that many have genuine potential warranting further investigation, and at least half-a-dozen can be considered suitable); it is also my intention to question Mr Keirle about the possibilities of expanding Goodison Park. However, there are one or two particular sites that I would like to ask you about at this stage” explained Trevor before asking, “Could you explain why you have on a number of occasions so vigorously opposed the Tunnel Loop site? The first serious mention of the Loop Site was in early 2007. I know because I raised it as a possibility – details will be included as appendices to the KEIOC evidence. Discussion of the Loop Site was widespread amongst the Everton Family long before the ballot raised its head. The opportunity for the club to be involved had been there for many months before Warren Bradley raised it as a serious possibility when the site owners, Bestway, approached him with a view to developing their site for other purposes. As someone working closely with the club, can you honestly say that you had no knowledge of the Loop site prior to the ballot?” Chris responded, “The club have not been furnished with plans or proposals. I've taken advice and the joint conclusions are that it fails. I've told the site owner this; I was only made aware of the scheme on June/July 07 when it started getting media coverage.” Trevor continued, “You will be aware of the success of the Millennium Stadium in Cardiff. Many of us believe that the Loop offers a city-centre opportunity comparable to that…. What do you think are the main differences between the two sites?” Is it not simply that this proposal, which is in Everton and very close to the City Centre, is supported by the site owner and the City Council and is backed by a feasibility study by HOK Sports Architecture (architects of the Millennium Stadium), has been seen as a serious threat to the Kirkby Project?

At this point all hell broke loose as Trevor had mentioned the HOK report in passing and Chris made a fuss about never seeing it. A clearly irate Patrick Clarkson QC jumped up, once again employing his usual theatrics to unsettle opponents, and demanded that the HOK report be produced before David Kierle was cross-examined or he would request that KEIOC shouldn’t be allowed to cross-examine. A thorn in the side thereby removed?

Chris answered “I’ve received no proposals from KEIOC relating to the loop site and that having assessed the site himself, in conjunction with other stadia experts (undisclosed), had concluded that the site fail to meet the qualifying criteria.”

Moving on to Everton Park, Trevor enquired “Finally, I note that the site on Everton Park the site of the current Everton Sports Centre, within the park, would make a cracking football stadium was dismissed by Liverpool FC because of ‘development issues’…. the first of these is the issue of steeply rising land. The second is that it is located within a high-density residential area with amenity and access/parking issues. The third is that it is relatively remote from Anfield. Do you agree with these reasons for dismissal? Is it also ‘relatively remote’ from Goodison?

Trevor continued, “Could the slope not provide a wonderful opportunity for a creative architect to save money by allowing spectators to have direct access to the stadium at different levels? Do you think that it would help if a creative architect was involved in site appraisals?

The applicant’s next witness was Mr. David Keirle, an employee of KSS, an expert in the strategic design of football stadia. Mr Keirle started by describing Goodison Park as having some of the worst facilities to be found in sports stadia in Europe. He went on to say that the restricted site, common in football stadia of this age, created major problems for clubs such as Everton that attract large crowds. No doubt Mr Keirle is unaware that the record attendance at Goodison, in 1948, was 78,299.

After the debacle the previous day when Robert Elstone attempted to portray Goodison’s hospitality facilities as poor only to be reminded that they were in fact award winning, Mr. Keirle neatly side stepped that trap by now describing the facilities as good but they needed more.

Mr. Keirle admitted that the Goodison matchday atmosphere was good, even with all its apparent faults, but explained that modern thinking by stadia designers had moved towards providing safe comfortable facilities for families, he explained that Goodison failed to provide these and consequently failed to attract many families. Perhaps this is an insight into why Everton are being misled by their advisors, the majority of new stadia are failing to attract anyone. All businesses need to be market driven, not advocates of missionary work, successful company’s give their customers what they want not what they think they want.

Without taking up the offer from the leader of Liverpool City Council, Mr Warren Bradley, concerning the availability of land surrounding Goodison, and without entering into any meaningful discussions with the council on this matter Mr Keirle has concluded that the redevelopment of Goodison, on an extended footprint, would cost up to £245M for the stadium alone. He went on to explain that redevelopment on the existing footprint was also too costly but preferred to explain the features and benefits of the proposed Kirkby stadium in preference to explaining the detail behind the apparent phenomenal cost of building in Walton in contrast to building in Kirkby, conveniently dismissing the CABE evaluation along the way.

Kirkby resident Dave Kelly questioned Mr. Keirle on behalf of the Kirkby residents, Dave asked “What other stadia have been developed on or near their existing sites? Mr. Keirle replied “Chelsea’s ground at Stamford Bridge but had taken nine years to complete on a complex site, he went on to agree that Spurs were building a near stadium close to their ground at White Hart Lane he explained that the improvements at Goodison had gone as far as possible hence the reason for the search for a suitable site which had established that Kirkby was the only viable alternative available.

Dave continued, “Would the stadium plans change the Valley Road gateway to Kirkby?” Mr Keirle explained that it would be changed as it, the stadium, was a large structure but there were measures in place to lessen the impact.” Dave dropped a bombshell when he asked, ” Why do the plans for the new stadium not meet the latest stadium guidelines known as the Green Guide?” Mr. Keirle responded “It’s a building designed to meet standards and regulations in place at that time, even though discussions might be ongoing to update or change those regulations, the design for this stadium met the regulations that were in place when it was drawn up.” So that’s perfectly clear then, it doesn’t meet the standards that it’s supposed to.

Trevor Skempton next question Mr. Keirle on behalf of KEIOC. Trevor outlined the areas he wished to question Mr. Keirle on the limitations on the potential size and capacity of the proposed Kirkby Stadium, the restrictions on the potential use of the stadium by ‘partner’ organizations, the conflict between long-term design quality and short-term priorities and the potential for the expansion of Everton’s present stadium in Liverpool.

Trevor began with “What, in a nutshell, was your brief for the stadium?”

“It seems that this 50,000-seat stadium is the minimum that the club require. Is this, in effect, just Phase 1? “ What allowance have you made for further expansion on the proposed site?” “Can you put a figure on the extra capacity that is created by filling in four corners?” “ Would an infill of the South-East corner further compromise the awkward relationship with the nearby houses?

Trevor continued, “When Paul McCartney appeared at Anfield in the summer, all the staging had to be craned in over the stands, an incredibly inefficient and expensive exercise. Have you made provision for the staging of regular musical or other events? Mr. Keirle replied, “This stadium can't be used for other events but the design will allow for this in the future.

Trevor, “The structure produced by Barr seems very cost-efficient – there are no curved rows of seats or overhanging tiers. What are the major compromises that you feel have been made in order to reduce the cost?” Mr. Keirle “ I don't think there are any.” Trevor, “One of the characteristics of many open modern stadia is that empty seats become very prominent. Have you considered ways of keeping the atmosphere of a full stadium even when the attendance is well below capacity?” Mr. Keirle “I don't design stadia with a view to them being empty. Not for football anyway, marketing will lift sales to the highest capacity so it's not been considered.”

Trevor “Football fans have many very different expectations of the stadium. Some like to jump up and down crowded together, sing and express their emotions. Others like to sit in wide comfortable seats akin to those in a cinema. Have you varied the seat specification in different parts of the ground?” Mr. Kierle, “Yes” Trevor, “Detail?” Mr. Kierle, “Hospitality” Trevor, “There are different standards and means?” Mr. Keirle, “Not from a design point of view.” Trevor, “Some supporters, particularly the next generation, are being priced out of Premiership games. Bearing in mind the overall increase in capacity, have you made any allowance for new kinds of cheaper seat? ”Mr. Keirle, “I don't know about the club's pricing policy.”

Trevor continued “Singing and chanting are an important component of the big-match theatrical atmosphere, and help sell the product to the broadcasting companies. Are any special measures proposed to enhance the acoustic properties of the stadium from this point of view? Mr Keirle, “ Yes, we've tried to close stadium to focus the noise inside.”

Trevor “Yesterday, Mr. Elstone referred to Everton ‘punching above its weight’ in terms of its relative success on the field. He mentioned his colleague, the manager, David Moyes. Do you think that the character and atmosphere of the stadium could also have something to do with that?” Mr. Keirle responded, “EFC have fantastic fans which generates atmosphere. Impact.” Trevor, “Are you aware that both Alex Ferguson and Arsene Wenger have praised the special atmosphere at Goodison?” Mr. Keirle, “No.” Trevor, “Alex Ferguson described it as a “pit-bull” of a stadium, which I take to be a compliment from him, and Arsene Wenger said how much better it is than Anfield.” Mr. Keirle replied, “People close to the action have an impact.”

Trevor, “You say that Goodison Park “makes no positive architectural contribution to the immediate surrounding area” yet it creates a wonderful atmosphere?” Mr Keirle, “It's the thing that gets people still supporting the team when they are under performing.” Trevor, “you concede that parts of Goodison have a certain historic charm, have you given any thought to preserving elements of these historic structures and incorporating them within your expansion proposals?” Mr Kierle, “There is a fundamental problem with that because of spectator experience. Retaining stands that are limited by their design. There is the burden of maintenance. Can't see how they can be converted. They are tight, uncomfortable, cramped, and claustrophobic. A truly horrible experience for people who go into those stands who aren't hardened football fans, problems attracting women to football.” Trevor “Is there not a case for listing these buildings as being of special architectural and historic interest, and treating them in the same way that historic dock warehouses such as the Albert Dock have been treated?” Mr. Keirle, “No.”

Trevor, “Moving to your proof we can see an aerial view of the stadium. At the top left is the historic St Luke’s Church occupying one corner of the stadium, to the right of the stadium is the Gwladys Street School and to the bottom is a car park owned by Everton, On page 18, paragraph 3.4.5, we can see a proposal to rebuild the ground to a capacity of 30-35,000, do you regard this as the maximum possible that can be fitted on the site, or is there room for a bit more…. at the bottom along Walton Lane?” “Mr. Keirle “Yes.”

Trevor, “On page 22, paragraph 3.4.11 “Scope for enabling in the form of a hotel?” “Yes” “This is your proposal?” “Yes” “Ground intact?” “Yes” “So the proposal is leaving EFC better off for facilities, atmosphere and location than Kirkby, what about the Chelsea model, for Bullens Road?” “There’s no comparison between the two, in cost terms.” “If Everton continued to advance, would there be options to develop?” “Maybe another 3 or 4,000 on the Park End” “So the potential is there in terms of incremental development?” “There would still be problems with spectator facilities and maintenance bills. I couldn't advise the board it was sensible.” “It's a route?” “If money was no object and not being concerned about two sides, you could expand.”

Can you understand why so many supporters feel that an incremental development of Goodison Park is preferable to the risk of ‘throwing the baby out with the bathwater’?” Mr. Keirle “I can't comment on that.”

Trevor “Finally, How will the site cope with crowd dispersal?” Mr. Keirle “It's totally different, fans passing peoples houses as opposed to fans leaving onto an external concourse. Trevor “I have an image of people not knowing what to do in Kirkby after the game”

Don’t we all Trevor, don’t we all.


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 Post subject: Day 12 – Kirkby – “In a Circle of Decline”
PostPosted: Sat Jan 03, 2009 8:57 pm 
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Saturday, 13 December 2008
Day 12 – Kirkby – “In a Circle of Decline”
Mike Hollis, a town planner, employed by Roger Tym and Partners was led through his evidence by Mr Martin Kingston QC, acting on behalf of Knowsley Council.

Mr Hollis mentioned the 50 most deprived districts , which showed Liverpool consistently above Knowsley. They will be similar to the Government tables previously posted on the KEIOC website that indicate Knowsley is improving without the philanthropic endeavours of a benevolent Tesco. He explained how the tables made comparisons between levels of income, employment, health, education, skills, training and crime. In a scene reminiscent of the famous Monty Python deprived Yorkshire man sketch he went on to explain that Kirkby was more deprived than Skelmersdale and St Helens and that the North West Regional Economic Strategy is designed to decrease levels of deprivation in the worst 5% of areas; this will in all probability include areas such as Walton, Kirkdale, Bootle, Skelmersdale and St Helens?

Displaying a total disregard to Kirkby’s geographical location, in relation to Liverpool, and Skelmersdale’s location next to, well nowhere really, Mr. Hollis explained that Skelmersdale retains 71% of its convenience expenditure whilst Kirkby only retains 46% if its convenience and 15% of its comparative expenditure. He explained that the quantum of need couldn’t be accommodated within the existing town center therefore “the need is significant and the scale is essential”. He closed by explaining that, “Kirkby was caught in a “circle of decline”, it had a very deprived catchment area and an underperforming town centre, which led to the migration of more affluent shoppers, this makes it difficult for KMBC to attract new retail tenants”

The problem with over egging the pudding is that, like others at this inquiry, you tend to get caught out, Mr Sauvain QC, acting on behalf of Liverpool City Council began his cross-examination of Mr. Hollis who continued to maintain the company line that Kirkby is a seriously deprived area inhabited by work-shy individuals. Mr Hollis explained, “There’s a high level of worklessness in the town and Tesco can deliver in this harsh economic climate.” A somewhat puzzled Mr Sauvain, referring to Government information on deprived areas suggested that Knowsley were improving their position in the deprivation league without Tesco’s intervention. Mr Hollis finally conceded that there had been a significant increase in employment in recent years Mr. Sauvain continued, “these Tesco jobs would be a drop in the ocean, there is no guarantee that all phases will be completed and that there was no commitment from other stores on the Job Guarantee scheme.”

Mr. Sauvain persisted “It’s a fact that these were low-paid, low-skilled jobs and it would always be council schemes that would be primary movers in solving long-term problems” Mr Sauvain then turned his attention to the applicants apparent disregard to the UDP which led a clearly irate Mr. Hollis to respond “In an ideal world you would do things in due process, however this “all or nothing” situation is here now, we can’t wait until 2011 for the LDF, it wouldn’t be fair on the next generation”

This display of emotion clearly motivated Mr. Sauvain, who continued with “it doesn’t help to explain things in a emotive way; your development won't solve Kirkby's problems, it's not going to save a generation is it?” Mr. Hollis replied in management speak “it would make a valuable contribution to meeting the regeneration targets” he continued by explaining that the proposal wasn’t out of scale for the area, nor did it contravene the Regional Spatial Strategy and that there was a considerable amount of evidence presented to the inquiry surrounding the type and scale of needs that were required to be met.

The cross examination is scheduled to continue on Tuesday.


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