G R V Ashworth
Head of Planning and Regeneration
Monmouthshire County Council
Environmental Department
County Hall
Cwmbran
NP44 2XH

By Fax (01633 644800) & Post

Our Ref: PS/rs/S.A.U.C.E./20176

Your ref:

6 December 2006

Dear Mr Ashworth,

Proposed Redevelopment of Cattle Market, Lion Street, Abergavenny

Application No.: M/12559

We are acting for SAUCE (Save Abergavenny's Unique Character and Environment). We are aware of your correspondence with the group. You will no doubt be aware that SAUCE represents a number of business, amenity and environmental interests including Abergavenny Development Forum, Abergavenny Civic Society, Abergavenny and Crickhowell Friends of the Earth, Abergavenny Tourists Association, Abergavenny Chamber of Trade and Campaign for the Protection of Rural Wales, Monmouthshire Branch.

We are aware that at Monmouthshire County Council's (MCC) planning committee meeting of 3 October 2006 the members voted to refuse planning permission for the above project. We have seen the minutes of that meeting. We have also seen the minutes of the meeting of the planning committee of 17 October 2006 and the recorded reasons for refusal. We return to that matter below. We understand that MCC's planning committee is to give further consideration to this application on 12 December 2006 and indeed may be asked to vote on an officer's recommendation to grant planning permission for the above project notwithstanding the earlier resolution to refuse permission. At the time of writing this letter we do not know whether the meeting on 12 December 2006 will be asked to consider an officer's report, or vote on an officer's recommendation. Either way we ask that this letter be taken into account by officers and members and reported fully to members before any decision is made in the determination of this application for planning permission albeit that this decision may not be made on 12 December 2006.

The purpose of this letter is two fold:

•  To set out our group's concerns as the context for potential grounds on an application for judicial review if permission is granted;

•  To set out the potential grounds of an application for judicial review.

The Context

We are concerned that there appears to have been a general background to the officer's approach to this project of not giving all relevant information to either potential developers or members, and even going so far as to misleading and manipulating members once members had decided to reject this application on 3 October 2006.

We are well aware that the development of this site is contingent on at least two major conditions precedent:

•  That in due course the relevant decision maker will agree to repeal the Old Abergavenny Acts that require MCC to hold a cattle market in the vicinity of this site;

•  That a suitable alternative location for the cattle market can be given the necessary consents elsewhere in the county.

Our concern focuses mostly on the first of these conditions. From our understanding of the position potential developers were not made aware at the time of bidding (and expending fees) that development of this site required repeal of the Old Abergavenny Acts. That is at least unfortunate and serves as an example, if true, of incompetence and a general cutting of corners in the officer's approach to this project.

Of much more significance is the officer's approach to the members' decision to refuse consent for this project on 3 October 2006. >From our understanding of the position members voted to refuse consent for the project outlined in the application before them. Indeed we note the reasons for refusal at paragraph 4.0 of the supplementary report to planning committee on 17 October 2006. This reads as follows:

“ 4.0 Reasons for Refusal :

•  The proposed development by virtue of its modern design will create a visually intrusive and discordant element in the town centre that fails to respect the character and appearance of the area contrary to policy ENV1 and DES1 of the Monmouthshire Unitary Development Plan.

•  The site is located adjacent to the Abergavenny Conservation Area. That modern design of the proposed development fails to respect the character and appearance of the Conservation Area. ”

With the above in mind we suspect that some at least (if not a majority) of the members deciding this matter on 3 and 17 October 2006 were under the impression that they were refusing permission for the proposed development and not merely limiting their concerns to the design of the superstore. We note from item 2 of the minutes of the 17 October meeting that the matter was left open by the following:

“ 2. The minutes of the meeting held on 3 October 2006 were confirmed and signed by the chairman. In doing so there was some debate over the reason given for the recommendation that members be minded to refuse application M/12559. However it was agreed that the matter be addressed when reconsidering the application later in the meeting. ”

We note that the minutes of the planning committee of 17 October 2006 note that the following amendment was carried:

“ We resolved that application M/12559 be deferred, as the earlier reason for refusal, the design of the superstore building was out of keeping with the historic market town and detrimental to the character of the area, was the reason for refusal and the revised sketch design was welcomed in principle and subject to the outcome of a full consultation on revised and detailed drawings could be favourably considered. ” (sic)

Our concern is that it appears arguable that a majority of the members were under the impression that they had voted to reject the very principle of the proposed development and not merely limited their objections to the design of the superstore with the clear implication that if design concerns could be resolved the project should be approved. We are aware of your own input in this matter and are concerned that members have been potentially manipulated by that input. We bear in mind the following passage from the minutes of the planning committee of 17 October 2006:

“ The head of Planning and Regeneration explained that the reason for the refusal, recorded at the last meeting, being restricted to the design of the superstore building, was as a result of the opposing views expressed on the other aspects of the application, as shown by the views expressed by members at this meeting. The only issue that obtained majority support for refusal was the design of the superstore building, and the reasons produced for refusal were therefore restricted to that issue .” (sic)

With due respect that appears to be your retrospective reasoning to justify why the developers should be given a further late opportunity to obtain approval by satisfying members on design aspects when in fact it is arguable that a majority of members had already rejected the project in principle. Bearing in mind the ground below regarding your conflict of interest we strongly recommend that there be a full and transparent debate at committee with members able to record their precise position on two alternatives:

•  Whether they object in principle to the proposed development.

•  Whether their objections are limited only to design aspects of the superstore which are capable of resolution by the developer.

Our client would be content not to include the above issues in grounds for judicial review if the members vote to record their position on the two options set out above. Without that clear transparent democratic process our client group will remain extremely concerned on the potential manipulation of members on this issue.

Grounds on a Potential Application for Judicial Review

Ground 1 – Likelihood of Appeal

We refer to the minutes of the planning committee 17 October 2006. At page 3 the following is recorded:

“ In response to a question regarding the process the committee's original view that the application be refused on grounds relating to the design of the superstore, was confirmed at the meeting, the head of Planning and Regeneration explained that the refusal notice would be issued and the applicant was likely to appeal the decision via the appeals process. ”

We submit that this represents a fundamental misleading of the members such that there is a serious risk that the members have taken into account a wholly immaterial consideration, namely, the costs to MCC of conducting a planning appeal, and the potential of costs against MCC if the appeal were to be in favour of the developer. In our view it is critically important that the members be given accurate advice as to the correct position and they were not. We now set out the correct position.

•  We refer to the Building Agreement relating to this project in schedule 8 planning conditions. You are of course specifically aware of this agreement as apart from anything else you are responsible for MCC's Asset Management Function which includes the regeneration of the cattle market (see below).

•  Paragraph 1.1 of the agreement defines an appeal to include “ an application to the National Assembly for Wales under Section 73 of the Planning Act following a Planning Refusal by the local planning authority .”

•  Paragraph 1.1 defines Planning Refusal to include (a) a refusal by the local planning authority to grant planning permission pursuant to a planning application.

•  Section 6 deals with appeals and planning proceedings. Section 6.1 provides that “ following a Planning Refusal the Tenant [here Henry Boot] is not to appeal or commence Planning Proceedings except in accordance with this paragraph 6. ”

•  Paragraph 6.3 provides as follows:

if the tenant wishes or the landlord so requests following a Planning Refusal by the local planning authority where the Planning Refusal arose for any other reason other than a failure to determine the Planning Application under Section 78(2) of the Planning Act:

(a) the Tenant and the Landlord are to instruct Planning Counsel to advise on whether an Appeal or Planning Proceedings would stand a greater than 50% chance of resulting in the grant of a Satisfactory Planning Permission; and

(b) if Planning Counsel advises that there would a greater than 50% chance of obtaining Satisfactory Planning Permission on an Appeal or following Planning Proceedings, the Tenant is to Appeal or commence Planning Proceedings depending upon Planning Counsel's advice as to which option maximises the chances of obtaining Satisfactory Planning Permission

•  Section 6.4 provides as follows “I f the Tenant makes an Appeal or commences Planning Proceedings it is to:

“ 6.4.1 do so at its own costs and expense; 6.4.2 prosecute the Appeal or Planning Proceedings with all due diligence and in a good and efficient manner…

It is manifestly the case that if this agreement remains in force it provides for a procedure whereby MCC are in a position where it is able to refuse planning permission for this project in the certain knowledge that if Planning Counsel advises that an Appeal would stand a greater than 50% chance of succeeding and thereafter the tenant makes an Appeal it is to do so at its own cost and expense. Nowhere is this position recorded in the relevant officer's report or minutes. We are well aware from a wide experience of similar matters in other authorities over the last decade and more that members often decide to grant permission for a project because they are concerned at the risk of costs if they were to refuse permission. Plainly they should have been given clear and accurate advice on this important matter and they were not.

We should make clear that unless this matter is dealt with appropriately and members are given the advice on the correct position in accordance with the above Building Agreement if permission is granted for this project this ground is highly likely to feature in an application for judicial review.

Ground 2 – Misrepresentation of MCC's Conservation Officer's Views

We have sight of the representations to your committee of Edward Holland, of 17 March 2006, being the relevant MCC conservation officer. A reading of this full response leaves one in no doubt that the conservation officer was recording fundamental objections to the very principle of this proposed development. Before introducing his more detailed comments he notes that the application “ proposes a level of development that will have a significant impact on this site.” (Our emphasis). He goes on to record that “ Abergavenny's long history as a market town makes the cattle market of material interest to the heritage of the town and its removal should endeavour to retain as much of a memory of that as possible. By contrast this application if granted consent would leave nothing of the former cattle market and would miss the opportunity to create a regeneration through heritage and would fail to create new uses that reflect the old .” Pausing there the conservation officer notes the significant impact of the project and gives three separate reasons, which we submit are fundamental, as to what is wrong with the application. We submit that these are extremely serious concerns and are in no way reflected in the report to members.

The conservation officer then goes on to deal with detailed comments which include the following:

“ Architectural Design Statement

1.2 (page 2) states that it follows the Urban Design Framework but comparison of that document (which I supported) and the submitted plans appear to have little correlation. For example the Urban Design Framework says that “the existing buildings associated with the Slaughterhouse complex, whilst not listed, are considered to be of significant townscape value to warrant their retention part, or whole, are fundamental to the realisation of the overall aims for the revitalisation of Abergavenny” (sic)…” “Development should reinforce the urban form and historic setting of Abergavenny” “The former Slaughterhouse buildings are considered appropriate for conversion” “The historic use of this site for livestock trading should be explored as a theme, to instil a sense of continuity and appreciation of the site's history”

None of these serious concerns have been reported to members. We see little point in having an Urban Design Framework if it is to be cast aside with no regard. Here the MCC's own conservation officer is saying that the plans have little correlation with that Urban Design Framework with specific examples given. We submit that these are fundamental concerns, should have been reported to members, have not been reported to members, and represent a serious flaw in the decision making procedure.

Elsewhere the conservation officer records a further objection as follows:

“ Archaeology is referred to in this Design Statement but is a significant issue. The designs produced in tandem with the Urban Design Framework proposed the foodstore further west and had no underground parking; the eastern edge of the site is known to have more important archaeology with evidence of the Roman fort and even further west the depth to which underground parking might be dug would impact on the archaeology making it vital that no consent is granted until an archaeological investigation has been carried out and agreed in conjunction with GGAT. ”

To conclude the conservation officer records the following:

“ The various reports do not make the connection between the identification of Abergavenny's long and important market town history with the need to retain some of the character of the former cattle market. The fact that the 19 th century Slaughterhouse buildings are capable of reuse, even if not for all the uses proposed for this area in this application, is not considered but equally nowhere does it state that the buildings are beyond reuse. The Urban Design Framework was clear that they could and should be reused. This consultation response is not arguing for total retention without alteration but consistent with earlier advice is arguing for conversion and reuse of what is of good and relevant character and adaptation of the overall concept to suit that reuse . This site could draw extra individuality, interest and quality from reflecting on the heritage of the site. ”

We refer to paragraph 4.2.8 of the report to committee of 3 October 2006 which summarises the MCC conservation officer's views in two lines thus:

“ Roof proposals conflict with townscape, stilts and design of residential block unsatisfactory, amongst general design and archaeological concerns. ”

We accept that the conservation officer was indeed registering concerns on those matters of detail. However it is plain that your officer's report does not draw the attention of members to the fundamental concerns we have set out above. We need not remind you of your legal duty to ensure that in determining this application members do not take into account immaterial considerations and take into account all material considerations. We submit that it cannot be disputed that members have fallen into error on both fronts:

•  They have not taken into account the conservation officer's fundamental concerns particularly regarding the lack of correlation with the Urban Design Framework and

•  Accordingly they have taken into account an immaterial consideration, namely, by proceeding on the understanding that the conservation officer has not registered these objections.

Again we make clear that if planning permission is now granted for this development without the conservation officer's views being reported accurately to members this matter is highly likely to feature in grounds on an application for judicial review.

Ground 3 – Representations from Professor Richard Parnaby

We refer to the addendum report “ Late Correspondence Received Since Closing Report, Planning Committee – 17 October 2006 ”. In that report from officers the following is recorded:

“ Further correspondence has been received including from the Design Commission for Wales, attached, and from Professor Richard Parnaby supporting the DCfW objections to the scheme but accepting that the principle of a supermarket on the site would be difficult for a planning authority to resist. ”

We have sight of the two page letter from Professor Parnaby of 11 October 2006. It is manifestly the case that Professor Parnaby registered fundamental objections to this scheme. He begins by saying that he is writing to the Chief Executive directly “ to register my strong objections to the proposed redevelopment on the cattle market site in Abergavenny ”. He then goes on to set out in brief detail his credentials. He then records that he is pleased that the planning committee of 3 October 2006 rejected the application for planning approval and expresses the hope “ that the council will take this clear rejection as a signal that it must fundamentally reconsider this proposal and your officers should not attempt to persuade the committee to approve any proposal that the applicant may submit that shows only minor design changes .”

He then indeed endorses the Design Commission for Wales objections which describe the scheme as “ unacceptable ” “ clearly stating that a major redesign was necessary. Both the lay out and design are fundamentally flawed – and cannot be made acceptable by amendment. This is a significant site bordering the centre of a delightful market town. It is not the place for an “urban retail park” but it does offer a unique opportunity to create a fine new urban quarter complimenting the historic fabric. ”

As far as the design aspects of the proposal go the Professor records as follows: “ any new proposal must be founded upon very widely accepted principles of urban design. These include real, fine-grain mixed use, permeability and legibility based upon real streets and well composed public spaces. At the smaller scale the buildings need to be designed and detailed with care – in an appropriately urban manner. The present proposal – now thankfully rejected – fails on all these counts. ”

Whilst we accept the next paragraph does indeed accept the difficulties for local planning authorities to argue on planning grounds that supermarkets should not be allowed on sites such as this, the Professor records that this constraint does not mean that LPAs should not demand high standards of urban and architectural design.

It is clear that your report to members completely ignores the fundamental objections registered by the Professor and chooses instead to pick up on the one point that could be turned in favour of the project regarding the principle of a supermarket on the site. We make exactly the same points regarding Professor Parnaby as we do regarding the conservation officer, that is, your members' duty to take into account all material considerations and to exclude immaterial considerations. Your reporting of Professor Parnaby's objections in a fundamentally skewed manner means that members have fallen into the same two errors in respect of Professor Parnaby's representations as they have done with the conservation officer.

Ground 4 – Representations by Gwent Police

We have sight of the five page letter from Gwent Police Headquarters of 11 April 2006. The letter comments on various aspects of the proposed development noting that the various facilities include residential, recreational, commercial and car parking at both surface and basement levels and that “ each of these provisions attract their own crime prevention requirements and all effect each other when treated as a whole ”. The letter records that “ although Monmouthshire has the lowest level of crime in the Gwent Police area, the crime levels for Abergavenny are the highest of the four towns (Abergavenny, Caldicot, Chepstow and Monmouth) and vehicle crime is more than double that elsewhere in the county. ”

The letter then goes on to set out a number of serious concerns as follows:

•  “ Once inside the building there appears to be unrestricted access to the corridors and front doors of the majority of the flats. A stairwell at each end provides an escape route and considering the number of properties, it is unlikely that residents would recognise other home owners or legitimate visitors. ”

•  “ Access control is strongly recommended with a suggestion that the basement car park be closed to non residents or access to the residential properties removed. ”

•  “ I strongly suggest that the final design of the properties incorporate the standards detailed in the Home Office “Secured by Design” scheme. ”

•  “ The perimeter protection could be improved at various points around the site. ” (He then goes to make 5 specific recommendations).

•  “ I consider that the residential element should be separate from the remainder of this development to avoid casual trespass and the anonymity provided by the free flow of the public. One of the basic principles of the Home Office “Secured by Design” scheme is the creation of defensible space which is totally absent in this design. ”

•  In respect of the food retail unit “ I have concerns regarding the unrestricted access to the east elevation between Lion Street and the rear service yard and it should be gated. ”

•  “The large expanse of light coloured wall could also be attractive to street artists. Having no natural surveillance this area could also suffer from litter and unlawful acts such as drug and alcohol abuse. ”

•  In respect of parking “ as stated Abergavenny experience more than double the number of car crimes than any other town in Monmouthshire, it is my view that the proposed parking of this development will suffer from car crime of a similar if not higher level. ” He then goes on to give nine reasons for his concerns.

•  He asks for further aspects to be considered and sets out 12 of those on the last page of his letter.

•  “A lthough the elimination of crime and disorder cannot be guaranteed the opportunity for it to be committed could be greatly reduced if some or all of the above advice is adopted. ”

On the issue of Gwent Police Community Safety Unit's representations the report to planning committee on October 3 records as follows:

“ 4.2.9 Gwent Police Community Safety Unit :

A detailed analysis by the safety unit has resulted in a wide range of recommendations, for example avoidance of any climbing aids that might allow access to roofs, use of anti-lift hinges to gates, vandal resistant polycarbonate covering to public art, and use of CCTV. Virtually all of the recommendations can be implemented without significant alteration to the scheme or even the need for planning permission. ”

As with the representations from MCC's conservation officer, and from Professor Parnaby, we submit that again the officer's report leads members to the same errors regarding failure to take into account all material considerations and taking into account immaterial considerations. One cannot read the letter from Gwent Police of 11 April 2006 and conclude that the summary of those representations at paragraph 4.2.9 is accurate and fair. There is no reference to the fundamental concerns regarding defensible space. Neither is there reference to the need to close the basement car park, or unrestricted access to the corridors and front doors of the majority of the flats. There is no reference to the nine reasons why the crime prevention officer concludes that the proposed parking development will suffer from car crime of a similar if not higher level than elsewhere in Abergavenny.

Again we make clear that the members must be aware of the serious and important concerns of Gwent Police. Unless they are made so aware again we confirm that if planning permission is granted it is highly likely that this issue will feature in the grounds of an application for judicial review.

Ground 5 – Traffic Issues

Paragraph 5.6.2 of the officer's report to planning committee of 3 October 2006 records that MCC's county highways engineer required “ a management agreement for the operation of the car park and service yard ” but “ subject to these caveats, his conclusion is that the scheme is acceptable in highway terms, albeit that there will be increased congestion and traffic flows in the town centre. ”

In fact the head of highways and waste management in making representations did not record that the scheme was acceptable. What he did say was that his comments were in addition to audit reports from two consultants. We understand that these reports were not included in the report to committee but were highly critical. For instance MCC commissioned TMS Consultancy who stated “ that there are number of areas where the transport assessment particularly the highway impact, is not considered to be robust. ” In our view it was important that members were aware of the concerns of those acting on behalf of MCC itself.

Of more serious concern in our view is the misrepresentation of the position of the Welsh Assembly Government (WAG). We have sight of an email to David Swanson at MCC from Gerald Mills on behalf of the WAG. Mr Mills notes paragraph 5.6.2 of the report which records that final WAG agreement has yet to be obtained. He goes on to note that until the transport assessment is completed the WAG cannot come to a conclusion as to what conditions, if any, they would require to be included in the consent. He then says this:

…” At this time we cannot say what our conditions are likely to be, but I should advise you that they could include requirements to change the scale or type of development in order to reduce the potential traffic impact. I would be grateful if you could ensure that the council is aware of our position. ”

We submit that the possibility that WAG might require a change to the scale or type of development in these circumstances was of huge significance. Despite the request that the members were made aware of WAG's position in fact the officer's report makes no reference to this request in either the report, late correspondence or verbal discussion. Again as with the conservation officer, Professor Parnaby and Gwent Police inevitably you have caused the members not to take into account an important material consideration, that is the potential need to change the scale or type of the development in order to avoid an unacceptable detrimental effect on trunk road traffic as set out by WAG.

Ground 6 – Conflict of Interest

We understand that as well as being the Head of Planning and Regeneration who has chosen to be the author of the relevant officer's reports on the project above, you are also responsible for MCC's Asset Management function which includes regeneration of the cattle market. We are aware that you have acknowledged the importance in this context of the separation of your role in respect of representing both the planning authority and the owner and landlord of the development site. However we submit that you have quite clearly crossed the line and that there is illegality here on the grounds of apparent bias. You will be well aware of the importance of the principle of justice being seen to be done and that what is in issue is whether there is a real possibility of bias rather than necessarily proven actual bias. Giving judgment in the planning context Richard J recently held that the test is “ whether, from the point of view of the fair-minded and informed observer, there was a real possibility that the planning committee or some of its members were biased in the sense of approaching its decision with a closed mind and without impartial consideration of all relevant planning issues ” (R (Ghadami) –v- Harlow District Council [2004] EWHC 1883 (admin) 30 July 2004). On the issue of justice being seen to be done Lord Bingham (speaking recently in the context of apparent bias) said “ It has… been accepted for many years that justice must not only be done but must also be seen to be done .” (Davidson –v- Scottish Ministers [2004] UKHR 34 15 July 2004).

It is not enough in this instance to point to any apparent distance between your role as the author of the officer's report, and as having very close control of these proceedings (see above on the context of manipulation of members) and the role members play as the actual decision-makers with the voting procedure. It is more than possible for the adviser to a planning committee in these circumstances to transgress the rule on apparent bias. By way of illustration in the context of advice given to magistrates by magistrates clerks the following passage is we submit helpful:

In addition to “ a real likelihood of bias on the part of the clerk… it must also be shown that, by reason of his participating in the decision-making process, there was a real likelihood that he “would impose his influence on the justices or give them wrong advice” (R –v- Gough [1993] AC 646 at 664C).

Similarly the following passage is helpful:

“ In a case concerned with bias on the part of a justice's clerk, the court should go on to consider whether the clerk has been invited to give the justices advice and, if so, whether it should infer that there was a real danger of the clerks' bias having infected the views of the justices adversely to the [claimant]” (R –v- Governors of the Sheffield Hallam University, exp R [1995] ELR 267, 284-285).

We have already drawn reference in this section to concerns regarding the manipulation of members and the confusion that has arisen as to whether the members were rejecting the proposed development or objecting only to selective aspects of the design scheme. We also refer to your personal failure to give the members the advice required regarding the impact of the Building Agreement (Ground One). In our view there is more than sufficient material and evidence to lead to a real possibility of bias in these circumstances. Further we draw your specific attention to the suspicions above regarding giving the members wrong advice or alternatively failing to give them the correct advice and the referenced need is the above case law to have impartial consideration of all planning issues. In our view you have allowed your determination to push through this project with your Asset Management functions hat on to cloud your mind regarding the proper discharge of your functions as Head of Planning and Regeneration. Indeed, we see no good reason why you chose to be the author of the relevant officer's reports, when our understanding of the position is that the officer with ultimate responsibility for reporting to Members, both in writing and orally, is the Head of Regulation and Community Protection, supported by the Head of Development Control. We submit that the damage has been done and that you should hand over the determination process to a colleague who can be shown to be independent and impartial. Further we submit that the members should for this reason alone be presented with a fresh officer's report written by that different officer. That fresh officer's report should remedy the defects we have highlighted in grounds 1 – 5 above.

We submit that any perceived benefits which might arise from the continuity from your role in 2004 at the outline application stage are clearly outweighed by the imperative that justice must be seen to be done.

For the avoidance of doubt we submit that the apparent bias evident in this case is an important matter and would be the subject of an application for judicial review if planning permission is granted.

In conclusion we submit that grounds 1 – 6 above are important matters and that they must be addressed before this application is determined one way or the other. We have set out under Ground 6 what we submit as being the appropriate remedy, that is, that members should have the benefit of a fresh officer's report from a different officer. We have made clear that if each and every matter set out above is not addressed we are instructed to advise our group as to the prospects of success of an application for judicial review.

We have said above that we are not sure whether the meeting on 12 December 2006 is going to further consider the matter or recommend that a decision be taken. Either way we would ask that you report to us in writing the outcome of the meeting on 12 December 2006 and that you do so as soon as practically possible after that meeting.

We await hearing from you.

Yours faithfully,

Public Interest Lawyers

cc Mr Colin Berg – Chief Executive

Mr Murray Andrews – Chief Legal Officer