Second procedural hearing of the Grenfell Tower Inquiry addressing disclosure, expert evidence, phase structure, and representation. Core participants including the Royal Borough of Kensington and Chelsea, TMO, companies involved in refurbishment, London Fire Brigade, Fire Brigades Union, and Fire Officers Association make submissions on transparency, disclosure processes, and the need for victims to be at the heart of the inquiry.
00:00:43 good morning everybody when we finished last night I had heard submissions from those representing that bereaved survivors and other local
00:00:55 bereaved survivors and other local residents and we've now got the stage at which I would invite mr. Maxwell Scott to say something on behalf of the council mr. chairman I'm James Maxwell
00:01:20 council mr. chairman I'm James Maxwell Scott and I represent the Royal Borough of Kensington and Chelsea instructed by DWF before turning to some specific topics I would like to make some
00:01:31 topics I would like to make some introductory points we have listened very carefully to the submissions made yesterday on behalf of bereaved family members survivors and former residents
00:01:43 members survivors and former residents many valid points were made which seemed to us to derive from two central themes first the centrality to this inquiry of the bereaved of the survivors and of the
00:01:56 the bereaved of the survivors and of the former residents secondly the importance of transparency our bkc respectfully agrees with the importance of both of those themes so you and many others
00:02:10 those themes so you and many others present today may already be aware of the resolution adopted by the full council at its meeting on Wednesday the 6th of December but I hope that you will
00:02:21 6th of December but I hope that you will forgive me reminding you of it the subject matter of the resolution was the report of Bishop Jones which was referred to in some of yesterday's submissions the resolution was proposed
00:02:33 submissions the resolution was proposed by the leader of a council Elizabeth Campbell and passed unanimously the full text of the resolution can be found on the council's website but I hope that it
00:02:44 the council's website but I hope that it will assist if I read some extracts from it the resolution began by stating this council notes the publication of the report by the right reverend James Jones
00:02:57 report by the right reverend James Jones Bishop of Liverpool and chair of the Hillsborough independent panel it also stated in line with the report's recommendations this council reaffirms
00:03:10 recommendations this council reaffirms its commitment to be open transparent and fully cooperative with the public inquiry into the Grenville tower 5 the inquests into the deaths in the fire and
00:03:21 inquests into the deaths in the fire and the police investigation the resolution went on to set out six numbered commitments of which I will read free if I may we commit to the Royal Borough of
00:03:35 I may we commit to the Royal Borough of Kensington and Chelsea becoming an organisation which strives to place to public interest above our own reputation we commit to the Royal Borough of
00:03:46 we commit to the Royal Borough of Kensington and Chelsea becoming an organisation which strives to approach forms of public scrutiny including public inquiries and inquests with candor in an open honest and transparent
00:03:58 candor in an open honest and transparent way making full disclosure of relevant documents material and facts our objective is to assist the search for the truth we accept that we should learn
00:04:09 the truth we accept that we should learn from the findings of external scrutiny and from past mistakes we commit to the Royal Borough of Kensington and Chelsea becoming an organisation which strives
00:04:21 becoming an organisation which strives to avoid seeking to defend the indefensible or to dismiss or disparage those who may have suffered where we have fallen short so I now turn to my
00:04:32 have fallen short so I now turn to my submissions on specific topics I have three topics which I wish to cover and they are disclosure experts and split between phase one and phase two
00:04:44 between phase one and phase two Tonie first two disclosure sir as you will have deduced from the resolution passed by the council last week we're sympathetic to the submissions made yesterday about the
00:04:56 submissions made yesterday about the importance of a disclosure process being transparent to you and of the need for participations been formed by disclosure in order for it to be meaningful our bkc received a detailed request for
00:05:10 our bkc received a detailed request for disclosure from Miss Lissa to be inquiry on the 24th of August we have provided your team with disclosure in response to that request and were they signed disclosure statement that disclosure
00:05:24 disclosure statement that disclosure statement dated the 8th of November runs two fifty two paragraphs plus Penda C's and you will probably be pleased to hear that I do not intend to read all of it into the record however it may assist if
00:05:36 into the record however it may assist if I refer to a small number of paragraphs from it because they may help to answer some of the questions raised entirely legitimately yesterday our bkc received
00:05:49 legitimately yesterday our bkc received notice from the Metropolitan Police to retain all data across its servers on the 20th of June our be KC's shared information and communications
00:06:00 information and communications technology service infrastructure manager ensured that upon receipt of a letter all data held on our B KC's storage area network was duplicated to
00:06:12 storage area network was duplicated to create a stable copy meaning that the data could not be changed or modified the amount of data preserved in this manner was around 80 terabytes in total
00:06:25 manner was around 80 terabytes in total DWF through their forensic services providers began extracting documents from our bkc servers on the 3rd of July the date was processed then added to an
00:06:37 the date was processed then added to an online review platform relativity chosen by DW F for amongst other reasons its advanced service searching capabilities
00:06:48 advanced service searching capabilities subsequently a large number of documents were uploaded onto relativity by the 8th of November 1 million five hundred and sixteen thousand four hundred and twenty
00:06:59 sixteen thousand four hundred and twenty seven documents have been uploaded onto relativity DWF and their forensic services providers can confirm that no documentation has been redacted altered
00:07:13 documentation has been redacted altered or tampered with in any way since being received by DW f border Renne 'ok services providers answer pausing there i can state that all of
00:07:24 pausing there i can state that all of those 1.5 million documents have been disclosed at a police that returning vendor how disclosure has been given to your team those documents were searched
00:07:35 your team those documents were searched electronically by running keyword search terms across the search terms used have been provided to your team in an appendix to the disclosure statement
00:07:46 appendix to the disclosure statement that process resulted in ninety thousand five hundred and sixty three responsive documents the team was then set up manually to review those documents and
00:07:57 manually to review those documents and the disclosure statement explains the nature of a team and how it worked the outcome at the manual review process was that twelve thousand nine hundred and eighteen documents were disclosed your
00:08:10 eighteen documents were disclosed your team by the 8th of november the concluding section of a disclosure statement addressed the ongoing duty of disclosure it stated DWF and our bkc
00:08:23 disclosure it stated DWF and our bkc understand that they have an ongoing duty of disclosure to provide the inquiry of documents identified after the 31st of october as being relevant to
00:08:34 the 31st of october as being relevant to the request it concluded by stating DWF and our bkc understand that the inquiry may request that further searches of
00:08:45 may request that further searches of relativity be carried out using additional search terms notified to them by the inquiry DWF and rbk see also understand that the inquiry may request
00:08:57 understand that the inquiry may request additional information beyond that identified in request gwf NRV Casey will cooperate fully with any such requests from the inquiry so you've heard me
00:09:11 from the inquiry so you've heard me refer to our disclosure statement and to endorse importance of transparency in the disclosure process we are conscious that we are just one of 31 document providers and therefore we leave it to
00:09:24 providers and therefore we leave it to you and your team to decide how best to achieve greater transparency in this important area I can take my remaining two points more shortly firstly experts so you have my
00:09:40 shortly firstly experts so you have my submission but it would greatly assist all court participants if expert reports could be provided sooner than one month before the start of phase one evidential hearings and they don't prepares to
00:09:52 hearings and they don't prepares to expand upon it further here and my final point the phase one phase two split as indicated in my written submissions we
00:10:03 indicated in my written submissions we recognize that the views of the bereaved the survivors and of the former residence on the timetabling of phase one and the phase one phase two split
00:10:14 one and the phase one phase two split our primary importance there's no perfect solution to this because some issues inevitably have the potential to overlap between phases at this stage I
00:10:25 overlap between phases at this stage I will restrict myself to the following general points by the time Phase one starts there needs to be clarity as to which issues will be addressed and
00:10:37 which issues will be addressed and whether any views expressed on them in an interim report will be provisional or final these issues need to be clarified in sufficient time to enable all core
00:10:48 in sufficient time to enable all core participants to prepare for phase one of course some residual flexibility will need to be retained fairness to all core participants must be ensured so we noted
00:11:02 participants must be ensured so we noted mr. Friedman's submission that provisional recommendations could be made before the end of phase one and we respectfully agree if at any stage you
00:11:13 respectfully agree if at any stage you reach a point where the information you have received leads you to consider that you should make a safety critical recommendation as a matter of urgency you can after inviting and receiving
00:11:25 you can after inviting and receiving submissions make it and in appropriate cases should do so so unless I can assist any further phase of my submissions thank you very much could I
00:11:36 submissions thank you very much could I trouble you perhaps on two matters which arose in the course of submissions yesterday on which you as an important core participant may or may not have a view 1/1 is the establishment of what I think we've
00:11:48 establishment of what I think we've called a consultative panel this was something I suggested I think to mr. Mansfield in the course of his submissions do you have any observations to make on that you certainly have no
00:12:00 to make on that you certainly have no objection to that you seemed a sensible suggestion all right thank you very much the other matter was suggestion which I think may have come from mr. Weatherbee
00:12:11 think may have come from mr. Weatherbee I can't quite clear down which was that we might invite some people to provide position statements and I think the council would probably be one party to whom such a request would be directed do
00:12:24 whom such a request would be directed do you want to say anything about that I will say I will say something about that sir the inquiry rules permit call participants to make an opening statement and a closing statement as you
00:12:35 statement and a closing statement as you know unless you direct otherwise it would be my intention on behalf of our bkc to make an opening statement and a closing statement those opening statements will assist the inquiry and
00:12:47 statements will assist the inquiry and other core participants by setting out our be KC's position on a range of issues of course if you consider it be helpful to have an indication of our be KC's position before the start of phase
00:13:00 KC's position before the start of phase 2 on phase 2 issues you have a number of options you could direct written phase 2 opening statements be provided in advance or you could direct something
00:13:12 advance or you could direct something very similar but call it a position statement we wouldn't in principle object to such an approach I don't know what timing is being considered but we would submit it was be premature to
00:13:24 would submit it was be premature to order position statements now if position statements are to provide you with real assistance there will as a minimum we suggest have needed first to be meaningful disclosure in relation to
00:13:37 be meaningful disclosure in relation to the issues sufficient time to analyze the relevant documents probably cite all relevant expert reports and time to take instructions but when certainly not opposed in principle that's very helpful
00:13:50 opposed in principle that's very helpful thank you very much
00:13:56 now the next speaker on my running order is Miss Jarrett yes
00:14:18 mr. Chairman I am Alice Jarrett and I appear on behalf of the Kensington and Chelsea tenant management organization the TMA and I'm instructed to attend today by Kennedy's solicitors the TMO
00:14:32 today by Kennedy's solicitors the TMO recognizes how important it is that this inquiry takes place to understand not only how this terrible tragedy came about but also to identify the steps to
00:14:44 about but also to identify the steps to ensure that it never happens again the TMO have engaged fully with the inquiry process thus far and it wishes to encourage transparency in this
00:14:55 to encourage transparency in this process and we will continue to assist the inquiry wherever possible going forward the TMO is a resident led organization with a majority of local
00:15:06 organization with a majority of local tenants on its broad they are accompanied by counsel nominated and independent directors it deals with the estate management of approximately 10,000 properties within the council
00:15:18 10,000 properties within the council portfolio including the Lancaster West estate and of course Granville tower in relation to our written submissions and turning today's they relate only of
00:15:29 turning today's they relate only of course to the timings of service if the inquiries expert reports and we echo the oral submissions of those who have gone before us that there must be prompt service of these reports to allow for
00:15:41 service of these reports to allow for their content to be properly considered by the core participants we welcome mr. millets of Queen's Council's acknowledgment in his opening yesterday that is right that the timescales for service of such reports in any
00:15:52 for service of such reports in any responses are carefully considered and we to ask for proper time to review that disclosure in respect of the two phases of phases one and two and we see the
00:16:04 of phases one and two and we see the difficulties that have been expanded on in detail yesterday by others of separating the issues into two phases whilst at the same time of course recognizing that it may be in logistical necessity and we support therefore
00:16:16 necessity and we support therefore whatever approach the inquiry concludes is appropriate in order to properly achieve the aim of addressing the the issues that you sir have already identified
00:16:29 opening statements and we note that the inquiry team hasn't visits that opening statements may be appropriate and we would hope to make an opening statement at the beginning of both phases one and
00:16:40 at the beginning of both phases one and two addressing the issues relevant to each phase of the process in respect of each of those statements and finally now so if I may turn to give you a brief
00:16:51 so if I may turn to give you a brief update in respect of disclosure the TMO support the disclosure process being a open and transparent procedure the TMO
00:17:03 open and transparent procedure the TMO is a paperless organization all records are maintained electronically immediately following the incidents and was supported the Metropolitan Police Service an independent digital forensic
00:17:16 Service an independent digital forensic IT consultancy company was instructed to capture the totality of the TMS electronic records since its inception in 1995 within a few days of the
00:17:27 in 1995 within a few days of the incident all electronically saved records were captured by the consultancy and were provided in their totality to the Metropolitan Police Service shortly afterwards the TMAO was offered to
00:17:38 afterwards the TMAO was offered to provide the inquiry with a copy of the entirety of his electronic records but the inquiry has thus far indicated its preference that the TMO continues to
00:17:49 preference that the TMO continues to respond to the specific disclosure requests as and when they arise since the inquiry has started the TMO has complied with each and every disclosure
00:18:00 complied with each and every disclosure request that has been made to date and it has done so within the requested timeframes in response to a recent request by the inquiry as of the 6th of
00:18:12 request by the inquiry as of the 6th of November the TMO has provided all records in relation to each individual address within Grenville tower and a wider area of the Lancaster West Estate
00:18:23 wider area of the Lancaster West Estate as has been specified to us by the inquiry all of these were provided to the inquiry in electronic form on the 15th and the 17th of November and they
00:18:34 15th and the 17th of November and they have again been provided on a memory stick that was delivered by hand to the inquiry team on the 28th of November on the 8th of December the inquiry team requested that hardcopy
00:18:47 inquiry team requested that hardcopy packs of all of these records for each of the gram full tower addresses be provided to the inquiry by the 12th of January in order to assist the inquiry with its preparations it's already been
00:19:00 with its preparations it's already been confirmed in correspondence to the inquiry that this will be completed in advance of this date as requested the TMO has also served statements from the head of its IT to explain how documents
00:19:13 head of its IT to explain how documents are managed on the TMA's electronic systems and from the independent digital forensic IT consultancy to explain how the raw data was captured in the first
00:19:25 the raw data was captured in the first place
00:19:26 place the TMO are committed to their engagement with this inquiry and will continue to respond promptly to all requests they receive from the inquiry
00:19:37 requests they receive from the inquiry wherever possible thank you very much would you like to comment at all on the two matter that I invited mr. Maxwell Scott to comment on the suggestions that were made yesterday
00:19:49 the suggestions that were made yesterday that there might be a consultative panel for the benefit of survivors bereaved and other local residents and the suggestion that that the inquiry might
00:20:01 suggestion that that the inquiry might consider asking for position statements from these some core participants before we get to my father I'm in respect to the first a consultative panel it's so
00:20:12 the first a consultative panel it's so it's of course as an entirely a matter for you but if it opens lines of communication it would seem an NMM inant Lisa sensible suggestion thank you in respective the second a position statement and not to repeat comments
00:20:25 statement and not to repeat comments that we made by myth mr. Maxwell Scott Queen's Counsel who's come before me but essentially our position would be similar if it is that you would see that to be a sensible way forward we of
00:20:36 to be a sensible way forward we of course do not object and we would be happy to provide a position statement of course I've already made a comment on the fact that we would hope in any event to be to make opening statements at the
00:20:47 to be to make opening statements at the appropriate moment and prior to the commencement of hearing evidence of phases
00:20:52 phases and phases to my observation would be that in order to make that statement to be full and useful and assist the purposes of inquiry and to echo those
00:21:04 purposes of inquiry and to echo those who've made representations yesterday we would require meaningful disclosure in order to properly prepare that statement all right well that's very helpful thank you very much indeed
00:21:19 now we come now to other core participants who were involved in the refurbishment cep architectural facades
00:21:30 refurbishment cep architectural facades mr. Christie
00:21:41 mr. chairman my name is Aiden Christy I represent CEP architectural facades one of the corporate participants I'm instructed by Clyde & Co and I'm
00:21:54 instructed by Clyde & Co and I'm appearing with mr. Jim Sterman and mr. Andrew Magee mr. chairman our written submissions are limited to the issue of expert evidence we have raised three
00:22:06 expert evidence we have raised three issues first the current position of CEP in relation to expert evidence secondly the proposed time table for expert evidence and thirdly the division of
00:22:19 evidence and thirdly the division of issues between phase 1 and phase 2 and any consequence of that decision mr. chairman I proposed to make very short
00:22:30 chairman I proposed to make very short submissions to indicate our current position in the light of the remarks and observations which have been made yesterday and then mr. chairman I'll pick up on the two additional questions
00:22:42 pick up on the two additional questions which you've been putting to people who have gone before me before I go any further may I say we are obviously aware that these are not adversarial court proceedings it is for the inquiry to
00:22:55 proceedings it is for the inquiry to investigate and we take on board mr. millets observations both in his written statement and in his remark yesterday that any party wishing to reduce expert
00:23:06 that any party wishing to reduce expert evidence will have to be in a position to show why it cannot be addressed by the inquiries experts and why it is necessary for that party to adduce its
00:23:17 necessary for that party to adduce its own evidence taking our three points in turn mr. chairman without access to the site our analysis of the expert issues will have
00:23:28 analysis of the expert issues will have to be confined to the documents and a desktop study that is not satisfactory but it is obviously unavoidable for the reasons which we have heard but we will
00:23:40 reasons which we have heard but we will review our position of when the inquiries experts ports are produced as to the timing of responses to the inquiries experts reports we welcome the observation of
00:23:52 reports we welcome the observation of Council for the inquiry that the inquiry will be sympathetic in relation to those matters we understand its proposed that we have further procedural hearing at the end of January and we're content to
00:24:03 the end of January and we're content to wait and see our position is that we should be permitted at least six to eight weeks to analyze reports and respond but we're happy to postpone the
00:24:15 respond but we're happy to postpone the issue until January to see what proposals might be made by counsel to the inquiry our third and last point mr. chairman relates to the division of evidence between phase one and phase two
00:24:29 evidence between phase one and phase two we appreciate that phase 1 is a fact-finding exercise and we'll be addressing what happened and how but not why but we have concerned that there may
00:24:40 why but we have concerned that there may be some blurring of those distinctions and that expert Evans may stray into an out into an analysis of the why we simply draw attention to the point at this stage because it may be we'll want
00:24:52 this stage because it may be we'll want to raise the issue when we've seen the inquiries experts reports but we support the observations of mr. Maxwell Scott that some clarity would be very helpful
00:25:03 that some clarity would be very helpful in relation to the distinction taking mr. chairman I assume that you want me to comment on the two additional points yes we take a neutral position in
00:25:15 yes we take a neutral position in relation to the consultative panel in relation to position statements our view is that it's premature that we shouldn't be required to put in a position
00:25:26 be required to put in a position statement until certainly we have disclosure until we have the experts reports and until we know more about the issues which we have to address but mr. chairman we are perfectly happy
00:25:37 chairman we are perfectly happy obviously to make an opening statement in relation to phase one there's no submissions thank you very much indeed [Music]
00:25:48 [Music] next on my sheet is mr. Andrew bus for max Fordham but I understand mr. Andrew bus
00:25:57 bus that you may not wish to add any oral submissions is that right right thank you very much
00:26:09 mr. Catchpole
00:26:23 good morning sir my name is Stuart Catchpole I am instructed by DAC Beechcroft on behalf of right and maintenance limited as you're aware from our written submissions we don't seek
00:26:35 our written submissions we don't seek any specific directions at this particular meeting we would however wish to make some shorts mainly responsive submissions to the matters that were
00:26:46 submissions to the matters that were addressed to you yesterday and in particular the submissions made obviously by those representing all of those affected by this tragedy if those submissions could be summarized
00:26:58 if those submissions could be summarized shortly UNITA will no doubt not do them justice as I understand it they were to the following effect which is that the inquiry must be fair and must be seen to
00:27:09 inquiry must be fair and must be seen to be fair right in the grease and that applies as much to those affected by the fire as that to those who are also appearing in front of you and the individual witnesses who will be called
00:27:21 individual witnesses who will be called to give evidence on behalf of the corporate and institutional corps participants with that instruction I with your permission would seek to deal
00:27:32 with your permission would seek to deal with three topics the first is the engagement with those affected by the fire by the tribal second is disclosure and the third is a broad ragbag of case
00:27:47 and the third is a broad ragbag of case management experts and the phase one phase two split you were addressed and if I may say so eloquently and length yesterday in relation to the desire of
00:28:00 yesterday in relation to the desire of those who have been affected by this tragic event to have a greater interaction with the inquiry process to have their individual and collective voices heard and have their concerns
00:28:13 voices heard and have their concerns raised publicly and have those concerns considered fairly and fair in this context as I understand it is in particular the need for their clients to
00:28:24 particular the need for their clients to have a reasonable confidence that the person actually or person was actually considering their concerns has a genuine a priest
00:28:33 a priest creation of the circumstances in which their lives are conducted and can see things from there very diverse perspectives to the extent that exists
00:28:44 perspectives to the extent that exists assists right and agrees and that's not just on behalf of writing the company it's the legal team who have represented writing have much experience of public
00:28:55 writing have much experience of public enquiry work it's fair to say almost all on behalf of institution or law corporate clients but it is a feature rightly or wrongly of a number of
00:29:06 rightly or wrongly of a number of inquiries that the victims are a substantial body of the victims feel as if they are disenfranchised they feel as if they're marginalized by the process and that the things that really touch
00:29:20 and that the things that really touch their lives aren't given proper consideration or aren't properly understood I say rightly or wrongly but it is clear that's happened from the Taylor inquiry in which I was involved
00:29:31 Taylor inquiry in which I was involved back in 1989 right the way through it is inevitable given the range and nature of the issues with which this inquiry is concerned that those feelings and those
00:29:43 concerned that those feelings and those concerns on behalf of those affected are going to be voiced in an acute form and we would respectfully suggest that they are real legitimate and however you do
00:29:55 are real legitimate and however you do deal with it they need to be addressed you've raised with others the need for a consultative panel as an approach we
00:30:06 consultative panel as an approach we would suggest that the the right way is actually interaction with those representing those affected but anything that can be done to instill greater public confidence in the outcome must be
00:30:18 public confidence in the outcome must be a good thing I would however note first of all you are unlikely to make everyone happy secondly that fairness also
00:30:30 happy secondly that fairness also demands that to the extent that any of those concerns are matters which are going to be raised in this form then proper notice needs to be given to those
00:30:42 proper notice needs to be given to those other core participants who might be affected
00:30:45 affected by those concerns and we need to respond to them and I'll return in a moment if I may to some short observations on the implications for the management of the inquiry process the second top issue is
00:30:59 inquiry process the second top issue is disclosure and that was split into two different aspects the first is a call for greater transparency and scrutiny of the inquiries disclosure process the
00:31:11 the inquiries disclosure process the requests and the responses the second is actual disclosure of documentation in relation to the call for transparency once again Ryden agrees that it would be
00:31:23 Ryden agrees that it would be appropriate for there to be greater transparency and scrutiny of the disclosure process it's both fair and if properly managed it's likely to lead the
00:31:35 properly managed it's likely to lead the early identification of gaps in the evidence that you will need to consider I say however that it not only applies to those affected by the fire it applies
00:31:46 to those affected by the fire it applies to all it goes without saying that with respect that those represented by counsel you heard from yesterday will have be able to identify gaps in disclosure they believe it exists my
00:31:59 disclosure they believe it exists my clients will be identified other gaps that we may think may exist in disclosure just as others we look at no doubt ours and new course and say the same thing I would add that as you're
00:32:10 same thing I would add that as you're aware and as others have said before me on behalf of this side of the alleyway Ryden has cooperated fully with the police and with the inquiry and I know so that you are aware in particular
00:32:21 so that you are aware in particular there's been active cooperation with your team by Ryden and its solicitors not only to gather and provide to the inquiry all of the evidence that they wish but to do so in a form that is
00:32:33 wish but to do so in a form that is comprehensible and usable and that has been ongoing for a number of months it's been a very substantial task I know that for the victims depth and I would
00:32:45 for the victims depth and I would suggest that public confidence can only be increase if in some manner a procedure can be adopted to allow them to see and to test what has happened we very much doubt that that requires
00:32:58 we very much doubt that that requires all cop core participants or indeed even some of them to be involved in the nitty-gritty of drafting requests scrutinizing drawers before they go out or things like that it's very much a
00:33:10 or things like that it's very much a process to give confidence in what has gone on and to identify areas which you may consider unnecessary to investigate further that leads me to actual
00:33:23 further that leads me to actual disclosure we would have thought that almost goes without saying that as a matter of principle core participants should be entitled to disclosure of potentially relevant documents in
00:33:36 potentially relevant documents in sufficient time to enable a proper and informed review of that body of evidence that is the only way they can contribute meaningfully to this inquiry process
00:33:48 meaningfully to this inquiry process that is a subject we would suggest to two caveats the first is there was a suggestion yesterday I believe at least that disclosure should commence immediately by the inquiry even if that
00:34:02 immediately by the inquiry even if that means that it should be given in an unstructured or I think the phrase of chaotic fashion because that is the inevitable consequence of an inquiry we would strongly very strongly caution
00:34:14 would strongly very strongly caution against unstructured or chaotic disclosure many of us have seen the effects of that approach in different forums and including in public inquiries in the VSC inquiry for example an
00:34:28 in the VSC inquiry for example an approach was taken for understandable reasons to disclose documents almost as soon as they received by the inquiry and someone had checked for potential relevance it made it impossible and I
00:34:41 relevance it made it impossible and I can say impossible for anyone meaningfully to get on top of that evidence in an efficient and economic way and I was representing one of the
00:34:52 way and I was representing one of the institutions who have been often accused of having deep pockets for those that do not have deep pockets it's inevitable that they will be significant wasted expenditure being sent down blind alleys
00:35:06 expenditure being sent down blind alleys and I would suggest an inability properly to digest versus you at the end of the day it's not an even putting
00:35:18 of the day it's not an even putting aside there's a second aspect the legal question of whether article two requires complete disclosure of every document to every core participant matter on which
00:35:30 every core participant matter on which there's plenty of law and I may doubt you'll have it in mind we would suggest it is not the function of the core participants any of us to duplicate the inquisitorial tasks of the enquiry team
00:35:42 inquisitorial tasks of the enquiry team we are here to assist you in resolving the issues within your terms of reference and we would suggest that disclosure to core participants has to
00:35:53 disclosure to core participants has to be made in a logical and structured manner it has to be managed in a way that is fair to all participating in this and I fully appreciate what those affected by the fire are saying that
00:36:05 affected by the fire are saying that they do not have access to as much as anyone else and steps need to be taken to address that but it has to be done in a way that actually allows you to
00:36:17 a way that actually allows you to progress this inquiry in the way that you ultimately determined is appropriate and which allows you and your team to actually do the tasks that you've been
00:36:28 actually do the tasks that you've been set and that tasks with respect risk of stating the obvious is to deal with a vast number of issues in a reasonably short period of time and that is not a process that is amenable to have many
00:36:42 process that is amenable to have many lawyers sitting around these tables scrutinizing 270,000 odd documents it's just not a sensible way of proceeding we will be here for years the that really
00:36:58 will be here for years the that really leads neatly into my third general ragbag area of case management the if I may say so there was a concern
00:37:12 the if I may say so there was a concern at least on our side yesterday from some of the submissions that we were focused on some really important issues for those affected by the fire but with
00:37:25 those affected by the fire but with respect we should not lose sight of the fact that at the end of the day this inquiry will have to deal with a vast quantity of potentially relevant
00:37:36 quantity of potentially relevant documentary evidence and will have to consider multiple expert reports covering complex and possibly not particularly clear technical issues even
00:37:49 particularly clear technical issues even if one assumes that the 270,000 documents mentioned by mr. millet yesterday contain an element of duplication or some which are not relevant although hopefully that is not
00:38:01 relevant although hopefully that is not the case given the work the inquiry team have put into disclosure one is certainly makes an educated guess that you are facing hundreds possibly
00:38:12 you are facing hundreds possibly thousands of leverage files of documents and these are documents which have already been filtered for relevance now reviewing assessing and making determinations on that evidence is a
00:38:25 determinations on that evidence is a very very substantial undertaking if you add into that the task of taking overlapping complex expert evidence which in itself from experience is a
00:38:37 which in itself from experience is a very substantial undertaking this inquiry faces a very formidable task and the marshaling analysis and
00:38:48 the marshaling analysis and determination of the issues arising out of that expert evidence requires in our submission a particular skillset whether we like not is a skill set that lawyers and judges possess that was what we are
00:39:00 and judges possess that was what we are trained to do and while we make no submissions as to whether or not the panel should be expanded it's not appropriate for us to do so we do suggest that one of the considerations
00:39:14 suggest that one of the considerations which needs to be given proper weight in determining whether that you happen is the need for any panel member to be able to do justice to the substantial tasks that is faced by this
00:39:25 substantial tasks that is faced by this inquiry it is not an inquiry like the Taylor inquiry that was about largely about factual evidence with one technical issue which is about a safety barrier this is not that case the third
00:39:37 barrier this is not that case the third area of case management is the case management by the inquiry and I hesitated to make observations on this but it's the we would suggest the cases of this magnitude inevitably have to be
00:39:49 of this magnitude inevitably have to be proactively managed by the tribunal it's simply impossible for them to be effectively and fairly managed if free rein is given to an equal participant to
00:40:03 rein is given to an equal participant to engage in the process to cross examine to cross feminine overlapping manner I would respectfully suggest but it's a matter for you that a procedure that's akin to an inquiry procedure where
00:40:15 akin to an inquiry procedure where everyone gets a chance to cross-examine on multiple evidences is unlikely to assist in actually distilling the issues it's unlikely to assist in narrowing expert issues it is highly likely to add
00:40:28 expert issues it is highly likely to add to the confusion of the matter and it is highly likely to be unfair to at least some witnesses who will receive multiple cross-examination by different parties and that is precisely why one assumes
00:40:40 and that is precisely why one assumes that the decision was making to make this inquiry an inquisitorial process at the end of the day as the others have said that is what should be respected and we are here to help you achieve that
00:40:51 and we are here to help you achieve that aim as best we can that is not to say however that the quarry should not receive and listen to carefully applications for specific targeted
00:41:04 applications for specific targeted cross-examination from contrasting court but of course they should a basic premise of fairness in terms of the expert process I echo what has been said
00:41:15 expert process I echo what has been said by many across this room first is the timetable that was suggested by the inquiry for the review of the inquiries expert evidence was simply too short it
00:41:26 expert evidence was simply too short it is impossible to do that job secondly should the those affected by the fire have access to expert evidence hopefully properly marshaled and coordinator pasta should anyone who does
00:41:39 coordinator pasta should anyone who does these sorts of cases knows you need to be informed by your experts because that's any way you can make meaningful contributions but hopefully properly managed not multiple experts limited
00:41:50 managed not multiple experts limited memory of course they should thirdly should the process be left to disclosing the inquiries expert reports and then
00:42:01 the inquiries expert reports and then inviting those who want to put their own experts forward to come in and get involved and mice mission no experience suggests that many technical issues can be resolved if you are involved early
00:42:13 be resolved if you are involved early enough and if we can make suggestions through the inquiry team as to what further inquiries the inquiry experts ought to make and to actually identify assumptions they may have made and have them tested to that end not only due to
00:42:27 them tested to that end not only due to some disclosure need to be given but one would think that there is evidence could be disclosed to all of us now video footage of the night if there are
00:42:38 footage of the night if there are records as the must be of the experts visiting the site given we cannot they should be disclosed they should be uncontroversial photographs taken by the experts with sensitivity for obvious
00:42:49 experts with sensitivity for obvious reasons should be capable of being disclosed the ability to see any tests or forensic examinations that they are undertaking not to participate to observe and then feedback through the inquiry all of those things are likely
00:43:02 inquiry all of those things are likely to lead to a more effective process for you at the end of the day and are likely to lead to a narrowing of the issues we that leads into the final point on which
00:43:15 that leads into the final point on which I would wish to address you which is phase one phase two clearly there are difficulties in the split clearly there is an imperative to get on with something we would suggest
00:43:27 get on with something we would suggest again from our experience that having effectively a provisional timeline of the events of the night relating to the fire ignition and spread and to the
00:43:42 fire ignition and spread and to the smoke penetration through the building together with the evacuation is inevitably a baseline against which this inquiry will proceed and it shouldn't be fixed maybe things that come up in phase
00:43:54 fixed maybe things that come up in phase 2 but having that document coming out of phase 1 and any recommendations that you see fit come it has got to be helpful because it focuses everyone's mind on
00:44:05 because it focuses everyone's mind on facts which are either not controversial or identifying those facts that are controversial for the purposes of phase 2 those were my submissions I anticipate
00:44:16 2 those were my submissions I anticipate you were going to ask me about a position statement and our position is quite clear and it really reflects what I've said before fairness demands that if people are
00:44:27 fairness demands that if people are going to be subjected to potential criticisms then they should be given notice of it that's the point at which they should be invited to respond we are
00:44:38 they should be invited to respond we are like other core participants would wish I suspect to put in opening and closing statements on the phases but the bottom line is that any core participant who may be subject to criticism should
00:44:50 may be subject to criticism should receive a letter of warning before that and have adequate disclosure in order properly to defend yourself alright thank you very much indeed next on my
00:45:06 thank you very much indeed next on my list is mr. Riley Smith but I think maybe you don't actually want to make all all submissions is that right
00:45:19 right thank you very much that's splendid all right thank you so we now get to mr. Walsh who's here for the lfpp a yes mister good morning sir
00:45:32 a yes mister good morning sir Stephen Walsh I represent the London fire and emergency planning authority the lfpp a which runs the LF be together
00:45:43 the lfpp a which runs the LF be together today with Sarila fair sir you I know have now read our written submissions and understand them and all other core participants have seen and so I have no
00:45:54 participants have seen and so I have no intention of repeating them today what I now have to say focuses on the submissions of other core participants many of whom who expand expanded on them
00:46:06 many of whom who expand expanded on them yesterday and in short the LF EPA agrees with certain of the views expressed by those representing the bereaved the
00:46:18 those representing the bereaved the survivors and residents who lived in the vicinity on the question whether phase 1 can realistically be restricted to the factual narrative only of the 14th of
00:46:32 factual narrative only of the 14th of June to the exclusion of what many have called the why questions or the qualitative questions and so while we accept entirely and understand given the
00:46:45 accept entirely and understand given the enormous task which the inquiry faces your pragmatic reasons for proposing a limited natured phase one we do feel strongly that there are good reasons for
00:46:57 strongly that there are good reasons for giving more flexibility and perhaps very considerable flexibility to phase one so
00:47:08 considerable flexibility to phase one so as to allow a consideration of the reasons why the LF EPA personnel carried out their fire and rescue operation
00:47:19 out their fire and rescue operation during the fire in the way in which they did the application of high-rise fire and rescue policies many of which have national application and how
00:47:32 which have national application and how they replied on the night and obviously the enormous challenges which the emergency services faced in the course of this unprecedented fire some of the
00:47:43 of this unprecedented fire some of the reasons for adopting a much more flexible approach at phase one have already been touched on by the lawyers for the bereaved and the survivors and residents but from the LF ease point of
00:47:56 residents but from the LF ease point of LFE pas point of view they include first of all a strong belief that the bereaved and survivors are entitled to gain an understanding of how and why the fire
00:48:09 understanding of how and why the fire rescue operation was conducted as it was as soon as reasonably practicable and that's the Paramount reason but but there are other reasons the second is
00:48:21 there are other reasons the second is that firefighters and others who give evidence should in fairness to them have an opportunity of explaining not only what they did but the reasons why they
00:48:33 what they did but the reasons why they did it that in part would avoid where possible it's not always possible that we accept the need for witnesses many of
00:48:44 we accept the need for witnesses many of whom have continued to be provoked profoundly traumatized by their experiences to give evidence on more than one occasion which I know is it is a name that everybody wishes to achieve
00:48:55 a name that everybody wishes to achieve if that is possible um but it goes beyond that because if if what might be regarded as obvious why questions that the elephant in the room which one of
00:49:07 the elephant in the room which one of the lawyers yesterday touched upon or not to be recognized and not to be asked at phase one the answers to them will inevitably be left hanging in the air
00:49:19 inevitably be left hanging in the air debated in the public arena possibly for several months pending phase two and the problem with that is that there is a
00:49:30 problem with that is that there is a real risk that public confidence in high-rise fire and rescue operations will be unnecessarily affected possibly through misunderstandings
00:49:41 through misunderstandings when clarity is capable of being achieved on certain issues by addressing quantitative evidence the why questions at a relatively early stage and it
00:49:54 at a relatively early stage and it obviously it goes without saying that the extraction of fire safety critical learning and any need to change policy obviously should be done as soon as possible and it occurred to me actually
00:50:05 possible and it occurred to me actually yesterday that the risk identified by mr. Westgate that expert reports that phase one may carry something of a lower status than those at Phase two by reason
00:50:19 status than those at Phase two by reason of the fact that phase two reports will be better addressed qualitative issues will be substantially ameliorated it's not a major issue but it is another concern and and sir I say that because
00:50:31 concern and and sir I say that because Frank frankly speaking the LF EPA at one stage believed that a full understanding of what went wrong with the structure of
00:50:43 of what went wrong with the structure of the building which we say must have been the case so as to create such an unprecedented fire was necessary in order fully to appreciate the way in which the fire service conducted its
00:50:55 which the fire service conducted its fire and rescue operation that remains true but the LF EPA now feels that the inquiry can properly proceed at phase one on the basis that the great many
00:51:08 one on the basis that the great many questions will obviously need to be left until phase two but questions which can be addressed at phase one without prejudicing the police investigation which is obviously of
00:51:20 investigation which is obviously of paramount importance should be answered as soon as possible which is in short is are the reasons why we urge upon you sir a very flexible potentially very
00:51:32 a very flexible potentially very flexible approach to phase one whether one calls it phase one or phase two those are our submissions on that issue there are only two or three other brief matters that I want to touch upon first
00:51:43 matters that I want to touch upon first of all disclosure lest there be any doubt and so as to be entirely clear the LF EPA is and always has been
00:51:54 LF EPA is and always has been not only in this inquiry but in other instances fully candid and Frank and open in its duty to carry out proper disclosure and certainly in relation to
00:52:05 disclosure and certainly in relation to this inquiry which I hope that we have discharged that Duty fully I know that you are to hear from the fire brigade union shortly and I'd simply want to
00:52:18 union shortly and I'd simply want to support the Fire Brigades Union suggestion and indeed that of others yesterday that the inquiry really would benefit from the assistance of a suitable expert in the application of
00:52:31 suitable expert in the application of the Housing Act 2004 a particularly part one of that statute whether it's a housing officer or an environmental health expert the lfpp agent have no particular comment but but great benefit
00:52:44 particular comment but but great benefit will derive from that position statements which I never say you've been asking everybody about this morning the LF ease basic position is that we can see the merit in the production of
00:52:56 see the merit in the production of written clarification of the LF EPA's position if only because it might properly reflect what will in any event be contained in an opening statement in
00:53:08 be contained in an opening statement in due course which all quarters but for participants of course have a right to make however such written clarification as might be provided whether in a
00:53:19 as might be provided whether in a position statement or another document can really only properly be made at a point when poor participants are cited on a significant element of the disclosure which the inquiry will be
00:53:31 disclosure which the inquiry will be having to look at in short it can only be as good as the disclosure on which it is based and if any precedent or Authority is required for that assertion
00:53:42 Authority is required for that assertion that the same question was addressed in be renewed Hillsborough inquests and the coroner formal or justice Goldring took that view in other words of the pair should be we should be further down the
00:53:54 should be we should be further down the line with more substantial disclosure before position statements are appropriate but that is not say that the LF EPA doesn't want to do it because we're very anxious to get to do it and
00:54:05 we're very anxious to get to do it and get on with it as soon as possible remembering that it is the Metropolitan Police who are responsible for taking statements and that that includes all statements from firefighters and lf-ii
00:54:18 statements from firefighters and lf-ii PA personnel the vast majority of which are obviously yet to be disclosed and on that topic finally we would have we
00:54:29 that topic finally we would have we would expect the LF EPA to provide its regiment opening statement to the inquiry for appropriate disclosure well in advance of the hearing of live evidence and then finally since so
00:54:42 evidence and then finally since so you've been addressing the question of a potential consultative panel the L of e PA certainly has no objection to that course and can well see why such a an approach could be very very beneficial
00:54:54 approach could be very very beneficial for many reasons so those are the short solutions that I make I don't have to Cynthia thank you very much an H sir no
00:55:08 Cynthia thank you very much an H sir no mr. C would
00:55:13 right
00:55:25 so I'm Marcin c-word I'm instructed behind Jared stille yard of Thompson's and I'm counsel for the FPU the FPU is the largest trade union in the fire
00:55:37 the largest trade union in the fire service and it represents firefighters nationally in London over 90 percent of uniformed staff are members of the FPU easily over 90 percent of the
00:55:49 easily over 90 percent of the firefighters who attended on the night of Graham Frontera were fbu members the FPU has a statutory health and safety role for firefighters and appoints safety representatives
00:56:02 and appoints safety representatives following the grenfell tower disaster the FPU is conducting its own investigation and by a safety representative Stephen white alongside the police and the lfb
00:56:15 white alongside the police and the lfb and he will report its findings to the GTI team in jus course there will be much agreement and the fbu report that
00:56:28 much agreement and the fbu report that will deal mainly with issues where there's a difference of opinion trying to avoid overlap the scale of the Graham felt our tragedy needs no hyperbole the
00:56:41 felt our tragedy needs no hyperbole the FPU has from the start argued that the victims and survivors the residents and the bereaved should be placed at the very heart of this inquiry the FPU
00:56:52 very heart of this inquiry the FPU supports their call for a panel to broaden diversity whilst understanding that you can't appoint one but you can recommend it and that panel to reflect
00:57:04 recommend it and that panel to reflect the ground felt our community the FPU supports the need if at all possible for a subsequent string of coroner's inquests to be
00:57:17 string of coroner's inquests to be obviated by the GTI addressing all relevant questions and applying articles to 14
00:57:27 the FPU supports the pleas for early and rolling disclosure of generic documents such as those listed in the FB us submissions and likewise support a venue
00:57:41 submissions and likewise support a venue closer to Greenville tower if that's possible to encourage greater participation and funding for experts to enable core participants to participate
00:57:52 enable core participants to participate effectively the if you also agrees on a procedural point that position statements there's no need to duplicate
00:58:07 statements there's no need to duplicate them they can come with opening statements they are effectively the same thing moving on firefighters are victims to firefighters
00:58:21 firefighters are victims to firefighters who attended of the Grand Vitara disaster and control room operators up and down the country who took those harrowing calls our victims they were exposed and re exposed to trauma as they
00:58:35 exposed and re exposed to trauma as they went back in again and again they they were in fact placed in an impossible position and they should never be placed
00:58:46 position and they should never be placed in that impossible position again the FB use knowledge and experience of earlier fire fatalities shows that nearly all the firefighters who were there will in traumatized and
00:58:58 who were there will in traumatized and that some will be injured by their trauma it's still too early to say in many cases in the military as in the fire service late onset PTSD is becoming
00:59:10 fire service late onset PTSD is becoming a recognized condition there are clear parallels between the firefighters and the residents survivors and bereaved
00:59:22 the residents survivors and bereaved firefighters are victims and survivors as I've already said off the ground filter our disaster firefighters are importantly a community of working
00:59:33 importantly a community of working people who reflect the diversity of the ground
00:59:36 ground community and the public that they serve up and down the country importantly and perhaps you may not appreciate this sir
00:59:50 perhaps you may not appreciate this sir but firefighters feel that their voices have not been heard by the fire service establishment over the last 15 years of deregulation cuts and closures moving on
01:00:08 deregulation cuts and closures moving on to the next procedural point mr. millet has described one procedure for getting evidence from residents of Iverson and bereaved and a different one for
01:00:19 bereaved and a different one for firefighters so that firefighters don't have the opportunity under the present arrangements to call for disclosure of documents and give a statement to their
01:00:30 documents and give a statement to their recognized legal representatives but instead they must rely solely on their police statement now we're in the dark at present about what may have been saving their police statements we did
01:00:44 saving their police statements we did provide a list of additional questions which we hope were put in the course of those interviews but we don't know if they were in all cases or if they were put if they were answered but for the
01:00:58 put if they were answered but for the reasons given by mr. Friedman yesterday the firefighters too should have safeguards so that where the need arises and I don't say in every case because
01:01:09 and I don't say in every case because I'm sure that in most cases firefighters will be content to stand by the statement they gave to the police but where the need arises and that other
01:01:20 where the need arises and that other process can be followed for them as well there may be a need for example to contextualize what they've said to as mr. Walsh indicated to explain why
01:01:36 I've raised this with mr. Mellott very briefly this morning and we'll be happy to discuss it with him in due course
01:01:45 firefighters should have a chance to talk to us about what they've said to the police that's the president the broad thrust of it so that they might want to have a document pointed out to
01:01:58 want to have a document pointed out to them they might want to refer to a document they might be able to answer a further question I appreciate that there's an anxiety not to delay the
01:02:09 there's an anxiety not to delay the process and I don't anticipate that arising in every case but it might arise
01:02:17 so moving on the Fire Brigades Union wants this grand vitara inquiry to be a success to gain and to keep public confidence that we've helped the police
01:02:31 confidence that we've helped the police and the London Fire Brigade to facilitate interviews and we've provided information when requested the fàbregas unit also wants and this inquiry to
01:02:43 unit also wants and this inquiry to answer the big question that mr. Mansfield identified yesterday so how could this happen in London where the resources to achieve fire safety in tower blocks and to fight fire effectively should be readily available
01:02:57 most importantly the Fire Brigades Union wants lessons to be learned recommendations to be made and for those to be acted upon and embedded the Fire
01:03:09 to be acted upon and embedded the Fire Brigades Union experience of earlier tragedies is that the recommendations are not always heeded and we've already provided to your team a list of the what
01:03:22 provided to your team a list of the what we perceive to be the relevant recommendations made from earlier inquiries and inquests into five firefighter fatalities and other fatalities in tower block fires and we
01:03:36 fatalities in tower block fires and we anticipate providing a witness statement from matrac general secretary of the FB you to address issue 10 and inquiry accordingly we support mr.
01:03:50 inquiry accordingly we support mr. state's team's proposals he made yesterday for your inquiry to retain or to implement oversight of the recommendations to ensure that embedded
01:04:02 recommendations to ensure that embedded and implemented how you do that is is obviously a very big question the coroner's rules were changed to try and do that but that perhaps you'd be
01:04:15 and do that but that perhaps you'd be prepared to hear submissions and in due course turn into phases the FB you argued in in our submissions for a
01:04:26 argued in in our submissions for a limited extension of the scope of phase one on the purely fact-finding basis been advocated by the team on the cause of spread of fire exception we now accept the arguments that were made
01:04:38 accept the arguments that were made yesterday and indeed which mr. Wolfe spoke to today for a more flexible approach and early reporting of safety issues as they arise
01:04:50 issues as they arise as indeed has been supported by mr. Maxwell Scott we think things have moved on and input importantly mr. Johnson's
01:05:01 on and input importantly mr. Johnson's submissions indicate that the police forensic evidence won't be complete until the autumn of 2018 and so inevitably all experts are going to make
01:05:13 inevitably all experts are going to make their reports provisional and that's going to make a make it impossible to make final findings of fact in any earlier at any earlier stage on the cause of spread of the fire and that
01:05:27 cause of spread of the fire and that leads us to starting now really starting quite quickly so the fire service is predicated on the basis that fire will
01:05:40 predicated on the basis that fire will break out the precise cause of the fire doesn't concern the incident commander who arrives he's confronted with a fire and the fire service is there to
01:05:52 and the fire service is there to extinguish it and people and so the firefighting operational side of Granville tower is is one aspect of this inquiry which the
01:06:05 is one aspect of this inquiry which the FB you would urge should be addressed as soon as possible what and none of us want is for instant commander to arrive at a tower block
01:06:16 commander to arrive at a tower block tomorrow and to face the same dilemmas that they faced a grim felt era if I can move on to the need for an independent
01:06:28 move on to the need for an independent and environmental health practitioner yeah I think there's quite a lot of support for that but just to underline it in our application we asked for such
01:06:40 it in our application we asked for such a person to become an Assessor in view of the submissions made by Russell cook have mr. Arthur mr. Bates and and argued orally yesterday by mr. Bates we would
01:06:53 orally yesterday by mr. Bates we would accept their position is is more refined and better serves the purpose we're trying to achieve which is to have a tenant representative as an assessor and
01:07:05 tenant representative as an assessor and to have an environmental an independent environmental health practitioner as an expert for the GTI team so that's that's if if I may orally amend our application
01:07:17 if if I may orally amend our application in in that regard
01:07:23 as Metis stems there's a very important part of the fire safety regime for tower blocks like gram flour which is wholly outside of the scope of this inquiry
01:07:36 outside of the scope of this inquiry which is part one of the Housing Act 2004 and there is there a little known and little-understood safety regime
01:07:48 and little-understood safety regime called the housing health and safety rating system HHS RS I think is how it's supposed to be pronounced and and that
01:07:59 supposed to be pronounced and and that these is currently being overlooked no questions are directed to that scheme of any of the experts and it's not it doesn't appear in any of the lists of
01:08:10 doesn't appear in any of the lists of issues at the moment the focus is perhaps erroneously on the fire safety order I st. perhaps erroneously because obviously that's a matter for you to
01:08:21 obviously that's a matter for you to consider in in due course but may I direct you to paragraph nine of our third submissions where I set this out in some detail and if I can just
01:08:32 in some detail and if I can just summarize it the HHS RS is the only fire safety regime which expressly includes the structure and exterior of buildings like Graham Bell Tower and so it's an
01:08:46 like Graham Bell Tower and so it's an important part of the fire safety regime that really should be looked at
01:08:55 and also an expert would be needed not only to do that because the HHS RS is quite complicated it's it's real expert territory but also if we're going to
01:09:07 territory but also if we're going to have proper and effective recommendations going forward we'll need it and experts help to formulate those
01:09:16 as to the terms representative we do adopt what the Russell Cook submissions said paragraph 7 & 9 can I just add what the FPU calls the
01:09:30 can I just add what the FPU calls the the establishment point and this is that as currently constituted leaving the academics to one side because everybody understands their academics and they
01:09:41 understands their academics and they have their own field of expertise and they get on and do what they're best at but the inquiry team currently has a firefighting expert Stephen Kirk and two
01:09:54 firefighting expert Stephen Kirk and two Assessors Joyce Redfield and chair Montgomery and all three of those are or were high-level managers and they were
01:10:07 were high-level managers and they were all possibly still are close to local and central government and if we add to that mix the fact that Steve McGurk and
01:10:20 that mix the fact that Steve McGurk and Joyce ruthian both are both deputy left tenants in the county of Greater Manchester then it emphasizes and reflects the the gap between them and
01:10:34 reflects the the gap between them and the Granville town community and indeed the only working people in the fabricator union and so this can be remedied it can be remedied in a number
01:10:46 remedied it can be remedied in a number of ways and if we have an environmental health practitioner expert for the team if we have a tenant representative assessor and if if there's a
01:11:00 assessor and if if there's a consultative panel and if fire expert is appointed to assist the team whose hasn't been so closely
01:11:11 team whose hasn't been so closely involved deregulation of caps as mr. McGurk then greater confidence would be established in the inquiry if I can move on now to mr. McGurk now the FPU does
01:11:26 on now to mr. McGurk now the FPU does not question his expertise his seniority or his experience we quite understand why he seems to the Granville town inquiry team to be the perfect expert
01:11:38 inquiry team to be the perfect expert but we do ask you to listen to our concerns and understand why we are persisting with our concerns we don't
01:11:49 persisting with our concerns we don't believe that Stephen McGurk is the appropriate fire expert to assist the inquiry
01:11:56 inquiry firstly he's been at the forefront of deregulation in the fire service from 1999 to 2015 the period when he was a
01:12:07 1999 to 2015 the period when he was a chief fire officer he has been a champion of the change and transformation that's taken place in the fire service and that has led to cuts
01:12:20 fire service and that has led to cuts and closures in reliance on statistics showing a full in domestic fires and fatalities during that time he was a
01:12:33 fatalities during that time he was a board member of the chief fire Officers Association for over seven years and he was his president from 2006 to 2008 the
01:12:44 was his president from 2006 to 2008 the Fire Brigades Union has opposed those changes all the way along and mr. McGurk has consistently been at the opposite
01:12:55 has consistently been at the opposite end of the table to the Farragut Union I asked Matt rack yesterday if he could remember any single occasion in which
01:13:06 remember any single occasion in which Steven the work and the FPU agreed on an issue and he was unable to recall that might of course reflect his poor memory it might reflect the fact that the that
01:13:20 it might reflect the fact that the that mr. mcquewick and the FPU have traditionally and still oppose each other
01:13:27 other certainly that is the perception the FPU has significantly the FPU wants this
01:13:40 has significantly the FPU wants this inquiry to consider the effect if any of deregulation and closures and cuts on the emergency response of the 14th of
01:13:51 the emergency response of the 14th of June 2017 and that is part of investigating the big question how could this happen in London and we contend
01:14:03 this happen in London and we contend that mr. McGurk is inevitably conflicted in considering or advising team on that issue furthermore he's been the principal advisor to the Local
01:14:15 principal advisor to the Local Government Association in the production of their fire safety guidance the fire safety guidance has been contentious from the outset but crucially it was
01:14:28 from the outset but crucially it was unamended following the recommendations in that regard made by the coroner after the inquest into the lateral house fire and so we take the view that mr. McGurk
01:14:44 and so we take the view that mr. McGurk is is conflicted and would be unable help to help the inquiry on several of the issues that have been listed 10 B 10
01:14:55 the issues that have been listed 10 B 10 seat any and 12 e for example he was in charge of Greater Manchester Fire and Rescue Associate II when the
01:15:06 Rescue Associate II when the recommendations were made by the coroner from from Leki north and one question for your inquiry will be whether those recommendations were implemented in
01:15:17 recommendations were implemented in London adequately and mr. McGurk I suggest is compromised in that regard he's unlikely to be critical
01:15:29 that regard he's unlikely to be critical of any such implementation that broadly mirrored what he did him in Chester he has a duty of impartiality and independence which the team have have
01:15:42 independence which the team have have rightly acknowledged when he's got to be seen to be both in partial and independent the FPU fears that instinctively he'll strive to show that
01:15:55 instinctively he'll strive to show that deregulation cut some closures were irrelevant to what happened to Greville town the FPU suggests that the team could use another retired chief fire
01:16:06 could use another retired chief fire officer preferably from Scotland who hasn't opposed the FPU throughout his or her time in high office I've made some
01:16:21 her time in high office I've made some specific points about the letters of instruction to experts in these submissions and I refer you to our supplementary submissions paragraphs 815 yes I've read those unless you want to
01:16:32 yes I've read those unless you want to ask any particular questions about them I propose to move on it's probably all there is but it's all this you want to expand on anything I don't know it's all
01:16:43 expand on anything I don't know it's all there thank you so much if I can take you to to the applications then the FPU is applying for the termination of the
01:16:58 is applying for the termination of the appointment of either or both mr. McGurk as an expert or which is ready an Assessor
01:17:03 Assessor we are grateful that the inquiry team have made their checks and are satisfied of the integrity of both and and we
01:17:14 of the integrity of both and and we accept that obviously but this is a process that's got to be transparent and justice has to be seen to be done the FB
01:17:27 justice has to be seen to be done the FB use reservations remain
01:17:33 paragraph three has been amended as idly indicated so it's the appointment of an Assessor who's a tenant representative and an expert is an independent environmental aesthetician and
01:17:44 environmental aesthetician and thereafter if mr. mcquewick stands as an expert inquiry then the FPU would ask for permission to instruct an expert in operational firefighting so as
01:17:55 expert in operational firefighting so as to peer-review his his his evidence and the FB only sensible for you to see his report before that taken any further it would be sensible yes certainly
01:18:10 and of course the FPU can't afford to fund that expert that expert would have to do a lot of reading and a lot of work and that would all cost money and so an
01:18:25 and that would all cost money and so an application for funding that will be made I believe that's already underway but the abuser non profit making organization it doesn't have a budget for this sort of commitment and the the
01:18:39 for this sort of commitment and the the sixth application I can leave that until the later stage yes so unless I can help you any further sir that's very helpful thank you very much indeed
01:18:50 thank you very much indeed thank you no um sorry give you a chance to sit down again for us although I
01:19:04 to sit down again for us although I think on your running sheet mr. beer comes next I've slipped in to my running sheet and note that mr. Brown who's instructed by the fire Officers
01:19:15 who's instructed by the fire Officers Association is here and would you like to make some submissions yes of course
01:19:36 good morning sir I am Louie Brown I'm instructed by Jonathan wall of Burton Copeland solicitors on behalf of the fire Officers Association the fire
01:19:48 fire Officers Association the fire Officers Association the F away has a current membership of around 1200 and represents mainly those in middle management roles it is one of the two nationally recognized unions for fire
01:20:00 nationally recognized unions for fire and service personnel whilst we of course represent the interests of the Union as a whole our particular focus at this stage is on two of his members Richard Welch and the drawbridge Richard
01:20:15 Richard Welch and the drawbridge Richard Welch is the borough commander from Lambeth and he arrived at Granville Tower shortly before 2 a.m. on the night of the tragedy he assumed the role of
01:20:26 of the tragedy he assumed the role of incident commander he designated the fire as a major incident the role of a sector commander was performed by Deputy
01:20:37 sector commander was performed by Deputy Assistant Commissioner Lee Trowbridge and mr. Welsh was then appointed fires sector commander a role which he held for about ten hours it was his duty to
01:20:49 for about ten hours it was his duty to constantly reassess the instance that developed the formulation of strategies and the deployment of resources including fire fighters mr. drawbridge
01:21:00 including fire fighters mr. drawbridge was tasked with the duties of sector commander command support and he remained at the scene of the tragedy until about 4:00 p.m. that day can I
01:21:13 until about 4:00 p.m. that day can I briefly say a word about collaboration please we will look to collaborate closely with both the London Fire Authority and the Fire Brigades Union
01:21:25 Authority and the Fire Brigades Union wherever possible with with both of whom we share many common interests and we will cooperate with them in a manner that will avoid the duplication of work
01:21:36 that will avoid the duplication of work resources and time can I then deal please with some discrete issues disclosure we adopt and repeat all that
01:21:48 disclosure we adopt and repeat all that has been said on that we would respectfully seek a disclosure in a structured manner as soon as recently practicable broader issues of disclosure
01:21:59 practicable broader issues of disclosure we agree with mr. seaward and the position he sets out in paragraph 11 of his written submissions and we would welcome the use of the relativity platform with which my instruct ministers have considerable familiarity
01:22:12 ministers have considerable familiarity give this user Judy Hillsborough inquests so far as the structure of the inquiry is concerned in the phases we
01:22:23 inquiry is concerned in the phases we would respectfully adopt them timely all that was said by mr. Welsh Queen's Counsel on behalf of the London Fire Authority and in particular the vital need for phase one to include the
01:22:36 vital need for phase one to include the ability of firefighters to deal with the rationale for their decision making these in part the state courts of policy
01:22:50 so far as the questioning of witnesses concerned looking farther forwards so we agree that proposed questions and prepared questions should be submitted in advance but would ask please that
01:23:01 in advance but would ask please that appropriate flexibility be given in due course so far as written statements are concerned we adopt and repeat what was said by mr. seaward insofar as any supplemental witness statements of key
01:23:13 supplemental witness statements of key witnesses are concerned and finally can I also say we share and endorse mr. C was submission that both firefighting
01:23:25 was submission that both firefighting unions will do everything within their power to ensure that the nor inquiry answers the questions that demand answers unless I can assess further thank you very much indeed
01:23:46 when I think it is some mr. beers turn if can you make your way out of there mr. beer
01:24:03 right
01:24:13 yes that's Jason bear representing the Secretary of State for Communities and Local Government I had indicated to mr. millet that I didn't intend to say anything and indeed I don't intend to
01:24:24 anything and indeed I don't intend to speak to the two-page document that we submitted given conversations that I'd have with him and the submissions that he'd made yesterday it's not necessary
01:24:35 he'd made yesterday it's not necessary to do so can I just briefly therefore address you or try and assist you on the two supplemental issues that have arisen yes of course and that you've been putting two other advocates firstly then a consultative panel if such a panel
01:24:49 a consultative panel if such a panel encourages the opening of lines of communication and a dialogue between former residents the relatives of the bereaved and survivors of the disaster
01:25:01 bereaved and survivors of the disaster and if it allows dialogue outside of the formality of hearings such as this it has much to say for it in our view thank you as for position statements we do not
01:25:15 you as for position statements we do not object in principle to the service of position statements but when you're considering the request that's been made to you we would respectfully ask that
01:25:26 to you we would respectfully ask that you bear in mind the following three points firstly of course these are inquisitorial proceedings with you as the Inquisitor in chief and plead
01:25:38 the Inquisitor in chief and plead pleadings of which position statements are a species are not a feature of such proceedings for good reason and that may
01:25:49 proceedings for good reason and that may be why they've not hitherto featured in any of the approaching two dozen inquiries established under the 2005 act in which the 2006 rules apply to but
01:26:01 in which the 2006 rules apply to but could they not be helpful in clarifying the ground yes if of course of course they can and it will be within your
01:26:12 they can and it will be within your section 17 power to require them and I'm going to suggest the potential solution in a moment and this is the run-up to the wicket effectively second an element
01:26:29 the wicket effectively second an element of realism needs to be brought to bear to the exercise because the application is made on the basis that the statements will help to narrow the issues and
01:26:41 will help to narrow the issues and therefore save time and cost as one reason for them but this inquiry is very much multi-party and there are no
01:26:52 much multi-party and there are no parties of course but in litigation equivalent it super charged multi-party and litigation and there of course where what CP number a says about an issue is
01:27:05 what CP number a says about an issue is not fair to bind CP v and so the likelihood of being able to take things completely off the table is perhaps more
01:27:16 completely off the table is perhaps more ilusory than real the third point as others have said already is that if position statements are to have value and meaning they must come after
01:27:29 and meaning they must come after disclosure and expert evidence indeed that was one of the reasons why Sir John Goldring in his ruling you may look at it at your leisure its paragraph 25 of
01:27:41 it at your leisure its paragraph 25 of his ruling and refused the equivalent application that mr. Weatherbee made in the hills were in quests of course that was slightly different the application was made whilst the inquest were on foot so we were partway through them but what
01:27:54 so we were partway through them but what he said was I could only have I couldn't have altered them before we started at one of the pre inquest hearings because there haven't been disclosure or expert evidence at that stage and so a
01:28:06 evidence at that stage and so a potential solution in particular where your operating necessarily under a compressed time scale and therefore there isn't going to be the luxury of
01:28:17 there isn't going to be the luxury of building in additional time to allow people to pause for thought consider all of the disclosure they've got and file a position statement is to give directions
01:28:29 position statement is to give directions as to the content of ruled in opening statements normally part is core participants are allowed almost the free reign as to what they may say but
01:28:43 free reign as to what they may say but you could under your section 17 powers give directions as to the contents of them and make that the occasion on which parties must in relation to a series of identified issues set out their position
01:28:57 identified issues set out their position with clarity and that's the solution that we would respectfully propose so that's what they intended to see yes well thank you thank you very much indeed know that you've been very
01:29:10 indeed know that you've been very economically in your use of time I must say all of you that completes the list of those who I have who were expecting to speak on behalf of core participant can I just
01:29:21 behalf of core participant can I just check there's no one here who thinks he's been ever looked well she's been overlooked because there's something you needed to say no right thank you very much well in that case I'll invite mr.
01:29:33 much well in that case I'll invite mr. millet to respond to the various submissions we've heard yes mister well
01:29:51 submissions we've heard yes mister well would you like to come and clarify it from the place where you can be seen on camera
01:30:02 I'm very much obliged for this opportunity and I think we'll only friend Fiona Murphy also wishes just to do this I'll do one point she has another point relating to our submissions the point I just wish to
01:30:14 submissions the point I just wish to clarify as far as I mean is the one that you raised with me yesterday that is the question of a consultative panel I think I answered it but in case there's any ambiguity in what has transpired we
01:30:30 ambiguity in what has transpired we maintain the position and it's only because the word panel crops up twice that there should be no confusion that a consultative panel is no substitute for
01:30:42 consultative panel is no substitute for a decision-making panel of which we are advocates and may I just say I think that makes the position clear I don't see anybody well if it's any
01:30:53 I don't see anybody well if it's any comfort mr. Manfield there was no ambiguity in my mind about your submission well I am very much but I thought it right given the particular nature of any consultative panel
01:31:05 nature of any consultative panel representing the views if you like of the bereaved residents survivors and so on those who are core participants but
01:31:16 on those who are core participants but not of that body yes should just have a chance to say whether they saw any objection to that course if we thought it right to take it forward that is and
01:31:28 it right to take it forward that is and I'm grateful to them for their assurances that they see no objection to that and that was the reason I raised it I'm very much obliged final matter on this is that I think I can only speak for the ones I represent we would need
01:31:40 for the ones I represent we would need an opportunity to consult with our own families about that particular concept but I can't take it in well it's an idea that had occurred to us and that we are thinking of taking full taking forward
01:31:52 thinking of taking full taking forward but it won't happen without consultation much obliged thank you
01:32:03 yeah
01:32:09 yes thank you Sara I'm instructed by mr. jang geurim a mode of fish with Lloyd Jackson solicitors led by mr. Weatherbee who apologizes as he's a another
01:32:20 who apologizes as he's a another professional commitment today I have two topics that I wanted to respond to very briefly they're both arising from the substantive focus of our in submissions
01:32:31 substantive focus of our in submissions and the first is with regard to position statements sir and could I ask you to consider our short paragraph paragraph 16 in which we set heart what we
01:32:43 16 in which we set heart what we considered to be the appropriate content of the position statements and what we say there is that it should set heart the party's position as to what happened
01:32:54 the party's position as to what happened and what failures if any they acknowledge as falling within their responsibilities and so we say concise but precise form of words there as to
01:33:05 but precise form of words there as to what is envisaged and we emphasize the importance of that being endorsed with a statement of candor and with that run-up to the wicked as mr. Barrett would put it I we would support his suggestion
01:33:19 it I we would support his suggestion that that be addressed by the means of a direction in the context of the rule 14 I believe it is directions with regard to the opening statements but it's
01:33:32 to the opening statements but it's important to appreciate so that they are different animals and we don't agree that their value is more elusive than rail in situations in which one party is
01:33:46 rail in situations in which one party is not able to bind another party because the statements not only are they very meaningful for the families to hear for the bereaved and the residents and those
01:33:57 the bereaved and the residents and those affected by the disaster more generally it's also the case that it will assist your enquiry as to how the inquisitorial process it is is focused and it may be
01:34:09 process it is is focused and it may be material that each of the state court participants appear to support the making of position statements was a perhaps significant progress that is
01:34:20 perhaps significant progress that is learning that has arisen from the Hillsborough inquests and clearly if mr. Catchpole does wish to advise his client not to make one then it's our proposal that he should give
01:34:31 it's our proposal that he should give reasons for not doing so so secondly and briefly with regard to disclosure a topic that has occupied quite rightly a significant portion of these hearings
01:34:43 significant portion of these hearings and we would like to emphasize that the specificity of the request that your enquiry have made and which we've now learned about in the course of these hearings underlines for us the
01:34:54 hearings underlines for us the importance of our requests for openness and transparency with regard to the process of disclosure everything we've heard has served to further emphasize the importance of that and in that
01:35:06 the importance of that and in that context we support mr. Catchpole remarks and we also agree that it's important that the process is structured and we commend to you paragraph ten of our
01:35:17 commend to you paragraph ten of our instructions in which we set out in some detail our understanding how this process should work and we emphasize there so the three stages production to
01:35:28 there so the three stages production to your inquiry disclosure to the core participants and the preparation of bundles and it's only the core bundles that will be relied upon in the questioning of witnesses so we strongly
01:35:40 questioning of witnesses so we strongly disagree that the core participants cannot scrutinize 200,000 documents we are experienced we have that skill set we've done it before and clearly it has
01:35:51 we've done it before and clearly it has to be supported with active pace management but finally on disclosure we emphasize and agree with the number of the submissions that early disclosure is possible it doesn't have to be chaotic
01:36:03 possible it doesn't have to be chaotic with much prefer its structured but as soon as we get started the better and the tranche approach is not inconsistent with with good management thank you sir thank you very much well mr. millet
01:36:23 thank you very much mr. chairman and may I start my very brief response submissions by thanking all the core participants and their advocates for
01:36:36 participants and their advocates for their helpful 16th and thought-provoking submissions there is much for the inquiry and for you mr. chairman to take
01:36:47 inquiry and for you mr. chairman to take away and consider carefully I only want to cover three things in my wrap-up as it were first mr. Mansfield's formal
01:36:58 it were first mr. Mansfield's formal application for a panel of decision-makers to sit as decision-makers with you second experts and just to say something very briefly about that and thirdly
01:37:12 very briefly about that and thirdly something even more brief about the TMO disclosure of the housing files so far as the first of those is concerned mr.
01:37:23 as the first of those is concerned mr. Mansfield's application for a panel our basic applicator position is this we recognize absolutely that unless the work of our inquiry is collaborative
01:37:35 work of our inquiry is collaborative inclusive and empowering of those who were the victims of the fire at grenfell tower our work will be in vain we completely agree with the sentiments
01:37:48 completely agree with the sentiments expressed by mr. Mansfield and others about public support for and confidence in the work of the inquiry it is for
01:37:59 in the work of the inquiry it is for that reason among others that the residents the survivors and the bereaved have been given automatic core participant status that has actually
01:38:12 participant status that has actually brought them right into the heart of the inquiry they will get access to the displays documents they will get to make
01:38:23 displays documents they will get to make submissions they will get to give evidence they will get to pose specific questions and see that justice is done at very close quarters core participant status brings very
01:38:37 core participant status brings very significant advantages it ensures balance that ensures thoroughness and it ensures openness as I set out yesterday mr. chairman we do intend to involve the
01:38:50 mr. chairman we do intend to involve the survivors the residents and the bereaved who are core participants in the process and processes of this inquiry into their tragedy as much as we can consistently
01:39:04 tragedy as much as we can consistently with our duty to control and operate a ruthlessly independent and effective investigation however the question of
01:39:16 investigation however the question of the composition of the panel does give rise to rather different considerations we would suggest very briefly that it is
01:39:27 we would suggest very briefly that it is properly a matter for the Prime Minister as the sponsoring minister to decide under the Act whether she wishes to appoint other members to sit as
01:39:39 appoint other members to sit as decision-makers with you on a panel we would suggest respectfully that it would be wrong for you to express any view either way before she has made that
01:39:52 either way before she has made that decision since that might be seen as influencing her decision on that matter and you need no reminding but I'll
01:40:03 and you need no reminding but I'll remind you anyway mr. chairman you must remain wholly independent of government in this inquiry if she decides not to ask you then the question of your
01:40:15 ask you then the question of your consent under the Act does not arise if she does ask you then you must and you will it approached the question of whether to consent with an entirely open
01:40:27 whether to consent with an entirely open mind so far as the question of experts is concerned my second wrap-up topic there is one important point of
01:40:38 there is one important point of clarification on expert evidence that I may need to make some of submissions that you heard yesterday from certain of the core participant
01:40:50 from certain of the core participant advocates including mr. steam suggested that the inquiry had accepted that bereaved residents and survivors should be allowed to engage their own experts
01:41:02 be allowed to engage their own experts and their own expert advisors I quote from the transcript at page 121 what in fact I said in my oral submissions to you yesterday was that the inquiry team
01:41:15 you yesterday was that the inquiry team was sympathetic to the need to allow more time for all CPS to digest the inquiry experts reports and to make any applications to call their own expert
01:41:28 applications to call their own expert evidence than had been indicated in our provisional program beyond that in terms of whether permission will be granted for any particular core participant to
01:41:40 for any particular core participant to call their own expert evidence our position remains entirely unchanged from my statement dated the 15th of November namely that the guiding principle will
01:41:52 namely that the guiding principle will be that it is for the inquiry to investigate any core participant who wishes to call an expert on any particular topic will have to make out
01:42:03 particular topic will have to make out an exceptional case as to why they should be permitted to do so I reiterated that yesterday any such application will need to explain why in
01:42:15 application will need to explain why in the context of an inquisitorial procedure such as this the core participant should be permitted to call expert evidence and why the work cannot be undertaken by the inquiry experts or
01:42:28 be undertaken by the inquiry experts or for example by putting questions to them all of that said we do see force in ensuring as far as we can that there is
01:42:39 ensuring as far as we can that there is equality of arms between the core participant organizations at work whether between themselves or or not and individual core participants so far as
01:42:52 individual core participants so far as concerns the assessment of the need to call
01:42:56 call an expert or the need to apply to do so and there is of course a threshold and preliminary set of work that may need to be done in order fairly to allow core
01:43:07 be done in order fairly to allow core participants to arrive at that position we would suggest mr. chairman that we've the inquiry team give that further consideration thirdly and finally that
01:43:19 consideration thirdly and finally that so far as the TM owes disclosure of the relevant housing files is concerned the position is that the memory stick provided by the TM Oh on the 28th of
01:43:32 provided by the TM Oh on the 28th of November was I'm afraid very difficult to access and manage the inquiry team met the TMS solicitors on the 5th of December and informed them of the
01:43:45 December and informed them of the problems such as corrupted documents duplication unreadable 'ti and other matters of that nature we wrote to them on the 8th of December asking for hard
01:43:56 on the 8th of December asking for hard copies by the 12th of January miss Jarrett has very helpfully told us that those will be produced by Christmas and so this particular problem has I think
01:44:09 so this particular problem has I think now been resolved and I'm glad to be able to tell you of that and we look forward to the TM O's continuing good offices and assistance in that matter as
01:44:20 offices and assistance in that matter as in all others mr. Chairman I have nothing else to add by way of reply I'm grateful to your for your attention thank you very much mr. millet well I'd
01:44:31 thank you very much mr. millet well I'd like to thank all of you who've made contributions for those contributions whether they've been written or oral or in many cases both and I'd like to thank you also for being so economical in your
01:44:43 you also for being so economical in your use of time which means we can now draw this hearing to a conclusion it goes without saying that I found your submissions very helpful and in many
01:44:54 submissions very helpful and in many cases as mr. millet put it thought-provoking and for that reason I'd like an opportunity to digest them and to review the transcript of the proceedings so I'm going to take a
01:45:07 proceedings so I'm going to take a little time to do that I shall respond in writing as soon as I can and in any event I hope by the middle of next week if not a bit sooner I'd also like to thank all council for
01:45:21 I'd also like to thank all council for the way in which the submissions have been presented they have been forceful and direct as one might expect at the same time they've been careful and measured and
01:45:32 they've been careful and measured and I'm very grateful for the way in which you've all contributed to the conduct of the hearing they have been clear indications as far as I can see that
01:45:43 indications as far as I can see that with the benefit of continuing dialogue it should be possible to take the enquiry forward in a way that enables the work to proceed as quickly and smoothly as possible
01:45:54 smoothly as possible while at the same time ensuring that the needs of all core participants but particularly those of the bereaved survivors and local residents are fully
01:46:05 survivors and local residents are fully met and I look forward to seeing you all on another similar occasion before too long thank you all very much