Studio Architects Evidence - Tuesday 14th July 2020 (3/3)

Full transcript

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00:13:43 right you'd like to ask mr sons come back please

00:13:54 all right mr sims ready to carry on yes good thank you very much yesterday yes thank you so mr stones just picking up

00:14:02 up um the chronology um in paragraph 200 of your statement what you say is that over the following weeks

00:14:09 weeks so this is kind of the spring of 2013 studio e corresponded with cep in relation to four different rayner bond products you say that our paragraph 200

00:14:21 200 for the transcript can we just go to the email that you've referred to in that paragraph of your statement this is

00:14:28 sca407527

00:14:37 and we can see that the email you've referred to is in fact a communication between blaine cagney of studio e

00:14:46 studio e and rayna bond uh at alcoa.com do you see that there yes so it seems to be a direct communication not with cep but with um alcoa or as we know them are conic do

00:14:58 um alcoa or as we know them are conic do you see that yes um do you recall any further direct communication or correspondence with arconic around this time

00:15:09 i i don't and this this was just a request for samples yeah by a plane yeah no that's right um can we go then to sea407563

00:15:24 and we can see that on the 17th of april you sent an email to peter madison of the tmo

00:15:33 the tmo copying in various others on the project and if we go to the very bottom of that first page [Music]

00:15:43 [Music] we can see that um you've circulated some

00:15:47 some samples um you say going beyond the meeting i think it's worthwhile circulating the samples we've been collecting of alternative cladding options to zinc do you see that there yes and then um

00:15:59 do you see that there yes and then um you've set out a number of samples um so we can see you've got coated aluminium aluminium composite material and there's a

00:16:10 and there's a five different acms there do you see that yes

00:16:13 that yes and then if we get over the page we get um some more acms i think six seven and eight

00:16:24 six seven and eight um and then you say marley equitone cement particle board do you see that there yes um and just looking back at item

00:16:35 yes um and just looking back at item eight you've got something called a rhyme zinc material originally shown to planners do you see that there yes now by this stage had you formed a view

00:16:46 view that aluminium composite material was going to be the best option in terms of cost on this project

00:16:58 from everything that we've been presented and discussed and i'm i'm not sure i'm exclusively referring to cep here but um

00:17:09 to cep here but um i think that would have corresponded with what um artelia thought as well but it was my understanding that asean would have been most cost-effective yeah

00:17:22 most cost-effective yeah and and it's right isn't it that by this stage of the mystery of the metals i should add yeah obviously the the marley tone isn't a metal at all no that's a cement particle board

00:17:33 that's a cement particle board yeah yeah i'm not sure how those compare i see okay um but by this point you haven't considered the fire performance of the

00:17:42 of the aluminium composite materials have you no

00:17:47 no now going back to your witness statement if we can look at paragraph 207 this is sca 3014273 at page 88.

00:17:58 sca 3014273 at page 88. in the first sentence of that you say that

00:18:02 that um this is in i think in april 2013 is the rest of the paragraph so that's the time period you say further to the above issues and apparent requirements of planning i

00:18:14 apparent requirements of planning i raised the idea of using a luca bond a supplier of acm panels on the basis that it had been suggested to me by numerous parties and there were various color options with this project do you see that there

00:18:31 product with this product yeah yes and you've said in the line before that it's been suggested to me by numerous parties can you remember which parties had been suggesting a luca bond to you

00:18:44 had been suggesting a luca bond to you um can i give a little bit of context yeah absolutely because

00:18:51 because why am i looking at acm i think it would be the

00:18:55 be the first point and at this point the project had stalled right almost entirely it seemed on the basis of cost okay um i don't

00:19:07 okay um i don't say we were desperate but it it it was not clear that it was going anywhere right in terms of negotiations with um ledbetter okay

00:19:18 um ledbetter okay so so why would i be looking at the cheapest options well that's because perhaps that's what the client would need yes well we've we've already looked at that email that you received

00:19:30 looked at that email that you received about a radical rethink but did anyone's no luca bonds i knew a luca bond from my student days you say a luca bond had

00:19:41 my student days you say a luca bond had been suggested to me by numerous parties but it was that that i was

00:19:45 was interested in which various parties had suggested a luca bond to you can you remember

00:19:55 no i raised the idea of using luca bond on the basis that it um being acm not luke bond itself i see have been suggested by numerous parties i see so it's the acm

00:20:07 parties i see so it's the acm that you're talking about that have been suggested to you i see yeah i i've obviously done some research and i've it's not currently on the enquiries portal but

00:20:21 enquiries portal but in 2009 luca bond produced a marketing brochure called from the pioneer to the synonym right and i think anyone of my age world

00:20:33 of my age world would commonly refer to hcm as a look i see yeah it was synonymous with that product was it that that particular brand i i was 19 when i learned about products and i

00:20:46 19 when i learned about products and i i believe it's it's older than i am as as a product on the market yeah can we look then at the alukabon product brochure this is

00:21:00 sca3014431

00:21:04 do you remember looking at this at the time of the grenfell project um the brochure yeah the luca bond product ratio do you remember looking at this at the time i was looking at the

00:21:16 this at the time i was looking at the samples

00:21:17 samples now if we go on within this at page 32 we see a list of the different panels available

00:21:23 available and their properties

00:21:26 and we can see that the standard a luca bond at the top of the page has a p e call and it's said in those little tiny writing the little tiny writing on

00:21:39 tiny writing the little tiny writing on the right hand side to have says one polyethylene core 0.5 millimeter aluminium and it says normal flammability do you see that there yeah the next down is a luca bond plus

00:21:51 yeah the next down is a luca bond plus and that says that it's a mineral filled core

00:21:55 core and in the tiny writing it says it's of low flammability do you see that there

00:22:04 and i think it also says yes in the middle of the text on the left it says thanks to its mineral filled core a luca bond plus meets the stricter requirements of the fire classifications

00:22:16 fire classifications do you see that there now i do yeah repeat i didn't look at this at the time no i okay i'm just going to ask you a general question then then at the bottom of the page we have the luca bon a2

00:22:28 of the page we have the luca bon a2 and it said there that it's the only non-combustible aluminium composite material

00:22:34 material used in architecture that fulfills the respective standards worldwide and it says thanks to its mineral filled core the luca 18 meets the strict requirements of the fire regulations and

00:22:45 requirements of the fire regulations and enhances the possibilities for the concept and design of buildings and on the right hand side in the little tiny text it says incombustible do you see that there yeah

00:22:56 yeah um now so i appreciate you saying you didn't read this product brochure at the time but did you appreciate that there were these different types of

00:23:07 that there were these different types of panel in terms of fire performance available at the time absolutely no so you it follows you didn't give any consideration to which of these might be appropriate on the grenfell

00:23:18 might be appropriate on the grenfell project when you were talking about a luca

00:23:21 luca that follows i can't see what application a flammable product has yeah can we now look at paragraph 209 of your statement this is

00:23:33 statement this is sca14273 page 89.

00:23:40 and you say there that in april you say on the 22nd of april 2013 i met with jason tisbury of cgl systems a facade designer and manufacturer

00:23:52 manufacturer in our office to discuss another project and then you say following the meeting studio ordered samples of a luca bond spectra metallic colors and requested further information on cladding pricing and subcontractors

00:24:05 cladding pricing and subcontractors i'd asked jason tilbury tisbury to provide me with contact details for appropriate subcontractors which we might approach to discuss the detail of the cladding on the project do you see that there yeah

00:24:19 do you see that there yeah now you say you'd asked him to provide you with appropriate subcontractors did you ask cep the same question no do you know why you didn't ask them

00:24:32 no do you know why you didn't ask them um sorry i do give a reason not in this paragraph by that stage i understood that they were not

00:24:40 were not um installers per se they didn't contract they were fabricators i see so is it explained by the next sentence

00:24:48 sentence by this time i understood the cp were fabricated rather than an installer and could only give limited comment on actual costs and details i can't remember where or how i learned that

00:24:59 that but i understood that they didn't themselves install and design the systems yeah and then you go on and you give the names that were provided to you and we

00:25:10 names that were provided to you and we can see that one of those names was harley

00:25:12 harley do you see that yes there yeah had you heard of harley before april 2013 no had you ever worked with them before no now in fact i think we can see that

00:25:25 no now in fact i think we can see that harley contact you then before you have a chance to contact them let's go to sca407603 if we can

00:25:42 them let's go to sca407603 if we can blow that up so this is mark harris of harley to you on the 25th of april 2013. and he says dear bruce following up on the contact from jason at cgl

00:25:54 the contact from jason at cgl this is just a quick email to confirm our interest in the proposed overclouding scheme for grenfell tower over cladding tower blocks is very much what we do and specifically in london hence our

00:26:06 and specifically in london hence our keen interest in grenfell and then he says i've attached a small selection of tower block projects information sheets and would welcome the opportunity of meeting up with you to talk through your requirements

00:26:17 talk through your requirements and then he looks forward to hearing from you

00:26:21 from you now in your experience was it common for a subcontractor to contact the architect about a project in this way

00:26:33 i can't think of many instances where this has happened however the circumstances in which it happened were very understandable yeah because you've been speaking to cdl about them

00:26:45 speaking to cdl about them yeah i see um now the project examples that harley provided to you with in that email we can see from looking at those that they all involved acm did you notice that at the time

00:27:02 i don't think i at the time um paid too much attention to this because the project was in a sense on hold i i can't recall exactly if i

00:27:13 hold i i can't recall exactly if i noted that they were acm yeah i might have done we can see there were attachments castlemaine chalcott clemens um i see so you didn't notice at the time that um i

00:27:24 you didn't notice at the time that um i might have done but i okay obviously it doesn't say so so i don't know i don't think i read those sheets i might have looked at the pictures

00:27:34 pictures and did you follow up with harley after this email much later much later yeah did you ever visit any of the sites of harley previous projects no

00:27:47 of harley previous projects no did you carry out any form of due diligence on harley as a sub contractor no were you aware of harley and ryden's work together on the chalcott's estate

00:27:58 work together on the chalcott's estate in camden

00:28:03 in camden i think i would have only been aware at the tender phase by the end of the once the tender returns came back so later in the project i don't think i connected them at this point

00:28:15 connected them at this point were you aware that there'd been a fire on the chalcott estate project in 2012 um involving the cladding

00:28:24 cladding can we now go to sea407722 and this is a a revised a draft revised

00:28:35 and this is a a revised a draft revised brief as at june 2013 that you're provided with by apple yards for the grenfell tower project now if we look down the first page

00:28:49 now if we look down the first page um to the heading primary project driver yes can you see there under that heading we have the primary driver for the project

00:28:59 project is value for money in accordance with apple yard's stat you report addendum issued on the 24th of may do you see that there yes

00:29:11 now by this stage it's right isn't it that you knew that acm was likely to be a cheaper option than the original zinc options you'd been considering yes but was zinc still your preferred

00:29:24 yes but was zinc still your preferred cladding option it was and i believed we were

00:29:32 steered towards that by the planners as well yeah was that a solid zinc panel or a zinc composite panel that was your preferred cladding option at this point can you remember i think at this point we were unclear

00:29:44 i think at this point we were unclear how we would achieve it still whether it would be a composite or some other folded because you can fold zinc in a number of

00:29:55 because you can fold zinc in a number of ways to to use it as a crowding yeah now can we go to sca402067

00:30:13 now i think it's right correct me if i'm wrong this is a proposed cladding materials project brief

00:30:19 brief that studioe prepared for councillor fielding melon in july 2013 is that right i think i prepared this following a meeting

00:30:30 following a meeting with councillor field and millen right and

00:30:33 and i see some after the meeting with him looking at the dates i think i have to conclude i did it after yeah and it was summarizing what we discussed

00:30:44 and it was summarizing what we discussed and it was you that prepared this document did you yes yeah and on on page four it's got a picture of some acm panels

00:30:56 it's got a picture of some acm panels yeah in the top right uh picture we see um

00:31:00 um it says an acm a polyethylene core with two outer skins of aluminium it's both light and strong do you see that there yes so as at this stage did you understand the difference between a polyethylene

00:31:12 the difference between a polyethylene core

00:31:13 core and other types of core um including fr cores

00:31:20 at this stage no i obviously we went on to specify something with a honeycomb call yeah

00:31:29 now you'd previously proposed we saw that the vm zinc composite panels with an fr fire resistance core

00:31:40 is it that just nobody thought about proposing the equivalent type of acm panel at this point

00:31:55 this was a discussion on finishes and appearance i see it not on and yeah i mean there's nothing here um the the examples below the euromax is

00:32:06 um the the examples below the euromax is is just a coated coil of aluminium without a core all we're looking at is the

00:32:14 the appearance yeah so this briefing note didn't look at anything to do with fire performance it wasn't you know so now going forward in 2013 we know

00:32:25 so now going forward in 2013 we know that you've provided a a revised stage d report on the 20th of august 2013 for the transcript that's at sca408052

00:32:38 let's just have a quick look at that so let's go to um a reference tmo one triple zero three three one zero

00:32:49 this is that stage d report of august 2013 and

00:32:52 2013 and within that can we go to page 21

00:32:58 where we've got a section 4.4 headed design approach facade and then at 22 at page 22 we can see

00:33:09 at page 22 we can see that you're still proposing a zinc composite rain screen panel which appears to be the rinsing panel that's being suggested here do you see on the right hand column at the top it talks

00:33:20 right hand column at the top it talks about a zinc composite rain screen cutting is proposed to the upper levels and then it talks about the advantages of zinc and at the bottom we have some images including of the

00:33:32 we have some images including of the rhine zinc and then you've got figure 28 rinsing natural and pre-patinated colors do you see that there

00:33:41 yes yes yeah now just pausing here and just looking at that rhine zinc bracelet you've got a picture of we find that

00:33:49 that at sea 3014616 at page 37.

00:34:04 so this is the the ryan zinc or some reinstinct information that you appear to have at the time um and can we go on within to page 41

00:34:19 and we can see that rhine's ink is non-combustible if we look at the right hand column under 1.2 the material properties at the end of that list you can see it says

00:34:30 that list you can see it says non-combustible do you see that there yes did that play any um or did that factor into your decision to select that panel at that time to put in

00:34:41 select that panel at that time to put in the stage d report that it was non-combustible no no was it appearance that had largely led to it being in the stage d report

00:34:54 being in the stage d report the preference for for zinc was yes its appearance but it's also its enduring appearance its it's longevity as material yeah now going back to the stage d

00:35:06 yeah now going back to the stage d report we can go back to that tmo one triple zero three three one zero at page twenty six

00:35:17 three three one zero at page twenty six it it said in the stage d report it had this page

00:35:21 this page headed alternative cladding options which may be considered do you see that in the middle yes and what we can see is various images there of

00:35:30 there of aluminium in the top middle figure 40 aluminium cassette rain screen aluminium composite rain screen below that

00:35:40 that do you see those there yes so they're being shown as alternative cladding options

00:35:48 and as we looked at previously issue one of x over's outline fire safety strategy was also included as appendix d to this stage d report

00:35:59 stage d report did you ever bring to x over's attention the specific cladding materials that you were considering in this report

00:36:07 i can't recall doing so no yeah can we also go to page 27 of this stage d report there we can see that there's

00:36:18 report there we can see that there's something called an architect risk assessment schedule do you see that there

00:36:25 this isn't stage d yes yes it is it was part of the stage d report so at this stage i and obviously later there's more conversations with xover but at this stage

00:36:36 but at this stage we we only commenced our serious engagement with terry around this point and that was all to do with the changes at the lower level which you covered with him

00:36:47 with him we're in august 2013 so he's delivered his issue one of the fire strategy back in

00:36:52 in october 2012. yeah um can just can we just focus on this architect's risk assessment schedule here um and look over at page

00:37:04 schedule here um and look over at page 28

00:37:05 28 because it goes on into page 28.

00:37:10 so that's the totality of the table we see at this stage would you agree that this is a fairly general list with little product specific risks

00:37:22 with little product specific risks identified very little project specific risks

00:37:25 risks identified um i wouldn't i wouldn't concede that straight off no i think this would have been prepared specifically for this report

00:37:37 specifically for this report or for for this project

00:37:41 because so many of them deal with with the

00:37:45 the working at height they may risks that would

00:37:49 would sit with the contractor they they may seem generic

00:37:55 can we look um i think back can we go back one page to the start of it yeah so the very first line under

00:38:07 yeah so the very first line under general

00:38:08 general it says zero zero a fire risks during work

00:38:13 work do you see that there yeah and then you've got some risk factors but then you haven't got any information there in the right hand columns do you see that

00:38:24 yes that virus during works specifically refers to a fire occurring during the work i see

00:38:36 what were the specific fire risks that were identified at this stage

00:38:44 were there any specific fire risks that were identified on this particular project

00:38:49 project i i would be looking to exert to clarify those um sorry obviously as part of a refurbishment within our within an occupied building

00:39:00 within our within an occupied building that there are very real issues around

00:39:07 machinery and work and what about as part of the cdm the construction design and management process were you looking to x over for assistance there with fire risks or with studio e looking at them themselves

00:39:24 the cdm obviously relates to design our our this is our cdm risk schedule yeah

00:39:32 yeah risk assessment we have flagged up the obvious that during the works there is a risk of fire right occurring as part of the works

00:39:44 as a more general comment on all of these headings these seem to be very generic headings and the only project specific item we can see it's

00:39:53 see it's if you go over the page again at page 28 item 14a

00:40:01 you can see there it talks about clearing of new external cladding cleaning of extern new external cladding windows and you've got an action taken at the design

00:40:13 you've got an action taken at the design stage horizontal tilt and turn units with key operator restrictor will now be fitted so

00:40:19 fitted so you've got something specific about the project there but otherwise it does seem to be a very generic list would you accept that at this stage no the cdm is is obviously

00:40:31 no the cdm is is obviously all-encompassing but as designers your your

00:40:36 your the cdm is encouraging you to think of the risk to the operatives during the work

00:40:44 work and and they're after the maintenance that's that's my that was my understanding of the focus of the cdm did you understand it could be more broad than that and look at absolutely the risk to

00:40:55 and look at absolutely the risk to anybody in that building absolutely but that that goes in a sense um without saying the the

00:41:07 um without saying the the my understanding of the introduction of the cdm was

00:41:12 focused on health and safety on site specifically construction and especially maintenance so that you didn't design yourself or a future maintenance operative a problem yeah

00:41:24 problem yeah okay yeah can you recall whether artelia had any role as cdm coordinator in the preparation of this

00:41:35 in the preparation of this schedule or this bit of the report designers would all prepare risk assessments on their own and the cdm coordinator would coordinate them and

00:41:45 them and receive them and i think the cdm coordinator did include a solution in this report right did artelia ever ask you for a more detailed design risk assessment

00:41:57 detailed design risk assessment including in respect of the over cladding

00:42:00 cladding no

00:42:08 now um i now want to consider the contact that you had with harley prior to or around stage e of the project um so

00:42:20 of the project um so by this stage we know that studio e was in contact with harley we've seen some of that

00:42:24 of that let's look at some further correspondence if we can go to sca four zeros 8375

00:42:39 so this is an email from you to mr harris at harley on the 11th of september 2013 and you say dear mark the grenfell project

00:42:48 project is moving again and i would like to arrange a meeting with you or someone from harley to discuss options costs and technical details this is integral to us de-risking the project

00:42:59 is integral to us de-risking the project which will be tended sometime in november

00:43:02 november we're not the easiest place to get to so i'm happy to travel many thanks bruce do you see that there yeah so you've asked to meet to discuss options costs and technical details and then what did you mean by the phrase

00:43:15 and then what did you mean by the phrase this is integral to us d risking the project what did that mean

00:43:21 i think i've said a few times that the

00:43:26 challenge of undertaking such a significant refurb and particularly overclouding on an occupied building

00:43:36 was something new to us and to understand any impacts on the client on the program on the cost

00:43:49 on the client on the program on the cost it wasn't it was important for us to try and understand how their component would interface yeah with a whole so

00:44:02 yeah with a whole so cp hadn't been able to give us that type of

00:44:06 of insight so it made sense to approach a specialist subcontractor yep now can we look at another email you send a little bit later in september to

00:44:17 send a little bit later in september to mark harris this is a har three zeros one zero two three three and i want to look at the bottom of the page

00:44:33 is there an email at the bottom of that yes that is the bottom of the page sorry so this is an email from you to mark harris 25th september sorry for the delay in getting back to you can we meet halfway in tower bridge

00:44:45 you can we meet halfway in tower bridge or victoria first thing on friday a coffee shop perhaps it would be fine for you to meet thomas alone but i would prefer to be there with two projects at critical junctions my weeks are beginning being rapidly consumed by meetings etc

00:44:57 being rapidly consumed by meetings etc and then you say we have and we have a full set of ers to prepare for end of october is that employers requirements yes yeah so you wanted harley's input into the

00:45:09 so you wanted harley's input into the specification uh prior to preparing the employer's requirements is that correct i think i'm referring to a different project i see which project was that

00:45:22 i see which project was that well the ers for grenfell were prepared end of november beginning of december right

00:45:29 right and i haven't checked but that is likely to refer to um the heston leisure center that i was working on i see and you were seeking harley's assistance in relation to that leisure

00:45:40 assistance in relation to that leisure center as well no um it was that project which initially

00:45:44 initially got me in touch with jason tisbury from cgl

00:45:48 cgl right which in turn led me on to harley no harley had no input on the other project i'm just referring to the fact that i'm focusing on the deadline on another project oh i see

00:46:00 project oh i see so that's just to explain that your weeks are becoming rapidly consumed was it

00:46:04 it a meeting yeah okay

00:46:08 did it occur to you that harley might ultimately end up in the supply chain for this project in terms of being the cladding subcontractor

00:46:21 i wouldn't have said likely no i'd definitely not likely obviously it was a possibility

00:46:29 your phrase de-risking might that have also been a reference to needing to produce a very clear and tightly framed specification so that the eventual contractor had less

00:46:40 so that the eventual contractor had less discretion to provide what it wanted and you had control over the spec for the cladding

00:46:50 so could you rephrase it yeah when when you refer to de-risking the project might you also have been referring to how specific you wanted the specification for the cladding to be

00:47:01 specification for the cladding to be so that you had control over what the product would be that's some that's something completely different to trying to de-risk project i'm sorry fair enough no i'm just asking

00:47:13 i'm sorry fair enough no i'm just asking um you then met with harley we know on the 27th of september 2013 at uh hayes galleria this is referred to as the hayes galleria meeting we looked at

00:47:24 the hayes galleria meeting we looked at it this morning in the context of insulation can we go to sca408790

00:47:39 can we go to sca408790 and what you've done in this email it's from you to philip booth peter madison tmo booth artelia um claire williams the tmo

00:47:52 booth artelia um claire williams the tmo and then someone from max ford and matt smith as well um is what you've done is you've given a summary of the meeting you've had with harley

00:48:01 harley after which you've sent to these parties um and you say we met with harley curtinwall this morning to discuss the project

00:48:09 project they are very keen and have been tracking the project for some time they are specialists in this type of project they pointed to ferrier point as being a very similar to grenfell although it's triple grazed

00:48:21 to grenfell although it's triple grazed and super insulated we had forwarded them sample details and the elevation measure beforehand and then you say this at the first sub-paragraph they're back of a packet budget

00:48:33 they're back of a packet budget based on the areas is around 3 million of which would include 250 k for the mast climbers and zinc rain screen cassettes

00:48:44 screen cassettes this equates to 18 over our stage d budget of 2.3 million assuming access costs fall under preliminaries do you see that there yes um

00:48:57 yes um so there you can see they're very rough estimate

00:49:00 estimate for uh installing the zinc rain screen cassettes they say in the middle do you see that there yes um and is that the estimated cost of

00:49:11 yes um and is that the estimated cost of installing the whole facade as you understood it yes um i guess it's open to interpretation what that meant but yeah

00:49:22 what that meant but yeah yes okay and then point two if we can read that their recurring experience is that budgets force clients to adopt the cheapest cladding option aluminium composite material

00:49:34 option aluminium composite material acm face fixed we have offered to forward a more detailed take off so they can provide a more accurate budget a zinc composite panel is also available which is cheaper to install than a

00:49:45 which is cheaper to install than a cassette

00:49:47 cassette do you see that there yes so at that meeting with um harley had you gained the impression that they had a preference for using acm i

00:49:58 acm i know that that explicit um preference came later i i don't think that was communicated this meeting it was

00:50:10 it was an opportunity for for me to ask questions to understand how they go about what they do i see but they had told you that their recurring experience was that budgets forced clients to adopt the cheapest

00:50:22 forced clients to adopt the cheapest cladding option yes but they didn't they didn't express any preference from their point of view about whether acm not well obviously mark harris's email

00:50:33 not well obviously mark harris's email subsequently states that but i don't recall that at this meeting i see yeah did the fact that it was the cheapest material ever caused you at this stage to

00:50:44 ever caused you at this stage to question whether it sacrificed performance in the interest of price

00:50:50 um well in my opinion it did because the the coating on the acm is

00:51:01 the coating on the acm is 40 micron it's

00:51:05 it doesn't last forever and it's subject to

00:51:08 to scuffing and scratches so your your appearance is not comparable to zinc in my opinion and it's durability not comparable

00:51:19 comparable not comparable it's aesthetic durability i think the panel itself is aluminium which is not going to corrode but its appearance will degrade did you think about

00:51:31 degrade did you think about um its fire performance and whether it might be sacrificing fire performance in the interest of price no i think

00:51:40 now you say in paragraph 207 of your statement that cep once said something similar about budgets forcing clients to adopt the cheapest cladding

00:51:51 clients to adopt the cheapest cladding options

00:51:53 options can you recall who said that to you from cep and

00:51:56 cep and and when that was said i only met jeff blades from cep and it would have been right at the very beginning of the project either a conversation impersonal and probably wasn't person but so you have a

00:52:09 probably wasn't person but so you have a clear recollection of that being said by mr blades to you it's in my statement i believe i did i'm sorry

00:52:16 sorry i think so yes

00:52:20 now you say at the end um of this email if we look at the very last sentence at the bottom of this page you say you've also approached panel tech who are preparing budget costs

00:52:34 and you've described in your witness statements your interaction with panel tech at paragraph 268 of your statement and you say there that you don't recall

00:52:45 and you say there that you don't recall if they ever provided you with any costs um is it fair to say that the only input on cost that you ever had was from harley

00:53:01 ever had was from harley yes although i think there was some communication between sig and harley between sig and harley yes at this point

00:53:14 between sig and harley yes at this point okay yeah we may come to that in a moment

00:53:18 moment um can we go now to sca408809 just sorry i can point out we're not the quantity surveyors so we

00:53:31 we're not the quantity surveyors so we were

00:53:32 were doing this off our own back yeah it's not for us to price price the project we were just helping

00:53:41 helping assisting as far as possible to get a as precise

00:53:44 precise cost advance of a tender because you knew your client was having issues about the budget and there was a suggestion that the cladding was an area where you needed to find

00:53:55 find savings yes and it was a risk item as i thought yes it's a difficult thing to put a

00:54:02 to put a a rate against because of the complexity involved

00:54:06 involved okay

00:54:09 so can we go then to sca408809 and um we can see from this email that you inform harley on the same day this is the 27th of september 2013 to mark

00:54:22 is the 27th of september 2013 to mark harris

00:54:23 harris copying and ray bailey of harley and thomas wreck within studio e and you say dear mark ray thank you very much for the conversation this morning it was very useful and i'm especially grateful you could

00:54:34 and i'm especially grateful you could come into london we will follow up early next week with the quantity takeoff from our model i've communicated your back of a packet figure to the qs and it is over budget which is to be

00:54:45 and it is over budget which is to be expected but some firmer budgets will help focus everyone's minds do you see that there yeah and then you say we're looking seriously at ned zink's composite panel the small

00:54:57 ned zink's composite panel the small sample we have in the office looks like a luca bond but is apparently zinc do you see that there yes and then if we can go on to sca408985

00:55:19 on the 4th of october you send another email to mark harris

00:55:25 and in the third paragraph you say this the client's response to your budget was what about aluminium we haven't had samples or costs back from nedsing

00:55:36 samples or costs back from nedsing but this could be ideal if it eliminates the need for fabricated trays and is true zinc and then you've got a link to the

00:55:43 the ned sink and we see that it's a ned zinc nova

00:55:46 nova composite panel from the title and then you say we're looking at ali planck's trays to the lower four floors and you ask would it be possible to come

00:55:57 and you ask would it be possible to come back with budget costs or what would the material cost uplift be

00:56:02 be for a nova composite versus a metallic faux zinc

00:56:06 faux zinc raynabon panel do you see all that yeah

00:56:11 um so you're suggesting there in that first paragraph i read that the ned zinc composite panel could be ideal you're saying um

00:56:22 you're saying um so is it right that your strong preference at this stage was still for zinc but it would appear to be a zinc composite panel you're referring to there

00:56:34 um i think i think i'm again expressing a preference for true zinc i see

00:56:45 true zinc i see so um

00:56:48 the ned zinc nova composite was your understanding that that was a

00:56:54 i haven't really a holy zinc panel i can't remember what that panel was it might have had aluminium on one side and zinc on the other okay yeah and you've asked harley in

00:57:05 okay yeah and you've asked harley in that last paragraph to come back with budget costs um what would the material cost uplift be

00:57:13 be for a nova composite versus a metallic faux zinc rainer bomb panel so were you actually asking for a quotation for the ned zinc nova panel is that what you were looking for from

00:57:24 that what you were looking for from harley

00:57:24 harley not a quotation i'm just an indication of a budget yeah okay so budget costs for that

00:57:33 and that the fosing the metal faux zinc rainer bomb panel you're referring to was that an acm panel yes that would have been

00:57:41 have been a panel that debbie french presented um yeah a year before no no that was in six months or so before

00:57:53 before and then let's look at harley's response next so harley respond with some um budget costs on the 18th of october 2013. if we can go to that email

00:58:04 october 2013. if we can go to that email that's at har 40s one five and it's at the bottom of that page

00:58:16 so if we can that's good yeah so 18th of october 2013 mark harris to you

00:58:24 you and he says hi brees apologies for the delayed response things have been a bit hectic in the past few weeks and he says that we've put a budget spreadsheet together which is based on using the rayna raynabon natural

00:58:35 using the rayna raynabon natural zinc product fabricated into cassettes as a starting point and then he says we've included three other options on the bottom of the attached spreadsheet showing the effect on the

00:58:47 spreadsheet showing the effect on the overall budget if we were to consider face fix natural zinc and then going to a standard aluminium acm in both cassette and face fixed

00:58:56 fixed do you see that there yeah and he says the most expensive expensive option is obviously the natural zinc cassettes and then he says if standard acm was to be considered in a zinc color face fixed

00:59:08 be considered in a zinc color face fixed the saving could potentially be over 500 000

00:59:14 500 000 and then he says as said when we met we have a number of examples of high-rise residential blocks in london where standard aluminium face fix acm was used

00:59:24 was used we can forward some photo images or arrange the site visit as and when required

00:59:30 required so do you see all that there yeah

00:59:36 and just to be clear did you ever take up his offer of a site visit to see some other

00:59:40 other blocks clad in acm no no i didn't then can we look at the budget cost document that harley attached this is at sea

00:59:48 sea four zeros two two seven five

01:00:02 and we can see on page one here that they've provided costs for the rainer bond zinc cassette rain screen cladding do you see that there

01:00:14 there underneath insulated render you've got raina bronzing cassette rain screen cladding

01:00:20 cladding final screen crown and then rayna bond zinc rain screen panel cladding and insulation do you see that there the next one so the third item down

01:00:35 third one down yes yeah rainer bronze zinc rain screen spandrel cladding and insulation and he's quoted a price of 315 pounds per meter squared

01:00:50 so we see that there and then on page three what they've done so that's the the main budget cost they provided for you for the cassette rain screens inc

01:01:02 the cassette rain screens inc and then if we go over the page they've just given you some line items for alternative options for cladding do you see that yes

01:01:14 and yes on page three exactly so we can see those there now they don't seem to have provided you with a quote for the ned zinc nova

01:01:26 with a quote for the ned zinc nova composite

01:01:26 composite panel that you had asked them about did that seem strange to you at the time that you didn't have a quote for that panel

01:01:34 panel sorry not a quote but a budget cost

01:01:40 no it didn't it didn't occur to me and

01:01:45 not subsequently either and i can't remember exactly what where that investigation went with the nova products i i think it moved towards the kme which

01:01:58 i i think it moved towards the kme which is what we have yeah specified yeah now um just going back to page one and just looking through the budget we noted that they've quoted you there a

01:02:10 we noted that they've quoted you there a price of

01:02:11 price of a rate sorry of 315 pounds and i put to you that was per square meter is that correct is that how you understood how i

01:02:22 is that how you understood how i understood it yeah and we also see the same price lower down for the rayna bond zinc column casings and insulation you can see

01:02:31 see four lines up from the bottom the same figure of 315 appears under the rate do you see that there yes

01:02:39 there yes and then as we saw on page three you just got the global figures for the three different types of rayna bond acm panels

01:02:49 panels now if we can go to page two of the quote

01:02:56 we can see at the end of it it's got a paragraph five exclusions do you see that at the bottom of the page yeah and

01:03:08 yeah and if you look four lines up from the bottom it says no allowance for fire rated products do you see that there yes now you've said in your statement that you don't recall whether you noticed this

01:03:19 noticed this at the time and does that remain your your evidence that you you can't remember whether you noted that at the time

01:03:28 time yes i would have passed this on and almost immediately to apple yachts because that was its primary

01:03:36 primary purpose so you didn't scrutinize in detail these exclusions no because this this was really just for the sake of budgeting yeah i understand had you noticed it

01:03:49 yeah i understand had you noticed it would you have queried it with harley

01:03:56 um

01:04:00 this page is quite detailed um if i'd picked up that i would have picked up all the other details as well yeah

01:04:07 yeah okay so that wasn't that wasn't our um agenda that wasn't what we were looking to do at this point

01:04:19 what we were looking to do at this point by this time were you still unaware that that fire-rated products were available in relation to these cladding options

01:04:29 no i think i know i think i don't recall when i first became aware but i first time

01:04:40 but i first time i think i might have come across it was when the um bba certificate was circulated right but i don't recall at that stage either being aware of it

01:04:52 at that stage either being aware of it i see so you weren't aware at this stage and you don't think you were aware when there's even if you were to glance at that it's not clear what products are referred to

01:05:06 okay but it's a more general question of whether you were aware that fire rated or fire resistant fr panels were available for some of

01:05:17 fr panels were available for some of these cladding options were you aware of that at this time all right i think i do state in my witness statement that the topic of the core was never discussed yeah now let's just go to your response

01:05:31 yeah now let's just go to your response then to mr harris this is a sea four zeros nine two three seven

01:05:46 so this is on the 18th of october back to mark harris and you say in the first line thank you for the spreadsheet very useful indeed and then you say this the raynabon

01:05:57 and then you say this the raynabon natural zinc is vm zinc quartz which we discussed i don't think it's an option do you see that there yeah and so that was one of the alternatives that they'd put

01:06:08 they'd put uh in there in the build-up um to that sheet um can you explain why that wasn't an option why did you not think that was an option

01:06:19 not think that was an option it was aesthetic was it that it was too dark is that right yeah in appearance yes we we had even as some

01:06:31 it was almost a year before that um been given a steer that the building needed lifting and a dark product wouldn't wouldn't do

01:06:44 that yeah and then you say could you give i think you mean an indication that premium would have to pay for the nedsync datasheet attached versus

01:06:55 nedsync datasheet attached versus standard acm i'm worried your standard is white and entirely unfeasible we've received the following guidance from paul cousins at six zinc and copper

01:07:06 six zinc and copper and then you set out the guidance you've had from sig in that email is that correct and you've got a proteus hr ned zinc panel 130 to 180 meters per

01:07:18 ned zinc panel 130 to 180 meters per squared

01:07:19 squared ned zinc nova composite 90 to 150 netting interlocking panel so you were asking again about the ned zinc panels aren't you in this email

01:07:30 aren't you in this email and you say there then a face fixed solution would be acceptable so i hope we would

01:07:34 we would be at the low end 90 pounds per meter squared

01:07:39 squared do you see that there yes now just picking it up at this stage can we look at paragraph 277 of your witness statement this is a sea

01:07:50 three three zeroes one four two seven three

01:07:54 three 115 to 116 and i want to read just the end

01:07:57 end of well let's just read that whole paragraph you say at the bottom of 515 the same day i emailed mark harris harley and thanked him for the useful spreadsheet so that's

01:08:09 him for the useful spreadsheet so that's the email we were just looking at i asked for him to provide a quote for the nedsync nova composite i now note the product sheet i attached said it had an ldpe core

01:08:21 i attached said it had an ldpe core although at the time i would not have spent time analyzing the data sheet and i had no experience with pe composites do you see that there yes

01:08:32 now what did you understand the ldpe core to be referring to i don't recall reading it at the time right but you've noted it i see so

01:08:43 right but you've noted it i see so you're noting it since in your statement

01:08:49 now you say there that you wouldn't have spent any time analyzing the data sheet because you had no experience with pe composites well i had no experience yeah

01:09:00 composites well i had no experience yeah but it's right isn't it that this was a product which you were actively seeking some prices for and you were actually considering specifying is that right the nedsync nova composite

01:09:12 nedsync nova composite yes you're looking closely at that panel we were yes

01:09:18 but um thomas was engaged in most of the discussion with um sig and i

01:09:30 um sig and i i can't recall why the ned zinc products went away cool well we'll move kind of through the the chronology and but the point i want to put to you

01:09:43 and but the point i want to put to you is given you were seriously considering that panel would you accept that it was necessary to check that there was nothing in the data sheet which rendered it unsuitable for the grenfell tower

01:09:56 yes we did yes would we check if we were going to specify we would ask the question directly and check yes who would you ask the question of

01:10:08 question of the supplier i see so you would ask them is this suitable to be used yes on our project

01:10:14 project yes and you would expect them to be able to give a view on compliance with the building regulations

01:10:26 i would expect them to have a view on it yes i see

01:10:30 yes i see but you wouldn't expect to do your own research on on that panel at this stage and its compliance

01:10:43 because there was no um knowledge of the hazard it would not whereas if it was a timber product you would think of it

01:10:55 would think of it but i had no knowledge of any hazard with

01:10:58 with acm as i said i've been aware of it for my entire career i'd never heard of it presenting a hazard and i'd seen it use whatever

01:11:11 now we know and we saw it a little bit um earlier that around this time you were also seeking quotes from the company called sig sig and they're a supplier rather than

01:11:22 sig and they're a supplier rather than an

01:11:22 an installer is that correct yes yeah can we just look at what you say about that at paragraph 282 of your statement this is

01:11:29 this is sca 3014273 at page 117

01:11:37 in the second sentence what you've done there is is summarize the rates that sig gave you

01:11:43 gave you for the proteus hr panel the ned zinc nova composite and the nedzing interlocking panel we saw that earlier

01:11:52 earlier and and can we actually now look at the the quote from sig this is a sca 409019

01:12:04 and it's at the bottom of page one and into page two so this is paul cousins from sig on the 9th of october 2013 emailing thomas wreck um you're not copied in here um

01:12:17 um you're not copied in here um and he says hi thomas with reference to the above mentioned project i've spoken to kme

01:12:24 um who were kme

01:12:30 um i think they were fabricators yeah were they called kme architectural solutions

01:12:40 solutions is that right

01:12:44 i i yes okay i discovered that we were in possession of

01:12:51 of some drawings of this in that binder discovered last year yeah which i think actually go back to 2012.

01:13:02 which i think actually go back to 2012. okay um

01:13:05 okay um so just to carry on he said i've spoken to kma about their proteus hr panel which i believe is the most suitable for this application as the panel construction will offer a very high level of flatness and

01:13:16 very high level of flatness and stability

01:13:17 stability and then if we go over the page

01:13:22 he says there are two other options ned zinc nova composite and the interlocking panels

01:13:27 panels and then he talks about a wind loading study and then you get the the prices and he says i can only provide panel prices only an installed price can be obtained from

01:13:38 an installed price can be obtained from a facade contractor and you've got the three prices there yeah and he says their supply only etc so was it the case that the proteus hr

01:13:50 so was it the case that the proteus hr panel was being suggested as being used with

01:13:53 with ned zinc flat sheets is that was that your understanding i think so and is it right that the proteus

01:14:01 proteus hr is a honeycomb panel which can be used with different types of metal outer sheets

01:14:08 sheets was that your understanding i'll be honest at the time i was unaware of it in context of the zinc finish

01:14:19 i see so you're only thinking about the zinc finish not about the the center of the panel

01:14:27 now you asked if it could be used with multiple um finishes but my understanding at the time was specifically a zinc system with an aluminium honeycomb

01:14:38 system with an aluminium honeycomb to provide stiffness i see yeah

01:14:44 now um we can see that they're saying it's a panel only quote for the proteus hr that's 130 to 180 meters squared um and you referred in your statement to

01:14:57 um and you referred in your statement to mr cousins advice that the proteus hr was the most suitable for this application and he says as it will offer a very high level of flatness and stability that's what we saw on the previous page

01:15:09 what we saw on the previous page and did this advice and and the cost that they were giving you give you confidence that zinc would be achievable within the budget the tmo had given you

01:15:27 i i don't think there was enough information to be to derive any confidence it was just information

01:15:36 okay now um i want to look at a little bit more

01:15:41 more um some communication between sig and thomas wreck so if we can go to sca four zeros nine four three seven

01:15:58 and he's seeking um quotes thomas rex seeking quotes from sig for zinc panels and if we go to the bottom of the email chain on page two

01:16:13 yeah sorry this is it 1831 on the 24th of october 2013 the next email chain up at the bottom of page one

01:16:32 and this is thomas wreck to simon walker afternoon simon with regards to the new rain screen cladding we are liaising with mark harris from harley

01:16:43 with mark harris from harley who are envelope installers you can find his details below do you see that there yeah

01:16:49 yeah and i think um in the next email up

01:16:59 no actually sorry can we go to the back to the top of page two

01:17:09 yes so there he says mark is putting together a quote for the whole envelope element of the job and would like to precise their quote based on your rates so when ready to send your quote across

01:17:21 so when ready to send your quote across to us can you please address it to mark as well is that mark from harley mark harrison so you seem to be saying to sig uh

01:17:33 so you seem to be saying to sig uh can they work with harley sorry thomas rex seems to be saying to sick can they work with harley on a quote for the whole of the envelope element of the job yes yes

01:17:47 and then at the very top of page one sig confirm

01:17:52 that um they say thomas matthew irving of kme

01:17:55 of kme architectural solutions has made contact with mark and will provide budgets to harley next week do you see that so that seems to be kme architectural solutions confirming that they will provide

01:18:06 they will provide harley with a price for the panels to enable harley to look at a quote for the whole of the job does that make sense it does i'm sorry i'm not connecting the

01:18:17 it does i'm sorry i'm not connecting the previous email where i provided rates to harley

01:18:23 where i think was a day or two before yes i think that's right

01:18:31 now can we go to another email har405996

01:18:45 this is another email of the 25th of october 2013. it's an internal harley email

01:18:56 can we just zoom in on the top i want to look right at the top of the page the top email

01:19:01 top email yes thank you so this was an email from mark harris to ray bailey on the 25th of october 2013. and but with reference to the exchanges that we were just talking about

01:19:14 that we were just talking about he says to ray bailey for your information for fyi and then he said looks like our old mates at studio e are now referring all manufacturers to us on grenfell

01:19:25 us on grenfell can't be bad and then might need rebecca to get rebecca to knock up a sketchbook model before too long do you see that there now i'm not suggesting you saw this

01:19:36 suggesting you saw this at the time but they're referring to you there as your their old mates studio e can you explain do you know why they might have been referring to you as old mates

01:19:49 referring to you as old mates um

01:19:56 i'd take its tone to be a bit of a ribbing tone

01:20:00 it's a bit ribbing he's

01:20:06 i mean he seems to be pleased that um

01:20:11 referring manufacturers to them so but but the old mates i mean i think you've made clear you'd never work with harley before on a other project no i don't believe anyone in the team

01:20:23 no i don't believe anyone in the team had either okay mr chairman that might be a good moment for a break yes um well we're going to have another break now mr sums we have to have these

01:20:36 break now mr sums we have to have these breaks every now and then we'll resume but have a reasonable amount of time had you at this stage um no i think it's i mean kind of if we start at maybe 25 past that okay

01:20:49 if we start at maybe 25 past that okay yeah long enough we'll resume it 25 past three so if you go the usher please and remember not to talk to anyone about your evidence yes thank you very much

01:21:09 right 25 past please thank you

01:26:11 [Applause]

01:26:27 [Music]

01:31:43 [Applause]

01:34:17 [Music]

01:38:04 [Music]

01:38:28 [Music]

01:39:05 yes would you ask mr sentence to come back please okay

01:39:14 all right happy to carry on mr sent yes very good yes yes yes thank you so we were at the end of october 2013 and i now want to look at some emails exchanged in november 13. so

01:39:25 some emails exchanged in november 13. so if we go to sca

01:39:28 409736

01:39:38 so this is mark harris of harley 7th of november 2013 to thomas wreck you're copied in there um and he said good morning thomas a

01:39:50 and he said good morning thomas a response has been received at last from kme

01:39:53 kme although i'm not sure it tells us a great deal and then he says all that's been provided is a base meter square rate for panel only

01:40:01 only excluding works he says that must have taken

01:40:05 taken all of ten minutes to think about so quite why it's taken them two weeks to provide it it's a mystery to me and then all i've been able to do with this extremely limited information is take a best guess at wastage transport and support rail

01:40:18 at wastage transport and support rail costs

01:40:19 costs and then input into our spreadsheet to give an end figure on the wall and he says then the result was proteus hr composite 282 pounds per meter squared do you see

01:40:30 282 pounds per meter squared do you see that there yes and he reiterates in the next paragraph quite what that finish is based on i've no idea due to lack of information um so just pausing there for a moment

01:40:42 um so just pausing there for a moment that the quote that harley gives of 282 meters pounds per meter squared is more expensive than the supply only price given by

01:40:53 price given by sig they'd said 130 to 180 meters squared

01:40:59 squared and and is that but because the the sig price was the supply only panel price

01:41:06 price whereas harley have tried to give you the price

01:41:09 the price for the whole installation and the the associated works is that correct that's how i understood it yeah and then can we look at the next paragraph in mark harris's email he then says

01:41:21 in mark harris's email he then says um

01:41:26 just picking up in the second sentence of that last main para i have to say from a highly selfish point of view our preference would be to use acm it's tried and tested

01:41:37 tried and tested on many harley projects and we are confident in the cost base that said we are of course an envelope contractor and we'd be happy to cloud the build

01:41:47 the build in the material of choice do you see that there yes so at this point did you understand harley to be expressing a strong preference for acm

01:42:04 strong preference it's a preference and the basis of that preference is that it's tried and tested in other words they're familiar with it

01:42:13 and confidence in its cost place now i'm sorry i'm volunteering a lot here but i think i think i understand your question it's how you understood it

01:42:24 your question it's how you understood it really did you understand harley to be expressing a i'd say a strong preference for acm but if you think it's just not a strong preference it's a preference and what contractors like is

01:42:35 contractors like is is reliability so that their supply chain does not um cause them problems on site in delivering materials

01:42:46 delivering materials in a timely fashion or at costs that are greater than what they anticipated so i i interpret that as being there behind the basis for preference of acm i

01:42:57 behind the basis for preference of acm i see

01:42:58 see did you feel in general at this time that harley was trying to encourage you towards the use of acm on the project

01:43:08 no i don't think that's an inc i don't think that's in any way trying to encourage us

01:43:13 given harley's preference as expressed in this email did you ever think about going to another subcontractor to get uh some quotes for the installation of either the proteus

01:43:24 either the proteus hr or the ned zinc nova composite panels

01:43:32 this wasn't tender this was um just research for the sake of establishing

01:43:43 establishing started out researching the viability in it

01:43:47 it its subsequent correspondence is focused a lot on cost but that wasn't why we started out i see so no it didn't occur to try and duplicate that exercise with yet another

01:44:00 duplicate that exercise with yet another subcontractor okay can we then go to sca40976 this is an email from you to harley of the 7th of november

01:44:13 and you say in the first paragraph mark thank you for your response we share your concerns about the reliability of the proposed panel source but we set out to do zinc and budget permitting it will be a

01:44:24 zinc and budget permitting it will be a fantastic result we're challenged to achieve a natural non-coated cladding look do you see that there yes and then in the second bullet point you

01:44:38 and then in the second bullet point you say

01:44:38 say um i think i explained when we met that the vm quartz product is an unfortunate dark tone

01:44:44 dark tone it may not be accepted the ned zinc option is much better is the rate you've given us for the km kme

01:44:52 kme net zinc cheaper overall so that's a question you're asking there of him do you see that yes um and then in the third bullet

01:45:06 um and then in the third bullet um you say this the client is going to want to include options in the tender for acm the standard finish is unfortunate plastic croydon planner and then you say

01:45:17 plastic croydon planner and then you say we have some matte satin and high gloss samples in the office please could you indicate appropriate rates for your spreadsheet for different finishes and then you say rayna bond and you're assuming duragloss 5000 and you ask for

01:45:29 assuming duragloss 5000 and you ask for some different finishes and you also refer there to the aluka bond

01:45:35 bond spectra and sakura 917 range at the end of that email do you see that there yes now mark harris then responds to you on the 21st of november 2013. if we can go

01:45:46 the 21st of november 2013. if we can go to that that's sea four zeroes nine nine nine seven

01:46:03 so this is his response to you on the 21st of november 2013 and he starts off high bruce apologies for the delayed response

01:46:10 response only just received a response from rayna bond

01:46:13 bond they were holding out on us because they were originally talking with another company

01:46:17 company and were concerned about maintaining loyalty on the basis that the other company introduced them to the project and then he says once i pointed out how much business we do with rayna bond it focused their attention

01:46:29 focused their attention do you see that now in your statement when you're referring to this email at paragraph 280 you say in your statement that he emailed you to state that he had

01:46:40 that he had only heard back from rayna bond and and highlighted that harley did a lot of business with rayna bond in fact would you agree with me that what he says in the first

01:46:51 what he says in the first lines of his email is that he's only just received a response from rayna bond yes so he's not saying he's only heard from rayna bond just that he's only just received a response from them do you see that

01:47:02 that yes

01:47:05 now was it your impression that he decided not to obtain quotes from other manufacturers because he goes on to

01:47:16 because he goes on to talk about the rainer bond and he gives you

01:47:20 you various quotes for acm standard and cassettes towards the end

01:47:28 he says it adds more or less the same amount to the standard rate [Music]

01:47:33 [Music] i think at this point i understood the room roughly equivalent yes what he doesn't do in this email correct me if i'm wrong is he doesn't give you

01:47:43 give you a quote for the ned zinc the proteus hr panel does he no or the ned zinc

01:47:50 ned zinc composite which she looked at earlier he doesn't give you any quotes for those does he no despite you having asked for that in your earlier email this is dated 21st of november which i

01:48:02 this is dated 21st of november which i think is getting very close to yeah our deadline yeah and as as helpful as it appeared to us this exchange was it we weren't relying on it

01:48:14 exchange was it we weren't relying on it i see

01:48:14 i see okay so you weren't concerned that you didn't have a quote for the preferred panel

01:48:19 panel despite asking more than once for that quote

01:48:22 quote no because we weren't negotiating with with harley they were just providing this input and to assist

01:48:30 to assist the tender would be the proper context for yeah discussing um actual quotes

01:48:38 quotes yeah now the email also refers as we've just seen to harley doing a lot of business with rayna bond at the end of that first paragraph yes once i pointed out how much business we do with rayna bond it focused their

01:48:49 we do with rayna bond it focused their attention

01:48:50 attention so he's telling you about that did you think anything about that statement at the time you received it did you note it did it provoke any particular reaction in you

01:49:05 again i think you're asking if it indicated anything untoward and i don't think it does no okay um there's reference in the third paragraph

01:49:17 there's reference in the third paragraph to ppc

01:49:19 to ppc aluminium cassette cladding you say with with regards to he says with regard to ppc aluminium cassette cladding we've just costed another project of a similar nature and he tells you what the on the wall

01:49:31 and he tells you what the on the wall rate is

01:49:32 rate is do you know what the pcc aluminium cassette cladding refers to do you know what that is polyester powder coated polyester powder coated yeah yeah okay so in other words not an icm now i'm not

01:49:45 so in other words not an icm now i'm not sure what he's referring to right and he gives an on the wall rate for that of 235 pounds per square meter

01:49:56 for that of 235 pounds per square meter including insulation

01:50:00 including rail insulation fixing etcetera now that was substantially cheaper

01:50:04 cheaper than the rate for the rainer bonds inc that harley had quoted in their budget spreadsheet of 315 pounds per meter squared

01:50:12 squared yes and he then gives figures for the acm

01:50:15 acm standard rate both face fixed and cassette at the end of 187 pounds 50 meters per squared and then for the cassettes 232 pounds 50

01:50:28 cassettes 232 pounds 50 per meter squared at the end of the email do you see that yes now let's go to your reply this is a sea three zeros one then

01:50:39 three zeros one then four zeros

01:50:49 and and you you give this response many thanks tenders are due to to be released shortly subject to the client agreeing the documentation we are virtually finished so i think that

01:51:00 virtually finished so i think that is what you were just explaining now that you were running short of time before

01:51:05 before the um tenders were due to be released um had you decided to include the reynabon acm as an option in the tender documentation before mark harris gave you those prices

01:51:17 before mark harris gave you those prices uh on the 21st of november can you recall

01:51:21 recall um i i don't think they're connected actually i think the decision to include the options this in a sense came from the client

01:51:33 from the client asking for an option so it wasn't necessarily on the basis of that cost information that you decided to include the reynabont acm as an alternative in the tender specification

01:51:46 um

01:51:50 i i don't think it's on the basis of the cost of cost information that i use those products and those finishes um in the tender specification though

01:52:02 um in the tender specification though okay

01:52:03 okay yeah and just to be clear at this stage you hadn't carried out any investigations had you into whether the rainer bond acm would comply with the building regulations and approved document b

01:52:14 approved document b no

01:52:18 can you just help me with this the um the drafting of the tender specification was done by studio e was it yes and you had been uh

01:52:29 yes and you had been uh putting at the front of your proposals the zinc cladding did the client actually come to you and say please put the acm isn't in as an alternative or do you recall

01:52:41 in as an alternative or do you recall how it happened there was an email acm to a layperson doesn't mean anything i think there is an email from peter madison

01:52:52 there is an email from peter madison asking for aluminium as an option right so i i think at this point they were used interchangeably yeah but your recollection is that the request to include

01:53:03 include an alternative form of cladding came from the tmo that there is a email to that effect okay thanks and and i had picked it up i mean there was that

01:53:14 mean there was that one of the emails we went to earlier where they said what about aluminium the client fed back could no no another one okay we'll have a look for that um

01:53:26 okay we'll have a look for that um yeah so that was my next question so you've decided to include acm in the specification um and you're saying that's because the tmo wanted it in the specification

01:53:37 the tmo wanted it in the specification well they didn't specifically want acm and this specification they they wanted a um

01:53:48 not necessarily premium product in the specification i see so they wanted they wanted a range and that's how the tinder and i believe the form of tinder was drafted

01:53:59 drafted to ask the tenders to provide options i see so the acm is in there because you knew it was a cheaper cladding option is that right yeah

01:54:11 can we look at paragraph 286 of your witness statement yeah yeah just to add to that um it's very common to negotiate with a contractor that as soon as you're in a um

01:54:25 that as soon as you're in a um a position where where they are favored in other words you've almost committed your ability to negotiate

01:54:33 negotiate cost diminishes so to put in the options up front

01:54:38 up front it was an effort to try and achieve best value on behalf of the client

01:54:45 client so that you are you're inviting in a sense um

01:54:54 requests for proposals you're asking for people to come forward with proposals costed proposals in a competitive situation

01:55:02 situation i see yeah

01:55:08 if we go to paragraph 286 of your statement that's sca3014273 at page 118. you you say that as a result of the

01:55:21 you you say that as a result of the inquiries above studio a prepared the specification for the rain screen cladding

01:55:25 cladding based on the input provided by the special specialist cladding subcontractors it had consulted with

01:55:32 with including harley and then you go on and say using a kme architectural solutions proteus hr honeycomb rain screen panel with the ned zinc nova pre-weather

01:55:43 with the ned zinc nova pre-weather finish manufactured by ned zinc so we've got that there now clearly um the i want to focus on that the words you've used based on the input provided by the specialist cladding

01:55:55 by the specialist cladding subcontractors it had consulted with including harley in the second and third lines now clearly that had included harley

01:56:02 harley but you hadn't actually consulted with another subcontractor other than harley had you

01:56:09 i think via sig we had consulted with kme

01:56:14 kme i believe there was correspondence not not that i was party to but did you understand kme to be a cladding subcontractor

01:56:25 i think they manufactured the products yeah when they're a manufacturer rather than a cladding subcontractor like like harley i believe that's what i

01:56:36 like harley i believe that's what i understood yes

01:56:40 so what i'm putting to you is in fact this the input from the specialist subcontract that you'd had was predominantly pretty much exclusively uh through harley

01:56:49 harley there was the meeting and the the sample we got from penalty yes but you said earlier you couldn't remember whether panel tech actually provided you it with any cost information

01:57:02 information no no they didn't but we did meet with them

01:57:06 them okay and i i we did for a period have a very large sample in the office which i think they provided what i want to put to you is that you asked a

01:57:17 to put to you is that you asked a supplier for quotes and then asked them to liaise with harley um

01:57:21 harley um and that you didn't actually ever test the price

01:57:24 the price against other suppliers or with other subcontractors

01:57:30 not on an informal basis that's the purpose of the tender is to put it out to the market yeah okay let's now look at the nbs

01:57:41 yeah okay let's now look at the nbs specification uh i know we've looked at this a few times but i want to look at it again

01:57:46 it again now so this is sca50169 if we go to page 63 this is the start of h92 which is the rain screen cladding

01:57:58 h92 which is the rain screen cladding section

01:57:59 section and if we look at page 65 at item 120 and we zoom in at the top of that page we can see that the the main cladding panel here that's in

01:58:10 the main cladding panel here that's in this specification is the proteus hr honeycomb rain screen panel manufactured by kme architectural solutions do you see that there yes so the manufacturer kme

01:58:22 yes so the manufacturer kme architectural solutions that's just about a third of the way down that first part and then we can see there's a product reference

01:58:31 reference where it says in capitals proteus hr honeycomb rain screen panel do you see that there yes

01:58:38 now and the the you also say in the the specification here that the zinc sheets manufacturer was to be ned zinc is that right

01:58:51 do you see that yes yes this was prepared by thomas i wasn't entirely clear of the um the background to this or whether they were all somehow connected i see can we go to a product

01:59:03 i see can we go to a product presentation for the proteus panel that we've got this is

01:59:07 this is a sig 504

01:59:11 a sig 504 248 sorry sig 5024a

01:59:21 [Music] did you see something like this at the time

01:59:27 time this specification was put together a proteus presentation

01:59:34 this is not immediately familiar no okay on page two we see that the product is described as an aluminium honeycomb structurally bonded between two thin

01:59:45 structurally bonded between two thin gauges of metal do you see that there yes and we can see there's a nice diagram of it on the right

01:59:52 right and it produces a lightweight and flat composite panel

01:59:57 um and then if we go to page nine where the brochure sets out the fire classifications for the panel

02:00:09 we can see it says tested to fire classification then there's a box a table bs 476 part six four seven six part seven and then a note it says meets the requirements

02:00:20 note it says meets the requirements according to class naught of the national building regulations and then there's a table below which gives various equivalent fire classifications for different countries did you investigate the fire performance

02:00:32 did you investigate the fire performance of this proteus hr panel before it went into the nbs specification i didn't were you aware of anyone else at studio

02:00:43 were you aware of anyone else at studio e specifically investigating the fire performance

02:00:48 if we go back um to the nbs specification this is a sca 50169 and i want to look at page 64.

02:01:03 and if we can look at the bottom of that page

02:01:07 page we can see that in section 11 of the h-92 rain screen cladding section there was this section information to be provided with the tender and it says in addition to the cladding specified in the below clauses

02:01:19 the below clauses 120 and 123 submit comparative supply and install costs per meter squared of the whole cladding system for the following alternative materials and we have raynabon

02:01:30 and we have raynabon duragross 5000 and then there's three different finishes you've outlined there and then a luca bond spectra sakura and then the zinc the quartz zinc

02:01:41 and then the zinc the quartz zinc composite polymer panel by vm zinc do you see that there yes now did you investigate the compliance of these alternative materials

02:01:50 materials with relevant stat streak requirements including the building regulations before inserting those into the nbs specification i don't think these are complete specifications they're finishes

02:02:06 the duragloss refers to the coating right

02:02:10 right so we're not asking are you not asking here for alternative costings for raynabon acm panels from their duragloss 5000 range isn't that a completely different type of

02:02:21 that a completely different type of panel

02:02:22 panel to the protease hr yes but no we didn't seek to

02:02:30 check as we've discussed before compliance with each item

02:02:35 now the mbs specification doesn't state any particular fire rating for the cladding panels does it

02:02:44 the mbs yeah no i don't think it typically does

02:02:51 do you know whether any thought went into whether a fire rating of the panels ought to be specified in the mbs

02:03:03 i do i don't recall it being discussed between

02:03:06 between thomas and i so we've been through a number of

02:03:09 number of products sorry for that matter prior to thomas's involvement because it was quite brief with adrian jess in the months before you don't recall that being dealt with with mr jess

02:03:23 being dealt with with mr jess we've been through a number of product brochures and seen that for some of these products they had different cores available

02:03:29 available but it's right isn't it that you didn't stipulate in the mbs specification which core you were expecting the contractor to price did you no we can see that from some other parts

02:03:40 no we can see that from some other parts of the mbs specification that you did sometimes specify a fire rating can i just take you to an example for the birch window reveals if we look at page 249 within this document

02:03:57 at page 249 within this document and if we can look at item 240 a in the middle

02:04:00 middle this is for the plywood window reveals and sills

02:04:05 and sills we can see in the fifth bullet down it says fire rating class 1 using uk testing methods or class c using the european testing methods do you see that yes

02:04:16 you see that yes and we don't need to go to it but also for the fire resistance of cavity barriers there are fire resistance requirements specified as well in the nbs can you explain why

02:04:27 as well in the nbs can you explain why you've identified fire resistance requirements for these products but not any particular fire rating or classification for the rain screen panels or the insulation

02:04:38 panels or the insulation well this this this is timber the plywood reveals timber which presents an obvious risk and one which obviously we were aware of

02:04:51 and one which obviously we were aware of and addressed the cavity barriers

02:04:58 um i know thomas checked the rating with x over i i assume there might have been a requirement to enter that rating but

02:05:12 it is a fire barrier so it needs to be defined yeah so i can understand why that is

02:05:16 that is yeah so the distinction with the sorry but but as to the boards sorry the panels

02:05:24 panels um we were not aware of their combustibility at all yeah so does it come down to you said the plywood reveals would present an obvious risk so that was something that obviously

02:05:35 so that was something that obviously needed to be addressed in terms of fire performance does it come down to because you weren't aware that there's any obvious risk in relation to the cladding panels or the insulation no thought was given to specifying a

02:05:48 no thought was given to specifying a fire performance rating

02:05:52 it's kind of summarizing hindsight that's

02:05:56 that's we were not aware that accumulated experience my accumulated experience and everyone in the team that composite panels presented any kind of risk

02:06:06 of risk okay well you you had seen i think uh the product data sheets of some of these panels haven't you because do you remember we looked earlier at the fact that they had different

02:06:19 at the fact that they had different cores

02:06:19 cores some had uh fire resistance cores and some this was the oligobond product yeah

02:06:27 yeah and it was the same basically the same type of

02:06:30 type of product wasn't it did it occur to you that some might be more fire resistant than others and therefore it might be wise to specify fire resistant variety we never

02:06:43 specify fire resistant variety we never spoke or invited a luca bond in to discuss their products um i was not aware at the time that the products

02:06:53 products you mentioned that data sheet i didn't study that data sheet at the time we were i think it came in as a

02:07:01 as a enclosure with samples that we had requested

02:07:09 until until the night of the fire had no knowledge

02:07:13 knowledge that the products came in different varieties

02:07:17 varieties of cool right thank you okay thank you um can we just go back within the rain screen section to look at

02:07:25 at a little note that's on page 64 of the spec yes at the end of that section 11 which sets out those alternatives you've got

02:07:36 sets out those alternatives you've got note faced fastened solutions permitted do you see that there yes um

02:07:43 yes um there's been some suggestion um i think in indeed in studio e's appendix to its opening that studio e specified face fixed panels

02:07:55 specified face fixed panels is that because of the reference to this note

02:07:58 note yes would you agree looking at the wording now that it's only saying face fastened solutions are permitted it's not saying that those are the only ones permitted

02:08:10 ones permitted that any reading of this would just be making clear that you can propose face face fix solutions face fixed solutions are invariably cheaper yeah i see

02:08:22 invariably cheaper yeah i see so it's making clear that those cheaper face fix solutions are permissible yes yeah that's helpful and then at the top of page 64 there's um

02:08:34 um a similar or equal provision

02:08:43 so um in that top paragraph it says to be read with the preliminaries and general conditions and the very the second bullet down sorry is it says the manufacturers noted within

02:08:55 it says the manufacturers noted within this specification are indicative and may be substituted with similar or equal alternatives do you see that there yes do you know who put that clause into the nbs specification was that something studio

02:09:06 specification was that something studio e did or somebody else

02:09:14 i would have to check i think it is something that we might have done typically right yeah i'm not sure if it is a standard mbs clause i'm not sure

02:09:27 mbs clause i'm not sure and there are some other changes that were made to the preliminaries and the general conditions to mirror that similar or equal alternatives and so did you have any involvement in in

02:09:38 so did you have any involvement in in that

02:09:40 that i may have done as i say that that was the intention to to allow for similar or equal alternative products yeah um

02:09:51 yeah um just back to the alternatives you give at the bottom of this page can you just explain why did the vm zinc quartz zinc appear as one of the alternatives given i think you told us earlier and we saw

02:10:02 i think you told us earlier and we saw it in the documents that you told mr harris that it was too dark in appearance and you wanted a lighter finish can you explain why that pops back into

02:10:13 can you explain why that pops back into the spec at this point

02:10:18 because it's a completely different type of product of being being a composite sync panel whereas the other aluminium i mean that

02:10:29 aluminium i mean that is how justify it now is just just to get another option

02:10:38 now mr chairman if you let me i would like to just carry on uh a little bit past four o'clock and given we lost some time with a technical problem this morning just so i can get to a

02:10:49 can get to a more logical place in my notes to stop and also just to keep making progress because how much longer you do you would need this witness tomorrow um i'd like to go

02:11:00 this witness tomorrow um i'd like to go to ten past four if that's okay yes all right well mr sends are you happy to carry on a little longer than usual

02:11:05 usual yes right well i'm going to say to ms grange if she can pass four o'clock but they were going to stop at 4 15 in any event that's all right yes yes right ms grange

02:11:16 that's all right yes yes right ms grange yes thank you now just thinking forward now to ryden's tender that comes in after this was studio e involved in the tmos procurement of the design and build

02:11:28 tmos procurement of the design and build contractor for the grenfell project

02:11:34 i'm sorry were you involved at all in the procurement process for the design and build contract we prepared the um architectural requirements yeah yes did you have any other involvement other

02:11:46 did you have any other involvement other than that um

02:11:50 yes we we attended the it is bitters day on site yeah um walked around answered questions

02:11:58 questions we responded to tender queries yeah a fair number of them and we i

02:12:05 and we i scored the quality sections in the three tenders that were received okay great

02:12:14 um and you read ryden's tender submission during that process didn't you yes can we look at an email on that this is sca 3010576

02:12:27 this is an internal email if we could look at the top of the page

02:12:39 if we could look at the top of the page this is you to mr kushal cc'ing mr crawford grenfell tower tender returns and we can see from the email below that artelia have been reporting back

02:12:51 have been reporting back on the tender returns and giving a summary of the tender returns from the different companies including ryden and and you say this nothing like a good tender

02:13:02 tender the qs hadn't found any significant clarifications in the lowest tender when i spoke to her a few minutes ago perhaps ryden have made a mistake or two a review is proposed next week

02:13:15 a review is proposed next week do you see that yes now can you explain to us why you made that comment that nothing like a good tender perhaps they've made a mistake or two i must profess i haven't revisited this

02:13:26 i must profess i haven't revisited this email

02:13:27 email since i think i'm suggesting that it was a good result in other words the price was close to

02:13:39 in other words the price was close to what we

02:13:40 what we wanted could it have actually been more of a sarcastic response because ryden's tender in your view was too low

02:13:49 too low at that time no no i don't think it's definitely not sarcastic i'm my comment is have they made a mistake is is it correct

02:14:00 correct in other words it looks good but is it correct

02:14:03 correct i see i don't think it's sarcastic it comes across as you saying this is too good to be true doesn't it too good to be true yeah how low the

02:14:14 too good to be true yeah how low the tender was nothing like a contender you usually

02:14:18 usually you go out to tend to test the market and

02:14:22 and you're never sure what you're gonna get and that's the purpose of tendering to get the best value

02:14:31 i think a good tender is when you've got a good result of the price a good good cost okay so you weren't surprised at um the figure that was coming in there for

02:14:43 the figure that was coming in there for ryden at 9.2 million i'm not sure i was necessarily even commenting on the level that ryden came in i was commenting on on the range i see the range between

02:14:55 the range i see the range between derek and mulally and ryden clearly reveals that ryden are much keen much more keen okay and therefore the tender process is working and then can we go to sca three one

02:15:12 this is an email from you to artelia of the 19th of february 2014 and you say in the first paragraph that you were concentrating on ryden's tender

02:15:23 you were concentrating on ryden's tender because the others are so far behind do you see that there yes

02:15:29 yes and did he mean that ryden's was by far the cheapest bid the lowest bid yes now

02:15:37 yes now we know that there was um quite a big difference in the savings being suggested between ryden and durkan for the acm can we just look at that this is in a artelia tender report which appears at

02:15:48 artelia tender report which appears at tmo

02:15:55 and i want to look at page 14.

02:16:14 we've got that tmo yes thank you and if we can look at that top line so

02:16:23 line so they've said the following cost for alternative design solutions do not form part of the tender sum and they've evaluated these separately and then we see in the very first line new aluminium cladding including necessary support insulation

02:16:35 including necessary support insulation etcetera

02:16:36 etcetera to facade of tower and ryden are there at

02:16:40 at a saving of 243 thousand durkheim 169 000 and then mullally make no offer

02:16:49 no offer on that did the extent of the difference in saving between ryden and durkheim for the acm raised any questions in your mind when you looked at that

02:17:00 looked at that i don't recall looking at it at the time i must be honest okay and if i can go back to that point about um errors and tenders in my experience that happens

02:17:13 in my experience that happens frequently it's a very very um that's where qs spends a good deal of their time just checking errors

02:17:22 so you know whether you you sure if the tender sum is very contingent on being able to check that there are no errors in

02:17:32 in yeah in the buildup yeah do you know looking at this why mulally didn't make an offer

02:17:38 an offer for any savings in relation to the acm no it's recall now ryden come on board and in april 2014 we know that you're informed

02:17:50 2014 we know that you're informed that ryden was proposing to use a face fixed aluminium composite material cladding system for the transcript you've addressed this at paragraph 373 of your witness statement

02:18:01 paragraph 373 of your witness statement and you've also referred to the planning discharge proposals from ryden at paragraph 55.1 of your statement can we go to that um these are the

02:18:12 can we go to that um these are the planning discharge proposals um if we look at sea three zeroes one zero six nine eight

02:18:32 yes so um we can see an email here from philip booth of artelia to the planners mark watterson um simon lawrence etcetera dryden

02:18:44 etcetera dryden and then you'll see seed into this um it's dated the first of april 2014. and we can see that philip b

02:18:56 and we can see that philip b says i've just left an introduction meeting with ryden the selected contractor for grenfell we discussed planning permission and discharge of conditions i would like your opinion on the following and he says one riding are proposing a face fixed aluminium

02:19:08 proposing a face fixed aluminium cladding system in colours to mirror those submitted for planning

02:19:13 planning and then he asks a question and then he also

02:19:17 also says two it is proposed to remove the crown to the top of the building as for maintenance reasons that be prudent to enable abseil access if ever required in the future do you see those yes and you if we could go then to

02:19:30 yes and you if we could go then to paragraph 376 of your witness statement sca 3014273 at page 153

02:19:42 you say with reference to to these conversations that studio e's input was principally involved

02:19:48 involved was principally providing input from an architectural perspective and i just want to ask you about what you mean by that that architectural

02:20:00 perspective i'm sorry i'm not connecting these this email in this this paragraph

02:20:11 are they connected uh we had understood them to be that you were explaining that around this time your input was principally providing input from an architectural perspective

02:20:22 from an architectural perspective is that how you understood your involvement once ryden started to propose solutions for the the cladding

02:20:35 we're referring to the changing studio's role as being

02:20:42 innovated but obviously not yet to the successful contractor

02:20:51 did you consider your role to be limited at this time

02:20:57 um

02:21:02 certainly our role had changed and had become limited yes

02:21:07 when mr crawford gave his evidence he referred to an informal conversation that he said he'd had with

02:21:14 had with simon lawrence of ryden where mr wright mr lawrence said to him that ryden tended not to use architects as much as it might do

02:21:25 architects as much as it might do and mr crawford also said in evidence that

02:21:29 that mr lawrence has said something similar to you and i want to ask you about this did mr lawrence ever say something along those lines to you yes can you remember exactly what he

02:21:42 yes can you remember exactly what he said to you

02:21:45 very very almost word for words they tend to not write intended to not use architects that much on projects can you remember

02:21:59 that much on projects can you remember when he said that to you at what point in the project it was near the beginning and

02:22:05 and it was more than once near the beginning of ryden's involvement you mean so early 2014 are we talking spring 2014

02:22:21 yeah but between um spring and summer i think he would have we would have had a conversation or two two or more conversations

02:22:32 conversations to that effect yes and were you surprised when he said that to you did that um seem unusual to you to come from a designer bill contracted to be saying

02:22:44 designer bill contracted to be saying that to the architects yes it was it was a surprise because he wasn't looking to discount our fee okay so yes it was a surprise and did

02:22:56 okay so yes it was a surprise and did you say anything in response to him when he made that comment to you no it just

02:23:01 just it wasn't defined it wasn't anything to warrant a response i see okay

02:23:09 mr chairman i think that is a good moment a good point that's where i wanted to get to thank you well you've done well and it's only 10 plus four

02:23:18 plus four well mr friends we're going to stop there for the day i'm afraid we have to ask you to come back tomorrow for some more questions um we'll resume at 10 o'clock tomorrow if you could be here ready

02:23:29 if you could be here ready in time to start then and and i keep saying this but it's important please don't talk to anyone about your evidence while you're away from the room all right okay thank you very much indeed you gave the option

02:23:54 right that's great well that's that for the day we resume with mr sons yes and we should finish him i mean we'll finish atm first first thing in the morning and then we've got a number of uh separate topics smaller to all

02:24:06 uh separate topics smaller to all smaller topics to deal with uh before he'll finish so i think he will go most of the day well the important thing is to finish him tomorrow it is it's all possible absolutely that's good right thank you

02:24:17 absolutely that's good right thank you very much 10 o'clock tomorrow please

02:24:45 you