Bell Green Gas Works Phases II & III

Introduction

Background

1. The Sydenham Society is a local, and entirely voluntary, amenity society with a paid-up membership of nearly 1,100 local residents. Its catchment area is principally Sydenham, but also extends to other parts of the Borough of Lewisham, including Forest Hill. The Society’s Executive is responsible for developing broad policy responses to local issues as they arise. There are two sub-committees, one specialising in roads and transport issues and the other in conservation, planning and environmental issues. Much of the work of the two committees involves advising and making representations to the London Borough of Lewisham (the Council), about local transport, planning and other associated matters.
2. What follows is the Sydenham Society’s statement of case, as required under Rule 6 of the Town and Country Planning (Inquiries Procedure) (England) Rules 2000, made in connection with the above inquiry.

The Applications

3. The current applications are as follows:
   a. the Phase ll application is for non-food bulky goods retailing floorspace of 13,517 m2, business and industry floorspace of 10,644 m2 and a restaurant of 316 m2; and
   b. the Phase lll application is for non-food bulky goods retailing of 1,247 m2 (or restaurant), and residential accommodation of 156 flats.
4. Although an outline permission already exists for the further development of the Bell Green site, the scale of development now proposed far exceeds the provision contained in the existing permissions.
5. If the existing proposals are permitted then the result would be an out of centre retail park at Bell Green, of almost 29,000 m2, that would be larger in its retail floorspace than its closest town centres of Forest Hill and Sydenham. The site would provide 1,830 car parking spaces, the majority of which (1,642) would be for shoppers. The proposed developments, when combined with the existing food retail provision on the Bell Green site, would damage the vitality and viability of Forest Hill and Sydenham and would result in a significant net increase in car traffic on the network. The developer estimates that 77% of visits to the proposed sites would be by car.
6. The Sydenham Society considers that the applications fail to meet the requirements of national planning policy guidance. We also consider that the applications do not comply with relevant development plan policies including the London Plan and the Council’s UDP – July 2004.
7. We also consider that the Council’s consideration of the applications, as contained in its reports to the strategic Planning Committees of 16 June and 14 July, was insufficient and flawed.
   Response to the Secretary of State’s Statement of Matters
8. The Sydenham Society’s objections to these applications can in the main be referred to the Secretary of State’s statement of matters as follows:
   a. retail and town centres, including matters at 4(a)(ii) and 4(a)(iii) of the Government Office’s letter dated 5 October 2005;
   b. employment, including matters at 4(a)(iv) and 4(c);
   c. transport, including matters at 4(b)(i), 4(b)(ii) and 4(b)(iii), including traffic generation and car parking; and
   d. alternative uses of the land, including matters at 4(e) in relation to housing provision.
9. The Sydenham Society’s main points in relation to each of the above are developed further in the sections which follow
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10. Retailing and Town Centres

Other Areas

1. PPS6 enjoins local authorities to consider the extension of primary shopping areas where growth cannot be accommodated in existing centres. The Council has not properly examined that possibility in respect of the proposals. As a result, possibilities such as an extension of the Forest Hill shopping area, in respect of which Lewisham Council have developed an Urban Design Framework, have not been properly examined in connection with these applications.
2. Nor, as part of the sequential test, has a thorough assessment (as required by PPS6) been made of all potential development opportunities in town centre or district centre sites. For example, the Council have not properly considered in any detail the potential of the Lee High Road site, which is noted in the UDP for retail, or a mix of retail and residential, and is described as a key development site. Likewise the Council have failed properly to consider, in sufficient detail, the Old Market site, Catford which could accommodate significant retail floorspace – approx 18,000m2 – albeit over a longer time scale than at the Bell Green site.
   Impact of the Proposals
3. If the Phase II application is approved then the total retailing floorspace located on the Bell Green site (including the Savacentre on the developed Phase 1 site) together with the Phase III proposal would be 28,606m2.
4. The result would be a retail park with retailing floorspace larger than Forest Hill centre (18,158m2), larger than Sydenham town centre (23,040m2) and 62% of the size of Catford town centre (46,358m2).
5. The retail park would (i) combine food and non-food retailing (with the non-food element containing – within the Savacentre – non-bulky goods) and (ii) provide 1,641 free car parking spaces for shoppers. Its sheer retailing scale and massive free parking provision poses a real threat to the viability of existing shopping centres, especially Forest Hill and Sydenham.
6. The Council already recognises the vulnerability of both shopping centres. In 2003 the Council adopted an Urban Design and Development Strategy for Forest Hill (as part of its wider programme of regenerating ailing town centres across the borough). In the case of Sydenham, the Council created the Sydenham Regeneration Partnership as a forum for securing the regeneration of the town centre.
7. However, at May 2003 (the latest available data) both Forest Hill and Sydenham town centres had a level of vacant retail units well in excess of the national average of 10.5%. The Forest Hill vacancy level stood at 15.3% and Sydenham at 13.3%.
8. Against that background, there must be the most serious concern about the level of spending that the developer estimates will be diverted annually from the local town centres by their proposal.
9. The developers’ figures for diverted trade, in bulky goods spending, are:

Area £ per annum % of goods spend

Forest Hill £550,000 12.6%
Sydenham £490,000 8.5%
Catford £1,890,000 12.3%

10. In addition to loss of spending on bulky goods there will be an additional loss of spending on non-bulky goods, and on food, arising from a decline in the shopping ‘footfall’ of the local centres, i.e. a decline in visitors to the town centres. The Council’s retail analyst, Nathaniel Lichfield and Partners (NLP), when referring to the broad range of comparison goods, i.e. bulky and non-bulky, stated that ‘subject to any permission being suitably conditionedthe levels of comparison impact on the existing centres, at less than 3.5%, are likely to be acceptable’. That assessment did not factor in further potential losses of food sales. In any event, NLP’s conclusion falls well short of a clear view that centres such as Forest Hill and Sydenham would not be harmed by the Phase II proposal. The developers’ evidence should be subject to the greatest possible level of scrutiny.
11. The Greater London Authority (GLA) have serious concerns about the ‘conflict with emerging and established national and regional policy by virtue of their scale relative to the established local centre’. In other words, the GLA is concerned that the amount of retailing proposed for the Phase II site is disproportionate to the size of existing town centres, and thus a threat to their viability. The GLA’s view is that ‘on balance’ their doubts can be outweighed only by the addition of housing (now met by the Phase III proposal) and a reduction in levels of car parking on the site. The developers do notpropose tomeet the GLA’s objection in respect of reduced car parking.
12. Bromley Council, with a borough boundary approximately 1km from the Bell Green site, formally objected on the grounds that ‘in view of the amount of retail floorspace, its location outside an established town centre and the amount of on site parking, the proposal would significantly undermine the trading patterns in neighbouring town centres in Bromley and would harm the viability and vitality of those centres, would encourage an unsustainable increase in car-based trips to the north of the Borough and would thereby be contrary to PPG6 and to Draft PPS6.
13. Bromley’s second ground for objection is ‘that the delays forecast for vehicles on the A2218 Southend Lane would increase the likelihood of significant queuing of vehicles seeking to use Worsley Bridge Road and would, in turn, increase the number of vehicles diverted onto other roads in the adjacent part of the London Borough of Bromley most of which are predominantly residential and would be detrimental to traffic flow and vehicle and pedestrian safety.’ This is echoed by the Society, as considered later in the section in this statement of case which deals with transport.
14. Neither the Council nor the developer have responded to Bromley’s concerns.
15. From a retail perspective alone, there is a clear case for refusing to permit the proposals.
    Planning Policy
16. The proposals are contrary to development plan and national policy, including but not limited to the following provisions.
    Planning Policy Statement 6: Planning for Town Centres (PPS6)

Paragraph 1.3 – ‘The Government’s key objective for town centres is to promote their vitality and viability by: …promoting and enhancing existing centres by focusing development in such centres and encouraging a wide range of services in a good environment, accessible to all’.
Para 2.56 – ‘Deprived areas often have poor access to local shops and services…local authorities should work with the local community and retailers to identify opportunities to remedy any deficiencies in local provision. This is likely to be best achieved by strengthening existing centres…’.
Para 2.57 – Local planning authorities ‘should strengthen local centres by seeking to ensure that there is a range of facilities in local centres consistent with the scale and function of the centre, to meet people’s everyday needs, particularly in deprived areas’.
Para 2.58 – ‘Local authorities should, where appropriate, seek to protect existing facilities which provide for people’s everyday needs and seek to remedy deficiencies in local shopping and other facilities to help address social exclusion…local authorities should take a positive approach to strengthening local centres…’.
The London Plan

Policy 3D.1 – boroughs should enhance access to goods and services and strengthen the wider role of town centres, including UDP policies to…encourage retail, leisure and other related uses in town centres and discourage them outside the town centres.
Policy 3D.2 – the scale of new schemes should be appropriate to the size and role of the established local centres.
London Borough of Lewisham UDP – July 2004

Policy STR.STC 1 – ‘To sustain and promote the vitality and viability of the existing shopping centres in the Borough

Employment

3. The Council refer to the schemes’ potential (in retail and light industry) to create up to 475 jobs. This figure is not substantiated either in the officer’s reports to the Council’s Strategic Planning Committee or by the developer. In his report to the Committee on 14 July 2005 the officer explained that the figure of 475 is based upon ‘recognised’ employment/floorspace ratios (see paragraph 2.5 of that report).
4. However, neither the officer’s report, nor the developer, disclose this ‘recognised’ formula in order to explain how the figure of 475 additional new jobs is arrived at. This formula should have formed part of a published human resource plan setting out, precisely and in detail, the methodology used to justify the figure of 475 additional new jobs. There is no real evidence of the employment to be generated by these proposals.
5. In the absence of a human resource plan, or other similarly detailed and persuasive evidence, very serious doubts must exist over the validity of the predicted job figure of 475. There are two reasons for this in particular:
   a. retail warehousing is not labour intensive, nor are small business enterprises, nor small industrial premises; and
   b. experience of earlier planning applications for the Bell Green site reveal that potential business and industrial users were only prepared to transfer their existing staff to the site. Few wholly new jobs would have been created. There is no reason to expect a different attitude from potential employers in respect of the present application.
6. The officer’s report, in advancing the figure of 475 jobs, takes no account of the prospect of serious job losses arising elsewhere in the local light industry and retail sector as a result of the proposed development. The developer acknowledges that town centres in Sydenham, Forest Hill, and Catford would lose at least around £3million per annum, in takings. The loss of this large sum from existing low profit margins would inevitably harm existing employment levels.
7. The reduction in takings by shops and in business and light industry in local town centres would be caused by two factors:
   a. a reduction in footfall in the town centres, as shoppers divert to the Bell Green site which (taking account of the existing superstore on the site) would cater for food and non- food (both bulky and non-bulky goods) items; and
   b. a loss of trade, by shops such as DIY, plumbers, furniture etc, to the national chains likely to occupy the retail warehouses on the proposed development.
8. Taken together, the proposals for retailing and employment would certainly not have the effect of strengthening or protecting existing shopping centres. They are more likely to result in harm to local shopping centres, especially those of Forest Hill and Sydenham. The employment benefits claimed to flow from the proposals have not been justified and appear to be exaggerated. Neither the developer nor the Council have attempted properly to assess what the net employment gain, if any, might be.
9. The Sydenham Society believes that the designation of the Bell Green site as a Defined Employment Area in the Council’s UDP would be more suitable and beneficial for local residents.
10. By not utilising this land for a use which brings significant levels of employment, and high quality employment at that, the proposals amount to a wasted opportunity. Regeneration, employment and economic growth will best be served by making the best possible use of land to generate high quality local jobs. The current proposals are contrary, and therefore harmful, to meeting objectives of regeneration, employment and economic growth to the greatest possible extent.
11. Accordingly, the employment benefits of the proposals are over-stated and are not supported by proper evidence. No account is taken of the harm in employment terms that will be caused by the development. Employment in nearby areas will be harmed. This is contrary to development plan policy and national planning policy guidance.

Planning Policy

10. The proposals are contrary to development plan and national policy, including but not limited to the following provisions.
    The London Plan
    Policy 3B.5 Strategic Employment Locations – “With strategic partners, the Mayor will promote and manage the varied industrial offer of the Strategic Employment Locations (SELs), set out in Annex 2 as London’s strategic reservoir of industrial capacity. Boroughs should identify SELs in UDPs, and develop local policies for employment sites outside the SELs, having regard to:
    • the locational strategy in Chapter 2 of this plan
    • accessibility to the local workforce, public transport and where appropriate, freight movement
    • quality and fitness for purpose of sites
    • the release of surplus land for other uses in order to achieve the efficient use of land in light of strategic and local assessments of industrial demand.”

London Borough of Lewisham UDP – July 2004

Policy STR.EMP 2 – “To protect a range of suitable sites for business including industrial uses, in line with sustainability and environmental objectives, especially for new growth areas of the economy.”
Policy EMP 1 – “the Council will aim to ensure a satisfactory supply of land and premises for employment uses, by protecting where appropriate those existing sites and buildings which it considers to be particularly suitable and by providing or identifying additional sites for new development in suitable locations, including where appropriate, Town Centres”
EMP4 – “Employment sites outside Defined Employment Areas Applications for the redevelopment, in whole or in part, of land currently or previously used for employment purposes but not falling within a Defined Employment Area will be approved where they are for an employment use and the land is still considered suitable for such a use, having regard to other relevant policies in the Plan. Applications for other uses will be approved if it can be demonstrated that, and evidence has been produced that: a) in the case of proposed mixed use development the number of jobs likely to be created by the proposal outweighs the loss of the employment site.

Transport

4. The proposed retailing developments on the Phase II and Phase III sites are geared primarily towards the car user. If implemented, the proposals, taken together with the business/industry element of the application, would result in a major increase in peak period traffic on the road network in the area.
5. The Phase II proposal provides for a total of 598 car parking spaces. If added to the existing car parking spaces at the Savacentre site of 1,121, then the total car parking spaces (including the 111 spaces associated with the Phase III proposal) would be 1,830. Of those, 1,641 spaces would be devoted to retailing – food, non-food, and restaurant uses.
6. The developers’ transport consultants, Savell Bird & Axon (SBA), have estimated that 77% of visits (person trips) to the combined Phase II/III proposals would be made by car, including by car as passenger. SBA have also estimated that 50% of trips made to the non-food retailing element of the proposals would be of a primary nature i.e. trips new to the road network, rather than pass-by trips already on the network or trips linked with an existing visit to the Savacentre.
7. Focussing on some of the local roads, in 2003 SBA predicted increases, at Saturday peak, in traffic flows arising from the Phase II and Phase III proposals ranging between 7.3% and 16.7%. SBA’s 2005 analysis predicts lower – although still significant – levels of increase, up to a maximum of 11.8%. The 2003 analysis took as its starting point existing traffic flows and then measured the predicted increase against that. Whereas, the 2005 analysis took as its starting point existing traffic flows plus a notional level of traffic arising from ‘approved development’ for the Bell Green site i.e. floor areas consented to in the Masterplan for Bell Green but which have not been implemented. Thus the 2005 analysis started from a higher base count than the 2003 calculation, resulting in a lower percentage increase in predicted traffic levels.
8. The Council’s report of 16 June 2005 to its Strategic Planning Committee, on the Phase II application, refers to ‘increases of about 6% or 7% over existing flows on the network’ during the Saturday peak period. That prediction was in fact based on a flow comparison between previously approved but unimplemented development at Bell Green and flows predicted to arise from the proposals. (The Council’s later report of 14 July 2005 to its Committee corrected the misleading statement in the first report). However, despite the Society repeatedly asking them to do so, the Council have not produced a comparison between existing traffic flows on the network and flows arising should the current proposals be implemented. The flow comparison used by the Council is seriously misleading.
9. It is inescapable that the Phase II and Phase III proposals would, in combination, generate increases in traffic levels on the local network that can only be described as substantial. The Council’s conclusion in the officer’s report (para 6.39) is that ‘there is sufficient capacity on the road network at most times to accommodate the proposed increase in demand from the Phase II and Phase III development’. Residents in the roads referred to above would strongly disagree with that conclusion, as would the Society.
10. The officer’s report does not argue that the overall effect of the proposals would be to maintain or reduce the existing levels of traffic on the wider network, nor does it refer to any data that would support such a view. In short, the available evidence suggests that the Phase II proposal would result in a net increase, significant in scale, in existing traffic levels on the network. It follows that some parts of the network would experience increased congestion. The Society considers that the effect in traffic terms would be significantly adverse and unacceptable.
11. Having regard to the expected impact, the Society considers that from a transport perspective the Phase II and Phase III applications are in clear contravention of important government planning policies at national, regional and local level.

Environmental Issues

9. The Bell Green site is immediately adjacent to an Air Quality Management Area (AQMA), comprising several of the roads that would carry the weight of the additional road traffic that the proposals would generate. The traffic assessments undertaken by the developers identify all of those roads as likely to experience a marked increase (between 7% and 16%) in traffic flow, during the Saturday peak, as a result of the proposals.
10. The Council’s officer’s report on the proposals contains no specific discussion of the impact of the proposals on the AQMA. Instead, it merely refers to the conclusion of ERM (consultants appointed by the Council) that the developer’s Environmental Statement complied with environmental impact assessment regulations and dealt with all significant environmental impacts, apart from some relating to construction noise.
11. One of the roads forming part of the AQMA is Sydenham Road, the main shopping thoroughfare of Sydenham town centre. The developers predict an increase in traffic on Sydenham Road, arising from the proposals, of 10.8%, peak period.
12. All that ERM have said about Sydenham Road is that ‘the applicant has assessed the impacts of air quality on Sydenham Road by using the Health Centre (at Bell Green) as the key sensitive receptor in this location. The assessment shows that this receptor will not be significantly affected by the Phase II development’.
13. In other words, ERM simply referred to the developer’s own assessment without providing any independent analysis of whether the conclusion reached by the developer was robust. Moreover, had ERM objectively assessed the developers’ assessment they would have noted that the receptor used to measure the air quality impact on Sydenham Road is located completely separately from Sydenham Road. It is in a location at Bell Green that has a quite different built environment than Sydenham Road and that experiences fewer and shorter traffic queues. In other words, the receptor used is in entirely the wrong place to measure air quality in Sydenham Road.
14. The overall quality and independence of ERM’s assessment of the developers’ Environmental Statement must be seriously questioned in the light of their Sydenham Road analysis. The Society considers that the proposals will result in unacceptable harm to air quality as a result of the increase in traffic.

Planning Policy

15. The proposals are contrary to development plan and national policy, including but not limited to the following provisions.
    Planning Policy Statement 6: Planning for Town Centres
    Paragraph 2.49 ‘The Government is seeking to reduce the need to travel, to encourage the use of public transport, walking and cycling and reduce reliance on the private car…local authorities should have regard to…the impact on car use, traffic and congestion’
    Paragraph 3.27 ‘In assessing new developments, local planning authorities should consider: whether the proposal would have an impact on the overall distance travelled by car…’
    PPG13: Transport
    Paragraph 49 – ‘The availability of car parking has a major influence on the means of transport people choose for their journeys. Some studies suggest that levels of parking can be more significant than levels of public transport provision in determining means of travel…even for locations very well served by public transport…Reducing the amount of parking in new development…is essential…to promote sustainable travel choices’
    The London Plan
    Policy 3C.16 Tackling congestion and reducing traffic ‘Working with strategic partners the Mayor will aim from 2001 to 2011 to…achieve zero growth [in traffic] across the rest of inner London [other than central London]
    Policy 3C.18 Local area transport treatments ‘…There is an urgent need to reduce congestion and traffic levels….Boroughs should consider local initiatives that aim to reduce traffic…’
    Lewisham Unitary Development Plan – Adopted Plan July 2004
    Chapter 6 Sustainable Transport and Parking – Policy STR.TRN 1 – ‘To co-ordinate land use and development with the provision of transport and car parking, so as to minimise the need for car travel…’
    Policy STR.TRN 4 – ‘To adopt an integrated car parking strategy which contributes to the objectives of road traffic reduction…’
    Reasons for policies – ‘There is a need to reduce car travel in order to reduce traffic congestion, improve the business-operating environment, improve bus reliability and improve air quality and health’
    Chapter 8 Shopping and Town Centres – Policy STC2 Location of New Stores (Sequential Test) ‘…Proposals for substantial retail provision on the edge or outside of these Centres [Major and District Town Centres] will only be considered if …the proposal is sited so as to reduce the number and length of car journeys…’.
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16. Alternative uses for the site
17. The Sydenham Society has engaged with the Council over the past 10 years about alternative uses for the site. It is a site with a long history of industrial and employment uses. The Society has suggested that the Council should consider using this site to produce high quality employment and training for local residents such as a high-tech science or business park. The Council has however chosen to consider this site primarily for retailing and includes it in its UDP Shopping and Town Centre chapter.
18. The Council has designated the site as “unsuitable for residential because of contamination”. The Sydenham Society believes that acceptable methods of building houses on contaminated brownfield sites are now available and has argued that this is also an alternative method of regenerating this site. The latest Phase III proposals now show that the Council is prepared to depart from the adopted UDP designation.
19. The Society considers that by providing more housing on the Phase II site the overall mix of uses on the development would be improved and many of the harmful effects of the proposals would be avoided.
20. The site has a number of attributes which make it highly suitable for residential development, not least its sustainable location near the transport network for those needing to travel to work.
21. By failing to make use of more land for housing as part of the overall development of this land the proposals do not maximise the opportunities presented by this land, including to promote a more sustainable pattern of development.
22. The proposals are contrary to development plan and national planning policy as a result.
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23. Summary and Conclusions
24. The Society accepts that there is a need to develop the remainder of the Bell Green site. Indeed, the Society has been pressing the Council over the last decade to persuade the site owners to put forward plans for site regeneration.
25. The present proposals, Phase II and Phase III, have the Society’s firm support in respect of their business/industrial and housing elements. The Society has consistently argued that those uses (and others) should form the core of regeneration. However, the Society has also consistently argued that further large-scale retailing should not be developed at the Bell Green site since that would damage the already faltering town centres of Forest Hill and Sydenham, and would create significant additional traffic in an area whose roads are badly congested. On that basis we have not objected to the Phase III proposal, in which the housing element predominates, but we continue to oppose the Phase II proposal which is dominated by the non-food retailing element.
26. The Society understands that the Council had to consider the applications before them, and on their merits. The Society also understands the argument that the Phase II proposal, when linked with Phase III, would bring into use a site that has long lain idle and in a way that would provide some employment and housing, and not just retailing. But the Society believes that the better view is that the benefits of the combined Phase II and Phase III proposals are clearly outweighed by the disbenefits (arising principally from the Phase II proposal), especially of damage to local town centres and significant increases in car traffic. That is why the Society considers that there are firm planning grounds for refusal, on its merits, of the Phase II application.
27. As to the link between the Phase II and Phase III proposals, the developer and the Council argue that in order to provide the social housing element of the housing proposed for Phase III, and the employment element of the Phase II proposal, both have to be subsidised by a substantial retailing element on the Phase II site. That is a superficially attractive argument. However, on closer scrutiny, the argument is not compelling.
28. Neither the developer nor the Council have specified what would be a minimum level of retailing that would be needed on the Phase II site in order to subsidise the employment and housing proposals. On the face of it, it appears possible that the developer could scale down the proposed retailing and still be able to provide the necessary cross-subsidy for housing on the Phase III site, and possibly also the employment proposal on Phase II. There must be the possibility too that, if not immediately then within the foreseeable future, funding for social housing in the form of a social housing grant could replace a cross-subsidy from retailing on Phase II. In other words, the Society considers that it may be possible to disengage the Phase III site proposal from the Phase II site proposal.
29. Returning to the subsidy for employment uses, the developers’ 2003 analysis of the viability of such uses on the Phase II site specifically excluded the possibility of a residential development on Phase II (which they acknowledged would be valuable) as a source of subsidy. That was because the UDP excluded housing, and still does, from the entire Bell Green site. However, the Council has now departed from its own UDP policy by agreeing (in principle) to housing on Phase III. There is no reason then, in principle, why that policy flexibility could not be extended to Phase II. Moreover, as recently as April 2005 the Council’s environmental consultants said that they had ‘no information to preclude possible residential development of the Phase II site’.
30. The Society considers it apparent then that if the Phase II application is refused that need not prevent a further application from coming forward which could provide for a mix of housing and employment on the site, and possibly a much scaled down amount of retailing. A housing development could subsidise the employment use and would have the major benefit of neither impacting on town centre viability nor creating significant increases in current traffic levels.
31. In other words, we believe that a development on the Phase II site that provided, predominantly, a mix of housing and employment uses (light industry etc) would be of infinitely greater value to the local and to the wider community than a DIY store, garden centre, and other associated retailing.

The documents to which the Society currently intends to refer at the inquiry are noted where relevant above. The Society reserves the right to refer to additional documents as it investigates further the proposals and develops its evidence.

This statement of case gives as full particulars of the case which the Society proposes to put forward at the inquiry as is possible in the circumstances. The Society reserves the right to refer to additional points as it further investigates the proposals and other relevant matters and develops its case.