Official Report: Minutes of Evidence

The Chairperson (Mr McCausland): I welcome the officials to the meeting. We are glad to have Ms Valerie Brown, who is the environmental health manager, and Mr John Walsh, who is the town solicitor. I suppose that there are no relevant financial or other interests to declare on your part in relation to today's business.

Mr John Walsh (Belfast City Council): No.

The Chairperson (Mr McCausland): I invite you to make an opening statement.

Mr Walsh: Chairman, I propose to allow Ms Brown to outline the council's position. Valerie Brown is the environmental health manager and has health and safety in her portfolio of responsibility. She is in charge of those officers who deal with issues in respect of the Safety of Sports Grounds (Northern Ireland) Order 2006. I am here to assist the inquiry and Ms Brown as is required.

Ms Valerie Brown (Belfast City Council): Mr Chairman, thank you very much for inviting us to brief the Committee. The council is the certifying authority under the provisions of the 2006 Order, and we have eight designated grounds in Belfast. We issued safety certificates for the eight grounds in September 2010 and, at that time, the certificates were issued for an indefinite period. They are reviewed annually, and we look at any changes that occur in relation to the physical condition of the grounds or in relation to the safety management at the grounds. We issued a certificate for Casement Park back in September 2010, initially for 5,000 because barrier testing had not been carried out, but then for 31,661 spectators, and that was regarded as the safe capacity at the ground. The three main factors that are used in determining the safe capacity are the entrancing capacity, the exiting capacity, which includes emergency exiting, and the holding capacity of the ground. The lowest of these figures determines the safe capacity of the ground. That is a very simplistic approach to it. The (P) factor, relating to the physical condition of the ground, is also taken into consideration, and then the (S) factor, relating to safety management, is applied. There are lots of different issues that are taken into consideration under the guidance issued for the safety of sports grounds, which is referred to as the red guide. Initially, that was the guidance that we were using. It was based on the GB 'Guide to Safety at Sport Grounds', which has since been reviewed and updated. We have the fifth edition, and the redevelopment has been based mainly on the fifth edition.

On the council's role in emergency exiting, I will talk about the process first. We were first notified of the safety technical group process in October 2012 by the then permanent secretary, Rosalie Flanagan, in a letter to my colleague Mark McGovern. The letter was primarily in relation to Windsor Park at that time, but it noted that the Casement Park project had been mobilised and the design team appointed. It also intimated that the design team had provided the safety technical group with an initial overview of the proposed option for Casement Park and that a more detailed submission would be available at the end of November 2012. The safety technical group process was outlined to us in the letter; Sport NI, as the overseeing body, was responsible for recording all agreements, queries and actions required to ensure that the safety technical group was in a position to confirm that all reasonably foreseeable safety scenarios had been considered and anticipated in the design to achieve full spectator capacity within the safety certification process.

The first meeting of the safety technical group for Casement Park was convened by the chair of the group, Paul Scott, in February 2013. At that meeting, Mr Scott basically outlined the role of the safety technical group, and it met again in April, May and September of that year to consider aspects of the design of the stadium brought to it on behalf of the design team by Mr Scott. Over the course of those meetings, a number of queries and concerns were raised regarding the design and, in particular, the egress time. Narrowing in the concourses, uncovered seating, location of concessions and emergency evacuation were the main points discussed. It was quite an unusual design. There were various issues.

A meeting — I have listed our basic engagement chronologically at the end of the report — was convened by DCAL in October 2013 between the STG and the design team. That sat slightly outside; it was not an STG, and we did not receive a minute of that meeting. Mr Carl Southern —

Mr B McCrea: Would you mind clarifying the date in October 2013?

Ms Brown: The date was 16 October. There were various people at that meeting. It was chaired by Mr Carl Southern from DCAL. The issue of emergency exiting was raised, based on a scenario of the Andersonstown Road exits being unavailable because of an incident outside the ground. It was agreed at that time that crowd modelling would be commissioned to establish some additional exiting data. Crowd modelling had already been carried out for exiting under normal conditions. That was to show how a crowd of 38,000 spectators could exit the ground in accordance with the standards set out in the guide. That was put to us, the modelling was shown and it was agreed that that was possible.

Because of a number of complexities, we always look at exiting and emergency exiting together when we are looking at going through the certification process and checking that it is in accordance with the guide. Normally, one would follow on from the other, but, on this occasion, we had a representative on the STG from the PSNI who raised the fact that it was a reasonably foreseeable scenario that, potentially, the exiting at Andersonstown Road could be unavailable for use because of a cordon or security alert. If it was cordoned off, the Owenvarragh and Mooreland exits would be used.

Because of the complexity around the design and its nature, we had asked for the crowd modelling just to see how the main concourse that formed part of the general exiting system would operate if the 72% who were shown in the modelling to normally exit via the Andersonstown Road used that exiting system and whether there were any particular issues around that, and then to develop some sort of emergency exiting strategy based on that additional information. Obviously, when you look at exiting, you look at the exit widths and whether the exiting system is going to be free-flowing at all points. You check whether there is any narrowing and whether that will cause potential issues, and how the rate of passage will be maintained throughout the exiting process. All of those things were looked at.

We felt that, due to the complexity of the design, the fact that there is no outer circulation area in the design of the ground and the fact that the majority of the exiting is to the front of the stadium, we needed this additional information to look at how emergency exiting could be achieved for a crowd of 38,000. We were assured at that meeting that the modelling would be commissioned, that it would be taken forward and that we would be advised early in January. However, to date, we have not received any further crowd modelling or information on the emergency exiting.

I have to say that some of the other issues that I referred to throughout the process were addressed as we went along, such as the narrowing of the concourse and moving concessions, to ensure that those problems did not happen. Suggestions were put forward about the uncovered seating in order to try to mitigate any persistent standing or any of that, because, if it is raining and the seating is uncovered, spectators may migrate into covered areas. Suggestions were put forward to address those issues. I think that it all boiled down to getting the additional information on the emergency exiting.

The Chairperson (Mr McCausland): OK. Thank you. A number of members have put their names down to ask questions.

Mr McMullan: Thanks for your presentation, Valerie. When Paul Scott gave his presentation here and made the comment that referred to a Hillsborough-type disaster, was he speaking on behalf of the Belfast City Council reps on the STG?

Ms Brown: I cannot say that. I think that you have all the minutes of the STG meetings. I have seen them. That was not discussed at the STG, as far as I am aware.

Mr McMullan: Bearing in mind the safety certificates and the licensing system for sports grounds, do you think that there could be a Hillsborough-type scenario, as Mr Scott described?

Ms Brown: In our role as a council on the STG, we were asked, given our experience and the fact that we would ultimately regulate the ground with regard to issuing a safety certificate, to sit in on the safety technical group meetings in an advisory role. The way that was put to us was that we would look at all the scenarios that were presented to us in terms of design and comment on that in accordance with the guidance. We would not have discussed it from that point of view. As a council and looking at the guide, we felt that we needed to get further information with regard to emergency exiting because of the complexity of the design of the exiting systems. We requested that in, I hope, a measured way in that we just felt that we needed that information to look to see how emergency evacuation could be achieved at the ground in a positive way.

Mr McMullan: Do you think that the Hillsborough comment was appropriate?

Ms Brown: I really do not feel that I am in a position to discuss that or comment on it.

Mr McMullan: Did you discuss it at all?

Ms Brown: I did not hear the comment, so I would not have —

Mr McMullan: Have you read the comment?

Ms Brown: I have not, no.

The Chairperson (Mr McCausland): I think that the witness has been fairly clear.

Mr McMullan: I just wanted to clear up whether she had heard it or read it. You have neither heard it nor read it.

Ms Brown: No.

Mr McMullan: Ok. Thank you.

Mr Walsh: Chair, can I make two points at this point? Mr Scott is not an employee of Belfast City Council, so any view that he expressed to this Committee or otherwise was not being expressed on behalf of the organisation that we represent. Secondly, in relation to the other point that has been made, regulatory powers are contained in the safety of sports grounds legislation, which you obviously do not want to have to use, but it is unlikely that a Hillsborough-type scenario would arise when or if issues were identified, because it is likely that measures would be put in place to limit the numbers of people who attend in the event that there was an identified risk.

Mr McMullan: Would you be happy with those comments about Hillsborough to remain on the record?

Mr Walsh: It is not for me to speak for the mind of Mr Scott or others. I will simply say that he is not associated with the organisation that we represent.

Mr McMullan: You were on the STG, were you not?

Mr Walsh: I was not, no.

The Chairperson (Mr McCausland): Neither of them were on the STG.

Mr Ó hOisín: Yes, but he does work for Belfast City Council.

Mr McMullan: The safety certificate that was issued by Belfast City Council in 2010 was for a capacity of 31,661. This capacity would obviously be based on the assumption that that number could safely evacuate the ground in an emergency. Is that correct?

Ms Brown: Yes, that is correct.

Mr McMullan: After the design of a new state-of-the-art stadium by a world-class design team, with exit widths increased by some 50%, the STG is stating that the emergency capacity is now 18,000. Can you explain that on its behalf?

Ms Brown: Yes, of course. The design that has been put forward for the new stadium is very different from the existing stadium. When the safe capacity was determined in 2010 for the existing stadium, we were looking at different standards, for a start, because it was existing construction. It was not new construction; it was an existing ground. A number of issues were associated with that. Number one, there was a fairly wide outer circulation area, which could have been used as a place of reasonable safety. You could have taken the evacuation onto the pitch into consideration in your emergency exiting calculations as well. Also, there were differences in how the ground would have been used. The rates of passage would have been different. At that time, that is what it was calculated at. According to the guide, you cannot take the pitch into consideration in the new design. You can use it, but you cannot take it into consideration in your calculations for emergency exiting. There is no outer circulation area in the new design, and there are limited or no other additional places of reasonable safety other than the exiting systems.

Mr McMullan: Is that your view or the STG's view?

Ms Brown: That is the STG's view, looking at the guidance.

Mr McMullan: Would you say that Mr Scott was wrong, then?

Ms Brown: In what way?

Mr McMullan: About his comments on the evacuation?

Ms Brown: That is supporting those comments, is it not?

Mr McMullan: OK, thank you.

The Chairperson (Mr McCausland): Who is responsible for producing the emergency exiting plan for a stadium? Is it the owner? Someone said to us last week that what we refer to as the "blue-light services" had some responsibility for it.

Ms Brown: The safety certificate is issued to the qualified person. The qualified person for the previous certificate for Casement Park was Danny Murphy, the Ulster secretary. He was responsible for ensuring that the terms and conditions of the safety certificate were met. The people who designed the new stadium should be designing it to green guide standard; in this case, we are looking at the fifth edition of the GB guide. They are responsible for ensuring that all the standards in the guide are met in the new stadium development. We look at the stadium purely from a regulatory point of view. Outside the STG point of view, if we were looking at issuing a safety certificate under our legal obligations, we would look at what is presented to us, and we would base that on their egress time, their emergency egress time and their entrance and exiting capacity. All those things would be looked at, and we would base the safe capacity on that.

You mentioned the confusion around the blue-light responsibilities. There is also an obligation in the standard to have a contingency plan should there be a major emergency that impacts on a ground. That contingency plan should contain arrangements for handover from the safety officer in charge of the ground to, normally, a senior PSNI officer if there is a major emergency. The types of emergency include, for example, serious public disorder at the ground, a gas explosion or a structural collapse — something of that nature, where a major incident occurs and there is a risk to life. You have a contingency plan whereby, at a certain point, where it is appropriate to do so, you hand over responsibility for the management of that incident to, normally, the PSNI. However, that is not the same as looking at having an emergency exiting capacity. That needs to be determined in advance.

The Chairperson (Mr McCausland): Does the responsibility for drawing that up lie with the designers, the architects and the owners of the stadium?

Ms Brown: Very much so, yes.

Ms McCorley: Go raibh maith agat, a Chathaoirligh. Thank you for the presentation. Valerie, you mentioned something, and I wonder if you could explain it a wee bit. You said that the pitch can be used for emergency exiting but cannot be considered when you are creating a plan.

Ms Brown: Perhaps I did not say that correctly. It can be used for the existing stadium, and for the existing grounds and design. You can use it in your calculation for emergency exiting. You can take it into consideration as people being moved on to the pitch, as a place of reasonable safety, but there are caveats about being able to get people off the pitch and into another exiting system.

It is certainly not an ideal situation and would therefore not be considered in new design. The guide clearly states that it should not be considered in determining the emergency exiting capacity from the ground.

Ms McCorley: Are you saying that it cannot be considered?

Ms Brown: Not for new design.

Ms McCorley: That runs contrary to the evidence we received last week from Populous. Mike Trice listed a whole array of stadia that he has been involved in the development of. He seems to have a lot of experience, and he said that the design was safe. We are trying to get through a lot of evidence to establish what is safe and what is not, but he was quite clear that the pitch could be used as a place of relative safety.

Ms Brown: Not in new design. The green guide is very clear that it cannot be used as a place of reasonable safety.

Ms McCorley: There is a clear dispute there. Are you then saying that Mike Trice and Populous are wrong?

Mr Walsh: Can the witness be permitted a moment to find the relevant provision?

The Chairperson (Mr McCausland): That is very helpful indeed.

Ms Brown: Under section 10.9 in the guide, "Emergency evacuation time", it clearly states:

Ms McCorley: There is a conflict, then, between different cases of interpretations —

Ms Brown: I think that it is very clear.

The Chairperson (Mr McCausland): The important thing is that we have now been given the page and paragraph reference in the green guide. That is the one that Mr Trice would have used when he designed grounds in GB, so I am sure he is familiar with it. It is good to have that, and we can get a copy of it circulated to members, but we appreciate Ms Brown clarifying that for us.

Mr B McCrea: Just for reference, it is on page 5 of Paul Scott's papers. We talked about it repeatedly.

Ms McCorley: This question is in relation to the emergency exiting and the potential closure of the Andersonstown Road in a specific scenario. You will be aware, of course, that plan drawings were complete at that stage and planning approval had been sought in June 2013 and that public money had already been spent on the stadium. Why do you think the STG waited until October 2013, after public money had already been spent? Was that appropriate?

Ms Brown: The first STG meeting for Casement Park was convened on 11 February 2013. That is when the issues of exiting etc were raised. Mr Scott, as Chair of the STG, convened that meeting. He provided drawings and gave an overview of the redevelopment. Concerns were raised by the group at that stage. That was set out in an initial review report that was sent to DCAL on 20 February. They included the potential for uncovered seating in areas of the ground to lead to persistent standing —

Mr B McCrea: Which year?

Ms Brown: It was 11 February 2013 — the first meeting of the STG. That initial review document was sent on 20 February. It included the potential for uncovered seating in areas of the ground to lead to persistent standing. The lack of access to the pitch for potential emergency vehicles was also discussed, as were the proposed exiting arrangements, particularly the potential for congestion. The STG was advised by Mr Scott that the architects were developing a flow model that would assist in looking at exiting arrangements. As I said in my initial statement, the emergency exiting normally follows on from the exiting arrangements. So, initially, we were querying the exiting arrangements, and then we wanted to get further information on those so that we could start to look at the emergency exiting, as would be normal practice.

The subsequent meeting, on 12 April, the second meeting of the STG, was attended by Carl Southern from DCAL and Tim Harkin from the GAA. Exiting and emergency exiting were again discussed, but the information relating to modeling and dimension drawings were not available to the STG at that meeting. So, it was difficult to take the discussions further at that time, but, certainly, the issues were raised, and we were waiting for that crowd modelling to look at the exiting arrangements.

On 30 April, we met STG representatives. We were invited to the latter part of a meeting, which is where the modelling for exiting was presented to us. Following that, we progressed through various meetings. The meeting of the STG on 31 May, which was the third meeting, was attended by Mott MacDonald, DCAL, Populous and the GAA. The main discussion was around questioning the representatives from Mott MacDonald on the crowd modelling and the exiting arrangements. Again, that was discussed, and the council again expressed concerns about issues to do with the narrowing of the main concourse and other issues, and with emergency exiting. On 30 July, following a meeting between Belfast City Council (BCC) representative Gerry Donnelly and the chair of the STG and Laura Strong from Sport NI, Mr Donnelly sent an email to Mr Scott and Ms Strong confirming his concerns about emergency evacuation arrangements and the continuing lack of information regarding that and other issues that was coming back to the STG. In particular he mentioned the narrowing of the concourse and the fact that an emergency evacuation plan had not yet been presented to the STG.

The fourth meeting of the STG was held on 5 September. A draft report to DCAL was circulated for comment. The narrowing of the main concourse, the location of the concessions and the need for unimpeded flow when exiting along the concourse were, again, discussed. The issue of restricting traffic flow at that stage was discussed as well, I think, by the PSNI.

On 16 September, the draft report was sent to members of the STG. On 12 September, Gerry Donnelly from the council sent an email to Paul Scott requesting adjustment to the report, again to make sure that those concerns around emergency exiting were reflected in that report that was going to DCAL. That was in September. On 1 October, following several telephone conversations between the council and Paul Scott, Mr Scott sent Mr Donnelly an email correspondence between him and Carl Southern regarding the draft report that he had sent to Mr Southern on 19 September. Mr Donnelly responded to Mr Scott by email, on 1 October 2013, regarding suggested wording for the report in relation to the narrowing of the concourses and the exiting, and he arranged to meet with Mr Scott later that day.

Again, on 15 October, we sent an email to Mr Scott following a meeting with him earlier that day. In the email, Mr Donnelly raised the issue of emergency exiting and suggested that the STG should advise DCAL to request the crowd modelling. We had not received any information to that which was completed for the normal exiting. On 16 October, a meeting was convened by DCAL to discuss that, and that is when we were given the assurance that the crowd modelling would be commissioned.

Ms McCorley: Just bear with me. The red guide is the one that determined exiting using the pitch. Is it the latest red guide that says that you cannot use the pitch? Which edition is that?

Ms Brown: There has only ever been one guide to safety of sports grounds produced in Northern Ireland, and that is referred to as the red guide. That was based on the fourth edition of the GB 'Guide to Safety at Sports Grounds', which is referred to as the green guide. Subsequently, that GB guide was reviewed, and there is fifth edition of it. It was agreed that the red guide — 'The Northern Ireland Guide to Safety at Sports Grounds' — needed to be reviewed and that, when looking at the regional stadium programme, the standard set out in the green guide would be used or, if those standards were higher in the red guide, which is the Northern Ireland guide, than in the fifth and latest edition of the green guide, they would be used, but that it would primarily be the standards set out in the fifth edition of the GB 'Guide to Safety at Sports Grounds' that would be used.

Ms McCorley: In terms of the how the fourth and fifth editions —

Ms Brown: Of the GB guide, yes.

Ms McCorley: What is the essential difference between those?

Ms Brown: There are numerous differences in the standards.

Ms McCorley: In relation to emergency exiting.

Ms Brown: The rates of passage were the main difference. Two interim reports were produced by the STG, and, in both of those reports, comparisons were made and statistics were given on flow rates based on the rates of passage in both guides. So, a comparison could be made.

Ms McCorley: So, it continually changes and continually moves in what it lays out.

Ms Brown: It does not make any fundamental difference to the issues around the complexity of the exiting and the need to look at networks because of that more complex arrangement and design. Both guides support that.

Ms McCorley: I have a final question. Were you one of the consultees for the outline business case of 2009?

Ms Brown: No.

Ms McCorley: You were not consulted. OK. Were you in the council at that time?

Ms Brown: Yes.

Ms McCorley: That is fine. That was the approval for the 40,000-seater stadium in 2009.

Ms Brown: We were not consulted.

Mr Ó hOisín: Thank you, Valerie. We have already discovered during this inquiry that a number of the rulings that we are dealing with are open to subjective interpretation. That has led to inconsistencies, as has been highlighted previously. I will follow up on what the Chair said earlier. You do not accept that the emergency plan is the responsibility of the police and the blue-light services, which was in line with the red guide.

Ms Brown: In our regulation of that and in the certification process, we insist that, for all the designated grounds — this is in the terms and conditions of the safety certificates, including the one for the existing Casement Park — each of the qualified persons or the ground management develop an emergency plan for their ground. They would do that in consultation, obviously, with the emergency services.

Mr Ó hOisín: You said earlier, and I hope I quote you correctly, that the PSNI representative on the STG talked about a reasonable understanding in terms of the Andersonstown Road exiting.

Ms Brown: He talked about a reasonable foreseeable scenario.

Mr Ó hOisín: Yes, OK. If all the parties to the emergency plan were to be consulted, why was the STG going after solely the GAA for an emergency plan? Is it because the GAA was the client?

Ms Brown: Can you repeat the question?

Mr Ó hOisín: Why was the STG demanding that the GAA come up with the document of the emergency plan?

Ms Brown: It is incumbent upon the owners of the ground to produce the arrangements for the ground.

Mr Walsh: It is one step further than that. It is their legal duty to do so.

Mr Ó hOisín: Yes, but all this depends on other sources, such as the STG make-up and the representatives thereon, including the PSNI.

Ms Brown: The council's role on the STG was to advise in relation to the design. We were asked to comment on the design and look at all the various scenarios associated with it. If we had any concerns or issues, we were to raise them, which we did. Issuing the safety certificate is a separate process. That is not done through the STG. It is the council's role to do that, and we will do it once we know what the circumstances are.

Mr Ó hOisín: I get that, but the emergency plan — this is where the inconsistencies appear. When were the emergency plans for the Kingspan and Windsor stadiums issued, before or after the appointment of the contractor?

Ms Brown: I think that we are talking about two different things, with respect. What we are talking about is the emergency exiting capacity of the ground, not an emergency plan. The contingency plan —

Mr Ó hOisín: You have talked about that before, but I am talking about the emergency plan in this case.

Ms Brown: The contingency plan for the ground? We would ask for that as part of a lot of different things that we would ask for in relation to ground management, before the safety certificate would be issued.

Mr Ó hOisín: Before or after the appointment of the contractor?

Ms Brown: I am sorry; perhaps I do not understand you. You will have to excuse me. Are you talking about a contingency plan for a major incident occurring at the ground or are you talking about emergency exiting capacity?

Mr Ó hOisín: I am talking about the emergency plan at this point. This is the one for which the police and the other blue-light services have responsibility. Emergency exiting, there are two [Inaudible.]

—

Ms Brown: No, they are completely different.

Mr Ó hOisín: Yes, one is for inside the stadium —

Ms Brown: Emergency exiting capacity has to be determined at an early stage in the design process, so that we can ensure that the design is going to facilitate the maximum capacity.

Mr Ó hOisín: Roughly speaking, one is for inside stadium and the other is for the immediate environs. Is that not right?

Ms Brown: No.

Mr Ó hOisín: Right. The other safeguard that the STG has is that it is required to sign off on the project pre-construction and also post-construction. Is that not a real safeguard that is included in the delivery of a safe stadium?

Ms Brown: My understanding, and what was set out to me in that letter initially from the permanent secretary of DCAL, was that we would look at the various scenarios that were put to us in relation to the design and we would provide advice and support to the STG around that. Yes, my understanding was that we would present a report, prior to the design being finalised and planning permission being sought. However, as I say, that did not happen.

Mr Ó hOisín: From the design stage, there are two lock-tight devices that will be there: the STG should sign off pre- and post-construction.

Ms Brown: No. The STG will not sign off finally, post-construction. At the end of the day, the safety certification process kicks in, and the council will issue the safety certificate for the safe capacity of the ground and the terms and conditions that are appropriate to managing it and the safe capacity within it.

Mr Ó hOisín: On the back of STG signing off?

Ms Brown: No.

Mr D Bradley: Good morning. Am I right in saying that the main sticking point for the new design regarding emergency exiting was a scenario in which people were unable to evacuate through the main Andersonstown Road exit? The police described a possible exclusion zone being established there. That was the main sticking point.

Ms Brown: It was raised as a foreseeable scenario by a member of the STG and by the police. We then looked at the emergency exiting capacity. The sticking point was really how the exiting system would be used under those circumstances, given that, for exiting under normal conditions, the modelling showed that about 72% of the people would exit via the Andersonstown Road. Given the design, it was really more that we felt that we needed to see how that exiting system and that main concourse would actually work if you took that large proportion of exiting out of it.

As I said before, the concourse is an oval shape and has varying widths. The modelling was able to show the way in which people would exit that under normal exiting conditions. There are parts of that where the flow would be maintained as a free-flowing exit system, and all of the spectators could exit into that free-flowing exit system within eight minutes, as is the required standard. So it was able to show that 38,000 spectators could do that under normal exiting conditions. The issue was, if you took out 72% of the final exiting in that system and you had a concourse, how people would then use that concourse. They would enter into it and travel in it in a different way.

Mr D Bradley: You mean in different directions?

Ms Brown: Potentially in different directions. You could end up with a situation where you had people who perhaps enter into it in a wider part but could potentially then flow into a narrower part, which could then create a funnelling effect, and obviously there would be a potential for crushing. Also, whilst the eight minutes to get people from the seated accommodation and into an exit system is in relation to fire safety, it is also based around experience of, and research on, crowd behaviour. Basically, it is a time that people will be happy to take to get into a free-flowing exit system before panic sets in. What we needed to know was how the concourse, the main exiting system, could operate under those conditions without becoming congested.

There are certain points on that exiting system that would narrow, so you would want to know where those points are. From that, you would also look at the final exit widths. Would they be sufficient to prevent a build-up, which would stop the evacuation being free-flowing and would cause congestion? Because of the complexity of all of that, we needed to see modelling. Even if the modelling showed that 38,000 spectators could not evacuate in the time, at least it would have given us an idea of where the issues where that could have been looked at or modified in the design, should it be identifying other places of reasonable safety or any of those things.

We really just needed that additional information to look at how the emergency exiting capacity could be achieved.

Mr D Bradley: Thanks. That is very useful. Am I right in saying that there was reasonable content that emergency exiting under normal circumstances could be carried out?

Ms Brown: We had concerns about crowd modelling initially. If you look at the guide, you will see that it suggests that there should be an even distribution of exiting or a reasonable number of exits. However, the modelling showed that exiting under normal conditions could be achieved, within the standards, for 38,000 spectators.

Mr D Bradley: Just as a matter of interest, was the exceptional circumstance that the police raised not a consideration when you granted a safety certificate for over 31,000?

Ms Brown: There are various reasons for that difference. First, the existing Casement Park is a completely different design. The standards that we took into consideration for it are slightly different. The existing stadium, for example, has a very wide outer circulation area that could be used as a place of reasonable safety. You can also include the pitch. If you have to evacuate on to the pitch, you can include that in your emergency exiting capacity calculations, which we cannot for new construction. The flow rates were slightly different, and the exit routes were very different. The circumstances as they are at Casement now determined the safe capacity. Basically, there is sufficient emergency exiting capacity for that number.

Mr D Bradley: OK. So, under those circumstances, you were content that the old Casement Park — let us call it that — could deal with emergency exiting even if there was an exclusion zone at the Andersonstown Road.

Ms Brown: In terms of the capacity, yes.

Mr D Bradley: OK. We have been told by a number of witnesses that establishing an acceptable emergency exiting plan was an ongoing process of refinement in the dialogue between you, the STG, the design team and so forth. Is that true?

Ms Brown: It was certainly discussed. The emergency exiting capacity was discussed regularly at meetings throughout the process. You talked about a sticking point earlier. I suppose that the sticking point for us was that it is very difficult for an emergency exiting strategy to be developed without sufficient information to show how the exiting systems would have worked in an emergency exiting situation. The sticking point was the lack of information on flows and crowd modelling.

Mr D Bradley: We were led to believe that you requested further crowd modelling to be done —

Ms Brown: We did.

Mr D Bradley: — and were awaiting that. We were led to believe that the judicial review process then slowed things and prevented further work being done at that time.

Ms Brown: As I said, our involvement in the STG was all through the chair of the STG, so, obviously, we were waiting for him to convene meetings and to discuss the issues. Those things were not really discussed with us at the STG.

Mr D Bradley: They were not discussed at the STG.

Ms Brown: The judicial review and those issues were not discussed.

Mr D Bradley: Were you not aware that a judicial review was ongoing?

Ms Brown: Yes.

Mr D Bradley: Would that not have led you to believe that the process would be halted temporarily or at least slowed?

Ms Brown: Personally, I did assume that.

Mr D Bradley: So, it is reasonable to assume that the modelling information, which you await, was prevented by the slowing down due to the judicial review.

Ms Brown: I cannot speculate.

Mr Walsh: That requires this witness to speculate, and that is a totally unfair question.

The Chairperson (Mr McCausland): I agree. Thank you. I appreciate that comment. I think that it is unfair to ask people to speculate. They can comment on what they know about and the things that they have been involved in, but that is a question for others, and it can be put to others.

Mr D Bradley: OK. I thought that she said previously that she had been aware of the judicial review and that that would affect matters.

The Chairperson (Mr McCausland): Absolutely, and —

Mr Walsh: She cannot speculate on why the requested information was never produced.

Mr D Bradley: As I said, she did realise that the judicial review would lead to a slowing of the process.

Ms Brown: I perhaps should not have said that, in the sense that I was certainly aware of it going on in the background, but it is not for me to speculate around that.

Mr D Bradley: Thank you very much.

Mr Dunne: Thanks very much for your evidence today. It has been very enlightening. During recent evidence sessions, we have talked about the drawings that were developed. We were told last week that the drawings that went forward for planning permission were developed, or brought through, to an operational design. They were submitted, I understand, in June 2013. What input had the STG into these drawings? Are you aware of any STG input?

Ms Brown: With the STG process, as a representative on that group, we were presented with various situations, plans and drawings, some of which were not dimensional or were just outline drawings. There were four STG meetings in 2013, and, at each of those meetings, we were given some drawings, but we were never clear. Whatever we were given was given to us by the chair of the STG, so we could comment only on those drawings at that time. Part of our issue when acting in that role was that issues were being raised, and we were getting drawings that pertained to those issues. It was hard to look at the whole thing in that wider context of design. It tended to be drawings pertaining to issues and particular areas that we looked at or commented on through the STG. Yes, we did see plans and we did comment, and our comments are recorded in the minutes of those meetings.

Mr Dunne: We understand that the drawings that went forward were not signed off by the STG.

Ms Brown: I do not think that it was the role of the STG to sign off drawings. I did not have terms of reference other than the paragraph in the letter from the permanent secretary to say what the role of the STG was. We did not have terms of reference, but we were never asked to sign off on drawings.

Mr Dunne: You were not.

Ms Brown: I do not feel that it is my position to comment on that.

Mr Walsh: I think that the witness, fairly, has set out that the role of the STG was really as a consultative forum. You can see that, within that, there are experts whose information would be relevant and would inform planning, which is very often an iterative process. I think that you need to be careful about elevating the role of the STG to something that it is not.

Mr Dunne: I understand that, but I feel that, in an integrated project team, which is a DFP requirement, there is a requirement to engage with all parties and stakeholders. Safety requirements and standards are paramount, so you would expect early engagement.

Mr Walsh: We accept that. In fact, anyone proposing any development that involves any statutory undertaker would be foolish not to consult and take their ear on the proposals.

Ms Brown: Would it be helpful if I read out again our invitation to be a member of the STG and what we were advised it would involve? The letter from the permanent secretary at the time, Rosalie Flanagan, stated:

We were invited on to the STG in an advisory capacity.

Mr Dunne: I appreciate that, but I still feel that there is a fundamental requirement to be engaged early in the process.

The Chairperson (Mr McCausland): Yes, and that is quite an important point. We will take that up with others.

Mr Dunne: That is fine.

You talked about the PSNI concerns and the "reasonably foreseeable scenario". How do you see that in relation to risk? Would that be relatively high risk?

Ms Brown: From our point of view, the PSNI is a statutory consultee in the certification process. As a member of the STG and a statutory consultee on safety certification, the PSNI raised that as a reasonably foreseeable scenario, so it would have been wrong of us not to take that on board.

Mr Dunne: I appreciate that. Would it be a relatively high risk?

Ms Brown: I cannot comment on that.

Mr Dunne: OK. You talked about the capacity of Casement Park. In 2010, a safety certificate was issued for 31,600. Has there been much recent experience of that size of crowd there?

Ms Brown: I could check, but not in recent times. There have been large crowds at the ground.

Mr Dunne: Yes, I understand that there was a huge crowd for the Michaela event, which was very successful — a relatively huge crowd.

Ms Brown: To be honest, I would have to check. I do not have that information to hand.

Mr Dunne: I understand that about 18,000 people were there.

You talked about the difference between how you would evacuate the new and existing stadiums. Will you outline that again? You talked about a wider circulation area. I take it that that applies to the existing stadium and that the new proposal has no outer circulation area.

Ms Brown: I think that this point may have been raised before. The guide refers to zones, and the new design has no outer circulation zone. The existing stadium is of an entirely different design and has a fairly wide outer circulation zone, which, when calculating the emergency exiting capacity, creates the opportunity for places of reasonable safety.

Mr Dunne: Obviously, you lose those places with the new stadium because it is more spread out and takes up more of the site.

Ms Brown: It is just a different design.

Mr Dunne: A totally different design.

Ms Brown: Yes, but there is a big exiting system via the main concourse in the new design. It is just different from the outer circulation zone.

Mr Dunne: There is little or no outer circulation zone in the new design. Are you aware of any discussion on how to address that to meet requirements for emergency evacuation?

Ms Brown: No, the discussions that we were aware of were on the issue of commissioning additional crowd modelling to look at how the concourse would be used. The exiting system in this case is a place of reasonable safety. It is just how it would be used to prevent congestion during any sort of emergency exiting.

Mr Dunne: Are you aware of any discussions about acquiring properties external to the site?

Ms Brown: No.

Mr Dunne: You are not aware of that?

Ms Brown: No, I am not.

Mr Dunne: OK. That was not discussed at any time that you were aware of.

Ms Brown: At the STG meetings? No.

Mr Dunne: Grand. Thanks very much.

The Chairperson (Mr McCausland): May I pose a question? The paper that you gave to us and to which you refer is extremely clear and comprehensive. It states:

That is still true as of today.

Ms Brown: Yes.

The Chairperson (Mr McCausland): At the beginning of July 2015, there is no emergency exiting strategy. Your paper states that, at the seventh meeting, on 13 November 2014:

That is in the note for that date.

Ms Brown: Yes.

The Chairperson (Mr McCausland): Going back to 16 October 2013, there is a reference to:

Over the period between October 2013 and July 2015 — roughly a year and nine months — an emergency exiting plan has not been produced for the STG to consider.

Ms Brown: No, not —

The Chairperson (Mr McCausland): In your experience of stadiums and certification, have you ever been involved in a process in which someone was developing such a strategy? It seems a very long time. That is what amazes me. I cannot imagine why it would take a year and nine months.

Ms Brown: It should not. If the modelling is commissioned, it should not take that length of time, I would have thought.

The Chairperson (Mr McCausland): Is this done by running a computer programme to produce a figure?

Ms Brown: Yes. For exiting under normal conditions, the modelling for evacuation, for egress, was carried out and presented by Mott MacDonald. I do not know, but I imagine that they would have been the people who could have then been commissioned to do this modelling.

The Chairperson (Mr McCausland): I just find it difficult to understand how it takes a year and nine months, and, at the end of that time, it still cannot produce one.

Mr B McCrea: A letter from Populous dated 7 April 2014 states:

That is a letter from Populous to the owners of the stadium, the GAA.

Is that letter correct?

Ms Brown: Again, I am not sure that I am in a position to comment on it without having the information that we requested on this.

Mr Walsh: Chair, the point that the witness has consistently made is that the modelling was requested in respect of the emergency situation, particularly with the Andersonstown Road exits unavailable, and that, to date, that modelling has not been provided.

Mr B McCrea: There is a statement here:

Is that correct or not?

The Chairperson (Mr McCausland): Sorry —

Mr D Bradley: Chair, can I take a point of information?

The Chairperson (Mr McCausland): I will make my point first, and we will go on from that.

If I understand this correctly, a statement was made in a letter or an email, but no one can know whether it is correct because nobody has ever managed to produce a document.

Mr Walsh: Exactly. Ms Brown cannot comment yes or no because she does not have the information that would allow her to say, "Yes, that's correct" or, "No, it's wrong".

Mr B McCrea: With respect, Ms Brown quoted certain parts of the green guide and the red guide, which I will invite her to restate. I can ask her whether she has some knowledge of the red and green guides. Are you familiar with those documents?

Ms Brown: I am, yes.

The Chairperson (Mr McCausland): Extremely, I would have thought.

Mr B McCrea: The point that I am making is that I have a document, and I am seeking to take advantage of the witness's expertise. The letter is from Mike Trice, who gave witness to the Committee at the last meeting.

Point 9.7 of the red guide refers to the egress time, not the emergency exit time. You may wish to familiarise yourself with that. I want to compare and contrast 9.7 with 9.9. That is where I am going with this, just so that you understand. At the last Committee meeting, Mike Trice said that the emergency exiting time — the eight minutes — was not the time taken to exit the stadium but the time taken to get to an area of free-moving circulation. I know that this is to do with egress time rather than emergency exiting, but point 9.7 of the red guide states:

Ms Brown: That is right.

Mr B McCrea: It continues:

Section 9.9 states:

It refers to the "rate of passage", but to:

It does not mention a comparative place of safety or a relative place of safety; it talks only about a place of safety. Is there any difference between a comparative place of safety and a relative place of safety?

Ms Brown: A place of safety is defined in the red guide at section 15.16:

Mr B McCrea: How does that compare with a relative place of safety?

Ms Brown: The term, "place of reasonable safety", is used and defined in the fifth edition of the green guide.

Mr B McCrea: What zone would that be?

Ms Brown: It could be in any of the zones — well, not in any zone. It cannot be in zone 1 or zone 2. The concourse in the new design for Casement Park could be a place of reasonable safety, because it has hour fire resistance.

Mr B McCrea: That is the argument that Mr Trice put forward.

Ms Brown: I understand that.

Mr B McCrea: I had not picked that up in the earlier design. If the concourse is a place of relative safety, is it acceptable to say that the stadium would comply with the green guide, given that it is mentioned in the green guide.

Ms Brown: I mentioned some of the other provisions and parts of the guidance that relate to exit systems. An exit system should be free-flowing. The rates of passage are taken as maximum, because rates of passage cannot necessarily be sustained over a period. The guidance talks about that. If the exit system is not free-flowing — we know that the concourse is an exit system — and there is congestion in it for some of the reasons I mentioned, it will not be a place of reasonable safety.

Mr B McCrea: A modelling exercise of emergency evacuation was undertaken by Tenos, Mott MacDonald's fire experts, on 26 November 2014. Are you familiar with that report? Have you had sight of it?

Ms Brown: No, I have not.

Mr B McCrea: You might be able to help me. I am happy to give you a copy, or you can just listen. The report looks at the impact of a number of considerations on emergency evacuation time. If all exits on the north stand are unavailable, the modelling produces 29 minutes. Would that be of concern to you? This is on 26 November, just before the judicial review. If 50% of the north stand exits are unavailable, the time is 13 minutes. Are there any mitigating circumstances that you could use to get over the 29-minute exit time?

Ms Brown: When you talk about 29 minutes, is that for final exit, or is that for exit from the seated accommodation?

Mr B McCrea: Unfortunately, all I can give you is the information that I have here. You said that you were expecting modelling. Here is modelling from this date. A number of mitigating factors are mentioned in relation to the 29 minutes, 13 minutes and 10 minutes. There are six variations in the report. The only system that meets the condition of eight minutes is "normal condition; all exits available". If any exit is not available, the time exceeds eight minutes. The figures are nine, nine, 10, 13 and 29 minutes.

The document refers to mitigation measures. I am wondering whether you have any comments on the following:

It is saying that the 29 minutes could be mitigated by using the pitch. It states:

Is that a reasonable statement to make in mitigation?

Ms Brown: It goes back to the issue of confusing contingency planning and emergency exiting capacity. The guide is very clear, and I read the bit from the guide that clearly says that the pitch cannot be considered when determining emergency exiting capacity for the ground. Whether you choose to use it, and whether it is possible to use it as part of a contingency planning process, is a different issue.

Mr B McCrea: That is OK; we are sort of in agreement. I am just looking for elucidation. The next point makes the following argument:

Ms Brown: Again, in determining the emergency exiting capacity, you cannot take evacuation onto the pitch into consideration in your calculations.

Mr B McCrea: I have read clearly — I might finish by asking you why it says that — and I understand that that is not a matter of interpretation and not something on which people have one view or another; it is a DCAL written document that states that you cannot include the pitch in your emergency evacuation.

Ms Brown: For new construction.

Mr B McCrea: For new construction.

The final point in the document, which I think is interesting and is in relation to pitch evacuation, is, in any case:

Even using the pitch does not really improve matters, because you still cannot get people to a place of safety.

Ms Brown: It says clearly in the guide that the pitch cannot be used. I am sorry to keep repeating this, but, without having sight of that document and being able to consider it, I cannot really comment on it beyond what I am saying in not being able to use the pitch in determining the emergency exiting capacity of a ground.

Mr B McCrea: OK. I will move on from that point by confirming that paragraph 9.12 of the red guide says:

I think that you have already quoted from —

Ms Brown: The fifth edition.

Mr B McCrea: — the green guide as well. I think that it was 10 —

Ms Brown: It was paragraph 10.5.

Mr B McCrea: — 10.5. I just want to get it right.

Ms Brown: Sorry — it was paragraph 10.9.

Mr B McCrea: Yes, paragraph 10.9 — emergency evacuation time.

Can I have clarification? What, approximately, is the rate of passage per metre per person on level ground coming from the green guide?

Ms Brown: I would have to look at the figures for that again. Sorry.

Mr B McCrea: You can do the green guide if it is handier. You can tell me the difference, which is really what I am looking for. People ask about the differences between the two guides.

Ms Brown: I will just take the figures from the report.

Mr B McCrea: It might be page 22 of the report that I am looking at.

Ms Brown: The rates of passage per metre on level ground is 82 in the green guide and 109 maximum in the red guide. On steps, it is 66 in the fifth edition and 73 in the red guide.

Mr B McCrea: Before that in the report, there are a huge number of calculations — stand by stand, concourse by concourse — which were evaluated to see the outworkings. Who produced that report?

Ms Brown: Those calculations were produced by Paul Scott.

Mr B McCrea: Do you agree with the calculations? Do they seem reliable to you?

Ms Brown: Yes, we were in agreement with them.

Mr B McCrea: The final point that I want to take you through — it seemed to be quite significant — was that there was a meeting on 16 October 2013. I think that your document states that.

Ms Brown: Yes.

Mr B McCrea: I am looking at some preparatory emails for that. There was one between Carl Southern and Paul Scott on 9 October in which Mr Southern stated:

This is prior to that meeting. The email also mentions:

Does that accord with your recollection that there would have been concern about the emergency exiting scheme at that time?

Ms Brown: Yes.

Mr B McCrea: Subsequent to the meeting that you had on 16 October, there was an exchange of emails in which, amongst other things, people suggested that there was some surprise from the members of the STG that DCAL was surprised that there was a problem.

Ms Brown: Sorry — what email is that?

Mr B McCrea: Let me see whether I can find that one. I think that it was dated round 20 October. Here we go: it was on 22 October between Paul Scott and Carl Southern. It states:

Is that your recollection?

Ms Brown: Yes, I have seen that. We were not copied into those emails at the time, but Paul Scott subsequently sent them through to one of my colleagues.

Mr B McCrea: Would you, from recollection, be able to support the statement in them that emergency exiting had been a concern for quite some time during 2013?

Ms Brown: Yes.

Mr B McCrea: Also, it should not have been a surprise to the Department that it was an issue.

Ms Brown: It was raised, and the Department was present at some of the meetings of the STG at which it was raised in 2013.

Mr B McCrea: OK. My final point is the one that you started with, which is the letter from Rosalie Flanagan, who was the permanent secretary at the time. In that letter, she states:

— I will admit that this is to do with Windsor —

Was that done for Windsor?

Ms Brown: Yes.

Mr B McCrea: Do you recall in what format the STG would have told the Department or the permanent secretary that it had considered those issues and that they were OK? How was that done?

Ms Brown: That was done in the same format as the reports that were put through to DCAL for Casement. It was done in a similar report form setting out the issues.

Mr B McCrea: You would have set out the issues for Windsor but said that, having considered the matter, you were content that the Department should do whatever the Department has to do?

Ms Brown: Yes. We had no other particular issues. Again, we went through a process whereby we addressed all the issues.

Mr B McCrea: Would there have been a conclusion at some stage? You would have said that, yes, you had addressed all the issues and that, on the basis of what you had seen, you were content.

Ms Brown: In our advisory capacity, we agreed that the report that was submitted to DCAL was accurate.

Mr B McCrea: Was there a corresponding report for Casement?

Ms Brown: We sent interim reports through. Three reports were sent through to DCAL on Casement Park.

Mr B McCrea: Yes, but my final point is that, unlike with Windsor, you did not get to the stage at which you were able to say that you were satisfied.

Ms Brown: No. We were still raising issues in those reports.

Mr B McCrea: Would you have felt that you had fulfilled your terms of reference or the guiding principles that you were set up by in saying that you had drawn attention to the matters but that the issue had not yet concluded?

Ms Brown: I am going to say this again: we did not have terms of reference for the STG, but the chair of the STG was certainly taking that approach. He was writing those reports on behalf of the group, circulating them to the group, and then the group was either in agreement or not with what was in the report, and the reports were agreed by all members of the STG before they were submitted to DCAL.

Mr B McCrea: I thank you for the clarity that you have been able to bring to the matter and commend you for the good work that you are doing.

Ms Brown: Thank you very much.

The Chairperson (Mr McCausland): Dominic, you have a point of clarification.

Mr D Bradley: I want to ask about the status of Mr Walsh here. Is he here as a witness who is part of the process of developing the emergency evacuation plan for Casement or as a legal adviser to Ms Brown?

Mr Walsh: I am here as a senior officer of the —

Mr D Bradley: Sorry, I am asking the Chair, not you.

Mr Walsh: Sorry.

The Chairperson (Mr McCausland): The Committee Clerk was the —

The Committee Clerk: Our understanding was that Mr Walsh was required to clarify the position of the council. When we asked Ms Brown to attend, we asked which colleagues she would need for that clarification. We did not enquire any further than that.

Mr D Bradley: Chair, it seems that he is acting as if this were a courthouse, and he is providing legal advice to the witness. That is quite unprecedented in my experience at Assembly Statutory Committees.

Mr B McCrea: Chair, I would like to say that I was supportive when this group across the table asked for the GAA to bring along their advisers and consultants, because people are there to be helpful on this. As far as I am concerned, we called Belfast City Council as a witness. We are trying to find out information, and I entirely support the two people being here; it has been most helpful.

The Chairperson (Mr McCausland): Mr McCrea has made what I think is the key point: we have got clarity around a lot of issues today, and we should be grateful for that.

Mr D Bradley: I am not saying that we have not. I am just saying that, from the point of view of precedent, I have never experienced a Committee at which a witness was accompanied by a legal adviser who intervened on a number of occasions.

The Chairperson (Mr McCausland): Mr Walsh is a senior official of Belfast City Council.

Mr D Bradley: He is described here as the town solicitor.

The Chairperson (Mr McCausland): That is correct; that is his position.

Mr D Bradley: So he is a legal adviser to the witness, then.

The Chairperson (Mr McCausland): He is the town solicitor, and I do not think that we want to detract in any way from the importance of the clarity that has been brought to the issue today.

Mr Humphrey: For Mr Bradley's information, when I was a member of the OFMDFM Committee, a number of religious orders brought legal advisers with them, so this is not a precedent.

I thank you both for your attendance and for the professionalism, clarity and certainly that you, Valerie, have brought to this in your answers. I had many questions, and many of them have just been scored off because of your answers. It is good to get clarity and certainty, instead of people interpreting things as they see them.

Last week, I asked the GAA whether, going forward, it was looking at remodelling its plans for Casement Park. It does not have plans at the moment and is looking at new plans, designs or whatever that will be brought forward in due course. To make sure that the plans that the GAA brings forward on the crowd modelling issue meet the criteria that you have set out clearly today, would I be right in saying, having listened to you, that it cannot finalise those plans and designs until the outstanding information on modelling is provided?

Ms Brown: Again, it depends on what the information is. We would have to look at that and see what the information provides. I have not had access to the report to which Mr McCrea referred, so I am really not in a position to say at this stage. I would need to see what is put forward.

Mr Humphrey: I am not trying to tie you down. Maybe I could ask it in a more general way. In any scenario, in the modelling of any stadium, would you need to have certainty about modelling before design and build could happen?

Ms Brown: Given the complexity of this design, you need to look at a networking approach to exiting. It is not simple exiting, as it can be with other grounds: it is the design. Therefore, we would definitely need further information about crowd flows.

Mr Humphrey: If I am right, you said that emergency exiting has to be addressed at an early stage and that all new stadia have to be built and designed to the green guide standard. I welcome that clarity. We have struggled to get such clarity over the last number of weeks, so I really appreciate it. They have to be compliant with the fifth edition, is that right?

Ms Brown: Yes.

Mr Humphrey: In your experience and professional judgement, Valerie, do you think that a 38,000- to 40,000-capacity stadium, on the site that we are talking about, could meet the green guide fifth edition, particularly when it comes to emergency exiting requirements?

Ms Brown: You are asking me to speculate. It depends on the design.

Mr Humphrey: Exactly. That is fine. That is all I wanted to know.

Mr Cree: Good afternoon. William was saying that a lot of questions have been struck off, and he has struck a few of mine off as well. That is maybe the advantage of coming in at the end, but it also gives you more time to listen to the evidence. I thank you and Mr Walsh for helping to keep the focus. That is very important, and we are not always very good at that.

You explained the main issues. Some people, for example, were telling us not to worry about certification and that the council did that at the end of the exercise. We now know that that is not the case. Others told us that blue light services will sort it out, but that is not the case. Can you clarify the difference between an emergency exiting plan and a critical incident plan? Are they treated in the same way? One comes from without and one comes from within.

Ms Brown: To be honest, the issue that we are addressing at the moment is emergency exiting capacity —

Mr Cree: I understand that.

Ms Brown: — and based on whatever is decided about emergency exiting capacity, you would expect operational arrangements to be put in place as to how it would operate. That should certainly form part of any wider contingency plan that is developed for any major incident occurring. The emergency exiting capacity would be considered as part of the general egress from the ground. You have to consider both together. Can exiting from the ground be achieved under normal conditions? What is the capacity when you look at it under normal conditions? Exiting capacity is one of the factors that would be taken into consideration when determining the safe capacity of grounds.

I said at the start that, for safety certification, you look at the holding capacity, the entrancing capacity and the exiting capacity of the ground. You look at each of those, and whichever is the lowest determines the safe capacity. Emergency exiting capacity is part of the exiting capacity, so the planning for how you achieve the safe operation of that should form part of the contingency arrangements. I do not know whether that is helpful.

Mr Cree: Yes, it is. I can see how they can dovetail. In fact, they would have to be parallel at some stage.

Ms Brown: You cannot separate them completely, but you need to separate them when considering the initial stages.

Mr Cree: You referred to the point that all documents to DCAL from the STG were unanimously agreed. Did you ever have any direct communication from DCAL about emergency exiting? Did you ever respond to or acknowledge it?

Ms Brown: Anything on that that we had was through the STG and the chair of the STG. There were meetings that representatives from DCAL were present at and discussions took place on emergency exiting. We had various meetings where there were representatives from DCAL. Certainly, those discussions would have taken place.

Mr McMullan: Valerie, can I ask you a couple of questions? We talked about emergency exiting. Did you get reports from the STG on emergency exiting for the stadium?

Ms Brown: We were invited to a wider meeting where, certainly, the fire engineer, on behalf of Mott MacDonald, presented some modelling and arrangements for exiting under normal conditions.

Mr McMullan: Was it raised as what they would call a red-flag issue, or was it raised under an ongoing process?

Ms Brown: Do you mean the emergency exiting capacity?

Mr McMullan: Yes.

Ms Brown: It was raised as an ongoing issue.

Mr McMullan: So, it was not raised as a red-flag issue?

Ms Brown: It was raised as an issue in the design.

Mr McMullan: So, it was an ongoing process.

Ms Brown: Over the period that the STG met in 2013, yes, it was raised —

Mr McMullan: So, it was not a showstopper; it was an ongoing process?

The Chairperson (Mr McCausland): It is better not to put words into the mouth of the witness.

Mr McMullan: No, I do not mean to do that. I think you are intelligent enough to know how I am doing this.

It was definitely not a showstopper or anything else; it was an ongoing process?

Ms Brown: The emergency exiting capacity was one of the considerations and concerns that were raised throughout the process.

Mr McMullan: Yes, thank you for that.

Can I go back to the process on not using the pitch? Can the pitch be used as a holding area and a place of reasonable safety?

Ms Brown: The pitch can be used to evacuate people on to. There is nothing in the guide to say that it cannot. When I say that it cannot, I mean that there are issues with that. If you are going to use it, there are certain issues, and the guide specifies that you would need to be able to get people off the pitch via an alternative exit route. The actual requirement in the guide says that you cannot consider it as part of your calculations on emergency exiting capacity for a new construction.

Mr McMullan: Yes, but it can be used.

Ms Brown: There is nothing to say that it cannot be used under certain circumstances.

Mr McMullan: Are we saying there is an interpretation in there?

Ms Brown: No.

Mr McMullan: So, it is hard and fast.

Ms Brown: It is very clear in both —

Mr McMullan: You cannot use the pitch and, at the same time, you can use the pitch.

Ms Brown: No. It is very clear that you cannot consider evacuation on to the pitch as part of your calculations when determining the emergency exiting capacity from the ground.

Mr McMullan: Where does the ground management come in, insofar as the emergency exiting and keeping the people flowing are concerned? You talked earlier, Valerie, about people turning left or turning right and causing a jam and narrowing down the concourse, etc. What is the role of the ground management in stewarding, etc, which your council would have responsibility for?

Ms Brown: Safety management is an essential part of the safety certification process. As I said, you have two factors that you need to take into consideration. You have the physical factors in the infrastructure of the ground, and you have the safety management construction. So, you have a (P) factor and an (S) factor. They go from 0·1 up to 1 for each of those, and you apply those depending on the safety management arrangements. For a new development such as this, you would be striving to have a (P) factor and an (S) factor of 1, and you would expect that for a new construction. So it would be really important that there were good arrangements for stewarding, crowd management and all those things and for the safety officer to be on top of all that.

Mr McMullan: It all feeds into safe exiting —

Ms Brown: Yes.

Mr McMullan: — and work on that.

Ms Brown: It is for the whole use of the ground.

Mr McMullan: How many would the ground hold as a holding area? What is the holding capacity of the proposed —

Ms Brown: The holding capacity for the proposed development was 38,000.

Mr McMullan: On the pitch?

Ms Brown: No, in the seated accommodation.

Mr McMullan: What would the pitch hold?

Ms Brown: I do not know. I would have to look at that.

Mr McMullan: Was that never raised?

Ms Brown: It was not relevant to the calculations, because you cannot count it in the calculations for emergency capacity.

Mr McMullan: As a holding area to a place of relative safety, it would be relevant to know those figures.

Ms Brown: My colleagues could well know them, but, as I say, for calculating the emergency exiting capacity, you cannot take the pitch into consideration.

Mr McMullan: When we got the presentation from Populous last week, we looked at the width of the exiting areas on the old stadium, as we will call it, and the exits of the new one. Are you aware of the proposed changes to the widths of the exits?

Ms Brown: Is this something that has been presented to you more recently by Populous, or is it the existing presentation?

Mr McMullan: It is the change from the old stadium to the proposed new one.

Ms Brown: We would have looked at that. Yes, there was an increase in the widths of the emergency exits to the front of the ground.

Mr McMullan: Would that help to evacuate the proposed 38,000?

Ms Brown: I think definitely that the additional exits and that additional exit width to the front of the ground was important in being able to achieve exiting for 38,000 under normal conditions.

Mr McMullan: Yes. What about the exit widths on to the Andersonstown Road, Owenvarragh and Mooreland?

Ms Brown: I am not aware that the exit widths for Owenvarragh and Mooreland were increased in the proposed plans that we saw. I know that exit widths were certainly increased to the front of the ground.

Mr McMullan: I do not wish to put words in your mouth, but, if the widths of exits to those other areas were increased, along with the increase to those at the front, how would that go with a capacity of 38,000?

Ms Brown: Again, it would certainly be one of the considerations that would need to be looked at in the emergency exiting capacity, because, obviously, that will be a factor in how free-flowing an exit system is.

The Chairperson (Mr McCausland): Oliver, are you anticipating this idea of knocking down houses to widen the exits?

Mr McMullan: No.

The Chairperson (Mr McCausland): I thought that that is what you were suggesting.

Mr McMullan: No, I never mentioned houses.

The Chairperson (Mr McCausland): If the exits between the houses are very narrow, how do you widen them without —

Mr McMullan: I did not mention the exits between houses. I am still in the stadium; I have not left it.

The Chairperson (Mr McCausland): Does the stadium not lead out into Owenvarragh and Mooreland?

Mr McMullan: I am sure that, yes, indeed it does, but I am talking about the doors leading —

The Chairperson (Mr McCausland): I asked just to get clarity on that, that was all.

Mr McMullan: I am a wee bit like Elvis; I have not left the stadium.

I am trying to get this whole thing, to see where we are with all this, between the council, the designers and all that. I appreciate what you are saying. However, we have it here that the time for the maximum capacity to exit by the side streets in the existing Casement Park is 5·4 minutes.

Ms Brown: What is the question?

Mr McMullan: If the widths of the doors were increased, would that help, along with the proposed increases at the front?

Ms Brown: As I said, I would need to see all the information so that I could look at it and see how that would work out. I have not had sight of that.

Mr McMullan: OK. There is no point in that. Thank you.

Mr Ó hOisín: If this morning's presentation has done anything, it has highlighted the inconsistencies across the board that were flagged up previously when dealing with the three different stadia. Because Casement is a new build, different criteria are obviously being applied, and the pitch could not be used. If it is any help to Oliver, the Populous people said in their presentation last week that the pitch could safely accommodate 58,000 people as a place of reasonable safety. They further stated that, in the concourse area, which was defined as a place of reasonable safety, a further 38,000 could be accommodated. Those are the figures. We are looking at different criteria being applied for new build for Casement and non-new build for Windsor and Ravenhill.

Ms Brown: No, no.

Mr Ó hOisín: Can you explain?

Ms Brown: Windsor Park and Ravenhill are both being looked at as new build.

Mr Ó hOisín: But in the case of Windsor is the pitch a place of reasonable safety?

Ms Brown: No.

Mr Ó hOisín: It is not?

Ms Brown: It is not considered in the emergency exiting capacity calculation.

Mr Ó hOisín: But is it considered a place of reasonable safety? Is it there in the case of a contingency plan?

Ms Brown: The arrangements are the same in the new design for the new Windsor Park stadium. The pitch will not be considered and has not been considered in the emergency exiting calculations for the ground.

Mr Ó hOisín: This is where the uncertainty still exists, Valerie — the definition between the emergency exiting strategy or plan and the contingency plans. That is what I was trying to get at.

Ms Brown: No, no. I will certainly try to clarify it again. I am sorry if I have not made it clear. What you need to look at is the emergency exiting capacity of the ground. When you are looking at normal exiting capacity, which is a determining factor when you are determining the safe capacity of the ground, you also need to look at the emergency exiting capacity. When you are calculating the emergency exiting capacity of the ground, you may not, according to the guide, take into consideration the use of the pitch as a place of safety: you may not take evacuation on to the pitch into your calculations in determining the emergency exiting capacity. When you are looking further down the line at developing a contingency plan for a major incident, you would certainly then take account of your exiting systems and emergency exiting capacity, systems and processes around that. In the development of the stadium at Windsor Park and Kingspan at Ravenhill, evacuation on to the pitch was not considered when calculating the emergency exiting capacity for those grounds.

Mr Ó hOisín: Yet paragraph 10.9 says:

It is quite clear.

Ms Brown: It goes on to say that you cannot consider the pitch for a new construction.

Mr Ó hOisín: What about the concourse?

Ms Brown: The concourse is.

Mr Ó hOisín: Populous told us that the concourse could safely accommodate 38,000 people.

Ms Brown: The other thing, though, is that the concourse is an exit system, and an exit system —

Mr Ó hOisín: Sorry; you said earlier that an exiting system, as proposed, is a place of reasonable safety.

Ms Brown: The concourse is a place of reasonable safety from a fire-safety point of view, in that it has hour fire protection. It is an exit system and therefore has to be free-flowing. You cannot faithfully hold 38,000 people in that concourse without them moving.

Mr Ó hOisín: Chair, I am not sure that we are going to get to the bottom of this, but —

The Chairperson (Mr McCausland): I thought that we had.

Mr Ó hOisín: As an aside, can I just ask whether Mr Walsh is here in his own right? He stated that Paul Scott was never a council employee.

Mr Walsh: I did not say that; I said that at the time that he was involved in this group, he was not a council employee.

Mr Ó hOisín: He has been employed by the council.

Mr Walsh: He has, yes; in the past.

Mr Ó hOisín: He has.

Mr Walsh: Yes.

Mr Ó hOisín: At what time was he not employed by the council?

Mr Walsh: I do not have that detail with me, Chairman, but it was some time ago when he left the council.

Mr Ó hOisín: Can you get us those details?

Mr Walsh: About when he left or when he was in employment? Yes.

Mr Ó hOisín: About when he was employed by the council.

Mr Walsh: It was quite some time before any involvement with this.

The Chairperson (Mr McCausland): Finally — very finally and briefly, because the lunch is waiting — Basil McCrea.

Mr B McCrea: No; I will take the same time that colleagues were entitled to. I want to ask a question just for clarity on the issue. Would it be fair to say that the capacity of an exit system is limited by its most restrictive element?

Ms Brown: Yes, that is what the guide states.

Mr B McCrea: Does the guide also say that it makes no difference to the efficiency of the system where the most restrictive element is located?

Ms Brown: Yes.

Mr B McCrea: And that the capacity is always determined by it?

Ms Brown: Yes.

Mr B McCrea: This is the issue of whether you look at exit widths or reservoir areas. Let me make this clear: there is no ambiguity. It is quite clearly written down in the guides, a DCAL document and a UK guide. It is not ambiguous; it is clear. Were the emergency exiting schemes a matter of concern to the STG in 2013?

Ms Brown: Yes.

Mr B McCrea: Was it a trivial concern? Was it a concern — one of many — or was it a significant concern?

Mr McMullan: Chair, he is leading the witness.

Mr B McCrea: I am not. These are open questions. I am just asking whether it was a concern. It was of significant concern. Could you tell me what Rosalie Flanagan, the previous permanent secretary, meant when she stated:

What does that mean?

Ms Brown: My interpretation of what she meant was that it was important in the regional stadia programme to have grounds designed that would achieve maximum capacity.

Mr B McCrea: This is my last thread on this. Some members have set considerable store by the fact that people mentioned the word "Hillsborough" and said that that could never have happened, because there would have been certification issues that would have come along. Would I be correct in assuming that, if a physical build passed through planning for 38,000, or 34,000 for that matter, and the emergency exiting scheme could not be satisfactorily resolved, the certification might have resulted in a lower capacity for the stadium?

Ms Brown: Yes.

Mr B McCrea: So, the risk is that there is a risk to public finance, in that you might build a stadium for 38,000 and end up being able to put only circa 18,000 into it.

Ms Brown: Which is why it was so important that the design was considered and looked at as we went along and any issues that needed to be resolved were dealt with.

Mr B McCrea: You are clear that that information would have been available to DCAL and that it would have been aware of the potential problem if the emergency exiting scheme was not satisfactorily addressed.

Ms Brown: Yes, it was in the report.

The Chairperson (Mr McCausland): Thank you.

Mr McMullan: Just to follow on from what Basil said, you could have a building that could be too big for the exiting plan that you have. When was the certificate given to Ravenhill?

Ms Brown: It was issued to Ravenhill in April.

Mr McMullan: And also to the other —

Ms Brown: It was for the new development. The final safety certificate was issued on 5 April 2014.

Mr McMullan: How close was that to the opening?

Ms Brown: Just before the opening.

Mr McMullan: Was it built before the certificate was given?

Ms Brown: Yes. It would have to be finalised.

Mr McMullan: So, the building was built before the certificate was given out.

Mr Walsh: You cannot not have it that way legally.

Mr McMullan: Could you build something that would not be compatible with emergency exiting, as Mr McCrea just stated?

Ms Brown: The certificate will be used to determine what the safe capacity of the ground will be. You can have a much greater holding capacity in a ground, but the safe capacity of that ground, under the certificate, could be much lower, because it could be limited by entrancing, exiting or emergency exiting.

Mr McMullan: Would all those things be done through the design process in consultation with you?

Ms Brown: I thought that that was the role of the STG.

Mr McMullan: So, in a sense it would be nearly impossible to have a building there with a lower capacity than it was built for.

Ms Brown: Legally, we would issue the safety certificate for the safe capacity of the ground.

Mr McMullan: This is my last question, Valerie, and thanks for your patience. I will go back very quickly to the holding capacity for the emergency exiting. You read out what was in the green book. Is there no way round that at all?

Ms Brown: You mean the pitch not being used as part of the calculation?

Mr McMullan: Yes.

Ms Brown: No.

Mr McMullan: Is it down to capacity? What is it down to?

Ms Brown: You cannot use the pitch when you are calculating your emergency exiting capacity.

Mr McMullan: Yes. Where do you get the numbers to calculate? Is that an ongoing process as well?

Ms Brown: That is where we are asking for the additional information so that we can look at that.

Mr McMullan: So, we have not got to that stage yet; it is still an ongoing process of design.

Ms Brown: It is, yes.

Mr McMullan: There are no red flags anywhere?

Ms Brown: I do not understand what you mean by that.

Mr McMullan: OK. Thank you.

Mr Humphrey: It was made very clear last week — I made this point earlier — that the GAA said that it has no designs.

I will just say that we have invited Ms Brown and Mr Walsh here because of the expertise and experience that Belfast City Council provides. Ms Brown has quoted facts from guidelines. Belfast City Council's health and safety record, whether for sports grounds or anything else, is exemplary. It has a huge event on this weekend. Members and parties are absolutely at will to make their own judgements and to take positions based on evidence that is provided. However, to the best of my knowledge, having listened to Valerie's presentation today and the evidence given, the case is factually based. So, it is not in order for members to say, "I'm not sure if we will get to the bottom of this", because what has been presented is factual and based on guidelines that are produced by the Department that we scrutinise and in the green guide, which governs stadia across the United Kingdom.

The Chairperson (Mr McCausland): Thank you indeed. I thank Valerie and John for their evidence. You were with us for well over two hours. You have been very helpful.