CARDIFF COUNCIL CYNGOR CAERDYDD

EXECUTIVE BUSINESS MEETING: 17 APRIL 2007

INTERNATIONAL SPORTS VILLAGE

REPORT OF CORPORATE DIRECTOR AGENDA ITEM: 4

PORTFOLIO: CORPORATE

Reason for this Report

1. This report is to seek the Executive’s approval of a competitive tender exercise in relation to disposal of the remaining part of the Sports Village retail site and to report recent progress at the site.

Background

2. Phase 1 of the Sports Village development has been completed. The road infrastructure and utilities works are complete, and Morrisons and Toys R Us are trading. 50% of the receipt for the residential site has been received, with the balance due in April 2007, and the 50 metre pool is due for completion at the beginning of January 2008. Practical Completion for the temporary ice rink was achieved on 8 March 2007 and the temporary rink is fully operational, some snagging work to the temporary rink remains to be completed including repainting of the external walls which requires a period of continuous of dry weather.

3. Financial appraisals and construction programmes are being updated for Phase 2 of the development which includes the multi purpose arena, snow box, hotel, parking infrastructure and the Olympic standard canoe centre. Discussions have commenced between the Council and a potential operator in respect of the proposed new multi purpose Arena at the Sports Village.

4. was contacted and asked to submit evidence by the Merits Committee of the House of Lords in respect of the debate in both Houses of Parliament concerning the Regional Casino, and a copy of Cardiff’s “Call for Evidence” submission to the House of Lords is attached as Appendix A. The House of Lords was critical of the recommendation by the Casino Advisory Panel to site the first regional casino in and the draft order containing the casino legislation was rejected by the House of Lords on Wednesday, 28 March 2007. In view of the inevitable delay to the casino legislation, appraisals are being developed which will allow phase 2 to proceed with or without a Regional Casino.

Page 1 of 3 Issues

5. The Executive at its meeting on 14th November 2006 agreed that the Retail Agreement of 9 June 2004 (as varied) with Bride Hall Developments Limited be extended until 31 March 2007 and if Heads of Terms are achieved for a suitable disposal by that date then by a further three months from that date.

6. Bride Hall has failed to locate a retail operator for the last remaining site and therefore their agreement needs now to be formally terminated. Following this there is a need to dispose of the site to a new bidder, developer, or owner operator who can provide the necessary land receipt in order to realize a capital receipt to finance outstanding commitments on Phase 1 and to progress Phase 2 of the development at the Sports Village. The site needs to be advertised for sale on the open market for disposal by means of a competitive tender with the option of both an unconditional bid and a conditional bid which will then have to be assessed by the Council’s specialist advisers.

Reasons for Recommendations

7. The outstanding retail receipt is required as quickly as possible so as to cross-subsidise the phase 2 leisure development

Legal Implications

8. There are no legal implications arising in respect of this report.

Financial Implications

9. The balance of the retail receipt is an important component in the funding of the outstanding commitments that remain from Phase 1 of the Waterfront development, which include:-

• The 10 year subsidy to be paid to the pool operator, there is also a financial risk to the Council if actual NNDR payments are above the base figure in the operator’s business plan. • Payment of the outstanding residential overage due to Orion Land & Leisure Cardiff Ltd. • Commuted sums for the road network.

A further report will be required when the updated financial appraisals and programmes are produced for phase 2 to demonstrate the financial implications for the Council and to approve any actions necessary.

Page 2 of 3 RECOMMENDATIONS

The Executive is recommended to agree that

1. the current Development Agreement with Bride Hall for the retail site at the International Sports Village be formally terminated.

2. the remainder of the retail site at the International Sports Village be advertised for disposal on the open market by means of a competitive tender with the option of both an unconditional bid and a conditional bid which will then have to be assessed by the Council’s specialist advisers.

TOM MORGAN Corporate Director 2 April 2007

The following appendix is attached:-

Appendix A – Casino - Call for Evidence

Page 3 of 3 APPENDIX A

Casino Call for Evidence – March 2007

Question 1 – Introduction. Briefly summarise the characteristics of your bid. Was it linked to a specific site or area, was it part of a wider development project or stand-alone?

Answer - The Cardiff bid is a fundamental part of a wider project intended to deliver the regeneration of the most socially deprived areas of the City and to support sport and the healthy living agenda leading up to the 2012 Olympics.

1.1 The proposal for a Regional Casino made on behalf of Cardiff Council is a major regeneration of an urban brownfield site located at the Cardiff International Sports Village (CISV) directly alongside Cardiff Bay, in what is acknowledged as one of the most socially deprived areas of Wales and the UK.

1.2 Following the establishment by the Government of the former Cardiff Bay Development Corporation, large scale land reclamation was carried out in South Cardiff and the key to continue this regeneration into the west side of the Bay is the completion of an arc of entertainment extending from the Inner Harbour to the site of the Cardiff International Sports Village.

1.3 CISV is one of the most exciting sports, leisure and entertainment destinations in the UK which will include a world class swimming, snow and ice complex, Olympic-standard canoe course, luxury and family hotels, retail, restaurants and apartments, plus a multi-purpose arena suitable for a range of sporting events, concerts and conferences. Also included within the scheme is a major casino which has been a core element of the project since planning consent was granted for the facility back in 2003.

1.4 A regional casino will provide the ability and means to bring forward and deliver a host of facilities which would enable Cardiff to play a full and active role in supporting the 2012 Olympics as a training venue for home and visiting teams. Similarly it would reinforce Cardiff as a major visitor and tourist destination and have a significant impact on the city-region economy.

1.5 CISV will provide some 5,000 jobs, 1,500 directly related to the regional casino, 3.24m visitors per annum, 2.6m related to the regional casino, the operation of the regional casino and hotel would result in an additional £65m of GVA pa in the local economy and an additional £26m of GVA accruing from the construction phase.

1.6 Following a rigorous competitive tendering exercise, the Council with its development partner Orion Land & Leisure (Cardiff) Ltd and the Department of Enterprise, Innovation and Networks- DEIN (formerly the WDA), identified Aspers as the preferred operator for the Regional Casino.

1.7 The Council is fully committed to plans for a Regional Casino which was reinforced in 2005 by a decision by the Council that CISV was the only location supported for a Regional Casino. In March 2006 the Council’s Licensing Committee recommended that it would give favourable consideration to an application for a licence for a Regional Casino at CISV.

Question 2 - Submitting your bid. Were the instructions on how to submit your application clear in terms of what was required and by when? Did you feel you had enough time to prepare your bid?

Answer - Throughout the selection process there have been a number of instances where the CAP has failed to provide clear guidance in relation to the type and nature of the submission required.

2.1 Details of the opportunity to make proposals to the CAP for casinos were made available to the Council through its working relationship with DEIN, as no details were directly received from CAP in the initial period for receiving expressions of interest i.e. 31 st December 2006. (Clause 28- Final CAP Report).

2.2 The original guidance for the first submission required was clear in that it required concise and relevant evidence limited to not more than 20 pages to be returned by no late than 31 st March 2006.

2.3 Following CAP’s initial sifting exercise and the publication of the shortlist detailing the local authorities to be invited into the next stage; there was much confusion and uncertainty from both successful and unsuccessful applicants as to the next stage of the process, during which submitting authorities were given an opportunity to provide CAP with additional information. Only after repeated attempts to contact CAP was the issue resolved. However, even though additional information was submitted, CAP did not issue a revised ranking.

Page 1 Casino Call for Evidence – March 2007 2.4 On 3 rd August 2006 the Council was asked to provide a written statement to CAP summarising the key merits of the proposal in no less than 1500 words by no later than 10 th August. Similarly CAP asked for the return of 16 additional specific questions plus supporting details originally by no later than Friday 18 th August. However on 3 rd August this was shortened to a return date of Monday 14 th August 2006. Also at the same time CAP had agreed to accept supplementary statements from Councils if the information was new and compelling. This placed great pressure on the Council to provide appropriate information to CAP in a shorter timescale.

2.5 On 31 st July 2006 CAP released a press statement advising that the Cardiff EiP would be held on Friday 1 st September. However it was not until Friday 18 th August 2006 that CAP confirmed the details of the venue and selected matters for the Cardiff EiP. Even as late as Tuesday 22 nd August 2006 CAP was still contacting potential participants to attend the Cardiff EiP during a prime holiday period.

2.6 The amount of information requested and the timetable involved made this a very difficult period in which to both provide the details to CAP and also to obtain clear, precise information from them in return. It was therefore very difficult to make contact with the staff at DCMS (in support of CAP) and the information they provided was often unclear, hesitant and referred to other colleagues for clarification in a number of circumstances.

Question 3 - Selection Criteria. What was your understanding of what was meant by “regeneration” and by “the best possible test of social impact?”

Answer - Our understanding is that regeneration is not just about investment in land and buildings, but most importantly, it is about investment in people and future sustainability.

3.1 In addition to the more traditional measures that the Casino Advisory Panel use to define regeneration Cardiff Council believes that urban regeneration and renewal must also combine the physical regeneration of land and buildings, including the improvement of environmental conditions, with investment in human socio-economic capital, and must incorporate measures that ensure local communities benefit from the investment in improved physical infrastructures and employment opportunities.

3.2 While environmental and housing deprivation can be addressed through physical investment in land and buildings (traditional regeneration), real regeneration must include investment in real people, so that they are more able to engage fully with the opportunities made available through the location of new employment opportunities. Real regeneration can only be achieved if the residents of an area targeted for physical regeneration are engaged holistically in the process. Locations of this nature are usually suffering from multiple types of deprivation, for example: Income deprivation; Employment deprivation; Health deprivation; Housing deprivation; Skills & educational deprivation; Environmental deprivation & access to services deprivation.

3.3 Any successful proposal for a Regional Casino Bid must contain comprehensive details of the measures already in place, or being planned, to ensure that the full regeneration benefits of a regional casino licence would be passed on to local people and communities, benefiting some of the most deprived communities in the UK.

Best Test of Social Impact

Answer - As the legislation currently only provides for a single regional casino licence, it is hard to see how any one area in the UK can be a best test of social impact, however under these difficult circumstances for any one area to be seen as the best possible test of social impact we believe it should satisfy the following characteristics:

• It must have a range of social and demographic characteristics that are comparable with national statistics. • It must also have appropriately diverse social and demographic characteristics in order that the social impacts can be evaluated on as wider a cross-section of the UK as possible, including minority ethnic communities, religious groups, and students. • It must be a geographically contained area in order that the true social impact can be monitored in isolation of other ambient factors. • It must have a defined catchment area that contains a sufficient range of geographic areas and types of location that might be suitable for future casino developments including urban centres, rural areas, and seaside resorts. • It should have in place a strong local research base, baseline data against which the social impacts can be evaluated evidence of past assessments of the impact of major developments. • It must be willing and able to undertake the research that is required.

Page 2 Casino Call for Evidence – March 2007 • It must have in place strong and established partnerships both within the local communities, local authority area and with adjacent local authorities through which to monitor the impact of the casino.

Question 4 - The criteria and your bid. Do you think your bid best met the selection criteria and, if so, why?

Answer – Yes, Cardiff as the capital city of Wales, best meets the selection criteria as defined by CAP.

4.1 Cardiff is not just a city; it is a capital city and a major regional and international destination. Cardiff and its city-region offer an exceptional set of circumstances which we believe are the best in the UK on which to test the social and economic impacts of a regional casino development.

4.2 Cardiff Council, the Welsh Assembly Government and other key public and private sector partners are fully committed to the proposal, and the development opportunity is available immediately

4.3 Cardiff’s key social and demographic characteristics are close to the Wales and UK average, represent the “world in one city”, and would provide a robust opportunity to evaluate the economic and social impacts of a regional casino. Cardiff has a diverse and cosmopolitan population and the highest proportion of ethnic minority residents in Wales, residents following all major world religions, over 56,000 residents in the 10% most deprived areas of Wales, 90,000 residents in the 10% least deprived areas of Wales and over 30,000 higher-education students.

4.4 Cardiff has an outstanding track-record of delivering major regeneration projects - on time and on budget and the completion of the development would deliver real and tangible benefits to local communities and will be the catalyst for a wide range of complementary regeneration activities across the city and Wales. Cardiff has excellent transport links and is located on the national motorway network which allows access to 80% of the UK population within 4 hours.

4.5 The benefits of the casino operations would go far beyond the casino itself. A regional casino in Cardiff would deliver a significant package of social and regeneration benefits, totalling £76.5m, to some of the most deprived parts of Cardiff and the UK. These communities would benefit further from a Community Trust Fund supported with a one-off community contribution of £2.5m and further annual contributions of £0.5m

4.6 The proposed site for the regional casino is a self-contained destination which will allow for the social impacts of gambling to be easily isolated from ambient social changes, and proactive steps have been already been taken to address the issues of community impact and gambling problems including the establishment of the Cardiff Community Action for Responsible Gambling (CARG). Well established policies, regarded as international best-practice, that have been formulated to ensure that gambling is conducted in a sustainable, safe and socially responsible manner would be implemented to deal constructively and proactively with any problem gambling.

4.7 Cardiff’s submission is supported by some of the most detailed economic impact modelling available in the UK and the proposal will ensure that employment opportunities are made available for local people and those who are long-term unemployed and economically inactive.

Question 5 - Evidence in Person. How useful were the evidence in person sessions?

Answer - Whilst the EiP provided the Council and participants with an opportunity to discuss the proposal with CAP we believe the EiP was of limited use because of the rushed programme, overall timing and organisation.

5.1 The date of the Cardiff EiP, 1st September 2006, was announced on 31 July 2006. However it was not until 18 August that CAP confirmed the details of the venue and selected matters. Even as late as Tuesday 22 August CAP was still contacting potential participants to attend the Cardiff EiP during what is a prime holiday period. This gave many preferred participants very little notice of the invitation to attend. For some senior candidates e.g. the First Minister and the Directors of DEIN or Visit Wales this meant they were unavailable due to unavoidable existing diary commitments, which was the loss of a valuable opportunity for CAP to question key stakeholders on the details of Cardiff’s proposal.

5.2 The Council’s preferred casino operator Aspers made a direct request to CAP to attend the EiP as they believed they could provide valuable information on many of the key attributes of the proposal.

Page 3 Casino Call for Evidence – March 2007 However their request was rejected by CAP. Again this meant the loss of a valuable opportunity for CAP to question a key stakeholder on the details of Cardiff’s proposal. On this very point one of the criticism of Cardiff’s proposal in the final CAP report was a lack of clarity in relation to community benefits and the establishment of a Community Trust Fund (Clause 136-Final CAP report). We believe any uncertainties would have been resolved had Aspers been invited to participate. In addition it was not until the morning of the EiP that the Council’s development partner Orion Land & Leisure (Cardiff) Ltd were invited to participate.

5.3 The Chairman of the Cardiff CARG (who is an employee of Aspers), was invited to attend the EiP as a participant, however the questioning by the Chairman of the Panel didn’t openly expand on the work and support proposed by CARG, but rather on the role and influence of Aspers. Again the opportunity for the Panel to fully discuss and understand the role of CARG and the community benefits it could provide weren’t expanded or examined further.

5.4 The Council formally offered to provide CAP with the opportunity to undertake a guided visit of the project and proposed site this wasn’t taken up although it is understood that Panel members attempted to visit CISV the night before the EiP.

5.5 Despite this the ability for the Council and the other participants to discuss and debate the Cardiff proposal with CAP was a welcome benefit following the preparation and submission of countless written responses. However the short-track programme and number of EiPs throughout the UK (7 in 11 days) must have been extremely challenging for Panel members and one must question whether sufficient time was given to prepare and debrief for each session.

5.6 Finally following the Cardiff EiP no minutes or record of the discussions held were released by CAP nor was any feedback from the Panel received.

Question 6 - Other Issues. Have you any other observations to make on the selection criteria or process?

Answer - Cardiff Council would like to express concern over the process by which the selection criteria were arrived at. We believe that this process led to a poorly defined set of un-weighted criteria for the Casino Advisory Panel to assess the bids submitted for a Regional Casino and that these criteria could not form the foundation for an objective evaluation of the bids.

6.1 When the DCMS published the Terms of Reference for the Casino Advisory Panel in August 2005 they stated that the criteria against which the Panel will assess submissions were set out in a Statement of National Policy on Casinos published in December 2004. However the actual criteria listed in the Terms of Reference clearly differ from those published in December 2004 by including a new primary consideration in relation to social impact and by excluding the need to identify a good range of types of areas and geographical spread across the UK. The document published in August 2005 stated:

6.2 The primary consideration will be to ensure that locations provide the best possible test of social impact. Subject to this, the criteria will also be:

• To include areas in need of regeneration (as measured by employment and other social deprivation data)and which are likely to benefit in these terms from a new casino; and • To ensure that those areas selected are willing to license a new casino.

6.3 Subsequently in the Casino Advisory Panel ‘ Call for Proposals 31 January 2006 ’ the Panel requested that proposals submit information under a total of 8 headings including Social Impact and the Need for Regeneration. However the actual criteria against which the Panel were to assess the final submissions, as set out in Chapters 3, 4 and 5 of the Panel’s Final Report, were at no time made available to those submitting bids. This, coupled with the lack of continuity between the 2004 Policy Statement and Terms of Reference, made it very difficult, in our opinion, for submitting authorities to put forward a complete case in support of their bids.

6.4 In their document “Call for Proposals 31 January 2006 ” CAP confirmed that they required each submission to address eight sections as follows Type of Area, Social Impact Need for Regeneration, Willingness to licence, Probability of Implementation, Regional Context, Community benefits and Unique Characteristics. However no weighting details were set out and subsequently in their review of the first stage process CAP advised that all key lines of enquiry carried equal weighting so they had no regard to the primary consideration for their terms of reference as detailed above.

6.5 In a report commissioned by the Council, Professor Terry Stevens believes the initial selection process was flawed as the 8 criteria used by CAP were given equal weighting despite some criteria being subjective and others objective measures. The final CAP report heavily emphasises the importance on

Page 4 Casino Call for Evidence – March 2007 measuring social impact yet this criteria is not singled out for special review in the initial assessment. Indeed Professor Stevens makes the point that the Panel makes great play about the importance of the social impact, despite admitting to having difficulty in defining and measuring this criteria.

6.6 In another report commissioned by the Council Professor Leighton Vaughan-Williams has advised that if the scores for the primary consideration are utilised then Cardiff’s position in the ranking moves up to third rather than joint seventh as CAP originally reported.

6.7 Also Professor Stevens makes a number of other observations namely that throughout the CAP reporting process the emphasis is upon Regional Planning Boards (of which there is no equivalency in Wales or Scotland), there is a constant struggle to understand the prevailing planning systems in the devolved governments and the language used throughout by the Panel clearly confuses what they mean by “national.” In addition there are clear differences in the way statistics are gathered and measured affecting some criteria. Also he suggests that there is an overemphasis placed upon the importance of policy guidance provided by Government in England compared to the emphasis given to similar guidance given by the devolved governments.

6.8 Similarly Professor Leighton Vaughan-Williams makes the point that CAP declare themselves impressed that Manchester (with Sheffield and Newcastle) is one of England’s eight “Core Cities” which it is asserted , are seen as drivers of national and regional economic growth. However neither Cardiff of can compete if this test is held as an important criterion in determining a bids success. This is a real issue for Wales & Scotland as it fetters the ability to compete against the English core cities such as Manchester. It should also be noted that the regional and all 8 licences for the large casinos are located in England as are 6 of the 8 licences for small casinos. Wales & Scotland have been allocated 1 licence each for a small casino, whilst the casino Statement of National Policy stated that CAP be asked to identify areas for the new casinos which will provide a good geographical spread of areas across Britain.

6.9 Turning to regeneration, in clauses 90, 91 & 101 of the Final CAP report, the focus is linked to the tourism potential of a destination and the scope for tourism to drive regeneration and therefore have a social impact. Professor Stevens makes the point that the way the Panel have chosen to develop their social impact argument effectively disregards the transient tourism markets in a destination. In short, the Panel appear to have been driven by the best location to test social impact not the best location within which a holistic approach to regeneration can succeed. This was not the impression given by Government as to the reason for developing a regional casino.

Question 7 - Costs. How much did the preparation of your bid cost?

7.1 As mentioned CAP were very clear in the type of document they required, i.e. a concise evidence based document and not a marketing brochure. Therefore the Council were very conscious of this requirement and the majority of the work undertaken together with the submissions made were carried out by existing staff with specialist advice from Professor Leighton-Vaughan Williams and Professor Terry Stevens. Therefore the cost of making the submission was approximately £20,000.

Question 8 - Improving the Process. Should a similar exercise be held in the future, how could the bidding, assessment and selection process be improved?

Answer – A clear process identifying a set of criteria which allow an objective assessment of the bid.

8.1 Initially a clear, uniform bidding or proposal process needs to be established and in place from the start. Although proposals should be invited as part of the process, candidates should all complete a proposal document released by Government which requires the completion and return of information including data which has consistent and measurable criteria applicable throughout the country.

8.2 Although the independence of Panel members is appreciated and respected, more engagement from any future assessment Panel would be welcomed so they can really understand and appreciate a project, its vision and the challenges it provides.

8.3 The administration of the whole process on behalf of CAP was undertaken by a small team which at times struggled with the enormity of the task provided and also the logistics of dealing with proposals from England, Scotland and Wales. For example the CAP administration team were originally involved in setting up and booking the venues for the EiPs and asked for guidance of available accommodation. This was then changed and the process handed to a third party so the work to date then proved abortive.

8.4 Also more feedback or review would also be welcomed so the Council can benefit more from the experience and therefore better understand future proposals and the challenges it will provide.

Page 5 Casino Call for Evidence – March 2007 9. Other Significant Issues

9.1 In Clause 137 (Final CAP Report) regarding Cardiff CAP note that - it is a capital city, but also the relative small size of its catchment area, its semi-peripheral position in relation to the European core of economic activity and its relatively undeveloped international airport at Rhoose. With a city-region catchment of 1.4million people within one hours drive-time of CISV and an ever increasing visitor and tourism market, concern is expressed why CAP consider the catchment too small. Indeed if this was the case why didn’t CAP establish from the start of the process that only cities with a catchment comparable with or Manchester need apply? Indeed a key issue raised by CAP at the EiP for Greenwich raised concerns about how exactly the social impact of a regional casino could be measured on an urban area the size of London, a concern that could also be made against Manchester which CAP themselves state has a catchment second only to London.

9.2 To state that Cardiff has a semi-peripheral position in relation to the European core of economic activity is clearly incorrect as it is a capital city located only some 150 miles from London. It is felt that the comment is too subjective and goes against the principles of the European Union, indeed why isn’t it applied to the other proposing cities which maybe even more physically distant? Also Cardiff is in fact closer to both London and Brussels than all of the 7 regional casino shortlisted submissions except for Greenwich, so clearly this claim cannot be substantiated in any way.

9.3 Cardiff International airport offers over 50 direct destinations and over 400 worldwide connecting flights and is an expanding regional facility which is experiencing significant recent investment from its new owners and “double-digit” growth. Also with the recent Government announcements for DARA at RAF St Athan and planned direct access to the M4 its success can only now further develop and increase.

9.4 In Clause 138 regarding the proposal of using CISV as a training venue in support and in the run up to London 2012, CAP state that- we have little evidence that would positively link Cardiff to the Olympics to any material degree. This statement is incorrect as the Millennium Stadium has already been nominated as a venue for holding 8 football matches in the first few days of the games, and Cardiff has further ambition to host more events as a key supporting city, but Cardiff & Wales can only bid for these events when the London Organising Committee of the Olympic Games allows Cardiff to bid which hasn’t to date. Cardiff has also been selected as co-host of the 2009 UK School Games, which is seen as an important part of the build up to London 2012.

9.5 Clause 139 states that in relation to employment opportunities, - We were disappointed, however, to find that little prior consideration had been given expressly to planning for bringing local jobless and hard to reach into the jobs that would be created by the casino and its spin-off activities. Cardiff has worked at great length with its neighbouring authorities in setting up the Capital Skills & Training Network and also in already establishing and operating for the local community an Enterprise and Training Centre directly on CISV. In conjunction with Aspers this work would then be further developed to target and develop skills in the local community specifically for the Regional Casino. To criticise the work is unfair as until a decision to locate the regional casino was made it was unhelpful and indeed abortive to raise hopes and heighten expectations in the local community for employment that may not materialise.

9.6 In Clause 140 CAP state that - we note substantial opposition locally and in the National Assembly to the proposal. This statement is both unfair and untrue. The Council carried out public consultation through its Citizens Panel programme and also the local newspaper carried out its own opinion poll. Neither produced any amount of local opposition to the scheme and only one member of the public wrote to CAP in objection.

9.7 The First Minister and the local Assembly Members plus the 4 Cardiff Members of Parliament wrote to CAP in support of the scheme whilst only Ieuan Wyn Jones AM and Nicholas Bourne AM wrote in to confirm that they could not support the proposal.

9.8 In Clauses 141 & 514 CAP state that as a negative factor the regeneration benefits for the Cardiff proposal are largely centred around CISV. However in respect to the Manchester proposal CAP see this as a positive benefit as the assessment of the strengths of the bid is predicated upon their site in East Manchester– see Clauses 172 & 178.

9.9 Finally we believe that a number of CAP’s comments are far too subjective and there is lack of overall consistency in the approach and methodology. Indeed in relation to social problems to state in Clause 182 that Manchester can be considered as “a safe pair of hands” suggests that the other six competing cities are incapable of dealing with this aspect in relation to their own proposals.

Signed………..………………………… Date: 8 March 2007 Tom Morgan Corporate Director, Cardiff Council

Page 6