Brighton & Hove City Council

 

Tourism, Equalities, Communities & Culture Committee

 

4.00pm19 November 2020

 

Hove Town Hall - Council Chamber

 

MINUTES

 

Present: Councillor  Ebel (Joint Chair), Powell (Joint Chair), Evans (Opposition Spokesperson), Nemeth (Group Spokesperson), Mac Cafferty, Mears, O'Quinn, Shanks and Simson

 

Other Members present: Nick May (Sussex Police), Joanna Martindale (Community Voluntary Sector), Lola BanJoko (B&H CCG), Stephanie Prior

 

 

 

PART ONE

 

 

<AI1>

36          Procedural Business

 

36(a)   Declarations of substitutes

 

36.1      Councillor Theresa Fowler declared her substitution for Amanda Grimshaw.

 

36.2      Councillor Sue Shanks declared her substitution for Councillor Clare Rainey.

 

36(b)  Declarations of interest

 

36.3      Councillor Powell declared her ongoing employment with Sussex Police and that her partner was involved as a consultant working with various local charities.

 

36.4      Councillor Appich declared her position as chair of the City Fair Trade group.

 

36(c)   Exclusion of press and public

 

36.5      In accordance with Section 100A of the Local Government Act 1972 (“the Act”), the Planning Committee considered whether the public should be excluded from the meeting during consideration of any item of business on the grounds that it is likely in view of the business to be transacted or the nature of the proceedings, that if members of the public were present during it, there would be disclosure to them of confidential information as defined in Section 100A (3) of the Act.

 

36.5    RESOLVED That the public be not excluded during consideration of any item of business on the agenda.

 

</AI1>

<AI2>

37          Minutes

 

37.1    AGREED – that the minutes were a correct record of the meeting held on 24 September 2020 as an accurate record.

 

</AI2>

<AI3>

38          Chairs Communications

 

38.1    The Chair gave the following Communications:

 

“Welcome everyone in the 2nd lockdown, hoping everyone is well, and thanks for attending today.  We’ve another packed agenda, but I will aim to factor in short comfort breaks where possible, so do remind me with a hand up if we go over time on this or when anyone is feeling the need for a break.

 

I would ask, because of the length of the agenda today, that each contributor keeps to succinct a point as possible to enable us all to get through the items with ease.

 

We are all aware of the upsetting and distressing news item yesterday of the anti-Semitic graffiti daubed on a wall in Hove.  I wanted to start today’s proceedings by reaffirming that we do not tolerate hate in our city in any form. We do not tolerate anti-Semitism, and I will be reaching out to local Rabbis in my capacity as Lead Member for Equalities.

 

I would like to extend a warm welcome to Stephanie Prior, our new standing invitee to TECC. We always welcome ‘a new lens’ on what we’re doing at committee, especially in these exceedingly challenging times.  Our standing invitees are a vital part of this committee.  we thank all of you for making the time to regularly attend TECC, and so we welcome Stephanie, we really look forward to working with you.

 

Another warm welcome is extended to Cllr Amanda Evans, who joins us today as the new Opposition Spokes.  Welcome Amanda, very pleased to have you on board.  I’d like it recorded please that I extend my thanks to Cllr Carmen Appich, your predecessor who worked closely with us on many matters, but in particular on equalities, so I look forward to continuing this collaborative, good-spirited relationship Amanda, and in particular on this topic. 

 

It’s been a busy time for us all of course, and none so more than on this committee:

 

i)             I’ve spent a good deal of time with various groups and individuals re: the anti-racism strategy.  This work is ongoing and will continue of course.

ii)            I’ve started holding online CVS surgeries: 1:1 meetings with any local charity or organisation to discuss pressing or urgent matters, and these will be held quarterly.

iii)           I’ve held the second CAG (Community Advisory Group) meeting which as you may recall comprises the BAME-led groups in the city to help shape the anti-racist strategy. This is going well with heartfelt and honest contributions and suggestions from everyone involved, and I look forward to continuing this dialogue.

iv)           I attended the sanctuary on sea AGM; an event looking ahead at the next stage of building a City of Sanctuary in the city, with some truly inspirational speakers.

v)            I attended a great session regarding Inclusive cities, and heard from some very powerful speakers, notably an SNP Cllr and the Deputy Mayor of London.

vi)           I did an interview with Latest TV about our support for the anti-harassment club,

 

During lockdown Libraries are continuing to offer some services for local people:

 

·                    Digital services including eBooks, eAudiobooks, newpapers, journals and comics

·                    Order & Collect – order a selection of books online or by phone, and collect from Hove or Jubilee Libraries

·                    Home Delivery Services for people who find it hard to leave their homes

·                    An Enquiry and Information service by email or phone

 

Information on all of these things can be found on the library pages on the council website. This December Libraries will be promoting a Winter Reading Challenge for children. It will run online for 6 weeks and will be very similar to the Summer Reading Challenge - the goal is for children to read a chosen number of books to collect a prize!  The Challenge starts on Tuesday 1 December 2020 and ends on Friday 15 January 2021.

 

 

Carbon Reduction Fund

 

I will take this opportunity to plug the council’s Carbon Reduction fund which is still open for bids until 27th November.  The council are looking to support projects that promote active and sustainable travel, create and improve open spaces, support a ‘reduce, repair, reuse and recycle’ approach, or other ideas that contribute to the city’s pledge to become carbon neutral by 2030. Applications are open to locally based community and voluntary organisations, and the planned project must be solely for the Brighton & Hove area of course.

 

 

Trans Day of Remembrance

 

On the occasion of the International Trans Day of Remembrance, this Sunday 20th November we remember that 350 Trans and Gender-Diverse people were reported murdered in the last year.

 

Aggregated data indicates that Black and migrant trans women of colour are more vulnerable and frequently targeted.

 

We share our solidarity with the city’s Trans and Gender diverse communities on this sad day & reflect that behind the statistical representation of numbers and percentages, these are people whose lives we value and whose loss is mourned. 

 

 

Disability

Disability History Month 2020 started yesterday on 18th November for a month until Friday 18th December 2020.

The theme is Access:

How far have we come?
How far have we to go?

For those of you who have not watched Question Time last week please do.   Disabled comedian Rosie Jones speaks passionately about her own experience in terms of accessibility, of prejudice, and in how far we have come since the Disability Discrimination Act 1995, and importantly how far we still need to go.

 

 

Religious Festivals

 

Happy Diwali to residents who celebrated the Festival of Lights last weekend, from 12th to 16th November. With Covid-19 restrictions in place, Diwali will have been a different experience for Hindus, Sikhs, Jains and Buddhists celebrating this year in many countries around the world and here in our local communities.

 

Also with Hanukah, the Solstice and Christmas next month I’d like to say that I know that this year has been hard for people of faith to celebrate with friends and family and that celebrations have been different from usual. I hope though that the festive season is full of light, happiness and celebration for us all and that we can look ahead to when we can be safely together once more.

 

To report on Cllr Marianna - my Co-Chair’s side of the portfolio:

 

·         Like me, M attended the anti-racist training –.  It’s informative, thought-provoking I encourage all councillors to attend this.

 

Support for the Arts, Cultural, Events & Hospitality Sector

 

The Government is giving out grants for small businesses and I encourage all businesses, especially in our hard-hit cultural & hospitality sectors, to apply for these grants and the application portal for the grants is now open so businesses can apply now.

 

Businesses that had to close during the lockdown can apply for funding of up to £3,000, depending on the rateable value of the business. And for businesses that did not have to close but are nevertheless affected by the pandemic a discretionary grant is being made available. The link is up so please do visit the Council’s website to find out more.

 

We are, of course, painfully aware that businesses in the creative, cultural, events and hospitality sector are in dire need of support to survive the current Covid-19 crisis, and we are therefore writing to the Secretary of State for Digital, Culture, Media and Sport. We are asking for further support, especially for those currently falling through the cracks, amongst them many people on zero-hour contracts and casual workers. We are also asking that Government extends the eviction support which is coming to an end by the end of the year. Many business owners had hoped to rebuild their businesses over the autumn and Christmas period which has sadly been thwarted by the current lockdown. The eviction support is now likely to end at the precise time of year that rent will be due, but with many businesses unable to forecast a sufficient improvement in their revenue over that time. Only with a robust and wide-ranging support package will our many vibrant Arts, Cultural, Events & Hospitality businesses be able to pull through this unprecedented crisis.

 

 

Consultation on Urban Design Framework SPD

 

A reminder that consultation is now taking place on the Draft version of the Urban Design Framework Supplementary Planning Document (UDF SPD). The consultation is running for 7 weeks until 11th December. The Draft UDF SPD looks at opportunities to deliver better design outcomes from new development in the city. This includes showing how good urban design can help to improve existing areas, shape new places and deliver safer, more inclusive, accessible, sustainable and climate-resilient buildings, spaces and places for the city; its residents, businesses and visitors.

 

Views put forward during the current consultation will feed into the final version of the guidance that will then be submitted to TECC Committee for adoption early 2021. Once adopted, this guidance will guide planning decisions on planning applications. You can view the Draft UDF SPD and its supporting documents on the council website.

 

Consultation on Sports Facilities

 

To plan for the future of sport in the city, the council has launched a consultation to find out how residents think sports facilities could be improved and developed. I would like to encourage residents to participate in this consultation. The findings of the survey will be included in the final Sports Facilities Investment Plan which will be presented to this committee and used to help inform the Sport and Physical Activity Strategy. The plan aims to encourage increased participation in sport and physical activity and improve the health and wellbeing of residents across the city. The consultation runs until 17 January 2021. Residents filling in our survey have the chance to enter a prize draw for the chance to win one of ten £25 Love2Shop vouchers!”

 

</AI3>

<AI4>

39          Call Over

 

39.1    The following items were called:

 

            42        Community Safety Strategy Update

            43        Progress Report on anti-racism Action

            44        Support for the Charity Sector and Volunteering

            48        Historic Motor Vehicle Events

            49        Outdoor Events Madeira Drive

            51        Hove Station Area Masterplan

 

39.2    The Following items were agreed as per the recommendations in the report:

 

            45        CIL Infrastructure Funding Statement 2019/2020

            46        Local Development Scheme Update

            47        Outdoor Events Parks and Open Spaces

            50        Brighton Centre Catering Concession

 

</AI4>

<AI5>

40          Public Involvement

 

(b)       Written Questions

 

(i)           Beach Chalets Report Removal

 

40.1     Mr Roy Pennington provided the following question:

 

“Why was the Beach Chalet Letting Report Survey report, due to be discussed 19th November 2020 meeting, removed from the agenda?”

 

40.2    The Chair gave the following response:

 

“We received 790 responses to our recent consultation on whether chalet licenses should all move in to fixed term basis. I fully understand how important these chalets are for our residents, for this reason myself and my Committee Co-Chair Councillor Marianna Ebel have decided to take more time to consider how this important amenity should be managed. Officers will bring a report to our January 2021 TECC Committee, we will listen to your concerns and the many valuable points made by people with indefinite licenses. The report will make recommendations on how beach chalet licenses can be managed for the benefit of as many people as possible whilst also respecting previous commitments the Council has made.”

 

40.3    Mr Pennington gave the following supplementary question:

 

“Can Brighton Beach Chalet Tenants Association be recognised as an association for all tenants of chalets?”

 

40.4    The chair stated that this would be considered.

 

 

</AI5>

<AI6>

41          Member Involvement

 

(b)       Written Questions

 

(i)           Funding Maintenance Plans

 

41.1    Councillor Nemeth gave the following question:

 

““The detailing and finishing of exterior surfaces (for example metal cladding, timber cladding, glazed curtain walling, concrete or rendered/painted surfaces) needs to be carefully considered to avoid requiring onerous maintenance requirements or poor weathering properties. Where appropriate, a funded maintenance plan will be required to demonstrate how the quality of materials used will be secured over time.”

 

41.2    The Chair gave the following response:

 

“I can confirm that the agreed change was taken forward into the supporting text (paragraph 2.151) of policy DM18 High Quality Design and Spaces in the Proposed Submission version of City Plan Part Two.  The role of supporting text is to help clarify the meaning of a policy and how it is envisaged to be implemented. It should be noted, however, that it does not carry the same weight as policy itself.

 

City Plan Part Two will not have full weight for decision-making purposes until it is formally adopted which is currently anticipated to be Spring 2022.  Submission of the plan to government is planned for March 2021 and examination by an independent Planning Inspector will follow with public hearings likely Summer 2021. This will be followed by the Inspector’s Report, then Council adoption.

 

The degree of weight that can be given to individual policies at this stage will depend upon the representations received (as part of the recent consultation) and whether soundness objections were received.  Policy DM18 has attracted some soundness objections so can only be given limited weight at this point in time.

 

However, the matter of materials and maintenance is also addressed in the draft Urban Design Framework SPD which is currently out to public consultation until 11th December. This further guidance (at Section 3.5) indicates that in the case of major development the council will require that a maintenance plan and indicative construction details are provided. Once adopted, by summer 2021, this guidance will help to deliver higher quality and better design outcomes from new development in the city.”

 

41.3    Councillor Nemeth gave the following supplementary:

 

“Did the chair recognise that getting principled maintainable materials, that installation required pride and love were key to the issue?”

 

41.4    The chair offered a written response.

(ii)          Field Officers

 

41.5    Councillor Mary Mears gave the following question:

 

“Would the Chair provide (i) an update on the Field Officer employment and retention situation and (ii) confirm that no council tenant will be charged (through the Housing Revenue Account) for the Field Officer service if, for whatever reason, it is not being provided?”

 

41.6    The Chair gave the following response:

 

“The current staffing position for field officers is

One Full Time Manager

4 full time in post

 

Recruitment for vacant posts took place in October and the following posts were filled and officers will be starting with the team in December

2 part time and 2 full time. The team will then be up to full capacity.

 

The HRA  provides some funding to the field officer service which amounts to 1 FTE and field officers continue to work with housing colleagues investigating noise and nuisance cases relating to housing tenants thus providing services to those tenants.  The Field Officers assisted housing colleagues to set up and run the EIB survey and carried out meetings until the meetings had to be cancelled due to Covid. 

 

A full report on Field Officer activity is being reported to TECC Committee in January.”

 

41.7    Councillor Mears gave the following supplementary:

 

“The issue was with tenants build up in taking over work from officers who deal with this. Due to a lack of officers, the recent issue of an 18 month old case only just being dealt with.

 

41.8    The Chair stated that this would be factored in to the report which was due to come in future.

 

(d)       Notices of Motion

 

(i)           Improving Availability of Beach Huts and Chalets

 

41.9    The Chair notified the Committee that this Notice of Motion was to be deferred to a later date as when the report was brought back to Committee.

 

(ii)          Volk’s Railway Improvements

 

41.10  The Committee considered a Notice of Motion from Councillor Nemeth and Councillor Mears which sought to:

(i)         Thank the Volk’s Electric Railway Association for the briefing note ‘An Accessible Future for Volk’s Electric Railway‘,

(ii)        Note the implications for tourism of successfully improving accessibility to Volk’s Electric Railway; and

(iii)         Call for an Officer Report in how the note’s recommendations may be implemented.

 

41.11  Councillor Mears formally seconded the motion.

 

41.12  Councillor Evans moved an amendment which sought:

 

(i)           To thank Volk’s Electric Railway Association for the proposal document ‘An Accessible Future for Volk’s Electric Railway’;

(ii)          To note the potential positive implications for inclusivity, the tourist economy and community wealth building of successfully expanding, updating and improving accessibility to Volk’s Electric Railway;

(iii)         To call for an Officer Report exploring how these proposals could be considered alongside existing planned works at Black Rock and Madeira Terraces, and be complementary to them; and

(iv)         Notes that due to the Covid-19 pandemic councils across the country are in a difficult financial position and that this council’s financial opportunities are just as limited. Committee therefore requests the report also explores options for funding the proposals through external funding, such as the Heritage Lottery Fund, or S106/CiL money.

 

41.13  Councillor Ebel formally seconded the amendment.

 

41.14  Councillor Nemeth welcomed the amendment.

 

41.15  RESOLVED – that the recommendations, as amended, be agreed.

 

 

(iii)        Low-Cost Nature Reserve Conservation Features

 

41.16  The Committee considered a Notice of Motion from Councillor Nemeth and Councillor Simson which sought to set out a preferred timetable for implementation of the agreement and called for an Officer Report on what conservation features should be included.

 

41.17  Councillor Simson formally seconded the motion.

 

41.18  Councillor Ebel stated that there were resources in place to update the guidance and that consultation on the rewilding strategy was to take place in 2021. It was noted that this would include low cost nature preservation features.

 

41.19  Councillor Evans expressed concern at the prospect of repeating works that had been carried out.

 

41.20  Councillor O’Quinn expressed concern with regard to the legitimacy of the motion.

 

41.21  Councillor Nemeth stated that opposition against this was unfair.

 

41.22  A vote was held and the notice of motion was not passed.

 

           

 

</AI6>

<AI7>

42          Community safety Strategy Update

 

42.1    The Committee considered a report of the Interim Director of Housing Neighbourhoods and Communities which sought provide an update on the work undertaken by the Community Safety Partnership in relation to the Community Safety and Crime Reduction Strategy. The report was provided by the Head of Safer Communities.

 

42.2    The Committee welcomed the report and thanked the officers involved in bringing it forward. Concerns of Antisemitism were expressed and solidarity with Jewish Community was stated with regard to a recent Anti-Semitic graffiti incident. Members expressed concerns with the rise of crime across Brighton and Hove. Sussex Police representatives gave a brief overview of the current status of crime and in Brighton and Hove City.

 

42.3    RESOLVED – that Committee:

 

1.    Notes the report.

2.    Reaffirm the Council’s commitment to continued support to the community safety partnership work.

 

</AI7>

<AI8>

43          Progress Report on Anti-Racism Action

 

43.1    The Committee considered a report of Interim Executive Director for Housing, Communities and Neighbourhoods which sought to provide an update on the progress made and identify priorities and next steps with regard to actions taken by the Council towards becoming an anti-racist council. The report was provided by the Equalities Manager.

 

43.2    The Committee welcomed the report and thanked officers involved in managing the process. Councillors and Co-optee members expressed support of the work being carried out. It was noted that Oxford had made an anti-racism pledge and that this was the intention of BHCC.

 

43.3    RESOLVED – that Committee:

 

1.    That committee notes this update on the council’s pledge to become an anti-racist council and requests that further updates on this vital work become a standing agenda item at future TECC committees.

2.    That committee notes that the council will continue to work with a range of partners to create an anti-racist city.

 

</AI8>

<AI9>

44          Support for the Charity Sector and Volunteering

 

44.1    The Committee considered a report of the Interim Executive Director of Housing, Neighbourhoods and Communities which sought to provide a response to a notice of motion brought to the previous TECC Committee held on the 18 June 2020.

 

44.2    The Committee welcomed the report and the officers involved in bringing this forward. Members noted the issues regarding methods in which large organisations operated which could lead to them being further funded by BHCC. Support was expressed for volunteer work, an increase in volunteers had been noted.

 

44.3    RESOLVED – that Committee:

 

1.    Noted the Council’s Third Sector Investment Programme (TSIP) as the council’s major grant funding support to the Community and Voluntary Sector (CVS)

2.    Approved the agile use of the Communities Fund 2021/22 under the guidance of the All-Party Members Advisory Group within the fund’s framework.

3.    Noted the Council’s investment in the Community Works Partnership to provide infrastructure support for the CVS in the City.

4.    Noted Officers would explore and report back on development of a policy and process for ‘community’ tenants to request a rent reduction/break to support their recovery from Covid-19.

5.    Noted that officers would explore the opening of council training to CVS organisations.

 

</AI9>

<AI10>

45          CIL Infrastructure Funding Statement - 2019/20

 

45.1    RESOLVED – that Committee:

 

1.    Approved the Brighton and Hove City Council 2019/20 IFS attached as Appendix 1, subject to any minor alterations (numerical, grammatical and spelling) to be agreed by the Head of Planning in consultation of the Chair of TECC Committee

2.    Authorised the Head of Planning to publish the statement on the BHCC website and submit the annual return to the MCHLG in accordance with Regulation 121A of the Community Infrastructure Regulations 2010 (as amended)

3.    Noted the emerging CIL Advisory Protocol for members to be further reported in 2021.

 

</AI10>

<AI11>

46          Local Development Scheme Update

 

46.1    RESOLVED – that Committee:

 

1.    Approved the revised Local Development Scheme 2020-2023, attached as appendix 1.

 

</AI11>

<AI12>

47          Outdoor Events - Parks and Open Spaces 2021

 

47.1    RESOLVED – That committee:

 

1.    Grant landlord’s consent (subject to the execution of a formal agreement) for each of the proposed events listed in Appendix 1.

2.    Authorise officers to enter into formal agreements with event organisers to determine conditions, fees and levels of support as appropriate.

3.    Authorise the Executive Director, Economy, Environment & Culture, after consultation with the Chair of the committee and opposition spokespersons, to make any alterations to the events programme as necessary including approving new applications in accordance with the Outdoor Events Policy and cancelling events if required.

 

</AI12>

<AI13>

48          Historic Motor Vehicle Events

 

48.1    The Committee considered a report of the Executive Director of Economy, Environment & Culture which sought to inform the committee of requests of upcoming motor vehicle events. The report was provided by the Head of Sport and Leisure.

 

48.2    The Committee welcomed the report and the work of officers involved in bringing this forward. A member stated the reason for the report in light of a lack of assurance given. A member expressed concern over hosting events which required motor vehicles, it was stated that Central Government had announced the end of all diesel cars and that such events were obsolete.

 

48.3    RESOLVED – that the committee:

 

1.    Noted the contents of the report.

 

</AI13>

<AI14>

49          Outdoor Events - Madeira Drive 2021

 

49.1    The Committee considered a report of the Executive Director for Economy, Environment & Culture which sought landlord’s consent for each of the proposed events on Madeira Drive 2021 and the associated road closures. The report was provided by the Head of Sport and Leisure.

 

49.2    Committee welcomed the report and made enquiries regarding the amount charged. The Head of Sport and Leisure confirmed that the standard charge would apply for arrangement of events and where commercial events were held, this would be negotiated separately in order that BHCC could achieve a return on the event.

 

49.3    RESOLVED – that the committee:

 

1.    Grants landlord’s consent (subject to the execution of a formal agreement) for each of the proposed events on Madeira Drive and the associated road closures as listed in Appendix 1.

2.    Authorises officers to enter into formal agreements with event organisers to determine conditions, fees and levels of support as appropriate.

3.    Authorises the Executive Director, Economy, Environment & Culture, after consultation with the Chair of the committee and opposition spokespersons, to make any alterations to the events programme as necessary including approving new applications in accordance with the Outdoor Events Policy and cancelling events if required.

 

</AI14>

<AI15>

50          Brighton Centre Catering Concession

 

50.1    RESOLVED – that Committee:

 

1.    Delegated authority be granted to the Executive Director, Economy Environment & Culture to:

 

(i)      Procure and award a concession contract for catering at the Brighton Centre with an initial term of 5 years; and

(ii)     Approve an extension(s) to the contract referred to in 2.1 (i) above for a period of up to two years, subject to satisfactory performance by the contractor.

 

</AI15>

<AI16>

51          Hove Station Area Masterplan

 

51.1    The Committee considered a report of the Executive Director. Economy, Environment & Culture which sought to provide an update on the preparation of the Hove Station Masterplan Supplementary Planning Document. The report was provided by the City Regeneration Program Manager.

 

51.2    Committee welcomed the report and welcomed the consultation due to take place in future. The City Regeneration Program Manager clarified the situation with regard to access siding railway in to the woodyard within Saville Trading Estate.

 

51.3    RESOLVED  - that Committee:

 

1.    Approves the draft Hove Station Area Masterplan Supplementary Planning Document (attached as Appendix 1 to this report) for public consultation for 8 weeks and authorises the Executive Director Economy, Environment and Culture to make any necessary minor amendments to the Draft SPD in consultation with the Chair of TECC Committee prior to the public consultation.

 

</AI16>

<AI17>

52          Items referred for Full Council

 

52.1    Nothing was referred to Full Council.

 

</AI17>

<TRAILER_SECTION>

 

The meeting concluded at 7.20pm

 

Signed

 

 

 

 

 

 

 

 

 

 

Chair

Dated this

day of

 

 

</TRAILER_SECTION>

 

<LAYOUT_SECTION>

 

FIELD_SUMMARY

 

</LAYOUT_SECTION>

<TITLE_ONLY_LAYOUT_SECTION>

 

</TITLE_ONLY_LAYOUT_SECTION>

<COMMENT_LAYOUT_SECTION>

FIELD_SUMMARY

 

</COMMENT_LAYOUT_SECTION>

<HEADING_LAYOUT_SECTION>

FIELD_TITLE

 

</HEADING_LAYOUT_SECTION>

<TITLED_COMMENT_LAYOUT_SECTION>

FIELD_TITLE

 

FIELD_SUMMARY

 

</TITLED_COMMENT_LAYOUT_SECTION>

<SUBNUMBER_LAYOUT_SECTION>

 

FIELD_SUMMARY

 

</SUBNUMBER_LAYOUT_SECTION>

 

<TITLE_ONLY_SUBNUMBER_LAYOUT_SECTION>

 

</TITLE_ONLY_SUBNUMBER_LAYOUT_SECTION>