Brighton & Hove City Council

 

Cabinet

 

2.00pm13 November 2025

 

Council Chamber, Hove Town Hall

 

MINUTES

 

Present: Councillor Sankey (Chair) Taylor (Deputy Chair), Alexander, Allen, Daniel, Miller, Muten, Robins, Rowkins, Williams and Robinson

 

 

PART ONE

 

 

<AI1>

60          Procedural Business

 

60a     Declarations of interests

 

60.1      There were none.

 

60b     Exclusion of the press and public

 

60.2    In accordance with Section 100A of the Local Government Act 1972 (“the Act”), the 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.

 

60.3    Resolved- That the public and press are excluded from the meeting from items listed on Part 2 of the agenda.

 

</AI1>

<AI2>

61          Minutes

 

61.1      Resolved- That the minutes of the previous meeting be approved as the correct record.

 

</AI2>

<AI3>

62          Chair's Communications

 

61.1      The Chair provided the following Communications:

 

“These remain challenging times financially for local authorities across the country, but this Council will remain committed to investing in transformative projects, thinking of creative, creative ways to tackle inequality, and ultimately working towards our ambition of creating a better Brighton and Hove for all.

We will always do the most with what we have and do our best to secure more funding for this city to invest in the lives of our residents.

The A259 Hove to Portslade Active Travel Scheme is a fantastic example of this approach and I want to commend Councillor Muten for his report today.

The proposed scheme will make walking, wheeling and cycling better and safer in a key part of our city, an area which includes the amazing Hove Beach Park development and which will be home to the new King Alfred Leisure Centre, a part of our city that I know so many residents from right across the city really enjoy spending time in, an important part of our seafront and our city and one that deserves a modern and efficient travel scheme.

Our six week consultation asked residents for feedback on the scheme, and we were delighted to receive more than 900 responses. Almost two thirds of those who responded live in Hove and Portslade, and it's always heartening to see so many local people keen to input into our local decision making. The results that we received showed strong support for widening pavements, better pedestrian crossings, upgrading cycle facilities and routes, and improving public spaces. A majority also felt it would improve safety for pedestrians and cyclists and make them more likely to visit the seafront, local shops, businesses and attractions.

But there were also some suggestions for the ways in which the scheme could be changed and improved and under this Labour Administration we will always listen to our residents and do our best to reflect their views. As a result, we've made several changes to the original design of the scheme, including increasing the number of parking spaces, relocating bus stops and adding extra green space. This scheme will make a huge difference to the area, which is why Cabinet is also being asked to approve plans today to secure additional funding on top of the £4.3 million we have secured from active Travel England to extend the scheme further to the east. This has been a genuinely collaborative project, with residents and businesses helping to shape the final design and a great example of this Council, our local businesses and local people working together to get the best outcome for everyone.

Another project everyone at the Council is rightly proud of that we're also looking at today is for 306 new affordable homes at Sackville Road.

This Labour Council is committed to increasing the number of affordable homes available to local people in our city and this development is a key part of our efforts to deliver at least 2000 homes by 2030.

Councillor Gill Williams is leading this scheme, which recently received planning permission, and is the latest from Homes for Brighton and Hove, our partnership with the Hyde Group. This will be the partnerships third scheme following the delivery of 104 new homes at Clarendon Place in Portslade and 242 at Denman Place in Coldean.

It will include 183 council rented homes and 123 homes for shared ownership and the plan is for this ambitious scheme to be delivered as 100% affordable.

These homes are so desperately needed in our city and once delivered, will make a significant and lasting impact to hundreds of local people and families. Everyone deserves a safe and secure, affordable and high-quality home, and that is an ambition that our Labour Council and our Labour government is working every day to realise.

This Council will never waiver in that belief, and councillors and officers should be rightly proud of the work that's gone into this latest initiative so far.

Thirdly, school admissions is something we know means a lot to families and parents across our city. The Council has taken innovative and proactive steps to address long standing educational inequalities in Brighton and Hove and our Labour Council will continue to do so.

We believe that every child deserves access to quality education and we're incredibly proud of the work being done by our hard-working community of schools, teaching and support staff right across the city.

Today's agenda item relates to school admission changes for the academic year 2027-28 and councillors are being asked to agree a small number of potential changes, changes which will then go out to public consultation. These include a potential change to the admission priorities for secondary schools to enable the sibling link to be applied regardless of the catchment area where a family may live and a change to the way waiting lists are operated, as well as potential adjustment of the published admission number for two local schools.

I'm pleased that the Schools Adjudicator found in our favour on the vast majority of objections that were brought to our admissions and catchment package of change brought earlier this year and I'm proud that as a Labour Council, and unlike the Conservatives and the Greens, we are prepared to take action on educational disadvantage. As a result, we now have one of the fairest and most progressive school’s policies in the country. This is labour values in action.

Lastly, we have an item on our agenda about women's football, part of which will take part take in Part 2 of this meeting due to the legal requirements which are prescribed as part of the host city bidding process.

The power of women's football to inspire girls and women right across our city to participate in sport and create lasting legacies is something we're passionate about. And as a host city for both the UEFA Women's EURO’s 2022 and this year's women's Rugby World Cup, we've already seen the amazing impact that Elite women's sport can have.

Not only of these events promoted the best of Brighton and Hove to people across the world and seen us welcome thousands of people to a wonderful city, they have also inspired more local women and girls than ever before to get active, and I see that in my own household.

As a result, we're proud to be considered as a potential host city for the FIFA Women's World Cup bid in 2035. If the UK is successful in its bid to host the tournament, it will be FIFA who decides which host cities are selected. So, for now, we will discuss today whether we want to put ourselves forward as part of that process”.

 

</AI3>

<AI4>

63          Call Over

 

61.1      All items on the agenda were reserved for discussion.

 

</AI4>

<AI5>

64          Public Involvement

 

61.1      There were none.

 

</AI5>

<AI6>

65          Issues Raised by Members

 

65.1        A copy of the questions received was circulated ahead of the meeting. Responses provided both at the meeting and in writing are as follows:

 

1.            Councillor Earthey- A259 Hove to Portslade Active Travel Scheme Consultation 

 

BHCC has allocated £2.7m from its Local Transport Plan, as well as a £4.3 million grant from Active Travel England, for the A259 Hove to Portslade active travel scheme. Do you agree that this £2.7 million would deliver more benefit for more people if it was spent on filling potholes, resurfacing roads that have failed, unblocking road drains, and reversing the 30p increase to the £1 short hop bus fare? 

 

Response: Cllr Muten

 

Thank you for your question, Cllr Earthey. 

We have been awarded £4.3 million by Active Travel England to deliver the scheme which must be used for active travel within our city – use it or lose it - with another £2.7 million coming from our Local Transport Plan (LTP) funding over the next 3 years. 

Each year, the Department for Transport (DfT) allocates LTP funding to highway authorities. From this year, the funding has been allocated in two specific ‘blocks’; the Integrated Transport Block and the Maintenance Block.  

The £3.083m Integrated Transport Block granted to Brighton & Hove City Council provides match funding to deliver a programme of active travel schemes including the A259 Active Travel Corridor Scheme. The £5.283m capital Maintenance Block grant funding for our city will deliver priority planned maintenance of roads, footways and drainage facilities.  

Which is exactly what we are doing – the A23 Tongdean Lane to Preston Park, Ditchling Road, Dyke Road, Sackville Road, Portland Road, Manor Road, Queens Park Road, Shirely Drive, Old Shoreham Road, Viaduct Road, Union Road, Terminus Road, Buckingham Place, Hangleton Road, Boundary / Station Road and more.

As part of the A259 Active Travel Scheme construction, some road and footpath resurfacing will take place along the route along with drainage improvements and traffic signal upgrades. 

Our continued commitment to supporting bus fares is funded from the Bus Service Improvement Plan (BSIP) grant allocation and not LTP capital funding.  

 

2.            Councillor Hill- School Admission Arrangements 2027-28 

 

In February, Cllr Daniel outlined proposed improvements to the process around Priority 2 to help applications for SEND children who do not have an EHCP. Previously, the vast majority of applications for priority 2 were denied which in my view created an additional problem to implementing the open admissions policy. Has the situation improved and can you provide evidence regarding this? 

 

Response: Cllr Daniel

 

Thank you, Councillor Hill. I'm really pleased to say that there's a vast improvement to the process for priority to applications since we took over now from the Greens and I'm much more confident in what we have in place. I think it was brilliant that this consultation floated those concerns and that we were able to, as a Labour Administration; act on them.

So at the moment some children who have no EHCP have the right to apply under priority two for a specific school in our school family and we made improvements to clarify the process for families and who would be considered for a priority two placement to a specific secondary school, all that information is now online and as a result of feedback from parents, It also includes case studies to bring to life exactly the kinds of scenarios in which those families may succeed and scenarios, of course, which may not be successful, and that specific feedback was gained during the very extensive consultation undertaken to review the admissions criteria as well as a range of parents surgeries that I personally undertook alongside officers to hear from parents or send children directly.

This guidance was then consulted upon by a Commission service, Amaze and the Parent Care Council, and I'd just like to extend my personal gratitude for their input and support in getting this reviewed guidance to a place that we can have confidence in.

Secondly, a multidisciplinary panel is now in place to hear cases again as a result of that feedback and that will contain professionals with specialisms in various areas that may arise during that application process, including new idea of urgent child mental health and the issues of young carers, so the carers centre being involved.

The information is all clear on the website and much clearer than before and it explains the decision making process. This represents a direct improvement in terms of the clarity of the process and I'm really proud of those collective efforts.

If you want to find that I can send you a link, but if you just put go onto a website and search priority two, it comes straight up.

The success of the policy update and the communication of that policy update and all of the information that's gone out cannot simply be measured in terms of the level of applications that are accepted and denied. What's important to measure is the quality and robustness of that decision making process so that parents can be assured that their child's need will be fully considered when making that application.

Having said how pleased I am with all the improvements, I would also like to add that we will continue to maintain our commitment to learning from feedback from parent carers and we will review, if necessary, if barriers arise in accessing that part of the school admissions process in future.

 

3.            Councillor Hill- School Admission Arrangements 2027-28 

 

Why has the administration chosen to keep the open admissions criteria it 5%? In February it seemed as though the plan was to increase the percentage to something like 20%. Is that still the case? 

 

Response: Cllr Taylor

 

Thank you, Councillor Hill, for your question.

Obviously worth reflecting as we will later in the report on School Admissions is that the Adjudicator reviewed multiple objections to our admissions process and they concluded that the arrangements were not unreasonable.

Neither were there was there any unfairness nor that the arrangements would be indirectly discriminate, which is a great result for the Administration and everyone who voted for those changes in admissions. And I paid tribute to Councillor Sykes in the Chamber, Councillor McLeay, Councillor Shanks, who had the bravery to vote for a changed system and a fairer system. Councillor Hill, who I like a lot, talks a lot about fairness and equality, but you actually have to vote for this stuff when it comes and you actually have to put the effort in to get it there. Making changes is really hard and I found it really hard, but it was something that we believed in and something we've changed for the city to make it fairer in terms of open admissions.

We never said we would increase it at all. We said we would certainly look at the impact of the policy and assess the policy and keep it under review. We'll obviously getting in applications which have now closed for next year. We'll have a look at those numbers in future years and consider the policy in the round, but it will be really important to properly assess the impact of the policy on a systems wide basis, but we're very pleased that we've brought in what we think is a much fairer school admission system

 

4.            Councillor Hill- School Admission Arrangements 2027-28 

 

What engagement has been with Downs Junior School prior to the proposal to reduce their PAN? 

 

Response: Cllr Taylor

 

There has been strong engagement with the school, and this proposal follows the previous reduction in PAN at Downs Infant School (from 120 to 90 in September 2024). This would mean that both the infant and Junior schools become 3 form entry, with the Junior school able to accommodate pupils wanting to move from the Infant school. The school governing body is supportive of the change.

 

5.            Councillor Shanks- School Admission Arrangements 2027-28 

 

The school adjudicators report does not allow the council to reduce the PAN of Blatchington Mill and Dorothy Stringer. What implications will that have for school numbers and the councils attempt to address issues of inequality? 

 

Response: Cllr Taylor

 

Thank you for the question and obviously we were pleased that overall the Adjudicator upheld most of the admissions arrangements.

The PAN’s, as you say, we were disappointed that they were not able to be reduced, but we of course respect the decision.

It's interesting that they noted that whilst reducing the PAN’s at these two schools appears to be needed in the longer term, doing so in 26/27 is premature. So, it's a balanced judgement and they're acknowledging the overall situation of falling numbers.

To answer your question, the likely consequences of this decision is that we'll have lower numbers of pupils attending some of the other schools across the city, although obviously we'll have to wait to see that in the final allocation numbers that will be published next year in terms of education inequality.

I think it's very difficult to say at this point, although as a general principle it's a better outcome if our smaller schools receive a number of pupils that's closer to their overall PAN. we don't really want a situation where some schools are getting very much lower numbers of pupils. That's not good for their budgets and for their offer but clearly we have to wait to see what the overall numbers are.

 

6.            Councillor West- A259 Hove to Portslade Active Travel Scheme Consultation 

 

In May 2023, the new administration inherited an approved and funded active travel scheme for the A259 (Fourth Avenue to Wharf), with contracts already let. What has been the total financial impact, to date, of the costs of cancellation, delay, and diversion of funding from other schemes, to satisfy the administration’s inflated ambition for this section of the Hove to Portslade scheme? 

 

Response: Cllr Muten

 

Thank you, Cllr West, for your question. You are right to highlight our well-placed ambition for better design and better use of space in delivering accessible active travel infrastructure that works well for all.  And thank you for highlighting the Green Party’s lack of ambition. To be content with infrastructure that disregards the needs of many as the Green administration did along the seafront, pitching cyclists against motorists and causing more congestion and air pollution, without learning lessons from their own design shortfalls in their plans to extend westward in Hove is contemptuous.

Our better planned scheme is more ambitious, uses the space available better, and provides a cycle route all the way to the city boundary. Our plan will connect much more of the city with a safe cycling route and uses additional funding from Active Travel England. For the Fourth Avenue to Wharf Road section, we reviewed this based on feedback received. The scheme proposed will be a higher quality and better for all road users, rather than a continuation of the split cycle route further east and avoiding the Green’s preference for using a whole traffic lane for one cycle direction, placing the pavement between the east and west cycle lanes – the lack of ambitious of the Greens was astonishing. Feedback we have had on the Green’s approach is this can be confusing and is also not as attractive for inexperienced or less confident cyclists because of the need to cycle closer to traffic. Yes, we intervened and we are unashamedly ambitious.

Funding provisionally earmarked for Marine Parade – insufficient to fully deliver such as scheme - was reallocated to the Hove scheme with agreement from Active Travel England to provide a facility which will better align with national guidance.  A “gold standard” of design to ensure better value for all.

 

7.            Councillor West- A259 Hove to Portslade Active Travel Scheme Consultation 

 

Supporting increased levels of active travel through infrastructure investment is highly beneficial to road safety, health and well-being, the city’s economy, and in reducing reliance on cars, congestion and carbon impact. What has been the cost in terms of these metrics of the considerable and unnecessary delay in implementing an active travel scheme between Fourth Avenue and Wharf Road? 

 

Response: Cllr Muten

 

Supporting increased levels of active travel through well planned infrastructure investment is highly beneficial to road safety, health and well-being, the city’s economy, and in reducing reliance on cars, congestion and carbon impact. This is best done though good design and better use of space. Where pedestrians, those crossing the road, bus passengers, cyclists and motorists all feel safe. Experience is good so to encourage others to actively travel. Poor design counters such aims. How would the Green’s lack of vision enable a real boost in active travel along Hove seafront? Poor design has led to tension and conflict between cyclists and drivers in our city. To the Green Party: Placing wands in the road to take out a vehicle lane for one direction of cycles increasing congestion and carbon impact is not the answer. We had a clear choice: More of the same or something that will really make the difference.

Stepping back, taking time to re-design the Fourth Avenue to Wharf Road scheme has meant some delay. However, the benefits of good design are increased due to our provision of a higher specification of improved active travel infrastructure – not just for cyclists but for pedestrians, bus passengers with bus stops and crossings aligned, for safety of those enjoying Hove Beach Park with crossings at desire lines, safer crossings for those with additional access requirements, better traffic flow and cyclists on defined paths not on traffic lanes defined by wands. Much better value for our residents, businesses and visitors to the City, beneficial to safety, health and carbon and encouraging more active travel along this important seafront route

 

8.            Councillor Sykes – Homes for B&H: Sackville Road trading estate 

 

Given the lamentable performance of the Building Safety Regulator in its consideration of Gateway 2 applications for work on high rise buildings and the acknowledged risk of delays and additional costs in this project because of this, what representations is the Administration making with Government and the Regulator? 

 

Response: Cllr Williams

 

We share concerns with the significant delays associated with Gateway 2 Building Safety Regulator approvals. These delays are affecting high rise residential properties across the country, including our own. For BHCC High Rise Residential Buildings, we have recently had Gateway 2 approvals for two of our schemes and we are preparing several other applications with our procured partners who are ensuring we have a complete application prior to submission, this is to avoid unnecessary and additional delays and address the backlog and particularly for Gateway 2 applications and the delivery of safe, high quality homes and maintain rigorous safety standards post Grenfell tragedy is very important now.

These recent government measures do include new faster processes, increased staffing and resources, leadership and structural changes, digital modernisation and further industry guidance and collaboration. We do remain in contact with East Sussex Fire and Rescue Service regarding our Council owned high rise residential buildings and we carry out regular surveys compliance cheques to ensure that we identify any issues at the earliest opportunity to enable us to engage and submit any applications in the correct format and as speedy as possible.

And we will continue to engage with BSR as they seek to resolve their issues whilst working with relevant steering groups to ensure our voice is heard and our concerns are shared within that arena. Thank you for your question.

 

9.            Councillor Sykes – A259 Hove to Portslade Active Travel Scheme Consultation 

 

The report mentions the transfer of ATE funding from other projects to support the increased costs of the Hove to Portslade scheme, and this principally affected the planned Palace Pier to Hospital active travel scheme along Marine Parade. What is the status and timeline of that scheme now? 

 

Response: Cllr Muten

 

Thank you, Cllr Sykes, for your question. 

Marine Parade remains a high priority route as identified in the City’s approved Local Cycling and Walking Infrastructure Plan (LCWIP). 

Funding provisionally earmarked for Marine Parade was insufficient to fully deliver such a scheme. With agreement from Active Travel England, our focus at this moment are the A259 sections outlined in this report we are keen to provide a “gold standard” design which will better align with national guidance. 

The Council's ambition is to provide a high-quality cycle facility all along the seafront between the Marina and the western boundary of the City and this will include Marine Parade. Today’s report proposes we do work back to bring this higher standard to that put in some haste previously.  We remain committed to our aspirational LCWIP as reflected in Our City Transport Plan 2035 as consulted on over the summer.

 

</AI6>

<AI7>

66          Matters Referred to the Executive

 

61.1      There were none.

 

</AI7>

<AI8>

67          Representations from Opposition Members

 

67.1      Cabinet received a representation from Councillor Hill on Item 70: School Admission Arrangements.

 

</AI8>

<AI9>

68          A259 Hove to Portslade Active Travel Scheme Consultation

 

61.1      Cabinet considered a report that provided a summary of the analysis for the A259 Hove to Portslade Active Travel Scheme public consultation and made recommendations on how to proceed. 

 

61.2      Councillors Robinson, Allen, Daniel, Rowkins and Sankey contributed to the debate of the report.

 

61.3      Resolved-

 

1)           That Cabinet notes the outcome of the most recent public consultation and stakeholder engagement as set out in Appendix 1 of this report.

 

2)           That Cabinet approves the amendments to the A259 Hove to Portslade Active Travel Scheme designs as outlined in the report at paragraph 5.4, Appendix 1 and Appendix 2, following consideration of the public consultation and stakeholder engagement responses.

 

3)           That Cabinet authorises that all Traffic Regulation Orders (TROs) required for the A259 Hove to Portslade Active Travel Scheme be advertised in accordance with the standard procedure. If the TRO consultation responses exceed the threshold as outlined in the Part 2F - Scheme of Delegation to Officers, the TROs will be reported back to this Cabinet next year to agree the way forward.

 

4)           That Cabinet delegates to the Corporate Director for City Operations, the decision to procure and award a call-off contract, within the budget outlined in Section 6 of this report, under the Council’s existing Highways Services Framework for the construction of the A259 Hove to Portslade Active Travel Scheme.

 

5)           That Cabinet requests officers to pursue external funding to extend the A259 Hove to Portslade Active Travel Scheme east towards Brighton in response to feedback received. Any designs would be subject to the usual approval and consultation processes.

 

</AI9>

<AI10>

69          Homes for Brighton & Hove - Sackville Road Trading Estate update

 

61.1      Cabinet considered a report that provided an update on the Homes for Brighton & Hove (HBH) joint venture at Sackville Road Trading Estate and sought approval for the next steps in the delivery of the scheme, reflecting the latest financial position.

 

61.2      Councillors Taylor, Robisnon, Rowkins, Muten, Robins, Miller and Sankey asked questions and contributed to the debate of the report.

 

61.3      Resolved-

 

1)           Cabinet notes progress with the project and approves the budget increase of up to £2.6m to fund the development and purchase of the affordable homes as set out in the financial implications.

 

2)           Cabinet agrees to delegate authority to the Corporate Director City Operations, in consultation with the Cabinet Member for Housing, to agree and enter into the necessary variations of the legal documentation for the project as a consequence of the increased funding requirement.

 

</AI10>

<AI11>

70          School Admission Arrangements 2027-28

 

70.1      Cabinet considered a report that sought permission to consult on proposed school admission arrangements for the academic year 2027-28 for the schools in the city where the council is the admission authority.

 

70.2      Councillors Alexander, Rowkins, Allen, Miller and Sankey contributed to the debate of the report.

 

70.3      Resolved-

 

1)           Cabinet agree to make no changes to the council’s admission arrangements other than the changes listed below.

 

2)           Cabinet agree to consult upon a change to the admission priorities for secondary schools to enable the sibling link to be applied regardless of the catchment area where families live.

 

3)           Cabinet agree to consult upon a change to the Published Admission Number (PAN) of Rudyard Kipling Primary School from 45 to 30 pupils.

 

4)           Cabinet agree to consult upon a change to the Published Admission Number (PAN) of Downs Junior School from 128 to 96 pupils to reflect changes previously made at Downs Infant School.

 

5)           Cabinet agree to consult upon a change to the way waiting lists are operated.

 

6)           Cabinet agree to consult on the Primary and Secondary coordinated schemes and to make no changes to the “relevant area”.

 

</AI11>

<AI12>

71          Update on Women's Football in Sussex

 

71.1      Cabinet considered a report that sought approval for the submission of a bid by Brighton & Hove City Council to be a host city for the 2035 FIFA Women’s World Cup.

 

71.2      Councillors Taylor, Ronins. Rowkins, Muten and Miller contributed to the debate of the report.

 

71.3      Resolved-

 

That Cabinet:

 

1)            Agrees the submission of a bid by Brighton & Hove City Council to be a host city for the 2035 FIFA Women’s World Cup;

 

2)            Delegates authority to the Corporate Director City Operations, following consultation with the Director Property & Finance and the Cabinet Member Finance & City Regeneration, to enter into the Host City Agreement and Host City Declaration attached to part 2 of this report, and any related documentation; and

 

3)            Notes the commercial arrangements and the associated potential costs of being selected as a host city as set out in the Part 2 Report and the safeguards in place should funding not be available as also set out in the Part 2 Report.

 

</AI12>

<AI13>

72          Update of Women's Football in Sussex (Exempt Category 3)

 

As per the confidential minutes.

 

</AI13>

<AI14>

73          Part Two minutes of the previous meeting

 

73.2      Resolved- That the Part Two minutes of the previous meeting be approved as the correct record.

 

</AI14>

<AI15>

74          Part Two Proceedings

 

74.1      Resolved- That Cabinet agreed that the confidential items listed on the agenda remain exempt from disclosure to the press and public.

 

</AI15>

<TRAILER_SECTION>

 

The meeting concluded at 4.20pm

 

 

</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>