091/2013: Revenue and Capital Budget 2014/15 – 13 February 2014

RECOMMENDATIONS

The Commissioner is requested to consider this decision notice, having regard to the recommendations issued by the Police and Crime Panel and agree the following:

(a) That the budget be agreed as set out below

	2014/15 £000
Gross Expenditure	148,710.9
Income	(7,079.0)
Contribution to/(from) Reserves and Balances	(2,553.3)
Total Budget 2013/14	139,078.6
Funded by:
Home Office Grant	72,839.0
Council Tax Support Grant	5,746.1
Council Tax Freeze Grant 2011/12	1,532.2
Council Tax Freeze Grant 2013/14	619.6
Total Government Funding	80,736.9
Estimated Collection Fund Surplus	384.7
Balance required from the Precept	57,957.0

(b) The Commissioner’s share of the estimated surpluses/deficits on Council Tax Collection Funds for 2014/15 for each of the Borough, District and Unitary Councils of £384,689 be applied to funding the Council Tax Requirement

(c) That, pursuant to the provisions of the Local Government Finance Acts 1992 and 1999 and all other relevant statutory powers, the Commissioner’s Chief Finance Officer issues precepts in the necessary form to each of the Borough, District and Unitary Councils indicated in the appropriate column of the table below, requiring those authorities to make payments of the sum indicated in the preferred option selected by Members in eleven equal instalments and payments for the Commissioner’s share of the estimated surpluses or repayments in the case of deficits on the Council Tax Collection Funds for 2013/14, in two equal installments on the agreed dates, of the sum indicated in the final column below:

Borough/District/Unitary Councils	£	£
	Precept	2013/14 (Surplus)/Deficit
Craven District Council	4,418,563	(40,140)
Hambleton District Council	7,097,609	(65,090)
Harrogate Borough Council	12,217,838	(52,519)
Richmondshire District Council	3,840,755	(9,134)
Ryedale District Council	4,189,171	(137,710)
Scarborough Borough Council	7,487,539	(6,661)
Selby District Council	5,859,771	(73,435)
York City Council	12,845,743	–
Total	57,956,989	(384,689)

(d) That the amount of council tax calculated in accordance with the Local Government Finance Act 1992 to be payable in respect of each category of dwelling, be confirmed by the Commissioner in the table below:

Valuation Band	Council Tax Proposed Levels £
A	139.08
B	162.26
C	185.44
D	208.62
E	254.98
F	301.34
G	347.70
H	417.24

(e) Approve the level of general reserves as set out in this report and at Appendix Three and note the predicted level, and use of, reserves in the medium term.

(f) Approve the initial 2014/15 Capital and Revenue Development Programme alongside the capital funding as set out in detail in Appendix Two of this report.

(g) Approve the budget breakdown as set out in Appendix One

(h) Approve the budget for the Office of Police and Crime Commissioner, as set out in Appendix Four

Police and Crime Commissioner decision:  Approved

Signature:

Date:  13 February 2014

Title:  Police and Crime Commissioner

Part 1 – Unrestricted facts and advice to the PCC

1.    Introduction and background

1.1       This report provides the Police and Crime Commissioner for North Yorkshire (the Commissioner) with the relevant information to assist in determining the revenue budget, council tax requirement, council tax and capital programme for 2014/15.

1.2       The Commissioner is requested to consider the report and determine for 2014/15 the:

• Revenue Budget; and consequently the
  • Council Tax Requirement (Precept);
  • Council Tax;
  • Capital Programme; and
  • Level of Reserves.

1.3       The Commissioner is also requested to approve the budget for the Office of Police and Crime Commissioner

2.    Matters for consideration

2.1 STATUTORY REQUIREMENTS

2.1.1    The Commissioner is required by the Local Government Finance Act 1992 as amended by the Localism Act 2011 to set a Council Tax Requirement and issue a Precept for the following financial year prior to 1 March. In setting a Council Tax Requirement, the Commissioner must calculate and agree the aggregate of revenue expenditure, contingency provision and level of reserves.

2.1.2    The Council Tax Requirement, which for the Commissioner is identical to the Precept, is calculated by deducting the sum of Police Grant and Department for Communities and Local Government (DCLG) Grant including any addition to or contribution from reserves and after taking account of any surplus of deficit on the Billing Authorities’ Collection Funds.

2.1.3    The Precept may only be issued following the conclusion of the scrutiny process by the North Yorkshire Police and Crime Panel. The Commissioner was required under Schedule 5 to the Police Reform and Social Responsibility Act 2011 and associated regulations to notify the Police and Crime Panel of her proposed precept for 2014/15 by 1 February 2014.

2.1.4    The Panel must review the proposed precept by 8 February and make a report to the Commissioner. The Panel has a right to veto the proposed precept if at least two thirds of the persons who are members of the Panel at the time when the decision is made vote in favour of making that decision.

2.1.5    The Commissioner must have regard to and give the Panel a response to their report. Where no veto is exercised the Commissioner may issue the precept. If the Commissioner’s proposal is vetoed by the Panel, a revised proposal must be notified to the Panel by 15 February.

2.1.6    The Panel must review the revised proposal and make a report to the Commissioner by 22 February. The Commissioner must respond to the report and issue her precept by 1 March.

2.1.7    Rejection by the Panel of the revised precept does not prevent the Commissioner issuing it as her precept for the forthcoming financial year.

2.1.8    The Local Government Act 2003 places a duty on the Commissioner’s Chief Finance Officer to make a report to her on the robustness of the estimates and the adequacy of the reserves, and this is included later in this paper.

2.2 REVENUE RESOURCES 2014/15

Police Grant Settlement – Formula Funding

2.2.1    The provisional police funding announcement for 2014/15 was made in a written ministerial statement on 18 December 2013. The Final Local Government Finance Settlement, including the police settlement, was announced on 5 February 2014, and did not make any substantive changes to the figures for North Yorkshire.

2.2.2    This year’s budget setting and considerations for the Medium Term Financial Plan (MTFP) are again in the overall context of significant public sector, Home Office and police funding reductions. The implications of these funding reductions have been considered in detail during 2013.

2.2.3    The reduction in funding is over and above the original forecasts set out in the indicative 2014 Spending Announcement in June 2013. The damping methodology remains unchanged for 2013/14 and 2014/15.

2.2.4    The total core funding position shows a reduction of £3.8m (4.47%) between 2013/14 and 2014/15 financial year on a like for like basis.

The funding reductions above include several areas of nationally top sliced funds as follows:-

• Innovation Fund £50 million
• Independent Police Complaints Commission (IPCC) £18m
• HMIC (new regime of inspections) £9.4m
• National Police Coordination Centre (NPoCC) £2m
• College of Policing for Direct Entry schemes £3m
• City of London Capital City Grant £2m

2.2.5    The Commissioner has sought to minimise the impact of the top slicing in relation to the Innovation Fund and maximise the opportunities for collaboration.  She has made two successful bids for funding for the 2013/14 financial year in relation to collaboration with the Fire Service for Support Services and the City of York for an Anti Social Behaviour Hub.

Further proactive work is already underway to prepare for future submissions to the 2014/15 Innovation Fund.  The detail and bidding round for the 2014/15 Innovation Fund is yet to commence at the time of writing.

2.2.6    Population projections used in the police funding formula were updated in 2013/14 to incorporate 2011 Census data. As much of the formula is driven by population, changes can result in significant variations. The resident population for North Yorkshire reduced by 0.6% in comparison with the national average increase of 2.1%. This reduced the raw formula allocation and as a result the amount gained through damping in 2013/14 increased from £7.5m to £9.4m.

Other Grant Funding

2.2.7    Other grants payable in 2014/15 include:

• Capital Grant – unchanged from expectations. North Yorkshire’s allocation is £1.050m.
• Council Tax Support – this grant is paid directly to Commissioners to reflect the Government’s contribution to Council Tax Support. North Yorkshire’s allocation is £5.746m.
• Council Tax Freeze Grant 2011/12 and 2013/14 – these grants continue to be paid for 2014/15 (and for 2015/16). North Yorkshire’s allocation is £2,152m.

2.2.8    The Government’s excessiveness limit for 2014/15 has been set at 2%.

Other Resources

2.2.9    The Commissioner has been notified of monies due to or from the Billing Authorities’ Collection Funds. There will be an overall surplus of £384,689 to be carried to 2014/15 and this has been included in the figures presented.

2.2.10 The taxbase, which represents the number of band D equivalent properties in the county, is notified to the Commissioner by the Billing Authorities. .

2.2.11 The taxbase notified to the Commissioner for 2014/15 is 277,811.28 as compared with the 2013/14 figure of 273,898.46. This is broken down as follows:

	Band D Equivalents
Craven District Council	21,179.96
Hambleton District Council	34,021.71
Harrogate Borough Council	58,565.04
Richmondshire District Council	18,410.29
Ryedale District Council	20,080.39
xScarborough Borough Council	35,890.80
Selby District Council	28,088.25
York City Council	61,574.84
Total Tax Base	277,811.28

2.3 Revenue Budget Proposals for 2014/15

2.3.1    The Commissioner reflects community priorities within the Police and Crime Plan and sets objectives based upon six goals, namely to:

• Reduce harm;
• Put people first;
• Deliver more with less;
• Ensure that we are “fit for the future”;
• Drive justice;
• Police UK

2.3.2    The Commissioner is currently intending to refresh the Police and Crime Plan and will do this following consultation with communities in March/April. This is to ensure that the priorities and objectives contained in the Police and Crime Plan remain relevant and appropriate. The Police and Crime Plan will also be informed by various information sources that are consolidated to produce an assessment of need across North Yorkshire and for local communities. The information sources include a Joint Strategic Intelligence Assessment with partners and a Joint Strategic Needs Assessment incorporating broader health related information. In addition North Yorkshire Police are currently undertaking a review of the Operational Policing Model to inform the development of the most effective response to community needs. Should any changes be required to the Police and Crime Plan these will be managed in accordance with legislative requirements and within the overall funding envelope for the 2014/15 budget.

2.3.4    In making this precept proposal the Commissioner has also taken into consideration consultation on the 2014/15 budget. The consultation posed three questions surrounding the budget and the analysis is provided in Decision Notice 01/2014 (Appendix 6).

2.3.5    The key priorities for 2014/15 financial year and to support the Police and Crime Plan are as follows: –

• Protecting frontline service delivery
  • A commitment to utilise the precept increase to provide an additional 24 Police Officers to contribute towards maintaining Police Officer numbers at the same level as when the Commissioner took office in November 2012 – 1392 Police Officers / £70.8m budget requirement
  • A commitment to maintain PCSO numbers at the same level as when the Commissioner took office in November 2012 – 183 / £6.1m budget requirement
  • Enable frontline services through investment in Information Technology and Estates
    • IT investment programme to ensure a modern infrastructure to support operational policing – £10m over the next four years
    • New Custody Facility within a new Northern Base for operational policing and headquarters facility
    • Introduction of a new Commissioning approach to reflect the broader remit of Police and Crime Commissioners for Community Safety
      • £1.1m per annum investment in Commissioning (including Victims Services)
      • £1m+ in 2014/15 partnership contributions supporting Community Safety activity (subject to review with the Commissioning approach)
      • £0.5m Transitional funding to reflect a requirement for a managed transfer to the Commissioning approach
      • Up to £0.25m Community Fund for local community initiatives not subject to commissioning processes
      • Ensuring a sustainable service to the public
        • Savings plans over the next four years have targets identified of £9.3m across four workstreams of activity; Operational Policing Model, People, Partnerships/ Collaboration and Fit for the Future.

2.3.6    The budget and resource requirements to deliver the Police and Crime Plan goals, and the priorities identified above, lead to the Revenue budget and Capital investment proposals.

2.3.7    The budgets are managed on a corporate/strategic basis across North Yorkshire. Although it is not feasible to allocate budget and resource allocations on a geographic basis the Commissioner and Chief Constable do provide financial information in line with nationally agreed systems of analysis. The Police Objective Analysis (POA) is the primary tool used across all Police Forces in the country and provides a different view of how budgets and resources are deployed to standardised categories of policing. This information is provided after the budget setting process and to national timescales. The analysis of the budget under POA will be assessed throughout 2014/15 financial year.

2.3.8  The revenue budget includes the following key assumptions:

• Absorbing service pressures including inflation £1.8m
• Savings from review of budgets £5.3m
• A pay award of 1% for police officers and police staff, effective from 1 September 2014
• A revenue contribution to capital programmes of £3.4m
• The continuation of a Community Fund to be allocated by the Commissioner (up to £250k for 2014/15)
• Protecting Frontline Policing numbers for 1,392 Police Officers and 183 PCSOs

2.3.9    Commissioner’s Budget

The budget for the Office of the Police and Crime Commissioner is set out within Appendix Four. The Commissioner has maintained the private office costs at £0.91m 2014/15 (13/14 £0.96m). For information the Police Authority budget prior to the introduction of the Commissioner was £1.080m.

The budget level has been achieved whilst making significant improvements in the following areas: –

• Accessibility via a new searchable website, attending a significant number of surgeries in local communities and creating a more accessible location in Harrogate for the Commissioners office
• Transparency of Information that goes beyond the statutory minimum requirements
• Publication of salary and expenses information for the Commissioner and senior/statutory officers
• Managing and implementing the expanded role of Police and Crime Commissioners in relation to Community Safety and Commissioning
• Statutory Officer reviews and savings
• Introducing a Community Fund to support local communities

2.3.10  The 2014/15 financial year introduces further services under the Police and Crime Commissioner. The Police Reform and Social Responsibility Act requires all Police and Crime Commissioners and Chief Constables to initiate what is known as a “Stage 2” transfer of services (Stage 1 being the creation of Commissioners) from the Commissioner to the Chief Constable.

Both the Commissioner and the Chief Constable are Corporations Sole in their own right as separate legal entities. The effect of the transfer for North Yorkshire is that the Commissioner will retain several delivery departments that will form part of her accounts and budgets. These departments will be known as “Support Services” and will be identified separately to the Office of the Police and Crime Commissioner to ensure the public and communities can still assess the cost of the Commissioners activities distinct from Support Service areas. The Commissioner and the Chief Constable have agreed to share services wherever possible and appropriate in order to reduce duplication and cost as a result of the transfer.

2.4 Capital and Revenue Development Programme (CRDP)

2.4.1    The capital and revenue development programme is included within Appendix 2a-d and reflects the Commissioner’s commitment to actively invest in information technology and the estate to deliver a sustainable future that is accessible, cost effective and responsive to the changing needs of users and the workforce, aiming to be as energy efficient as possible. This effectively supports Police delivery of services.

2.4.2    The programme is based on a capital investment of £11.1m for 2014/15 and totals £54.9m over the next four years from 2014/15 to 2017/18. Resourcing of the plan is from a range of sources summarised over four years as: –

	£m
Capital Government Grant	3.8
Capital receipts	7.3
Revenue contributions reserve	10.8
Earmarked reserves	20.8
Borrowing	12.2
	54.9

2.4.3    Contributions to and utilisation of the earmarked reserves are detailed at Appendix Three. The MTFP makes provision for the contribution to reserves and the revenue consequences of prudential borrowing, which is currently anticipated in 2015/16 and later years.

2.4.4    The Prudential Code for Capital Finance in Local Authorities published by the Chartered Institute of Public Finance and Accountancy sets out a number of indicators which must be used to demonstrate that capital investments plans are affordable, prudent and sustainable. These indicators will be included within the report to the Commissioner on the Treasury Management Strategy for 2014/15.

2.5       Medium Term Financial Plan

2.5.1    One of the key requirements of the Prudential Code is that the Commissioner takes a longer term view of the spending pressures facing the organisation in setting and approving the budget and council tax for the following financial year. A summary of the five year revenue forecast is provided below, with a more detailed breakdown at Appendix One. This demonstrates the estimated level of budget gap to be met by savings in future years.

	Budget Shortfall  £’000
2013/14	–
2014/15	–
2015/16	3,086.8
2016/17	10,567.2
2017/18	13,764.9

2.5.2    Forward planning is relatively more complex at present because of the levels of uncertainty surrounding future Government funding, particularly in the period following the current Spending Review, and the ongoing impact of council tax support localisation. There is therefore potential for a significant degree of variation to the forward projections presented above, which represent a worst case scenario. It is anticipated however that the level of additional savings which will be required by 2016/17 will be in the order of £9m to £10m.

2.6 Level of Reserves

2.6.1    An analysis of general and earmarked reserves is given at Appendix Three and the forecast closing balance at 31 March 2014 is shown below.

	Opening Balance 1 April 2013 £000	Predicted movement in period £000	Forecast Closing Balance 31 March 2018 £000
Capital Programme Reserves	20,799	(20,626)	173
Revenue Programme Reserves	614	(614)	–
Insurance Reserve	1,219	200	1,419
Short Term Reserves	2,447	(191)	2,256
General Reserve	9,493	816	10,309
Total	34,572	20,415	14,157

2.6.2    The prudent setting aside of adequate levels of reserves ensures the consistent delivery of required levels of policing should unexpected and unforeseen events occur during the year. This, together with the adoption of a sustainable funding strategy, should balance the MTFP and ensure a robust level of funding for the base budget and future investment.

2.6.3    The Commissioner’s financial regulations set the level of general reserves at not less than 6% of the net revenue budget. This level is set to ensure that there are sufficient, but not excessive, unallocated funds available to withstand the cost of unforeseen events or circumstances without recourse to council tax payers.

2.6.4    The levels of both earmarked and general reserves are reviewed during budget setting and closure of accounts. The levels set out above have been assessed as appropriate given the medium term forecasts of revenue and capital expenditure and the high levels of uncertainty surrounding future funding.

2.7 Precept Proposal

2.7.1    The Commissioner has given due consideration to the revenue budget requirements for 2014/15, the Capital and Revenue Development Programme and the medium term position set out above, and has considered in particular

• The goal of maintaining frontline operational capacity
• Delivering major transformational Information Technology and Estates projects to enable and support front line services
• Reflecting the broader role of Police and Crime Commissioners in respect of Community Safety and commissioning services
• The impact on council taxpayers
• Future financial health, including the adequacy of reserves and balances
• The robustness of financial and organisational management processes in place
• Levels of demand and Force resilience
• Savings made to date and the capacity for future savings
• Public views obtained during consultation

2.7.2    As a result of this consideration the Commissioner notified the Police and Crime Panel of her intention to increase the council tax by 1.99% in 2014/15.

2.7.3    The Police and Crime Panel met on 6 February 2014 to consider the Commissioner’s precept proposal and agreed to accept it. This is therefore the basis of the recommendations and statutory calculations set out in the report.

1. 3.    Other options considered, if any

3.1       An option to take a Council Tax Freeze Grant of 1% had been identified. The government have written to Commissioners confirming that the precept freeze grant will be rolled into the funding formula for 2015/16. Where roll up of grants into the funding formula have occurred previously for North Yorkshire the funds have not necessarily been distributed due to the funding levels being fixed. The implications of this for North Yorkshire are that the grant is only guaranteed for one year in terms of formal written settlement notification. The precept freeze option would reduce the Precept base for future years, and therefore would reduce the available funding for 2014/15 by £562.4k. This would increase the budget savings required in 2014/15 and in future years, and for this reason this option has been rejected as it would be increasingly difficult to sustain officer numbers and invest in the future of policing.

1. 4.    Contribution to Police and Crime Plan outcomes

There is an integrated strategic planning process to align financial planning to the outcomes included within the Police and Crime Plan.

1. 5.    Consultations carried out

The Commissioner has consulted on the precept proposal with three key questions. The details of the questions and associated response analysis is provided at Appendix Five to this notice.

There is recognition within the responses of the need to maintain frontline policing resources and a sustainable service over the medium term. Therefore taking account of the consultation feedback and the proposals contained within this notice the Commissioner is proposing to increase the Council Tax by 1.99%.

6 Chief Finance Officer Report

6.1       Section 25 of the Local Government Act 2003 requires that a report be made by the Responsible Financial Officer to the Commissioner when she is considering her budget and council tax. The report must deal with the robustness of estimates and the adequacy of reserves allowed for in the proposals.

6.2       As the council tax is set before the year begins and may not be increased during the year the Commissioner must consider risks and uncertainties which might result in spending more than planned. These risks and uncertainties include:

• The delivery of the savings identified to balance the budget.
• The global economic climate and in particular, levels of inflation, interest rates for investment, security of investments, availability and viability of competitive suppliers and so on.
• A high degree of uncertainty surrounding future funding assumptions
• Proposals for risk sharing in respect of the localisation of council tax benefit
• Potential reduction in external funding from partners.
• The impact of unforeseen events which would fall initially on general balances.
• The need to meet new national standards and demands.
• The impact of increasing mandation of national contracts.
• Ongoing transfer of costs from the NPIA for key systems
• Potential for further top slicing of other areas of funding presently allocated to Commissioners.

6.3       Allowance is made for these risks by:

• Making prudent allowance in the estimates on each of the budget headings.
• Ensuring that there are adequate reserves to draw on if the estimates turn out to be insufficient.
• Robust financial management processes throughout the year to identify emerging spending pressures and manage them appropriately.

6.4       The Commissioner’s Chief Finance Officer is satisfied that the procedures adopted by the Financial Services Department are sufficiently robust to ensure that the financial data collected is accurate and forms a strong platform from which necessary estimates of future financial requirements and projections can be confidently made and ensures that monies set aside as specific reserves are adequate and not excessive.

6.5       The estimates have been prepared by the Chief Constables Chief Finance Officer and Chief Accountant and qualified staff in the Financial Services Department, and reviewed by the Commissioners Chief Finance Officer. They are based upon the continued delivery and achievement of the affordability programme savings targets in future years, which has been contributed to by all Directors and endorsed by Chief Officers.

6.6       Known spending pressures have been identified and provided for within the base budget. Provision has been made for specific inflationary pressures on both pay and prices. Savings identified have been deducted from the budget and these have been phased in such a way that there is a justifiable expectation that they will be achieved, although the assumptions made are more significant than in previous spending review periods.

6.7       Future investment in IT and the estate has been identified within the CRDP and adequate funding has been provided through a combination of capital grant, capital receipts, contributions from the revenue budget and prudential borrowing.

6.8       There is no projected use of borrowing until 2015/16, although the MTFP assumes use of capital receipts of £7.3m which have the potential to be realised in slower time or at reduced amounts. The borrowing level can be adjusted at any time to reflect the actual level of receipts received.

6.9       Current forecasts are for a balanced budget in 2014/15 but future years remain to be balanced and there is a high level of uncertainty surrounding the funding assumptions which can be made.

6.10     The Chief Finance Officer concludes that the estimates for 2014/15 are robust and the level of reserves, as set out in the Appendices, is adequate.

7.         Legal Implications

Having read this report and having considered such information as has been provided at the time of being asked to express this view, the Force Solicitor and Head of Legal Services is satisfied that this report does not ask the PCC for North Yorkshire to make a decision which would (or would be likely to) give rise to a contravention of the law.

8.         Equality Implications

There are no equality or diversity issues resulting from this Decision Notice.

Appendices

• Appendix One Medium Term Financial Plan: 091 Precept App 1 – Revenue Budget – v43 DRAFT v7
• Appendix Two (a – c) Capital and Revenue Development Programme and Funding Summary:  091Precept App 2 (a – c) – CRDP v43 DRAFT v7
• Appendix Two (d)  Capital and Revenue Development Programme and Funding Summary: 091Precept App 2 (d) – CRDP Funding Summary v43 v7
• Appendix Three Reserves Projections:  091 Precept App 3 – Reserves version 43
• Appendix Four Budget for the Office of the Police and Crime Commissioner:  091 Precept App 4 – PCC Budget – 14-15 on
• Appendix Five Decision Notice 01/2014:  Please see Decision Notice 090/2014: https://northyorkshire-pfcc.mixd.co.uk/0902014-notification-of-the-commissioners-precept-proposal-for-201415-to-the-north-yorkshire-police-and-crime-panel/

Public Access to information

The Police and Crime Commissioner wishes to be as open and transparent as possible about the decisions he/she takes or are taken in his/her name. All decisions taken by the Commissioner will be subject to the Freedom of Information Act 2000 (FOIA).

As a general principle, the Commissioner expects to be able to publish all decisions taken and all matters taken into account and all advice received when reaching the decision. Part 1 of this Notice will detail all information which the Commissioner will disclose into the public domain. The decision and information in Part 1 will be made available on the NYPCC web site within 2 working days of approval.

Only where material is properly classified as restricted under the GPMS or if that material falls within the description at 2(2) of The Elected Local Policing Bodies (Specified Information) Order 2011 will the Commissioner not disclose decisions and/or information provided to enable that decision to be made. In these instances, Part 2 of the Form will be used to detail those matters considered to be restricted.  Information in Part 2 will not be published.

Is there a Part 2 to this Notice – No

Originating Officer Declaration –

Author name:     Gary Macdonald, Commissioners Chief Finance Officer  Collar number:     005299

I confirm that all the above advice has been sought and received and I am satisfied that this is an appropriate request to be submitted for a decision

Signature     Gary Macdonald                                                                               

Date  11.02.14