Transport Investigations “administrative option” - is this fair please?

Ignoring the weird wording of the latest letter (what does "extend the law" mean?), unfortunately your account explains exactly why you aroused suspicion.

You repeatedly said that you had travelled from Bristol, and the staff member quite reasonably said that you had an opportunity to pay there.
Under caution you then changed your starting point to Parson Street, which (conveniently) means you had no means of paying..
An inconsistent story is bound to arouse suspicion, especially when you change it when challenged.

I understand from your account that you travel reasonably regularly from Parson St to Cardiff, and would assume that you know that the station is not called Bristol Parson St.

Please be aware that I am not doubting your story, merely pointing out how it might seem to a staff member who is used to inconsistent stories.

30907 said:

Ignoring the weird wording of the latest letter (what does "extend the law" mean?), unfortunately your account explains exactly why you aroused suspicion.

You repeatedly said that you had travelled from Bristol, and the staff member quite reasonably said that you had an opportunity to pay there.
Under caution you then changed your starting point to Parson Street, which (conveniently) means you had no means of paying..
An inconsistent story is bound to arouse suspicion, especially when you change it when challenged.

I understand from your account that you travel reasonably regularly from Parson St to Cardiff, and would assume that you know that the station is not called Bristol Parson St.

Please be aware that I am not doubting your story, merely pointing out how it might seem to a staff member who is used to inconsistent stories.

Click to expand...

It’s pretty rare to be able to gain ticketless access to the platforms at Temple Meads at evening rush hour though, as the gatelines are always manned and in use.

Hi 30907


Thank you for your reply, and no worries, fully understood!


When the barrier person asked me where I’ve just come from (which they did), I just said Bristol. I can’t escape that fact, it’s a reasonable response from someone from Bristol.


Had I been asked what station have I travelled from, or when saying “Bristol”, to clarify exactly what station in Bristol, I would have said Parson Street.


I would like to add please that was the only time I stated I had travelled from Bristol – the second time was confirming “yes” when asked – “so you’ve come from Bristol?”….


I do wonder, if this is the entire crux of this whole situation, i.e. ”Bristol” is not the name of a station, why not just ask me to confirm exactly where I’ve come from before going down the caution route?


Not that that matters now I guess – Presumably I have no case as the opportunity to pay @ Bridgend was legitimately bypassed?


Many thanks


TP

Also, in my written answer taken by the inspector I said Parson Street, plus expected departure time (17:06) and how long it was delayed by (14 mins). All exactly true, and pretty elaborate for someone wanting to change their story after being cautioned – but maybe some people are genuinely that devious tho!


But if I’m that devious, I'm probably going to say Parson Street to begin with!

And as the revenue inspector has written “travelled from Bristol” on his form, and given “Bristol” is not a station name rather a geographical location, is it not fair to say that up until that point all that can be assumed was that I had travelled form a geographical location, rather than a station with ticket facilities?

Sorry, just thinking outloud. It’s really starting to really affect my thinking TBH and I’m just wondering if it’s just simpler to pay and move on…

Some suggestions, which if you feel appropriate you can drop into the appropriate sections of your letter.

(First para)
Further to your latest letter of x, I believe that, in line with the NRCoT, I was entitled to attempt to purchase a ticket on arrival at Bridgend, (which I attempted to do), and will again set out my journey and the reasons why I believe this. I think it is now well established that I commenced my journey at Parson St, a station without ticketing facilities, and that point is not at issue.

Between Parson St and Cardiff Central, the obligation is to buy a ticket "as soon as you are reasonably able" "from the conductor on the train if one is available". This is not the same as your assertion that I should "pay the fare due immediately on boarding the train". It is not unreasonable to assume that in a journey of over an hour a ticket check will be carried out, at which time I would have purchased a ticket. It is not reasonable to expect a passenger to seek out a conductor on a crowded commuter train, thus giving up my seat, particularly when the conductor is often in the back cab and unavailable.

At Cardiff, as the NRCoT explicity state that I should only purchase a ticket if sufficient time is available before my connecting service, again I did not breach them, contrary to your assertion, with only 4 minutes before the scheduled departure (less than the minimum connection time, and certainly less than time needed to find the unpaid fares staff, queue, pay, and return to the platform).

(Second bullet between Cardiff and Bridgend)
However, notwithstanding the discussion with the catering staff, by this time I did attempt to seek out the conductor, although as stated above there was no obligation for me to do so. I passed through the full length of the train but was unable to find anyone.

Personally I would drop the section regarding the confusion between Bristol and Parson St, although you might add to the appropriate bullet point "...to which I replied Bristol. As Parson Street is in Bristol, this was an accurate answer - had I been asked which station I had travelled from then I would have been more explicit in my response."

(Before last para)
I note that you quote the Railway Byelaws 2005 of the Regulation of Railways Act 1885. Setting aside that there is no such act, the relevant paragraph of the Byelaws is Paragraph 17, travel from a compulsory ticket area, where paragrah 3.1 specifically allows me to board at Parson St, as it has no ticket purchasing facilities.

Last para
In conclusion, I started from an unstaffed station, I was given no opportunity to purchase between Parson St and Cardiff, no opportunity between Cardiff and Bridgend, and so was entitled, under the NRCoT to purchase a ticket at Bridgend, which I actively sought to do, and was denied. I would note that the NRCoT explicity state that the option to purchase on arrival is allowed under these circumstances. At this stage I have still not been given a chance to pay the fare due, and would reiterate that I wish to do so to settle the matter. I am however, not prepared to pay the amount due, and should you proceed to a court case then I will be pleading not guilty and setting out the circumstances, as laid out above, which has led to the railway breaching its own Conditions of Travel.

This is definitely worth fighting. Hope these suggestions are helpful, and happy if others chip in with any other comments.

Is there a typo here?

Brissle Girl said:

Last para
I am however, not prepared to pay the amount due, and should you proceed to a court case then I will be pleading not guilty and setting out the circumstances, as laid out above, which has led to the railway breaching its own Conditions of Travel.

Click to expand...

Should it actually read

I am however, not prepared to pay the amount demanded, and should you proceed to a court case then I will be pleading not guilty and setting out the circumstances, as laid out above, which has led to the railway breaching its own Conditions of Travel.

Firstly, you have some time to think about this, because they are now talking about 3 January.

Maybe it's possible to deal with this more simply, by sending something like:

"Dear TIL,

Please clarify the allegations and statement about a possible allegation of intent.

1. How can I be guilty under a byelaw, when the byelaws say I can't be guilty if I started at a station with no ticket facilities? Your first letter accepts that I started at Parson St, which appears to mean I am automatically innocent.
https://www.gov.uk/government/publications/railway-byelaws/railway-byelaws#travel-and-fares-1



2. Are you suggesting it may be beyond reasonable doubt that I am guilty of intent to avoid a fare? I can see no reason for you to suppose I was aware of any requirement to seek a conductor, or delay my journey to buy a ticket at Cardiff. If your view of the Conditions of Travel is correct that there are such contractual requirements, which is not clear to me, that would create a civil liability, not a criminal offence."

Fawkes Cat said:

Is there a typo here?



Should it actually read

I am however, not prepared to pay the amount demanded, and should you proceed to a court case then I will be pleading not guilty and setting out the circumstances, as laid out above, which has led to the railway breaching its own Conditions of Travel.

Click to expand...

Absolutely! Good spot and thanks.

some bloke said:

2. Are you suggesting it may be beyond reasonable doubt that I am guilty of intent to avoid a fare? I can see no reason for you to suppose I was aware of any requirement to seek a conductor, or delay my journey to buy a ticket at Cardiff. If your view of the Conditions of Travel is correct that there are such contractual requirements, which is not clear to me, that would create a civil liability, not a criminal offence."

Click to expand...

Being aware or not of a law is not normally a valid defence, so I'm not sure I would use that word.

I would prefer to be more explicit, set out in noddy steps how I haven't breached the law on any step of the journey, and effectively set out my defence in court should it go that far. Given the nature of the people dealing with these cases, who can't even quote the correct law, this may be preferable to a statement that they may not even understand, and thus just result in another repetitive rebuttal. However, it's the OP's choice.

Brissle Girl said:

I note that you quote the Railway Byelaws 2005 of the Regulation of Railways Act 1885. Setting aside that there is no such act, the relevant paragraph of the Byelaws is Paragraph 17, travel from a compulsory ticket area, where paragrah 3.1 specifically allows me to board at Parson St, as it has no ticket purchasing facilities.

Click to expand...

I think the above should refer to para 18?

Remember that Penalty Fare areas are not usually compulsory ticket areas.

Brissle Girl said:

Being aware or not of a law is not normally a valid defence

Click to expand...

The question I'm asking is whether there is solid evidence of intent to avoid a fare, rather than intent to break a law.

I see no law requiring a passenger to delay a journey by buying at an intermediate station, and the Passengers' Charter instructs passengers to "buy a ticket from the Conductor", rather than to seek a conductor.

https://tfwrail.wales/sites/tfwrail.wales/files/2019-09/Passenger's Charter English 19092019.pdf


Edit: The GWR Passenger's Charter says,

"Where a station isn’t staffed, or the ticket machines aren’t working or cannot
give you the ticket you want, you must, as soon as you are reasonably able, buy
an appropriate ticket to complete your journey."

https://www.gwr.com/~/media/gwr/pdf...er's-charter-english-april-2019-web.pdf?la=en

This question may seem trivial to you, but if they decide to proceed it may well be considered important at a later stage.

When you were under caution, were you were given an opportunity to read, check the words written and to sign the notes made by the Inspector as accurate?

Brissle Girl said:

the obligation is to buy a ticket "as soon as you are reasonably able" "from the conductor on the train if one is available".

Click to expand...

The second isn't even a contractual obligation, as it's in an information box rather than a Condition.

https://www.railforums.co.uk/threads/requirement-to-find-the-guard.189136/#post-4157422

Brissle Girl said:

I was given no opportunity to purchase between Parson St and Cardiff

Click to expand...

They might think that in a way there was an opportunity, if the guard was available elsewhere on the train. It might be better to say,

"I see no clear obligation to seek a conductor in the Conditions of Travel, Byelaws or section 5 of the 1889 Act.

[@treep80, section 5 mentioning "intent" is at https://www.legislation.gov.uk/ukpga/Vict/52-53/57/section/5]

The statement "you should buy a ticket from the conductor on the train if there is one available" is not in any Condition of Travel; it is in an information panel. Page 3 of the Conditions states these are not part of the contract. The same is clear from the start of Appendix B.

Even if an obligation to seek a conductor were beyond doubt, I was in any case not aware of any such requirement. I am not aware of any widespread publicity for that idea.

I therefore cannot see how it was other than reasonable for me to sit waiting for a conductor, or how remaining seated could be substantial evidence that I somehow intended to avoid a fare."

Hi…I would like to thank EVERYONE for their replies and advice! Given I have time, I’m going to take a breath and look back over everything over the next few days and consolidate into two responses (one short & one long) please.


Hi @ Fare-Cop: Yes - I was given the opportunity to sign the notes as accurate. Re-reading again:


[1] Jumps straight in at me explaining how the late departure from Parson Street left me no time at Cardiff.


[2] Doesn’t mention anything about a conductor having passed though or not. I certainly said one had not during our conversation (and reiterated in my mitigating evidence), be it proactively or in response to being asked if one passed through. Maybe I didn’t emphasise enough that one didn’t (TBH I wasn’t expecting one to pass though given it was pretty busy, and historically hasn’t done anyway – hence why I previously used unpaid fares at Cardiff)


I hope an incorrect conclusion hasn't been drawn that a conductor did pass through whom I ignored, because I wanted to get my tickets at Cardiff unpaid fares (which would be baffling – why would anyone do that when they can on the train?)


[3] Arriving @ 18:20 & connecting 18:25 left me 3 minutes. Maybe I said 3 as by the time I had got off, and knowing doors close 30 seconds (?) before departure? But the maths shows it was 5


[3] Doesn’t specify where I asked the beverage seller if the conductor would come through. It was on the train, I was seated, and it was before the train departed. (I remember it departing late, which worried me thinking I’d got on the wrong one!)


[5] Says I passed through the train looking for her. I just went to the rear (that's where Iw as told she was) from where I was sat, through first class (which I remember I felt awkward about). I didn't go forward.


[6] Doesn’t mention my conversation with the barrier gentleman




Of course, knowing what I know now, I would have scrutinised every word on that report and explained how every opportunity (start / train / interchange / train) was not there or unreasonable. But at the time I felt it was an accurate summary of my journey, explaining how I hadn't got a ticket or tickets by the time I reached Bridgend…..and absolutely no intention to fare evade.


It’s the first time I’ve ever gone through anything like that.

I'm worried that the omission of any reference as to whether the conductor "did or did not approach me or pass though" from Parson Street changes something - does it please?

(I don’t think so as the argument is not being given the opportunity to purchase at Bridgend, and thus should not have been cautioned in the first place?)

Thanks again everyone…


Many thanks


TP

I remember vividly the gist of the conversation I had with the revenue inspector - I was told no I cannot buy a ticket because of how far I’ve come / where I’ve come from (cannot be exactly sure of teh words used), and had plenty of opportunity. I remember then joking how I could have just said I've came from Cardiff (bad taste!?), to which he replied (smilingly) I couldn’t as they have barriers. I then start explaining my journey…..but told I’ll be able to provide a statement. Cautioned then written statement given….


How could he know what opportunity I had or hadn’t had by the time I got to Bridgend?


Sorry, thinking & rambling out loud again!

I'll carry on compiling my response letter(s) as advised above – thankyou again

Just to add, is the fare from Parson Street the same as the Fare from Temple Meads? I think it is and if so you've therefore not attempted to deprive the railway of any money (avoid a fare), I'd have to check the fares, also, it may be worth contacting GWR as they've had numerous issues with star mobile machines batteries draining, on services where this happens it is logged with control.

Again, I can see why the RPI started with the route of a report for prosecution as they were acting on what you said, you needed a ticket from Bristol, even at the point of this being clarified in the interview I still get why he carried on and submitted the report as it may seem to him that you changed your mind when questioned to a convenient station with no facilities (this happens often by people playing the system - I'm not saying you are, just saying why the inspector carried on).

It should all then have become clear once you had responded and shown clearly that you had in fact travelled from Parson Street and had not attempted to avoid your correct fare!

Apologies for the bad grammar in the above post, not easy typing an essay on this phone

I note that in your first post you mentioned your local station. I assume that this is Parson Street.

Is this the nearest station to your home address?
If so then it would aid your credibility to point this out - something like "as you can see from my address that Parson Street is the nearest station, being [number] minutes walk OR being [number] [units] away.

Just my thoughts to help you in making your case that you did indeed commence your journey at Parson Street.
Please do not post your street address on the forum

A couple of points:

1) A while back, I suggested that you write courteously. I'm a little worried that the tone of what we're putting together here might be a little confrontational. To take an example (and please let me emphasize that this is not meant as a dig at anyone)

some bloke said:

"I see no clear obligation to seek a conductor in the Conditions of Travel, Byelaws or section 5 of the 1889 Act.

Click to expand...

This is accurately worded, which is good - but if (as a representative of the railway) I was reading it, I might feel rather under attack. To my mind, I would feel happier with wording rather like

"I see no clear obligation to seek a conductor in the Conditions of Travel, Byelaws or section 5 of the 1889 Act so I would be grateful if you could explain why you think I am obliged to do so.

I know it's adding words but it's offering a way for the railway to either explain their position or gracefully withdraw. Since your aim is to get them to withdraw, then surely making it easy for them is a good thing.

2) The more this discussion goes on, the more convinced I am that the railway thinks that you started your journey at Temple Meads or Parkway, both of which have ticket sales facilities. We know why the railway think that, although you have also told them that you started at Parson Street. So it's in your interest to do what you can to help them understand why you started at Parson Street.

We don't know where you live (and to respect your privacy, we don't need to). But if you live much nearer Parson Street than Temple Meads or Parkway, then explain this to them. If there's some other good reason why you started there, then explain that!

(And I now see that @PG has made exactly the same point.)

It's far, far too long and comes across as suspiciously over-analysed IMHO. Just respond succinctly to the bits that matter - don't go inventing problems that aren't stated.

Hi RPI - no worries at all, and yes it is the same fare please (if I were travelling later today):

Parson Street to Bridgend = £22.90
Parson street to Cardiff Central = £13.80

Bristol Temple Meads to Bridgend = £22.90
Bristol Temple Meads to Cardiff Central = £13.80

(Cardiff to Bridgend is £5.20 – incidentally these are the exact prices I was expecting to pay on the day in question - hence my reason to split ticket)

In the eyes of the RPI, I still can’t fathom why me saying “Bristol” automatically assumes it was from a station with facilities. If it’s “Bristol” geographically then some do have no facilities; if it’s a station with the word “Bristol” in then there is more than 1. Either way, it’s surely fundamental at that point to ask me exactly which station….

…and why, once cautioned, I’m deviously changing my story to a station with no facilities - why not just say that station in the first place. But as you say, they have probably heard every tale under the sun!

Hi PG & Fawkes Cat – Yes Parson Street is 5 mins walk from my house (Temple Meads is 30 mins walk and parkway is a car journey) - I’ll be sure to mention that

And thankyou everyone again for all your replies!

Many thanks

TP

treep80 said:

Hi RPI - no worries at all, and yes it is the same fare please (if I were travelling later today):

Parson Street to Bridgend = £22.90
Parson street to Cardiff Central = £13.80

Bristol Temple Meads to Bridgend = £22.90
Bristol Temple Meads to Cardiff Central = £13.80

(Cardiff to Bridgend is £5.20 – incidentally these are the exact prices I was expecting to pay on the day in question - hence my reason to split ticket)

In the eyes of the RPI, I still can’t fathom why me saying “Bristol” automatically assumes it was from a station with facilities. If it’s “Bristol” geographically then some do have no facilities; if it’s a station with the word “Bristol” in then there is more than 1. Either way, it’s surely fundamental at that point to ask me exactly which station….

…and why, once cautioned, I’m deviously changing my story to a station with no facilities - why not just say that station in the first place. But as you say, they have probably heard every tale under the sun!

Hi PG & Fawkes Cat – Yes Parson Street is 5 mins walk from my house (Temple Meads is 30 mins walk and parkway is a car journey) - I’ll be sure to mention that

And thankyou everyone again for all your replies!

Many thanks

TP

Click to expand...

I understand why you would generalise "Bristol" as being any station in the Bristol area but to a member of railway staff, particularly one who works a fair (but admittedly not a massive) distance away then a safe assumption if someone asks for a ticket from "Bristol" is that they've come from Temple Meads, look at it another way, if you had mad a journey from Parson Street to Temple Meads and arrived at the excess desk asking for a ticket then where would you say you had travelled from?

This may all seem trivial but its helps to understand why you were reported in the first place - even if it should now be obvious to TIL that you haven't actually committed an offence!

By changing to Parson Street during the conversation the RPI may, as I pointed out earlier, believe that you have travelled from another station but knowingly changed to Parson Street because it is unstaffed with no facilities, an example would be that before Weston-super-mare had ticket barriers people would ask for a ticket from Weston-super-mare, when asked why they hadn't purchased they'd change to Weston Milton because they knew they couldn't be Penalty Fared.

Again, I'm not saying you're guilty of any of this I'm just giving the view that the RPI may have had at the time, it's important to understand that all an RPI does when completing an MG11 is report the facts to the prosecution team, it's down to the prosecution team to weigh up whether to take further action.

I say this as someone who has been an RPI for over 10 years (NOT working for TIL I hasten to add!)

If you'd have arrived at Bridgend and stated that you needed a ticket from Parson Street then I expect you'd have been sold the ticket as requested, again, I can see that you haven't done anything to intentionally avoid your fare, the whole thing just looks like crossed wires!

RPI said:

the whole thing just looks like crossed wires

Click to expand...

Well, yes.



I'm almost tempted to suggest sending just the question and statement below (using more polite words if desired), and seeing if they have the nerve to allege intent. All the other mentioned offences seem to be inapplicable.

some bloke said:

How can I be guilty under a byelaw, when the byelaws say I can't be guilty if I started at a station with no ticket facilities? Your first letter accepts that I started at Parson St, which appears to mean I am automatically innocent.

Click to expand...

RPI said:

Just to add, is the fare from Parson Street the same as the Fare from Temple Meads? I think it is and if so you've therefore not attempted to deprive the railway of any money (avoid a fare)...

Click to expand...

I know it's perverse but, for the purpose of the Regulation of Railways Act, two fares are no considered interchangable simply by dint of them being for the same amount of money.

some bloke said:

I'm almost tempted to suggest sending just the question and statement below (using more polite words if desired), and seeing if they have the nerve to allege intent.

Click to expand...

There's no way that a Byelaw 18 prosecution could succeed, but if they were being exceedingly pedantic they could argue that the OP was attempting to short-fare - inasmuch as the ticket that they were "attempting" to buy didn't cover the entire journey. (See point above)

I don't think there is any question regarding short faring between Parson St and Temple Meads, so probably best not to confuse matters. They seem to have accepted that the OP started the journey at Parson St. I agree there is no way that a Byelaw 18 could succeed, but the danger is that when they realise this they change it to a more general concern regarding not having made enough of an attempt to purchase before arriving at Bridgend.

Brissle Girl said:

...but the danger is that when they realise this they change it to a more general concern regarding not having made enough of an attempt to purchase before arriving at Bridgend.

Click to expand...

Which is why @Fawkes Cat has the right idea. Ask the TOC what the OP was supposed to have done in order to comply with rules that clearly say you can purchase at your earliest opportunity - which includes at your destination.

If the byelaw doesn't apply (if there are no other considerations such as the existence of/requirement to use a Permit to Travel machine), the real question is how they could show intent rather than whether you breached the contract (ie the Conditions).

Even if a magistrate thought "reasonably able" meant that you broke the contract by not seeking a guard, that doesn't necessarily prove intent.

We don't know whether they have any interest in pursuing an allegation of intent, once it's made clear that
a) the byelaw offences mentioned don't apply and
b) no law or Condition requires delaying a journey to buy at the intermediate station.

You could repeat that you have paid at Cardiff before - it seems to me a bit difficult for them to prove intent beyond reasonable doubt. These seem to me relevant points worth repeating:

treep80 said:

I have travelled before to Cardiff, same day & time as recently as September 2019, and always used unpaid fares. I know where it is and how long it takes, and 12 mins is more than enough under normal conditions

Click to expand...

treep80 said:

Train arrives late by 14 mins, but still shows unchanged arrival time into Cardiff

Click to expand...

treep80 said:

[2.6] Tell the first train staff I see (refreshments trolley) I need to buy tickets and would the conductor be passing though

[2.7] Was told the conductor is at rear of train and not to worry

[2.8] Before arriving in Bridgend she has not passed through, so I look for her (walk to rear through 1st class and cannot find)

Click to expand...

Were there open barriers at Bridgend, giving you the choice to walk out without paying, and yet you still asked about paying? If so, that would make an allegation of intent less plausible.

(Intent may be implausible for another reason as well: If a return is not much more than a single, you'd have to dodge on the way back as well to make a significant saving, and if there are barriers at Bridgend it might be harder than on the way out - but this may not be worth mentioning)

The draft says you boarded at Bridgend - would need correcting to Cardiff.

It may be wise to make sure that any communication is phrased in a way that can't be interpreted as rejecting their offer.

I would write to them restating all the circumstances ie, that you started your journey at a station with no ticket facilities, that you had no opportunity to purchase a ticket en route, and you were therefore entitled to purchase a ticket at your destination. Add that, in these circumstances I enclose payment for the fare due of £xx.xx and trust that this will resolve the matter. Add that any action they might bring will be defended in court and that you will seek to recover your legal costs from them. Enclose with the letter a cheque for the actual fare due then sit back and see what they do next.

Hi all, thanks again for all your replies and advice! (..and barriers at Bridgend were UP if I remember rightly)


I'm finishing my response, which is essentially:


[1] Each purchase opportunity (start / train / change / train / end) and how I acted in accordance with NRCoT (apart from end where I was denied - a potential breach of their own conditions)


[2] My conversation @ Bridgend (I said “Bristol”)


[3] Given I acted in accordance NRCoT, what did the Rail Company expect me to do?


[4] Mentioned their incorrect reference to of Regulation of Railways Act 1885


[5] Asked how I can be guilty under bylaw 18 when that states I can start from a station with no ticket facilities.


It’s written a bit “mechanically” TBH - I did [1] as a table / matrix – but it’s the simplest way for me to process & summarise – and it should be to anyone reading too.


Agreed, I don’t want to infer I’m reject their offer - I’ve got to be honest, the legal stuff & costs concern me and I’m hesitant about gambling with them. I don’t know enough about the legal process and I’m not even sure what I’m being threatened in court with:


[1] Intent to evade fare? - vehemently deny this, not true!


[2] Innocently travelling ticketless because I didn’t make enough effort? – sure I could have gone up and down both trains, delayed my journey at Cardiff…but NRCoT do not mandate this.


[3] Something else?



…so I’m just working on this last part!



Many thanks again


TP