RIVERSIDE DEVELOPMENT SCHEME  

The Background

Over the past 40 years, there have been several proposals for the redevelopment of the Twickenham Riverside. 

In 2012, the Diamond Jubilee Gardens - Public Open Space on the swimming pool part of the larger Twickenham Baths site - were opened, significantly expanding on the Jubilee Gardens that had already been created on the same pool site in 2004.

The Trust currently holds a lease of 125 years on the Diamond Jubilee Gardens, located in a prime position raised above Twickenham's Embankment. The Trust is therefore a key stakeholder in Richmond Council's current proposals for the development of Twickenham Riverside. 

 

The Trust is working to protect, preserve and improve the provision of Public Open Space within the Council’s proposed scheme. Our statutory obligation, as defined by the Charity Commission, is to ensure that any exchange or reprovision of land is ‘equally advantageous’ to the people of Twickenham. We are optimistic that a fair agreement with Richmond Council will be reached and we will do our best to keep you updated through the news section of our website.

Brass Band sitting on grass.jpg
Timeline Summary of the Twickenham Riverside Development
  • October 2018: The Trust agrees with the Council’s proposal that the Diamond Jubilee Gardens, subject to both the Charity Commission Guidance (see section below), and the Trust's 'Principles for Development', are included in a proposed RIBA Competition for the development of Twickenham Riverside 

  • December 2018: The Local Stakeholders Reference Group (SRG) meetings start, inputting into the RIBA Competition Design Brief.  The Trust is a member of the SRG. 

  • March 2019: Launch of RIBA Competition for Twickenham Riverside

  • June 2019: RIBA Competition shortlisted candidates prepare their proposals

  • September 2019: Public consultation on the proposed schemes from the five shortlisted candidates 

  • November 2019: Hopkins Architects is named the preferred bidder, as chosen by the RIBA Competition Design Panel 

  • November 2019 onwards: The Trust enters into legal discussions with the Council regarding the terms of a new lease, subject to the reprovision of the Gardens in accordance with Charity Commission Guidance and the Trust's 'Principles for Development'.

  • February 2020: The Council's Finance Committee approves the appointment of Hopkins Architects

  • July-October 2020: Following input from the Environment Agency, the competition-winning design undergoes change

  • October 2020: Eight new Trustees are appointed to the Trust, with five ‘founding’ trustees standing down, having served the Charity Commission recommended maximum term of office of nine year

  • December 2020: The Trust’s newly formed Design Team (consisting of four trustees, two of whom are qualified architects) embarks on a series of meetings with Hopkins Architects

  • The Council suspends plans for a potential Compulsory Purchase Order (CPO) on the Diamond Jubilee Gardens to allow negotiations to continue with the Trust.

  • January 2021: The Council begins public consultation on the plans. Info here.

  • March 2021: The Council publishes the results of its consultation, to include its engagement with Children and Young People.

  • April 2021: the Council announces that in June 2021 it will use Compulsory Purchase Order Powers to obtain Diamond Jubilee Gardens, should negotiations with the Trust not result in an agreement.

  • May 2021: The Trust appoints Carter Jonas as its surveyor.

  • June 2021: The Council confirms its use of CPO powers to acquire the Trust’s demise within Diamond Jubilee Gardens, should on-going negotiations with the Trust not be successful.

  • The Trust briefs its surveyors Carter Jonas to prepare a Qualified Surveyor's Report and an Open Space Replacement Land report.

  • July/August 2021: The Trust’s surveyor prepares the reports which examine various aspects of the proposed reprovision of its land. The reports are with reference to Charity Commission Guidance and the Acquisition of Land Act (1981). These reports, and input from its legal advisers, guide the Trust’s negotiations with the Council.

  • September 2021: The Council confirms it will use Compulsory Purchase Powers to acquire Diamond Jubilee Gardens.

  • In advance of a council meeting on September 19th, the Council publishes revised documents that show a changed open space plan with respect to its Compulsory Purchase Order. As a result of these late-stage changes introduced by the Council, the Trust is advised by its surveyor and legal advisors that the recently completed Open Space Replacement Land Report prepared for the Trust will need to be revised.

  • Hugh Brasher, Chair of the Trust and a Trustee since 2012, stands down, having served the maximum nine years (minus four days) that a Trustee is allowed to be on the Trust. Trustee Martin Cox also stands down, his family having relocated outside of London.

  • Luke Montgomery-Smith is elected Chair of the Trust by his fellow Trustees.

  • October 2021: Jonathan Preece joins the Trust as a Trustee, replacing the legal skillset of recently retired Trustee Martin Cox.

  • The Council makes a Compulsory Purchase Order (CPO) to acquire the Trust's 125-year lease on the Diamond Jubilee Gardens.

  • The Trust's surveyor delivers a revised draft Open Space Replacement Land Report.

  • November 2021: The Trust submits to the Secretary of State its Objections to the CPO process and to the use of the Acquisition of Land Act (1981)

Richmond’s Council’s Compulsory Purchase of the Diamond Jubilee Gardens on Twickenham Riverside

The Twickenham Riverside Trust was set up in 2011 following a extensive campaign by local residents (including in a petition of over 8,500 signatures presented to Downing Street) explicitly to protect and preserve the public open space on Twickenham’s riverside. 

 

A 125-year lease on a substantial part of the Diamond Jubilee Gardens (opened in 2012) was granted to the Trust in 2014.

 

At that time, the then Leader of the Council stated that the lease was granted “in perpetuity for the people, so that never again can any other Council come forward with a plan to sell [the Gardens] off to a developer”. 

 

In October 2021, however, the Council launched a Compulsory Purchase Order (CPO) in order to enable development to take place on the Gardens.

 

In November 2021, with 118 years still remaining on the its lease, the Trust submitted its Objections to the CPO to the relevant Secretary of State’s office.

 

Please use the links below to view the Trust’s CPO Objections and their appendices:

 

TWICKENHAM RIVERSIDE TRUST OBJECTION TO THE LONDON BOROUGH OF RICHMOND UPON THAMES (TWICKENHAM RIVERSIDE) COMPULSORY PURCHASE ORDER 2021

 

TWICKENHAM RIVERSIDE TRUST OBJECTION TO THE ACQUISITION OF PUBLIC OPEN SPACE USING SECTION 19 OF THE ACQUISITION OF LAND ACT 1981, AS PROPOSED UNDER THE LONDON BOROUGH OF RICHMOND UPON THAMES (TWICKENHAM RIVERSIDE) COMPULSORY PURCHASE ORDER 2021

 

The seven Appendices below relate most specifically to the Objection to the Acquisition of Public Open Space, but also support the Objection to the Compulsory Purchase Order:

 

Appendix 1 Trust's demise within the Diamond Jubilee Gardens

Appendix 2 Order Land Council Finance Committee 20.9.2021

Appendix 3 Overlay of Order Land on Existing Gardens (plots 63 and 76)

Appendix 4A Flood Zones Planning Application Design & Access Statements

Appendix 4B Flood Zones Planning Application Design & Access Statements

Appendix 5 Embankment Vehicle/Cycle Corridor

Appendix 6 Examples of events in existing Gardens (photos/posters)

Appendix 7 Planning Application ‘Daylight, Sunlight and Overshadowing Report’ - External Amenity Areas

 

For more information about the CPO process and general information about the Trust, please see ‘More Information’ below.

More Information

What is the Trust's role in the proposed Twickenham Riverside development?


The Trust is liaising closely with the Council and its architects. The Trust has a 125-year lease on the Diamond Jubilee Gardens, held in trust as public open space for the people of Twickenham and beyond. In late 2018, the Trust agreed to include this protected public open space in the Council’s wider plans for Twickenham Riverside, subject to being able to obtain an Order (or permission) from the Charity Commission for any resulting changes to the location of Diamond Jubilee Gardens. The Trust is a charity and needs to be able to demonstrate to the Charity Commission that the reprovided Gardens are at least as good as, though ideally better, than the existing public open space, and that the overall development enabled by the inclusion of the Diamond Jubilee Gardens as part of the development site advances the Trust’s objects and “protects, preserves and enhances” Twickenham Riverside. The Trust has this statutory obligation to seek permission from the Charity Commission to ‘dispose’ of the Diamond Jubilee Gardens even though it is the intention that a ‘new’ Diamond Jubilee Gardens will be simultaneously reprovided.




How will the Trust decide if a new Diamond Jubilee Gardens have been appropriately reprovided?


The Trust has a statutory obligation to refer to Charity Commission guidance regarding disposing of charity land. Accordingly, the Trust appointed a legal team with experience in both charity and property law. Independent reports from a surveyor called Carter Jonas have been commissioned.

Once all the information has been collated, the Trustees will have a vote, as per their legal duty, with a simple majority determining the outcome.




What criteria are the Trust using to guide its decision making?


Charity law dictates that the Trust must always consider what is in the best interests of the charity, with reference to its Objects. This is one of the trustees’ main responsibilities and the Charity Commission emphasises that this must be borne in mind throughout the decision-making process. To that end, the Trust had carried out a week-long survey of existing users of the Diamond Jubilee Gardens. A detailed report can be found here and a shorter two-page summary can be found here. Key points from this survey were used to inform some of the Trust’s ‘Principles for Development’, submitted to the Council in December 2018 during early discussions about a riverside development. These development principles subsequently underpinned the section about the Diamond Jubilee Gardens in the June 2019 RIBA Competitions Design Brief for Twickenham Riverside. In seeking an Order from the Charity Commission, the Trust will therefore be looking at how successfully any reprovision of the charity land responds to the section about Diamond Jubilee Gardens in the RIBA Competition Design Brief, and also taking into account how the development as a whole addresses both its Objects and the RIBA Competition Design Brief, as created with input from local Stakeholder Groups. This latter is important as, in seeking an Order, the Trust needs to indicate any opposition to the disposal of the land (and by extension what any disposal thereof enables) and what measures the Trust has taken to resolve any opposition.




What is the timeframe of the proposed development?


The Council’s Twickenham Riverside Development website pages provide the most up-to-date information.




How much will the proposed development cost?


The Council, as and when it considers appropriate, makes financial information relating to the proposed development available. This can mainly be found in material (Agendas, Minutes, webcasts) related to meetings of the Council’s Finance, Policy and Resources Committee or meetings of the full Council.




Have a question?


If there is something specific you would like to ask, or have a comment about anything you have read on this website or about the development of Twickenham Riverside, we would be very happy to hear from you at: twickenhamriversidetrust@gmail.com




CPO: Has the Trust rejected the Council’s offer of the replacement land in exchange for its lease on Diamond Jubilee Gardens?


No, the Trust has not rejected the Council’s offer of replacement land. Discussions about this continue. However, the Trust has lodged formal Objections to the Compulsory Purchase Order process, initiated by the Council. The CPO Objections were submitted to the Secretary of State’s office following very clear advice from the Trust’s professional advisors. The Trust was advised to object to a process that was not in the best interests of the charity and its beneficiaries, the public. The CPO process could result, if Objections were not lodged, in the seizure of the Trust’s asset of its 125-year lease (with 118 years unexpired). This is a lease on an area of public open space sitting within - but not including the entirety of - the Diamond Jubilee Gardens on Twickenham Riverside.




CPO: Why has the Trust lodged Objections to the Council’s Compulsory Purchase Order (CPO)?


We have a statutory obligation, as defined by the Charity Commission, to ensure that any exchange or reprovision of land is ‘equally advantageous’ to what exists today. The professional advice we have received is that the public open space provided for in the CPO is not of equal advantage to what exists today and so we have no choice but to contest it. By objecting to the CPO, we are fulfilling our duties to protect public open space.




CPO: Does this mean the Trust opposes the overall redevelopment plans?


No. The Trust was founded in 2011 with the primary purpose of preserving, protecting and improving the riverside for the benefit of the public. Riverside redevelopment is long overdue in Twickenham, and we take our role as a key stakeholder in helping to make that happen extremely seriously. Our desire is for an agreement with the Council for the disposal of the land which ensures that, at the very least, the overall amount and quality of public open space currently enjoyed by the public on Twickenham riverside will be available to all in the redevelopment.




CPO: Where can you see the Trust’s Objections to the CPO that were sent to the Secretary of State?


The Objections can be seen on this website, above this ‘More Information’ section. The Trust objected to both the CPO process and to the proposed use of the Section 19 of the Acquisition of Land Act 1981. The Objections are based on the professional reports commissioned by the Trust in a process that started in June 2021.




CPO: On what grounds is the Trust objecting to the CPO?


The Trust’s Objection is in two parts. The first part is a general Objection, on the following grounds:

  • That no compelling case in the public interest has been established for a CPO and that it is not an act of last resort.
  • That the Council has not proved its case that the public open space has been increased or improved – either in the reprovisioned Gardens or the scheme itself.
  • That the Trustees are duty bound to contest the CPO.
  • That the Council has not yet secured planning permission for the overall redevelopment.
  • That the Council is unable to demonstrate today that it has all the funds required in order to implement the scheme being promoted by its CPO.
Full details around all these points are set out in the documents to be found in the section called “Richmond’s Council’s Compulsory Purchase of the Diamond Jubilee Gardens on Twickenham Riverside” above this 'More Information' section. The second Objection specifically addresses the Council’s use of Section 19 of the Acquisition of Land Act 1981 to support the CPO. We have been advised by our professional advisors that this is a flawed approach and an inappropriate use of that Section.

The issues relate to the overall public open space offered in the scheme. The Council is asserting that:
  • the new open space is as advantageous (in size and amenity value) as the existing open space which is being built on.
  • that a large section of the existing Gardens needs to be seized by the Council in order to preserve it and improve its management.
Our advice is that neither case is valid. Full details around all these points are set out in the documents above this ‘More Information’ section.




CPO: What happens next?


The CPO and our Objections to it will be considered by the Secretary of State for Levelling up, Housing and Communities who will determine the next steps. If the Secretary of State assesses that there is a need and the Council continues with its CPO, there could be a Public Inquiry sometime in mid to late 2022.

In parallel to this, we look forward to reprising the negotiations with the Council, in the light of the advice which we have received.




CPO: Can you continue to negotiate with the Council alongside this legal process?


Yes.




CPO: Is the Trust meeting with the Council?


There have been no meetings with the Council since 8th October 2021, when the new Chair of the Trust had an initial meeting with lead officers at the Council. The Trust has been in email contact with the Council’s Project Team since this date. When the Council formally launched its CPO process in late October with a one-month deadline for Objections, meetings between the Trust and the Council had to be put on hold. This was because the Trust’s Objections to the CPO were drawn up internally by Trustees, and this work, on the advice of the Trust’s professional advisors, had to be given priority over meetings with the Council. The Council’s Project Team was informed that this work was taking place, and that meetings would be reprised after the Objection submission deadline. The deadline for CPO Objections was 22nd November 2021. Meetings are accordingly resuming with the Council’s Project Team in December 2021.




To date, what have talks with the Council about the riverside development focused on?


Our primary focus has been on the Council’s offer of re-provisioned Gardens and what will satisfy the public open space requirement which we are duty-bound to protect. The discussions with the Council have centred on: 1. legal aspects – relating to the new arrangements under the new lease that the Council has offered and on transitional arrangements while the existing Gardens would be out of commission 2. the landscaping and configuration of the new spaces offered to the Trust and across the development. We now need to see what the Council will be proposing in the light of the points made in our Objections.




The Council said in a recent statement that you had agreed several months ago to their Heads of Terms in relation to the land exchange. Is this the case?


The Heads of Terms are the legal agreement about a new lease over a reprovided area of public open space. It was a surprise to us to see the Council state that an in-principle agreement had been made on the Heads of Terms as this is inaccurate. Several aspects of this legal agreement were still being discussed in April 2021 and beyond. Moreover, no discussion, other than on amenities and landscaping, had taken place on the critical attachment to the Heads of Terms terms containing the actual plan of the re-provisioned Gardens/public open space. During and since this time, too, the overall scheme – for example, layout and location of open space, vehicular movement on the site – continued to change. The reprovision offer to the Trust was confirmed only in June 2021. This is when we were first able to share it with our professional advisors.




Who are the Trust’s professional advisors, and why does the Trust need them?


Charity Commission Guidance regarding a Trust making an application to obtain an Order to dispose of its land requires that a Trust obtain independent advice from appropriately qualified professionals. As the Council is a “connected party” in any disposal - having been the original donor of the land - the Trust is not legally able to dispose of its land without first having obtained an Order for disposal from the Charity Commission. Accordingly, to comply with the Commission’s Guidance:

  • November 2019 - the Trust appointed BDB Pitmans as its legal representatives, with the lead advisor being a specialist in charity law.
  • May 2021 - the Trust appointed Carter Jonas to act as its surveyor.
Both appointments have been shown on the Riverside Development timeline (see above this 'More Information' section) on our website for several months. Carter Jonas has prepared two reports for the Trust: a Qualified Surveyor’s Report and an Open Space Replacement Land Report.




Can the Trust share with the public the advice and the professional reports it has received from its professional advisors?


In October 2020, the Council formally indicated its intention to use Compulsory Purchase powers to obtain the land within the Diamond Jubilee Gardens protected by Trust’s lease. From this point onwards, the Trust’s professional advisors advised the Trust that, in the light of possible future legal action, it would need to keep confidential the advice it was receiving, to include the detailed content of the reports being commissioned. To act otherwise would be to not act in the best interests of the charity and its beneficiaries. The Trust continues to be guided by its professional advisors in this regard, and is making public such information as its advisors feel will not prejudice the Trust’s legal position. The Trust’s second Objection (to the Acquisition of Public Open Space) provides a comprehensive description of the Trust’s case on this specific aspect – see the links to the Trust's Objection document above this 'More Information' section. It is to be noted that, had the Council not formally indicated in October 2020 its intention to use Compulsory Purchase powers, the Trust would have been able to communicate much more openly with the public.




How is the Trust funding the professional advice it receives?


Once an Acquiring Authority (AA) - in this instance, the London Borough of Richmond upon Thames - has indicated it intends to use Compulsory Purchase powers, it is understood by all parties that the legal costs of those affected by the proposed use of such powers will be met by the AA whilst parties remain in negotiation. The Council first formally indicated its intention to use Compulsory Purchase powers in October 2020. The Trust has not received any advice paid for out of public funds other than in connection with the Qualified Surveyor’s Report and the Open Space Replacement Land. The Trust did not use any public funds to object to the CPO process. Both of the Objections submitted to the Secretary of State were written by Trustees, and submitted with the approval of all Trustees present at a meeting (one Trustee was absent and had not nominated a proxy). The Council-appointed Trustee, as with all matters relating to the proposed riverside development, participated in neither the drafting nor the approval of the Objections.




Going forward, will the Trust be engaging with the public more?


The Trust fully intends to step up its engagement with the public. However, this needs to happen at an appropriate juncture in the Trust’s decision-making process. A significant part of this engagement process will be guided by and with reference to the independent reports the Trust has been obtaining from its professional advisors. This process started in May 2021, with the appointment of the Trust’s surveyors, Carter Jonas. Due to significant changes outside of its control, the Trust was only able to brief Carter Jonas in June 2021. Additionally, the Council made changes to the open space exchange land in its CPO case just before submitting the relevant documentation to the Secretary of State. As a result, the Trust’s surveyors had to make substantial revisions to the Open Space Replacement Land Report it had submitted to the Trust just a few weeks prior. The final revised version of this report, first commissioned in August 2021, was only available in early November 2021.




How are decisions taken by the Trust?


Following the consideration of any relevant advice and a meeting, Trustees vote. Those Trustees not present at the meeting can appoint a proxy to vote on their behalf. For example, the decision to accept the advice from our professional advisors that to object to the CPO process was to act in the best interests of the charity: all Trustees - with the exception of the Council-appointed Trustee, and one absent Trustee who had not appointed a proxy - took part in a discussion followed by a vote. It was a unanimous vote of those present in favour of accepting the advice of the Trust’s professional advisors. The Council-appointed Trustee does not participate in discussions/votes and nor is party to any professional advice sought by the Trust with respect to the Twickenham Riverside Development. This is due to a conflict of interest that she has declared arising from her employment by the Council.




How were the new Trustees who joined the Trust in October 2020 and October 2021 appointed?


Any recruitment of new trustees has always been undertaken in close liaison with and following the advice of the Richmond Council for Voluntary Service (RCVS). Candidates are invited to submit a letter of interest. Short-listed candidates are then interviewed by at least three, but usually four, existing Trustees. Their appointment is then considered and ratified by the whole Trust. Information regarding the above resignations and appointments can be found on both the Charity Commission website and Companies House website.




When new Trustees join the Trust, what training do they receive?


All new Trustees receive a ‘New Trustee Pack’, which include copies of the Trust’s lease on Diamond Jubilee Gardens and the Management Agreement, in addition to other background documentation, to include that as recommended by the Charity Commission. Several Trustees have also taken part in Trustee training sessions organised by the Richmond Council for Voluntary Service.




Who is responsible for the maintenance of Diamond Jubilee Gardens and are Trustees involved with that?


At the moment, under the 10-year Management Agreement between the Council and the Trust, the Council is responsible for the maintenance of the Diamond Jubilee Gardens. However, in 2024 the Trust will become responsible for some aspects of the Gardens’ upkeep. Several Trustees live near the Gardens, and are able to help the Council’s various maintenance teams with input regarding general maintenance and repairs. In the past 18 months, Trustees have either organised or liaised closely with the Council regarding:

  • new planting to all the Gardens’ planting beds
  • weeding/maintenance of the planting beds
  • removal of a redundant watering system
  • upgrade to the sandpit
  • on-going repairs to the c.50 garden lights that are longer working
  • on-going work to replace missing benches in both the Gardens and along the Embankment Promenade
  • ensuring that the Council-owned empty pool buildings are adequately secured
  • replacement bins for the riverside, the ones currently being trialled not suitable for the location
  • litter picking in the less accessible areas in and around the Gardens




How will the Trust fund the maintenance of the Gardens when the Council is no longer responsible for certain aspects of their upkeep in 2024?


As part of the brief to its surveyors, the Trust obtained a detailed breakdown of the maintenance costs associated with the Gardens. It also obtained clarification, under the terms of its lease, what aspects of the upkeep the Trust would be liable for after the end of the existing Management Agreement in 2024. Based on this information, the Trust is confident that, given the relatively limited maintenance costs for which it would be liable, the Trust would be able to meet its obligations using the revenue from the cafe currently on the Gardens, rent from which would be payable directly to the Trust when the Management Agreement ends in 2024.




Has the Trust organised any events on the Diamond Jubilee Gardens since January 2020?


The 10-year Management Agreement - which runs alongside the 125-year lease - requires the Trust to facilitate six events a year to be held on the Diamond Jubilee Gardens. Every year, by approximately the end of February, the Trust presents a schedule of events for the year. The Trust will publish its list of events for 2022 in the Spring 2022. At the end of February 2020, a calendar of events for 2020 was agreed with the Council. This was a calendar of events similar those that have been taking place in the Gardens since 2014:
2020 CALENDAR OF EVENTS

  • Sat May 30th
    Twickenham Riverside Dog Show
  • Sun June 14th
    Axel Scheffler at the Twickenham Festival
  • Sun June 28th
    Richmond Brass Band
  • Sat July 11th
    High Tide Festival
  • Sat 25th or Sun 26th
    July RNLI event (TBC)
  • Tues Sept 1st
    Petanque Taster Day
  • Fri Sept 25th
    Twickenham-on-Thames Heritage Day
    (part of Totally Thames 2020)
  • Sat Sept 26th
    Twickenham-on-Thames Heritage Day
    (part of Totally Thames 2020)
  • Sun Nov 22nd
    Xmas event
    (content to be discussed)
Unfortunately, the global pandemic of March 2020 onwards prevented these events from taking place.

In early Spring 2021, the Trust liaised with Council officers regarding events for the Summer 2021, and it was agreed that no events would be programmed for that summer. In September 2021, the Trust liaised extensively with the organisers of the High Tide Festival to host a large stage on the Events Space on the Diamond Jubilee Gardens. And for December 2021, the Trust has organised a Dog Show.




What does Charity Commission Guidance say about disposing of “charity land”?


The Twickenham Riverside Trust is a charity and is therefore subject to Charity Commission guidance and regulations. The Charity Commission has produced a 32-page Guidance document: “What trustees need to know about disposing of charity land.” The full Guidance can be read here. The Guidance outlines what trustees ‘should’ do and what trustees ‘must’ do. When it is indicated that trustees ‘must’ do something, this means that there is a specific legal or regulatory requirement that must be complied with. One of these regulatory requirements relates to when the “original donor” of the land (in this case, the Council) is involved in any transaction. In these circumstances, a charity must obtain an Order, or permission, from the Charity Commission before it can complete any transaction. To obtain an Order, the Trust will need to present a case to the Charity Commission that the disposal of its land is in the best interests of the Trust, that it will further the purposes of the Trust and that it will be beneficial to the Trust. The proposed terms of any transaction must be the best that can be reasonably obtained and any replacement land must be of “equivalent amenity value.” The Trust’s legal representatives at BDB Pitmans are specialists in both charity and property law, and have been advising the Trust in its negotiations with the Council since November 2019.