Statement on Tree Replacement by Sheffield City Council

Statement on Tree Replacement by Sheffield City Council

From: Bob Jeffery [mailto:bobjeffery.sheffieldtuc@gmail.com]
Sent: 18 February 2016 16:37
To: editor@jpress.co.uk; news@thestar.co.uk; Julia Armstrong; ellen.beardmore@sheffieldnewspapers.co.uk; Leeds Look North; RSF Internet; South Yorkshire Online
Cc: Bob Jeffery; Martin Mayer
Subject: Statement on Tree Replacement by Sheffield City Council

Statement on Tree Replacement by Sheffield City Council

To whom it may concern,

We, the undersigned, our writing to express our consternation at the extent of the negative media coverage relating to Sheffield City Council’s tree felling operation, being conducted by the subcontractor AMEY. Firstly, let us state that we are all in favour of environmental protection, we accept the reality of climate change and acknowledge the importance of green spaces for creating healthy and vibrant communities. Nonetheless, we do feel that the extent of negative publicity that the Council has faced has been hugely disproportionate.

Let us be absolutely clear about this situation. Sheffield has an estimate 2 million trees within its borders, giving it a strong claim to be the greenest city in Europe. The council are proposing felling and replacing 14 per cent of the 36,000 street trees, or 5,000 in total. After this process is complete, Sheffield will still have a strong claim to be the greenest city in Europe.

Moreover, the City Council is not felling these trees because they ‘hate the environment’, but because professional tradespeople have deemed these trees to be in danger of falling down, or because they are damaging pavements and potentially hampering the mobility of the elderly and disabled. Trees that have a strong potential of future risk, at a time when roads, pavements and lighting are being upgraded or replaced, are also in scope. Ignoring that is simply adding a greater expense onto current and future Council budgets. It should also be noted that the current AMEY contract was negotiated by Liberal Democrat and Labour Councils over many years. Nor are the council removing these trees once and for all, they are replacing them with younger trees and with species more suitable for an urban environment.

We also feel it important to state that the opposition to these tree-felling operations is solely concentrated in the most affluent neighbourhoods within Sheffield, with the local groups that compose Sheffield Tree Action Group ranging from the Rivelin Valley through Crookes, Nether Edge and Dore. It is difficult to escape the conclusion that opposition to the tree felling has as much to do with the protection of house prices in the leafy suburbs as it does with environmental protection.

We also want to contrast this issue with what we would see as some of the more pressing concerns facing the city of Sheffield at this time. The city has been badly hit by economic recession and ongoing government austerity that has seen £350 million slashed from the council’s budget. Many residents have been rendered destitute by a toxic cocktail of the bedroom tax, benefits sanctions and cruel and perverse medical assessments that have seen the terminally ill deemed fit for work. Air pollution deaths are estimated to be stand at around 500 per year, overwhelmingly concentrated in Tinsley and the northeast of the city, and yet this had provoked no outcry from the residents of Dore and Totley.

Emblematic of the astonishing lack of perspective and navel-gazing of those who would seek to make tree felling the defining issue of the moment is a certain Nick Clegg MP, who has recently gone on the record as stating that the Council policy is a ‘national scandal’. This from the man who has the lowest attendance record of any Member of Parliament since the 2015 election, a man who has indebted an entire generation of students and has consistently shown to be no friend of the Sheffield “common people”.

So please, while we are open to sensible debate about whether trees actually need to be removed and replaced, can we ask the people of Sheffield for a little more perspective on the issues facing our city.

Bob Jeffery, President of Sheffield Trades Union Council, (personal capacity)
James Bangert, President of Sheffield College Students Union (personal capacity)
Christy McMorrow, President of University of Sheffield Students Union (personal capacity)
Abdul Galil Shaif Alshaibi, Sheffield Yemeni Community Association (personal capacity)
Muna Abdi, Doctoral Researcher, University of Sheffield (personal capacity)
Martin Mayer, Secretary of Sheffield Trades Council (personal capacity)
Andrew Yeardley, Secretary of UNITE Bus Drivers Branch (personal capacity)
Dave Smith, Chair of UNITE Bus Drivers Branch (personal capacity)
Zahira Naz, Labour Candidate for Darnall Ward (personal capacity)
Sohail Mumtaz, Sheffield Muslim Community Forum (personal capacity)
Jonathan Marsden, Community Organiser and Richmond Resident (personal capacity)
Cheryl Robertson, Community Worker, Drop the Knife (personal capacity)
Simon Murch, Branch Secretary, National Union of Teachers (personal capacity)
Mazher Iqbal, Labour Councillor, Darnall Ward (personal capacity)
Daragh O’Neil, Treasurer of Sheffield People’s Assembly (personal capacity)
Peter Davies, GMB Regional Organiser (personal capacity)
Jonathan Dean, Senior Lecturer, Sheffield Hallam University (personal capacity)

Contact:
Bob Jeffery
Bobjeffery.sheffieldtuc@gmail.com
07714760672

Bob Jeffery
Senior Lecturer in Sociology
Campus Convenor – UCU Sheffield Hallam
http://ucuhallam.wordpress.com/
Chair of Sheffield Trades Union Council
sheffieldtuc.co.uk

Response from Louise Wilcockson

My statement which is my opinion (in my personal capacity of course):

“As a mixed heritage person, originally from Broomhall and from a single parent family, I find the statements in this letter to be wholly misleading and unjust. Over 15,000 people have so far signed the Save Our Rustlings Trees petition showing that this is far more than a neighbourhood situation. STAG (Sheffield Tree Action Groups) had to be formed because this is a CITYWIDE issue and concern. We are thinking of the health and well-being of Sheffielders now and in the future – and not short-term goals of convenience and profit making – only to have a costly health bills and other lasting consequences caused by the loss of our highway trees.

As for the figure of only 5,000 trees, this has been a recent new piece of communication by SCC’s Streets Ahead and we have written and verbal evidence that they have previously indicated it is 18,000 trees. Due to the recent anomaly, we have written to Simon Green (Director of Place) to ask him to explain this sudden change in scheduled felling figure.

We also object to the myth being perpetuated by Labour supporters and some of the Labour Cllrs that there is one choice – safety or the retention of our highway trees. They are not mutually exclusive – both are possible with good management. This is a 2.2 BILLION pound PFI contract into which alternative specifications and other options should already have been factored. No one is suggesting SCC should beg from Peter to pay Paul.

We are also highly disappointed to learn today that despite SCC indicating to the media and the public that there is some sort of ‘Drop In’ to discuss a draft Tree and Woodlands Strategy on Friday, 26 Feb, that this too is misleading. There is no draft strategy and they have indicated today that highway trees will not form any part of that ‘Drop In’ (as they call it).

Nor have we received information on if and why the Highway Tree Advisory Forum is now over 2 months late with no explanation and no apology.

We are also still waiting for SCC to publish a breakdown of the 26 million pound bizarre figure they have given for potentially retaining Sheffield’s roadside trees and for them to explain to the people of Sheffield how it is even possible that 200 trees will each cost up to £100,000. It beggars belief and is arguably bad management on their part or exaggerated figures.”

Louise Wilcockson – SORT campaigner (in a personal capacity)

To balance this silly letter, the media should also contact campaigning citizens (in a personal capacity of course) at Heeley, Meersbrook, Sharrow, Gleadless, Greenhill, Crookes, etc.

Best regards

Louise Wilcockson
Save Our Roadside Trees
Creative Octopus Media Services (COMS)
Media Relations With Reach
07810 172417

“I wish COMS lots of Good Times!” – Justin Lee Collins

“The best PR I’ve ever had” – Sophie Mei – Britain’s Got Talent semi-finalist

“Safety is but one of the many goals to which we aspire; the mistake is often made to focus on safety as if it is the only goal.” – Professor Davis Ball – Centre for Decision Analysis and Risk Management Middlesex University – From NTSG: Common Sense Risk Management of Trees – Guidance on trees and public safety in the UK for owners, managers and advisers (2007)

“So far as non-fatal injuries in the UK are concerned, the number of accident and emergency cases (A&E) attributable to being struck by trees (about 55 a year) is exceedingly small compared with the roughly 2.9 million leisure-related A&E cases per year. Footballs (262,000), children’s swings (10,900) and even wheelie bins (2,200) are involved in many more incidents.” – National Tree Safety Group (NTSG) report.

“What is the risk? 1) Each year between 5 and 6 people in the UK are killed when trees fall on them. Thus the risk of being struck and killed by a tree falling is extremely low. Around 3 people are killed each year by trees in public spaces; but as almost the entire population of the UK is exposed, the risk per person is about one in 20 million. The risk, per tree, of causing fatality is of the order of one in 150 million for all trees in Britain or one in 10 million for those trees in, or adjacent to areas of high public use. However the low level of overall risk *may not be perceived in this way by the public, particularly following an incident.” – from SIM (Health and safety executive [2007]. Management of the risk from falling trees. Hse sector information minute, sim 01/2007/05. [guidance for HSE inspectors and local authority enforcement officers]. *We have a duty of care not to exaggerate, scaremonger or exploit misperceptions.

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9 Responses to Statement on Tree Replacement by Sheffield City Council

  1. Technotronic says:

    27,000 MATURE HIGHWAY TREES FACE THE AXE

    There are 27,000 MATURE HIGHWAY TREES that account for 75% of the population of street trees. Many of those, if not most, are being classed as DAMAGING, DISCRIMINATORY AND DANGEROUS for associated damage to kerbs and footways (pavements).

    The Deputy leader of the Council – Leigh Bramall – has recently mentioned (on 3rd February, 2016, at the meeting of full Council) that only 5,000 trees are being felled. However, when questioned as to why he believed that (on twitter – 4th Feb*) he said:

    “coz only trees that fall under ‘6 ds’ are replaced”.

    Also, Amey have scheduled many of these trees for felling on the basis that their planning machine and digging machinery will cause such severe damage to mature trees that they will decay and structural integrity will be compromised. Compliance with the current good practice guidance and recommendations that they claim to comply with, but don’t (such as National Joint Utilities Group Guidance and British Standard 5837: 2012), would ensure that such damage did not occur and would enable mature highway trees to be safely retained, long term, without unacceptable compromise to structural integrity.

    Recently, Cllr Terry Fox, Streets Ahead, Steve Robinson (SCC HEAD OF HIGHWAY MAINTENANCE) and David Wain (leader of SCC’s Environmental Maintenance Technical Team within the Highways Maintenance Division: also an “expert” on the HTAF panel) have all refused to the request:

    “ please provide full work contact details for the Sheffield City Council Officers/personnel most directly responsible for:

    a) MONITORING highway works in close proximity to trees;

    b) ON SITE SUPERVISION of highway works in close proximity to trees;

    c) AUDITING of highway works in close proximity to trees;

    d) ENFORCEMENT of compliance with current good practice guidance and recommendations for highway works in close proximity to trees.”

    In December, the Streets Ahead team claimed to be: “looking at IMPROVING OUR PROCESSES AND BUILDING ON INDUSTRY GOOD PRACTISE.”

    In the Rustlings Road Response PDF document (July, 2015**), Streets Ahead stated:

    “…all works will be supervised by a qualified arboriculturalist [sic] to ensure no tree root damage occurs as part of our works. The Streets Ahead team work to National Joint Utilities Group (NJUG) regulations and relevant British standards for construction works in the vicinity of trees”.

    Sheffield’s neighbourhoods face serious, irreversible environmental degradation by the loss of so many mature highway trees. Cllr Bramall – Deputy Leader of the Council – has stated at two meetings of full Council that the Amey contract permits the felling of 18,000 mature highway trees – half the population of highway trees. In December 2012, The Chartered Institution of Highways & Transportation interviewed SCCs Head of Highway maintenance – Steve Robinson – and reported that 18,000 highway trees will be felled before 2018.***

    The Streets Ahead project is a 2.2bn, fully funded, city-wide felling programme, with up to £1.2bn of taxpayers money from the Government’s Department for Transport. Highway trees are a significant component of the urban forest and all tree populations within the urban forest must be managed in a sustainable manner, as required by The UK forestry Standard. This requires the stewardship and use of the highway tree population in a way and at a rate that maintains its potential to fulfil, now and in the future, relevant ecological, economic and social functions. These are wholly dependent on the shape, size and distribution of canopy cover, which provides a range of valuable ecosystem service benefits to neighbourhoods and communities. The benefits are not confined to political wards/constituencies, but are afforded to the whole city – the wind does not choose where it blows, nor the rain choose where it falls.

    In a communication dated 7th July, 2015, the Department for Transport stated:

    “Local highway authorities, in your case Sheffield City Council, have a duty under Section 41 of the HIGHWAYS ACT 1980 to maintain the highways network in their area. THE ACT DOES NOT SET OUT SPECIFIC STANDARDS OF MAINTENANCE, as IT IS FOR EACH INDIVIDUAL LOCAL HIGHWAY AUTHORITY TO ASSESS which parts of its network are in need of repair and WHAT STANDARDS SHOULD BE APPLIED, based upon their local knowledge and circumstances. Central Government has no powers to override local decisions in these matters.”

    Steve Robinson (SCC Head of Highway Maintenance) gave a presentation at the second Streets Ahead Highway Tree Advisory Forum meeting, on 2nd September, 2015. He stated:

    “We are replacing about 70% of the City’s footways over the first FIVE YEARS. We have a duty to consider equalities. Now, in the past, existing TRIP HAZARDS have been left, and the Council has a defence under the Highways Act – SECTION 58 DEFENCE UNDER THE HIGHWAYS ACT – OF NOT HAVING SUFFICIENT FUNDING TO DEAL WITH ALL THOSE DEFECTS.”

    On 23rd July, 2015, at the inaugural meeting of the Highway Trees Advisory Forum (HTAF), Steve Robinson (SCC Head of Highway Maintenance) commented:

    “So, just because a tree is diseased doesn’t mean to say that that tree needs to be replaced. It is the type of disease, the effect that disease will have on the tree’s life, err, whether it turns out to be dangerous, so on and so forth, and those judgements are made by tree people. …In terms of damaging, yes, again, there is a degree of judgement and, erm, and, you know, if something can be done, IF AN ENGINEERING SOLUTION CAN BE APPLIED, THEN IT WILL BE APPLIED. Err, there was a lots of comment made earlier on about whether a tree is removed as a last resort; and a tree is removed as a LAST resort.”

    Jeremy Willis (Amey Operations Manager and self-styled “arboricultural specialist”), stated (Ref: 101002253550), on 14/10/2015:

    “At Streets Ahead we are extremely proud of our green city and in order to maintain this it is our policy to retain healthy trees WHEREVER POSSIBLE. We will only remove trees as an ABSOLUTE last resort.”

    For further information, see the SORT letter to Cllr Fox, dated 29th January, in the Resources section of the Save Sheffield Trees.org website.
    http://www.savesheffieldtrees.org.uk/wp-content/uploads/2015/11/SORT-LETTER-TO-THE-CABINET-MEMBER-FOR-ENVIRONMENT-AND-TRANSPORT_29th-January-2016_v1_v51_Corrected_a.pdf
    or:
    https://ianswalkonthewildside.wordpress.com/2016/01/31/street-trees-letter-to-sheffield-city-council-cabinet/comment-page-1/#comment-1107

    * https://twitter.com/SaveSheffTrees/status/695253114400739328

    ** https://www.stocksbridgecommunity.org/news/streets-ahead-stocksbridge-trees

    *** The Chartered Institution of Highways & Transportation, 2012. Transportation Professional. [Online] Available at: http://www.ciht.org.uk/download.cfm/docid/EAFEC96C-F341-455B-B811F1C627AC75AD [Accessed 15 October 2015].

    • Technotronic says:

      CORRECTION:
      “Planning machine” should read planing machine. Some dumb auto correct function keeps changing my words without me noticing. 😦

      • Technotronic says:

        I should point out that the Streets Ahead project is NOT just a city-wide felling programme, but it does include a city-wide felling programme. Sorry for any confusion.

    • Technotronic says:

      CABINET MEMBER FOR ENVIRONMENT & TRANSPORT: Cllr Fox (Labour)

      On 23rd October, 2015, The Star newspaper reported:

      “Cllr Terry Fox, Cabinet Member for Environment and Transport, said: ‘We have always said that WHERE IT IS POSSIBLE TO RETAIN A TREE, THIS IS WHAT WE WILL WORK HARD TO DO, and we have clearly shown that we are serious about that commitment.’ ”

      Source:
      http://www.thestar.co.uk/news/three-trees-at-root-of-city-wide-campaign-spared-the-chop-1-7533375

      • Technotronic says:

        FELLING

        ALL MATURE TREES CAUSING KERB / FOOTWAY DAMAGE WILL BE FELLED: UP TO 18,000 – 27,000 HIGHWAY TREES
        (50% TO 75% OF THE HIGHWAY TREE POPULATION)

        “We are open and transparent with the Sheffield public ensuring all relevant information is available and in the public domain.

        Alternative engineering solutions are not affordable

        Officers have produced some approximate figures looking at the cost of alternative engineering solutions not provided for within the Streets Ahead contract. Implementing these would cost the council thousands, and in some cases tens of thousands of pounds, for each tree.

        We have just had to save another £50m from our budget as a result of Government cuts, on top of a further £300m since 2010. With this scale of cuts such additional costs are not affordable.”

        Source:
        http://www.laboursheffield.org.uk/sheffield_s_tree_replacement_scheme_the_facts?recruiter_id=5

        The public have yet to see any evidence that alternative highway engineering specifications for footway, kerb & drain construction have been commissioned or draughted, despite repeated requests since May, 2015.

        At the Heeley Roadshow, on 17th November 2015, mentioned in the SORT letter, Darren Butt (Amey Operations Director for ALL aspects of highway maintenance) dismissed the Council’s list of 25 “Streets Ahead engineering options”* as “bolo**s”. He claimed Amey don’t use those as they have their own that they use, instead.

        *presented by SCC Head of Highway Maintenance – Steve Robinson – at the second [final] meeting of Cllr Fox’s “bi-monthly” Highway Tree Advisory Forum. See page 265 of the recent SORT letter:

        https://ianswalkonthewildside.wordpress.com/2016/01/31/street-trees-letter-to-sheffield-city-council-cabinet/comment-page-1/#comment-1107

  2. Technotronic says:

    SHU: WOULD YOU GO THERE?

    Bob Jeffery – Professor of Sociology at Sheffield Hallam University – appears to be the man behind the letter (the fall-guy, at least). Seriously, if this letter represents the standard of university level debate on the matters of urban tree population management raised by SORT campaigners*, it gives a very poor impression of the standards of education at Sheffield Hallam University. If you wanted to do a course and faced debt of >£40,000 for tuition fees to pay wages for people like Prof Jeffery, would you go SHU, or would you expect better for your HARD-EARNED money? Remember, you have to pay any debt, to it would be you that forks out for university blunders.

    My initial observation was that Jeffery’s letter is one of jealousy. The signatories apparently resent not having so much media coverage for other topics that affect life in the city. My opinion is that if they feel so much resentment and jealousy, the best thing for them to do would be not to belittle the good that is being done by others but it would be for them to get out there and start making positive steps to address all the other matters they claim to care about. In my opinion, if they really cared about the people of Sheffield, they would get off their arses and put as much effort as SORT and STAG campaigners have in to positively affecting change for the benefit of EVERYONE.

    “You shall not set your heart on… any of your neighbour’s possessions.”
    OT: Exodous: 20:17
    http://www.bibliacatolica.com.br/new-jerusalem-bible/exodus/20/

    Christy McMorrow‏ – President of University of Sheffield Students Union – signed.
    Here is what he has said since, in response to questions asked by Leo Bird:

    Q: “Can you explain why you have an issue with trying to protect Sheffield’s trees?”

    A: “I was also not aware the union would appear next to the signature to clarify”

    Q: “Can you explain why you have an issue with trying to protect Sheffield’s trees?”

    A: “I want to learn more about it but its become a political football, used by a party who have caused Sheffield and students more harm”

    Source: https://twitter.com/lmbird1

    So, in the case of Mr McMorrow, his excuse was that he forgot to engage his brain, prior to agreeing to sign. Mr McMorrow clearly didn’t make any effort to read SORT communications, so as to develop informed opinions, prior to signing. What a NUMPTY! I suspect the other signatories made the same mistake. McMorrow, YOU HAVE CONTRIBUTED TO AN ATTEMPT TO MAKE A POLITICAL FOOTBALL OUT OF THESE ISSUES. Please think hard about the consequences of your acts and omissions in future. If you lack wisdom, knowledge and understanding, gain it first, before making a decision, so as to ensure that your opinions are based on sound evidence and not unduly influenced by transitory or exaggerated opinions.

    What these signatories have done is encourage greater division within and between communities throughout the city, to further their own political aspirations. Shocking! They should get out and do some real graft and make some real effort to positively affect change in their neighbourhoods and the wider city. This is the problem with society – those with the most power are the least informed and, arguably, the most lazy.

    For the record, I am a grafter. In terms of class, I believe I now belong to what is termed the under-class. I am amongst the 30% of Sheffield’s population live in areas that fall within 20% most deprived in the country. If any of the puffed-up, posh, lazy eejits that signed that letter wants a real discussion about responsible, sustainable tree population management, come on here, and let’s have it!

    Just because the poorest in society don’t comment doesn’t mean we don’t care about the prudent, rational management and utilisation of community assets, the quality of our neighbourhood or our health and wellbeing. Many poor citizens of Sheffield lack the time, money or opportunity to launch campaigns to encourage the adoption of sound policies, specifications and practices for the responsible and sustainable management of the urban forest resource. I, for one, am glad that some one can be arsed to fight for justice on my behalf and on behalf of all hard working folks that just can’t afford the time and money to fight for the common good.

    MANY THANKS INDEED TO ALL SORT AND STAG CAMPAIGNERS, HOWEVER RICH OR POOR YOU ARE. TREES IN ALL PARTS OF THE CITY BENEFIT EVERYONE! 🙂

    * http://www.savesheffieldtrees.org.uk/wp-content/uploads/2015/11/SORT-LETTER-TO-THE-CABINET-MEMBER-FOR-ENVIRONMENT-AND-TRANSPORT_29th-January-2016_v1_v51_Corrected_a.pdf

    * https://ianswalkonthewildside.wordpress.com/2016/01/31/street-trees-letter-to-sheffield-city-council-cabinet/comment-page-1/#comment-1107

  3. Technotronic says:

    “AS PART OF GOOD GOVERNANCE, DECISION-MAKING AFFECTING PEOPLE AND USING PUBLIC FUNDS NEEDS TO BE OBJECTIVE, BALANCED AND TRANSPARENT.

    Access to the right information at the right time is fundamental to coherent policy trade-offs.
    Better understanding and quantitative measurement of biodiversity and ecosystem values to support integrated policy assessments are a core part of the long-term solution.”
    (ten-Brink, et al., 2009, p. 4)

    “New approaches to macroeconomic measurement must cover the value of ecosystem services, especially to those who depend on them most –
    ‘the GDP of the Poor’.”
    (ten-Brink, et al., 2009, p. 5)

    Reference:
    ten-Brink, P., Berghöfer, A., Schröter-Schlaack, C., Sukhdev, P., Vakrou, A., White, S., Wittmer, H., 2009. TEEB – The Economics of Ecosystems and Biodiversity for National and International Policy Makers – Summary: Responding to the Value of Nature. [Online] Available at: http://ec.europa.eu/environment/nature/biodiversity/economics/pdf/d1_summary.pdf [Accessed 14 January 2016].

  4. Technotronic says:

    BRITISH STANDARD 5837 (2012):
    “Trees in Relation to Design, Demolition and Construction – Recommendations”

    An extract from the Forward to the standard:

    “INFORMATION ABOUT THIS DOCUMENT

    This is a full revision of the standard, and introduces the following principal
    changes:

    • takes account of current practice regarding planning for the management,
    protection and planting of trees in the vicinity of structures, and for the
    protection of structures near trees;
    • updates the guidance in relation to building regulations;
    • recognizes the contribution that trees make to climate change adaptation.

    This British Standard provide RECOMMENDATIONS AND GUIDANCE FOR
    ARBORICULTURISTS, architects, builders, ENGINEERS, and landscape architects. It is also
    expected to be of interest to land managers, contractors, planners, STATUTORY UNDERTAKERS, surveyors, and all others interested in harmony between trees and
    development in its broadest sense.

    Annex A contains general information which is expected to be of use to
    developers, builders and engineers.

    USE OF THIS DOCUMENT

    This British Standard takes the form of guidance and recommendations.
    IT SHOULD NOT BE QUOTED AS IF IT WERE A SPECIFICATION AND PARTICULAR CARE SHOULD BE TAKEN TO ENSURE THAT CLAIMS OF COMPLIANCE ARE NOT MISLEADING.
    Any user claiming compliance with this British Standard is expected to be able to
    justify any course of action that deviates from its recommendations.

    It has been assumed in the preparation of this British Standard that the
    execution of its provisions is entrusted to appropriately qualified and
    experienced people, for whose use it has been produced.”

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