OPPONENTS of the planned £750m container terminal are scrabbling to negotiate the most favourable fall-back position should their nightmare come true and the plan is approved.

As the year-long public inquiry at Southampton's Eastern Docks reaches its last month, and summing-up speeches are getting their final polish, the pro and con parties to the port plan are jockeying for position on points where they have agreed to agree.

Inspector Michael Hurley had told everyone: "We want a comprehensive list of all the conditions and agreements that have been proposed and we want to see where we stand on all of them.

"By next Thursday's closing submissions I want precise terms of all undertakings, modifications and planning conditions so I can report to the secretary of state."

He said he had received "an avalanche" of paper in the last couple of days from people desperate to meet yesterday's deadline for legal submissions.

Southampton City Council has submitted three conditions to try and alleviate railway noise for residents living near the tracks. New Forest District Council has set out controls to lessen construction and operational noise, and tried to firm up details on the protective Hythe Marina Bund.

For the Royal Society for the Protection of Birds (RSPB), plans to offset the environmental impact of the Dibden Bay proposals are of paramount importance. Its legal spokesman David Elvin was scornful of environmental agreements drawn up by Associated British Ports (ABP) - developers of the Dibden Bay scheme - which include a nature reserve at Church Farm west of Dibden.

"ABP's covenants are disappointing, undefined, vague and misleading," Mr Elvin told the inquiry. "The wording doesn't tie them to supporting the principal aims. One key issue is to provide measures to offset the environmental impact of the development, but that comes only fourth in ABP's list of aims. Number one is to set up an organic farm.

"And why are they only committing themselves to fund the Church Farm project for 30 years? A similar scheme at Cardiff Bay has secured funding from developers in perpetuity."

For ABP, Martin Kingston said: "We have tried to take on board points as and when parties have made them. We are not looking for disagreements just for the sake of them.

"By next Friday all should be able to say ' I know exactly what ABP's case is for Dibden Bay'."

The inquiry resumes tomorrow.