Thanks for the feedback fellas. My reading of the ADR indicates that the 10mm clearance is not absolute, but discressionary. They say "recommended clearance of 10mm". So I figure it is the certifying engineers call. I think he may be prepared to deviate slightly from the 10mm. In any event, my suspension is not fully set up and aligned at the moment, and as I have adjustable strut tops the clearance may change for the better (I hope).
If I need to go back to solid discs, can anyone advise me if the TX3 discs being used by many have the wheel stud drillings to suit the Escort 4 x 108 pcd, or do these need re-drilling?