20982/A3/JR/sw

25 August 2016

CHESHIRE EAST LOCAL PLAN STRATEGY EXAMINATION STATEMENT ON BEHALF OF THE DUCHY OF LANCASTER – ID 489374

MATTER 2: PLANNING FOR GROWTH – OVERALL DEVELOPMENT STRATEGY (Policy PG1)

Key issue: Is the Overall Development Strategy for East, including the revised housing and employment land requirements, soundly based, effective, locally distinctive and justified by robust, proportionate and credible evidence, particularly in terms of delivering the proposed amount of housing and employment development, and is it positively prepared and consistent with national policy?

2.1 The Case for Growth a. Does the revised Plan reflect the Case for Growth and the Strategic Priorities set out in the Plan? b. Should the revised Plan include a specific commitment to early review, and should it cover a longer period than 2010-2030?

1. Section 4 of the Local Plan Strategy (LPS) Proposed Changes (REF 003) sets out the Case for Growth, and why it is necessary and beneficial. The revised Plan reflects the key points set out at paragraph 4.3, following the increase in housing requirement (from 27,000 to 36,000 homes) and employment land, from 300ha to 380ha, both over the period 2010- 2030. Given the period of time it has taken to prepare the Plan and reach this stage in the Examination process, the Plan Period will expire within just 14 years.

2. The Duchy of Lancaster considers that the significant priority is to deliver the spatial strategy, however given the Plan does not aspire to meet the identified OAN, the Duchy of Lancaster Estate would strongly recommend that there is a commitment to the Plan being revised ahead of 2031 to ensure that sight of the true OAN is not lost.

3. Whilst not ideal, the investment of all parties in this Plan to date, and the need to deliver the Strategic Priorities of the Plan, should also be balanced against this period. The Plan sets out Strategic Priorities at Section 6. These are briefly covered below.

• 1. Promoting economic prosperity by creating conditions for business growth. In so far as the Duchy of Lancaster’s land at Radway Green Extension is concerned, the revised Plan has maintained the Submission version allocation of land referred to as Radway Green Extension (CS15) and therefore continues to positively respond to this priority. This strategic site, with excellent access to the M6, will attract new and innovative business, and enable existing businesses in / to grow.

• 2. Creating sustainable communities, where all members are able to contribute and where all the infrastructure required to support the community is provided The revised Plan has also sought to maintain the delivery of this Strategic Priority through the revisions to Policy CS15. The location for development – at Alsager, is in accordance with the Spatial Strategy, given Alsager is a Key Service Centre. The Proposed Changes include reference to the contributions that the allocation will make

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towards junction improvements on the M6 and the railway crossing on Radway Green Road. These are in addition to the infrastructure contributions to be secured that are referenced in the text of the Submitted Plan, i.e. towards improving public transport.

The South Cheshire Growth Village allocation also delivers this Strategic Priority, with clear, robust policy criteria that seek to secure a number of elements of provision alongside new homes, to ensure a truly sustainable community is delivered. Furthemore, because the Duchy of Lancaster will be a Joint Venture partner within the delivery of the site, there remains a vested interest and a level of guarantee that can be drawn from the project in terms of the overall ‘place’ that the Duchy of Lancaster is seeking to create here.

• 3. Protecting and enhancing environmental quality This Strategic Priority requires development to conserve and enhance the natural environment ensuring appropriate protection is afforded to designated and non designated assets. The Radway Green Extension site is approximately 1 km/0.67 miles to the south-east of the Midland Meres and Mosses Phase 2 Ramsar and Oakhanger Moss SSSI, and is separated by extensive road infrastructure i.e. Radway Green Road, and the B5007. The site falls within the SSSI Impact Risk Zone, which is used to determine whether to assess planning applications for likely impacts on SSSIs/SACs/SPAs and Ramsar sites in .

Upon review of the SSSI Impact Risk Zone User Guidance, in particular Appendix 1: Flow Chart, the proposed development at Radway Green Extension is unlikely to pose a risk to SSSIs (given that the allocation is separated from the SSSI by significant road infrastructure that forms a barrier to the ecological relationship between the two).

In terms of the South Cheshire Growth Village, the Duchy of Lancaster has worked proactively with the Council and Heritage England to arrive at a concept masterplan that respects the local heritage assets and enhances their landscape setting, whilst delivering new homes to contribute towards growth at Crewe. Again, this responds positively to this Strategic Priority.

• 4. Reducing the need to travel, managing car use and promoting more sustainable modes of transport and improving the road network Locating strategic employment sites that serve a demand for distribution and logistics, adjacent to the motorway network, reduces for the need for the operators of those business to incur unnecessary lorry miles. Furthemore, the Policy criterion as drafted seek contributions towards the improvement of public transport links, which is consistent with this Strategic Priority.

In respect of South Cheshire Growth Village, there is an opportunity to secure diversion of existing bus/cycle and public footpath routes that run close to the site, and to connect via pedestrian and cycle links to the Basford East area of growth. The provision of a local centre will also reduce the need for residents to make motorised trips for everyday goods. South Cheshire Growth Village represents a location that is a clear direction of growth for Crewe, continuing eastwards from Basford East. This corridor of development benefits from accessibility to a rail station; existing and proposed bus services; and the recent investment in the Link Road, that together, reduce pressure on the Weston Road.

2.2 Employment Strategy: a. The revised Plan proposes to provide a minimum of 380ha of employment land (2010-2030) to support the growth of the local economy. Are there any new issues or new evidence to suggest that the basis and justification for this scale and location of employment land is unsound or inconsistent with the latest national 20982/A3/JR/sw 3 25 August 2016

policy and guidance, including future rates of economic growth, the various economic scenarios and forecasts, and the aim to provide 31,400 new jobs?

4. As set out within our response to the consultation on the Proposed Changes, in April 2016, the Duchy of Lancaster fully support the increased employment land requirement of 380ha, and this goes to further demonstrate that there is a need and demand for employment land that cannot be met on existing sites or without Green Belt release. Those objecting to the Radway Green Extension for example, hold a narrow view that suggest the reuse of existing land at Radway Green and the release of non Green Belt land adjacent to the existing site, is a preferable alternative. We do not share this view and given that the increase in employment land to 380ha was made post the allocation of Radway Green Extension, the decision of the Council to maintain the Radway Green Extension allocation and not substitute it with other sites, carries weight.

5. Given that the Radway Green Extension allocation (dating back to the Pre Submission Plan in January 2013: BE 100) is made to a Key Service Centre, it is therefore consistent with the Spatial Strategy and necessary to ensure the Local Plan achieves this 380ha requirement overall. There are no new issues or evidence to suggest that the location of the allocation is unsound or inconsistent. As noted above, the site has also been identified for employment use since January 2013 and has been the subject of technical reports including the Green Belt Review (ref. PSE034); Site Selection Methodology (REF010), Alsager Final Site Selection Report (PCB008) and scale of this allocation, that meets the requirements of the market in terms of access, cannot be allocated on non Green Belt land to serve the southern half of the Borough.

b. How will the employment strategy be delivered effectively, including the provision of additional employment land, existing commitments and proposed allocations?

6. The Duchy of Lancaster employment allocation at Radway Green Extension can be delivered in part, within the first five years post the adoption of the Plan (in 2017). The Duchy of Lancaster has met with officers regarding a potential occupier identified for the first phase of the site, within the order of 7.5ha/ (circa 325,000 sqft/ 30,000sqm) of floorspace. Phase 1 is critical for opening up the site, with a new roundabout access, and raising the profile. If the Local Plan is adopted in early 2017 we would be looking to deliver Phase 1 before 2020. This is in direct response to the identified need and demand for employment land of this scale, nature and location that is identified by CBRE in their advice to the Duchy of Lancaster. The CBRE Report has been forwarded previously to the Council, and given its site specific discussion, it is appended to our Matter 5 Statement, rather than this one. The Duchy of Lancaster has submitted a Phasing Plan to the Council to assist in their preparation of a trajectory to inform the Local Plan. A copy of the Phasing Plan is attached to this Statement at Appendix 1. Having invested heavily in the site, the Duchy of Lancaster would also be looking to make substantial progress on Phase 2 (10.5ha) for completion in the early part of the period 2020 - 2025. Phase 3 (7.5ha) would then follow subject to market conditions at the time. This fits with a jobs led growth strategy of the Plan and the desire to improve access to and appeal of the adjoining brownfield allocations. c. Has the revised Plan properly addressed the balance between new employment and housing development, has the evidence addressed the quantitative and qualitative aspects of employment land provision, and does it provide sufficient information about the types of business uses to be accommodated at the proposed sites?

7. The relationship and therefore balance between the Housing Strategy and the Economic Strategy has improved from the previous Submission Local Plan, albeit 0.7% Economic Growth is lower than the 0.9% growth that is more probable.

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8. The Ekosgen Report (PSE 032) page 2 states (with our emphasis):

“Three sets of economic projections for over the Local Plan period (2010- 2030) (two from the Cheshire and Econometric Model (CWEM) and one from Oxford Economics) have been compared. The two CWEM projections (one based on national ONS data and one based on local data) produce the same average annual employment growth rate at both the sector and overall economy level for Cheshire East. To ensure that previous local housing proposals are not affecting the projections, analysis is based on the ONS based CWEM.

The projection for Cheshire East in the ONS based CWEM covers 2010-2025 and is in line with the national average resulting in the creation of 22,200 net additional jobs by 2025. When this growth rate is extended, the number of net additional jobs increases to 31,400 by 2030. However, the Oxford Economics model, which covers 2010-2030, suggests that Cheshire East will outperform the national average with an average annual growth rate of 0.9% , resulting in 37,600 net additional jobs by 2025 and 38,600 by 2030.

The growth projected for the next 20 years in Cheshire East in the ONS based CWEM (0.7% including self-employment) falls within the range of employment growth rates recorded between 1998 and 2008 (0.8% including self-employment) and 2009 and 2013 (0.6% including self-employment), while the Oxford Economics projection for Cheshire East (0.9%) exceeds this.”

9. We agree that the increased economic growth rate to 0.7% appropriately then leads to the identification of additional employment land. The Duchy of Lancaster welcome this in principle. We note that the revised Plan now identifies 2050 homes to Alsager, and 40ha of employment land, this being an increase from the previous 1600 homes and 35.12ha of employment land. Radway Green Extension remains as a significant component of the Alsager (and South Cheshire East) requirement. We are aware of the Radway Green Brownfield and Radway Green North sites, that are additional allocations in the Plan, however it is the Radway Green Extension Site that offers the most suitable, flexible and attractive proposition for the market to deliver.

10. Whilst the Plan does not comment on the types of business to be accommodated at the allocated site, given the location on the strategic highway network and the suitability of the junction to provide for access serving B8 uses, it is highly likely that the Radway Green Extension site will fall within this Use Class. The Plan however need not be amended to be specific on this.

d. Has the revised Plan considered the cross-boundary implications of the economic strategy on the economic strategies of adjoining local authorities, including Greater Manchester, The Potteries/North , Cheshire West & and Derbyshire, including the amount, type and location of additional employment development proposed?

11. The supporting text to Policy CS15 notes that Radway Green Extension has strategic importance in terms of its location within the M6 Growth Corridor from Birmingham to Manchester, and this too is noted within the CBRE Report appended to our Matter 5 Statement and previously supplied to the Council.

12. We note that the Council has prepared an updated Duty to Co-operate Statement (PCB 036) and that within this it is reported that Stoke on Trent City Council/Newcastle under Lyme Borough Council have made no further comments to the revised Plan. Equally, Staffordshire County Council have no unresolved planning issues with Cheshire East. e. Has the revised Plan properly assessed the need for, and demand and supply of, sites for logistics uses and made sufficient provision for this form of economic development? 20982/A3/JR/sw 5 25 August 2016

13. We attach a copy of a letter (Appendix 2) that we prepared on behalf of the Duchy of Lancaster that responded to objections made by Barthomley Action Group and the Parish Council that they made in respect of the continued allocation of Radway Green Extension. Within that letter we reference the Council’s document REF020 – Review of Supply and Demand for Logistics Sites. Appended to our letter is a short report by CBRE that confirms the absence of a supply in logistics sites that can be met if allocated sites like Radway Green Extension, come forward. The Plan therefore caters for the needs of logistics use with allocated site that that at Radway Green Extension.

2.3 Housing Strategy: a. The revised Plan proposes to provide at least 36,000 homes at an average of 1,800/year (2010-2030). Are there any new issues or new evidence to suggest that the basis and justification for this increased level of housing requirement is unsound or inconsistent with the latest national guidance in the NPPF (¶ 14, 17, 47-55; 159) and PPG (ID: 2a/3), including the demographic assessment of housing need (including migration), housing factors (including market signals, housing market areas and the need for affordable housing and other specialist accommodation), economic factors (including economic growth rate, commuting assumptions and alignment with the economic strategy), the effect of restrictive policies and other relevant factors?

14. We welcome the increase in housing requirement from the 27,000 dwellings within the Submission Plan however it might have been more appropriate for the Council to identify a higher figure than 36,000 dwellings particularly in light of the ORS Housing Development Study 2015 which finds a need for 37,871 dwellings over the period 2010 to 2030 to support a job growth rate of 0.7% (ORS May 2015, figure 57, page 84). A higher figure would also enable the delivery of more affordable homes and respond positively to adverse market signals. These are notable in Cheshire East, where the Duchy of Lancaster has interests at South Cheshire Growth Village and Crewe Green, both of which are allocated sites.

15. Therefore whilst 36,000 is a significant boost to the Plan, and may provide the Inspector with confidence that the Plan can progress through an Examination towards adoption, it may be prudent to acknowledge that OAN is higher than 36,000. If the Inspector has this confidence, and prioritises the need to get a Plan in place and guide development, then he may decide to accept this figure also.

16. The Duchy of Lancaster considers that the significant priority is to deliver the spatial strategy, however given the Plan does not aspire to meet the identified OAN, the Duchy of Lancaster would strongly recommend that there is a commitment to the Plan being revised ahead of 2031 to ensure that sight of the true OAN is not lost. b. Do the latest DCLG 2014-based Household Projections have any significant implications for the current objectively assessed housing need in the revised Plan?

17. We note that the Council has prepared PCB 032 in response to the Inspector’s question regarding the implications of the 2014 based Household Projections. We agree with the Council, and their comments at paragraph 6 of that document, that states that the significance of the change in household projections (a change that results in the OAN reducing by around 4%) is not to such a degree that it would warrant changing policy PG1. Indeed, the flexibility implied by having a Plan that can withstand changes in Household Projections is to be welcomed. c. Has the latest assessment of housing need considered the relationship with neighbouring housing market areas and the cross-boundary implications of the increased amount and location of new housing proposed, including Greater Manchester, Cheshire West & Chester and The Potteries/North Staffordshire?

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18. The Duchy of Lancaster have no further comments to make on this. d. How does the revised Plan ensure a current and continuing 5-year supply of housing land over the period of the Plan, in order to fully and effectively deliver the proposed amount of housing within the Plan period, with sufficient flexibility, including existing commitments, future provision proposed in the Local Plan Strategy and other subsequent plans, allowance for windfalls, balance between brownfield and greenfield sites, provision identified in the latest SHLAA and Housing Topic Paper, and the revised housing trajectory? e. Is the approach to addressing the need for a 5/20% buffer to 5-year housing land supply, as required by the NPPF (¶ 47) to significantly boost housing supply, and addressing the previous under-supply of housing appropriate, fully justified, effective, soundly based and consistent with the latest national policy guidance?

19. The Council have published a Housing Topic Paper (February 2016) that identified the Council’s five year housing land supply and it is noted at paragraph E.13 of the Revised Plan that this will be updated. The Council has now published PCB 037. ‘Housing Supply and Delivery Topic Paper’ (August 2016). The Duchy of Lancaster liaised with the Council regarding the assumed delivery rates for their sites that were subsequently used to inform this Paper.

20. We note that 64% of the overall plan requirement is referenced as being committed (with planning permission or a resolution to grant) (page 10, PCB 037).

21. The ‘Housing Supply and Delivery Topic Paper’ (August 2016) concludes at paragraph 8.2 that the Council has a 5.3 year supply of housing land for the purpose of the Local Plan Strategy.

22. The Duchy of Lancaster land is the subject of two draft site allocations for housing – CS37 and CS4, totalling 800 dwellings.

23. In respect of Crewe Green (CS4) the Duchy of Lancaster are keen to progress this site and are already in an advanced position with a housebuilder as a joint venture. We therefore anticipate that a full or at least hybrid application would be submitted and determined during 2017 and with conditions discharged in early 2018. This programme anticipates completion of the Crewe Green Road Scheme later in 2018. We are assuming that site preparation works would commence in the first half of 2018 but that residential completions/sales are likely to await completion of the road works towards the end of 2018. Delivery is therefore anticipated as being 40 dwellings per annum from October 2018 and at the same rate per annum for subsequent years, completing in 2022. An earlier start is possible albeit this would require more detail on the exact timing and extent of the road improvements that are planned by the Council for the Crewe Green roundabout. We note from the Council’s website that the Crewe Green roundabout scheme is currently the subject of an options consultation. We do not consider the highways works (from a timing perspective) to be a particular concern given that access could be taken off Sydney Road and by then commencing development from the north working south. In addition, all of the land required to deliver this allocation is within our Client’s single ownership.

24. The South Cheshire Growth Village (CS37) site is a larger project and is also identified in our Client’s programme as being a combined Joint Venture. Our delivery trajectory anticipates commencement in 2019/20 following detailed masterplanning and heritage assessment work. This ensures that the Duchy of Lancaster maintains control of the delivery of a high quality, design sensitive scheme and that this respects the working relationship that has been developed to date with statutory consultees including Heritage England. We would anticipate approximately 80 dwellings per annum on average based on two outlets, 20982/A3/JR/sw 7 25 August 2016

potentially peaking slightly higher, later in the project. This gives a delivery programme of 7-8 years from commencement.

25. All the land required is again in our Client’s single ownership aiding delivery and comprehensive masterplanning.

26. The Duchy of Lancaster together with their preferred Joint Venture partner has indicated (based on their knowledge and experience), the anticipated rates of delivery and this has informed the housing trajectory within PCB037. Given the Duchy of Lancaster sites will be delivering new homes within the five year period against which housing land supply would be calculated, the Duchy of Lancaster have no further comments to make on the Inspector’s questions.

APPENDIX 1

RADWAY GREEN EXTENSION PHASING PLAN

Key

Phase #1

Phase #3

Phase #2

Revisions - -- --.--.------

0 m 50 m

Scale 1:1,250@A1 / 1:2,500@A3

Client

Duchy of Lancaster Planning Support

35477-LEA-PDD-A002 Radway Green Master Plan Phasing

Based upon the Ordnance Survey Map with the permission of the Controller of Her Majesty’s Stationery Office. © Crown Copyright. 100001776. November 2015 35477-LEA-PDD-A002 Radway Green Phasing.dwg SoutP

APPENDIX 2

LETTER RESPONDING TO BAG AND PC OBJECTIONS TO RADWAY GREEN EXTENSION DATED 19th AUGUST 2016

Spatial Planning Team Cheshire East Council Westfields Road Cheshire CW11 1HZ

BY EMAIL: [email protected]

20982/A3/JR/sw

19th August 2016

Dear Adrian

RESPONSE ON BEHALF OF THE DUCHY OF LANCASTER TO BARTHOMLEY ACTION GROUP (BAG) AND BARTHOMLEY PARISH COUNCIL’S REPRESENTATIONS TO THE CHESHIRE EAST LOCAL PLAN PROPOSED CHANGES

We write on behalf of our Client’s, the Duchy of Lancaster (‘the Duchy’) in respect of their interests at Radway Green, Alsager. The Duchy owns land that has been identified as a draft employment allocation within policy CS15 of the emerging Local Plan. We note that BAG and the Parish Council have objected to this draft allocation (letter from WW Planning dated 19th April 2016). We consider that it would be helpful to the Council and the Inspector, prior to the resumed Examination, to set out our response to their points raised specifically in respect of the Radway Green Extension. We note that the Council has also now uploaded to the Examination website, a series of documents that set out the justification for sites being selected, and we will draw upon that and other evidence as is necessary in this letter.

1. Is there land and buildings that are underused at the existing Radway Green Site?

1.1 BAG and the Parish Council claim that there is underused land and buildings at Radway Green site. They consider that rather than extending the current site to include the Duchy’s land, that a more appropriate allocation would be to redevelop the current employment site and then to extend it to the south, into open countryside. This approach would avoid the need for Green Belt release and therefore the allocation of the Duchy land.

1.2 Firstly, PSE 032 (The Alignment of Economic, Employment and Housing Strategies, para 3.53) is clear that vacant land and buildings have been factored in as part of the calculation of employment land requirements, and therefore to count them again, (and discount the additional Duchy land in exchange) would be an incorrect approach and would in effect be ‘double counting.’ Furthermore, the Plan is based on evidence (PSE 032) that explores the

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rate of future economic growth from a baseline, where existing employment land forms part of that baseline. The calculation establishes the number of jobs for the Plan Period, then converts this to additional future land requirements. Given that the existing Radway Green site is a committed site, seeking to allocate the non surplus land and count any redevelopment of that, towards the new employment land requirement for the Plan Period would be inconsistent with the approach taken to the Local Plan as a whole.

1.3 The Employment Land Review (BE 009) assessed surplus land at Radway Green (sites SU- AS02 and AS03). The site assessments within that document clearly state that the sites (that went on to be allocated) were surplus, and hence it was appropriate to count and then allocate them. The Review did not consider the remainder of the existing Radway Green employment area, which was not/is not surplus.

1.4 It is important to note that the Council also revisited their Assessment of Sites as part of a number of Reports including:

• PSE039 ‘Assessment of the Urban Potential of Principal Towns, Key Service Centres and Local Service Centres and Possible Development Sites adjacent to those Settlements’ • REF010 ‘Site Selection Methodology’ • REF010a Alsager Town Report • PCB008 Alsager Final Site Selection Report

It concludes in PCB008 that the opportunity to extend Radway Green as part of a Brownfield Extension (Site PSS311) is not on planning balance, an available or achievable site (paragraph 7.39) and that given the majority of the site is in operational development, this omission site is not included as an allocation. The Report does explore other potential sites at Alsager, including recommending the allocation of PS308a at Radway Green North for employment use (12ha), and of course, site PSS303 Radway Green Extension (Policy CS15). The objection from BAG and the Parish Council appears to focus on a strategy whereby only one site at Radway Green is necessary, when in reality, the allocation of the greenfield site (Radway Green Extension) is a site that is attractive to the market and has the potential to be a catalyst for development at Radway Green as a location, including the brownfield site by virtue of improving the access to it. The ease of direct motorway access, and a location that is market facing to both the North West and the Midlands is enviable, and benefits the Radway Green Extension site. The attached Report prepared by CBRE, (previously submitted to the Council in earlier representations), highlights that there is an absence in land supply for sites of this nature. The report refers to the fact that if current (2015) take up rates are maintained, then there are just 18 quarters of land supply left.

1.5 It is also notable that the surplus land at Radway Green (sites SU-AS02 and AS03) is being marketed at present. This highlights the difficulty from a major occupier point of view, due to the relatively poor access and legacy issues stemming from previous land uses, making it far less attractive to the market than the Radway extension for the specific occupier requirement identified by Gazeley.

2. Should the extension to Radway Green be on non Green Belt land to the south – estimated as being 15ha in area?

2.1 The Duchy do not consider that the extension to the Radway Green site should be via the allocation of 15ha of non Green Belt land to the south of the existing site. The Council identifies this site as PSS311 within PCB 008 – Alsager Final Site Selection Report. 20982/A3/JR/sw 3 19th August 2016

2.2 The Framework and PPG is clear that in considering the allocation of strategic sites, the LPA must be certain that a site is developable. The site should be suitable, available and deliverable. The land south of the existing Radway Green employment area that is being suggested by BAG and the Parish Council as an alternative site (that is not Green Belt) is not suitable for an extension because:

• it is not of the sufficient scale to meet the employment needs identified by the Council’s evidence base. • it is not accessible via the existing employment site and is effectively land locked or dependent on an access being negotiated through the existing site. • It is not attractive to the market – being located within a blast zone and offering future developers with poor configuration. • It has not been confirmed that the additional 15ha of land is available (page 77 of PCB 008), with the site having not been promoted to date, or assessed in the SHLAA/SSM process until post the April 2016 consultation on the Proposed Modifications. To introduce additional sites into the Plan making stage at this late stage is unacceptable and is not a fair and robust approach when balanced against other sites that have been promoted in accordance with the Regulations. • It is ecologically constrained (page 78 -80 PCB 008) with likely significant effects on the Midland Meres and Mosses Ramsar (Oakhanger SSSI) and the potential for adverse impacts on protected species (Great Crested Newts recorded on part of this site). • It would extend further into the existing countryside than the Radway Green Extension Site (CS15), which instead, infills the land between the existing site and the M6.

2.3 Given the unsuitability of the PSS311 within PCB 008 – Alsager Final Site Selection Report for employment use (based on the list above), it may be a more suitable site to be replacement Green Belt to in part compensate for the 25ha Green Belt removal as a result of the Radway Green Extension site. This may be on balance, the preferred approach, resulting in Radway Green Extension offering a suitable employment opportunity, and the PSS311 site compensating (in the region of 15ha) new land for inclusion in the Green Belt?

3. Can land within the existing Radway Green site be assembled for redevelopment?

3.1 Land assembly is one of the critical factors in terms of delivery. Ensuring that there are willing land owners, with agreeable terms, phasing and apportionment of development are all necessary matters to have been addressed and a site cannot be included in the emerging Plan where there is no certainty that the assembly of land has not taken place. Furthermore, the existing site may have tenants on longer leases operating within it that may not sign up to an assembly agreement.

3.2 Suggestions by BAG and the Parish Council that land owners could come to an agreement for the release of their land for redevelopment simply highlights the problems and complexity of the option. The current marketing of parcels of surplus land at the existing Radway Green site suggests there is little appetite at present for a more complex land assembly solution to be pursued. It is clear within the Planning Practice Guidance that when assessing the availability of land for housing and economic uses that a site is only considered available for development where there is confidence that based on the best information available, that there are no legal or ownership problems and that the land is 20982/A3/JR/sw 4 19th August 2016

controlled by a developer or landowner who has expressed an intention to develop/sell. (Paragraph 20, PPG Ref ID 3-020-20140306).

3.3 The alternative policy wording suggested by BAG / the Parish Council is also objected to. We comment on this, notwithstanding the principle point that the allocation of Radway Green Extension is sound and the wording of the policy should reflect the current text, but with amendments outlined in Barton Willmore’s representations to the Proposed Changes dated 19 April 2016.

3.4 The Duchy does not consider that the Policy wording suggested by BAG/ the Parish Council is effective. The wording attempts to phase the release of the extension site that they suggest, in order that the existing employment site is redeveloped and substantially completed by the time the extension site is brought forward. The development of these employment sites must be responsive to the market and cannot be hindered by one phase only being implemented when another phase is substantially completed – this is not a commercial outlook for the Local Plan to adopt.

3.5 It fails to acknowledge that operators looking to locate to the extension site, that may have particular requirements in terms of scale, timing, etc., would be prevented from doing so by a policy that sought the substantial completion of development on the adjacent brownfield site. The rate of delivery on the brownfield site will be a matter for the developers seeking to deliver that site and the potential future operators. It should not be tied to the operational needs of other companies or developers. The brownfield site is also more fraught with constraints, including poor access, land contamination resulting from a legacy of previous uses etc., and if tied to the delivery of the greenfield land, will ultimately slow the overall supply of employment land, and have detrimental knock on effects for the District economy.

3.6 Furthermore, the suggestions by BAG and the Parish Council are based on the PSS311 site (within PCB 008 – Alsager Final Site Selection Report) being an alternative to the Radway Green Extension site, rather than the Radway Green Extension Site complementing the PSS311 site and the brownfield allocation already being proposed at Radway Green. The Radway Green site ‘ticks all boxes’ when considered for market attractiveness and delivery – as is supported within the attached CBRE Report, however offers more potential than that. It offers a real opportunity to unlock the brownfield site allocation and to offer potential access that will benefit the PSS311 site being suggested by BAG/Parish Council.

3.7 BAG claim that there is no need for this amount of employment land within Alsager. However this is a narrow point, and overlooks the role of Alsager as a Key Service Centre within Cheshire East. Document PC B008 (Alsager Final Site Selection Report) states at paragraph 3.1 that

‘the focus for Alsager over the Local Plan Strategy period is to boost economic growth in the town, increase job density and reduce overall out commuting. The position of Alsager, adjacent to the M6, makes it an attractive location for future investment, with the future regeneration of Radway Green employment area expected to enhance the town’s employment role in line with the conclusion of the Settlement Hierarchy (BE046)’.

3.8 The role attributed to Alsager and the amount of employment land allocated to it, is therefore supported by evidence. 20982/A3/JR/sw 5 19th August 2016

3.9 BAG suggest that the growth projections within the Plan are not justified. However The Inspector, in his Further Interim Views [RE A021] of December 2015, indicated that CEC seems to have undertaken a comprehensive and objective assessment of housing need for Cheshire East (40, [RE A021]). In relation to employment needs, the Inspector comments at paragraph 19 of his Further Interim Views (RE A021):

‘Having considered all the evidence, discussions and statements at the hearing sessions, CEC seems to have adopted a balanced and rational approach to economic and jobs growth, which is both ambitious and aspirational, yet realistic and with a reasonable prospect of success; it balances migration and commuting to ensure sustainable movements and patterns of development, and is based on up-to-date, proportionate and robust evidence. CEC also seems to have considered all the relevant economic factors, including the likely future economic performance of Cheshire East and future employment land requirements. The amended economic growth strategy not only aligns with the LEP’s economic plans and strategies and considers cross- boundary implications, but also takes account of recent employment projections and likely trends. There also seems to be a more direct relationship and closer alignment between the economic and housing strategy than in the previous submitted Plan, and it seems to be justified, positively prepared and soundly based.’

3.10 Given the wealth of further evidence prepared and examined in the Autumn of 2015, and with no comparable, alternative evidence from BAG, it is our view that the projections within the Plan are justified.

3.11 BAG claim within their response to the Proposed Changes that there are no exceptional circumstances demonstrated within the Plan, to justify the release of the Green Belt for Radway Green Extension.

3.12 The Duchy of Lancaster agrees with the Council that there are exceptional circumstances in place to justify the alteration of the Green Belt Boundaries in Cheshire East, and specifically in the case of the Radway Green Extension.

3.13 Arup prepared a Green Belt Update report, PSE 034 in 2015 to inform the resumed Examination. Appendix 4 of that report includes a plan illustrating the result of the Assessment, and confirm (as did the previous Green Belt Assessment) that the parcel of land known as AS12 (within which Radway Green Extension is located) performs a significant contribution to the Green Belt. However what the plan also clearly shows is that the area between Crewe and the motorway – which offers strategic transport links, is surrounded by Green Belt. If Crewe, as a principal town, and Alsager, as a Key Service Centre are to capitalise on employment land opportunities offered by the transport network, then Green Belt land must be released. The Report also notes that Alsager (and ) are settlement located adjacent to Green Belt, as opposed to being inset or washed over settlements.

3.14 The Council’s Assessment (PSE 034) states that land south of Alsager does make a significant contribution to the Green Belt function, however this is based on an assessment that looks 20982/A3/JR/sw 6 19th August 2016

at a wider parcel of land (i.e. AS12) and not just the Radway Green Extension Site which is part of AS12. A finer grained assessment of the Radway Green Extension site could produce conclusions more in line with the Barton Willmore Assessment – i.e. a limited contribution. It should also be balanced against the need for employment land to be adjacent to strategic highway links. Furthermore, the selected parcel of land (draft allocation) is a direct extension of this urban area and the existing employment land at Radway Green.

3.15 Page 83 of the Arup Green Belt Update (PSE 034) summarises the exceptional circumstances that justify the release of Green Belt land. Within the South Cheshire Green Belt, the report states that exceptional circumstances will be ‘site based’ and in these cases it will be for individual proposals to set out the exceptional circumstances that justify the alteration of Green Belt boundaries.

3.16 It is not possible to extend Radway Green southwards in the order of land that is required and capitalise on this location that is adjacent to the M6, without releasing Green Belt. There is potential to expand Radway Green to the north, on non Green Belt land, but given the commentary at paragraph 10.16 of PSB 006b, this isn’t a suitable alternative. This is because the site is essentially going to attract logistics type operations, given the proximity of the M6 junction, and these vehicle movements would struggle to manage the level crossing that is located to the north of the site, in non Green Belt land. Locating the site in other locations around Alsager would add further distance from the M6 and not offer potential companies the visibility and direct access they would seek for a logistics operation, for example.

3.17 Barton Willmore also undertook a Green Belt and Landscape Visual Appraisal Study and submitted this in response to the Development Strategy in February 2013, and a copy is appended to our Submission Representations. Within the Barton Willmore Assessment it is referenced as Employment Area B - east of the M6. Paragraph 5.6 of the Barton Willmore Green Belt Study assesses the contribution the Radway Green extension area (including a wider area) makes to the purpose of Green Belt and concludes these are limited contributions. Notably;

• The area is a considerable distance from the Potteries and has been shown to be physically and visually separated by the intervening rise in the landform. Therefore this land cannot contribute to restricting the sprawl of the Potteries. This area does relate to the works and ammunitions factory south of Alsager.

• These works and the settlement of Alsager are separated by a strip of land located between the Crewe to Stoke-on- Trent railway line and the B5077 which runs from Alsager to Crewe. Therefore it is these transport routes which form the barrier to sprawl. Removing the site from the Green Belt would not allow sprawl to increase or reduce the ability of nearby Green Belt sites to reduce sprawl.

3.18 This area of Green Belt does not prevent any nearby towns from merging and removing it from the Green Belt will not allow any towns to merge. Removing these areas from the Green Belt will not cause encroachment from the existing settlements into the countryside. However, the addition of new development will have an impact upon the countryside.

3.19 This part of the Green Belt does not relate to any historic centres or settlements. The Arup Update report (PSE 034 page C11) states that the AS12 parcel of land within which Radway Green Extension is located, makes ‘No Significant Contribution’ to preserving the setting and special character of historic towns. 20982/A3/JR/sw 7 19th August 2016

3.20 Therefore the balance of locational need of employment versus Green Belt has been a necessary judgement for the Council, and one that they have been able to take to deliver the Strategy. The opportunity of reviewing Green Belt is afforded by the Framework through a Local Plan Review, and it is precisely this opportunity that the Council has seized.

3.21 We note that on page C11 of the PSE 034 Update that the following comments are made in relation to Radway Green Expansion. We comment on each below:

“Check the unrestricted sprawl of urban areas: Significant Contribution: the parcel is adjacent to the Radway Green industrial area but divorced from Alsager. Boundaries are only moderate to the south and east, formed by tree and hedge rows but stronger to the north and west formed by the M6 and Radway Green. Future development would be isolated from existing services in Alsager.”

3.22 Given the proposed function of this site for employment use, and given the location, it is likely to be of a logistical type of operation, and we consider that there would be benefits in the site being divorced from the village of Alsager. Indeed, given the likely 24/7 operations and lorry movements, the benefits of the site are that it is divorced from the residential areas and services. Development of the Radway Green Extension site would simply infill the area of land between the existing employment area and the M6, to the east, whilst boundaries on the southern side of the CS15 allocation could be strengthened. As a result, the development of the site would not represent unrestricted sprawl.

“Prevent nearby towns from merging into one another: No Contribution: Does not have a significant role in the separation of settlements, although it does form part of the wider Green Belt.”

3.23 We agree with this conclusion in respect of not merging towns together by virtue of its release and as it is infilling land towards the M6, and not towards another town.

“Assist in safeguarding the countryside from encroachment: Major Contribution: moderate boundaries to the east and south suggest the parcel may be vulnerable to encroachment in the long term. The land is largely in agricultural use with a strong relationship to the wider countryside. There are few urbanising influences and the parcel retains a rural and open character.”

3.24 We disagree given the considerable urbanising influences of the existing Radway Green Business Park and M6, is what lends this site at Alsager as opposed to others, from being a development opportunity. The southern boundaries are clearly defined and can be strengthened.

3.25 We disagree with the view of BAG that there are ‘plenty of non Green Belt sites that could be developed as an alternative to the Radway Green Extension’. The Green Belt Update (PSE 034) refers to there being just 0.2% brownfield urban capacity within Alsager (page C11).

3.26 The Council’s evidence base has been bolstered by REF 020 ‘The Supply and Demand for Logistics Sites’ that was undertaken in March 2016. This responds to the Inspector’s Further Interim Views (paragraph 17) where further work was requested. 20982/A3/JR/sw 8 19th August 2016

3.27 Paragraph 2.2 of REF 020 notes that the logistics sector is projected to experience significant growth over the Plan Period, a total uplift of 26% in the sector. When applying this to land requirements, the Report states at paragraph 2.5:

‘Factoring in a 20% allowance for flexibility (as per the AEEHS), and applying a land loss assumption that is consistent with both the AEEHS report and the Cheshire East Employment Land Review (ELR) report takes the total B8 land requirement to 147.16 hectares. The logistics share of this is anticipated to be a requirement of 72.55 hectares over the 20 year plan period.’

3.28 Section 2.5 of the Report clearly outlines the requirements that drive the suitability of logistics sites. These include access to major population centres and markets; good strategic road network access, large unconstrained sites enabling units of up to 500,000 sqft of floorspace, potential for multi modal transport options, and the ability to deliver scale and quality.

3.29 In response to these factors the Local Plan identifies potential sites, within section 4 of the REF 020 Report. At Section 4.8, Radway Green Extension is listed, noting that it is in the order of 25ha, of which 12.5ha could be logistics space and the site benefits from very close proximity to the M6 junction 16. Junction 16 has also been subject to a recent programme of improvements, which has enabled more consistent traffic flows than are experienced further north, and the junctions thereafter, upon which other sites listed within Table 4.2 rely upon for motorway access. The A500 dualling is also progressing as a local scheme.

3.30 The ‘The Supply and Demand for Logistics Sites’ Report is clearly supportive of the allocation of Radway Green Extension in principle, and along with other sites identified, enables there to be considerable flexibility in the offer to potential developers and occupiers, which is essential for this industry sector. We do not agree with the emphasis placed at paragraph 4.15 of the Report however, which suggests that Radway Green (brownfield), Middlewich and land adjacent to Junction 17 are able to provide for some 50 ha of land and that this is ‘sufficient to meet demand and offer a market choice,’ excluding Radway Green Extension. We disagree with the preference expressed in this section of the report, given that Basford East as a B8 site is some distance from the M6 Junction 16 and will not be as attractive to future occupiers as land at Radway Green Extension. Similarly, the Middlewich site is some 2 miles from junction 18, and again, does not offer B8 companies with the direct motorway access and visual presence that are key drivers in terms of their location.

3.31 We enclose a Report from CBRE that has previously been submitted to the Council in support of the Radway Green Extension site. The market commentary within that is informed by Gazeley – Brookfield Logistics Properties – a market leader in developments of this nature. The CBRE Report supports the findings of REF 020 ‘The Supply and Demand for Logistics Sites.’ It concludes in section 3 and 4 that there is a shortfall in available employment land that is attractive and developable for the market, and as a result, deliverable. It concludes by stating that from a commercial perspective, based on supply and demand, there is a compelling case for development at the Radway Green Extension site. The Policy constraint that is the ‘Green Belt’ must be weighed in the planning balance against the suitability and deliverability of the site, and how likely it is that development can be achieved here. The Green Belt Review has been undertaken in respect of the Radway Green Extension; and the Site Selection Methodology has considered the site and recommended its allocation. From 20982/A3/JR/sw 9 19th August 2016

our perspective the Council has followed a due process, in support of the draft allocation and has explained the justification for Green Belt release.

3.32 Having addressed the key points within the BAG and Parish Council’s letter in respect of their objection to Radway Green Extension, we consider that their points are unfounded, not based on robust evidence and do not take account of the planning balance that officers have considered to be necessary in determining the quantum of growth at Alsager in order that it performs as expected within the settlement hierarchy, and the spatial implications of achieving that growth. The Duchy of Lancaster remains committed to delivering the Radway Green Employment Site and has fully engaged with the Local Plan process throughout to ensure this.

Please do not hesitate to contact me to discuss any aspect of this letter, or speak directly with Neil Hall (for the Duchy of Lancaster - [email protected])

Yours sincerely

JOANNE RUSSELL Director

CC Neil Hall, Duchy of Lancaster

Enclosure: CBRE Market Report: Land at Radway Green, Crewe, J16 of the M6

Market Report: Land at Radway Green, Crewe, J16 of the M6

1 INTRODUCTION

This report looks into the supply, demand and competition relating to the development potential of the 63 acre plot of land (outlined in red on Figure 1) at Radway Green, in Cheshire, which we believe could accommodate over 1,000,000 sq ft of industrial space.

As a wider sub-market, Crewe and Stoke is considered a discount location, well-placed to cater to both Birmingham/Midlands and Manchester/North-West requirements and, crucially, offering lower rents and land prices than either. For this reason, this report will take both Midlands and North West Market dynamics into account and, take as its focus those buildings and sites able to cater to requirements in both of these markets and capable of accomodating, like Radway, single buildings of over 200,000 sq ft.

Figure 1 Radway Green Red Line Plan

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2 CBRE MARKET OVERVIEW

2.1 UK LOGISTICS SECTOR OVERVIEW Leasing activity in the UK Logistics sector for the Q1-3 2015 has been buoyant with logistics take-up totaling 14.7 million sq ft, an increase of 0.5 million sq ft compared to the same period in 2014. Occupier demand continues to be strong and supply levels have fallen to their all-time low of circa 11 million sq ft, of which over 75% is made up speculative new build.

The overall take-up statistics at the end of Q3 2015 point to an active occupier market, albeit one that is now almost exclusively focused and reliant upon the delivery of new space via either Design & Build (D&B) agreements or speculative development. Indeed, this is acutely apparent from the take-up for the year to date, where 55% of total take-up and 65% of new build take-up is accounted for in D&B deals. The percentage is 16% down on 2014 figures, primarily due to the recent surge of investors funding speculative development across the UK.

Ongoing requirements throughout 2015 have once again been dominated by online and traditional “bricks-and-mortar” retailers, accounting for 44% of total take-up. The largest retail deal was TK Maxx’s commitment to take a 638,000 sq ft D&B at Cross Point, Knottingley. We understand the occupier who has committed to the greatest amount of space is Amazon who will take over 2m sq ft across the UK this year.

Interestingly, the budget retailers have also been active throughout 2015, with a number of notable deals secured in the North. B&M Bargains leased 460,000 sq ft in Cheshire and 343,000 sq ft in . Poundland has acquired 20 acres to develop 335,000 sq ft in Wigan and Poundworld has committed to a D&B in Wakefield comprising 524,000 sq ft.

With renewed occupier confidence and diminishing supply, we have seen even stronger investor and developer confidence and the widespread resumption of speculative development across the UK. The North West in particular has seen the greatest level of speculative development with 2.37 million sq. ft currently committed across 14 units. Of these, two buildings are already under offer. The majority of developments are concentrated along the M6/M56/M62 corridors, however, due to diminishing land supply, occupiers have become more flexible, considering sites further afield in order to secure the right building.

3 CURRENT SUPPLY

3.1 EXISTING STOCK With B&M Home Retail having completed their sublease of Midpoint 460 from Tesco in Mid-2015 and Wincanton and Expert Logistics each taking half of the former Tesco RDC at Weston Road, Crewe, there remains just one Grade A standing building within 25 miles of the subject site; ‘Big Stan’ on the Trentham Lakes Industrial estate.

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Building Map Size PC Date Comments Former Plastics Factory. Recently Big Stan 1 220,067 sq ft Early 2000s refurbished by Sladen Estates.

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3.2 COMPETING LAND There are currently only seven sites in the immediate vicinity of Radway Green that offer the same potential for satisfying both a midlands and a North-West requirement in excess of 200,000 sq ft, at a similar discount to either the Birmingham or Manchester prevailing rents or land costs. They are scheduled and mapped below:

Site Map Size Total Capacity Biggest Single Unit Developer Notes Crewe Site access roads were completed in late 2015 and delivery is now Commercial 1 70 Acres 1,042,500 sq ft 750,000 sq ft Goodman only contingent on a final decision on the route of HS2. Park

Midpoint 18 2 226 Acres 1,031,664 sq ft 600,000 sq ft Pochins 1,000,000 sq ft available in 4 plots. Site access roads required.

Although the site has the benefit of a reserved matters consent for Chatterley Harworth 3 109 Acres 900,000 sq ft 800,000 sq ft B1,B2 & B8 development, all proposals remain subject to technical Valley Estates due diligence as there are issues in the ground here. Following the recent pre-let to Dunelm by Prologis there are currently two plots, of 6 acres and 10 acres approximately, which Prologis potentially allow a building of circa 200,000 sq ft on the land to the Park, 4 16 Acres c.300,000 sq ft 200,000 sq ft Prologis rear. It is understood that both plots are now under offer – with Sideway the larger plot being let to a 3PL with a Dunelm contract and the smaller plot being under offer to Michelin for a 92,000 sq ft distribution facility. A mixed use scheme, capable of accommodating a single building Etruria 5 60 Acres 500,000 sq ft 300,000 sq ft St. Modwen of upto 300,000 sq ft but requiring the construction of an access road. A 14 acre development site owned by London Metric. Demolition The of the old building should begin imminently and will be complete Campbell 6 13.5 Acres 290,000 sq ft 290,000 sq ft London Metric by 2016. The site can accommodate units between 100,000 sq ft Centre and 290,000 sq ft in either a one or two unit scheme.

Whittle 7 21 Acres 462,000 sq ft 462,000 sq ft IDI Gazeley Consented development site on the established Meir Park. Road, Stoke

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4 CBRE REPORT ON DEMAND

Due to a general lack of stock, there has been only one Crewe-based transaction to report. In February 2015, Wincanton and Expert Logistics each committed to taking 50% of Tesco’s RDC on Weston Road, Crewe comprising 387,000 sq ft. The modern warehouse was built in 2006 by ProLogis and is leased at £4.50 per sq ft.

At Industrial Estate, Howard Tenens agreed terms to lease a second hand warehouse comprising 100,000 sq ft to service a Bentley contract. The rental achieved was £3.25 per sq ft which represented the quality of the building.

In October 2014, Norbert Dentressangle (now XPO Logistics) leased 185,000 sq ft at Radial Point, Stoke at £4.75 per sq ft. The building was constructed by Sladen Estates in mid 2000s and sits adjacent to Stoke City FC’s ground.

As can be seen by the recent deals, with Dunelm taking a pre-let, Screwfix taking a further 230,000 sq ft at Stafford and extending their base on Trentham Lakes at Stoke on Trent by a further 300,000 sq ft, there is good demand in the area, in line with strong take-up figures for the last three years:

Prime Regional 'Big Box' Take-Up

Q4 2015 102,000 sq ft Q3 2015 658,726 sq ft Q2 2015 230,347 sq ft Q1 2015 525,000 sq ft Total 2015 1,516,073 sq ft

Q4 2014 184,910 sq ft Q3 2014 - sq ft Q2 2014 300,000 sq ft Q1 2014 - sq ft Total 2014 484,910 sq ft

Q4 2013 340,157 sq ft Q3 2013 387,000 sq ft Q2 2013 407,061 sq ft Q1 2013 - sq ft Total 2013 1,134,218 sq ft

2013-2015 Total 3,135,201 sq ft 2013-2015 Annual Average 1,045,067 sq ft 2013-2015 Quarterly Average 261,267 sq ft

Currently there are a number of key local enquiries on the market:

 National Veterinary Services 300,000 – 400,000 sq ft  Portmerion 150,000 – 200,000 sq ft

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 XPO Logistics 200,000 – 250,000 sq ft  Simarco 100,000 sq ft

In addition to these particular enquiries, a recent enquiry schedule is attached as Appendix A, which suggests that there could be requirements in the area for upto 3.1m sq ft of built space and a further 30 acres of land.

4 CONCLUSIONS

Looking at the picture of supply and demand in the region, there is a compelling case for development at Radway Green. The figures below suggest that, if take-up continues at the levels seen in 2015, there is just eighteen quarters’ worth of supply in both standing buildings and land combined and less still if the level of take-up seen in 2015 persists:

Quarters of Supply

Total Supply (Land and Existing Stock) 4,746,231 sq ft

Quarters of Supply (2013-2015 average take-up rates) 18 Quarters Quarters of Supply (2015 take-up rates) 13 Quarters

What is more, if the current requirements from the attached schedule all materialize in the region, they would use up around 65% of this supply.

Not only would Radway Green be Geographically well-placed to cater to much of this demand, its positioning could allow it to act as a “gateway site” catalyzing an increase in demand for some of the older industrial units in the area.

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