December 6, 2021

BREAKING NEWS: Griswold Withdraws Proposal Prior to Meeting: Letter to the Editor: HRIC Chairman Invites Questions, Comments From Public on Halls Rd. Village District Application; Old Lyme Zoning Hearing Monday

UPDATED: 3:45PM We have just heard that Old Lyme First Selectman Timothy Griswold has withdrawn the application for the Halls Road Village District so it will no longer be on the agenda at the Zoning Commission this evening. 

To the Editor:

Schematic of proposed Halls Road Village District taken from application for same to Old Lyme Zoning Commission.

Creating a Village District is a complex process that involves multiple stakeholders and professionals. It is intended to address the goals of the Halls Road Master Plan Report, which were based on the past three years of research surveying the people and businesses of Old Lyme.

The Old Lyme Zoning Commission’s next Public Hearing will be held Monday, Nov. 8, at 6:30 p.m. and will include the continuation of the town’s application for the new Halls Road Village District.

Now is the time to pose questions to make this new zone the best it can possibly be. These can be sent ahead of the hearing to the zoning commission and/or in person at the meeting.  We welcome your comments, support and suggestions. Please email them to hallsroadcommittee@oldlyme-ct.gov

The rezoning application forward* that explains the reasons behind the rezoning is printed in its entirety below.

Visit this link to view the full application related to the Halls Road Village District, which has been submitted to the Old Lyme Zoning Commission.

Visit this link to view the presentation made to the Old Lyme Zoning Commission by the Halls Road Improvement Committee to support the application related to the Halls Road Village District.

Sincerely,

Edie Twining,
Old Lyme.

Editor’s Note: i) The author is chairman of the Halls Road Improvement Committee.

ii) *For the benefit of our readers, the text below is the explanation sent the Old Lyme Zoning Commission by the HRIC to support the application to create the Halls Road Village District. 

Dear Members of the Zoning Commission,

The Town of Old Lyme is excited to submit to the Old Lyme Zoning Commission this application to create the Halls Road Village District. This application is the result of years of work by the Town’s Halls Road Improvements Committee (HRIC) in consultation with local businesses, residents, town and civic groups, and professionals in relevant fields.

The aim of the Halls Road Master Plan (attached) is to secure the long-term viability of the town’s main retail district by a combination of improvements in the public realm, and changes in the zoning that regulates and guides the development of private parcels in the Halls Road district. The effort is intended to serve these and other needs of Old Lyme by changing the focus of development on Halls Road from isolated, car-centric, commercial-only strip centers to a walk-able, bike-able, mixed-use neighborhood that is safe and inviting, and is both more accessible to, and better integrated in form and function with, our historic civic center and arts district on Lyme Street. We believe these changes are needed to secure the town’s continued vitality, and will best serve the near-universal desire of residents to maintain the small town rural New England look and feel of Old Lyme.

Making the Halls Road area safe, inviting, and accessible to pedestrians and cyclists, and giving them an attractive connection between Lyme Street and Halls Road is chiefly a matter of public realm improvements. These improvements are a major part of the Halls Road Master Plan, but they do not, in themselves, require changes to zoning. The zoning changes are required in order to implement the over-all plan and support the long-term viability of retail on Halls Road.

The two aspects of the plan work together, and each relies on the other.

The turn away from a strip center model and toward a mixed-use village district does require zoning changes as requested in this application. Briefly, these changes include:

  • Establish a Halls Road Village District in which Lyme Street (not the current Halls Road) is the model.
    Allow mixed use in the new district. That is: allow a mix of retail, office, and residential, in which “residential” is limited to smaller-scale (e.g. apartments, condos, town houses, etc.) market-rate alternatives to the currently dominant housing stock (92% of which is single-family houses on their own lot).
  • Reduce the set-back requirements to encourage mixed-use buildings directly on Halls Road with retail on the first floor (facing Halls Road) and office or residential above and/or behind.
  • Relax the older parking requirements that encouraged maximal parking lots, and promote parking behind new buildings that face Halls Road.
  • Establish Design Guidelines and a design review process for the Village District to ensure new development and renovations advance the long-term goals of making Halls Road visually and functionally an integrated part of an extended town center based on historic Lyme Street.

Mixed Use
The introduction of mixed use in the new Halls Road Village District is a key part of the Halls Road Master Plan, and promotes the shared goals of Old Lyme on multiple levels.

Mixed use as proposed for Halls Road directly addresses a critical shortage of smaller-scale housing options in town, and places that housing in a village environment that is particularly attractive to older residents wanting to downsize, and to young families moving into town or just starting out in life. By making it possible for older residents to stay in town when they downsize, we keep friends together and support a community with deep connections. Younger families are the future of our town. They are the backbone of our all-volunteer support systems, including the OLFD, and their children are the whole purpose of our excellent schools. Without younger families, all of these institutions will wither.

Mixed use also helps to improve the general business climate of the town and of Halls Road in particular. Retail trade is under severe pressure from the Internet. There is increasing dis-investment in retail malls and little interest in retail investments generally. One type that does still draw investment is retail embedded in a mixed-use neighborhood, where foot traffic and casual browsing help bolster trade. Mega-malls tried to imitate a village setting but they failed. It turns out a neighborhood needs actual neighbors if it is to support local retail trade. It is not just the foot traffic, but the ambience of a vibrant living neighborhood that makes a retail area an interesting place to walk, browse, and meet one’s friends. That is the goal for the Halls Road Village District, and mixed use is a crucial part of that aim. Over time, the Halls Road Village District should become a living neighborhood with a mix of retail, office and residential—a walk-able retail town center that complements the civic and arts district centers on Lyme Street and connects with them seamlessly.

Mixed use supports our retail trade, but it is also beneficial in an indirect way. None of the hoped-for changes in retail or housing along Halls Road can come about until private investors are willing to create them. It is true that investors are more likely to invest in the kind of town-focused retail space that serves Old Lyme if that retail is in a mixed-use neighborhood, but residential building is still more attractive in the current economic climate than retail space. We think it is important to account for this in the new zoning by, for example, mandating a minimum of retail construction on Halls Road frontage. With the current commercial-only zoning, Halls Road is primarily attractive to businesses focused on the highway, not the needs of Old Lyme. Allowing mixed use will help to attract the kinds of investments we want, creating competition for the limited space. Clear zoning and Design Guidelines will also help to attract the kinds of investments we want, and discourage those we do not want. People in business like certainty. Clear planning, zoning, and design guidelines can give them that.

In addition to its direct benefits, mixed use in the Halls Road Village District will add much-needed variety to the housing stock and new tax revenues to the town without increasing sprawl across the remaining open land elsewhere in town.

The goal is to create, over time, an attractive streetscape of shops and restaurants/cafes that encourage residents and visitors to stroll, browse, and meet their friends. When people park once and walk it is better for business, builds community, and helps the environment. What Halls Road lacks today, and what the Halls Road Village District is intended to supply, is a sense of place that says “Old Lyme.”

Mixed use of the type proposed:

  • Creates a significantly more supportive environment for town-focused retail trade. (Crucial in the fast-changing economy.)
  • Makes a gesture at balancing our mix of housing stock.
  • Directly benefits two un-served housing markets (vital to Old Lyme):
  • Older residents downsizing (community continuity)
  • Young families starting out (town future: schools, fit volunteers)
  • Attracts investment in town-focused retail, as well as small-scale residential. 
  • Encourages what we want, which helps to forestall getting what we do not want.
  • Supports the most likely path to a wider range of retail to serve the town.
  • Creates a real, living town center that looks, acts, and feels like Old Lyme.
  • Gains new housing stock and tax revenues without sacrificing rural open space.

Public Realm Improvements 

The proposed public right-of-way roadway and sidewalk improvements (see attached Master Plan) will create safe pedestrian and bike routes along Halls Road from Neck Road (Rte. 156) to Lyme Street. Pedestrian lighting, landscaping, open green spaces, sidewalks, and crosswalks are all a part of the improvements the town will undertake. The plan also includes the most popular element suggested in town-wide surveys conducted in 2019: a new replacement for the old ‘Bow Bridge.’ This biking and walking bridge will span the Lieutenant River at the old bridge abutment, creating a safe and beautiful connection between Lyme Street and our main commercial district on Halls Road. Work on these improvements will begin as soon as the town secures funding and the required regulatory approvals.

Private Property Improvements 

The actual building and maintaining of a vibrant new Halls Road (commercial and/or residential) will be initiated and carried through by private investors and business people. The town can only open opportunities, provide guidance, and set limits; it cannot initiate in these areas. We hope to achieve a significant change, recreating a mixed-use town center for Old Lyme. That means responding to market forces and guiding development along Halls Road into the avenues that seem best for Old Lyme’s long-term future. 

An illustrative plan was drawn up to show how Halls Road could be redeveloped to reflect community priorities and desires for this area. It is just an example of how new private investments could play out over the next 20 years. To allow this type of development to occur, new Village District zoning is needed to allow and attract retail and residential investment, and to no longer require the deep set-backs and large parking lots that favored strip centers. The zoning that once attracted strip centers now disproportionately favors investments aimed primarily at serving highway traffic (e.g. gas stations and fast food chains). 

The town has said for decades it does not want Halls Road to be dominated by highway services. New zoning is required to address that. In addition, the 2020 Plan of Conservation and Development (POCD) states that visual details such as adequate buffering and landscaping, appropriate architecture, preservation of natural site features and vistas are among the critical components of the look and feel of Old Lyme, yet there are no regulations in place mandating attention to such details except in the Sound View Design District. The proposed zoning changes are intended to address these community concerns in the Halls Road area. 

The Master Plan was used as a tool to help in writing new zoning language and design guidelines. In the new zoning, cluster housing, town houses, and second-story apartments will help ease the severe shortage of smaller-scale housing options in Old Lyme, and help turn a “9-to-5, commercial-only” area into a living neighborhood with mixed use—as Lyme Street was before the 1960s. The primary goals of the new Halls Road Village District zoning and Design Guidelines are to keep and attract the kinds of amenities that serve the needs of Old Lyme, and to create a look and feel in keeping with the rest of the town. The long-term goal is to create a mixed-use commercial and residential neighborhood that feels like a part of Lyme Street and the wider town of Old Lyme.

Zoning Regulations and Design Guidelines 

Two additional (new) Zoning elements are proposed to help guide the redevelopment of the Halls Road area. One is a recommendation that the Town establish a new zoning district called the Halls Road Village District. The second is the preparation of Design Guidelines to be used by a new Halls Road Design Review Committee (under the Zoning Commission) to guide the design of new buildings and sites as well as the rehabilitation of existing buildings within the Halls Road Village District.

New Zoning Regulations for the Proposed Halls Road Village District 

The proposed Halls Road Village District zoning is intended to encourage the redevelopment of this older commercial corridor in a manner that is more consistent with the architectural styles of the Historic District of Old Lyme. The proposed regulations have been written to encourage safe and healthy use of the area by providing for a mix of residential and commercial uses along or within close proximity of the road corridor to encourage walking and shopping within a village atmosphere. Further, the intent is to encourage a new mix of residential and non-residential uses within the district, and to encourage the creation of diverse housing types that are currently under-represented in Old Lyme.

Once the new and revised zoning is adopted, development in the district shall be designed to achieve the following compatibility objectives: 

  • The building and layout of buildings and included site improvements shall create a village character and streetscape environment through the placement of buildings and included site improvements to enhance the district
  • Existing and proposed streets shall be inter-connected
  • Open spaces within the proposed Village District shall reinforce the rural, riverside setting and the small-town nature of Old Lyme in form and siting
  • Locally significant features of the area, such as natural resources or sight lines of vistas from within the district, shall be integrated into the site design 
  • The landscape design shall complement the district’s landscape patterns
  • The exterior signs, site lighting, and accessory structures shall support a uniform architectural theme
  • The scale, proportions, massing and detailing of any proposed building shall be consistent. 

Design Guidelines to Supplement Zoning in the New Halls Road Village District 

In surveys and public meetings, many residents said they wanted Halls Road to be a walk-able, bike-able area with safe streets, and the feel of a real neighborhood with mixed use – a new town center. Older residents remember Lyme Street as just such a place before retail trade was deliberately moved to Halls Road. Old Lyme is one of the oldest settlements in New England, and as attached to its traditions as any small town needs to be. Traditions notwithstanding, the town has evolved over the centuries to meet changing conditions.

Most retail trade was banished from Lyme Street around 1960 and relocated to a series of strip centers with vast parking lots fronting Halls Road. Easy parking was the “must-have” of the car-centric 1950s. In exchange for more parking (and to relieve pressure on potential wastewater treatment capacity) the town broke with 250 years of community development in which commercial, residential, and civic uses had evolved together in mutually supporting roles. Something was gained, but something valuable was lost.

This is not a criticism of the people who made those decisions in the 1950s. They faced the challenges of their day, and chose the solutions that made sense then. We face different challenges. Today, the older mixed-use model seems most resilient in the face of online commerce, while strip malls fade. We must choose what makes sense now. If the specific choices seem opposites, the impulse is identical: to do what is best for Old Lyme’s future. 

Despite efforts at tasteful design, the strip centers on Halls Road have never looked like a part of Old Lyme, nor of any other New England town. The Halls Road Village District Design Guidelines will look to Lyme Street as the basic model to set the style of future development along Halls Road. We believe that functional and aesthetic improvements to the Halls Road Village District will increase its value to businesses, residents, and property owners alike.

The purpose of the Design Guidelines and design review process is to implement design standards for new or renovated buildings that will: 

  • Make sure future development in the Halls Road Village District works to make the look and feel of the district more like that of historic Lyme Street.
  • Provide prospective developers or renovators with a clear view of acceptable styles, including examples. 
  • Make clear what is not acceptable in renovations or new developments. 
  • Support and reinforce the long-term aims of the Halls Road Village District: the creation of a vibrant, mixed-use neighborhood, well integrated with historic Lyme Street. 

Community Input and Process to Date 

The preparation of the Halls Road Master Plan, and of the proposed new Halls Road Village District zoning and Design Guidelines, has been guided by: 

  • Recognition of changing economic and environmental circumstances,
  • The established aims of the Town (as expressed in official planning documents), and 
  • A continuous and extensive effort to keep all stakeholders involved in planning a better future for Old Lyme’s main retail district along Halls Road. 

A more complete discussion of these elements, including a timeline, summaries of actions and findings, and pointers to additional sources is included in this document as Appendix A.

As the formal Halls Road Master Plan was completed, HRIC went back to the community to gauge support, visiting local businesses, institutions, and civic groups to present the final plan and answer any questions. This is an ongoing effort, but the response to date in dozens of sessions involving scores of individuals has been very positive, often enthusiastically so. 

Opinion seems to have evolved since the subject of change along Halls Road was first raised several years ago. Residents and other stakeholders have had time to consider the issues. Responses to the CERC survey of 2019 showed over 80% of respondents wanted some development along Halls Road, though only a minority at that time asked specifically for mixed use. Today the idea of mixed use on Halls Road has much greater and broader support, and its role in helping to achieve related aims is better understood. 

Appendix A:

Community Input and Process to Date 

The preparation of these proposed Halls Road Village District zoning regulations and Design Guidelines has been guided by: a recognition of changing economic and environmental circumstances, the established aims of the Town (as expressed in official planning documents), and a continuous and extensive effort to keep all stakeholders involved in planning a better future for Old Lyme’s main retail district along Halls Road. 

Plan of Conservation and Development 

The proposed changes address four long-standing concerns of Old Lyme’s formal planning efforts: the mix of retail trade along Halls Road, the viability of the town’s main business center, the need for greater variety in the town’s housing stock, and the over-arching concern of maintaining Old Lyme’s small-town look and feel. 

Retail:

Because Halls Road is the connector between the two halves of Exit 70 it has always been attractive to businesses focused primarily on serving the through traffic on I-95, the main route between Boston and New York. The town has always insisted that Halls Road, the town’s main shopping district, should be focused instead on the needs of Old Lyme residents (year-round and seasonal). The town has opposed any tendencies to allow Halls Road to become a mere ‘service plaza’ for travelers. From the Old Lyme Plan of Conservation and Development (POCD) of 2000 and of 2020:

“Old Lyme was once an active center of transportation as passengers awaited the ferries carrying people, goods and even railroad cars across the river. With the construction of a series of ever larger bridges, there is now little need to pause in Old Lyme during journeys along the Connecticut coast. The town’s interests are focused on providing basic services and amenities for year round and summer residents and guests. It has successfully avoided any pressure to allow turnpike oriented* services such as multiple gas stations, fast food restaurants and motels. This is not an accident, but a deliberate choice.” [Old Lyme POCD 2000, page 5, paragraph 3] 

“Although Old Lyme has two exits connecting to Interstate 95, the town’s interests are focused on providing basic services and amenities for year-round and summer residents and guests. It has deliberately avoided any pressure to allow turnpike-oriented* services such as multiple gas stations, fast food restaurants and motels.” [Old Lyme POCD 2020, page 8, paragraph 3] 

*[I-95 shares the roadbed with the older (1958) Connecticut Turnpike from the New York border to Exit 76 (I-395) in East Lyme.]

Change:

Changing economic conditions are overtaking the confident language of the POCDs. Old Lyme long resisted the pressure to make Halls Road a mere service plaza for I-95, but it did so in a time when many other uses (more congruent with town aims) were competing for the same retail and commercial space. Since 2000 Internet commerce has come to dominate one retail segment after another. For goods or services that can be delivered electronically or by express truck, the Internet now offers a wider range at a lower price than any local ‘bricks-and-mortar’ retailer can hope to match. Retail that is embedded in a viable mixed-use neighborhood (with foot traffic and walk-in trade) seems best able to resist the total virtualization of retail trade. Halls Road was always attractive to highway-focused services. In these new market conditions the “commercial-only” designation makes Halls Road attractive primarily to such businesses. 

The proposed zoning changes and Design Guidelines are necessary to protect and promote the long-established aims for Halls Road set out in POCDs over multiple decades. They will help Old Lyme adapt to changing market conditions, and retain the convenience of town-focused retail trade along Halls Road. 

Housing:

The proposed changes will address another long-standing concern of the Old Lyme Planning Commission: adding much-needed variety to Old Lyme’s housing stock, 92% of which is single-family homes on their own lot. For decades, Old Lyme’s POCDs have called for the addition of alternative housing types in appropriate locations. Halls Road is an appropriate location in which to meet some of the demand for smaller-scale, market-rate housing that is not of the dominant type. 

Small Town:

The proposed zoning changes and Design Guidelines are intended to work together to ensure that Halls Road becomes more integrated with the rest of Old Lyme’s town center, both in form and in function. The aim is to create, over time, a mixed-use district that looks, acts, and feels like a living part of Old Lyme—a small town on the Connecticut shoreline. 

Halls Road Improvements Committee 

The Halls Road Improvements Committee (HRIC) was formed at the close of 2015. The initial impulse was public demand for safer pedestrian and bicycle access to the shopping district along Halls Road, and a desire to support the future commercial viability of the town’s main retail area. 

A 2015 change in Connecticut law had made it easier for towns to create Tax Increment Financing (TIF) Districts, and that was an early focus of the HRIC. A TIF district allows a town to fund current development (such as capital improvements) in the TIF district by earmarking future property tax revenue increases there for those purposes. The creation of a TIF district requires a formal plan of development for the district, and there was none for Halls Road. Funds were allocated for the planning work. 

The improvements under consideration were not a trivial expense. Many residents objected that such a large sum should not be spent without looking more broadly at Halls Road and the various problems and opportunities it presents. Without a plan, how could we know what sort of development we wanted along Halls Road or what Halls Road should look like in 20 years, much less how the sidewalks should be laid out to accommodate that future? To build sidewalks without a plan for the future seemed unsound, so planning took precedence. 

Early in 2018 HRIC was allocated $20,000 to begin the planning process. The town hired the Yale Urban Design Workshop (YUDW), which produced very helpful baseline drawings of the existing conditions at Halls Road. YUDW also ran two public meetings intended to introduce the town to the kinds of considerations typically encountered in a planning effort. Ultimately, HRIC felt YUDW failed to grasp the small town nature of Old Lyme, offering options more appropriate to an urban than a rural setting, and so recommended the town not engage YUDW for later phases. 

The planning effort continued with local volunteer resources. During this process it became clear that Halls Road was not a project of the right scale and scope to take advantage of a TIF district, and that avenue was not pursued further. In 2018, HRIC’s volunteers produced a vision proposal for Halls Road.

In 2019 HRIC presented the vision proposal to multiple local groups, publicized it online and at the Mid-summer Festival, and held two open houses at which residents and business owners could speak one-on-one with committee members and register their opinion on specific aspects of the ideas under consideration. 

EDC and CERC:

Also in 2019, the future of Halls Road figured prominently in economic research, surveys, and workshops conducted on behalf of the town’s Economic Development Commission (EDC). The EDC engaged the Connecticut Economic Resource Center (CERC, now AdvanceCT) to help create a picture of the economic environment of Old Lyme and its place in the surrounding region. 

As a part of that effort CERC and EDC conducted a major survey of Old Lyme residents and business owners. Nearly 10% of the adult residents and over 10% of the representatives of local businesses responded to the survey. It covered Old Lyme as a whole and broke out specific areas, including Halls Road, for particular questions. Most of the survey questions were in the form of ranking a set of attributes or aims by their importance. Respondents also had the option to provide additional comments. Among the findings were: 

  • Nearly all respondents said future development should be consistent with the small town charm of Old Lyme and reflect its particular rural New England look and feel. 
  • Over 80% wanted improvements along Halls Road, from more varied restaurants and shops to greater safety for walkers and cyclists. 
  • Businesses wanted the town to do more to encourage business, thought the town needed a proper town center, and wanted the town to encourage more young people to move here. 
  • Responses regarding housing were self-contradictory, with only one in five saying Old Lyme needed more housing, yet two-thirds saying some specific type of housing was in short supply and should be added. 
  • Similarly, few said Old Lyme needed additional green space, but when asked about Halls Road in particular, 75% said development there should include additional green space, small parks, etc. 

CERC ran two workshops with representatives of commercial property owners, local businesses, and civic groups. The workshops considered the Strengths, Weaknesses, Opportunities, and Threats (SWOT) relevant to Old Lyme’s future. Although the scope was town-wide, Halls Road (as the main shopping area) was a major focus. A wide variety of factors were identified and discussed, but a few stood out as areas of broader agreement. In order of their relative prominence under each heading, these were: 

  • Strengths: Good schools, artistic heritage/culture, natural beauty/location, and volunteerism/sound town finance. 
  • Weaknesses: Lack of diverse housing for younger/older residents, weak CT economy, constraints on infrastructure [presumably: wastewater/groundwater], lack of walking/biking infrastructure, no coherent plan for commercial areas (Halls Road, Hartford Ave.) 
  • Opportunities: Deliver action plan for Halls Rd./Hartford Ave., make town more connected for bike/foot traffic, diversify housing stock, change Soundview stigma, attract younger residents. 
  • Threats: Resistance to change, CT state policies, environmental change, growing competition nearby. 

There was some confusion between “weaknesses” (~internal to the town) and “threats” (~external). Despite that definition, “resistance to change” was the most commonly cited threat to Old Lyme’s future, and Connecticut’s lackluster economy accounted a weakness. 

The need for different types of housing, and its role in ensuring a viable future for Old Lyme was far more prominent in the SWOT workshop discussions than it had been in the general survey. The fact that SWOT participants were all business- and civic-oriented may help to explain why they were more aware of the issue. Also, the SWOT workshops took place after the town-wide survey and many HRIC presentations, at a time when there was increasing public discussion of possible changes to Halls Road. The idea of mixed-use along Halls Road seems to have steadily gained public support over time, and continues to do so. 

Formal Plan:

Feedback from HRIC’s town-wide presentations and interactions, and the results of EDC research provided additional direction to the planning process. 

A formal plan for Halls Road required professional experience and knowledge. A search narrowed the field to three firms who presented proposals to HRIC. Of these, BSC won the contract at a cost within the limits of the funds previously allocated for planning. At the end of 2020, the town of Old Lyme engaged BSC Group, Inc. and their sub-consultant, Bartram & Cochran, to create a Master Plan, propose Public Realm (i.e. roadway, sidewalk and public open space) improvements, and to write Design Guidelines and recommended Re-Zoning Language for a new Halls Road Village District. 

That work is now complete, and the re-zoning language and Design Guidelines are presented with this request. 

Community Support 

As the formal Halls Road Master Plan was completed, HRIC went back to the community to gauge support, visiting local businesses and civic groups to present the final plan and answer any questions. This is an ongoing effort, but the response to date in dozens of sessions involving scores of individuals has been very positive, often enthusiastically so. 

Opinion seems to have evolved since the subject of change along Halls Road was first raised several years ago. Residents and other stakeholders have had time to consider the issues. Responses to the CERC survey of 2019 showed over 80% of respondents wanted some development along Halls Road, though only a minority at that time asked specifically for mixed use. Today the idea of mixed use on Halls Road has much greater and broader support, and its role in helping to achieve related aims is better understood.

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