Public Toilets Block Millfields Road London E5 0RU

Application Number 2011/0094Application Registered 27-01-2011 Comments Until 28-02-2011 Site Address Public Toilets Block Millfields Road London E5 0RU Application Type Conservation Area Consent Development Type Other – miscellaneous Proposal Conservation Area Consent for demolition of existing WC block. Current Status REGISTERED Applicant Mr Temel Alp Agent Claridge Architects Wards Leabridge (K) Location Co ordinates Easting 535145 Northing 185950 Case Officer / Tel Adam Flynn 020 8356 8095 Proposed Land Use Dwelling houses (whether or not as a sole or main residence), Retail shops other than the sale of hot food -o0o-This looks like a big block of flats and a shop sitting on Clapton Pond, I’ll see if I can dig out the drawings.The objection period is over, but @ianrathbone is talking at the planning hearing, so can take any objections with him

62 Comments

  1. @ianrathbone @ewebber This is a difficult site. I guess that it is inevitable that it gets developed at some point and at least this proposal isn’t some ludicrous pastiche (like the low-grade Victorian pastiche building that has recently been tacked, anachronistically, onto the other side of the 1930s Palm2 building.)That said, I think it silly that an otherwise modern apartment building should be clad in brick (which, more often than not in Hackney, means the architectural nadir of faux-brick cladding!). But weighing everything up I probably approve of it on the grounds that more pastiche mocking (in the crueler sense of the word) our historical period architecture would actually culturally degrade the area. Furthermore, given London’s chronic and dire housing shortage, resulting in some of the smallest and most expensive housing anywhere in the world, we need all the new apartments we can build (and more).

  2. @benjamin I know just a snippet of this, but the building they are proposing is pretty big and goes against many of the guidelines of the conservation area, I’ll see if I can get some more info

  3. @ewebber No, it’s actually lower than both the Georgian terrace to its north, and the 1930s Palm2 building to its south.

  4. Actually, having looked at the plans again, I think the proposal rather good (except the nostalgic brick).

  5. @benjamin and all – I’ll dig out the full details of why people are objecting a little later after work.

  6. I suppose anything too massive would be a problem. However, it’s hardly an architectural triumph at the moment… 😉

  7. @ewebber @ianrathbone \..is talking at the planning hearing so can take any objections with him”.Not just “objections” I hope?”

  8. @benjamin – I believe @ianrathbone has registered to speak in opposition, although I may have confused that with something else he’s going along to. If you want him to speak on behalf of any opinions you have on it, it’s worth getting in touch with him

  9. Well let’s be frank, it aint a work of art, but then neither is it a monstrosity. Given that the area around the pond is one of mixed architectural style, with Georgian, Victorian and 20 century buildings around it, something more modern looking wouldn’t necessarily be out of place. On a broader note, I think it’s pretty important to strike a balance between protecting our neighbourhoods and encouraging development. Given recent opposition to things – most notably the opposition to the license for the Clapton Hart – I’m a bit worried that the area could become a sort of Boho-Nimbyist ghetto.

  10. @gavinredknap I agree with you about the mix of architectural styles. Each era has been allowed to sing its own tune (so to speak), so I don’t really understand this obsession many have with homogeneity and/or fixating on one era. Note the low-grade Victorian pastiche that has just been added to the side of the 1930s building housing Palm2, which I mentioned earlier. Did people really object to Clapton Hart license!! I’m amazed. I would have thought everybody would recognise their arrival as one of the best things that’s happened to Clapton in years. On what grounds were the objections?

  11. Please don’t tell me The Clapton Heart had its license turned down due to people objecting…

  12. Well unless I have the wrong end of the stick (wouldnt be the first time mind) there is an objection to the hours that they are requesting license for, essentially midnight weekdays and 1 am weekends – the same sort of license that the Coach and Horses have on Stokie high street.

  13. @cherkoff I don’t think a decision has been made yet. Let’s hope not. I’m sorry to say that I think there’s a contingent in Clapton that just likes opposing things for the hell of it!

  14. @gavinredknap I agree with a mix of styles, after all I live in a new build in Clapton – I’m not a fan of pastiche at all. Although it should be remembered that this application is not just residential, there is a new shop underneath – it would be useful to push for this to be community use (not that it did 144-146 Lower Clapton Rd any good)With regards to the Clapton Hart, I am a big advocate (I think that’s pretty clear) – I understand that people can remember how bad it really was and it’s understandable that it makes them nervous. As far as I am aware the police are supporting the licence application so it has a good chance of going through.

  15. Well whether we like it or not we can’t dictate what businesses want to take up residence in our area. Sometimes theyre good (like the coffee shop), sometimes neutral (in my opinion, at least, Tesco), sometimes negative (bookies). We can’t hope to successfully oppose it every time a business we don’t like comes into the area. What we can do is form better neighbourhood bonds through discussion and events and promote the sort of shops we like with patronage, which should eventually attract more of the type of shops and businesses we want to see. In the meantime it’s a case of preventing the sort of cheap, ugly developments which hinder the long term fabric of the neighbourhood and maintain the areas great potential.

  16. @ewebber but as you say that approach didn’t achieve anything at 144-146 LCR, so why would it by the Pond? Given its prime location I’d be happy to see a pavement cafe open there.

  17. @gavinredknap the council can if they want to, choose to make the premises of a different use, e.g. rent it to community organisations as a lower price. In my opinion this helps communities and keeps money in them, rather than bringing in big organisations with greedy shareholders. At the end of the day we all have our own ideas about wether we thing certains businesses are good, negative or neutral. But unless we know about them we don’t even have a chance to form that opinion – I started this group to help spread the word and keep people informed enough to choose.

  18. @benjamin there were other factors in play at 144-145 – mainly a massive mobile phone mast and base station in the way for a number of years

  19. It is a difficult site. They could have had a small public space on the acute corner, which could have worked well with a cafe or restaurant on the ground floor, but maybe the footways are wide enough to put chairs and tables outside.It’s quite a large retail unit on the ground floor. I’m not sure if they already have an occupier but the size would be perfect for a betting shop(!). I’m not sure what the proposed use of the unit is, but if they’d split it in half it wouldn’t be as attractive for larger chains. (but then they wouldn’t get as much rent!) The north facing single aspect flats won’t be very nice either. I haven’t looked at all the plans but it seems the first and second floor have north facing single aspect flats.It’s not terrible, but i think it’s impact on it’s immediate surrounding will be based on who and how the ground floor is used by, and you can’t enforce that through planning.

  20. I think it’s helpful if companies are aware that an area has a reputation for being vocal (aka a pain in the a**). I became embroiled last year in opposing National Grid’s plans to build a road through Millfields Park. I’m not sure if the local residents managed to actually stop that plan. However, I was left with the impression that NG, having intially thought they’d could just steamroller it through, were surprised at the level of protest, and decided it all was a bit more trouble than it was worth.

  21. @euan \perfect for a betting shop”? I would have thought it would suit any number of commercial uses.”

  22. But is that the solution long-term for the area? Say for an example that this place was rented – at a subsidy paid for by taxpayers – to a community group instead of given to a bookie. What stops the bookie setting up shop down the road? At the end of the day what’s going to make it a good area will be the economic viability of the area. Bookies and chicken shops dont proliferate in ‘better’ areas because the council or lottery is subsidising artists or community groups. They dont exist because they cant make money to cover their rents.

  23. Don’t get me wrong, I hate bookies and would be happy to see central government tighten up on gambling law. But since what they do is legal, and there’s obviously a demand for them (God knows why) then I don’t think we can realistically complain about them via a planning issue.

  24. @benjamin sorry, i was highlighting a point. What i mean is that the unit size will probably be to big and expensive for a new/independent/local venture. @GavinRedknap to a certain extent i agree with you. However, the ‘hardware’ of a place has an impact on who and how it is used. It happens that large retail chains are not very flexible in terms of the size and types of units they can use – so this is one way that you can influence the type of place an area becomes.

  25. That’s getting to the crux of the issue. Shops can come and go but the buildings in which they are housed are more permanent. I think its in everyone’s interest to make sure that those buildings are of a good standard and add to the landscape, but we cant expect to successfully oppose what shops go there on grounds of morals, ethics, political persuasion et al. Like it or not the law of the land previals.

  26. i’m not sure why, but everyone seems to have missed the fact that the building is clad in timber, with only a little bit of brick at ground floor. i like it – much better than the previous scheme anyway. have a look at this application for the same site… http://apps.hackney.gov.uk/servapps/Northgate/PlanningExplorer/Generic/StdResults.aspx?PT=Planning%20Applications%20On-Line&SC=Application%20Number%20is%202009/0843&FT=Planning%20Application%20Search%20Results&XMLSIDE=/servapps/Northgate/PlanningExplorer/SiteFiles/Skins/Default_AA/Menus/PL.xml&XSLTemplate=/servapps/Northgate/PlanningExplorer/SiteFiles/Skins/Default_AA/xslt/PL/PLResults.xslt&PS=10&XMLLoc=/servapps/Northgate/PlanningExplorer/generic/XMLtemp/iiomth55trao1n45aqci0b55/d9e29beb-2d50-480e-bf8d-a9961ee8c0f7.xmlalthough the retail unit at ground floor could end up as anything, they’ll only put a tesco metro in there if clapton needs one. and they could quite easily put one somewhere else on the high street if they want to. there probably isnt enough foot fall on that side of the pond anyway. just my views anyway.

  27. as I understand it the planning application is not currently for a bookie or a chicken shop (no hot food), but for retail use. both of those an additional licence – which could be applied for.@euan I agree on the size issue, as I understand it one of the problems with 144-146 LCR was also size, what local business can afford 3 units knocked into 1

  28. @helenlittlewood: surely even Tesco aren’t that aggressive to want another store there?!@Euan: fair point and well made. Unfortunately, the places that seem to best fit the bookies these days are pubs, which are some of (sometimes the only) architecturally interesting buildings in this part of London.

  29. @helenlittlewood I did notice the wooden strips, but I think theysit infront of brickwork that covers most of the building

  30. i just printed the design document and the pictures of the new building look like you only really see the wooden bits when you look at it. its nice that theyve tried not to do some horrible cheap brick thing like the previous one. GavinRedknap – where i used to live in manchester there was a crossroads with a tesco, a sainsburys and a coop on three of the 4 corners- V agressive. i agree though, a bookmaker sounds most probable. would be nice if i could get a costa on my way to the station in the morning though!

  31. well given their expansion in the area and the size of the place, perhaps s prime candidate will be – whisper it – nandos…..

  32. And that’d be fine with me. I think some of this selective opposition to different businesses is often rooted in cultural snobbery rather than any coherent reasoning.

  33. @helenlittlewood Thanks Helen. I just looked at your link to the previous application that was refused. Phew! Actually, the link wouldn’t work but the app. no. is 2009/0843

  34. @benjamin i’m sure you’re right about cultural snobbery. However, there is significant amount of research that shows that independent businesses have a much stronger relationship to the local community, keep money in the area and are much more beneficial to their neighbourhood than a national chain. So although the aspiration for local independent businesses might derive from cultural snobbery they have tangible long term advantages.

  35. @euan But Lower Clapton Rd is overwhelmed with empty small commercial premises! Why do we need more? Give me an open shop run by a large company rather than an empty one any day.

  36. ..or for that matter give us a decent small chain restaurant rather than another late night ‘local’ offy or kebab house.

  37. @euan \So although the aspiration for local independent businesses might derive from cultural snobbery they have tangible long term advantages.”But if all we’re left with is small empty shops there are no tangible benefits just a self-defeating snobbery. It appears to me that the drivers of commercial vibrancy on LCR is the arrival of two chains; Tesco and Antic. Hopefully these will bring more people to the area and consequently make the smaller and currently empty shops more appealing/profitable/viable. I simply can’t think of any reason why we’d want more small shops other than as an ideological expression against large business.”

  38. Benefits of independent businesses aside, the size of units is also important as it makes up what urban designers call ‘grain’. Streets with finer grain are more adaptable and resilient to economic and cultural change than a street with a more coarse grain. For example, a street might have 20 shops with 5m frontages or 4 shops with 25m frontages. The former makes the street more resilient as not single unit has too much of an impact over the street as a whole. LCR is a perfect example of this, although there are some sections of fine grain on the whole it is made up of large plots of land that take up significant street frontage. I’d claim thats the reason it’s not as successful street as Kingsland Road is exactly this.

  39. @euan Professional jargon aside, the reasons why LCR is a commercially less vibrant than some others is multiple and complex but include the \Murder Mile” tag (one recent post on this forum stated that the loan for her coffee-shop was only granted because it was opposite the police station). Your argument would make more sense were we talking about say Islington Upper St where the number of chains are increasing and one might argue that they are “forcing out” small independents. But to make the argument for more small shops in an area dominated by small empty shops is perverse. You say that LCR “on the whole is made up of large plots of land that take up significant street frontage”. I don’t agree. We are talking about commerce here. On the whole it is dominated by small (often empty) shops. Stretches of commercial areas are separated by residential parts but since no-one is talking about replacing these with shops (small or large) I can’t see the relevance. Also there are far more large shops on Kingsland than on LCR so I can’t see your point here.”

  40. @euan I understand that local businesses \keep money in the area” but since we have plenty of cheap empty small premises we have to ask what are the reasons they are not opening rather than building more of the same. The net result of this is keeping new money out of the area.”

  41. The biggest drive of commercial and cultural vibrancy in the area is from the small local shops (I’d include Palm 2, pages of Hackney, Biddle brothers in that), the influx of people with more money and community initiatives that are helping form stronger local identity.Tesco Express are doing well at creating a lot of excess rubbish I have to walk through when I come home.

  42. Since we’re broadening the discussion beyond a planning app. here, I’ve started a new topic;http://www.yeahhackney.com/how-to-improve-commercial-vibrancy-on-lower-clapton-rd/#post-2759

  43. I’d suggest that the main reason LCR isn’t particularly successful comes more down to its inaccessibility than anything else. Upper Clapton has the train station and through traffic but little potential, unfortunately. Lower Clapton has the potential but dreadful transport. Both are separated by a huge roundabout. That said, I see enough people getting off of the train every night to know that there is a vast potential pool of local consumers. Problem is you need people to take risks to create the sort of places that they’re likely to go to. In this regard the opening of the Clapton Hart is perhaps the most significant thing to happen to the area to date. If that proves successful, others will take note and follow. One thing we really, really need is a decent restaurant.

  44. CPNAG have just sent out an email with a computer generated image of the proposed development of the disused toilet site. Personally, the more I look at it the more I like it. I think it would elevate the status of the Pond area no-end. CPNAG oppose it however, instead favouring something “sympathetic to the best bits of the architecture around the pond, and to the pond itself”. It’s a virtually meaningless sentence I know, but reading between the lines, I guess they mean they favour Georgian pastiche. Excuse my crappy computer skills, but I don’t know how I can get the CGI posted on here. Could someone else who has the CGI – and better skills than me – have a go?

  45. If people want to have an input into the decision on this application, there is still time to make comments, please see the thread here: http://www.yeahhackney.com/still-time-to-have-your-say-on-the-millfields-public-toilet-site/

  46. @ewebber Why a new thread?

  47. Could someone direct me in the way of the CGI pics of the proposed development?

  48. @euan You state: \Great that @yeahhackney allows for this difference of opinions – it would be interesting if they could put up a poll to see what most people here think. I agree that the site will be developed in one way or another. However I think it’s important not just to take what you’re given when it comes to development. That other block just to the north on Clapton Pond is a perfect example objections made developers go back to the drawing board and improve their scheme and since then the community supported the application. Once something is built it will be there for generations to come and can make or brake a place. As I expressed elsewhere there are good and bad aspects about the scheme and i think it is only right to push the developers to improve it. Remember they are in it for the money not for the place and the role of planning is to ensure that what gets built will benefit the place in the long term. One development at a time a once vibrant area can become derelict and under used – look at LCR. @benjamin are you at all involved in the proposal?”Are you now suggesting that LCR is run down and under-used because of developers??!!No I am not involved in the proposal euan. But I’d be very interested to know why you ask!”

  49. Since this topic has now been restored to unity, I’ll repost my comments to the council, if anyone’s interested:Dear Mr FlynnI understand that the deadline for comments regarding the above application has been extended and I would be grateful if you would take into account mine before making judgement on the application. Firstly, I think everyone is agreed that this site will be developed and I believe that the proposal is an excellent one for a variety of reasons;a)Its scale/massing is smaller than both the Georgian to its north and the 1930s building to its south and therefore I cannot see how anyone could object on these grounds.b)The proposed shop on the ground floor is large enough to be commercially attractive/viable, ie, the last thing Clapton needs is yet more small empty shops.c)It provides much needed housing.d)It is of modern appearance which is in keeping with the long-established approach in the area of allowing each era to sing its own tune ie, the Pond area already has an array of building styles from Georgian to Victorian to 20thCentury. This modest addition would be in keeping with that tradition.e)On a less objective note, I find the proposal aesthetically modest, refined and elegant and I believe that it would elevate the status on the Pond area no-end. Finally, I would also like to draw your attention to something that has been troubling me. The Clapton Pond Neighbourhood Action Group (CPNAG) seems to acknowledge that there is differing opinion on this proposal (both within the community as a whole and within the group itself) and yet it takes a position of opposition and via its email releases etc. appears to only encourage comments of opposition. You may wish to take this into account before jumping to the conclusion that this \neighbourhood” group is in anyway representative of it. Yours sincerely.”

  50. @benjamin thanks for bringing my comment back to here – it was getting confusing. My question about your involvement was just because you seem to support it a lot. Apologies, no offence intended.About LCR, yes, it is my view that LCR has suffered because of poor development over the years – Lea Bridge Roundabout being the most obvious.It would be great if you came to one of the meet-ups, i’d love to continue the chat about LCR over a pint!

  51. I live on Millfields road and when I saw in early Feb that another application had been made, my gut reaction was that it was going to be terrible. However, I read through the entire application (it strikes me that sometimes there are a few too many people protesting about things without fully reading the actual plans) and felt that ultimately I thought the development was pretty decent and was light years better than the previous submission. I think as a community we need to strike a balance between rejecting developments and showing that this area is an area that is open for good quality urban regeneration. It is our job to push the council to by proxy push developers to make sure that the quality of the regeneration is kept high and appropriate. For example, I think it would be a crying shame if people like Antic had such a bad experience opening a pub on a site that has been a disused eyesore for many years (yes I know its history) that other people thinking of investing in the area had second thoughts. Anyway I’m all for protesting, but I think that this development is actualy reasonable unlike some of development crimes that look like they could be allowed at the Tram Depot and the Essex Wharf development.These are the comments I submitted to Hackney on the 9th Feb, which I think broadly align with some of the discussions that have been going on here:I just wanted to make a short comment in support of this planning application. I was pretty dubious when I saw the 2D elevation drawings, but reading through the impressive pack put together by the architects, I was won over by their design vision. The development will be impressive and I think it will offer an impressive entrance to our road: Millfields. I have a few concerns:1. The architects have outlined an excellent vision, but I worry that the developers may, once construction started, seek to cut corners and thus eat into the architect’s vision resulting in a poor quality addition to Clapton pond that is far from the original vision. For example, the brown roof and solar panels are absolutely commendable (we put a green roof on our kitchen extension), but they are a favourite of architects but add complexity and cost and I can see the developer removing this. The same goes for the high quality exterior and what is there to stop the developer from reverting to something more akin to their disgusting original submission.2. The retail space: what kind of shop is going to take advantage of that retail space. It is a layout that would lend itself to an express supermarket, but with Palm 2, the new Tesco express, this is the last thing we need. I just don’t see that retail space being attractive to a wide range of retailers.3. Although, the supporter of regeneration in me supports the concept of a high quality retail space addition to the pond, it is worth noting just how many shops are derelict on the opposite side of the road.Overall I think the development is well thought out and the properties are not as small as some of the space-pinching low-quality developments that are so common around here. I hope, though, that the developer is forced to see this vision through and is not just using this impressive planning submission as a smokescreen to start building an uninspirational development.

  52. @euan I support it because I think it will be a huge improvement for the area and I live nearby in Cricketfield Rd. Actually, I think we may have already met fleetingly at a Chatsworth Market meeting in Chats Palace in Jan.

  53. @euan \About LCR yes it is my view that LCR has suffered because of poor development over the years – Lea Bridge Roundabout being the most obvious.”Whilst I think opinion on that roundabout is uniformly critical I think we shouldn’t pretend that it is that which is the cause for LCR’s run-down commercial streets. What is the central influencing factor is the fact that Hackney in general Clapton in particular has in the recent past been home to a very large number of poor people. In addition not so long ago the council was disfunctional and verging bankrupcy. It is the influx of a huge number of more affluent people and the shake-up that the council has undergone that has been the most defining transformers in Hackney’s fortunes. I know planners like to think they’re gods but really what happens here and elsewhere is mostly down to who lives here. I think LCR’s commercial future is a rosey one simply because of this. I just wonder how that process can be sped up and given that I believe the “Murder Mile” tag has been a significant deterrent to new business setting up here whether a traders association would be a good means of getting the word out of LCR’s huge potential to new investors?”

  54. Clapton is one of the last pockets of this part of inner London that hasnt been gentrified, but, thanks at least in part to the fact that other parts of East London have gone through that process, it has in my opinion certainly reached the level of critical mass necessary to support that process. What’s needed – what in fact is already happening – is to see just one anchor restaurant/ retail outlet/ pub do well, which will spur others to follow. As members of the community, its in our interest to support those taking that risk now. Even if it is a chain, or business that you morally object to, or because you prefer brick to more modern building materials. I think CPNAG have clearly done a magnificent job of improving the pond, and that’s to everyone’s benefit. I worry however that the current constitution of the group may be a wee bit nimbyist given their objection to this proposal. To dilute that I’d suggest that more people attend the meetings, as I still think it is probably the best forum we have for actually getting our voices heard as a community.

  55. @gavinredknap Regarding the CGI: I don’t know how to post it here, but I could forward you the CPNAG email which contains it if I had your email address.

  56. I’ve spoken with an architect friend of mine and asked him how much he reckoned a developer would have to fork out to get a proposal such as this through the planning process. He said about £100,000 on architects/surveyors/consultants and a further sum of around £100,000 to the council for something called an S106. Now, if we’re all agreed that Clapton Pond/LCR is in dire need of investment, ask yourself would you gamble that kind of money – in an uncertain property market – on a proposal with the knowledge that you’re going to have to confront an aggressive opposition group? Personally, I wouldn’t. I’d look for an area more conducive to development. If CPNAG et al truly have the neighbourhood’s interests at heart, I would recommend that they cease in their reckless opposition to change.

  57. \Hackney Council are planning to sell this site despite the hard work of Clapton residents to secure a lease last year.Public toilets are essential to our local economy and our public health. We plan to refurbish the toilets and make them fit for use once again with an events space and licensed bar in the gents.” https://www.change.org/petitions/don-t-sell-our-public-toilets

  58. @ewebberI think you’ve posted that on the wrong thread

  59. Well the Planning Inspectorate has refused permission;http://www.pcs.planningportal.gov.uk/pcsportal/fscdav/READONLY?OBJ=COO.2036.300.12.4715300&NAME=/2176342%20&%202171673%20DECISION.pdfThe good news (to my mind at least) is that they were quite praising of the design aesthetically but they took issue with the small size of some of the accommodation. Hopefully the developer will do a quick redesign of the interior (perhaps with one less apartment) and resubmit.”

  60. Hi there, I was recently told that there was still an opportunity to put forward an idea for this space and am wondering how I would do this? I am a chef/baker living n Clapton. I run a supperclub here and work for E5 Bakehouse in London Fields too. I have been searching for the ‘right’ location in Clapton to open a bakery cafe for over a year now. Please can someone advise!! kindest regards Ian07887493882ballantyne.ian@gmail.com

  61. Looks like this has come back around again with a new applicant:http://nearme.at/param=194721&type=PNot a great deal of detail available right now Application Number: 2013/1222Current Status: REGISTEREDProposal: Demolition of existing redundant WC block on the corner of Millfields Road and Mildenhall Road and erection of a 4 storey building to provide 8 residential units (2x 1 bed 5x 2 bed and 1x 3 bed) with A1 A2 A3 B1 & D1 use on the ground floor and basement (Opening times: 08:00 – 22:00 daily)Site address: Redundant WC Block Millfields Road Leabridge E5 0RUApplicant: Mr Alex DavisComments until: 06-05-2013Date registered: 15-04-2013Proposed land use: UnknownCase officer: Evie Learman 0208 356 8245″

  62. @ianballantyne you may be able to find the owner through these details

  63. The new application has two entries for some reason. The other number is 2013/0492 and here’s the Design & Access Statement. I’ve only had a quick look but it appears to be basically the same design only with a slight re-configuring of the internals to address the concerns of the Planning Inspectorate over room sizes.”

  64. "former toilet"Well it was finally granted permission last week.A good decision in my opinion.”Sad day for Clapton Pond area” according to CPNAG.”

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