A review of the extant planning consent concluded that B8 storage and distribution was a lawful use for the site. An exercise was undertaken to establish the maximum traffic generation that the extant consents were capable of generating. Mayer Brown argued that B8 trade retail would be an appropriate lawful use for the site, which would also have a significantly higher traffic generation than the proposed residential and office scheme.
A traffic generation and traffic impact case was prepared that concluded the proposed development would not intensify vehicular traffic movements through the problematic junction when compared to the maximum trip generation that could be associated with the extant lawful uses.
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