Regeneration - Communities and Local Government Committee Contents


Written evidence submitted by Leeds City Region

The Leeds City Region is the single largest functional economy outside of London, with a £52 billion economy, generating 5% of the nation's GVA economic growth. The City Region has over 103,000 businesses and a resident workforce of approximately 1.4 million people, and covers the districts of Barnsley, Bradford, Calderdale, Craven, Harrogate, Kirklees, Leeds, Selby, Wakefield, and York.

The diverse geography and nature of the City Region does though present a multitude of regeneration needs and challenges both in urban and rural areas, and city and town centres. The city region includes both economically prosperous areas alongside areas in need of long term regeneration and renewal, which is reflected in City Region strategies and investment plans.

Collaboration between authorities in liaison with the private sector and other partners at the city region level over the past five years has been critical in ensuring a coordinated approach to effective planning, infrastructure alignment, delivery capacity, and links to employment growth. Regeneration remains a key strategic priority for the city region and the emerging Local Enterprise Partnership, and there are significant concerns about how the city region can maintain momentum in the face of significant reductions in core regeneration and renewal funding. We are at a critical stage, and the City Region is responding by exploring and piloting new collaborative approaches to respond to the changing fiscal and policy environments, including seeking to maximise the benefits presented by potential new opportunities such as the New Homes Bonus, Tax Increment Financing / Enterprise Zones, and Asset Backed Vehicles.

Our response to Committee's specific questions are set out in the attached Appendix 1, which is submitted as evidence to support the Inquiry. Due to the importance of regeneration to the city region in terms of supporting economic growth and social and environmental enhancement, we would welcome the opportunity to appear at the Inquiry to share our views and experiences directly with the Committee.

March 2011

APPENDIX 1

SUMMARY OF KEY POINTS

—  We would advocate an approach to regeneration of "thinking big, but acting locally". Regeneration and renewal requires a package of locally tailored interventions addressing job creation, liveability and viability issues together in a holistic manner.

—  The city region is diverse and incorporates areas of strong economic growth and areas of deprivation and regeneration need. Significant progress has been made in completely restructuring regeneration areas, although some considerable needs remain.

—  Locations with significant impacts on wider economic growth such as town and city centres, and areas continuing to undergo major structural change will continue to require substantial public funding to support their regeneration. Elsewhere, smaller scale locally tailored interventions tackling root causes rather than symptoms of deprivation and vulnerability will be appropriate approach, with some support funding.

—  The quality of the urban environment still presents a barrier to both investment and an attractive residential offer, and this will inevitably need public sector capital to resolve.

—  Long term secured public funding will continue to be required to address market failure to enable the necessary long term planning and support major structural change, but this is increasingly uncertain due to significant reductions in capital and mainstream regeneration related funding. Eg, in the apparent absence of an alternative, sufficient public funding for major town and city centre regeneration will rely on substantial RGF funding.

—  Gap funding is not needed for all regeneration activity. In many areas the focus now needs to be building market capacity through targeted interventions and catalyst projects.

—  The Government's new incentive initiatives such as the New Homes Bonus, Regional Growth Fund, and Affordable Rent, present opportunities to support regeneration activity, but needs will far outweigh available resources, and these market-based approaches are unlikely to provide the necessary support in areas of greatest need.

—  In the slow growth economy, it is unlikely that significant private sector investment will be attracted to support regeneration. New approaches such as Asset Backed Vehicles, Tax Increment Financing and Enterprise Zones could provide solutions to lever in significant private resources and secure long-term sustainable investment, but will require freedoms and flexibilities from Government; eg in relation to the use of former RDA assets.

—  There is little evidence that the government's approach of reducing perceived obstacles to investment, such as "bureaucracy", "planning rules" will have a positive impact in the more challenging areas.

—  The Government's emerging delivery approach on skills and employability, inward investment and business support (single national contracts; delivery agencies rather than policy makers determining priorities) is likely to make a coordinated approach to regeneration at the local level more difficult. A strengthening of the "duty to cooperate" powers to apply to all relevant agencies and partners would help alleviate this barrier.

—  The City Region is being proactive in liaison with DCLG. DECC and HCA to explore and pilot new innovative ways to maintain momentum in tackling regeneration, utilising both local public and private sector resources, and the opportunities created by the new national incentive and support initiatives.

Q1.  How effective is the Government's approach to regeneration likely to be? What benefits is the new approach likely to bring?

1.  Tackling regeneration is complex, requires a holistic and multifaceted approach and long term perspective and commitment, particularly if there is a need to completely restructure communities and areas. Although the Leeds City Region is the largest economy in the country outside London and is continuing to experience economic growth and increased prosperity, the city region is diverse and incorporates areas of significant deprivation and regeneration need, particularly in areas still recovering from the previous decline in the coal and manufacturing industries.

2.  Although, significant progress has been made over the past 30 years, some of these areas remain characterised as "run-down" due to a combination of, for example, poor quality housing and neighbourhoods; poor accessibility to good quality schools, amenities and services; a prevalence of negative social issues such as drug abuse and disconnected families; and probably, most importantly, a lack of employment opportunities. These circumstances often lead to a downward spiral of disadvantage and vulnerability for local people in these areas, as well as poor quality environments and conditions.

3.  No single measure can address all these failings in an effective way; For example, improving housing and the environment can have a substantial impact on quality of life, health and mental well-being and help attract new investment into an area, but would not directly affect the (often poor) underlying economic circumstances of individuals. Regeneration, therefore requires a range of interventions that tackle a number of issues in a holistic and complementary manner. The necessary package of interventions will be different in different areas and circumstances and, therefore, in principle a local/neighbourhood approach offers the most effective opportunity for success.

4.  It is recognised that the fiscal environment in the short to medium term is very challenging and the days of major capital interventions in regeneration areas are unlikely to return, at least for some time. The quality of the urban environment still presents a barrier to investment and to creating attractive residential offers, and this will inevitably need public sector capital to resolve. However, although some areas that require major physical change will still require significant levels of capital investment, effective regeneration can in many areas be achieved through smaller scale targeted local/neighbourhood revenue intensive interventions, particularly focussed on improving the underlying causes that affect local people's life chances; supported by a modest level of capital investment for housing and environmental improvements:

CASE STUDY: HOLBECK, LEEDS

Holbeck in Leeds is a mixed community of postwar social housing and pre 1919 back to back terraces close to the city centre and the Holbeck Urban Village regeneration area. Whilst the social housing stock is in line for a major PFI renewal scheme, the terraced neighbourhood has been the subject of a recent partial clearance programme and suffers from a poor quality environment and high levels of deprivation. If this neighbourhood could be improved alongside the social housing stock then a critical mass of sustainable urban regeneration could be achieved linking together the residential neighbourhoods of Holbeck through the urban village to the city centre.

There is little likelihood of significant capital funding in the foreseeable future to regenerate the terraced neighbourhood, so an alternative strategy is being developed to build a partnership with the community to deliver a programme of neighbourhood improvement.

This will involve a phased set of actions and community development work to gain community confidence, deliver sustainable environmental improvements and improved community safety and move on to create community assets, including new green space and social facilities. A key part of this work will be the deployment of experienced family intervention workers as the core of a community regeneration team delivering support to problem families to reduce anti-social behaviour and worklessness. The desired outcomes are:

—  a sustainable and stable neighbourhood;

—  owner-occupier and landlord investment in property improvement and maintenance;

—  small scale inward investment in local retail and service activity; and

—  an increase in property values.

When the community has developed its ideas and priorities for neighbourhood improvement a modest grant to pump-prime a neighbourhood renewal fund built on community fundraising and attracting support in cash and in kind from business, would be a major boost for local confidence and an important step towards a self-sustaining process of community regeneration. Small scale neighbourhood level regeneration of this kind is the way forward at this time in this and other similar areas. Whilst government funding for regeneration is being significantly reduced, a small proportion of the funding the Government intends to invest in regional development could be used very productively supporting grass roots community-led regeneration of this kind.

5.  A major challenge is to ensure that the modest available resources are targeted and phased in the most effective manner. The Government's approach to de-ringfencing funding regimes will be helpful in enabling local authorities and partners to be more responsive to addressing local needs. Though in practice, the significant budgetary pressures currently being experienced will impact on where resources are targeted, which may not be where they were originally intended. Similarly, although some of the Government's new incentive initiatives such as the New Homes Bonus and Regional Growth Fund present additional funding opportunities, there are significant concerns that needs will far outweigh available resources; that expectations have been raised nationally that they will be the solution for almost anything and everything; and in practice due to the scale of available resources they are likely to only have a limited impact overall, particularly in the North where regeneration needs are most prevalent.

6.  The coordination of activity and pooling of resources locally from local authorities, the Police, education and skills providers, and Government agencies is essential to maximise regeneration outcomes. In this respect, the Government's approach to decentralisation is welcomed to a degree. However, in practice, it is often difficult to secure the full commitment of some of these bodies to long-term strategies and priorities due to their narrowly focussed responsibilities. Furthermore, the Government's emerging delivery approach on skills and employability, inward investment and business support (single national contracts; delivery agencies rather than policy makers determining priorities for investment; no local leverage) is likely to make a coordinated approach to regeneration at the local level more difficult. A strengthening of the 'duty to cooperate' powers to apply to all relevant agencies and partners would help alleviate this barrier.

7.  Regeneration and renewal remains a key priority for the Leeds City Region Partnership/emerging Local Enterprise Partnership - for example, in terms of the private sector housing stock, there are estimated[82] to be around 280,000 non-decent private sector homes in West Yorkshire alone, 78,000 of which were inhabited by vulnerable households. Within this stock there are around 45,000 back-to-back properties, of which up to 50% fail the decent homes standards. The areas in which this stock is located have a strong correlation with concentrations of poor health, and many are within the top 10% of the most deprived areas of the country.

8.  Addressing these and wider regeneration needs will be increasingly challenging due to the massive capital reductions in regeneration related funding in the city region due to the ending of RDA funding (circa £300 million pa), Housing Market Renewal pathfinder funding (circa £4 million pa), private sector housing renewal funding (circa £25 million pa), as well as reductions in HCA funding and mainstream funding to local authorities; mainstream funding has always played a significant role in supporting regeneration activity. Similarly, it is uncertain as to the Government's view on the continued use of the Private Finance Initiative, which has been successful in attracting significant private investment for regeneration schemes, but which if continued, is likely to be smaller scale and in a different form due to changes in financial regulations.

9.  Together with the wider public sector job cuts, which are likely to have a significant and disproportionate impact on Northern areas, there is likely to be an even greater need for regeneration activity over the coming years, particularly in relation to job creation and labour market accessibility, and "place making".

10.  The City Region is keen to develop and pilot new innovative ways to maintain momentum in tackling regeneration, utilising both local public and private sector resources, and the opportunities created by the new national incentive and support initiatives. We are currently working alongside DCLG, DECC and the HCA to explore new innovative ways for continuing private sector housing and neighbourhood renewal and delivering the Government's Green Deal, including investigating the potential of new opportunities presented by, for example, Affordable Rents, New Homes Bonus and the Community Infrastructure Levy.

11.  However, these new funding initiatives by their nature, work against areas in greatest need. Furthermore, there is little evidence that the government's approach of reducing perceived obstacles to investment, such as "bureaucracy", "planning rules" will have a positive impact in the more challenging areas. Indeed it is important that authorities have the powers and resources to set high aspirations for the quality of development in these areas.

12.  The City Region has been in the vanguard of developing proposals around Accelerated Development Zones/Enterprise Zones and Tax Increment Financing, which we are keen to pilot in the city region. We have also made significant progress in developing proposals around a city region LEP based Asset Backed Vehicle (ABV), which could incorporate public sector assets such as local authority and former RDA land, to lever in European and private sector investment and form a long-term sustainable self-financing development and regeneration delivery vehicle. We therefore welcome the Government's proposals in relation to TIF, retention locally of business rates, and the potential use of RDA and HCA assets, which would allow the city region LEP and partners to pool significant resources to maximise regeneration and local economic impacts.

13.  Importantly, regeneration does not need gap funding for everything and the focus going forward needs to be on building market capacity through targeted interventions and catalyst projects. Developing mechanisms to secure sustainable long-term funding needs to be a priority, recycling funding such as through an ABV and utilising, for example, business rates where the commercial case is strong. Gap funding should therefore be much more targeted to provide upfront support to unlock the greater potential of regeneration areas. The difficultly though will remain the need to meet the twin aims of supporting regeneration in both growth and less prosperous areas. A fair and equitable society and the need to maximise overall economic growth demands actions to tackle both.

Q2. In particular:

(a)  Will it ensure that the progress made by past regeneration projects is not lost and can, where appropriate, be built on?
(b)  Will it ensure that sufficient public funds are made available for future town and city regeneration projects as well as for more localised project?

14.  Regeneration areas tend to be by their nature located in areas where market failure exists and public sector investment and intervention is required to bridge the gap where the market will not provide. In some of the larger areas such as the Green Corridor in the city region, situated in former coalfield areas where major structural change has been necessary, significant time and resources have been invested over the past 10-20 years to completely restructure these areas. Significant progress has been made, but the considerable reduction in public sector capital now available for renewal and regeneration is seriously jeopardising the completion of these long term projects, and the progress made is in grave danger of being lost due to a lack of a guaranteed funding source.

15.   It is recognised that the Regional Growth Fund (RGF), New Homes Bonus and Community Infrastructure Levy, for example, could offer opportunities, but due to competing budgetary pressures/national competition, it is unlikely that the necessary levels of capital will be available for completing these transitional schemes and enabling them to once again fully contribute to economic growth and prosperity. The RGF is, in principle, a potential major funding source that could make a significant contribution, but the criteria for funding focussed, for example, on direct private sector job creation, makes it challenging to build a strong business case for the funding for regeneration and renewal projects and programmes. In the slow growth economy that we will likely experience in the short-medium term, it is highly unlikely that significant private sector investment will be attracted to fill the gap in these major regeneration areas.

16.  In regeneration areas that have completed major structural change and areas where the needs are less extensive or severe, including rural pockets of deprivation and those within more prosperous wider market areas, the Government's new initiatives may support much of the smaller scale local interventions that may be sufficient to tackle the regeneration needs. However, even in these areas, it will be important that a modest level of direct funding from Government for regeneration is available to plug any small scale funding gaps that may arise.

17.  The lifeblood and economic and social drivers of towns and cities are their centres. Where major town and city centre regeneration need is identified, it is critical, particularly where market viability is marginal, that such regeneration is undertaken as a matter of urgency. In the Leeds City Region, the centres of Bradford and Barnsley fall into this category, and their potential to act as catalysts to accelerate city region economic growth and prosperity is recognised. However, although plans are well advanced in these areas, and up until the recent recession, packages of public and private resources were in place or being negotiated, the significant reduction in capital funding, including RDA funding, has left these critical economic projects in a state of hiatus.

18.  Private sector investment has similarly been reviewed in the light of the economic climate, increasing the potential burden on public investment and intervention. Currently, the only direct source of significant funding for major town and city regeneration projects appears to be the RGF, although Round 1 bids were more than 10 times over subscribed. Also, as mentioned previously, it remains to be seen whether larger scale regeneration schemes will provide the employment and leverage outputs that are sought by Government from this fund.

CASE STUDY: BRADFORD CITY CENTRE CENTRAL BUSINESS DISTRICT (BCBD)

The BCBD was submitted through the Leeds City Region for Regional Growth Fund Round 1 funding. It is essentially looking to rebalance the city's economy and build on a great entrepreneurial culture and great businesses in growing sectors. Bradford needs more great businesses and it needs its existing business to grow and thrive in the UK and beyond. In particular it needs to address the uncompetitive and unattractive City Centre that is a result of 20th Century industrial decline and lack of investment. A new Central Business District and revitalised retail offer through the Westfield Shopping Centre development are essential elements in building Bradford's economy. These two projects build on investment of more than £3 million in key streets that connect the City along with a £24 million investment in Bradford's City Park to act as an enabler to private investment in the CBD and other key developments. Through a critical mass and high quality delivery right in the heart of the City, the projects will create transformational change for businesses, investors and Bradford citizens.

Bradford City Centre is well placed to unlock the development of a number of strategic sites once initial funding can be secured to provide a development platform in facilitating the BCBD. We anticipate that later sites would not require any public sector intervention as the critical mass in the centre would be established through targeted interventions in BCBD and Westfield. The provision of 500,000 sq ft of retail space by Westfield and the availability of the BCBD will facilitate circa 5,000 new jobs and substantially increase city centre footfall leading to wider regeneration and investment in the city centre. The impact of prioritising two catalyst projects will then have the ability to change the whole perception of the Bradford city centre and its wider the district.

The delivery of these projects will be overseen by the City Centre Delivery Group, Chaired by the Chief Executive of Morrison's and comprising CEO level membership of three leading PLC's, along with the CEO and Leaders of the three main parties in the Council. There is wide private sector support for the approach which builds on approximately £300m worth of investment already made in the city centre. This has included investment from both London based developers like Welbeck Land and also investment based in the Middle East. But clearly focus on the targeted projects and their combined effect will radically improve investor confidence, improve development viability and raise land and property values in the city centre in particular.

19.  The TIF and local business rate retention initiatives may provide potential funding sources in the medium term, although these rely on a successful and growing economy and business base. These models will therefore not generate sufficient funds to be reinvested in regeneration where there are weak markets areas. The current city region proposals for an Asset Backed Vehicle may provide a potential secure funding source through recycling investment, but this is some years off at the moment, and town and city centre regeneration is required now to contribute to the much needed acceleration in economic growth and prosperity.

20.  In the current absence of any alternatives of any scale, unless significant RGF funding is made available for key major town and city centre regeneration schemes in areas where market viability is marginal, sufficient public funds will not be available for major town and city regeneration projects.

Q3.  What lessons should be learnt from past and existing regeneration projects to apply to the Government's new approach?

21.  We would advocate an approach to regeneration of "thinking big, but acting locally". High ambitions and commitment are required to truly achieve a transformation, but this requires dedicated and locally tailored solutions.

22.  As discussed previously there is a continuing need for major regeneration efforts and resources in priority locations such as town and city centres and areas of major structural change. Regeneration in areas elsewhere in the city region could be achieved through smaller scale locally tailored interventions that tackle root causes rather than symptoms of deprivation and vulnerability. There have been examples in the past where this has not occurred due to a focus on short term physical improvement rather than long term social improvement. This has provided short term remediation but has meant that some of these same areas have returned to a state of need some years later. This has often been perpetuated from national Government through physical regeneration based initiatives such as City Challenge and to a lesser extent the Single Regeneration Budget.

23.  The principles of the HMR Pathfinders and New Deal for Communities which sought to provide a secure funding stream over 10 years and beyond were more realistic in recognising that effective regeneration is not a short term activity. Similarly, the principles of the PFI scheme to attract significant additional private sector investment should continue to be a key ambition for the public sector, although future or replacement schemes should not require millions of pounds to be spent upfront on procurement.

24.  Going forward, a key factor for any regeneration scheme is to have a guaranteed long-term funding source that enables the necessary long term planning to be put in place, irrespective of the scale of the resources needed. There are opportunities through the Government's proposed funding and incentive initiatives. However, due to uncertainties over budgets and priorities and some being both subject to a competitive process and likely to be significantly oversubscribed, this certainty is not being provided at the current time. This uncertainty is already also hampering efforts to secure complementary funding, including from the private sector.

25.  It is critical that regeneration strategies and initiatives are not left uncompleted. This can lead to Blight and further disadvantage for local communities, such as in terms of land laying underused and homes boarded up.

CASE STUDY: GREEN CORRIDOR HOUSING MARKET RENEWAL

The Green Corridor alliance was established by Barnsley, Doncaster and Wakefield councils in 2003 to promote the regeneration of former coalfield areas in the three districts. Its primary focus has been housing renewal - six neighbourhoods experienced complete housing market collapse during the late 1990s, with up to 60% of properties falling vacant in some areas, concentrations of poor quality renting, and associated problems of crime arson and anti-social behaviour. Many other neighbourhoods were also showing signs of vulnerability at that time.

The priority was to deal with the crisis areas through clearance, enabling the remaining residents to relocate into areas of their choice. Over the last decade all but one of the areas has been purchased by agreement and cleared. Without external capital funding through government Private Sector Renewal funding and the Housing Market Renewal programme this could not have been achieved.

New mixed-market housing has already transformed Grimethorpe, bringing in higher income residents to stimulate the local economy. The remaining areas will be redeveloped as the market recovers. However, the cessation of the Housing Market Renewal Programme leaves uncertainty about how to fund critical work to bring sites forward and stimulate market engagement. This has put forward as a Round 1 bid for the Regional Growth Fund.

In other vulnerable areas, the focus of the programme has been holistic neighbourhood renewal to target worklessness interventions, tackle substance misuse, address crime and anti-social behaviour, and improve housing conditions. This has required significant and sustained officer resources.

Although the areas in crisis have been successfully addressed., the wider economic and environmental deficits require continued intervention; for example, achieving a competitive workforce, improving town centre environments, attracting new businesses, supporting marginal home owners, improving private rented housing.

26.  It is important going forward to embed a true culture of sustainability within regeneration strategies and interventions. Adopting more holistic package approaches to tackling regeneration such as has been tried and tested in other parts of Western Europe, including addressing design, job creation, liveability and viability issues together, if outcomes are to be maximised.

27.  In many areas, the focus needs to be on addressing social regeneration needs - providing specialist intervention to truly working with local residents, local businesses, and community groups. This will help identify underlying problems and the necessary targeted interventions, particularly in relation to families (eg tackling anti-social behaviour, homelessness, drug and alcohol addiction) and job creation (eg long-term unemployment, access to jobs, local business support), which tend to be the root causes of deprivation and neighbourhood problems. The Family Intervention Services and other socially targeted initiatives such as the Leeds Local Inclusion Lab proposal to address the needs of adults with multiple disadvantage, provide such services in the more deprived areas of the city region critical to tackling these fundamental causes of regeneration need. These initiatives though are labour intensive and require revenue support.

28.  An important initial objective should be to secure a degree of stability in regeneration areas. This often requires improving law and order first within communities to help improve the confidence of residents in their area and be the pre-requisite for attracting further investment. Working closely with families and local businesses, and undertaking capital improvements to housing and neighbourhoods will complement these activities, helping to improve quality of life and further assist in generating investor interest. As a principle, it is essential to generate stable social environments as a pre-requisite to ensuring that capital investment will maximise its impact and help create long-term sustainable quality neighbourhoods.

29.  As we are exploring on a number of levels in the Leeds City Region, there is a need to explore innovative new solutions to integrating public service delivery (including eg health and police resources), accessing a range of funding opportunities, pooling these resources (eg as in the Community Budgets pilots), and rigorously prioritising and phasing interventions that maximise both the delivery of required outputs and the value for money of public resources.

Q4.  What action should the Government be taking to attract money from (a) public and (b) private sources into regeneration schemes?

30.  As we are already undertaking in the Leeds City Region, the public sector will need to rethink its approach to regeneration, not necessarily lowering long-term ambitions, but recognising the realities of the market and public support, and seeking new innovative solutions to long-term problems. Expensive and intensive property and land assembly schemes are unlikely to occur on any scale, but as discussed above, the economic importance of towns and city centres and areas still undergoing major structural change, need to be recognised as priorities for major public investment.

31.  New models such as the ABV approach, Enterprise Zones, TIF and retention of business rates appear to present viable opportunities to secure long-long term sustainable investment. Importantly, though it is unlikely that a one-size-fits-all approach will be appropriate throughout the country, and Government should therefore welcome local areas and Local Enterprise Partnerships such as in the Leeds City Region, bringing forward locally based solutions to regeneration and renewal challenges. Government should be supportive of proposals for devolution or freedoms and flexibilities that are identified to enable such approaches to work effectively - one example of this in the city region is for Government to allow former RDA assets to be incorporated within the proposed ABV to help lever in significant additional European and private sector investment, which would likely reap much greater long-term sustainable financial and regeneration benefits than would simply selling them off.

32.  It is difficult to attract private sector investors into regeneration areas as these areas tend to result from systematic market failure of some description. Policies incentivising the development of brownfield sites, and/or underwriting the risk could help to persuade businesses to invest in such regeneration areas. In stronger economic areas though, with the right strategy in the right locations, targeted interventions could be the catalyst for improving commercial viability that would be sufficient to lever in additional private sector investment for regeneration and renewal.

Q5.  How should the success of the Government's approach be assessed in future?

33.  As noted regeneration is complex and takes time to achieve sustainable results, so assessing and measuring success is difficult. Measures such as levels of employment, unemployment, homelessness, fuel poverty, drug and alcohol abuse land brought back into use, and private sector leverage could provide useful indications of the direction of travel in the short to medium term. The appropriate measures may be different in different areas depending on the nature of regeneration needs.

34.  Over a longer period, the long term impacts of regeneration activity will need to encompass the effects on levels of multiple deprivation, economic growth and prosperity, and whether areas have truly experienced structural change. Qualitative measures will be just as important and quantitative measures in assessing the long term impacts.



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